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Document Sample
Case Study: EMP for the Combined-Cycle Power Plant Project in
Country X
Case presentation and discussion format
Participants are given a PowerPoint presentation in which the key elements of the case
are laid out. Each participant receives a printed copy of the presentation and key tables
from the Environmental Management Plan (EMP) for the hypothetical project in the case.
Equipped with this material, the participants are given a few minutes to think about the
general question included in the Role Play (see below). Then they are “visited” by the
author of the case study impersonating the NGO critic of the project, who asks them the
specific questions given below. Ideally, the participants should be able to retrieve the
appropriate information from the EMP and the PowerPoint presentation to answer the
questions. After the role play, a discussion follows, in which the answers given by the
participants may be compared with the possible answers given below.
Learning objectives:
Identify and analyze strengths and weaknesses of an EMP
Learn about typical environmental issues covered in an EMP for a project
involving construction of a thermal power plant
Analyze EMP in a broader context of the project development cycle
Appreciate the importance of public information and timely involvement of the
local community.
Scenario for discussion
Country X has would like to improve its energy supply situation and decides to build a
new thermal power plant with an electric capacity of about 100 MW. The country’s
Ministry of Energy is the borrower. The country’s National Power Company (NPC) is put
in charge of implementing the main physical component of the project, which consists of
building a combined-cycle thermal power plant and connect it to the power grid. The
choice of power plant site is made according to certain criteria (environment being one of
them). The task team leader (TTL) discusses the project with the NPC management. TTL
says, “It is obvious that the project is Category A. The World Bank takes Category A
projects very seriously. Let’s make sure the EIA is comprehensive and state of the art. I
would like the EMP to be especially well developed. At the end of the day, the EMP is
the document that will be most useful to you in practice. Fortunately, we have secured
enough grant money to hire top-quality experts to conduct the EIA and develop the
EMP.”
EIA/EMP is prepared by a highly reputable team of environmental experts from
consulting firm Top Quality Experts (TQE) hired by the Ministry of Energy. The
EIA/EMP is the third phase in TQE’s contract. The two earlier phases consisted of (i)
selecting the best site, technology, and fuel for the generation facility (power plant); and
(ii) conducting a feasibility study to evaluate the technical requirements, as well as the
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environmental, economic, and financial viability of the generation facility at the selected
site.
The TQE team chooses the sea coast of town Z to be the site for the power plant. It also
chooses liquid fuel (distillate oil) as the primary fuel, and the once-through cooling
(OTC) system utilizing the sea water for converting the plant’s exhaust steam back into
water.
When the EIA report is completed, it includes an EMP as one of its chapters. The EMP
consists of an Environmental Mitigation Plan and an Environmental Monitoring Plan (see
Annex 1 for the key tables from the EMP).
When the bids are invited for the Engineering, Procurement, and Construction (EPC)
contract, the EMP requirements are incorporated in the bidding/contract documents
(binding for EPC contractor). Relevant EMP provisions are also included into the
contracts for fuel supply during operating phase.
The borrower believes that the environmental aspects of this project’s preparation are
exemplary. State of the art combined cycle power plant is designed by the EPC contractor
and is ready to be supplied and installed. The office of the PIU director proudly displays
the computer-generated image of the plant.
Source: http://eia.csir.co.za/cip/docs/Overview_CIP_Eskom_iGas_13092006.pdf
Still, the TTL is worried about possible criticisms from environmental groups (NGOs).
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Role play
General Question. You are the PIU Director at the NPC, and you are asked to prepare
for a meeting with Dr. Ruffle, a senior representative from an international environmental
NGO and a likely critic of the project. You believe that the recently finalized EMP can
help you answer his questions. What kind of issues do you think you need to be
especially prepared to discuss?
Some correct answers:
Siting (relates to avoidance versus mitigation of environmental impacts)
Technology used (esp., once-through cooling), including mitigation technology
Public consultation (note that public consultations in our case were held in an
exemplary manner)
The effectiveness/practical implementation of EMP
Possible scenario of the meeting between the PIU director and NGO activist
Specific Questions
Siting:
Ruffle: In environmental management, like in many other fields, avoidance of damage is
considered a better option than mitigation. The World Bank, among others, certainly
subscribes to this view in its guidance on Environmental Management Plans1. Some of
the impacts this project will have on the environment might have been completely
avoided had a different site been chosen for the project. This particular coastal area of
Country X is particularly valuable/vulnerable and only 3 km away from a National Park.
How did your experts choose the coastal area of town Z as the site for the project? What
kind of criteria did you use to eliminate all the other possible locations?
PIU Director: We have considered six other possible locations, and every one of them
had some environmental issues of its own. But if you would like to know all the selection
criteria we used, here they are: (i) environmental conditions on site; (ii) air quality
concerns; (iii) cost of electricity generation; (iv) socio-economic concerns; (v) proximity
to available transmission lines; (vi) transmission system considerations; (vii) fuel
availability; (viii) water and sewer needs; (ix) transportation; and (x) property
availability.
Ruffle: Thank you for this information, but I remain unconvinced. The environmental
criteria you mention seem too general. An in-depth analysis of environmental conditions
should have led you away from the green field areas of town Z and into areas that are
already built-up by industry.
Air Pollution Control:
Ruffle: How will you manage the air quality concerns at the site you have selected –
especially the pollution resulting from fuel oil combustion?
PIU Director: As you know, Country X has adopted the standards of the European
Union for air quality. To demonstrate compliance with these standards, our experts have
utilized the latest US EPA air pollution simulation model (ISCST3).
1
Environmental Management Plans. Environmental Sourcebook Update/ No. 25. January 1999.
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Annual Averaging Period 24-hour Averaging Period
Pollutant Maximum Ambient Air Quality Maximum Ambient Air Quality
Modeled Standards (μg/m3) Modeled Standards (μg/m3)
Impacts World European Impacts World European
(μg/m3) Bank Union (μg/m3) Bank Union
NOx 4.5 100 40 17.5 150
PM10 0.5 50 40 2.2 150 50
SO2 2.1 80 20 10.5 150 125
As you can see, these modeled concentrations are far below the strictest of the standards
we could possibly apply, and these air quality levels will be ensured through the
mitigation measures included in the EMP. Specifically, the combustion turbines will
employ state of the art control technology for all pollutants. NOx will be controlled using
low-NOx burners and water injection. SO2 will be controlled by firing only low-sulfur
(less than 0.1% by weight) distillate fuel oil. Employing good combustion control will
control CO, particulate matter, and volatile organic compounds. The plant will feature
stack heights that conform to good engineering practice to facilitate dispersion of emitted
gases. The plant stack heights in our case will be at least 45 m. At the plant
commissioning, the EPC contractor will need to demonstrate compliance with the
emission standards guaranteed by the manufacturer. Subsequently, there will be
continuous monitoring of NOx and opacity emissions. Fuel sulfur content will be
monitored to ensure that it is less than or equal to 0.1% by weight. Sampling and analysis
will be performed on each delivery received.
Fuel supplies:
Ruffle: Choosing offshore oil as primary fuel is a big environmental risk to take. How
many tanker trips per year do you anticipate, and how will you manage the risk of oil
spills?
