Sohar Refinery Improvement Project Potential Lenders on behalf of

Transcription

Sohar Refinery Improvement Project
Independent Technical Consultant
Environmental Report
Prepared For
Potential Lenders on behalf of ORPIC
April 2014
Jacobs Consultancy Limited
Tower Bridge Court
226 Tower Bridge Road
London SE1 2UP United Kingdom
Phone: +44 (0) 20 7403 3330
Fax:
+44 (0) 20 7089 7750
Sohar Refinery Improvement Project
Independent Technical Consultant
Environmental Report
Prepared For
Potential Lenders
on behalf of ORPIC
For Jacobs Consultancy
Author:
Elizabeth Turk
Reviewer:
Glyn Johnson
April 2014
This report was prepared based in part on information not within the
control of the consultant, Jacobs Consultancy Limited.
Jacobs
Consultancy has not made an analysis, verified, or rendered an
independent judgment of the validity of the information provided by
others. While it is believed that the information contained herein will be
reliable under the conditions and subject to the limitations set forth
herein, Jacobs Consultancy does not guarantee the accuracy thereof.
Use of this report or any information contained therein shall constitute a
release and contract to defend and indemnify Jacobs Consultancy from
and against any liability (including but not limited to liability for special,
indirect or consequential damages) in connection with such use. Such
release from and indemnification against liability shall apply in contract,
tort (including negligence of such party, whether active, passive, joint or
concurrent), strict liability or other theory of legal liability, provided,
however, such release limitation and indemnity provisions shall be
effective to, and only to, the maximum extent, scope, or amount allowed
by law.
This document and the opinions, analysis, evaluations or
recommendations contained herein are for the use and benefit of the
Sponsor and the Beneficiaries (who have executed a Reliance Letter) of
the Letter of Appointment dated 28 May 2013 between Oman Refineries
and Petrochemicals Company and Jacobs Consultancy Ltd and the
liability of Jacobs Consultancy Ltd is expressly limited as provided in the
Letter of Appointment.
Neither the Work Product nor any information contained therein or
otherwise supplied by Jacobs Consultancy Ltd in connection with the
Project released by Oman Refineries and Petrochemicals Company
shall be used in connection with any proxy, proxy statement, proxy
soliciting materials, prospectus, Securities Registration Statement or
similar document without the express written consent of Jacobs
Consultancy Ltd.
Jacobs Consultancy Limited
Registered Office: 1180, Eskdale Road, Winnersh,
Wokingham RG41 5TU
Registered in England and Wales No. 2995682
Table of Contents
Page
Background ............................................................................................................................. 1
Project Area of Influence ........................................................................................................ 2
Scope of Work ......................................................................................................................... 5
National Legislation ................................................................................................................ 6
Overview ................................................................................................................. 6
National Environmental Permits and Licences ......................................................... 7
Assessment of the Project against International Standards ............................................... 9
Overview ................................................................................................................. 9
International Standards ............................................................................................ 9
Conclusions and Recommendations................................................................................... 32
-i-
Table of Contents
Figures
1
2
3
4
Page
Location of the Project Site within the SIPA ................................................................. 2
Project Area of Influence and Surrounding Communities............................................. 3
Project Area and Surrounding Industries (Current and Proposed) ............................... 4
Location of CAAQMSs 1 and 2 .................................................................................. 29
Tables
1
2
3
4
5
Page
Environmental Permits ................................................................................................ 7
International Environmental and Human Rights Treaties Applicable to the Project .... 11
List of Ratifications to ILO Labour Conventions by Oman .......................................... 12
Review of the Project against the IFC Performance Standards ................................. 13
Review of the Project against the Requirements of the Equator Principles ................ 33
- ii -
Background
The existing Sohar Refineries receive, by pipeline, a blend of Oman Export Blend (OEB)
crude oil and atmospheric residue as produced at the Mina-Al-Fahal (MAF) refinery. The
quality of this OEB crude oil has changed since the original Sohar Refineries were designed.
The crude has become significantly heavier and it is expected that this trend will continue
due to the blending of additional heavy crude oils.
These changes in crude quality are and will be posing operational constraints at the MAF
and Sohar Refineries. At the MAF refinery the sulphur recovery unit will limit the amount of
heavy gas oil that can be processed and any excess will have to be routed together with the
atmospheric residue to the Sohar Refineries.
In the Sohar Refineries the constraints are primarily in the Residue Fluid Catalytic Cracking
(RFCC) Unit. Constraints in RFCC operation are forcing the refinery to operate at reduced
throughput. The reduced RFCC throughput is also limiting the supply of required quantity of
propylene to Oman Polypropylene LLC (OPP). The Sohar Refineries is also only able to
meet about 30% of the committed naphtha quantity to Aromatics Oman LLC (AOL).
In order to overcome these constraints and to produce required quantity of products, Oman
Refineries and Petrochemicals Company LLC (ORPIC) wishes to upgrade the existing Sohar
Refineries configuration as well as carry out capacity expansion — the Sohar Refinery
Improvement Project (SRIP).
The expansion will require approximately 105 hectares of land which have been allocated
within the Sohar Industrial Port Area (SIPA), adjacent to the existing Sohar Refineries (see
Figures 1 and 2).
Although the proposed expansion project will enhance production at the existing Sohar
Refineries, the new process units and the dedicated utilities that will be developed at the
new refinery make it an independent refinery plant. Furthermore the land identified for
development is currently undeveloped and the project can be considered a “greenfield
development”.
During operation the project will employ approximately 300 people who will work over four
shifts. Refinery employees will be accommodated in rented apartments / accommodation in
the town of Sohar. During construction it is estimated that there will be a workforce of
approximately 4500, rising to 7000 during peak times. This workforce will be accommodated
in purpose built workers accommodation located outside of the SIPA boundary — location to
be determined.
This document, and the opinions, analysis, evaluations, or recommendations contained herein are for the sole use of the contracting parties. There
are no intended third party beneficiaries, and Jacobs Consultancy shall have no liability whatsoever to third parties for any defect, deficiency, error,
omission in any statement contained in or in any way related to this document or the services provided.
1
Project Area of Influence
The majority of the SRIP will be constructed within the SIPA on Plot number 18 which is
spread over 195 hectares of land area. The area is depicted in Figure 1 below. The refinery
will be developed in the northern portion of Plot 18 adjacent to the existing refinery, on an
area of 105 hectares. Plot 18 is located south of the existing refinery.
There are a total of five settlements, Al Ghuzayyil, Ghadfan, Al Khuwairiya, Majees, and Al
Hadd, identified within the Project Area of Influence. The project site itself is devoid of any
residential settlement as the SIPA is a designated industrial area. Access to SIPA is
restricted to authorized personnel only.
The following associated infrastructure will be required for the project and is to be
constructed outside of the boundaries of Plot 18:
•
Temporary workers accommodation — location currently undetermined, but will be
outside of the SIPA boundaries.
