Ghana - Second Takoradi Project : environmental assessment summary

TIC Takoradi Thermal Power Plant, Proposed Expansion EXECUTIVE SUMMARY Introduction Takoradi International Company (TIC), a joint venture between the Volta River Authority and CMS Energy, is currently undertaking a project (referred to as T2) to expand the existing Takoradi Thermal Power Plant (TTPP). The existing TI plant comprises a 330 MW light crude oil (LCO) fired combined cycle thermal generating plant. An EIA Report was prepared in 1995 in support of an application for funding from a number of agencies, including the World Bank, through the International DevelopmentAssociation.' TI began generating power in December 1997. The design of TI was structured as such to provide for the T2 expansion to accommodate future electrical energy demand growth and to effectively double the plant's output from 330 MW to 660 MW. A Supplementary Environmental Impact Assessment was undertaken of the proposed T2 expansion in 1999 in accordance with guidance from the Environmental ProtectionAgency (EPA)of Republic Ghana in order to obtain an Environmental Approval to commence construction of the expansion project. This report supplemented the 1995 EIA Report and addressed specific environmentaltopics determined in consultationwith the EPA. The Supplementary Environmental Impact Statement (referred to hereafter as the `I999 SEIS')was submitted to the EPA in March 1999and the EPA providednotice of EnvironmentalApproval in April 1999. The `Notice to Proceed' with the construction phase of T2 was issued to the contractor in February 1999 and construction is well underwaywith the first two of three phasescomplete. TIC are currently seeking to apply for funding from the International Finance Corporation(IFC) and/or the Overseas Private InvestmentCorporation (OPIC) for the third phase of the T2 project. These organisations requirethat additionalwork to the 1999 SEIS be carried out to address certain specific environmental and social issues particularly supported by these agencies and that updated information on T2 is supplied accordingly. It is also necessary to demonstrate compliance with current World Bank environmental, health and safety criteria. This report therefore forms an Addendum to the 1999SEIS and the main text should be read in conjunctionwith the 1999 SEIS; it has been prepared with due reference to the IFC policy on EnvironmentalAssessment. This Executive Summary provides a standalone description of the environmental implications (benefits and adverse effects) of the T2 project. It has been prepared in accordancewith IFC requirements. 'Acres InternationalLimited, Takoradi Thermal Plant EnvironmentalAssessment, Volumes 1 and 2, 1995. Addendum Environmental Report J98404B JacobsGlBB Limited i Issue 3.0 /November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion Takoradi Thermal Power Plant The Existing T I Plant TTPP was largely developed in response to a consistently high rate of growth in domestic demand for electrical energy generation in Ghana which far exceeded the actual capacity for energy generation available, as well as exceeding projected annual average long term capacity levels. It was subsequently identified that developing Ghana's power generating capacity through the use of combustionturbine technology was preferable to expanding the existing hydro-electric system. TI was initially developed in 1995 as a 330 MW combined cycle generating plant, which in turn primarily consists of two combustion turbine generators (CTGs), two heat recovery steam generators (HRSGs) and one steam turbine generator (STG), associatedtransmission lines and other facilities. In addition to the above, other key components of TI included switchyard, transmission lines from the site to the National Grid at Inchaban, a single offshore mooring point for the delivery of light crude oil (the principalfuel supply for TTPP until natural gas becomes available), fuel storage tank farm, seawater cooling tower system with seawater intake and outtake pipes and desalination plant, plant access infrastructure, water supply, sewage lagoons, waste oil treatment facility and incinerator,and a permanenttownship for the workforce. The TTPP project occupies an area of approximately 168 ha, which included provisionfor future expansion, i.e. the allowance for doubling in generating capacity was designed into the project at the start. The original TI proposals were subject to an EIA and public consultation between 1993 and 1995 which led to the preparation of the 1995 EIA Report; this was prepared with due reference to EnvironmentalApproval for the constructionof TI to commenceBankprovided in July World criteria2. was 1995. Construction of TI commenced in 1996 and the first simple cycle unit (110 MW combustion turbine) became operational in December 1997. The commercial operation of the second simple cycle unit began in January 1998 and commissioning activities on the combined cycle, including the steam turbine and generator, commenced in April 1999. At the time of writing only one of the CTGs for TI was operational in combined cycle, with the second T I CTG currently under repair. Repair is expectedto be complete in July 2001, * Operational ~ Directive 4.01, Environmental Assessment, October 1991. Addendum EnvironmentalReport JacobsGlBBLimited ii Issue 3.0 /November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion The T2 Project The T2 project has been developed in responseto growing electrical energy demand within Ghana and has been designed to double the electrical energy output from the existing TI plant from 330 MW to 660MW. The expansion project was consideredto the best option for meeting the growing electrical energy demand while remaining environmentally,economicallyand logisticallyfavourable. The objectives of the T2 project primarily include assistingwith the development of a more reliableand stable electricity supply, reducing Ghana's dependencyon imported electricity, minimisingenvironmental impacts (through expansion of an existing plant and through its design), and providingsurplus energy for export. The 1999 SEIS was produced in 1999 after consultation with the EPA (see section I.3below)andsubmittedinMarch1999withanapplicationforanEnvironmental Approval for the construction of the project. The report was made available for public the EPA. EnvironmentalApproval for the construction of T2 was provided in April review and comment in April 9999 and for review by other groups as determined by 1999. The T2 project is currently being constructed within the existing TI plant site and comprises providing two 110 MW CTGs, two HRSGs and one 110 MW STG, and associatedfacilities (includingfuel storage tanks, fuel treatment unit, desalination and