Takoradi Thermal Power Plant Expansion Project (T2) Addendum

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							Takoradi Thermal Power Plant
Expansion Project (T2)


Addendum Environmental Report
Prepared in Support of March 1999
Supplementary Environmental Statement




Third Issue

Volume 1: Text

November 2001

Prepared by:

      ®




                          GIBB
on behalf of Takoradi International Company
TAKORADI THERMAL POWER PLANT EXPANSION
               PROJECT

    ADDENDUM ENVIRONMENTAL REPORT

PREPARED IN SUPPORT OF 1999 SUPPLEMENTARY
       ENVIRONMENTAL STATEMENT


              November 2001


             VOLUME 1: TEXT
TIC Takoradi Thermal Power Plant, Proposed Expansion


    TAKORADI THERMAL POWER PLANT EXPANSION PROJECT
      ADDENDUM ENVIRONMENTAL REPORT: THIRD ISSUE

                                            CONTENTS

Chapter        Description                                                             Page


EXECUTIVE SUMMARY                                                                           I

1              INTRODUCTION                                                              1-1

               1.1      General                                                          1-1

               1.2      Objectives of the Addendum                                       1-1

               1.3      Study Methodology                                                1-2

               1.4      Structure of Addendum                                            1-3

2              POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK                                2-1

               2.1      Introduction                                                     2-1

               2.2      National Environmental Requirements                              2-1

               2.3      Project Sponsors and Stakeholders                                2-1

3              TAKORADI 2 PROJECT OVERVIEW                                               3-1

               3.1      Introduction                                                     3-1

               3.2      Background and Status of the TTPP Development                    3-1

               3.3      T2 Project                                                       3-2

               3.4      Common, Shared Facilities with T1                                3-8

               3.5      Site Preparation and Construction Details                       3-11

               3.6      Operation Details                                               3-14

               3.7      Summary of Key T2 Changes Since 1999                            3-17

4              BASELINE ENVIRONMENTAL CONDITIONS                                         4-1

               4.1      Introduction                                                     4-1

               4.2      Physical Environment                                             4-2

               4.3      Biological Environment                                           4-3

               4.4      Human Environment                                                4-4


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               4.5      Environmental Quality of the Area                                  4-10

5              SIGNIFICANT ENVIRONMENTAL EFFECTS                                            5-1

               5.1      Introduction                                                        5-1

               5.2      Physical Environment                                                5-1

               5.3      Biological Environment                                              5-2

               5.4      Human Environment                                                   5-3

               5.5      Environmental Quality of the Area                                   5-6

6              MITIGATION MEASURES AND LIKELY NET ENVIRONMENTAL
               EFFECTS                                                                      6-1

               6.1      Introduction                                                        6-1

               6.2      Physical Environment                                                6-1

               6.3      Biological Environment                                              6-1

               6.4      Human Environment                                                   6-1

               6.5      Environmental Quality of the Area                                   6-2

7              HEALTH AND SAFETY MANAGEMENT FOR T2                                          7-1

               7.1      Introduction                                                        7-1

               7.2      Site Preparation and Construction Phases, T2                        7-1

               7.3      Operational Phase, T2                                               7-3

8              ENVIRONMENTAL MANAGEMENT AND MONITORING PROGRAMME,
               T2                                                                           8-1

               8.1      Provisional EMMP for T2                                             8-1

               8.2      T1 EMMP                                                             8-2

               8.3      T1 Environmental Management System                                  8-2

9              CONCLUSIONS                                                                  9-1

               9.1      Introduction                                                        9-1

               9.2      Conclusions on Overall Effect of T2                                 9-1

               9.3      Conclusions on Overall Effect of T1 + T2                            9-1

               9.4      Conclusions of Addendum                                             9-2




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Figures:

Figure 3.1:             Location Plan
Figure 3.2:             T2 Structures and Layout, Simple Cycle 1, Phase 1
Figure 3.3:             T2 Structures and Layout, Simple Cycle 2, Phase 2a
Figure 3.4:             T2 Structure and Layout, Combined Cycle, Phase 2b
Figure 3.5:             Transmission Line Routes Associated with TTPP
Figure 3.6:             Construction Schedule Phase 2b, Combined Cycle