•
Seawater intake system located close to the existing seawater intake at the coast line
(see Figure 3). This will consist of four seawater intake pumps (three operating, one
standby) each of 14,000 m3/h pumping capacity, and an electrical substation. These
facilities will be built by Majis Industrial Services Company (MISC).
•
Coke storage and handling facilities at the port.
Figure 1: Location of the Project Site within the SIPA
Plot
18
N
Source: Figure 6-1: The Existing and Upcoming ORPIC Facilities within SIPA, SRIP EIA July 2012
2
Figure 2: Project Area of Influence and Surrounding Communities
N
Source: Figure 6-9: Project Influence Area: An Overview, ORPIC SRIP EIA July 2012.
3
Figure 3: Project Area and Surrounding Industries (Current and Proposed)
Seawater intake
Seawater outfall
SRIP
Source: Figure 6-10: Industries next to SRIP, ORPIC SRIP EIA July 2012.
4
Scope of Work
The following section:
•
Identifies and comments on the environmental laws, regulations, and procedures that
the project will have to comply with during construction and operation of the project.
•
Based on the detailed review of the Environmental and Social Impact Assessment
(“ESIA”) report and the Environmental Management Plan (“EMP”), this section of the
study assesses whether, from an environmental perspective, this project can be
expected to be in compliance with the Omani environmental regulations and other
recognised environmental standards for this type of project including World Bank
guidelines / Equator Principles and the environmental guidelines of the Export Credit
Agencies.
•
Confirms that project’s proposed facilities comply with the recognised guidelines in
the field of international Health and Safety regulations.
This review has been undertaken using information provided by ORPIC, supplemented by
information in the public domain.
5
National Legislation
Overview
In the Sultanate of Oman, the laws and regulations are issued as Royal Decrees (RDs) and
Ministerial Decisions (MDs). The project development and operation is required to be in
compliance with applicable environmental laws and regulations contained in various RDs
and MDs.
The Omani law on environmental protection, control and management is covered under the
basic law, the ‘Law for the Conservation of the Environment and Prevention of Pollution’ first
promulgated in 1982 as RD 10/82 and superseded in November 2001 as RD 114/2001. The
responsibility for the implementation of the environmental laws and regulations rests with
Ministry of Environment and Climate Affairs (MECA), which issues regulations, standards
and guidelines through MDs. Within MECA, the Director General of Environmental Affairs
(DGEA) is the authority responsible for environmental permitting, inspection and control in
the Sultanate of Oman. Recently, MECA has established a Director General of Climate
Affairs (DDCA), which is the authority to assess the potential aspects of projects with regard
to climate change. The Omani environmental laws and regulations (with regard to air
emissions, noise, wastewater, solid and hazardous wastes, hazardous materials, chemicals,
etc), that are potentially applicable for the project are listed in Appendix IV.
In addition to the environmental regulations discussed in the preceding sections, the project
will be governed by relevant regulations for addressing social issues. The social laws in the
Sultanate of Oman address aspects such as community involvement, local employment,
protection of cultural / heritage / archaeological sites, etc. Potentially applicable regulations
for the project are listed in Appendix IV.
In May 2008 an agreement was signed between DCMR (the environmental protection
agency of the local and regional authorities in Rijnmond, Netherlands) and the MECA of
Oman to cooperate in setting up the Sohar Environmental Unit (SEU). The goal of the SEU
is to control and monitor the environmental situation in the SIPA area by issuing
environmental permits, executing inspections, using enforcement if necessary and
monitoring the air, water, soil quality in the port area and surrounding residential areas. SEU
also controls nuisance like noise and odour. In addition to national legislation, the project will
take into account the Guidance Notes issued by the Sohar Environmental Unit (SEU) for
management of materials and wastes, industrial safety and environmental impact
assessment (EIA) for the industries within the SIPA. Many of SEU guidance notes and
requirements are based on European Union (EU) requirements specified under the Directive
96/61/EC Integrated Pollution Prevention and Control (IPPC) and Directive 96/82/EC
SEVESO II.
6
National Environmental Permits and Licences
The following presents a table of environmental permits and licences required for the project
and the current status of these permits.
Table 1: Environmental Permits
Permit
Issuing Authority
Status
Preliminary Environmental Permit (PEP) issued
upon approval of the EIA. The permit for
construction can be applied for once the PEP is
received.
MECA / SEU
Approval granted July
31 2013.
Final Environmental Permit
MECA / SEU
Can be applied for on
completion of
construction and can
be received one year
from start of
commercial operation
date.
Permit for marine disposal of return cooling
water and other treated liquid effluents
MECA / SEU
To be secured by the
Engineering,
Procurement and
Construction (EPC)
Contractor - application
not progressed to date
(18 March 2014).
Permit for disposal of treated wastewater (if
any) during construction phase
MECA / SEU
As above.
Permit for storage, handling, transportation and
disposal of hazardous wastes during
construction and operation.
MECA, SEU and Royal
Oman Police (ROP)
As above.
Permit for development of groundwater
boreholes
MECA / SEU
As above.
Permit for abstraction of groundwater
MECA / SEU
As above.
Permit for operating stationary emission sources
(stacks).
MECA / SEU
As above.
Permit to abstract water (if required).
Ministry of Regional
Municipalities and Water
Resources (MRMWR) /
Ministry of Health
(MOH)
As above
Permit for disposal of hydrotest water.
MECA / SEU
As above.
Permit for import, transportation, usage and
storage of radioactive material and explosives, if
required (mainly during construction phase).
MECA / ROP
As above.
Consent for setting up construction camps.
Liwa Municipality and /or
Sohar (if applicable)
As above.
Permit for setting up temporary desalination
plant (if required) during construction
MRMWR
As above.
7
Permit
Issuing Authority
Status
Approvals from the Ministry of Awqaf and
Religious Affairs (MARA), as required
MARA
As above.
National Heritage and Culture Approval
Ministry of Natural
Heritage and Culture
(MNHC)
Permit for installation of onsite sewage
treatment plant or approval for discharge of
sewage to municipal sewage treatment plant.
MECA / SEU
As above.
Permit for re-use of treated wastewater.
MECA / SEU
As above.
Permit for storage, handling and transportation
of chemicals and fuel used at the site during
MECA / SEU
As above.
Permit for installing onsite desalinisation plants
and disposal of wastewater.
MECA / SEU
As above.
Permit for dewatering.
MECA / SEU
As above.
Permit for use of industrial / laboratory gas
cylinders.
MECA / SEU
As above.
No objection letter from SEU for storage of
hazardous wastes at Liwa site
SEU
As above.
No objection letter from SEU for storage of nonhazardous wastes at Sohar waste collection site
or for any other solution proposed by ORPIC.
SEU
As above.
Permit for dumping of excess dredged material
into the sea (if required).
MECA / Ministry of
Transport and
Communication (MOTC)
As above.
In addition to the above, the contractors transporting/handling chemicals, fuels, other
hazardous materials and hazardous wastes will require relevant approvals/permits.
8
Assessment of the Project against
International Standards
Overview
The following focuses on noteworthy omissions and gaps of the project when assessed
against the requirements of the Equator Principles and International Finance Corporation
(IFC) Performance Standards (PS).