demineralisationplant). Many of the components,facilities and infrastructureof T2 will be shared or extended from those already constructed as part of TI. Of the total 168 ha occupied by the TTPP site as a whole, approximately 7.5 ha is directly associated with T2. Other key components that will be constructed as part of T2 include water storage tanks (demineralised, potable, raw, filtered and condensate), fuel treatment structures, oillwater separator, treated and untreated LCO storage tanks, steam distributionsystems, circulatingwater systems, transformers and control rooms. T2 will, by definition, interface with or be incorporated into various existing T I structures, services and systems. These include oil off-loading and storage facilities, potablewater supply, sanitary and wastewater discharge and sewer systems, sewage and wastewater treatmentfacilities, firewater systems, seawater intakeand discharge and maintenancebuildings. The TTPP project includes various transmission line and substation modificationsthat allow for tie in with the National Grid and evacuation of the full generating capacity. Much of this work has been completed. The TTPP development also allows for future tie-in with the proposed West-African natural gas pipeline. Key shared facilities have been described in 1999 SEIS and are outlined again in section 3.4 of this report. Updates on the status of transmission line upgrades and the West African Gas Pipelineproject are also given in this report. The construction of T2 has been divided into three distinct phases, such that Phases 1, 2a and 2b represent the construction of Simple Cycle Unit 1 (SCI), Simple Cycle Unit2 (SC2)and Combined Cycle Unit (CC), respectively.At the time of preparing the Addendum, Phases 1 and 2a of the project were complete and operational and construction of Phase 2b has yet to start. It is anticipated that Phase 2b will be operationalin 2003. Addendum EnvironmentalReport J98404B JacobsGlBB Limited iii Issue3.0 /November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion The parties involved in the T2 project include: Project Sponsor TIC (comprising a partnership between CMS Energy and the Volta River Authority of Ghana): EPC Contractor (Equipment Black and Veatch International (BVI) and Procurement, Engineering, Overland Contracting Incorporated (a Construction, Start-up and subsidiary of BVI) Testing) Operator CMS InternationalOperating Company Addendum Environmental Report JacobsGlBB Limited iv Issue 3.0 /November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion Alternatives Considered for TI and T2 As T2 is accommodatedwithin the TI design, which itself was subject to a review of alternative location,design and operational specificationoptions during the 1995 EIA, it was considered during the 1999 SEIS that no further assessment was required. A summary of the alternatives consideredat the outset of the TTPP project includethe following: 0 The `Do-Nothing' option (Le.a hypotheticalsituationwhere TI is not constructed); Alternative geographical locations (e.g. eastern and western Ghana, coastal and inland locations) 0 Alternativetechnologies includingopen and closed-circuit cooling water systems, 0 Usingalternative fuels, includingLCO and residualfuel oil 0 Usingalternative methodsfor fuel oil transportation; and 0 Broad potential environmental impacts associated with the various alternatives, such as air quality (fuel types, stack heights and control technologies) and marine environment (coolingsystems and single point mooring locations). These alternatives, consideredat the TI planningstage, were subsequentlyaccepted or rejected primarily on the basis of practical, economical and environmental context relativeto best meetingthe specificobjectives for relievingthe nationalenergy crisis. With regard to T2, the proposed expansion was selected on the basis that it represented the most economically viable option for achieving the key objective of providing a rapid response to the energy crisis. It also involved minimal environmental disturbance particularlyas an alternativewould have been to construct a second, separate plant on a newsite. Policy, Legal and Administrative Framework Ghanaian EIA and Permitting Procedures The Environmental Protection Agency Act, Act 490 was passed in December 1994. This act established an EIA system for Ghana and provided for the establishment of the Environmental Protection Agency (EPA), replacing the former Environmental Protection Council, to ensure compliance with the appropriate procedures and guidelines. Procedures for EIA are provided in the Ghana Environmental Assessment Procedures 1995, and are enforced by the EPA under the EPA Act 490. Additional guidelines for EIA are contained in the EPAs `EnvironmentalAssessment in Ghana, A Guide, December 1996'. In short, the procedures provide for a permitting system whereby a project may or may not be required to obtain an Environmental Permit and in so doing, may be required to be supported by an EIA of a specific level of detail. Public notice of availabilityof submitted EIA reports and public hearings are also provided for, where necessary, and on submission of a satisfactory EIA, an EnvironmentalApproval (EA) Addendum EnvironmentalReport J98404B JacobsGlBB Limited V Issue 3.0 / November2001  TIC Takoradi Thermal Power Plant, Proposed Expansion will be issued to permit construction. A `full' Environmental Certificate, which covers the operation of the project may be issued once an EnvironmentalManagementPlan (EMP) and monitoring programmes have been demonstrated as satisfactory and an Annual EnvironmentalReport has been submitted. Ghanaian EPA EnvironmentalCriteria The EPA has prepared environmental criteria for noise, ambient air quality and maximum permissible levels for effluent quality (based on sector specific releases to naturalwater bodies). The T2 environmental studies for the 1999 SEIS were undertaken with specific reference to these guidelines for each of the environmental topics addressed. As required for the Addendum Environmental Report, the emphasis was placed on assessing the effects of T2 relative to the World Bank GroupllFC criteria as listed below. World Bank Group Environmental Criteria Both IFC and OPlC requirethat projectsshould be assessed relativeto the following: 0 World Bank Group's Pollution Prevent and Abatement Handbook, 1998 - Thermal Power: Guidelinesfor New Plants 0 World Bank Group'sOccupationalHealthand Safety Guidelines 0 IFC Environmental and Social Policies including EnvironmentalAssessment, General Health and Safety Guidelines, Natural Habitats, Pest Management, Safeguarding Cultural Property, Involuntary Resettlement, Forestry, International Waterways and Child/ForcedLabour. Baseline Environmental Conditions The following