Photographs:

Photograph Sheet 1:             Photograph 1
Photograph Sheet 2:             Photographs 2a to 3a
Photograph Sheet 3:             Photographs 3b to 4b
Photograph Sheet 4:             Photograph 5
Photograph Sheet 5:             Photographs 6 to 7
Photograph Sheet 6:             Photographs 8a to 8c
Photograph Sheet 7:             Photograph 9

Appendices:                     See Volume 2




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                                THIS PAGE IS INTENTIONALLY BLANK




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           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 T1 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.1 T1 began generating power in December 1997.

           The design of T1 was structured as such to provide for the T2 expansion to
           accommodate future electrical energy demand growth and to effectively double the
           plant’s output from 330 MW to 660 MW. A Supplementary Environmental Impact
           Assessment was undertaken of the proposed T2 expansion in 1999 in accordance
           with guidance from the Environmental 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
           ‘1999 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.




1
    Acres International Limited, Takoradi Thermal Plant Environmental Assessment, Volumes 1 and 2, 1995.

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           Takoradi Thermal Power Plant


           The Existing T1 Plant

           TTPP was largely developed in response to a consistently high rate of growth in
           domestic demand for electrical energy generation in Ghana which far exceeded the
           actual capacity for energy generation available, as well as exceeding projected
           annual average long term capacity levels. It was subsequently identified that
           developing Ghana’s power generating capacity through the use of combustion turbine
           technology was preferable to expanding the existing hydro-electric system. T1 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 T1 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 T1 proposals were
                                           Accra
                                                             subject to an EIA and public
                                                             consultation between 1993 and
                                                             1995 which led to the preparation
                     Takoradi
                                                             of the 1995 EIA Report; this was
                                                             prepared with due reference to
                                                             World        Bank        criteria2.
           Environmental Approval for the construction of T1 to commence was provided in July
           1995.

           Construction of T1 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 T1 was
           operational in combined cycle, with the second T1 CTG currently under repair.
           Repair is expected to be complete in July 2001.


2
    Operational Directive 4.01, Environmental Assessment, October 1991.
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        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 T1 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 Ghana’s 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
        1.3 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 1999 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 T1 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 T1. 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, oil/water 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 T1
        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
        pipeline.

        Key shared facilities have been described in 1999 SEIS and are outlined again in
        section 3.4 of this report. Updates on the status of transmission line upgrades and
        the West African Gas 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 (SC1), 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.

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        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




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        Alternatives Considered for T1 and T2

        As T2 is accommodated within the T1 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:

•       The ‘Do-Nothing’ option (i.e. a hypothetical situation where T1 is not constructed);

•       Alternative geographical locations (e.g. eastern and western Ghana, coastal and
        inland locations)

•       Alternative technologies including open and closed-circuit cooling water systems,

•       Using alternative fuels, including LCO and residual fuel oil

•       Using alternative methods for fuel oil transportation; and

•       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 T1 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 EPA’s ‘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)

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        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 Group/IFC criteria as listed
        below.

        World Bank Group Environmental Criteria

        Both IFC and OPIC require that projects should be assessed relative to the following:

•       World Bank Group’s Pollution Prevent and Abatement Handbook, 1998 – Thermal
        Power: Guidelines for New Plants

•       World Bank Group’s Occupational Health and Safety Guidelines

•       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 T1.

        Physical Environment

        Landscape and Visual Quality

        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 T1, had already been cleared of vegetation, regraded and levelled during the
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           construction T1. 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 flora/vegetation 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 Policy.3

           As the T2 site is incorporated within the T1 boundary there was little vegetation
           present prior to construction commencing as the site had already been cleared during
           site preparation activities for T1. Similarly, for borrow areas, those sites being used
           for T2 had already been ‘active’ for the T1 construction period. There were also no
           forests present on the site prior to clearance for T1.