Discussion of the project’s proposed compliance with recognised health and safety
regulations are presented in regard to the relevant PS below.
International Standards
Overview
The Equator Principles are a voluntary set of standards intended to ensure that projects
financed by Equator Principle Finance Institutions (EPFIs) are developed in a manner which
is environmentally and socially responsible. The Equator Principles apply to all new project
financings with a total project capital cost in excess of US$ 10 million or more. There are ten
principles:
•
Principle 1:
Review and Categorisation
•
Principle 2:
Social and Environmental Assessment
•
Principle 3:
Applicable Social and Environmental Standards
•
Principle 4:
Action Plan and Management System
•
Principle 5:
Consultation and Disclosure
•
Principle 6:
Grievance Mechanism
•
Principle 7:
Independent Review
•
Principle 8:
Covenants
•
Principle 9:
Independent Monitoring and Reporting
•
Principle 10: Equator Principle Financial Institution Reporting.
For projects located in high income non-OECD (Organisation for Economic Co-operation
and Development) countries such as Oman (according to the World Bank Development
Indicators Database), Principle 3 requires the project to be compliant with the IFC PS and
the corresponding applicable industry IFC Environmental, Health and Safety (EHS)
Guidelines. The relevant IFC PS are as follows:
9
•
PS 1: Assessment and Management of Environmental and Social Risks and
Impacts
•
PS 2: Labour and Working Conditions
•
PS 3: Resource Efficiency and Pollution Prevention
•
PS 4: Community Health, Safety and Security
•
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural
Resources
•
PS 8: Cultural Heritage.
The following PS are considered not applicable to the project for the following reasons:
•
PS 5: Land Acquisition and Involuntary Resettlement — the Government has made
the decision to relocate nearby residents away from SIPA, due to existing poor
environmental conditions. ORPIC have stated that the Government has developed
an action plan. It is understood that three settlements are to be affected involving
between 1000-2000 people. Affected people are to be relocated from SIPA to an
area approximately 8km inland. It is understood that people will be compensated with
like for like accommodation, with additional houses being provided for large families
with multiple nuclear families sharing one residence. The Government appointed
consultants to design the new residences and a contractor is about to be appointed.
ORPIC have stated that they have no involvement in this relocation.
•
PS 7: Indigenous People — no indigenous people have been identified within the
project area of influence and no impacts are foreseen.
•
PS 8: It is not foreseen that any areas of cultural importance will be impacted. There
is a grave located on the project site which belongs to a local dignitary. This grave is
to be fenced off and kept outside of the development area.
The applicable IFC EHS Guidelines for this Project are:
•
IFC EHS General Guidelines (April 2007).
•
IFC EHS Guidelines for Petroleum Refining (April 2007).
10
Applicable International Conventions
Table 2 summarises the international environmental and human rights treaties that Oman is
currently a signatory to and for which consideration would be required by the project.
Table 2: International Environmental and Human Rights Treaties Applicable to the Project
International Conventions
Environmental
Convention on Biological Diversity
United Nations Framework Convention on Climate Change
Kyoto Protocol
Convention on International Trade in Endangered Species of Wild Flora and Fauna (CITES)
United Nations Convention on the Law of the Sea (UNCLOS)
Vienna Convention for the Protection of the Ozone Layer
Montreal Protocol on Substances that deplete the Ozone Layer
Protocol of 1978 International Convention for the Prevention of Pollution from Ships (MARPOL) 1973
Convention on Migratory Species
Convention on Wetlands (Ramsar)
Human Rights*
Geneva Conventions I, II, III, IV
ICERD (International Convention on the Elimination of All Forms of Racial Discrimination 1965)
ICCPR (International Covenant on Civil and Political Rights) 1966
ICCPR – Optional Protocol (OP) 1 1966
ICCPR - OP2 1989
ICESCR (International Covenant on Economic, Social and Cultural Rights) 1966
OP-CEDAW (Optional Protocol to the Convention on the Elimination of Discrimination against
Women) 1999
CAT (Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment)
1984
OP-CAT 2002
Convention on the Rights of the Child (CRC) 1990
CRC Optional Protocol Armed Conflict 2000
CRC Optional Protocol Sale of Children 2000
ICRMW (International Convention on the Protection of the Rights of All
Migrant Workers and Members of Their Families) 1990
Disability Rights Convention
Source: http://www.geneva-academy.ch/RULAC/state.php?id_state=162
11
Oman has been a member of the International Labour Organisation (ILO) since 1994 and
has ratified the following labour related conventions identified in Table 3.
Table 3: List of Ratifications to ILO Labour Conventions by Oman
No.
Name of ILO Convention Ratified
C. 29
Forced Labour Convention, 1930 (No. 29)
C. 105
Abolition of Forced Labour Convention, 1957 (No. 105)
C. 138
Minimum Age Convention, 1973 (No. 138)
Minimum age specified: 15 years
C. 182
Worst Forms of Child Labour Convention, 1999 (No. 182)
Source: http://www.ilo.org/dyn/normlex/en/f?p=1000:11200:0::NO:11200:P11200_COUNTRY_ID:103441
IFC Performance Standards
Table 4 provides a summary of key gaps and omissions of the project when assessed
against the requirements of the IFC PS. It also provides recommendations and timescales
for addressing gaps.
12
Table 4: Review of the Project against the IFC Performance Standards
Performance
Standard
Discussion
Timescales for
Implementation of
Recommendation
Recommendations
PS 1: Assessment and Management of Environmental and Social Risks and Impacts
National EIA
requirements
-
-
A national EIA has been produced and submitted to MECA for
approval. A PEP is expected in July 2013. See National
Environmental Permits and Licences above for further details.
There are omissions and gaps within the national EIA when
compared against international requirements.
Gaps and recommendations for bridging gaps are discussed
further below.
See recommendations below for
individual topics.
See timescales on
individual topic discussions
below.
As soon as design
requirements and locations
are confirmed.
What does the
EIA cover?
The EIA covers only the main project site i.e. those developments
found within Plot 18 – see Figure 1 above. Additional
infrastructure is going to be / maybe required to be developed to
support the project i.e. workers accommodation, coke storage and
conveyors at the port (TBC if under ORPIC or third party
responsibility). Associated infrastructure outside of Plot 18 which
ORPIC intends to build as part of the project should be subject to
appropriate environmental assessment i.e. marine intake and
outfall and coke storage and handling at the port.
Once the location for the temporary
workers accommodation and
responsibility for the coke storage
and conveyor at the port is
determined the associated
environmental impacts should be
assessed and included within the EIA
or as an addendum.
Consultation and
information
disclosure
In line with PS 1, the project will need to identify the relevant
stakeholders and prioritize directly affected communities (if any).
Additionally a formal Stakeholder Engagement Plan (SEP) is
required under PS 1. This SEP should outline all consultation and
information disclosure requirements for the lifecycle of the project.
The SEP should be a “live” document to be updated as the project
progresses.