comprises a summary of the environmentalconditions observed during the T2 environmental studies for the 1999 SEIS and Addendum Environmental Report; bothof which take into accountthe presenceof TI. Physical Environment The site lies on relatively flat land that rises from sea level to 50m at a distance of 4km inland. The surrounding area is predominantly open with scattered trees and wetland habitat, some of which is used for subsistence farming and was generally described as `pleasing'. With regard to visual aspects, the presence of TTPP effectively represents an adverse effect through the introduction of a large scale, man-madefeature into a generallyflat landscape. However,it is importantto notethat taking into account local culture, landscape and visual issues are not key issues of importance in comparison to health services, water supply and other basic commodities. At the time of the 1999 studies, the site for T2, which is contained within the confines of TI, had already been cleared of vegetation, regraded and levelled during the Addendum EnvironmentalReport JacobsGlBB Limited vi issue 3.0 I November2001  TIC Takoradi Thermal Power Plant, ProposedExpansion construction TI. During the May 2000 site visit, it was noted that a slight improvement in the landscape and visual quality of the area had occurred on account of the ongoing natural and assisted regeneration of vegetation within TTPP and immediate surrounding area. In particular, this included the re-establishment of a stand of coconut trees along the coastline. BiologicalEnvironment There are three main zones of florahegetation present within the study area, including coastal strand, seasonal swamp/wetland and grassland, and a mixture of isolated or continuous areas of coastal thicket. Although there are recognised and protectedwetlands in Ghana, the site on which the Takoradi complex is located has not been designated as such. The area had largely been influenced by human activity for some time and is considered not to have contained `natural habitats' as defined in the IFC P~licy.~ As the T2 site is incorporated within the TI boundary there was little vegetation present prior to construction commencing as the site had already been cleared during site preparation activities for TI. Similarly, for borrow areas, those sites being used for T2 had already been 'active' for the TI construction period. There were also no forests presenton the site priorto clearancefor TI. Human Environment The following represent the key features of the existing human environment affected by TTPP. A map showing the site's location relative to surrounding settlements can be found on the followingpage. Settlements TTPP lies within the Shama Ahanta East District which comprises a number of settlements,the closest of which includes Aboadze (1.5 km to the east of TTPP) and Abuesi (3 km to the east of TTPP). These settlements have an approximate combined population of 9,000 (1984). It is understoodfrom the 2000 studies that the communities have generally increased in size since the development of TI in response to direct and indirect employment opportunities associated with TTPP. In addition, informal consultations with communities officials and the general public in Aboadze indicated a general contentment with the existing arrangements with TTPP and no real significant concerns pertainingto operational and construction activities at TTPP. Land OwnershiD and ComDensation With regard to land tenure and ownership no further land was acquired for the construction and operation of T2 as this was accommodated within the land already acquired, occupied or used for TI. Land was acquired from the `Stool Lands' of Dwomo (Le. the local administration area under the custody of the Stool Chief) in accordance with the State Lands Act 1961 (Act 46) and the Volta River Development Act. Under a Community Impact Agreement arranged under TI, a number of infrastructure improvements have been carried out to reduce any nuisance associated with constructionactivities (such as dust generation) and as compensation to provide more long term community benefits. These include reconstruction of the local road network between Abuesi and Aboadze to lnchaban and from Dwomo to OP.4.04,NaturalHabitats Addendum Environmental Report J98404B JacobsGlBB Limited vii Issue 3.0 / November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion lnchaban and constructing a cold storage facility in Aboadze; both these are near completion. Five new school blocks and public convenience blocks are also under construction and plans for a clinic are being finalised. An additional community water tap has also been recently provided. Waste Manaaement With regard to waste managementissues, Since the preparation of the 1999SEIS, an alternative oil waste management procedure has been adopted partly in response to delays in the commissioning of the waste oil incinerator. Waste oil sludge is currently removed off site via road tanker under an arrangement with Tema Oil Refinery (TOR) where it is reprocessed for use as a fuel or other uses such as wood preservatives. These procedures have been adopted in favour of regular incineration, such that the latter will be used only when the collection of the oil waste by others is interrupted. At present the waste oil sludge is sold for recycling, rather than incinerated because of the high costs associated with the diesel required to supplement sludge incineration, a favourable income from sale of sludge and to address environmental concerns. Despite waste being removed from site and recycled or reused, a monitoring programme is in place to assess the nature and levels of heavy metals in the waste oil sludge prior to removal by other parties. Addendum Environmental Report JacobsGlBB Limited viii issue 3.0 / November 2001  TIC TakoradiThermal Power Plant, ProposedExpansion Environmental Quality of the Area Air Quality Routine stack emissions and ground level air quality monitoring for T I in 1999 indicatethe following: NO, stack emissions have largely remained within World Bank criteria, with the exception of conditions where the NO, control systems were temporarily offline. SO2 stack emissions were within the relevant World Bank criteria; Where available, ground level PMlo and SO2concentrationsmonitoring data indicated that concentrations were well within the relevant Ghanaian criteria. However it is important to note that ground level NO, monitoring equipment was generally out of service throughout 1999 and various problems were experienced with the remaining monitors. Water SUDD~Y Water is supplied via a dedicated water supply pipeline from lnchaban reservoir approximately 3 km north west of the site. This can provide a maximum supply of 1,820 m3/day to T I and can be supplemented