           Human Environment

           The following represent the key features of the existing human environment affected
           by TTPP. A map showing the site's location relative to surrounding settlements can
           be found on the 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 T1 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 Ownership and Compensation

           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 T1. Land was acquired from the ‘Stool Lands’ of
           Dwomo (i.e. 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 T1, 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 Inchaban and from Dwomo to

3
    OP.4.04, Natural Habitats

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        Inchaban 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 Management

        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.




                                                                   VRA TOWNSHIP

                                                               TTPP




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        Environmental Quality of the Area

        Air Quality

        Routine stack emissions and ground level air quality monitoring for T1 in 1999
        indicate the following:

•       NOx stack emissions have largely remained within World Bank criteria, with the
        exception of conditions where the NOx control systems were temporarily offline.

•       SO2 stack emissions were within the relevant World Bank criteria;

•       Where available, ground level PM10 and SO2 concentrations monitoring data indicated
        that concentrations were well within the relevant Ghanaian criteria. However it is
        important to note that ground level NOx monitoring equipment was generally out of
        service throughout 1999 and various problems were experienced with the remaining
        monitors.

        Water Supply

        Water is supplied via a dedicated water supply pipeline from Inchaban reservoir
        approximately 3 km north west of the site. This can provide a maximum supply of
        1,820 m3 /day to T1 and can be supplemented by desalinated seawater from the T1
        Desalination plant of up to 1,135m3/day. In Phase II of the T2 development, a further
        Desalination plant of more than 2080m3/day capacity will be constructed to ensure
        baseload freshwater demand for both the T1 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 T1 for 1999 indicate that with the exception of
        suspended solids, monitored results were within the relevant T1 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


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        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 T1 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 EPA 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

        Landscape 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 T1, 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 Ecology, Natural Habitats and Forestry

        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 T1. In addition, the ecological importance of the
        area prior to site clearance for T1 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
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        laydown areas have been located on sites previously used for T1 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 Property

        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 T1, and T2 is being constructed within the existing TTPP site
        and/or affects land previously affected by T1.

        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 Management

        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 T1 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

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        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 Management

        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 T1.
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        Air Quality

        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.        T1 stack emissions results and ground level pollution
        concentrations indicate that concentrations have largely been in compliance with the
        relevant criteria for T1, as well as the current criteria. The exceptions include
        instances where the NOx control systems have been offline and NOx 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 PM10 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 NOx levels have
        remained within the 1998 World Bank NOx 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 SO2, PM10 and NOx.
        Predictions made in the 1999 SEIS of the cumulative effects for T1 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 T1 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 CO2 emission of 1.78 MtC. However, within the context of global emissions of
        CO2, Ghana’s entire CO2 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
        CO2.

        There is a potential cumulative adverse effect with T2 compared to T1 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


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        reduced for T1 by the installation on the cooling towers of drift eliminators, which will
        also be installed on the new cooling towers proposed for T2.


        Water Supply and Wastewater

        A Desalination plant will be constructed during Phase IIb of T2 to supplement the
        supply from the T1 Desalination plant and from Inchaban 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 T1’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 TTPP’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 T1.

        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 Waterways

        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
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        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 T2’s 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.




