There will be no new construction and no land acquisition as part of IFC’s investment. The terminal is located inside a port and industrial zone.  Therefore, PS5: Land Acquisition and Involuntary Resettlement, PS6: Conservation and Sustainable Management of Living Resources, PS: 7 Indigenous Peoples, and PS8: Cultural Heritage are not considered to be applicable to the project.                                                 

   Sonker’s terminal is inside a port complex and an industrial area. There is no manufacturing process onsite; therefore, air emissions, wastewater discharges, and waste generation are all limited. The liquid chemicals are transferred to and from the terminal through an underground pipeline system. The nearest community is approximately 3 km away, which is unlikely to be impacted by the operations at Sonker’s terminal.

Mitigation measures for the potential E&S risks and impacts as part of this investment have been identified and are incorporated into an Environmental and Social Action Plan (ESAP). The potential adverse E&S impacts of this project are considered few in number, of limited significance and readily mitigated through the Company’s existing systems and procedures. This is therefore a Category B project according to IFC’s Policy on Environmental and Social Sustainability   

 Environmental and Social Assessment and Management System

Sonker hired external experts to conduct E&S risk assessments for past projects according to Egyptian laws/regulations. With IFC’s previous investments, additional risk assessments were conducted to meet IFC Performance Standards (PS) and WBG EHS Guidelines. During the construction period and implementation of E&S requirements from IFC’s previous investment, Sonker developed and implemented the E&S management systems that incorporate the existing procedures and are consistent with the IFC Performance Standards. These systems include management procedures, monitoring plans and key performance indicators (KPIs) and reporting requirements. The operations are audited by external experts periodically. With the completion of construction in 2020, Sonker started to strengthen its E&S management system for the operations phases and received Bureau Veritas certification of ISO 9000 (quality), ISO 14001 (management), and ISO 45001 (OHS) on 15 February 2022. 

Policy

Sonker has developed a set of EHS policies, which include the EHS/security policy, with the objective to promote the highest practicable standards of health, safety, security, and environment management to be compliant with both Egyptian laws/regulations and IFC PS and to meet the requirements of good international industry practices (GIIP). Sonker’s E&S policy is implemented though its environmental, OHS, and safety procedures, which include well-designed KPIs to evaluate and improve E&S performances.  Sonker will update its Human Resources Policy to include provisions for non-discrimination and equal opportunity, child labor, forced labor, freedom of association and Sexual Harassment in line with IFC PS 2 as per ESAP # 2.

Identification of Risks and Impacts

E&S risks for any new projects are initially identified and mitigated during preparation phases through Sonker’s internal procedures for labor, environmental, OHS, and security risk identification. External E&S consultants are also hired to conduct the needed assessments. During operational phases, EHS risks are identified through formalized auditing programs and informal frequent inspections. All audits and inspections are summarized with corrective actions to mitigate the EHS risks and impacts. Sonker has an Environmental Aspect and Impact Mitigation Program, which requires hazard and operability study (HAZOP) / HAZOP updates, quantitative risk assessment (QRA), and job hazard analysis (JHA) to identify operation safety risk and develop mitigations.

Organizational Capacity / Competency

Sonker terminal has an EHS and security (EHSS) unit, which leads the EHSS works with 21 fulltime employees, including environmental engineers, safety engineers, firefighters, and security officers, etc. The EHSS unit head reports directly to the terminal manager. The EHSS team manage the daily EHSS operations according to its policies, programs, and procedures. The EHSS team is also responsible for educating, training and motivating employees to understand and comply with EHS performance procedures and the EHS management systems have been set up to monitor and support the works at the terminal.

Management Programs

Sonker’s EHS management system is well developed and includes detailed technical standards, standard operating procedures (SOPs) and work instructions, internal codes for EHS performance, and an extensive inspection/audit program. Systematic monitoring of environmental performance and process safety measures is in place for air emissions, wastewater/solid waste management, occupational health/safety tracking, and process safety management. Non-conformities to the technical standards are monitored and extensively followed up by the technical teams and management.

Emergency Preparedness and Response

Sonker keeps an updated version of its emergency response (ER) plan, which details all the ER scenarios and response methods. The locations for toxic gas sensors and automatic fire detectors were decided through 3-D mapping of the entire terminal and its installations. All the detectors are connected to the control room. The detector/alarm system can automatically trigger emergency responses, including sprinkler cooling, firefighting, emergency shutdown, etc.