by desalinated seawater from the T I Desalination plant of up to 1,I 35m3/day. In Phase II of the T2 development, a further Desalination plant of more than 2080m31day capacity will be constructed to ensure baseload freshwater demand for both the TI and T2 plant can consistently be met. However, should all CTGs be operated at base load for extended periods prior to the T2 desalination plant being operative, freshwater supply could fall slightly short of demand. In this operating scenario, temporary process adjustments can be made to conservewater usage while allowing for full plant operation. Wastewater A storm water system has been constructed around the TTPP site to collect surface water where it is discharged into the adjacent wetlands which form part of the Anankwari River feeder system. Any potentially contaminated surface waters are diverted to an oily water sewer system. Domestic wastewater at the site (including from the township) is discharged into three effluent oxidation ponds to the north west. After extended aeration the treated liquid waste is sent to sea via the common discharge sump. Sludge wastes will be dried and landfilled approximately once every 10 years. Current process wastewater streams from TTPP are associated with the demineralisation plant, desalination plant, chemical lagoon and oil/wastewater collection system. Water effluent from the demineralisation process and oil water collection system is discharged to the stormwater drain after treatment via the neutralisation sump and the oil/water separator respectively. Water effluent from the desalination plant and chemical lagoon eventually discharges to sea via the common discharge sump after dilution and neutralisation respectively. Monitoring is currently undertaken at each of the intermediate `treated' process water storage areas prior to discharge and at the final, common discharge sump. Wastewater monitoring results for T I for 1999 indicate that with the exception of suspended solids, monitored results were within the relevant T I environmental criteria as well as 1998 World Bank and post 1995 Ghanaian criteria. Monitoring of the neutralisation sump, oil/waste plant and chemical lagoon effluent streams for Addendum Environmental Report J98404B JacobsGlBB Limited ix Issue 3.0 I November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion 2000 indicates that total suspended solids exceeded the required limits. This was due to wind blown solids, HRSG operation and from oily waste lagoon sources. Ambient seawater monitoring indicates no significant increase in temperature as a result of operation to date. Noise Construction and operation of TI and or T2 during the 1999 and 2000 site visits would have influenced the observed noise levels. However, noise monitoring undertaken during the 1999 site visit at selected sensitive sites indicated that noise levels were generally within Ghanaian PA guidelines. The ongoing noise monitoring results recorded in 1999 indicated that some construction activities had resulted in noise levels at the perimeter fence exceeding 1988 World Bank guidelines. Some specific plant was noted to exceed required standards, however, noise protection measures have since been set up to protect workers in these areas. Key Environmental Effects The T2 environmental studies considered the likely environmental effects associated with the pre-construction, construction and operation of T2. These have been summarised below. Physical Environment LandscaDeand Visual Effects The main landscape and visual effects, irrespective of the construction phase, are associated with the introduction of new man-made features into an otherwise natural, relatively attractive coastal environment. However, the adverse effects of T2 will largely be cumulative given the presence of TI, and therefore are expected to be relatively slight in significance. In addition it is important to bear in mind that the local perception of landscape and visual effects by the neighbouring communities is generally of low priority relative to the importance attached to employment, health services and education. Irrespective of this, there is likely to be decline in any significance attached to the adverse landscape and visual effects as the local people become accustomed to TTPP. BiologicalEnvironment General Ecoloav, Natural Habitats and Forestrv There will be no effect on natural habitats or areas of forestry (as specifically defined in IFC policy documents) during site preparation and/or construction of T2. This is on account of the T2 site being located within the existing TTPP site that was cleared and graded during the construction of TI. In addition, the ecological importance of the area prior to site clearance for TI was described as low in the 1995 EIA and, due to the influence of human activity the ecology of the area would not have strictly complied with the IFC definition of `natural habitat' or `forestry'. Furthermore, there will be no additional land-take as the small volume of borrow material still required will be provided from existing borrow areas off site and construction compounds and Addendum EnvironmentalReport JacobsGlBBLimited X Issue 3.0 /November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion laydown areas have been located on sites previously used for T I construction. The privately owned borrow areas supply material to many users, mainly for road improvements. In terms of operational effects associated with the settling of stack emissions downwind of the plant, it is concluded that there will be no effect on natural habitats or forestry as the areas downwind of the plant largely comprise land modified for subsistence and generally of low ecological importance. The predicted ground level concentrations of the main pollutants associated with the plant (includingT2) are also well within specified limits. Some degree of wildlife disturbance during construction would occur, albeit slight, along with a potential for habitat contamination during the construction and operation of T2. However, this is not expected to be significant given the low ecological importance of the area and that a degree of wildlife acclimatisation to conditions on site will occur/has occurred. HumanEnvironment Cultural Propertv There would be no significant effect on these issues during site preparation and operation of T2 as no such features were either present prior to or discovered during the construction of TI, and T2 is being constructed within the existing TTPP site and/or affects land previously affected by TI. Resettlement As T2 is contained within the existing TTPP site there were no residents or squatters present on the T2 site that would require resettling. There were also no settlements on the site prior to the construction