PIU Director:
For some impacts of the project, the EMP we have developed is only a start. Oil spills is
one of the risks requiring an individual risk management plan. The plan must be
acceptable to the NPC and the World Bank. It is anticipated that about 30 deliveries will
be made per year by a barge with minimum capacity of 3,000 m3 from a distance of 20
km away. Monitoring and enforcement of sea conditions under which a vessel may make
deliveries will be part of the plant procedures and implemented through the delivery
contract. The necessary response equipment will be provided.
Ruffle: What other impacts of the project will require a specialized EMP?
PIU Director: To name just a few: waste management plan, site drainage and grading
plan, health and safety plan, and noise and vibration plan (the complete list of such
specialized EMPs, as well as additional studies required, is given after the tables in
Annex 1).
Power plant cooling technology
Ruffle: I am surprised that, after so much analysis of environmental impacts, your
experts would choose the once-through cooling (OTC) technology to cool the power
plant. The OTC technology uses the living and breathing sea water as the radiator fluid to
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run through the plant. Furthermore, the quantities of water involved in this process are
enormous. Do you know how much water these systems use? There are estimates2 that
the water demand for a once-through cooling system is 30 to 50 times that of a closed-
cycle system. Not only are fish and other marine organisms destroyed by being sucked
into the plant at the point of intake, but the thermal and chemical pollution of the sea by
the return water coming from the outfall is also very harmful for the aquatic ecology.
Would you like to have a few copies of this poster?
Once-through cooling technology
schematic emphasizing damage to aquatic environment
PIU Director: The OTC option was chosen based on its superior cost-benefit
characteristics. The power plant is known to operate more efficiently when this
technology is used. Regarding the environmental impact, please note first of all that there
are no local restrictions in Country X on the use of OTC. Secondly, our EIA has clearly
demonstrated an acceptable level of environmental impact resulting from the use of OTC
technology. In our EMP, we have included the necessary mitigation measures: traveling
water screens at cooling water pump suctions will be employed. An inlet velocity less
than 1 m/s will be used to minimize entrainment of fish and other aquatic fauna. Thirdly,
thermal discharge modeling demonstrates that the thermal impact from the discharge is
well below 3ºC allowed by international guidelines. Finally, the chemical discharges are
in compliance with the residual chlorine discharge limits recommended by the World
Bank.
2
http://www.lcca.co.uk/upload/pdf/POWER_STATIONS_WATER_DEMAND.pdf
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Ruffle: In that case, why do you think the US EPA is considering a prohibition on the
construction of new power plants using OTC in the United States? They are even
studying the options for upgrading the existing power plants to the closed-cycle cooling
system. I have just returned from a trip to California. The environmental community is
clearly winning the argument there.
PIU Director: The closed-cycle cooling system requires the construction of cooling
towers and is generally more expensive. However, we did consider this option in our
analysis of alternatives in the EIA. Our experts estimated that a cooling tower would add
as much as US$10 million (or almost 9%) to the cost of the project. Corrosion-resistant
materials would have to be used if the system uses saltwater from the sea, while using
fresh water is practically out of the question due its intermittent availability. The plant
efficiency would also be somewhat lower with the closed-cycle cooling system, which
would translate into higher consumption of fuel.
Wastewater disposal
Ruffle: How will you manage the wastewater coming from the pant?
PIU Director: A sewage treatment facility will be provided at the plant and discharge of
treated effluent will be combined with the cooling water discharge. The sewage treatment
plant will provide secondary treatment.
Practical implementation (enforcement) of EMP
Ruffle: I have seen your EMP and I appreciate the fact that it was on the table when the
consultation meetings were held with the local public. I have to admit that it is probably
one of the best documents of this sort that I have seen for similar projects. But I have
some concerns about its practical implementation. How exactly can you make sure that
the mitigation and monitoring measures included in the EMP will be actually enforced?
PIU Director: I would like to answer as follows:
First of all, there is a provision in the project agreement about the need to
implement the EMP. The National Power Company, as the project implementing
entity, is legally obligated to follow the provisions of the agreement. And why
wouldn’t it? You may have noticed that practically every item of the EMP has a
cost estimate. Essentially, this is the budget allocated to these items, and they are
included in the procurement plan.
Secondly, every time we have a tender, we include the relevant provisions of the
EMP into the bidding documents. You can see from Annex 2 how detailed these
environmental requirements are. To win the tender, the candidate contractor will
have to fully accept these requirements as an integral part of their contract. In our
case, the successful EPC contractor has gone beyond the scope of the mandatory
EMP provisions and developed its own version of the EMP, which is more
detailed than the original version.
Also, we’ll make sure that NPC includes the relevant environmental requirements
into the contracts with the fuel suppliers.
Last but not least, implementation of the environmental mitigation measures will
be closely supervised. The PIU has recruited a full-time environmental specialist.
It is in her job description to periodically check compliance of the project with the
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environmental monitoring plan and obtain regular reports from the NPC on
compliance.
Analysis/Discussion
The EMP strengths and weaknesses
Strengths:
The EMP (and the Environmental Management Planning process more broadly)
incorporates the following elements of best practice:
The air pollution control measures are designed to comply with the stricter of the
potentially applicable standards (EU, WB)
Cost estimates are available for most items in the EMP and included in the
Procurement Plan
EMP requirements are incorporated in the bidding/contract documents (binding
for EPC contractor) and into the contracts of suppliers of fuel during operating
phase
The EMP has been adequately disclosed, and the local community was actively
involved
Weaknesses and what might have been done differently/better:
The mitigation options in the EMP are limited by the earlier commitments to
pursue particular technological solutions (e.g., the once-through cooling system)
Furthermore, both the technology and the project site have been chosen mostly on
the basis of narrowly defined (financial) cost minimization and plant efficiency,
giving a lower priority to environmental considerations
No siting or technology choices should be eliminated until completion of the
detailed EIA: while the EMP reduces the impacts, some of them might have been
completely avoided with a different site and/or technology
Lesson learned:
EMP is not an isolated tool but should be part of the overall good environmental
management and decision making
Environmental mitigation is an integral part of decision making and must be
considered simultaneously with the analysis of alternative technological and siting
choices
The project team may prepare a state of the art EMP, but may still be in a
vulnerable position if the upstream decision making is perceived to be flawed
In making choices about the technology, it is more prudent to err on the
conservative side and require the technology consistent with the higher degree of
environmental protection: the absence of local environmental restrictions on
certain technology in Country X is a weak excuse if the environmental credentials
of the technology are known to be questioned
Economic (including environmental) rather than just financial costs/benefits need
to be part of the analysis of alternatives.
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Annex 1. Environmental Management Plan
A. Mitigation Plan
Construction Phase Mitigation
Activity Potential Mitigation Measure Responsi Approximate
Impacts bility Cost
Site Work – Loss of Trees There are few trees that are potentially affected by EPC $5,000
Clearing and the site work. No trees will be cut that do not Contractor
Grading interfere with the site work. The wood that is cleared
will be made available to local residents.
Site Work – Interference with Final site grade will facilitate drainage and avoid EPC $40,000
Clearing and Natural Site flooding and pooling. A site drainage plan will be Contractor
Grading Drainage – Soil developed that protects against erosion. Protecting
Erosion stockpiles through the use of silt fencing and reduced
slope angles will also minimize soil erosion during
construction.