A template for a SEP has been
provided by HMR. This template
should be developed into a live
document with actions implemented
throughout the lifecycle of the project.
Cumulative
Impacts
No cumulative impact assessment has been undertaken. Given
the location of the proposed refinery adjacent to, three existing
ORPIC refining facilities within a designated industrial area,
See recommendations below for
individual topics.
-
Prior to construction.
Periodic reviews and
updates of the SEP
should be undertaken
throughout the project
lifecycle to ensure the
contents are relevant
for the project at the
time.
See timescales on
individual topic discussions
below.
13
Performance
Standard
Discussion
Recommendations
Timescales for
Implementation of
Recommendation
consideration of cumulative impacts should be paramount to the
EIA. Typically within an EIA, cumulative impacts from other
existing facilities would be addressed by inclusion of baseline
monitoring results within quantitative modelling scenarios and
discussion of impacts to sensitive receptors. Cumulative impact
assessment should also take into consideration qualitative
discussion on impacts from future planned or proposed
developments in and around the project. Figure 3 illustrates the
range of existing and future activities that are proposed in SIPA.
Further discussion on cumulative impact omissions are discussed
in relevant topics below.
Trans-boundary
impacts
SIPA is located approximately 100km south of the United Arabia
Emirate (UAE) and on the edge of the Arabian Gulf. Transboundary impacts especially from effluent discharges, ballast
water from vessels, marine debris and spills from vessels could
occur and have not been assessed within the EIA.
Nevertheless, we consider risks from trans-boundary impacts are
considered low assuming development and implementation of
appropriate management and mitigation plans and active health,
safety and environmental (HSE) management throughout
construction, operation and decommissioning.
Inclusion of actions within HSE
management and mitigation plans to
prevent potential trans-boundary
impacts.
HSE plans to be produced
prior to construction.
Implementation of plans to
be assessed during ongoing lenders and third
party monitoring.
14
Performance
Standard
Discussion
Recommendations
Timescales for
Implementation of
Recommendation
PS 2: Labour and Working Conditions
Human
resources (HR)
policies and
procedures
Working
conditions and
terms of
employment
No details of HR policies and procedures have been provided for
review.
-
-
-
-
-
1
HR policies and procedures should
be developed and aligned to meet
national and international
requirements.
During EPC contract
development
Within the draft EPC contract there is a requirement that
places responsibility for recruitment of staff and labour on the
EPC Contractor. There is also a requirement that the
contactor shall pay rates of wages and observe conditions of
labour which are not lower than those established for the
trade or industry where the work is carried out.
Within Oman there is a requirement that 30% of a workforce
is sourced from Omani nationals. It is recommended that
where practical recruitment is sourced from local
communities.
The contractual and legal obligations in place are deemed
reasonable to ensure appropriate terms and conditions for
workers. On-going lenders monitoring during construction and
operation will confirm appropriate implementation of these
requirements.
Consider including the EPC contract
preference to employment of staff
from local communities where
practical.
During EPC contract
development.
Workers accommodation and facilities should be provided in
line with IFC / European Bank of Reconstruction and
1
Development (EBRD) workers accommodation guidance .
These worker accommodation guidelines are stringent and
costs for provision of accommodation to these standards
should be considered early in project development.
The EPC contract should make
specific reference to contractor
requirement for compliance to the
IFC/ EBRD’s worker accommodation
guidance document and monitor
implementation to ensure
compliance.
Prior to signing of the EPC
contract.
http://www1.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/ifc+sustainability/publications/publications_gpn_workersaccommodation
15
Performance
Standard
Discussion
Timescales for
Implementation of
Recommendation
Recommendations
Workers’
organizations
EPC Contractor / ORPIC will comply with national law regarding
workers organisations
-
-
Grievance
mechanism
ORPIC have confirmed they have an existing workers’ grievance
mechanism which will be used for construction and operation of
the project.
Contractors should inform employees
of the grievance mechanism at the
time of hiring, and make it easily
accessible to them. The mechanism
should involve an appropriate level of
management and address concerns
promptly, using an understandable
and transparent process that
provides feedback to those
concerned, without any retribution.
The mechanism should not impede
access to other judicial or
administrative remedies that might be
available under law or through
existing arbitration procedures, and
ensure arrangements are made to
implement the mechanism when
applicable.
Implementation of existing
grievance mechanisms prior
to the recruitment of
construction workforce.
Protecting the
workforce – child
and forced
labour
Omani law prohibits the employment of persons under 18 years
old. Additionally Oman is a signatory to ILO requirements which
should prevent forced or child labour.
The EPC contract should make
specific reference to contractor
requirement for national and
international compliance and monitor
implementation to ensure
compliance.
Prior to issue of the EPC
contract.
Occupational
health and safety
During construction the EPC Contractor will be responsible for
developing and implementing appropriate HSE plans and
procedures. Once the EPC Contractor hands back to ORPIC for
operation, ORPICs existing HSE team, plans and procedures will
be implemented at the project. ORPIC will take corporate
responsibility for ensuring the EPC Contractor is complying with
national requirements on HSE. ORPIC typically undertake a
EPC Contractor to develop and
implement HSE plans, procedures
and management systems to meet
national and international
requirements.
Prior to construction
commencing and
implemented throughout
construction.
16
Performance
Standard
Discussion
Timescales for
Implementation of
Recommendation
Recommendations
monthly inspection during construction activities to audit
appropriate HSE implementation by contractors. Quarterly auditing
is also undertaken by ORPIC of third party consultant on behalf of
ORPIC.
PS 3: Resource Efficiency and Pollution Prevention
Water – intake
and discharge
The water supply for the project will be sourced from seawater.
The project will have a dedicated seawater intake facility at the
seawater intake pumping station (SWIPS) located within the SIPA.
The facility will comprise four seawater intake pumps (three
3
operating, one standby) each of 14,000 m /h pumping capacity,
and an electrical substation. These facilities will be built by MISC.
The intake water will be electro-chlorinated by addition of
hypochlorite. Two buried supply lines will transport the intake
seawater from the SWIPS to the refinery. No assessment within
the EIA has been given to the impacts during construction and
operation of this infrastructure. Although to be constructed by
MISC, the project EIA should consider the impacts of increased
abstraction on marine flora and fauna including a cumulative
impact assessment with other neighbouring industries.
-
Qualitative assessment of
perceived impacts from the
intake and outfall will be
provided by HMR, based on their
existing knowledge of the marine
environment and third party
monitoring data.
-
Final quarter of 2014.
Aquatic organisms drawn into cooling water intake structures are
either impinged on components of the cooling water intake
structure or entrained in the cooling water system itself. In the
case of either impingement or entrainment, aquatic organisms may
be killed or subjected to significant harm. In some cases (e.g., sea
turtles), organisms are entrapped in the intake canals. No details
are given within the EIA of the marine sensitivity at or within the
area of influence of the proposed intake structure. There could be
potential impacts if the cooling water intake structures are located
in or near habitat areas that support threatened, endangered, or
other protected species or where local fishery is active. The
potential for impacts to threatened or endangered species is
17
Performance
Standard
Discussion
Recommendations
Timescales for
Implementation of
Recommendation
considered limited given the disturbed industrial setting, however,
fishing has been identified as a valuable commercial and
subsidence activity for nearby local communities and no details
are provided on impacts. Measures to prevent, minimize, and
control environmental impacts associated with water withdrawal
should be established based on the results of the EIA. This does
not appear to have been undertaken nor preventative measures
identified.