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         Table (i) Ground Level Air Quality Summary
Contaminant Averaging                                          Ground Level Concentrations (GLC) Time Weighted Average (TWA) in µg/m3
              Time
                            Estimated         T1           T1         T1 Actual    T1 Actual T1 and T2 T1 and T2         T1 and T2         Ghanaian EPA              World Bank
                            pre TTPP      Predicted     Predicted     (1998) (c)   (1999) (c) Predicted Predicted          actual           Guidelines               Guidelines
                             Backgrd      Increment       Total                               Increments  Total            (2000)              (g)
                                (a)                                                              (CC on oil) (CC on oil) (T1 CC, T2 Land         T1       T2    T1 (1988) T2 (1998)
                                                                                                       (e)          (e)     SC, on oil) Use                         (h)         (i)
SO2             1hr          35           34.8          69.8                         20         58.7          94                        I                   900
                                                                                                                                        R                   700
                24hrs        35           23.9          58.9           65.4                     11.6          47           24.7         I         200       150         500         150
                                                                                                                                        R                   100
                1yr          35           20.5          55.5                                    1.3           36                        I                    80         100          80
                                                                                                                                        R                    50
NOx             1hr          7            52.7          59.7                                    72.9          80                        I                   400
                                                                                                                                        R              -
                24hrs        7            36.5          43.5           120 (d)       49.8       14.3          21           46.0         I         320       150                     150
                                                                                                                                        R                    60
                1yr          7            31.3          38.3                                    1.66          9                                                         100         100
Total           24hr         94           0.8           98.8                                                                            I         260       230         500         230
Suspended                                                                                                                               R                   150
Particulate     1yr          94           0.7           98.7                                                                            I                    75         100          80
(TSP)                                                                                                                                   R                    60
PM10            1hr          84 (b)       0.8           84.8                                    10.4          95           NA (f)
                24hr         84           0.7           84.7           17-124        12-92      2.05          86                                             70         500         150
                1yr          84                         84.0                                    0.24          84                                                                     50
         Note: The World Bank limits given in the World Bank’s Pollution Prevention and Abatement Handbook are to be used only in the absence of host country standards.
         The table above demonstrates that in most cases the Ghanaian limits are stricter than those set out by the World Bank.
         I = Industrial Environment
         R = Residential Environment
         (a) Background from 1993 two-week exercise. Statistical and seasonal variations mean the actual background may vary significantly from the figures quoted.
         (b) The figure quoted for particulate was averaged over two weeks. Consequently, the hourly, 24-hr values could be expected to be higher. Particulate levels are also
         very dependent on local conditions during monitoring, with dust generation varying significantly with season and weather.
         (c) Values quoted here are the maximum of the TWA’s for the year. PM10 is the exception and is quoted as a range to illustrate the variability in the environment.
         (d) This value was recorded in Beposo village. The monitoring sites are affected by other emission sources that are relevant when comparing to background levels
         (e) The characteristics of the T1/T2 prediction differ from the T1 prediction as a result of the modelling approach and met data set used.
         (f) Not available. Due to equipment breakdown and subsequent procurement difficulties no PM 10 data collected
         (g) A set of Ghanaian guidelines applied at the time of the 1995 EIA submission and are relevant to T1, while updated limits at the time of the 1999 SEIS apply to T2.
         (h) Applies to T1 predictions and monitoring results
         (i) Applies to T1 & T2 predictions and monitoring results


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         Table (ii) Stack Emissions Summary

Contaminant           Averaging T1 Predicted                 T2 Predicted          T1 Jan 99- T1 Jan 00-Dec 00                      T2 Mar 00         T2 Apr 00- Dec 00 Relevant Guidelines
                        Basis        (EIA)                      (SEIS)               Dec 99
SO2                 1hr (ng/J)   92.7                                             28    - 249 25 - 196                                                                            258 (j)
                    1hr (mg/Nm3)                            330.9                                                                                     <889   (h)                  2000 (j)
                    (tpd)        <2.4 (a)                   <2.4                  <2.4        (a)          <2.4     (a)           <2.4 (a)            <2.4   (a)                  116 (k) (T1+T2 emissions)
                               3
NOx                 1hr (mg/Nm )                            205                                                                   128-153             77   - 408 (i)              300 or
                                                                                  (c)                      (c)                                                                    400 without NOx
                                                                                                                                                                                  control (l)
                    1hr (ng/J)          100                                       82        - 415( 23             - 369 (f),(g) (c)                   (c)                         100 (m)
                                                                                              d)                                                                                  130
PM10                1hr (mg/Nm3) 15, 16 (b)                 15, 16 (b)            (e)                      (e)                    (e)                 [16]          (e)           50(n)