Site Work – Noise from Construction equipment shall meet the applicable EPC Minor
Clearing and Equipment standard in EU Directive 2000/14/EC of May 2000. Contractor
Grading The Directive applies to the manufacturer of the
noise emitting equipment. Work involving nuisance
noise will be minimized during locally recognized
days of rest and at night. All equipment will be
maintained in good working order. Construction
activities that generate significant noise levels will
be limited to reasonable daytime hours. These
conditions will be specified in the bidding
documents.
Site Access Dust and Noise Watering of disturbed site areas on an as needed EPC $5,000
Upgrades - from Equipment basis will minimize dust. No equipment noise will Contractor
Roadwork exceed the applicable standard in EU Directive
2000/14/EC of May 2000. This Directive applies to
the manufacturer of the noise emitting equipment.
Work involving nuisance noise will be minimized
during locally recognized days of rest and at night.
All equipment will be maintained in good working
order. Construction activities that generate
significant noise levels will be limited to reasonable
daytime hours. These conditions will be specified in
the bidding documents.
Dewatering Sediment and Oil Where site excavations require dewatering, the EPC $7,500
and Grease loading excess water will be visually inspected for oil Contractor
to Nearby contamination prior to discharge to the site drainage
Waterways system. Oil contaminated water will require
treatment prior to disposal. Water potentially
contaminated with oil will be routed to the onsite
water oil/water separator (OWS). Package OWS
typically remove oil below the manufacturers
guarantee of 10 ppm.
Borrow Site Conflicts with Borrow area will avoid agricultural areas. EPC Minor
Present Land Use Contractor
Borrow Site Disturbance to All permits and approvals will be obtained from the EPC $2,000
Local Community appropriate authority prior to operating a borrow Contractor
site.
Borrow Site Unsightly Area Borrow areas will be reworked to blend into the EPC $4,000
9
Finished with surroundings. Revegetation will be performed using Contractor
Borrow Activity local plants. All slopes and working faces will be
returned to a stable condition.
Disposal of Disturbance to Local authorities should approve the disposal site. It EPC $2,000
Excavated Land will not interfere with local land use. Vegetation will Contractor
Material if be performed using local plants. All slopes at a
Necessary borrow disposal site will be graded to a stable
condition.
Transmission Disturbance to The amount of land used for the transmission EPC Minor
Interconnection Land interconnection will be minimized. No agricultural Contractor
lands will be disturbed by the transmission line.
Private land acquisition will follow the procedures
that are based on Country X Law No. XXXX, dated
XXXX, etc.
Provision of Reduced Water The water supply for use in construction of the EPC $5,000
Potable Water Supply to Area generation facility must be monitored to ensure that Contractor
Residence it does not adversely affect other water uses in the
area.
Handling and Potential Health All employees will undergo health and safety EPC $12,000
Storage of Fuels and Safety training. Those dealing with hazardous materials will Contractor
and Hazardous Concerns receive specific training in handling the materials.
Materials There will be no ash generated from the oil
combustion. Hazardous waste generated will
primarily be from waste lubricants and rags from
clean-up and maintenance activity.
Handling and Soil and Water Fuel storage tanks will have secondary containment EPC $30,000
Storage of Fuels Contamination with sufficient volume to contain a spill from the Contractor
and Hazardous from Spills largest tank in the containment structure. The
Materials containment area will have a means of removing
accumulated water. Drains will be routed through the
site oil/water separator. A spill and emergency
response plan will be developed and put in place
prior to commencement of construction. This plan
must be acceptable to NPC and the World Bank.
Aggregate Source Reduced Local No new sources will be developed. Existing quarries EPC Minor
Resources will be utilized. Contractor
Batch Plant – Noise, Dust, and Storm water runoff will be directed to the site EPC $2,000
Concrete and Potential Runoff drainage system. Noise will be controlled to an Contractor
Asphalt Concerns acceptable level. Dust bags will be installed as
necessary. The EPC specification will require that
the batch plant owner/operator must hold valid
operating permits.
Construction Work Influx of Workers Influx of workers is not expected to exceed 400 EPC $10,000
Force Creating Pressure individuals. Workers will be housed in Z and bussed Contractor
on Housing and to the site. A first aid station will be provide for
Other Resources workers onsite.
Delivery of Increased Traffic Upgrade of the main access road to plant will have EPC $200,000
Equipment and and Dust positive effect on local traffic. Dust from the road Contractor
Materials will be minimized with water during construction
and by providing paved surface. Trucks will be
tarped when carrying load. Road speeds will be
controlled to reduce the potential for accidents.
Solid Waste Potential Health Solid waste will be stored in a special area and EPC $20,000
Disposal Concerns disposed of using a licensed contractor. Contractor
Liquid Waste Potential Water A packaged sewage treatment facility will be EPC $95,000
Disposal Contamination provided for the site. No direct discharge of Contractor
untreated liquid waste will be allowed.
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Intake and Outfall Disturbance of Main mitigation is in siting the exact location of the EPC $200,000
Construction Aquatic Resources intake and outfall. Construction wastes will not be Contractor
disposed of in the bay. Intake design will follow the
USEPA Draft Guidance for Evaluating Adverse
Impact of Cooling Water Structures on the Aquatic
Environment and the European Commission IPPC
reference Document on the Best Available
Techniques for Industrial Cooling Systems. Dredged
materials and water will be monitored for mercury.
Dredged materials and water found to have a
mercury content above the guidance found in
Evaluation of Dredged Material Proposed for Ocean
Disposal (USEPA 503/8-91/001) will be segregated
and disposed of in a secure hazardous waste landfill.
Liquid wastes will be sent for offsite treatment.
Intake and Outfall Interference to Construction period will be scheduled to minimize EPC Minor
Construction Coastal Fishing impact on fishermen.
Intake and Outfall Interference to All barges and buoys will be clearly marked and EPC $20,000
Construction Navigation illuminated at night. Proper authorization will be Contractor
obtained prior to commencement of offshore work.
Intake and Outfall Sediment Release Intake and outfall will be constructed with the intent EPC $50,000
Construction to minimize the release of sediments to the bay. Contractor
Final Site Aesthetics Topsoil will be graded and planted as appropriate. EPC $5,000
Contractor
Operation Phase Mitigation
Activity Potential Mitigation Measure Responsi Approximate
Impacts bility Cost
Distillate Fuel Oil Air emissions of The combustion turbines will employ state of the art EPC $1,000,000
Combustion NOx, SO2, CO, control technology for all pollutants. NOx will be Contractor
particulate matter, controlled using low-NOx burners and water /NPC
and volatile injection. SO2 will be controlled by firing only low-
organic sulfur (<0.1% by wt.) distillate fuel oil. [Employing
compounds that good combustion control will control CO, particulate
can adversely matter, and volatile organic compounds. The plant
affect human will feature stack heights that conform to good
health and the engineering practice (GEP) stack height to facilitate
environment. dispersion of emitted gases]. The plant stack height
will be at least 45 m to facilitate dispersion of
emitted gases.