The water system proposed for the plant will be designed to
produce desalinated and demineralised water for distribution within
the plant for use in steam generation, and as potable and service
water. The desalinisation plant will be designed to provide three
distillation trains – two in operation and one standby. Each train
will be capable of producing 164 t/h of desalinated water. Effluent
from the desalinisation plant will be discharged to the centralised
Seawater Intake and Return System (SWIRS) channel and
subsequently to sea.
The project will have its own designated wastewater treatment
plant (WwTP). The treated wastewater from the WwTP and the
wastewater stream from the cooling water system will be
discharged into the SWIRS channel near the western corner of the
project site (see Figure 3). The discharged wastewater will mix in
the channel with the existing discharge from the SIPA. The water
in the SWIRS channel is supposed to be compliant with the marine
discharge standards (MD 159/2005) and the wastewater from the
new refinery will be treated to this standard in its WwTP. Thus it is
anticipated that the discharge from the WwTP will not result in a
deterioration in the quality of water discharged to sea at this
location.
The quantities of effluent to be discharged from the desalinisation
plant and once-through water cooling are not specified within the
18
Performance
Standard
Discussion
Recommendations
Timescales for
Implementation of
Recommendation
EIA, but are considered to be a sizeable quantity. The waste
stream resulting from desalination plants consists of highly
concentrated saline brine. High salt concentrations and
fluctuations of salinity can impact on marine organisms near outfall
points. Although it is considered that dilution of this saline brine will
occur within the SWIRS, it may adversely affect the discharge
water quality. Cumulative impacts should have been considered
and dilution confirmed within the EIA.
Ballast water is a major source of biological pollution (transference
of non-native species) from one country to another. Such species
are a major threat to national coastal and marine natural
resources, including human health. Examples of such invasions
include diseases, e.g. cholera; toxic algae, predatory species, etc.
No consideration of impacts from ballast water has been given
within the EIA. It is understood that approximately 90% of product
will be transported by ship. The remaining 10% by trucks.
Turbidity –
marine impacts
Surface water quality would be impacted during construction as a
result of increased suspended solids in the water column in the
vicinity of pilling and dredging activities and construction vessels.
During operation disturbance to sediments from vessel
movements would cause temporary turbidity along the transit
pathway. No consideration is given to impacts to the marine
environment from turbidity during construction and operation.
Recommendation as above, HMR to
provide professional judgement of
potential impacts from turbidity.
Final quarter of 2014.
Groundwater
The groundwater in the area has been impacted by saline intrusion
and is no longer used for nearby agriculture. Groundwater will be
abstracted from the coastal side of the SIPA for the project.
Groundwater from existing boreholes is also used for current
operations. Permits will be required for construction of new
boreholes and abstraction of groundwater for the SRIP.
-
Determine appropriate
measures during facility
design.
The air quality assessment undertaken for the project has a
number of limitations and omissions. Please refer to
A number of recommendations are
proposed regarding air emissions,
Air
-
Measures to prevent releases
from contaminating ground or
groundwater should be included
in the facility design.
Protection of groundwater
should be included within EMPs.
Please see supplementary
discussion below.
19
Performance
Standard
Discussion
supplementary discussion presented below this table.
Odours
ORPIC have historically received complaints from nearby
communities regarding odours from the WwTP from the existing
refineries.
Greenhouse
Gases (GHGs)
The project will produce more than 25,000 tonnes of carbon
dioxide (CO2) equivalent annually.
As a requirement of PS 3, a facility producing more than 25,000
tonnes of CO2 equivalent annually, must quantify direct emissions
from the facilities owned or controlled within the physical project
boundary as well as indirect emissions associated with the off-site
production of energy used by the project. PS 3 requires the
quantification of GHG annually in accordance with internationally
recognised methodologies. GHG emissions must be disclosed in
for example annual reports.
Noise
-
HMR have confirmed that the project will meet the required
national noise limits at the boundary of the SIPA closest to
residential areas. However, on-going noise monitoring is
recommended to confirm limits can be met.
Wastes
-
Construction projects have the potential to generate large
volumes of waste that can be avoided through proper
planning of the work.
Refineries generate solid wastes and sludges with a range of
approximately 0.01 – 2 kg per tonne of crude processed
(before waste treatment). According to the World Bank, 80%
-
Timescales for
Implementation of
Recommendation
Recommendations
please see supplementary discussion
below.
- Odours should be minimised
from the WwTP at the new plant,
through use of appropriate BAT
measures identified within the
EU Bref note on Common Waste
Water and Waste Gas
Treatment Management
Systems in the Chemical
Section.
Odour minimisation should
be considered during
finalisation of detailed
design.
Calculate and disclose annual GHG
emissions in annual reports.
Assessment to commence
on start of operations with
first annual report in year
two. .
-
On-going throughout
Undertake regular noise
monitoring at the fence line and
nearby residential receptors
throughout construction and
operation, to confirm compliance
with national noise limits.
A waste management plan (WMP)
should
be
developed
and
implemented for construction and
operation. The waste management
plan should identify ways to prevent,
minimise, reuse and recycle wastes
-
-
WMP developed and
implemented for
construction.
WMP developed and
implemented for
operation.
20
Performance
Standard
Discussion
-
-
-
Ground
conditions
Recommendations
Timescales for
Implementation of
Recommendation
of those solid wastes maybe considered hazardous because
of the presence of toxic organics and heavy metals.
Omani national legislation on hazardous wastes (MD 18/93),
confirm requirements for storage, handling and disposal of
hazardous wastes.
Municipalities are responsible for collection and management
of all municipal solid wastes in the Wilayat. The wastes are
collected by Municipality in dedicated collection trucks and
transferred to the waste dumpsites within the Wilayat. The
dumpsites are also managed and maintained by the local
municipality. However, the Oman Environmental Services
Holding Company formed by a Royal Decree in August 2009,
is to take over the waste management responsibilities from
the municipalities and ensure proper management of all solid
wastes in the Sultanate. Disposal of non-hazardous industrial
solid wastes is the responsibility of respective industries and
this is usually sent through the licensed contractors of
municipalities.
where practical.
Presently there is no scientific or engineered way of disposal
of the hazardous solid wastes and these are currently being
stored within the generating facilities and then shipped to the
Philippines under the requirements of the Basel Convention.
However, for the SIPA, a centralized hazardous waste
storage yard has been constructed in Liwa and is currently
being utilized by the industries.