There is sufficient firefighting equipment and firefighting water/foams onsite, which are all properly maintained. Automatic sprinkler systems are installed for storage tanks. Sonker has its own dedicated firefighting team with a fire truck, an ambulance, and other necessary equipment. Sonker conducts bimonthly ER drills and annual joint ER drill with other facilities coordinated by Sokhna Port. During the joint drills, Sokhna Port Authority also works with Sonker for marine spill prevention and cleanup.

Monitoring and Review

Sonker has instituted comprehensive environmental and OHS/process safety monitoring programs, which include wastewater, air emissions, workplace noise levels, waste handlings/disposals, OHS, and process safety. Sonker adopts both lagging and leading KPIs to monitor its EHS performance.  Sonker will include additional monitoring requirements around dissemination of the code of conduct and updates to the grievance procedure around its implementation.

EHSS team conducts daily inspections across the terminal. EGPC, Sonker’s main customer, conducts mandatory annual E&S audits to ensure compliance with project E&S requirements. Sonker also contracts external consultants to review its E&S management system to maintain the needed certifications. Corrective actions are proposed at all inspection/audits with implementation timelines. Implementation of the corrective actions is evaluated following inspection/audits. As part of this project, the external consultant will also conduct operational E&S audits besides management system review as per ESAP #1.                             

  Sonker employs 125 direct employees of which 7% are females mainly occupying administrative positions. Services such as security, maintenance and general, employing a total of 120 staff are contracted out to private service providers.

Human Resources Policies and Procedures:

Sonker has in place a Human Resource (HR) Policy, a set of HR Procedures and Code of Ethics in line with National Law. These include provisions for Recruitment and Selection, Training and Development, Succession Planning, Performance Management, Pension Plans, Promotion Procedures, Transportation, HSSE, General Services, Payroll, Staff Loans and End of Service Benefits, Disciplinary Policy and Procedures, etc. As per the Code of Ethics, Sonker gives workers the right to join any workers associations as long as this does not conflict with national law and governing regulations. The Code of Ethics also states that discrimination based on color, race, belief, religion, orientation, gender and nationality is not part of the company’s culture. However, these requirements together with protection against child and forced labor are not formally part of the HR Policy.

Going forward, Sonker will update its HR Policy to include provisions for non-discrimination and equal opportunity, child labor, forced labor, freedom of association and Sexual Harassment in line with IFC PS2 (ESAP#2). The updated HR Policy and Procedures and Code of Ethics will be readily accessible (e.g. placed on notice boards around in areas where workers gather) and clearly communicated at induction and through the provision of additional sensitization and training.

Working Conditions and Term of Employment:

All Sonker direct employees receive contracts. Contracts are initially valid for one year and, based on the employees’ performance, may be made into an open-ended contract thereafter. They include information on the basic salary, annual performance bonus, social insurance, medical and life insurance, and end of contract benefits. The HR policy also states the working hours, annual leaves, and pre-approved allowance for those who work on shifts basis and overtime. The company also provides transportation to workers to and from Suez. The transportation company is audited regularly by the HSSE department. Covid-19 precautions are all taken on the buses.

Grievance Mechanism

Sonker currently has in place an Internal Grievance Policy and Procedure and associated tiered mechanism for direct employees that allows for workplace concerns to be raised and resolved in a timely manner. Going forward and as part of IFC’s investment, the Internal Grievance Mechanism will be amended to align with PS2. This includes allowing for anonymous grievances to be submitted and resolved and providing all employees, including those on probation and temporary contracts, and third-party workers access to the grievance mechanism. Sonker will also remove the language warning employees of abusing the grievance mechanism.  (ESAP#3)

Occupational Health and Safety

Sonker has developed OHS programs and procedures to manage OHS risks from its operations. JHA is conducted for each position and OHS procedures are prepared per JHA results for each position to prevent incidents and accidents. Moreover, as described earlier, Sonker has implemented a formal OHS management system compliant with ISO 45001 standards as certified by Bureau Veritas on 15 February 2022..

Sonker has routine OHS training, including new employee/contracted worker training, quarterly safety training, and specialized safety trainings each year. All staff members and onsite contractor workers have daily safety briefing before each shift. EHS engineers organize quarterly safety trainings for all staff members and specialized safety trainings based on specific job requirements every year.