Note: Figures bound in parentheses are quoted for comparison only. The corresponding guideline is not directly relevant to the bracketed figure.
(a) . This figure based on design mass discharge with 24 hour operation on 0.17% sulphur by weight crude. Fuel sulphur content is restricted to below 0.2%, and total emissions predicted to be <
2.4+2.4 = 4.8 tpd.
(b) Based on 5g/s design emission rate in combined cycle and simple cycle respectively.
(c) Data is given in the relevant units for each unit. However, for illustrative purposes, T1’s 1999 emissions achieved 98% Compliance with the 1998 World Bank 300 mg/m3 Limit under all operating
conditions, 99.5% with 400mg/m3 Limit.
(d) Exceedances that occurred were attributed to NOx control equipment failure. These were associated with the water injection control valves and have since been addressed.
(e) Not measured as a result of very low anticipated emissions. The value indicated in brackets for T2 Apr 00 - Dec 00 is as per estimates for simple cycle operation.
(f) Injection system problems over this period were linked to demineralisation problems and led to higher NOx. 89% compliance with 1988 World Bank Limit over this period.
(g) Fuel-bound Nitrogen (FBN) allowance would lift limit to 174ng/J for Jan-Mar 2000, 222ng/J for Apr December 2000
(h) Based on maximum measured value from T1 monitoring (249ng/J). Note that SO2 emissions are limited by the <0.2% Fuel Sulphur content, and this value represents the likely peak
(i) A 2% exceedance of the upper limit occurred during NOx control failure arising from demineralisation issues, otherwise compliance with limits is approximately 100% (AER 2000)
(j) 258 ng/J Canadian Guideline taken as effective World Bank guideline for T1. 1998 World Bank Guideline of 2000mg/Nm3 flue gas (0oC, 1 atm, 15% O2) concentration applies to T2, however SO2
not measured due to fuel-Sulphur control.
(k) This 1998 World Bank guideline is cumulative for the site. Based on 0.2tpd/MW x 500MW for first 500MW, 0.1tpd/MW for each additional MW over 500MW to 660MW (TTPP) for non-degraded
airsheds.
(l) World Bank PPAH Limits 1998, applying to T2. "Without NOx control" refers to scenarios where there are technical difficulties such as scarcity of water for water injection. TTPP countered water
issues by employing purification plant, during the establishment of which issues arose that affected the NOx water injection. World Bank advise that the 300mg/m3 limit applies to TTPP's ongoing
operation and they require that during ongoing operation the NOx control equipment will be operated in a way that ensures compliance with the 300mg/m3 limit.
(m) 100ng/J is the T1 limit required subsequent to the 1995 EIA. 130ng/J was the World Bank 1988 Limit. A Fuel Bound Nitrogen uplift, as introduced after 1995, is considered against the World
Bank limit in note g to indicate how it might have affected earlier World Bank guidelines.
(n) 1998 World Bank PPAH Guideline.




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        Table (iii) Wastewater Quality Summary


Contaminant             T1 Predicted     T1 Actual  T1 and T2 (As                               T1 and T2       Ghanaian EPA           World Bank              World Bank
                           Levels     Levels (1999) Controlled By                                 (2000)         Guidelines            Guidelines              Guidelines
                                                       Process)                                                                          1988                   1998 (e)
BOD5 (mg/L)             20           NA (a)                                               NA                    50                  30
Suspended Solids (mg/L) 25           0.6-80 (b)                                           8-116 (b)             50                  30                    50
Total Coliform (100mL) 100           0              0                                     0                     -                   100
pH                      6.5-9        6.5-9          6.5-9                                 6.5-10                6-9                 6-9                   6-9
Oil and Grease (mg/L)   5            <5             <5                                    NVS (d)               5                   5/NVS                 10
Temperature (oC)                     0.12oC below                                         0.10oC above          <3oC above          <3oC above            <3oC above
                                     ambient (c) at                                       ambient at beach      ambient at edge     ambient at edge       ambient at edge
                                     beach                                                (Aboadze)             of mixing zone      of mixing zone        of mixing zone
                                     (Aboadze)
Total Residual Chlorine <0.2         (f)            <0.2                                  (f)                                                             <0.2
(mg/L)
Chromium (Total) (mg/L) <0.5         (f)            <0.5                                  (f)                                                             <0.5
Copper (mg/L)           <0.5         (f)            <0.5                                  (f)                                                             <0.5
Iron (mg/L)             <1.0         (f)            <1.0                                  (f)                                                             <1.0
Zinc (mg/L)             <0.5         (f)            <1.0                                  (f)                                                             <1.0