Equipment Noise from The combustion turbines will be enclosed in an EPC $180,000
Operation Equipment acoustic enclosure to ensure that noise does not Contractor
exceed 85 dB(A) at 1 m. [Workers in close /NPC
proximity to this equipment will be required to use
hearing protection]. Offsite noise will not exceed 70
dB(A). There is no residential housing in the area of
the site.
Cooling Water Entrainment of Final location to be made to minimize impact on EPC
Intake larval fish, aquatic environment. Bar screen intake screens will Contractor
shellfish, and other be utilized. Final screening with traveling water
marine fauna. screens at cooling water pump suctions will be
employed. An inlet velocity less than 1 m/s will be
used to minimize entrainment.
Cooling Water Impingement of See above
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Intake adult and juvenile
fish and shellfish
Cooling Water Thermal effects on Thermal discharge modeling demonstrates that the NPC Minor
Discharge marine fauna thermal impact from the discharge is less than or
equal to 3ºC after mixing zone. This ensures that
there is minimal impact from the discharge. The
discharge will be designed to minimize or eliminate
re-suspension of sediment in the vicinity of the
outfall. If the impacts are found to be greater than
predicted after operation begins, modifications to the
diffuser operation can be made to increase mixing
and reduce impacts accordingly.
Cooling Water Chemical effects Cooling water will be treated with sodium NPC Minor
Discharge on aquatic hypochlorite to eliminate fouling. Residual chlorine
ecosystem in the effluent will meet World Bank guidelines (0.2
mg/l)
Fresh Water Reduce water The plant will supply its own service water supply EPC $1,000,000
Supply supply to the local from the Blue Sea through a membrane desalination Contractor
community system /NPC
Sewage Treatment Discharge of A sewage treatment facility will be provided at the EPC
nutrients and other plant and discharge of treated effluent will be Contractor
containments to combined with the cooling water discharge. The /NPC
waterways sewage treatment plant will provide secondary
treatment either through aerobic or anaerobic
treatment.
Local Community Stress on the local The infrastructure of the town of Z will be able to NPC Minor
Services infrastructure accommodate the amount of new residence of new
workers in the plant even if all workers come from
outside the country. However, it is anticipated that
many of these workers will be from the town Z area.
Handling and Delivery of fuel oil A spill response plan and necessary response NPC $50,000
Storage of Fuels could result in a equipment will be provided. The plan must be
and Hazardous spill that would acceptable to NPC and the financing institutions. It
Materials impact the aquatic is anticipated that as many as 30 deliveries will be
and coastal made per year by a barge with minimum capacity of
environment 3,000 m3. Monitoring and enforcement of sea
conditions under which a vessel may make deliveries
will be part of the plant procedures and implemented
through the delivery contract.
Handling and Pipeline between The pipeline will be regularly inspected and NPC $15,000
Storage of Fuels the terminal and maintained. An inspection and maintenance program
and Hazardous the site could will be developed as part of the plant operating
Materials rupture and impact procedures.
the aquatic and
coastal
environment
Handling and Oil storage tanks Oil storage tanks will include secondary containment EPC
Storage of Fuels could fail and of sufficient size to contain 110% of the contents of Contractor
and Hazardous result in adverse the largest tank. A means of removing rainwater will /NPC
Materials impacts on the soil be included. Drains will be routed through the plant
and groundwater oil/water separator.
resources
Hazardous Waste Ground water Small amount are anticipated. Waste will be handled NPC Minor
pollution. Health in accordance with Country X regulations and sent to
and safety risk. a dedicated facility properly equipped for receiving
these materials.
Transmission of Disturbance to Clearing for transmission lines will be minimized. NPC Minor
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Power Land Lines will be routed to minimize the impact on
residential areas. The electromagnetic field (EMF)
emitted by the line will be checked.
Aesthetics Aesthetically Some disruption is unavoidable. The plant will be NPC $40,000
displeasing shielded by trees and set back from the ocean.
appearance may Comprehensive landscaping will be used to enhance
affect the tourist the appearance of the generation facility.
appeal of the coast.
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B. Monitoring Plan
Monitoring Plan for Construction
Activity Monitored Parameters Responsibility
Site Work – Clearing and The practice of sharing the wood that is cleared with the local EPC Contractor
Grading residents will be monitored
Site Work – Clearing and Protecting stockpiles through the use of silt fencing and EPC Contractor
Grading reduced slope angles to minimize soil erosion during
construction will be monitored to ensure that the practice
conforms to site drainage plan.
Site Work – Clearing and See detail provided in the Final EIA on Air Quality and Site EPC Contractor
Grading Drainage.
Site Access Upgrades - See detail provided in the Final EIA on Air Quality and Site EPC Contractor
Roadwork Drainage.
Dewatering Maintain a record of visual inspection of excess water from EPC Contractor
dewatering activity
Borrow Site Monitor and document that borrow areas avoid agricultural EPC Contractor
areas.
Borrow Site Obtain and maintain applicable permits. EPC Contractor
Borrow Site Document final condition of borrow areas to ensure that they EPC Contractor
have been reworked to blend into the surroundings and are
safe.
Disposal of Excavated Material if Monitor and document the use of borrow material. EPC Contractor
Necessary
Disposal of Excavated Material if Obtain and maintain applicable permits. Document final EPC Contractor
Necessary condition of borrow areas to ensure that they have been
reworked to blend into the surroundings and are safe.
Transmission Interconnection Document the amount of land used for the transmission EPC Contractor
interconnection and that no agricultural lands are disturbed.
Provision of Potable Water Monitor water supply to ensure that it does not adversely EPC Contractor
affect other water uses in the area.
Handling and Storage of Fuel and Document health and safety training. EPC Contractor
Hazardous Materials
Handling and Storage of Fuel and Spill Response Plan EPC Contractor
Hazardous Materials
Aggregate Source Records will be kept on quarries utilized EPC Contractor
Batch Plant – Concrete and Noise will be monitored once, at both day and night, for an EPC Contractor
Asphalt eight-hour period at the perimeter of the site during the peak
of construction activity. In addition, spot monitoring of
various pieces of construction equipment will take place to
ensure that noise emissions are not excessive. The site
construction manager will maintain records of any noise
complaints received during the construction process. Visual
inspection of dust emissions will be performed daily with
records of results.
Construction Work Force A first aide station will be provided for workers onsite. EPC Contractor
Delivery of Equipment and Visual inspection of dust from road construction will be EPC Contractor
Materials ongoing and application of water will be employed to suppress
dust during periods of high dust generation. Road speeds will
be clearly posted.
Solid Waste Disposal Contact for proper disposal of solid waste will be kept onsite. EPC Contractor
Records on the date of disposal and the amount and type of
solid waste disposed will be maintained.
Liquid Waste Disposal and Monitoring of the appropriate operational parameters will be EPC Contractor
Sewage Treatment performed as per the manufacturer’s requirements. Oil water
separators will be equipped with an oil level indicator and
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inspected daily. Sewage treatment may include portable
facilities. If so, the containment levels will be monitored daily
and the contents disposed of properly when full level is
reached. If the sewage treatment consists of the packaged
treatment facility that will ultimately be placed into service for
the facility, then the appropriate parameters such as airflow,
temperature, and discharge biological oxygen demand (BOD)
should be monitored.
