Both terminals are in desert area and within designated and well established industrial area, with no residential communities in the vicinity. Trucks transporting fuel are contracted by the local oil marketing companies and are inspected for safety compliance before loading.  The terminal facilities do not employ armed security guards.  Hence, PS 4: Community Health, Safety and Security is not applicable. PS 5 – Land Acquisition and Involuntary Resettlement is not considered applicable since the proposed construction of three additional tanks in Nouakchott terminal, will be within the existing facilities and no new land acquisition is necessary. The ASTs are in an industrial zone, considered modified habitats without significant biodiversity value, with no known historical and/or cultural heritage sites; and the project and its activities will not impact any indigenous people/community. Therefore, PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources, PS7: Indigenous Peoples and PS8: Cultural Heritage, are not applicable. 

Key issues associated with this project include: adequate development and implementation of a comprehensive EHS and social management system; HR management including that of contractors; implementation of occupational health and safety (OHS) measures; adequate management of wastes and emissions; and emergency preparedness and response for fuel storage and handling.

Both petroleum products storage terminals are located within the industrial area and approximately two kilometers from the shoreline. The tank farms have recommended 110% secondary containment systems. The fuel tanks are installed with floating screens and roofs to prevent vapor emissions. Both terminals have established EHS procedures for operations. The potential adverse E&S impacts of this project are therefore limited in number and limited to project sites, and may be readily mitigated. This is therefore an E&S Category B project in accordance with IFC’s Policy on Environmental and Social Sustainability (2012). 

Environmental and Social (E&S) Policy and Management System:

As an oil trading company, Addax mainly purchases the refined petroleum products from the international spot market. Addax follows its parent company, Oryx Energies’, Health, Safety, Security, the Environment and Quality (HSSEQ) policy and has strict internal EHS procedures to review risks when evaluating fuel storage facilities. 

Identification of Risks and Impacts:

Addax‘s environmental and technical risks and impacts identification for its operations focuses on storage and transportation of oil products. For this project, Addax conducted site appraisals for the fuel storage terminals both at Nouakchott and Nouadhibou fuel storage terminals before the bidding process.

Organizational Capacity and Competency:

Both SMHPM and GIP/SNIM have more than 20 years’ experience in management of fuel storage terminals. Each management company has a designated safety coordinator, in charge of various aspects of environment, OHS, and operational safety. The safety coordinators routinely check the firefighting equipment, road tanker safety, tank loading, and road tanker filling operations. Besides routine internal safety checks, both terminal management companies also contract third party experts to inspect tank integrity periodically or carry out major maintenance when required. 

Emergency Preparedness and Response at the Terminals:

Both SMHPM and GIP have fire prevention rules, and emergency preparedness and response plans. Both terminals have appropriate fire prevention and response services, including a 35,000 m3 above ground water tank at each terminal, fitted with high pressure water pumps, which can be powered by onsite diesel generators in case of power failure; firefighting hydrants, alarm systems and foam-based firefighting equipment, which are properly maintained by a third party at regular intervals. The fire prevention and firefighting systems at both terminals were designed and constructed by European contractors. 

As part of emergency preparedness and response plans both SMHPM and GIP conduct regular fire drills.  SMHPM conducts fire drills every month, while GIP conducts fire drills quarterly. 

Monitoring and Review:

External audits are conducted by relevant government departments for compliance on environmental and occupational health and safety. The audit reports, incorporating corrective actions, are submitted to the director of operations for implementation. 

 HR Policy, Working Conditions, and Terms of Employment:

Addax Energy SA  HR policy and procedures are compliant with applicable Swiss labor laws. Addax has no employees in Mauritania. The Mauritania project is handled by a local company - Maghreb oil Ltd. As at appraisal, Maghreb oil had 12 employees at its headquarters in Nouakchott and five in Nouadhibou.  The company has a human resources policy aligned to Mauritania labor laws and the employees have access to the policy.

The management companies have approximately 70 employees at each fuel storage terminals, with majority being male, with only three women employees.  At the Nouakchott terminal, employees adhere to SMHPM HR policy, while in Nouadhibou the GIP/SNIM HR policy is in effect.  Both the management companies are government owned and hence the staff are civil servants. 

Workers’ Organizations and Grievance mechanism:

All the staff are unionized, allowing employees to raise grievances anonymously through the union.  The HR policy has a grievance procedure which articulate how the grievances will be handled and resolved.  The procedure is communicated to all employees as part of induction. 