(a) Not applicable - irrelevant to the discharge types involved
(b) Limit exceeded 4 times per year
                                                                                                                 o
(c) 'Ambient' taken as 1998 baseline annual average beach-side sea temperature down-current at Aboadze (26.29 C)
(d) No Visible Sheen, taken as 5mg/L
(e) PPAH Effluent Levels required for new Thermal Power Plant. These guidelines also include Total Residual Chlorine, Total Chromium, Copper, Iron and Zinc. While
Chlorine and Iron are measured and checked prior to discharge, the remainders are not presently measured at the TTPP as the nature of the discharge does not require it.
(f) These parameters are controlled by waste treatment measures but did not form part of the Ghanaian EPA criteria to which TTPP has been operating. Testing for Copper
and Iron is however proposed in the provisional EMP.




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        Table (iv) Noise Level Summary


Location            Background T1 Predicted T1 Predicted       T1 Actual     T1&2     T1&2 Actual Ghanaian                                        World Bank
                    Noise Levels Levels (L Aeq Levels (L Aeq Levels (1999 Predicted Levels (Sept      EPA                                         Guidelines (i)
                       (1993       dB) In SC     dB) In CC    Survey) (d)   Levels (L  -Dec 2000) Guidelines
                     Survey) (a)                                           Aeq dB) CC      (e)
                                                                                                  Day Night                                        Day      Night
Beach at Amazu      42.3-54.9    36            40            58.3         43                     55 (h) 48                                       55 (j)     45
Lorry Park, Aboadze 44-56 (b)    40            44            48.8-53.9    47                     55 (h) 48                                       55 (j)     45
Aboadze Monitoring 42.3-49.5 (c) 36            40            43.4- 50.3   42          44-62 (f)  55 (h) 48                                       55 (j)     45
Station
VRA Township        NA           40            43            40.4-59.1    45          44-62 (f)  55 (h) 48                                       55 (j)     45
TTPP Boundary                                                50.1-62.6                40-72 (g)  55 (h) 48                                       55 (j)     45

(a) These background levels were from an isolated noise survey and may vary in relation to environmental or development factors. For example, noise from wave action was
observed in the 1993 survey at Amazu.
(b) The background location was actually Methodist Church in Aboadze, used for comparison.
(c) The background location was actually Primary School in Aboadze, used for comparison.
(d) Construction activities were occurring during this survey.
(e) Levels after September 2000 are given because this period excluded major construction activities
(f) All months measured <= 55 with exception of December
(g) An increase in noise levels was observed on the North, West and South boundaries, likely to be a result of the expansion. However, noise levels in the community do not
appear to been appreciably affected by this.
(h) "Residential areas with negligible or infrequent transportation.
(i) These are the most recent 1998 PPAH standards and apply to the property boundary. The 1988 standards relevant to the T1-only phase of operation apply to the perimeter
fence.
(j) "Residential/Educational/Institutional"




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                                            TIC Takoradi Thermal Power Plant, Proposed Expansion




        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 T1 during construction is
                                reduced. Extend the landscape planting proposals developed for
                                T1 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.
        Ecology                 Mitigation measures to be incorporated during the construction
                                include utilising existing T1 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.
        General Social          The Community Impact Agreement initiated under T1 will continue
        Issues                  to provide mitigation for T2, through, for example providing a
                                forum for any concerns etc. of the local communities to be voiced
                                about T2 construction activities. Provision of public health
                                awareness training to T2 construction and operations personnel
                                and the extension of anti-malaria mosquito spraying to T2 areas
                                will help reduce any associated public health problems. In terms
                                of pest management it is 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

