IFC’s appraisal considered the environmental and social management planning process and documentation for the Project and gaps, if any, between these and IFC’s requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through implementation of these measures, the Project is expected to be designed and operated in accordance with Performance Standards objectives.
PS1: Assessment and Management of Environmental and Social Risks and Impacts
IDMI’s QHSE Manual contains a general description of E&S assessment and management measures although these are not specific to the technology to be used as part of the project, or the project's location in Jordan. Hence, the QHSE Manual needs to be augmented to address project-specific E&S risks and impacts in line with national law and requirements of IFC’s PSs. The HAZOP Report for the new plant contains basic information associated with future sources of operational safety risks, hence the company also needs to augment further HAZOP Report in line with GIIP.
IDMI has started updating its QHSE Manual, which will form part of its corporate Environmental and Social Management System (ESMS), to make it consistent with the principles of IFC PSs when ESAP is implemented. This will require additional E&S assessment on specific topics, and details of the process are provided below.
IDMI has appointed a dedicated E&S Manager. The company seeks to recruit two more HSE professionals with relevant expertise and experience to further strengthen their internal EHS organizational capacity.
IDMI has obtained an Environmental License from the national regulator following the submission of the EIA for the construction and operation of a refining processing facility prepared in line with national law. A review of the EIA indicates certain gaps with the requirements of IFC PS1, including those associated with the provision of worker accommodation, management of contractors, and water use-related resource efficiency measures. As part of the ESAP implementation, the company will address such gaps.
As per ESAP #1, the Client will prepare and implement a Corporate E&S management system (ESMS) in line with the requirements of IFC PSs and WBG EHS General guidelines and develop site-specific Construction Environmental and Social Management Plans (ESMPs) in line with the EIA, IFC PSs, GIIP, and national regulations. These will include, but are not limited to, identifying E&S risks and impacts, and contractor management (in line with IFC’s Good Practice Note: Managing Contractors' Environmental and Social Performance). As per ESAP #2, the ESMPs will be updated before the start of the operational stage, and the Corporate ESMS will continue to be implemented.
IDMI’s QHSE Manual contains an Emergency Response Plan, which includes details of the planned response to a fire, earthquake, intense rainfall/flood, hurricane event, bomb threat, medical illness, off-site emergency, and an oil/chemical spill. Whilst the content is detailed, it does not contain a layout plan, site-specific muster points, or indicate the details or locations of emergency response resources that are to be held at the site such as spill kits. The interface with the JPMC site is also not included. As per ESAP item #3, the Emergency Response Plan (ERP) will be updated, and a draft version will be shared with IFC, JPMC, and authorized government agencies. A joint ERP with JPMC will be finalized before the start of peak construction expected in March 2024.
IDMI’s QHSE Manual includes details of leading and lagging E&S key performance indicators (KPIs) that are intended to be used to monitor the effectiveness of the control measures, and additional KPIs need to be defined. As per the ESAP item #4, IDMI will update its existing suite of monitoring procedures with KPIs for water, electricity, fuel, hazardous and non-hazardous wastes, LTIFR (Lost Time Incident Frequency), and LTISR (Lost Time Incident Severity Rate), near misses, and other topics. The Client will use the KPIs and other relevant information to generate monthly E&S Monitoring Reports during construction and operations.
PS2: Labor and Working Conditions
The peak construction workforce is expected to consist of 200-250 contracted workers, of whom approximately 160 will be the operational workforce and located within the project site accommodation units while others will commute from regional settlements.
IDMI has documented Human Resources (HR) policies and procedures that are compliant with national law, although these do not reflect all IFC PS 2 requirements including specific controls associated with gender-based violence, harassment in the workforce, activities to help manage relationships between workers and senior management, retrenchment, and controls on supply chain workers. IDMI does not prohibit the freedom of workers to associate and form/join a workers’ organization. Each worker receives a written contract that describes the working conditions and terms of employment. The company policies encourage equal opportunity for its direct workers and contract workers. IDMI’s HR policies prohibit the use of child, forced or bonded labor.
