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
At a corporate level, AMEA Power has developed a set of policies, including quality, health and safety, gender equality, security, and environmental and a social sustainability, that outlines its commitment to quality, the prevention of injury, ill-health, limiting pollution of the environment, and compliance with applicable statutory and regulatory requirements. These policies apply to all AMEA projects, including this project. AMEA Power has also developed an Integrated Management System (IMS) which is certified ISO 9001:2015 (Quality), ISO 14001:2015 (Environment) and ISO 45001:2018 (OHS) since April 2021. A project specific Environmental and Social Management System (ESMS), in line with IFC PSs, details the processes and standards to be implemented during construction to provide adequate E&S management and supervision. This ESMS manual also serves as a guide to the EPC and Operation and Maintenance (O&M) contractors.
The project was requested to undertake a Management of Change (MoC) to identify and assess any additional environmental and social risks related to the BESS expansion component. The risks to be managed regarding this project include, among others, legal requirements, occupational health and safety, supply chain, waste management, hazardous materials management among others.
AMEAs’ Quality, Health, Safety and Environment (QHSE) Employer Requirements (Rev. 10) was updated to include the BESS component. The MoC also required the EPC contractor to develop a BESS Management Plan (BESSMP) in line with IFC PSs. The BESSMP will address any identified E&S and Occupational, Health and Safety (OHS) gaps associated with the construction and O&M of the BESS component. This will include but not be limited to fire detection, construction and operational procedures, health and safety risk assessment, emergency preparedness and response plan (ESAP#1). Whilst it is understood that the BESSMP is going to be developed to complement the Abydos Project Construction (C-ESMP) and Operations (O-ESMP), reference to this interrelation will be explicitly made through the update of the ESMS Manuals.
A project specific, IFC aligned, C-ESMP was developed by the EPC for the Construction Phase of Abydos I. At the time of reporting, the Abydos Solar PV O-ESMP was under preparation ahead of the start of the Operation Phase. The project will update the Abydos Project specific Construction Environmental and Social Management System (C-ESMS) and Operation Environmental and Social Management System (O-ESMS) in line with the MoC requirements. The Project also plans to update the monitoring and review procedure to include BESS requirements.
The project will maintain their site team from the project construction phase including their QHSE manager, sufficient EHS officers and the current social specialists. The project will continue to apply 1:35 HSE personnel/workforce ratio. The project organization chart will be included in the BESSMP prior to the start of construction and operation. As per ESAP#01, the company will require their EPC and O&M contractors (including their sub-contractors) to maintain a HSE Manager and a suitable number of environmental, labor, social and OHS personnel to manage the scope of work.
The project MoC undertaken indicated that the selected BESS technology meets Good International Industry Practice (GIIP). The Emergency Preparedness and Response Plan which was developed for Abydos I is overall still applicable to the construction of the 300MW BESS. Any BESS specific risks related to emergency controls including, but not limited to, on-site emergency responders, certified training for BESS, appropriate emergency signs, etc., will be included in the BESSMP.
Existing C-ESMS and O-ESMS of the Abydos I include a monitoring and review procedure that are currently implemented and that will be updated with additional BESS component requirements where relevant. This will include updating KPIs and reporting requirements. It is expected that either the BESSMP or the monitoring and review procedure for C-ESMS and O-ESMS be updated to allow for BESS requirements.
PS2: Labor and Working Conditions
Construction activities of the 300MW BESS will require approximately 200 workers who will be mostly from the local community with a limited number of skilled expatriate supervisors. The BESS will remain operational for a duration of 20 years and 5 additional O&M workers will be required for this period. The EPC Contractor will implement existent approved ESMPSs of Abydos I, which are in line with IFC PSs and the National Legislation. Going forward, the Human Resource Procedure will be adjusted to consider inflation and devaluation and cover any lessons learned from the execution of Abydos I, to ensure that the EPC Contractor and all active Contractors meet the expectations related to the provision of suitable salaries (ESAP#2).
The ESMPs of the Abydos I include OHS management plans incorporating existent construction risks. The project will identify, assess and include BESS specific risks to this expansion component including, but not limited to the required site controls, occupational health and safety and relevant OHS training requirements. Risks from fire, explosions, battery rupture hazard, exposure to toxic gas (e.g., from battery fire etc.,) will be considered. In addition, exposure of project operators and maintenance workers to the BESS component should also be included in the updated BESSMP, please refer to ESAP#1.