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                                there will be no significant residual effects beyond the
                                construction and operations phase.
        Air Quality             Mitigation measures to limit dust generation during the
                                construction stage include traffic management, protecting
                                stockpiles of material and damping down areas. In terms of the
                                operation of T2, mitigation measures associated with the design
                                of the plant (which are in agreement with those for T1), such as
                                the use of water injection for NOx 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 NO2 and SO2 predictions for
                                the cumulative impact of TTPP will remain within relevant criteria
                                in particular. In terms of global CO2 emissions, as Ghana’s CO2
                                emissions will remain a very small percentage of total CO2
                                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
                                TIC’s consultants will reduce the significance and impact of any
                                incidents during construction. The closed cooling system was
                                chosen to mitigate thermal discharge and the wastewater
                                discharge monitoring plan will help to ensure discharges are in
                                compliance with appropriate guidelines. Containment areas have
                                been provided for oil/fuel storage tanks and appropriate
                                separation of runoff and process wastewater has been provided
                                to ensure treatment prior to discharge to the stormwater drains
                                and/or 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 Manager’s ongoing TTPP monitoring
                                programme will ensure compliance with the appropriate criteria
                                during the combined operation of T1 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

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                                found to exceed occupational noise limits.
                                As the predicted cumulative noise effects of T1 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 (i.e. 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.




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    SUMMARY OF PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN (EMP)

EMP ISSUE            DESCRIPTION OF ACTION
1. GENERIC           Mitigation Measures and Monitoring
RESPONSIBILITIES     1. Setting up the EMP. Define job descriptions for and appoint staff
AND ROLES            2. TIC Environmental Policy.
                     3. Complete EMP.
                     4. Annual Environmental Report (AER).
                     5. Environmental technical training..
                     6. Awareness training.
                     7. Documentation
                     8. Record site conditions prior to any construction work.
                     9. Prepare site plans and restoration plans
                     10. Public and Authority/Agency Liaison.
                     11. Development of an Environmental Management System (EMS)
                     12. Audit Review Programme.
2. AIR QUALITY       Mitigation Measures
                     1. Ensure measures taken to control dust emissions.
                     2. Ensure measures taken to install and efficiently operate NOx control equipment.
                     3. Ensure stack height is adequate for dispersion of turbine emissions.
                     4. Ensure sufficient emission controls and adequate maintenance of plant vehicles
                     Monitoring
                     1. Design and set up monitoring programme.
                     2. Purchase and install air emissions monitoring equipment for T2.
                     3. Develop air quality monitoring procedures to include appropriate calibration/maintenance.
                     4. Undertake staff training.
                     5. Undertake air quality monitoring
                     6. Tabulate data and interpret ready for inclusion in AER.
                     7. Commitment to preventative maintenance of monitoring equipment (3 month intervals)
3. SOCIO-            Mitigation Measures
ECONOMIC AND         1. Public Health. Ensure air quality mitigation measures are adequately controlled.
PUBLIC HEALTH        Mitigation
ISSUES               2. Socio-economics.
                     a. Maintain the Community Impact Agreement set up under T1.
                     b. Measures to reduce risks of accidents on improved roads, for example raising risk
                     awareness.
                     c. Raise the awareness of the risk posed by HIV /AIDS with respect to prostitution.
                     Monitoring
                     1. Public health.
                     Air quality monitoring programme
                      2. Socio-economics
                     a. VRA to continue with current monitoring with additional monitoring to ensure the mitigation
                     measures in place for T1 are sufficient to cope with the demands of T2.
                     b. Monitor local traffic accidents, health statistics and success of awareness raising measures.
                     c. Monitor the land-use in the area immediately surrounding the site.
4. WATER AND         Mitigation Measures
WASTEWATER           1.Water supply. Potable water for Phase 1 of the plant. Desalination plant for T2.
ISSUES               2. Wastewater treatment facilities include septic tanks and .the sewage lagoons already
                     installed for T1, which are suitable for combined operation of T1 and T2. Effluents are
                     discharged to local surface waters (Anankwari River feeder stream) initially, and then into the
                     ocean upon completion of the seawater discharge pipeline installed under contract T1.
                     3. Stormwater site drainage. Maintain boundary collection systems. Contain and treat spills.
                     4. Collect and treat wastewater from the plant.
                     Monitoring
                     1. Establish Effluent and Water Quality Monitoring Programme.
                     2. Purchase water effluent monitoring equipment and install as necessary in laboratory.
                     3. Develop adequate monitoring procedures.
                     4. Undertake staff training.
                     5. Undertake water quality monitoring.
                     6. Tabulate data and interpret.
                     7. Provide commitment to maintenance.