As per ESAP item #5, IDMI’s HR policy and procedures will be updated to be consistent with the requirements of IFC’s PS2. A template employment contract was developed and will be updated, and an employee handbook will be prepared to provide details to workers of their terms and conditions, benefits and entitlements, details of a retrenchment procedure, and other information. Standard working hours will not exceed 8 hours per day and 48 hours per week in accordance with national labor law. All employees will be enrolled in a mandatory social insurance scheme and be provided with an annual medical check-up to ensure that they are fit to work in a remote setting. IDMI will also establish a worker grievance mechanism in line with the national law and requirements of IFC PS2, allow submission of anonymous grievances, and make this available to the EPC contractors’ workforce.
As per ESAP Item #6, IDMI will conduct regular quarterly audits of the EPC Contractor’s compliance with applicable national law and legally binding contract clauses that reflect PS2 requirements.
A certain number of IDMI workers that have been accommodated at JPMC’s facility have recently moved to newly furnished accommodation unit constructed by IDMI. As per ESAP item #1, all worker accommodation units will be constructed and operated in accordance with Workers’ Accommodation: processes and standards, A Guidance Note by IFC and the EBRD (2009). This shall be reflected in the Construction ESMPs. A food safety audit shall be conducted on the JPMC and/or IDMI canteen when such facility is completed and offer services to the workforce.
The company has formulated a health and safety policy as part of its QHSE Manual. As per ESAP item #1, a Construction Health and Safety Plan will be prepared to reflect the site-specific activities undertaken during construction using a risk assessment approach. As per ESAP item #1, comprehensive training in E&S shall be provided to the workforce that will reflect the tasks they are involved in and the risks they may be exposed to, which will be reflected in a specific section of the ESMP concerning the provision of worker training. In response to the risk posed by extreme temperatures in the project’s region, the client will design and implement a heat management procedure within the ESMS to protect workers from heat stress. Control measures included in the procedure may include a site-based temperature monitoring system, a modified work schedule to avoid peak temperatures during the day, providing cooling vests to workers, heat-stress training and education, and more frequent rest periods with water breaks in air-conditioned areas. The client will update their Occupational Health and Safety (OHS) policy to include climate risks to the workforce.” As per ESAP item #7, workplace noise, air quality, and heat stress monitoring will be undertaken, and the results will be compared to the stricter applicable limits from national legislation and the WB EHS Guidelines Section 2.0 Occupational Health and Safety.
PS3: Resource Efficiency and Pollution Prevention
Electricity will be supplied to the site during the construction stage from the national grid. During operations, electricity from the national power grid will be used, along with 2,930 MWh/year from the 1.2 MWac solar photovoltaic (PV) plant to be installed on the site.
The company estimates that its annual use of 35,640 tons of pet coke will generate greenhouse gas (GHG) emissions of 126,196 CO2eq tons/year. The Client anticipates that during the project’s operational phase, a natural gas pipeline may be connected to the Eshidiya industrial area, and if natural gas becomes available in the future, petroleum coke will no longer be used. As per ESAP item #8, IDMI will annually quantify plant-related operational GHG in accordance with internationally recognized methodologies and good practices.
Air emissions will be generated during the construction phase from mobile construction machinery and are not expected to be significant. During operations, emissions (including particulate matter, NO2, SO2) will be generated from the dryer. The plant beneficiation will be equipped with bag filters to minimize the particulate air pollution. The pet coke consumption rate of the dryer will be 5.23 tons/hr to 7.63 tons/hr and the content of sulphur in pet coke between 3.5% to 5.5%. Considering the scenario of consuming 7.63 tons/hr of pet coke with the highest sulphur content (5.5%), the anticipated emissions, as per the designer of the drum scrubber (air volume is 460,000 m3 / hr), emission of SO2 will be 1000 mg/Nm3, which is well below national air emission standards and WBG General EHS Guidelines (2007) small combustion emission level guidelines.