Intake and Outfall Construction Documentation on the siting study performed to locate the EPC Contractor
intake and discharge will be maintained onsite.
Intake and Outfall Construction Documentation on the siting study performed to locate the EPC Contractor
intake and discharge will include a construction schedule and
information and information on historic fishing activity. A
copy of this report will be maintained onsite.
Intake and Outfall Construction Documentation of construction authorization will be EPC Contractor
maintained onsite.
Intake and Outfall Construction The construction technique and means minimizing sediment EPC Contractor
releases will be documented and a copy maintained onsite.
Monitoring of mercury in sediments will be carried out if
excavating and dredging are performed as part of the intake
and outfall construction.
Final Site A plan for final grading and landscaping of the site will be EPC Contractor
developed and maintained onsite.
Monitoring Plan for Operation
Activity Monitored Parameters Responsibility
Distillate Fuel Oil Combustion Fuel sulfur content will be monitored to ensure that it is less NPC
than or equal to 0.1% by weight. Sampling and analysis will
be performed on each delivery received.
An initial performance test will be performed to confirm the
emissions from the plant do not exceed the amounts listed in
this report. The stack will include continuous monitoring of
NOx and opacity emissions.
Equipment Operation Baseline noise monitoring will be conducted prior to operation NPC
of the plant, both at the plant and at predefined receptor
locations. Then, offsite, far field noise monitoring will be
performed at those locations once during operation of the
facility to confirm that the operation conforms to 70 dB(A)
limit.
Workers in close proximity to the turbines or other noise
emitting equipment will wear hearing protection in accordance
with a written health and safety plan. A copy of the health and
safety plan will be maintained onsite.
Cooling Water Intake Documentation will be maintained onsite concerning the final NPC
design of the water intake including the inlet velocity.
Cooling Water Intake See above NPC
Cooling Water Discharge The condenser discharge temperature will be monitored to NPC
ensure the operation of the facility meets the maximum
temperature discharge described in this report. Quarterly
monitoring of the temperature at the discharge will be
performed to confirm the maximum discharge temperature
used in this analysis. In addition, pH and residual chlorine
levels will be monitored on a continuous basis. Suspended
15
solids and oil and grease will be measured semiannually.
Fresh Water Supply The use of water from the desalination plant will be confirmed NPC
through maintaining the pertinent plant design documents
onsite.
Sewage Treatment Monitoring of the appropriate operational parameters will be NPC
performed as per the manufacturer’s requirements. If the
sewage treatment consists of the packaged aerobic treatment
system then the airflow, temperature, and discharge biological
oxygen demand (BOD) should be monitored at a minimum. If
the system consists of an anaerobic treatment process, then
process temperature, and discharge BOD should be monitored
at a minimum. All associated values, pumps, blowers, and
filters will be visually inspected weekly.
Local Community Services Maintain record on complaints concerning stress on the local NPC
community services created by the plant operation.
Handling and Storage of Fuels Maintain records to demonstrate adherence to the spill NPC
and Hazardous Materials response plan.
Handling and Storage of Fuels Maintain record of pipeline inspections. Inspections should NPC
and Hazardous Materials include daily inspections of visible fittings, valves, and joints.
Annual pressure testing of the line must be performed to
verify the pipeline integrity.
Handling and Storage of Fuels Maintain the pertinent design information onsite. Records on NPC
and Hazardous Materials the date of discharge, approximate quantity of discharge, and
final disposition of the discharge. Oil water separators must be
equipped with an oil level indicator and inspected regularly.
Daily inspections of the levels in the oil water separators must
be performed. Weekly inspections of the proper function of
the oil level indicator must be performed.
Transmission of Power The electric and magnetic field (voltage and magnetic NPC
gradients close to an energized transmission line) emitted by
the interconnection line will be monitored once at four
locations along the line. Measurement must take place when
the line is fully energized. The location of the measurements
will be at the plant switchyard, at the terminating substation
and two places in between to be determined by NPC.
Aesthetics The property maintenance records will be maintained onsite. NPC
Additional Plans and Studies
There are a number of additional plans and studies recommended throughout the EIA,
many of which include the collection of site specific data. The plans required are to
establish operational and response procedures. The studies are intended to both verify
some findings in the Final EIA and generate useful information for design and execution
of the project. The additional plans and studies are as follows:
Oil spill response, recovery, and mitigation plan
Emergency response plan
Site drainage and grading plan
Community impact action plan (only if deemed necessary)
Health and safety plan
Noise and vibration plan including baseline monitoring
Waste management plan
Simplified employee health and safety manual
Environmental assessment of the final transmission line
16
Ambient air monitoring including meteorological data, sulfur dioxide, oxides of
nitrogen, and particulate matter
Cooling water intake and discharge structure location study including fish studies,
seabed flora and fauna, sea temperature monitoring, sediment sampling and
analysis for mercury contamination in areas of potential dredging.
17
Annex 2. Environmental Requirements for the EPC Contractor included in the Bidding Documents
A. Mitigation Plan
Item no. Potential
Category Activity Effects Mitigation Plan Responsibility
Site Access Stress on local Numerous small bridges and culverts along the EPC
Upgrades - infrastructure route will also require upgrade to support the Contractor
Roadwork high loads associated with the heavy-haul of the
turbine-generator components. Sediment control
1.1 measures, (i.e. sediment sampling and analysis)
may also be required for road improvement
activities, particularly at stream crossings.
1. Planning/Logistics
Modification Stress on local Several low hanging distribution power lines EPC
of existing infrastructure will require modification to allow the passage of Contractor
1.2 transmission large components and construction equipment.
lines Any permits required for this work should be
obtained from the proper authority.
Borrow Site Disturbance to Soil borrow sites should be carefully selected to EPC
Local assure that the sites can be properly regarded and Contractor
1.3 Community revegetated after completion of the project.
Construction Influx of Influx of workers is not expected to exceed 350 EPC
Work Force Workers to 500 individuals. Workers shall be housed in Contractor
Creating the town of Z and bussed to the Site. A first aid
1.4 Pressure on station shall be provided for workers onsite.
Housing and
Other
Resources
18
Handling and Potential All employees shall undergo health and safety EPC
Storage of Health and training. Those dealing with hazardous and toxic Contractor
Fuels and Safety materials shall receive specific training in
Hazardous Concerns properly handling, storage and disposal of the
1.5 Materials materials. There shall be no ash generated from
the oil combustion. Hazardous waste generated
shall primarily be from waste lubricants and rags
from clean-up and maintenance activity.
Solid Waste Potential Solid waste shall be stored in a special area and EPC
1.6 Disposal Health disposed of using licensed contractors. Contractor
Concerns
Liquid Waste Potential A packaged sewage treatment facility shall be EPC
Disposal Water provided for the site. No direct discharge of Contractor
1.7 Contamination untreated liquid waste shall be allowed.
Intake and Interference to Water construction activities associated with the EPC
Outfall Coastal pipelines for the cooling water intake and Contractor
Construction Fishing discharge systems should be performed during
periods of low fish activity. Marine disposal of
1.8 excavated material should be timed to be outside
of the upwelling period. NPC to advice EPC-
Contractor regarding disposal sites.