It is not sustainable to store
hazardous solid waste without having
a permanent treatment or disposal
facility. ORPIC should engage with
other companies in the SIPA to work
on a collective solution, which may
involve commissioning a specialist
company to develop and provide a
suitable facility for hazardous waste.
As this activity may take
several years to achieve its
objective, work on this
should be started as soon
as possible.
A desk study (pre-construction soil
condition survey) and preliminary risk
assessment should be undertaken to
assess the potential for
contamination in the development
plot. This should identify sources of
The desk study and
preliminary risk assessment
should be undertaken pre
construction, to enable an
appropriate mitigation
strategy to be developed if
A total of eight soil samples were taken over the 192 hectare site.
No environmental quality standard (EQS) exceedances are noted
when compared against the US EPA standards. Eight samples will
not be representative of the condition of the whole site and the
potential for ground contamination cannot be discounted due to
the nature of the adjacent operations.
Design decisions can significantly
contribute to the potential for
resource efficiency during the
construction phase. A considerable
body of guidance is now available to
assist in the planning of construction
projects for avoidance of waste.
These should be considered.
21
Performance
Standard
Traffic and
transport
Discussion
Recommendations
Contamination could be present in the development plot as a
result of aerial deposition or migration via groundwater or surface
waters of pollutants from the nearby industrial operations.
Development work could result in contamination being mobilised
(e.g. as a result of piling), harm to construction workers, harm to
new buildings or building services, or harm to the new users of the
site (e.g. by vapour intrusion into new buildings).
If significant contamination is present, it could result in serious
delays if it is not found until construction is underway or could
result in costly liabilities following construction.
contamination and the potential for
harm to occur during or after
construction of the new development.
If a significant potential risk from
contamination is suspected, further
investigation and/or mitigation
measures should be taken to
manage the risks. This assessment
will also provide a robust baseline for
ORPIC to benchmark soil condition
pre and post construction.
If required a ground contamination
watching brief should be
implemented during construction to
identify unexpected contamination. If
contamination is noted then works
should cease at this location and a
specialist called to determine an
appropriate management strategy.
- Given the increased levels of
transportation required during
construction and operation, a
traffic management plan (TMP)
should be developed and
implemented, with disclosure to
local communities. The TMP
should be appropriate to the
nature and scale of transport
movements and location of
communities. A outline structure
for a proposed TMP has been
provided by ORPIC.
- Local communities should be
informed of wide or abnormal
Limited impact assessment is provided within the EIA regarding
transportation to and from the site of products and raw materials,
or the impacts on third parties and sensitive receptors from the
transportation of these goods. No indication is given of the nature
or scale of transportation required during operation, nor the
proposed forms of transport. However, it is understood that
approximately 90% of product will be transported by ship. The
remaining 10% by trucks. The majority of the local communities
surrounding SRIP have built up around the main roads and
motorways and many of these communities are fishing
communities which could be impacted by for example, increased
ship traffic and restriction of access to fishing areas.
Timescales for
Implementation of
Recommendation
required and avoid delays
to the project.
Implemented throughout
construction.
-
-
-
TMP- developed for
implementation during
construction.
Communication to local
communities prior to
abnormal or wide
loads.
Movement restrictions
obligated for contractor
and operational
compliance.
22
Performance
Standard
Discussion
Recommendations
-
Spills and
emergency
response
procedures
The EIA makes reference to the requirements of the EU Seveso-II
Directive as a basis for analysis and provision of safety aspects for
the project. HMR provided a safety assessment for the PEP
approvals and the existing Emergency Response Plans for
facilities will be used for SRIP. .
-
Energy efficiency
Operators should aim to maximize energy efficiency in the design
of facilities (e.g. opportunities for efficiency improvements in
utilities, fired heaters, process optimization, heat exchangers to
minimize energy use). HMR have confirmed that the project has
incorporated the principles of the EU best available technique and
energy / resource efficiency has been considered by CB&I during
the development stages of the project.
Timescales for
Implementation of
Recommendation
traffic loads passing their
communities.
Traffic movements should be
restricted during the night, at
weekends and religious days to
afford the local communities
some respite from disturbance.
Update the existing Emergency
Response Plan to incorporate
requirements for SRIP.
Prior to operation of SRIP.
EPC Contractor to include training on
community aspects as part of
employee induction.
Implemented throughout
construction.
PS 4: Community Health, Safety and Security
Community
health and safety
The risks to the local community from the construction and
operation of the project are considered minimal assuming
appropriate implementation of HSE management plans. There will
be an increase in the number of people in the area during
construction which could cause concern for the local community,
especially if there are cultural differences. The construction
workforce is estimated as 4500 rising to 7000 during peak times.
23
Performance
Standard
Discussion
Timescales for
Implementation of
Recommendation
Recommendations
Security issues and the other requirements of IFC PS4 to manage
this process are discussed below.
Infrastructure
and equipment
safety
No information has been provided on the techniques used for
construction of the infrastructure. It is important to ensure that the
design, construction, and operation and decommissioning of the
plant and all associated infrastructure are in accordance with good
international industry practice.
Include a requirement within the EPC
contract to require that international
good practice is adhered to for any
infrastructure to be constructed in, or
outside of the main plant boundaries.
Prior to signature of the
EPC contract.
Hazardous
materials safety
The project will use and create a number of hazardous
substances. It is important that good practice measures for the
storage, handling and disposal of any hazardous materials or
substances on site are implemented within relevant plans and
management systems.
Ensure that an up to date list of
hazardous materials, with up to date
material safety data sheets, is
maintained by the project and made
available to local emergency
services.
The hazard properties of the
substances held on site should be
taken into consideration for the
design of storage, handling and
process use.
Throughout the project.
Emergency
preparedness
and response
(EPR)
It is understood that ORPIC will implement existing EPR for the
SRIP. The EPR should be disclosed to the local communities.
-
-
Community
exposure to
disease
Potential risks to community health include the spread of
communicable diseases including HIV/AIDS a result of the
incoming construction labour force.
Security
-
-
Security personnel will be employed at the site during
Update the existing ERP to
include the SRIP.
Ensure the ERP is disclosed to
the local communities.
As part of site induction training, the
contractor should inform workers of
HIV/AIDS risks and protection to
minimise risk of infection to workers
and communities.
- In accordance with the
EPR plan to be update
prior to operation of
SRIP.
Prior to and during
construction.
-
Prior to security
24
Performance
Standard
Discussion
-
Recommendations
construction and operation. No information has been provided
with regards to the process for selecting a security services
provider.
Crime risks to the community caused by an influx of workers
to the area have not been considered.
-
Grievance
Mechanism
ORPIC have confirmed that existing community grievance
mechanisms exist which will be used for the project. These
grievance mechanisms and forms of communication i.e. internet,
phone, personal etc exist for the facilities. Complaints from local
communities are monitored and responded too on a regular basis.
Social
Management
Plans
Development and implementation of the social management plans
recommended by the project environmental consultants HMR
Consultants, within their document “Bridge Document for Social
Management Plans Sohar Refinery Expansion Project”, December
2013.
requirements of PS4, a
formalised security policy, to
include criteria for hiring security
personnel, training requirements
and procedures for investigating
allegations of reported unlawful
action by contracted firms
should be developed and
implemented. This aspect
should be closely monitored.
