26788

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
Development Association. 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
plants 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 Protection Agency (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 environmental topics determined in consultation with the EPA.
The Supplementary Environmental Impact Statement (referred to hereafter as the
I999 SEIS) was submitted to the EPA in March 1999 and the EPA provided notice of
Environmental Approval 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
underway with the first two of three phases complete.
TIC are currently seeking to apply for funding from the International Finance
Corporation (IFC) and/or the Overseas Private Investment Corporation (OPIC) for the
third phase of the T2 project. These organisations require that additional work 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 1999 SEIS and the main text should be read in conjunction with the
1999 SEIS; it has been prepared with due reference to the IFC policy on
Environmental Assessment.
This Executive Summary provides a standalone description of the environmental
implications (benefits and adverse effects) of the T2 project. It has been prepared in
accordance with IFC requirements.
Acres International Limited, Takoradi Thermal Plant Environmental Assessment, Volumes 1 and 2, 1995.
Addendum Environmental Report J98404B
JacobsGlBB Limited i Issue 3.0 /November 2001
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26788
Takoradi Thermal Power Plant
The Existing TI 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 Ghanas power generating capacity through the use of combustion turbine
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),
associated transmission 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 principal fuel 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 permanent township for the workforce.
The TTPP project occupies an
area of approximately 168 ha,
which included provision for 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
World Bank criteria2.
Environmental Approval for the construction of TI to commence was provided in July
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 TI CTG currently under repair.
Repair is expected to be complete in July 2001,
~
* Operational Directive 4.01, Environmental Assessment, October 1991.
Addendum Environmental Report
JacobsGlBB Limited ii Issue 3.0 /November 2001
The T2 Project
The T2 project has been developed in response to 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 considered to
the best option for meeting the growing electrical energy demand while remaining
environmentally, economically and logistically favourable.
The objectives of the T2 project primarily include assisting with the development of a
more reliable and stable electricity supply, reducing Ghanas dependency on imported
electricity, minimising environmental impacts (through expansion of an existing plant
and through its design), and providing surplus energy for export.
The 1999 SEIS was produced in 1999 after consultation with the EPA (see section
I .3 below) and submitted in March 1999 with an application for an Environmental
Approval for the construction of the project. The report was made available for public
review and comment in April 9999 and for review by other groups as determined by
the EPA. Environmental Approval for the construction of T2 was provided in April
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
associated facilities (including fuel storage tanks, fuel treatment unit, desalination and
demineralisation plant). Many of the components, facilities and infrastructure of 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
distribution systems, circulating water 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,
potable water supply, sanitary and wastewater discharge and sewer systems, sewage
and wastewater treatment facilities, firewater systems, seawater intake and discharge
and maintenance buildings. The TTPP project includes various transmission line and
substation modifications that 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
pi pel i ne.
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 Pipeline project 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
Unit 2 (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
operational in 2003.
JacobsGlBB Limited iii Issue 3.0 /November 2001
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 International Operating Company
Issue 3.0 /November 2001 JacobsGlBB Limited iv
Alternatives Considered for TI and T2
As T2 is accommodated within the TI design, which itself was subject to a review of
alternative location, design and operational specification options during the 1995 EIA,
it was considered during the 1999 SEIS that no further assessment was required. A
summary of the alternatives considered at the outset of the TTPP project include the
following:
0 The Do-Nothing option (Le. a hypothetical situation where TI is not constructed);
Alternative geographical locations (e.g. eastern and western Ghana, coastal and
inland locations)
0 Alternative technologies including open and closed-circuit cooling water systems,
0 Using alternative fuels, including LCO and residual fuel oil
0 Using alternative methods for 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 (cooling systems and single point mooring locations).
These alternatives, considered at the TI planning stage, were subsequently accepted
or rejected primarily on the basis of practical, economical and environmental context
relative to best meeting the specific objectives for relieving the national energy 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 particularly as an alternative would have been to construct
a second, separate plant on a new site.
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 Environmental Assessment 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
availability of submitted EIA reports and public hearings are also provided for, where
necessary, and on submission of a satisfactory EIA, an Environmental Approval (EA)
JacobsGlBB Limited V Issue 3.0 / November 2001
will be issued to permit construction. A full Environmental Certificate, which covers
the operation of the project may be issued once an Environmental Management Plan
(EMP) and monitoring programmes have been demonstrated as satisfactory and an
Annual Environmental Report has been submitted.