Occupational Health and Safety: 

There has been no serious accidents or fatalities in the past 10 years in either terminal. Workplace risk assessments and monitoring is performed annually in compliance with the Mauritania OHS regulations.  These OHS audits are undertaken by approved safety and health advisors.  

SMHPM and GIP/SNIM provides all workers with personal protective equipment (PPEs), but lack systems to enforce its compulsory use at all times. Going forward, Addax will work with SMHPM and GIP/SNIM to ensure that both SMHPM and GIP/SNIM strengthen the use of PPE at all times and conduct an annual OHS training to all the staff.  Also as part of this project, SMHPM and GIP/SNIM shall initiate weekly safety talks (toolbox meetings) to reinforce the importance of a strong safety culture, in the workplace – and especially the use of PPE.

During the appraisal site visit, housekeeping at both facilities, except for the jetties was found to be inadequate. Both SMHPM and GIP/SNIM will develop an annual workplan for progressive painting of the tanks to prevent rust.

All the road tankers are inspected for safety before allowing to enter the terminals. The safety inspection includes permits check, exhaust spark prevention, brakes, etc. 

Fuel Storage: 

The Nouakchott terminal was built in 2005 based on EU standards for most of the safety features. SMHPM commissions third party contractors to clean tanks and inspect tank integrity periodically. The last tank cleaning was conducted in 2008 and the last integrity inspection was conducted in early 2012 and another one planned for 2018. 

The Nouadhibou terminal was part of an oil refinery built in 1977 but ceased its refining operations in 2000, when it was converted into ASTs with 268,000 m3 storage capacity. The renovation, which started in 2012 is continuous. Currently, GIP/SNIM only uses 225,000 m3 storage capacity, which is considered safe based on integrity inspection. GIP/SNIM routinely cleans the tanks and inspects the tank integrity. The last integrity inspection was conducted in early 2008.  The jetty was renovated in 2013 benchmarked to EU standards. 

Supply Chain: 

Addax purchases refined energy products on the international spot market. Since Addax’s suppliers are large crude refining companies who do not rely on low labor costs for competitiveness, child or forced labor are not expected to be encountered among Addax Energy suppliers. 

Resource efficiency:

The terminals have two main energy sources; the national grid, and standby diesel generator. Currently, Both SMHPM and GIP/SNIM do not calculate its energy utilization.  Going forward, Addax will ensure SMHPM and GIP/SNIM to collect data on energy utilization and propose measure to ensure energy efficiency at the terminals. 

Greenhouse Gases (GHG) Emissions: 

There is no manufacturing process in this revolving credit facility transaction. Current GHG emissions from the existing operations (based on electricity and fuels) are limited. Additional GHG emissions due to the proposed project is not expected to be significant, and will be well below 25,000 tons of CO2-equivalent per year. 

Pollution Prevention:

Emissions to Air: There are floating screens and roofs for all gasoline and kerosene tanks at Nouakchott and Nouadhibou respectively, to prevent emissions to air of volatile organic compounds (VOCs). There is no other significant air emission source at either terminal.

Coastal Environment Protection: The coastal environment will not be impacted in case of any catastrophes, such as structural failure or earthquake. Both fuel storage terminals are located approximately two kilometers from the shoreline. The loading jetty in Nouakchott was put into operation in April 2012 and the safety design meets current international norms in respect to emergency shutdown, firefighting, and spill prevention features. The jetty in Nouadhibou was renovated in 2013 and was benchmarked according to EU standards. The secondary containment walls are in good condition. 

The oil tankers are required to comply with all applicable environmental standards of International Maritime Organization (IMO). The characteristics of the oil tankers must be certified to the standards by an independent control specialist in the field and approved by the manager of the terminals. Besides the certification, the oil tankers must be less than 20-year old. There are also routine inspections for spill/fire prevention at each jetty during unloading periods, including pipe connections, water pump readiness, fire source inspection, etc. 

The company’s operations are located in the desert and within an industrial area without close proximity to any community, except other users of the industrial park, mostly cement and gas industries.  Both SMHPM and GIP/SNIM (http://www.snim.com/ ) have customer care numbers and websites as part of their external communication strategy.  

  Contact Person: Amaury Barreau

Company Name: Addax Energy SA

Address:  Rue Michel Servet

Email: amaury.barreau@oryxenergies.com

Phone: + 41 22 702 90 55