of the existing TTPP plant. Child and Forced Labour There will be no use of child and/or forced labour during the construction and operation of T2 in accordance with Ghanaian regulations and the terms of the construction and operations contracts. Pest Manaaement There will be no operation of pest management controls as defined in the relevant IFC policy. However, the existing use of herbicides within the substation/switchyard at TTPP will increase due to the extension of this area to include new plant for T2. This represents a minor incremental increase in terms of both the area affected and quantities of spray applied and is not thought to represent a significant environmental effect, particularly as the surrounding area is of low sensitivity to any drift of sprayed chemicals. A `disinfection and fumigation' programme for TI will also be expanded to include T2, but is, again not thought to represent an issue relative to the health benefits achieved. General Social Issues As described in the 1999 SEIS, there will be significant benefits associated with T2 through the strengthening of the electricity power supply, which in turn will provide for the expansion of the general economy and a consequential improvement in the standard of living. As the power supply becomes more reliable, the inconvenience of and damage from power outages and curtailments will also be reduced. Other benefits include an increase in the construction and operating skills of the local Addendum Environmental Report J98404B JacobsGlBB Limited xi Issue 3.0 I November 2001  TIC TakoradiThermal Power Plant, Proposed Expansion workforce, enhancing Ghana's future ability to construct and operate other high technology industrial projects. There will also be temporary and permanent employmentavailablethrough the constructionand operationof T2. There will be a general slightly adverse impact on the local communities due to disturbance associated with construction traffic on the roads leading to the site, and there may be a potential for public health issues primarily associated with the construction workforce. The potential extension of the construction programme with the new T2 phasing may extend the period over which community disturbance associated effects on air quality, noise and risk of accidents may occur. This is not consideredto be significant. Waste Manaqement The revised approach to management of oil waste sludge will effectively representa slight improvementin terms of air quality emissionsfrom the site as a whole. This will be achieved through the removal of the waste product for alternative uses off site in favour of routine incineration. There remains a potential for improper and/or indiscriminate disposal of solid waste generated in and around TTPP, which could in turn lead to land contamination,visual and public health issues. However, mitigation measures are in place through the existing Environmental Management Plan, which will be extended to cover T2 to managewaste storage and disposal accordingly. Environmental Quality of the Area Environmental monitoring has shown that T2 generation equipment has achieved excellent compliance with relevant other guidelines. With some parameters it is very difficult to separate the effect of T2 from T1 discharges and in these instances the discharges from the plant as a whole are considered. Examples include noise and wastewater quality. Ground level concentrations of the relevant air contaminants have remained within the appropriate air quality guidelines since the TTPP first commenced generating. Exceptionsto this have been linked to identifiable external influences. Despite some complaints and infrequent exceedances,the community noise levels do not appear to have deteriorated significantly as a result of the T2 expansion to date. Wastewater quality is controlledto meet limits and monitoring has demonstrated good compliance, with exceptions beingattributed to identifiablecauses. Commissioning issues and the challenging operating environment have meant that items of pollution monitoring and control equipment have periodically suffered outages, and the plant's location can mean significant downtime results. However, such problems are expected to become less frequent over time, particularly as a result of measures taken to date such as equipment adjustments and increased stocking of spare parts, as well as the further measures proposed in the provisional EnvironmentalManagementand MonitoringPlan (EMMP). The T2 plant is expected to reliablymeetthe relevant environmental guidelines. Tables on the following pages summarise the plant's past and predicted performance in relation to air and liquid discharges, and noise emissions. Included in the tables are the World Bank and Ghanaian guidelines at present, as well as those at the time of the 1995 EIA, applicable to TI. Addendum Environmental Report JacobsGlBB Limited xii Issue 3.0 / November 2001  TIC Takoradi Thermal Power Plant, ProposedExpansion Air Qualitv In terms of air quality there is expectedto be no significant change to the conclusions of the 1999 SEIS such that dust generation during the construction stage of T2 is expected to have localised,short term moderate to significantadverse effects on the local communities. TI stack emissions results and ground level pollution concentrations indicate that concentrations have largely been in compliance with the relevant criteria for TI, as well as the current criteria. The exceptions include instanceswhere the NO, control systems have been offline and NO, stack emissions . have temporarily exceeded the appropriate criteria. For ground level monitoring, available data also indicatescompliancewith requiredcriteria. The exception relates to ambient PMlo levels which have occasionally exceeded recent Ghanaian criteria, and are also predicted to exceed this level once T2 becomes fully operational. The exceedances (real and predicted) are largely due to background dust levels that alone can exceed the criteria. During commissioning, tests on T2's SC1 demonstrated its ability to comply with emission limits. Available emissions results from 2000 showed T2's NO, levels have remained within the 1998 World Bank NO, emissions criteria. There have been instances where problems were experienced with NOx control equipment, but levels remainedwithin the World Bank limit for operation without NOx control except for an occasion where the NOx levels exceededthis limit by 2%. Ground level air quality data for the plant as a whole (where available) indicate compliance with World Bank and Ghanaian EPA criteria for SOz, PMlo and NO,. Predictionsmade in the 1999SEIS of the cumulative effects for TI and T2 on ground level air quality are also within the appropriate World Bank criteria. It is of note that