Ghanaian EPA Environmental Criteria
The EPA has prepared environmental criteria for noise, ambient air quality and
maximum permissible levels for effluent quality (based on sector specific releases to
natural water 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 require that projects should be assessed relative to the following:
0 World Bank Groups Pollution Prevent and Abatement Handbook, 1998 - Thermal
Power: Guidelines for New Plants
0
World Bank Groups Occupational Health and Safety Guidelines
0 IFC Environmental and Social Policies including Environmental Assessment, General
Health and Safety Guidelines, Natural Habitats, Pest Management, Safeguarding
Cultural Property, Involuntary Resettlement, Forestry, International Waterways and
Child/Forced Labour.
Baseline Environmental Conditions
The following comprises a summary of the environmental conditions observed during
the T2 environmental studies for the 1999 SEIS and Addendum Environmental
Report; both of which take into account the presence of 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-made feature into a generally flat landscape. However, it is important to note that
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
JacobsGlBB Limited vi issue 3.0 I November 2001
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.
Biological Environment
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
protected wetlands 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~l i cy. ~
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 present on the site prior to clearance for TI .
Human Environment
The following represent the key features of the existing human environment affected
by TTPP. A map showing the sites location relative to surrounding settlements can
be found on the following page.
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 understood from 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 pertaining to 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 construction activities (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, Natural Habitats
JacobsGlBB Limited vii Issue 3.0 / November 2001
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 management issues, Since the preparation of the 1999 SEIS, 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.
JacobsGlBB Limited viii issue 3.0 / November 2001
Environmental Quality of the Area
Air Quality
Routine stack emissions and ground level air quality monitoring for T I in 1999
indicate the 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 SO2 concentrations monitoring 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 I I 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
conserve water 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
JacobsGlBB Limited ix Issue 3.0 I November 2001
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
LandscaDe and 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.
Biological Environment
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
JacobsGlBB Limited X Issue 3.0 /November 2001
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 (including T2) 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.
Human Environment
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
JacobsGlBB Limited xi Issue 3.0 I November 2001
workforce, enhancing Ghana's future ability to construct and operate other high
technology industrial projects. There will also be temporary and permanent
employment available through the construction and operation of 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
considered to be significant.
Waste Manaqement
The revised approach to management of oil waste sludge will effectively represent a
slight improvement in terms of air quality emissions from 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
manage waste 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.
Exceptions to 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 controlled to meet limits and monitoring has demonstrated good compliance,
with exceptions being attributed to identifiable causes.
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
Environmental Management and Monitoring Plan (EMMP).
The T2 plant is expected to reliably meet the 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 .
JacobsGlBB Limited xii Issue 3.0 / November 2001
Air Qualitv
In terms of air quality there is expected to 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 significant adverse 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
instances where the NO, control systems have been offline and NO, stack emissions
have temporarily exceeded the appropriate criteria. For ground level monitoring,
available data also indicates compliance with required criteria. 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
remained within the World Bank limit for operation without NOx control except for an
occasion where the NOx levels exceeded this 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,.
Predictions made in the 1999 SEIS 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 incineration is lower, which will have a benefit for TTPP in general
as well as removing a minor cumulative effect previously associated with 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 COz emission of 1.78 MtC. However, within the context of global emissions of
Con, Ghana's entire COz contribution will represent just 1/30th of 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
JacobsGlBB Limited xiii
J984048
Issue 3.0 / November 2001
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
baseload freshwater 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
incidents were 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 l TPP 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.
International Waterwavs
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
JacobsGlBB Limited xiv Issue 3.0 / November 2001
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
Overall, it is of note that under the current intermittent operating conditions at TTPP
(including T2s SC1 and SC2) there will be a general decrease in the overall resource
inputs required and resulting discharges and noise emissions. However, it is still
planned to operate the plant continuously when the oil market is more favourable.
JacobsGlBB Limited xv Issue 3.0 1 November 2001
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Recommended Mitigation Measures and Net Environmental Effects
The following comprises recommendations for mitigation measures for T2, as
described in the 1999 SEIS and Addendum Environmental Report:
Landscape and 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
TI to accommodate T2, and commence planting as soon as
practical to quickly maximise the benefits of the planting.