An accommodation
management plan should be
produced in accordance with
international guidelines and
particular consideration should
be given to the siting and
security of workers
accommodation to manage
impacts of an influx of workers
on local communities.
-
Timescales for
Implementation of
Recommendation
personnel being hired.
Prior to construction
accommodation being
siting and developed.
-
HMR Consultants, the project
environmental consultants have
identified and recommended the
development and implementation of
a number of social management
plans and community initiatives
which they recommend ORPIC
All recommended plans to
be developed and
implemented prior to the
appropriate stage in project
development.
25
Performance
Standard
Discussion
Timescales for
Implementation of
Recommendation
Recommendations
adopt.
PS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Protected
species /
biodiversity
-
The site is of limited ecological interest with no protected or
endangered species identified within the EIA.
The EIA does not consider impacts to the marine environment
from increased abstraction, discharge and vessel movements.
There is mention of coral habitats within the EIA, although this
is not expanded on nor impacts discussed in any detail. HMR
have confirmed they consider it unlikely that coral still exists
given the professional knowledge of the area and the
industrial activities that have taken place.
-
-
-
-
Ecosystem
Services
No assessment is included within the EIA relating to ecosystem
services. However, HMR have confirmed they consider it unlikely
that there will be any impacts to relating to ecosystem services
from the project.
26
Supplementary Discussion on Impacts to Air
The General IFC EHS Guidelines advise that ‘relevant standards’ with respect to ambient air
quality are national legislated standards or, in their absence, the current World Health
Organisation (WHO) Air Quality Guidelines or other internationally recognised sources.
Where a host country’s legislated standards are less stringent than either the WHO or other
internationally recognised sources, the IFC acknowledge that it is acceptable to use the
national legislated standards as the principal standards that the project is assessed against.
National legislated ambient air quality standards are available and have therefore been used
within the EIA to determine air quality impacts. However, for comparison purposes the EIA
includes reference to the US EPA NAAQS (US Environmental Protection Agency National
Ambient Air Quality Standards).
The General EHS Guidelines specifically refer to the European Union Directives as being an
‘internationally recognised source’ of ambient air quality standards. Although numerically
equal to the WHO standards for nitrogen dioxide (NO2), the EU legislation introduces a
threshold of tolerance to account for exceptional, worst case episodes. This translates as a
limit not to be exceeded more than a certain number of times, and can be expressed as a
‘percentile’. In an assessment of human health effects, which takes account of a relevant
exposure period, this approach is considered more appropriate.
The IFC General EHS Guidelines suggest that, as a general rule, emissions should not
contribute more than 25% of the difference between the background pollutant concentrations
and the relevant air quality standards to allow additional, future sustainable development in
the same airshed.
The EIA assessed potential impacts to air quality under normal and upset operating
conditions (Scenario 1 and 2, respectively). Continuous Ambient Air Quality Monitoring
stations (CAAQMS) were placed at two positions on the site boundary to collect background
pollutant concentrations for 15 days in August 2011.
The EIA presents the ambient air quality as monitored in August 2011 at the project site, the
predicted ground level concentrations (GLCs) during operation of the refinery, and the
maximum resultant concentration (defined as the average baseline concentration + the
maximum GLC from the refinery) against relevant national and international standards. This
appears to provide a very conservative basis for the assessment.
27
The following presents some key discussion points regarding air emissions in relation to the
project:
1. The results presented within the EIA demonstrate that the maximum resultant ground
level concentrations are below the national AAQS with the exception of particulates
(PM10). Resultant concentrations for PM10 are as follows:
o
Scenario 1 (normal operating conditions)
–
117
µg/m3
o
Scenario 2 (upset conditions)
–
81
µg/m3
o
Omani AAQS
–
125
µg/m3
o
EU / WHO AAQS
–
50
µg/m3
High levels of PM10 are attributed within the EIA to dust from neighbouring
construction works, which is a plausible explanation. However, the project is
currently planning to use open stockpiles of coke, which would further increase
ambient PM10 levels. Under the requirements of the IFC general environmental,
health and safety guidelines for air, ORPIC have a commitment to ensure:
o
Emissions do not result in pollutant concentrations that reach or exceed relevant
ambient quality guidelines and standards by applying national legislated
standards, or in their absence, the current WHO Air Quality Guidelines or other
internationally recognized sources;
o
Emissions do not contribute a significant portion to the attainment of relevant
ambient air quality guidelines or standards. As a general rule, this Guideline
suggests 25 percent of the applicable air quality standards to allow future
sustainable development.
Currently PM10 levels far exceed the EU / WHO ambient air quality standards which
are considerably more stringent than the Omani national ambient air quality
standards, for which the plant is predicted to be compliance with. Given the high
existing baseline concentrations of PM10, during construction and operation of SRIP,
it will be essential that the highest standards of dust suppression measures are
employed to prevent PM10 pollution worsening. This should include minimisation of
particulates from handling and processing of coke to prevent further degradation of
the airshed from particulate emissions.
2. Predicted GLCs for all monitored emissions for scenario 1 (normal operations) fall
below the IFC 25% threshold. The use of low NOx burners and software to optimise
combustion should be considered to ensure levels do not exceed the IFC threshold
level.
3. The EIA does not fully explain the stack height determination process undertaken. A
list of proposed stack heights is included, which has been based on the Omani air
quality regulation MD 118/2004 which specifies minimum stack heights.
4. Ambient air quality monitoring was only carried out for a total of fifteen days at two
different locations. The mobile ambient air monitoring stations locations are shown in
28
Figure 4 below. The EIA reports that the prevailing wind direction for CAAQMS–1
was from east–southeast (sea towards land) and CAAQMS–2 was from the west
(land to sea).
Figure 4: Location of CAAQMSs 1 and 2
N
Source: Figure 6-7: CAAQMS Locations at SREP Site, ORPIC SIPR EIA.
The fifteen days monitoring do not provide a representative analysis of ambient air
quality. Typically you would expect to see at least six months and ideally twelve
months of ambient air quality data on which to base your assessment.
ORPIC has confirmed that historically, there have been issues with environmental
performance at their facilities including air emissions. This appears to be consistent
with press reports indicating that local residents are being re-located due to air
pollution from the existing adjacent ORPIC refineries (located to the north of the
project site). However, ORPIC has implemented a wet gas scrubber at the existing
facilities and SOx levels have subsequently fallen from levels in the region of
2460 mg/Nm3 to levels below an emission limit threshold set by SEU of 780 mg/Nm3.
Within the air quality assessment, you would expect to see identified impacts of
predicted emissions on “discrete” or “sensitive” receptors. Sensitive receptors are
categories of the population which may be particularly vulnerable to the effects of
poor air quality, e.g. schools, hospitals and residential areas.
The overall purpose of the air quality assessment is to compare predicted pollutant
concentrations with the relevant standards identified above, using the appropriate
averaging period for the likely period of exposure at specific locations.