owing to a change in the waste management of waste oils for TTPP as a whole, the volume of waste oil incinerationis lower, which will have a benefitfor TTPP in general as well as removing a minor cumulative effect previously associatedwith T2. TTPP is the only large scale thermal power plant at the moment and consequently makes a significant contribution to the overall Ghanaian Carbon Dioxide emission inventory. For both TI and T2 fired on oil under the same conditions, the Carbon Dioxide emissions from the plant would be 0.71 million tonnes of carbon (MtC) and the Ghanaian emission would be 1.89 MtC. For gas firing, the increased energy to carbon ratio would result in a lower TTPP emission of 0.61 MtC, with a subsequent Ghana COzemission of 1.78MtC. However,within the context of global emissions of Con, Ghana's entire COz contribution will represent just 1/30thof 1% of global emissions. In comparison with many thermal power generation plants around the world, the TTPP is designed to generate power at a high efficiency by utilising gas turbine technology in conjunction with a heat recovery plant and steam turbine. In combined cycle operation, a generation efficiency of approaching 50% should be achieved. This is in contrast to many conventional steam plants where efficiencies in the range 25 to 38% are not uncommon. Consequently, the TTPP is considered energy efficient from the perspective of global fossil fuel power generation and emissions of coz. There is a potential cumulative adverse effect with T2 compared to TI in terms of fogging and salt deposition from the cooling towers, the significance of which, at any time, will depend on the prevailing meteorological conditions. The impact has been Addendum EnvironmentalReport J984048 JacobsGlBB Limited xiii Issue3.0 / November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion reduced for TI by the installation on the cooling towers of drift eliminators, which will also be installed on the new cooling towers proposed for T2. Water Sueplv and Wastewater A Desalination plant will be constructed during Phase Ilb of T2 to supplement the supply from the T1 Desalination plant and from lnchaban pipeline. The new T2 desalination plant will be able to supply the 382 gallons per minute needed to ensure baseloadfreshwater demand for T2 can consistently be met. Effluent quality for TTPP is currently in compliance with 1998 World Bank criteria. While there have been some exceedances of Suspended Solids criteria these incidentswere isolated and attributed to specific process or environmental causes. The risk of oil spill events is currently lower than for normal operation owing to reduced operation and hence reduced LCO and diesel deliveries. However, operation is expected to reach capacity in future and the plant therefore has relevant oil spill procedures in place. At present these include TI'S Oil Spill Response Plan, which is being used to cover T2 also, and annual Oil Spill Response exercises. At the time of writing, the Response Plan was being updated and expanded to include T2, while an Oil Spill Prevention Plan and Oil Spill Risk Assessment were also being prepared. These are expected to be complete in May 2001 and are expected to significantly improve the lTPP's spill prevention capability, spill readiness and response effectiveness. There are expected to be no other significant adverse effects related to water supply and wastewater issues due to the installation of a desalination plant and the provisions made under TI. In terms of changes to seawater temperature with T2 discharges, it is expected that due to the pipeline design, the natural seawater temperature fluctuations, and the higher exit velocity associated with the combined discharge flow, the cumulative effect of T2 will not be significantly different to the modelled results for a 660 MW scenario undertaken in 1995. It should be noted however that inclusion of a cooling tower system provides significant mitigation in terms of reduced thermal effluent impact on receiving waters. InternationalWaterwavs As the single point mooring station for unloading LCO via shipping tankers is not located within an international waterway, as defined in the IFC policy, there will be no effect associated with the general increase in delivery frequency for T2 above that already undertaken for T1. Noise Taking into account the specifics of the 1998 World Bank noise level criteria, recent and current noise levels at TTPP, including T2 construction noise, are generally within the stated criteria, and in particular at the nearby settlement of Aboadze. Some short- lived high noise events have occurred which lead to complaints from the local community, and measures to forewarn the communities are to be enforced. The potential extension of the construction period under the new phasing for T2 will potentially result in an additional cumulative effect, but this is not thought to be Addendum Environmental Report JacobsGlBB Limited xiv Issue 3.0 / November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion significant. Noise levels at one meter from selected specific T2 equipment have been found to exceed 1998 World Bank criteria; appropriate warnings have been erected and the use of protective measures made mandatory. General (including T2's SC1 and SC2)there will be a general decrease in the overall resource Overall, it is of note that under the current intermittent operating conditions at TTPP inputs required and resulting discharges and noise emissions. However, it is still planned to operate the plant continuouslywhen the oil market is more favourable. Addendum Environmental Report J98404B JacobsGlBBLimited xv Issue 3.0 1November2001  nj I- -Oh c $m Q Q (I) a Q, : 5 a, c 0 .- E c 5 a, c .-.- c mIn -E U + a -0 mQ -3a E3 F c 0 -mC>a2 c g U .-mC0In C .-In n E a3 In   .-0 C v) C Q m W X TI al n 8Q2 U- S h m L al n g  In 9 L E .-C0 m3 .-& 4-8 0 ma, sa a, C i s>E - 3 h Q .-8 .-mQ C 0 .L -6 2 $Q c 0 0 2a, 8m LL b r -2. Q C 9 3 2 F ,m 0 a, 3 C 5 a, 3 ,. -mCa,g! I > U -09a, E -8mCa, I U Em v) C I v) .-2> s 43 43 5 S?a, 3 F -0 C 1- 4- m U $ .-g!C C n 2 $ -F Eh > U Ea, mC 2. a, $ v) .-8 0 U C -a,m c .