In terms of residual effects, there will inevitably be an adverse
residual effect due to the large scale of TTPP. However a degree
of acclimatisation will assist in reducing the significance of the
residual effect. TTPP will inevitably form a distinctive man-made
landmark on the coastline.
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 conjunction with 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 continued acclimatisation of the wildlife
to TTPP will reduce the significance of any residual effects to
minimal.
The Community Impact Agreement initiated under TI will continue
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 recommended that 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 implementation of mitigation measures
Ecology
General Social
Issues
JacobsGlBB Limited xx Issue 3.0 I November 2001
Air Quality
there will be no significant residual effects beyond the
construction and operations phase.
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 monitoring programme for
both stack emissions and ground level concentrations at selected
sensitive sites will help to ensure compliance with appropriate
criteria is maintained. TIC will be responsible for the effectiveness
of this programme for 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 NOn and SO:! predictions for
the cumulative impact of TTPP will remain within relevant criteria
in particular. In terms of global Con emissions, as Ghanas Con
emissions will remain a very small percentage of total Con
emissions, the residual effect is considered to be slight.
Water Supply Precautions will 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
TICS 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 discharge to the sea.
It is considered that overall there will be no significant residual
effect with the construction and 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 Managers 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 activities during 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
JacobsGlBB Limited xx i
J98404B
Issue 3.0 I November 2001
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.
JacobsGlBB Limited xxii Issue 3.0 I November 2001
SUMMARY OF PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN (EMP)
RESPONSIBILITIES
AND ROLES
4. WATER AND
WASTEWATER
ISSUES
Issue 3.0 /November 2001 JacobsGlBB Limited xxiii
6. ACCESS AND
TRAFFIC
Mitigation Measures
1. Existing access and haul routes will be used for transport of construction materials.
2. Controlled loading of materials on and off vehicles.
3. Appropriate Speed Limits will be set on all roads used by plant traffic.
4. Proper maintenance of site vehicles.
5. Provision of bus service to reduce road traffic.
6. Vehicle speed control measures, education programmes and hazards awareness guidance.
Monitoring
No monitoring proposed.
7. LAND ISSUES Mitigation Measures
AND WASTE 1 1. Local borrow areas will be rehabilitated to former condition by contractor, audited by EM.
11
I O. RISK
MANAGEMENT
MAWW~V~ENT I 2. Waste management procedures will be developed and a waste management manual
II
necessary.
Mitigation Measures
1. Staff will be educated as to spillage and explosion risks, prevention and response.
2. Review of existing contingency plans for incident management, updated as required.
Monitoring Measures
1 Check accident records and the procedures which are used to record incidents.
2. Audit clean up operations for any spills that occur.
3. 5-monthly checks on storage facilities, general housekeeping with repair or upgrade as
needed.
8.ECOLOGICAL
EFFECTS
Monitoring
I. Operation of Oily waste treatment will be monitored, audited and maintained for efficiency.
2. Undertake an audit of wa
Mitigation Measures
1. All operations will remain within the existing site fence line. Areas already cleared of
vegetation for the construction lay down sites during construction of TI will be used during T2.
EFFECTS
Monitoring
1. Ensure planting programme is effective by monitoring tree health and replanting as
I
JacobsG166 Limited xxiv Issue 3.0 / November 2001
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 Labours
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.
JacobsGlBB Limited xxv Issue 3.0 / November 2001
Conclusions of the Addendum
Specific to addressing the environmental and 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 involuntary resettlement.
Ghanaian workers rights legislation does not permit the use of child or forced labour
and the Contractors EPC Agreement enforces this requirement. No such practices
occur on the TTPP site (operations and 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
expected to be minor to 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 Banks Pollution Prevention and 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
agreements between regulators and enterprises. Generally speaking the IFC expects
compliance with 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
continue to last for the duration of the construction period only.
With the upgrading and expansion of the existing TI environmental management
policies and procedures to accommodate T2, the environmental quality monitoring
and pollution prevention response procedures, it is expected that the residual effect of
T2 will be minor. Recommendations laid out in the framework for the Environmental
Management and Monitoring Plan should also ensure a greater level of environmental
protection.
JacobsGlBB Limited xxvi issue 3.0 / November 2001

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