29
For the purpose of the modelling assessment, the standards should have then been
compared against concentrations predicted at sensitive receptors which are located
within identified residential areas and the significance criteria applied to those
concentrations. Sensitive receptors should also include permanent workers
accommodation (if applicable). This prediction of concentrations at sensitive
receptors has not been discussed, nor results tabulated within the EIA. From the
GLCs contours presented within the EIA, it is considered that, given the distances to
local communities, impacts should not be felt, however, this assessment should be
provided.
5. No cumulative impact assessment has been considered. Given the scale of the
adjacent refineries and surrounding industrial area, this is considered a significant
omission. Cumulative impact assessment should be undertaken and qualitative
discussions of future impacts from development of other industries post operation of
SRIP provided.
6. Although trans-boundary impacts are considered unlikely, no assessment or
discussion is given of trans-boundary air quality impacts.
7. No EVLs are given or recommended within the EIA or EPC contract.
Jacobs Consultancy recommendations:
1. Permanent ambient air monitoring stations should be installed and commissioned at
least six months prior to construction to gather a suitable baseline of the ambient air
conditions. The location for siting of these monitoring stations should be undertaken
by a suitably qualified air quality specialist / MECA to ensure appropriate monitoring
results, taking into account the surrounding industries. Consideration should be
given to installing a monitoring station within one of the local communities.
This baseline, plus existing monthly monitoring baseline data should be used to
remodel the air quality impacts within the EIA and also to be held as a record to
protect the plant in case of future claims regarding degradation of ambient air quality
from their operations. The re-modelling should include assessment of impacts at
sensitive receptors.
2. Given the high existing baseline concentrations of PM10, during construction and
operation of SRIP it will be essential that the highest standards of dust suppression
measures are employed to prevent PM10 pollution worsening. This should include
ensuring appropriate technologies and processes for the handling and management
of coke to minimise PM10 levels including minimising the use of open storage areas
as proposed inside the battery limits. It has been agreed that the SRIP will provide
storage of up to 12 days (10 days storage (to be used in emergencies only) plus
2 days of regular storage with additional in silos) inside the battery limits. Hence in
normal operations the refinery will operate with 2 days of coke storage and will rely
on a larger enclosed store at the port. It has been agreed that the open stores of
coke will be dampened with water spraying to minimise particulate emissions. Please
reference to Jacobs Consultancy’s technical report for details and discussions on
30
coke storage. Regular monitoring of ambient air quality within the vicinity of the
2 day stock piles should take place i.e. daily or weekly, to ensure that particulate
levels are not exceeding the ambient air quality standard and personal exposure
levels.
3. ELVs for air emissions should be set within the EPC contract.
standards have been proposed.
Omani national
31
Conclusions and Recommendations
Our overall conclusions are as follows:
•
The EIA for the project is compliant with national requirements.
•
The EIA can meet EP and IFC standards by following the ESAP developed
by ORPIC and Lenders.
The EIA is compliant with national requirements and an ESAP has been developed in
agreement with ORPIC and Lenders. It is considered that the gaps identified in the EIA in
meeting EP and IFC Performance Standards can be appropriately managed through the
implementation of the correct controls, design, contractual requirements and implementation
of robust management plans and procedures within the ESAP. Prudent on-going monitoring
of implementation is recommended to ensure positive execution.
The following table summarises project compliance against the requirements of the Equator
Principles.
32
Table 5: Review of the Project against the Requirements of the Equator Principles
Equator Principle
Comment
1: Review and
Categorisation.
Under national Omani categorisation of projects as prescribed by the MECA
the proposed project is classed as a Group 1 Industrial Project, sub
categorised as ‘Oil and Gas’. Group 1 projects require an EIA and detailed
EMP to secure the PEP required for construction. Further details on
permits are presented above.
Under the requirements of the Equator Principles we would recommend that
this project be categorised initially as ‘Category B’ i.e. a project with
“potential limited adverse social or environmental impacts that are few in
number, generally site-specific, largely reversible and readily addressed
through mitigation measures”. The justification for this categorisation is due
to the location of the development within an existing industrial area (see
Figure 3 above), on land designated for industrial development which is
considered of limited ecological or cultural importance and currently not
used nor owned by local communities. There are some impacts and
omissions as discussed above in more detail and concerns regarding the
coke storage and poor environmental performance from the operation of the
existing facilities. Prudent on-going monitoring of implementation of
environmental actions and ORPICs existing environmental improvement
programme are recommended.
2: Social and
Environmental
Assessment.
A national EIA has been completed and the PEP was awarded in July 2013
affirming national approval of the EIA. There are omissions within this EIA
when compared against the requirements of IFC PS. Refer to Table 4 for
discussion on social and environmental assessment. However, it is felt that
these gaps can be addressed assuming implementation of the
recommendations provided in Table 4 above.
3: Applicable Social
and Environmental
Standards.
The national permitting status and international requirements of the project
are discussed above. Currently the project appears to be in compliance with
national requirements and a PEP was received in July 2013 affirming
national compliance. Work is required to bring the project in line with
international requirements. We believe this can be achieved within the
project timescales.
4: Action Plan and
Management System.
It is understood that ORPIC plans to use existing management plans and
develop some site specific plans to address social impacts. HMR in their
assessments for the project have recommended the development of a
number of specific management plans to manage key impacts from the
project. All management systems and plans need to be developed
implemented prior to relevant stages of project development i.e.
5: Consultation and
Disclosure.
Some consultation is believed to have taken place as part of the national
EIA process and HMR have developed an outline SEP for the project. The
project will be required to develop the SEP in-line with the requirements of
PS 1. This SEP should contain details of all on-going consultation and
information disclosure for the project. This should include, for example,
details of emergency response plans and procedures and abnormal
activities which may cause disturbance to local communities. See Table 4,
PS 1 above for further details.
6: Grievance
Mechanism.
ORPIC have confirmed that existing grievance mechanisms will be used for
workforces and the local communities. See Table 4 PS 2 and 4 above for
further details. From a recent site visit, it was demonstrated that existing
grievance mechanisms do exist and are in operation.
33
Equator Principle
Comment
7: Independent
Review.
To be undertaken as the part of project development. Jacobs Consultancy’s
review forms part of this independent review. Further independent review
will continue throughout construction and operation.
8: Covenants.
Incorporation of
covenants linked to
compliance.
To be confirmed as the project develops in liaison with lenders and project
sponsors.
9: Independent
Monitoring and
Reporting.
This role will be fulfilled by the Lenders.
The sponsor is required to ensure that provisions are in place to fulfil this
requirement on an on-going basis through the project lifecycle in
accordance with Lender requirements.
10: Equator Principle
Finance Institution
Reporting.
This role will be fulfilled by the Lenders.
The sponsor is required to ensure that provisions are in place to support this
requirement on an on-going basis through the project lifecycle as required
by the Lenders.
34

Sohar Refinery Improvement Project Potential Lenders on behalf of

Transcription

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