-8 C m  TIC TakoradiThermal Power Plant, Proposed Expansion Recommended Mitigation Measures and Net Environmental Effects describedin the 1999SEIS and Addendum EnvironmentalReport: The following comprises recommendations for mitigation measures for T2, as Landscapeand TIC to ensure accidental vegetation clearance or disturbance in Visual Issues areas not previously affected by TI during construction is reduced. Extend the landscape planting proposals developed for T I to accommodate T2, and commence planting as soon as practicalto quickly maximisethe benefitsof the planting. In terms of residual effects, there will inevitably be an adverse residual effect due to the large scale of TTPP. Howevera degree of acclimatisation will assist in reducing the significance of the residual effect. TTPP will inevitably form a distinctive man-made landmarkon the coastline. Ecology Mitigation measures to be incorporated during the construction include utilising existing TI construction storage/laydown areas, incorporating native species common to the area into the landscape planting proposals and extending the landscape planting plans to include the replanting of former borrow areas, construction laydown areas used for T2 once construction is complete. The Environment Manager will be responsible for implementation,in conjunctionwith TIC and the EPA. The main residual ecological effects are likely to be associated with the operation of the plant through air emissions, possible pollution through accidents and a minor degree of wildlife disturbance. However, it is expected that in the long term, the conversion of TTPP to natural gas, the setting up of emergency contingency plans and the continuedacclimatisation of the wildlife to TTPP will reduce the significance of any residual effects to minimal. GeneralSocial The Community ImpactAgreement initiated under TI will continue Issues to provide mitigation for T2, through, for example providing a forum for any concerns etc. of the local communities to be voiced about T2 construction activities. Provision of public health awareness training to T2 construction and operations personnel and the extension of anti-malaria mosquito spraying to T2 areas will help reduce any associated public health problems. In terms of pest management it is recommendedthat measures be taken to avoid drift of sprayed chemicals beyond the target area. These will include spraying under calm conditions, using environmentally acceptable chemicals where practical and storing, handling and disposing of unused chemicals appropriately. In order to control the distribution of waste oil sludge containing high levels of heavy metals from TTPP to other sites (such as Tema Oil Refinery), regular monitoring of the waste oil sludge will be undertaken prior to its collection by other companies. It is expected that with the implementationof mitigation measures Addendum EnvironmentalReport JacobsGlBB Limited xx Issue 3.0 I November2001  TIC Takoradi Thermal Power Plant, Proposed Expansion there will be no significant residual effects beyond the constructionand operationsphase. Air Quality Mitigation measures to limit dust generation during the construction stage include traffic management, protecting stockpiles of material and damping down areas. In terms of the operation of T2, mitigation measures associated with the design of the plant (which are in agreement with those for TI), such as the use of water injection for NO, emissions control will help to reduce the cumulative impact of TTPP. T2 stack height will be 40m upon completion and the sulphur content of the crude oil used is limited to 0.2% by weight. The monitoringprogrammefor both stack emissions and ground level concentrations at selected sensitive sites will help to ensure compliance with appropriate criteria is maintained. TIC will be responsiblefor the effectiveness of this programmefor T2. While a localised residual air quality effect will remain despite the emission control design of TTPP, this is expected to be of minor significance given that ground level NOnand SO:!predictions for the cumulative impact of TTPP will remain within relevant criteria in particular. In terms of global Conemissions, as Ghana's Con emissions will remain a very small percentage of total Con emissions,the residualeffect is consideredto be slight. Water Supply Precautionswill be taken to prevent spillage accidents during the and T2 construction phase, and oil and fuel areas will be bunded. TIC Wastewater will ensure appropriate training is provided on the handling, storage and disposal of hazardous materials and the upgrading and implementation of emergency spill response measures by TIC'S consultants will reduce the significance and impact of any incidents during construction. The closed cooling system was chosen to mitigate thermal discharge and the wastewater discharge monitoring plan will help to ensure discharges are in compliance with appropriate guidelines. Containment areas have been provided for oil/fuel storage tanks and appropriate separation of runoff and process wastewater has been provided to ensure treatment prior to discharge to the stormwater drains and/or dischargeto the sea. It is considered that overall there will be no significant residual effect with the constructionand operation of T2. Noise Mitigation measures to limit noise during construction include providing screens, using exhaust and equipment silencers and minimising nighttime activities. Advance warnings of particularly noisy construction activities are also provided to local communities,where such noise cannot be mitigated. The Environmental Manager's ongoing TTPP monitoring programme will ensure compliance with the appropriate criteria during the combined operation of TI and T2, as well as provide a warning for any particularly noisy construction activitiesduring T2. In terms of occupational noise levels associated with specific plant equipment, monitoring will be undertaken by the Environmental Manager and Assistant Environmental Manager. Appropriate measures such as provision of ear protection and placing of warning signs will be implemented where the plant is Addendum Environmental Report J98404B JacobsGlBBLimited xxi Issue 3.0 I November2001  TIC Takoradi Thermal Power Plant, Proposed Expansion found to exceed occupational noise limits. As the predicted cumulative noise effects of TI and T2 are not predicted to exceed appropriate noise criteria at specific selected sites, it is considered that the inevitable residual noise effects will be minor. Residual noise effects associated with the construction of T2 will last the duration of the construction stage only. With regard to any net effects associated with T2 (Le. after taking into account the mitigation measures outlined in the 1999 SEIS and above), it is concluded that overall, provided the Provisional EMMP for T2 is implemented and enforced during the remaining construction phase and operational phase, there will be no resulting long-term significantly adverse net environmental effects. A summary of the matters covered by the Provisional EMMP is given below, while the EMMP has been repeated along with progress updates within the Addendum. Addendum EnvironmentalReport JacobsGlBBLimited xxii Issue 3.0 I November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion SUMMARY OF PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN (EMP) RESPONSIBILITIES AND ROLES 4. WATER AND WASTEWATER ISSUES Addendum EnvironmentalReport J98404B JacobsGlBB Limited xxiii Issue3.0 /November 2001  TIC Takoradi Thermal Power Plant, Proposed Expansion 6. ACCESS AND MitigationMeasures TRAFFIC 1. Existingaccess and haul routeswill be usedfor transport of constructionmaterials. 