Intake and Interference to All barges and buoys shall be clearly marked and EPC
Outfall Navigation illuminated at night. Proper authorization shall Contractor
1.9 Construction be obtained prior to commencement of offshore
work.
19
Transmission Disturbance to The amount of land used for the transmission EPC
Interconnection Land interconnection will be minimized. No Contractor
agricultural lands will be disturbed by the
transmission line. Private land acquisition will
follow the procedures that are based on Country
X’s Laws Nos. XXXX. The width of the corridor
for the transmission line should be no more than
60m. Any wood vegetation which must be
cleared in the transmission line corridor shall be
made available to the local residents. Clearing
for transmission lines will be minimized. Lines
2.1 will be routed to minimize the impact on
2. Power Plant Design
residential areas. The electromagnetic field
(EMF) emitted by the line will be checked. If
possible the area under transmission line should
not be cleared.
Handling and Soil and Fuel storage tanks will have secondary EPC
Storage of Water containment with sufficient volume to contain a Contractor
Fuels and Contamination spill from the largest tank in the containment
Hazardous from Spills structure (110% of the contents of largest tank).
Materials The containment area will have a means of
removing accumulated water. Drains will be
2.2 routed through the site oil/water separator.
Proper equipment must be available on site for
the workers to contain and clean up spills of
chemicals, oil and fuel in case of an emergency.
20
Intake and Disturbance of Main mitigation is in siting the exact location of EPC
Outfall Aquatic the intake and outfall. Construction wastes will Contractor
Construction Resources not be disposed of in the bay. Intake design will
follow the USEPA Draft Guidance for
Evaluating Adverse Impact of Cooling Water
Structures on the Aquatic Environment and the
European Commission IPPC reference
Document on the Best Available Techniques for
Industrial Cooling Systems. Dredged materials
and water will be monitored for mercury.
Dredged materials and water found to have a
2.3 mercury content above the guidance found in
Evaluation of Dredged Material Proposed for
Ocean Disposal (USEPA 503/8-91/001) will be
segregated and disposed of in a secure hazardous
waste landfill. Liquid wastes will be sent for
offsite treatment. Experienced marine
contractors with environmental procedure in
place should be contract ted to perform all work.
Cooling Water Chemical Cooling water will be treated with sodium EPC
Discharge effects on hypochlorite to eliminate fouling. Residual Contractor
aquatic chlorine in the effluent will meet World Bank
2.4 ecosystem guidelines (0.2 mg/liter). PH and residual
chlorine levels shall be monitored on a
continuous basis.
Cooling Water Thermal The discharge will be designed to minimize or EPC
Discharge effects on eliminate re-suspension of sediment in the Contractor
marine fauna. vicinity of the outfall. If the impacts are found to
2.9 be greater than predicted after operation begins,
modifications to the diffuser operation shall be
made to increase mixing and reduce impacts
accordingly.
21
Cooling Water Entrainment Final location to be made to minimize impact on EPC
Intake of larval fish, aquatic environment. Bar screen intake screens Contractor
shellfish, and with spacing of 25cm will be utilized. Final
2.5 other marine screening with traveling water screens at cooling
fauna. water pump suctions will be employed. An inlet
velocity less than 1 m/s to will be used to
minimized entrainment.
Intake and Sediment Intake and outfall will be constructed with the EPC
2.6 Outfall Release intent to minimize the release of sediments to the Contractor
Construction bay.
Distillate Fuel Air emissions The combustion turbines will employ state of the EPC
Oil of NOx, SO2, art control technology for all pollutants. NOx Contractor
Combustion CO, shall be controlled using water injection. SO2
particulate shall be controlled by firing only low sulfur
matter, and (<0.1% by wt.), distillate fuel oil. Employing
volatile good combustion control will control CO,
organic particulate matter, and volatile organic
2.7 compounds compounds. The plant will feature stack heights
that can that conform to good engineering practice (GEP)
adversely stack height to facilitate dispersion of emitted
affect human gasses. The stack height will be approximately
health and the 50 m from grade.
environment.
Equipment Noise from The combustion turbines will be enclosed in an EPC
Operation Equipment acoustic enclosure to ensure that noise does not Contractor
exceed 85 dB(A) at 1 m. Workers in close
proximity to this equipment will be required to
2.8 use hearing protection. Offsite noise will not
exceed 70 dB(A). The noise requirement stated
in the technical proposal shall be respected.
22
Fresh Water Reduce water The plant will supply its own service water EPC
Supply supply to the supply from the Blue Sea through a membrane Contractor
2.10 local desalination system.
community.
Storm water Site drainage - All buildings shall be provided with suitable EPC
soil erosion means for disposal of storm water. This shall be Contractor
accomplished by either use of gutters or down
pipes or gargoyles as appropriate to the
building's design and usage. All such drainage
2.11
shall be routed to the site drainage system. It is
important that all culverts be sized to adequately
pass expected sreamflow under flood conditions.
Any marine disposal of excavated material EPC
2.12 should be done away from sensitive fisheries or Contractor
breeding grounds.
Marine contractors utilized on the project will be EPC
required to demonstrate use of BMP’s to Contractor
2.14 minimize the environmental impact of their
work. It is up to the EPC contractor to identify
and avoid sensitive marine environments.
Sewage Discharge of A sewage treatment facility will be provided at EPC
Treatment nutrients and the plant and discharge of treated effluent will be Contractor
other combined with the cooling water discharge. The
contaminants sewage treatment plant will provide secondary
to waterways treatment either through aerobic or anaerobic
2.15
treatment. The EPC contractor will be
responsible for the design of the treatment
system to meet the effluent standards stated in
this specification.
23
Aesthetics Aesthetically Some disruption is unavoidable. The plant will EPC
displeasing be shielded by trees and set back from the ocean. Contractor
appearance Comprehensive landscaping will be used to
2.17 may affect the enhance the appearance of the generation
tourist appeal facility.
of the coast.
Site Work – Loss of Trees There are few trees that are potentially affected EPC
Clearing and by the Site work. No trees will be cut that do not Contractor
3.1 Grading interfere with the site work. The wood that is
3. Site Preparation
cleared will be made available to local residents.
Site Work – Contamination Vegetative removal should be done manually EPC
3.2 Clearing and of soil without the use of herbicides. Contractor
Grading
Borrow Site Conflicts with Borrow area shall avoid agricultural areas. EPC
3.3 Present Land Contractor
Use
Borrow Site Disturbance to All permits and approvals will be obtained from EPC
3.4 Local the appropriate authority prior to operating a Contractor
Community borrow area on or off site.
Site Work – Interference Final site grade will facilitate drainage and avoid EPC
4. Construction /
Commissioning
Clearing and with Natural flooding and pooling. Protecting stockpiles Contractor
Grading Site Drainage through the use of silt fencing and reduced slope
- Soil Erosion angles will also minimize soil erosion during
construction. Measures such as seeding may also
4.1
be implemented to minimize erosion of
stockpiles.