As per ESAP#3 the project will strengthen the existing pre-employment medical screening program by identifying additional medical fitness evaluations, based on Project specific risks and lessons learned from the Abydos I. Fit for purpose fitness medical tests will be undertaken by suitably qualified third-party medical service providers, in addition to government mandatory health screening to all project workers.
AMEA has a Supplier Code of Conduct (CoC) in line with IFC PSs and has recently signed a Responsible Sourcing Policy (dated Oct 1, 2024). They both commit the company to communicate this policy to all third-party suppliers, contractors, and business partners, requiring full adherence to both host country regulations and internationally recognized standards.
AMEA engaged with its suppliers through the EPC contractor. The company undertook its own Reputational Risk Review (RRR) on key suppliers covering relevant risks such as forced labor, child labor, indigenous people and working and labor conditions. The results of the RRR were shared with the EPC contractor and suppliers were asked to provide their responses to any allegations raised, which must be formally submitted (i.e., in writing and using official business letterheads). In addition, all short-listed suppliers are requested to provide a list of key components (tier 2 suppliers), to check their location and assess any potential E&S risks. For the BESS component AMEA undertook supply chain mapping for tier 1 and 2 suppliers.
Once the EPC is contracted, the main suppliers are required to sign a declaration form to comply with AMEA supply chain code of conduct and ESG standards. Equally, suppliers are also required to sign a forced labor statement form to confirm that all contracting practices are in accordance with the local laws and international labor standards. AMEA reserves the right to terminate its contracts with any suppliers that repeatedly do not comply with the material obligations of the CoC. However, the Supply Chain CoC does not specify the planned frequency of supplier audits. AMEA will develop a corporate supply chain procedure clarifying how supply chain assessment will be further implemented (regularity, third-party independent or internal, etc.) and detail sources of reputational risk screening, supplier scoring system and means of triangulating supplier information around identified risks. AMEA will require, via the EPC contract, for the BESS supplier to engage an independent, reputable and experienced third-party consultant, to conduct an audit of their supply chain. This audit will be undertaken to verify labor and working conditions compliance with the local regulations and international best practices. The audit report and any suggested corrective actions will be made available to the company and IFC (ESAP#4).
A Local Supply Chain Management Plan has been developed as part of the C-ESMP of the Abydos I which will be applied in the context of the 300MW BESS project to all local subcontractors or suppliers providing services during the construction phase. Such interrelation will be however already ensured through the update of the ESMS Manuals that will also include any lessons learned, refer to ESAP#01.
PS3: Resource Efficiency and Pollution Prevention
Batteries can generate pollutant emissions such as Polychlorinated Biphenyl (PCBs) or Ozone Depleting Substances (ODSs). AMEA will require the Original Equipment Manufacturer (OEM) to confirm in writing that the BESS does not include PCBs or ODSs. Due to the limited nature of construction activities, the 300MW BESS Project will apply the Abydos Project C-ESMP, O-ESMP and BESSMP to manage environmental risks, particularly in terms of Green House Gas (GHG) Emissions, water consumption, dust control, waste, and hazardous materials management.
The project will handle battery waste from maintenance activities during operation and batteries at “end of life” before decommissioning as well as in case of damaged batteries. As per ESAP#1, the Project will develop as part of their BESSMP a battery disposal plan including the recycling options for e-waste and identification of licensed waste processing facilities. The plan will specify which materials will be recycled, disposed of locally and which will be exported and to which locations.
The Original Equipment Manufacturer (OEM) of the BESS will provide written confirmation regarding decommissioning, disassembly, packaging and safe transport to the designated recycling sites, including recycling and disposal according to the state of the art of technology. All required recycling and safe disposal options of battery related waste will be included into the BESSMP, as per ESAP#1.
PS4: Community Health, Safety and Security
The construction and installation activities for the project will require 200 workers for a six-month duration. The project workforce will mainly be sourced from the local communities with the majority coming from Fares community. During the operations phase, the workforce will be composed of 5 additional O&M workers.
The construction and installation of the BESS component requires the transport of 110 containers. The existent Abydos Traffic and Transportation plan will continue to apply for the BESS component. The BESSMP will include the total number of transport trips for BESS and associated components, transportation permits for heavy and abnormal loads, proposed routes and custom clearance points.
The existing security management plan remains applicable. Access to the site will be controlled through the existing security procedure.