The dryer’s air emissions of particulate matter (PM) and nitrogen oxides (NOx), considering the content of sulphur <5%, in pet coke, will be between 3.6–6.0 mg/Nm3 for PM, and 30-200 mg/Nm3 for NOx, which is aligned with national air emissions standards and with WBG General EHS Guidelines (2007) small combustion emission level guidelines. As per the dryer’s technical design specifications, air emissions of heavy metals or mercury resulting from the utilization of pet coke are not expected.
As per ESAP item #9, IDMI will develop an Air Emission and Ambient Air Quality Monitoring Plan in accordance with national law and applicable WBG EHS guidelines and regularly monitor all point-source air emissions and compare these to the stricter national legislation and WB EHS Guidelines Section 1.1 Air Emissions and Ambient Air Quality.
Water is to be supplied by JPMC and supplemented by rainwater collected by IDMI to minimize their water usage. The total annual quantity of water to be used in the process is around 39 million cubic meters (118,000 cubic meters a day), in which 85% of the water is recycled and the plant will be consuming 3.3 million cubic meters annually of fresh water (10,000 cubic meters a day) which is one-fifth of the daily/annual freshwater requirements of JPMC. Since the benefaction plant will process the phosphate rock using a closed water system, whereby once filled, almost all the water used continues to be recycled inside the plant, IDMI estimates that during the operations up to 85% of the water used will be recycled and transferred back into the process. This will reduce their total water demand. The JPMC has a valid license for the groundwater extraction for their own operations from the national Ministry of Water and Irrigation (MWI), which is based on water resource sustainability assessment.
JPMC’s wastewater treatment plant (WWTP) has been constructed but is not yet operational. IDMI operations will generate small volumes (estimated to be 30 m3/day) of sanitary waste (high in ammonia, dissolved oxygen, and biochemical oxygen demand) to be sent to JMPC’s WWTP for the final treatment. Once treated, wastewater will be used to reduce dust dispersion within the project site. As per ESAP item #10, IDMI will request technical details from JPMC demonstrating how the WWTP effluent quality will meet national legislation when operational.
As per ESAP item #1, waste generated during the construction stage will be managed in line with site-specific waste management procedures that cover the minimization, appropriate sorting, handling, storage, and disposal to reflect national legislation and WB EHS Guidelines Section 1.6 Waste Management. All hazardous and non-hazardous wastes will be collected for disposal by authorized public service agencies specialized in each type of waste. As per ESAP item #11, IDMI will conduct audits on their contractors used for the treatment and final disposal of hazardous waste to check that their infrastructure is being operated following applicable national legislation and GIIP.
PS4: Community Health, Safety and Security
As the project is in a remote area of the country without any adjacent sensitive land users, community health and safety risks are limited and include IDMI’s use of the public road network for transporting construction materials and personnel and their transport of petroleum coke during operations. JPMC will transport the final product to the port of Aqaba by road. As per ESAP item #1, IDMI will develop a Construction ESMP which includes a section describing the control measures applied to using the public road network. As per ESAP item #12, and commensurate with its leverage and interlinkages of the project and JPMC operations, IDMI will work with JPMC to help ensure that the drivers engaged by JPMC to transport the final product are fully trained, adopt safe driving practices, and make use of trucks that are roadworthy and all safety critical elements (brakes, horns, lights, etc.) are maintained in good working order.
The area of Eshidiya Mine is considered medium risk zone from the earthquake probability point of view. As per ESAP item #13, IDMI will demonstrate how the project's design (including its worker accommodation) reflects applicable national building codes and standards, and also GIIP.
During construction, privately contracted security personnel will be provided through the EPC contractor, and they will be unarmed. JPMC security personnel oversee the larger perimeter surrounding the mine and its facilities including the IDMI facility, which is located within the JPMC controlled area. For the operational phase, security personnel will be contracted by IDMI and are not expected to be armed. As per ESAP item #1, IDMI will ensure during the preparation of the Construction ESMP that all security personnel have not been implicated in past abuses, are trained adequately in the use of force (and if applicable firearms), and use appropriate conduct towards workers and local people, always acting within the law.