24
Site Work – Noise from Construction equipment shall meet the EPC
Clearing and Equipment applicable standard in EU Directive 2000/14/EC Contractor
Grading - site of May 2000. This Directive applies to the
access and manufacturer of the noise emitting equipment.
roadwork Work involving nuisance noise will be
minimized during locally recognized days of rest
4.2 and at night. All equipment will be maintained in
good working order. Construction activities that
generate significant noise levels will be limited
to reasonable daytime hours. These conditions
shall be specified in the bidding documents.
Site Work – Dust from Watering of disturbed site areas on an as needed EPC
Clearing and Equipment basis will minimize dust. Fugitive dust emissions Contractor
Grading - site from roads and site work can be eliminated on
4.3 access and minimized by applying water on an as needed
roadwork basis to dirt roads and exposed construction
areas during the dry season (oil will not be used
as a dust suppressant).
Dewatering Sediment and Where site excavations requiring dewatering, the EPC
Oil and excess water will be visually inspected for oil Contractor
Grease contamination prior to discharge to the site
loading to drainage system. Oil contaminated water will
4.4 Nearby require treatment prior to disposal. Water
Waterways potentially contaminated. Any visible oil and
grease shall be skimmed off the surface using
absorbent pads.
Dewatering Sediment to Measures that may be taken to remove settle able EPC
nearby solids prior to discharging water from the site Contractor
4.6 waterways include the use of sediment sumps or other
sediment control structures. An oil water
separator shall be installed.
25
Site Work – Sediment to Exposed soil surfaces should be revegetated as EPC
Clearing and nearby soon as possible to further minimize the potential Contractor
4.8 Grading - site waterways for erosion and sediment releases.
access and
roadwork
Potential The construction mitigation plan contains EPC
Mercury sediment sampling and analysis requirements to Contractor
4.9 release from ensure that contaminated material is handled
dredging properly.
Segregation of Contamination The following mitigation measures should be EPC
liquid wastes of surrounding employed: Segregate all waste oils and Contractor
surface water lubricants from maintenance of construction
and equipment and dispose of these wastes properly;
4.10 groundwater inspect secondary containment areas and other
sumps regularly and properly remove oil from
the surface of the accumulated material.
Disposal of Interference to The amount of material to be disposed of will be EPC
Excavated Natural minimized by borrowing only as much as is Contractor
4.11 Material if Drainage needed.
Necessary
Disposal of Disturbance to Local authorities should approve the disposal EPC
Excavated Land site. It will not interfere with local land use. Contractor
4.12 Material if Vegetation will be performed using local plants.
Necessary All slopes at a borrow disposal site will be
graded to a stable condition.
Provision of Reduced The water supply for use in construction of the EPC
Potable Water Water Supply generation facility must be monitored to ensure Contractor
4.13 to Area that it does not adversely affect other water uses
Residence in the area.
26
Aggregate Reduced No new sources will be developed. Existing EPC
4.14 Source Local quarries will be utilized. Contractor
Resources
Batch Plant - Noise, Dust, Storm water runoff will be directed to the site EPC
Concrete and and Potential drainage system. Noise will be controlled to an Contractor
Asphalt Runoff acceptable level. Dust bags will be installed as
4.15 Concerns necessary. The EPC specification will require
that the batch plant owner/operator must hold
valid operating permit.
Delivery of Increased Scheduling the delivery of major plant EPC
Equipment and Traffic and components for off-peak traffic times can also Contractor
4.16 Materials Dust help to mitigate impacts on the local traffic flow.
Delivery of Increased Upgrade of the main access road to plant will EPC
Equipment and Traffic and have positive effect on local traffic. Dust from Contractor
Materials Dust the road will be minimized with water during
4.17 construction and by providing paved surface.
Trucks will be tarped when carrying load. Road
speeds will be control
Borrow Site Unsightly On and off site borrow areas will be reworked to EPC
Area Finished blend into the surroundings. Renegotiation will Contractor
Construction
with Borrow be performed using notice plant species. All
5. End of
5.1
Activity slopes and working faces will be returned to a
stable condition.
Final Site Aesthetics Topsoil will be graded and planted as EPC
5.2 appropriate. Contractor
27
B. Monitoring Plan
Responsibility
- Submission Approval
Category Item no. Activity Plan / Monitored Parameter Monitoring Schedule Date by
Transmission An environmental assessment of the transmission line NPC Env. NPC
line routing will be performed when the final transmission line route Consultant
1.1 is set. 8 weeks after
finalization of
line routing
Handling and Oil spill response, recovery and mitigation plan. Audit storage and EPC NPC
Storage of All related activities shall be tracked and documented. handling records monthly; Contractor
1.2 Fuels and revise plan as required. 4 weeks before
Hazardous excavation
1. Planning/Logistics
Materials
All site Emergency response plan. All related actives shall be Audit records monthly; EPC NPC
activities tracked and documented. revise plan as required. Contractor
1.3
4 weeks before
excavation
Site Work - A site grading and drainage plan shall be developed to Audit records semi- EPC NPC
Clearing and manage flow of water offsite in a responsible manner. annually Contractor
Grading - site Measures taken to protect against erosion shall be 4 weeks before
1.4 access and road indicated. All areas shall be included in this plan such as excavation
work the construction site itself, the batch plant area, the
equipment staging areas etc.
Construction Community impact action plant (only if deemed NPC /
and Operation necessary) Consultant
of Power Plant NPC to clarify
1.5 necessarily
before contract
award
28
Handling and Health and safety plan. All related activities shall be Audit records semi- EPC NPC
Storage of tracked and documented. annually. Contractor
1.6 Fuels and
Hazardous
Materials
Compliance Noise and vibration plan including baseline monitoring EPC NPC
with noise Contractor
1.7 requirements 4 weeks before
excavation
Disposal of Waste management plan shall be developed Audit records monthly; EPC NPC
Waste revise plan as required. Contractor
1.8
4 weeks before
excavation
Establishing Simplified employee health and safety manual NPC
health and 4 weeks before
1.9 safety commencement
standards for of
O&M staff commissioning
Establishing Ambient air monitoring including meteorological data, Continuous monitoring NPC
baseline for sulfur dioxide, oxides of nitrogen, and particulate matter. ongoing
1.10 ambient air
quality
Intake and The EPC contractor will perform a siting study to EPC NPC / Env.
Outfall determine the most appropriate exact location and the Contractor to Consultant
1.11 Construction best time to construct the intake and outfall structures. be indicated by
Contractor in
Bid
29
Intake and The EPC Contractor will also conduct subsequent EPC NPC / Env.
Outfall confirmatory modeling to assess the thermal impact and Contractor to Consultant
Construction make adjustments to the discharge diffuser design if be indicated by
necessary. Thermal discharge modeling demonstrates Contractor in
1.12 that the thermal impact from the discharge is less than or Bid
equal to 3°C after mixing zone. This ensures that there is
minimal impact from the discharge.
Sediment Sediment control plan including procedures for sampling Weekly EPC NPC / Env.
control and analysis for mercury contamination in areas of Contractor Consultant
1.13 potential dredging. All related activities shall be tracked 4 weeks before
and documented. excavation
Site Work - The practice of sharing the wood that is cleared with the Weekly EPC NPC
1.14 Clearing and local residents shall be monitored and documented. Contractor
Grading
Final Site A plan for final grading and landscaping of the site will Audit records semi- EPC NPC
1.15 be developed and maintained onsite. annually. Contractor
Permitting Contractor shall provide support to the Owner for Review requirements NPC
obtaining the relevant environmental permits for the monthly
1.16 construction and operation of the plant from the
authorities.