There have been no fatal or serious accidents in Sonker’s construction and operational history. Sonker tracks all recordable accidents and near misses. All accidents are logged and followed by corrective actions. The incidence rates meet industry norms. As indicated in ESAP #4, Sonker will start to monitor workplace and fence line ammonia levels as part of this project.

Workers Engaged by Third Parties

Sonker has minimum contracts with Security, Catering and Transport services. The contracts include a commitment to align with the national law in hiring and payment of workers. They do not refer to the company’s Grievance Mechanism or the right for Sonker to audit their third-party workers. In practice, Sonker reported only auditing of the transportation company. Going forward, as required in in ESAP#5, as part of all new contracts, Sonker will require EPC/subtractors to follow IFC PS and WBG EHS Guidelines and put in place the processes and systems as part of its management system to be able to effectively audit its service providers/contractors and subcontractors on regular basis. Sonker will also ensure all third-party workers are provided with formal contracts as per the national law.                                                   

 Resource Efficiency

Sonker’s business activities primarily include loading, unloading, and storage of gasoil, LPG, and ammonia. There are no manufacturing processes and thus resource consumption is very limited. The main resource consumption is electricity, which is supplied from grid and used for cooling, compression, and pumping. Sanitary, cleaning, and firefighting water is sourced from the port authority, while bottled water is used for drinking.

GHG Emissions

Sonker generates very limited amounts of GHG emissions (less than 25,000 ton of CO2 equivalent per year), mainly from electricity consumption and diesel for transportation.

Air Emission, Wastewater and Waste Management

At Sonker terminal, the sanitary wastewater is primarily treated in septic tanks. The treated effluent is then used for onsite gardening and dust controls. The contaminated cleaning water from the tank/pipeline areas is collected and transferred to a licensed wastewater treatment company for transportation and offsite treatment. Five soil monitoring locations across the terminal are being set up to monitor any potential soil contaminations if this occurs.  

Both LPG and ammonia storage tanks have vapor recovery units to recycle the vapors from loading process back to the tanks. The gasoil is a combustible product (not flammable) and the quantity of generated vapors is negligible (API 650 - Hydrocarbon storage tanks construction code is classifying Gasoil storage tanks as atmospheric tanks); therefore, there is no vapor recovery unit for gasoil.

The domestic/ sanitary solid wastes and limited amount of hazardous wastes are collected by different licensed contractors for transportation and offsite disposal.

Hazardous Materials and Operation Hazard

Gasoil, LPG, and ammonia are all hazardous materials. The handling and storage of these materials may pose high risks to employees and nearby facilities alike. Sonker employs a set of tools for operational safety. HAZOP was conducted during the design phase and will be updated whenever any process is modified.

Fire detectors, leak detectors, and toxic gas sensors are installed in all key locations of installations. All these detectors/sensors are connected to the control room together with all other process data. All tank farms have proper bottom and secondary containment structures with sufficient holding capacity in case of leak. According to Sonker’s current maintenance schedules, the integrity test for ammonia, gasoil, and LPG tanks will be conducted every 5, 27, and 30 years, respectively. The gasoil and LPG tanks are equipped with release prevention barriers. Following American Petroleum Institute Standard 653, Sonker will modify the tank maintenance schedule to conduct the integrity tests for gasoil/LPG tanks every 20 years, as indicated in the ESAP #6, 

QRAs were conducted for all storage tanks. In line with the ESAP #7, the QRA will be modified for the impact zones of ammonia under the credible worst-case scenario. Operation and ER procedures will be modified according to the QRA results. JHA are also prepared for all position to handle hazardous materials.                                                   

 Community Health and Safety

The activities surrounding the port are industrial activities with the closest community being a Bedouin settlement located over 6 km to the southwest of the project location, and a tourism resort approximately 3 km north of the project location. The normal operations at the jetty and pipeline will have no impacts on communities.

Emergency Preparedness and Response

In case of the emergency situations, neighboring facilities in Sokhna Port might be impacted. Sonker has mutual aid agreements with the civil protection department, port authority, and other companies in Sokhna Port for emergency responses. This includes chemical leak, spills, fires, explosions, etc.  Annual joint ER drills are also planned by the port authority.

Security Personnel

Sonker has a contract with a security services company employing 47 trained security persons. They operate on rotated shifts basis and are not armed.