2. Controlled loadingof materialson and off vehicles. 3. Appropriate Speed Limitswill be set on all roads used by planttraffic. 4. Proper maintenanceof site vehicles. 5. Provisionof bus service to reduce road traffic. 6. Vehicle speed control measures,educationprogrammes and hazardsawarenessguidance. Monitoring No monitoring proposed. 7. LAND ISSUES MitigationMeasures AND WASTE 11. Localborrowareaswill be rehabilitatedto former conditionby contractor,auditedby EM. 11 MAWW~V~ENT I2.Waste managementprocedureswill be developedand a waste managementmanual II Monitoring I. Operationof Oilywaste treatment will be monitored,audited and maintainedfor efficiency. 2. Undertakean audit of wa 8.ECOLOGICAL MitigationMeasures EFFECTS 1.All operationswill remainwithin the existingsite fence line. Areas already clearedof vegetationfor the constructionlay down sites during constructionof TI will be used during T2. EFFECTS Monitoring 1. Ensure plantingprogramme is effective by monitoringtree healthand replantingas I necessary. I O . RISK MitigationMeasures MANAGEMENT 1. Staff will be educated as to spillage and explosionrisks, preventionand response. 2. Reviewof existing contingency plans for incidentmanagement, updatedas required. Monitoring Measures 1Check accident records and the procedureswhich are used to record incidents. 2. Audit clean up operations for any spills that occur. 3. 5-monthly checks on storagefacilities, general housekeepingwith repair or upgradeas needed. Addendum EnvironmentalReport JacobsG166Limited xxiv Issue 3.0/ November2001  TIC Takoradi Thermal Power Plant, ProposedExpansion Health and Safety Issues and Risk Management Health and Safetv Issues The T2 expansion project has been designed in accordance with a range of standards and industry specifications for its mechanical, chemical, electrical, civil, structural and architectural elements, including US Department of Labour's Occupational Safety and Health Administration (OSHA), World Bank Health and Safety Guidelines and Ghanaian Workers Rights Requirements. In addition, BVI, the EPC contractor for T2 are committed to operate under a corporate health and safety (H&S) plan which seeks to ensure a safe working environment for all personnel, clients and customers, consistent with governmental H&S requirements. This in turn provides policy and procedure guidance on a broad spectrum of issues, including those particularly highlighted by the World Bank/lFC guidelines, including for example training, emergency/medical injury, general safety, reporting and environmental protection. The operations and maintenance H&S manual for T2 has been prepared and is currently in use. The policies and procedures were prepared with due reference to the requirements of OSHA. Risk Manaaement Risk management was discussed in the 1999 SEIS. This identified that there would be a change in the risk of oil spills, fire and explosions or new risks occurring during the construction and operation of T2 compared to the situation associated with TI. However, appropriate mitigation measures have already been incorporated into the design and specification of the plant, equipment and management systems to assist in preventing accidents occurring. Training programmes and safety equipment set up for all stages of T2 to contain and manage any such incidents and to reduce the scale, nature and significance of any potential impacts that may result. Monitoring programme set up under T I will be continued for T2. Addendum EnvironmentalReport J98404B JacobsGlBBLimited xxv Issue 3.0/ November2001  TIC Takoradi Thermal Power Plant, Proposed Expansion Conclusions of the Addendum Specific to addressingthe environmentaland social issues requested by IFC/OPIC, it is concluded that due largely to the former land use of the T2 construction site and temporary storage and compound areas (Le. it had already been cleared and/or in use for TI) there has been no effect on natural habitats, forestry; cultural property; and involuntaryresettlement. Ghanaianworker's rights legislation does not permit the use of child or forced labour and the Contractor's EPC Agreement enforces this requirement. No such practices occur on the TTPP site (operationsand construction). In terms of pest management, those activities that are undertaken on site are small scale compared to the types of project referred to in OP 4.09. Given the health benefits associated with limiting the prevalence of mosquitoes and the small area to be sprayed with appropriate herbicides, the overall effect of T2 on this topic is expectedto be minorto negligible. As the fuel supply pipeline and SPM are not directly affecting an international waterway and T2 will share the existing facilities, it is concluded that there is no adverse effect on this issue. The World Bank's Pollution Preventionand Abatement Handbook indicates that local standards need to be complied with, or where relevant local guidelines do not exist the World Bank guidelines may provide a basis for negotiating site-specific agreementsbetweenregulatorsand enterprises. Generallyspeaking the IFC expects compliancewith both sets of guidelines. Although the air, water and noise monitoring programme has indicated high results on occasion, these have been attributed to specific short-term source difficulties that have subsequently been addressed. The T2 project should comply with the relevant guidelines for air and water quality and noise levels. It is considered that overall, there has been no significant adverse change to the environmental impacts (beneficial and adverse) described in the 1999 SEIS as a result of the minor changes to T2 since March 1999. This is on account of there being no substantial change to the design of the plant. While the construction phase has essentially extended, provided the appropriate construction phase mitigation measures are employed as discussed, any associated construction effects should continueto lastfor the duration of the constructionperiod only. With the upgrading and expansion of the existing TI environmental management policies and procedures to accommodate T2, the environmental quality monitoring and pollution preventionresponseprocedures,it is expectedthat the residualeffect of T2 will be minor. Recommendations laid out in the framework for the Environmental Managementand Monitoring Plan should also ensure a greater level of environmental protection. Addendum EnvironmentalReport JacobsGlBB Limited xxvi issue 3.0 / November 2001