Borrow Site Monitor and document that borrow areas avoid Monthly EPC
Construction
2.1 agricultural areas. Contractor
Borrow Site Obtain and maintain applicable permits. As required EPC
2.2
2.
Contractor
All activities of A first aid station will be provided for workers onsite. Aid station to be manned EPC
2.3 Construction continuously during Contractor
Work Force working hours.
30
Site Work - Protecting stockpiles through the use of silt fencing and Weekly EPC
Clearing and reduced slope angles to minimize soil erosion during Contractor
2.4 Grading construction will be monitored to ensure that the practice
conforms to site drainage plan.
Site Work - High-volume dust sample to monitor emissions from Sample for 24-hr period, EPC
Clearing and batch plant. monthly throughout Contractor
Grading construction
2.5
Site Access High-volume dust sample to monitor emissions from Sample for 24-hr period, EPC
Upgrades - batch plant. monthly throughout Contractor
Roadwork construction
2.6
Dewatering Maintain a record of visual inspection of excess water Monthly EPC
2.7 from dewatering activity. Contractor
Disposal of Monitor and document the use of borrow material. Monthly EPC
Excavated Contractor
2.8 Material if
Necessary
Transmission Document the amount of land used for the transmission Monthly EPC
2.9 Interconnection interconnection and that no agricultural lands are Contractor
disturbed.
Provision of Monitor water supply to ensure that it does not adversely Monthly EPC
2.10 Potable Water affect other water uses in the area. Contractor
Aggregate Records will be kept on quarries utilized Audit records semi- EPC
2.11 Source annually. Contractor
31
Batch Plant - Monitor noise at the perimeter of the site during the peak Monitor noise once, at EPC
Concrete and of construction activity. In addition, spot monitoring of both day and night, for an Contractor
Asphalt various pieces of construction equipment will take place eight-hour period. Spot
to ensure that noise emissions are not excessive. The site monitoring of equipment
construction manager will maintain records of any noise to be conducted weekly.
2.12 complaints received during the construction process. Review complaint records
Visual inspection of dust emissions will be performed monthly. Inspect dust
daily with records of results. emissions daily.
Delivery of Visual inspection of dust from road construction will be Monitor road dust and EPC
Equipment and ongoing and application of water will be employed to speeds daily. Contractor
2.13 Materials suppress dust during periods of high dust generation.
Road speeds shall be clearly posted.
Solid Waste Contact for proper disposal of solid waste will be kept Audit records semi- EPC
Disposal onsite. Records on the date of disposal and the amount annually. Contractor
2.14 and type of solid waste disposed will be maintained.
32
Liquid Waste Monitoring of the appropriate operational parameters Monitor operational EPC
Disposal and will be performed as per the manufacturer’s parameters monthly. Contractor
Sewage requirements. Oil water separators will be equipped with Inspect oil levels in
Treatment an oil level indicator and inspected daily. Sewage separators daily. Monitor
treatment may include portable facilities. If so, the containment levels in
containment levels will be monitored daily and the portable facilities daily.
contents disposed of properly when full level is reached. Monitor sewage treatment
If the sewage treatment consists of the packaged parameters daily.
2.15 treatment facility that will ultimately be placed into
service for the facility, then the appropriate parameters
such as airflow, temperature, and discharge biological
oxygen demand (BOD) should be monitored.
Intake and Documentation on the siting study performed to locate Audit records semi- EPC
2.16 Outfall the intake and discharge will be maintained onsite. annually. Contractor
Construction
Intake and Documentation on the siting study performed to locate Audit records semi- EPC
Outfall the intake and discharge will be maintained, including a annually. Contractor
2.17 Construction construction schedule and information on historic
fishing activity. A copy of this report will be maintained
onsite.
Intake and Documentation of construction authorization will be Audit records semi- EPC
2.18 Outfall maintained onsite annually. Contractor
Construction
33
Intake and The construction technique and means of minimizing Audit records semi- EPC
Outfall sediment releases will be documented and a copy annually. Monitor Contractor
Construction maintained onsite. Monitoring of mercury in sediments sediments for mercury
2.19 will be carried out if excavating and dredging are weekly (if required).
performed as part of the intake and outfall construction.
Cooling Water Documentation will be maintained onsite concerning the Audit records semi- EPC
2.20 Intake final design of the water intake including the inlet annually. Contractor
velocity.
Borrow Site Document final condition of borrow areas to ensure that Upon closure EPC
Construction
3.1 they have been reworked to blend into the surroundings Contractor
3. End of
and are safe.
Disposal of Obtain and maintain applicable permits. Document final Permitting as required. EPC
Excavated condition of borrow areas to ensure that they have been Document final area Contractor
3.2 Material if reworked to blend into the surroundings and are safe. conditions upon closure.
Necessary
Distillate Fuel Fuel Sulfur content will be monitored to ensure that it is Conduct comprehensive EPC
Oil less than or equal to 0.1% by weight. performance test. Monitor Contractor
Combustion NOx and opacity
Conduct performance test to confirm the emissions from continuously (minimum
4. Trial Run / Plant
4.1
Performance Test
the plant do not exceed the amounts listed in this report. three samples per hour).
The stack will include continuous monitoring of NOx
and opacity emissions.
Equipment Conduct baseline noise monitoring at the plant and at Monitor baseline noise EPC
Operation predefined offsite receptor locations. Monitor offsite, far prior to start of operation. Contractor
field noise at offsite locations to confirm that the Monitor far field noise
operation conforms to 70 dB(A) limit. once during facility
4.2 operation (at maximum
Workers in close proximity to the turbines or other noise operation conditions).
emitting equipment will wear hearing protection in Hearing protection to be
accordance with a written health and safety plan. used as required.
34
Cooling Water The condenser discharge temperature will be monitored Monitor daily EPC
Discharge to ensure the operation of the facility meets the Contractor
4.3 maximum temperature discharge. In addition, monitor
pH, residual chlorine, suspended solids and oil and
grease concentrations.
Sewage Monitoring of the appropriate operational parameters Monitor treatment plant EPC
Treatment will be performed as per the manufacturer’s daily for manufacturer's Contractor
requirements. If the sewage treatment consists of the recommended operating
packaged aerobic treatment system then the airflow, parameters. Inspect
temperature, and discharge biological oxygen demand associated equipment
(BOD) should be monitored at a minimum. If the system weekly. Audit records
4.4 consists of an anaerobic treatment process, then process semi-annually.
temperature, and discharge BOD should be monitored at
a minimum. Visually inspect all associated valves,
pumps, blowers, and filters.
Handling and Maintain the pertinent design information onsite. Inspect containment levels EPC
Storage of Records on the date of discharge, approximate quantity in separators daily. Test Contractor
Fuel's and of discharge, and final disposition of the discharge. Oil function of oil level
4.5 Hazardous water separators must be equipped with an oil level indicator weekly. Audit
Materials indicator and inspected regularly. Inspections of the records semi-annually.
proper function of the oil level indicator must be
performed.
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