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5. NOISE             Mitigation Measures
                     1. Ensure plant components are selected to meet noise specifications.
                     2. Ensure sufficient noise controls at source.
                     3. Ensure noise bund is as required.
                     4. Control construction work times.
                     Monitoring
                     1. Design and set up monitoring programme Sites not permanent.
                     2. Purchase further noise monitoring equipment (part of start up and testing effort) if required.
                     3. Enhance noise monitoring procedures and actions in the event of non-compliance.
                     4. Undertake/continue additional staff training.
                     5. Undertake noise monitoring in accordance with methods and procedures.
                     6. Tabulate data and interpret.
                     7. Monitor site operations to identify where careless practices are contributing to noise
                     emissions.
6. ACCESS AND        Mitigation Measures
TRAFFIC              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. Local borrow areas will be rehabilitated to former condition by contractor, audited by EM.
MANAGEMENT           2. Waste management procedures will be developed and a waste management manual
                     produced.
                     3. Providing training, safety equipment, and hazard guidance to waste management personnel.
                     4. Isolation and treatment of Waste Oils. Efficient and timely operation of treatment equipment..
                     5. Sludge Waste from Oxidation Ponds dredged and landfilled or used locally for agriculture.
                     6. Solid wastes from construction and operation phases will be transported to local landfill.
                     Monitoring
                     1. Operation of Oily waste treatment will be monitored, audited and maintained for efficiency.
                     2. Undertake an audit of waste management procedures and practices for operation of T1. An
                     audit of waste carrier and landfill site will be undertaken. Prescribe mitigation measures.
8.ECOLOGICAL         Mitigation Measures
EFFECTS              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 T1 will be used during T2.
                     2. Re-vegetation of areas following construction.
                     3. Landscape screen planting will be undertaken using appropriate native species.
                     4. Restoration of borrow areas by contractor, using native species for planting.
                     5. Specific routes for construction vehicles to avoid off-road vehicle movements.
                     Monitoring
                     1.Brief annual ecological walkover survey to assess ecological effects.
                     2. Restoration of borrow areas will be periodically assessed.
9. LANDSCAPE         Mitigation Measures
AND VISUAL           1. Ensure that no disturbance/ encroachment occurs in areas not previously effected by T1.
EFFECTS              2. Design landscape scheme including suitable native trees and other local species.
                     3. Implement planting scheme as quickly as practically possible.
                     Monitoring
                     1. Ensure planting programme is effective by monitoring tree health and replanting as
                     necessary.
10. RISK             Mitigation Measures
MANAGEMENT           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.




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        Health and Safety Issues and Risk Management


        Health and Safety Issues

        The T2 expansion project has been designed in accordance with a range of
        standards and industry specifications for its mechanical, chemical, electrical, civil,
        structural and architectural elements, including US Department of Labour’s
        Occupational Safety and Health Administration (OSHA), World Bank Health and
        Safety Guidelines and Ghanaian Workers Rights Requirements. In addition, BVI, the
        EPC contractor for T2 are committed to operate under a corporate health and safety
        (H&S) plan which seeks to ensure a safe working environment for all personnel,
        clients and customers, consistent with governmental H&S requirements. This in turn
        provides policy and procedure guidance on a broad spectrum of issues, including
        those particularly highlighted by the World Bank/IFC 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 Management

        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 T1.
        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 T1 will be continued for T2.




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        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 (i.e. it had already been cleared and/or in
        use for T1) there has been no effect on natural habitats, forestry; cultural property;
        and involuntary resettlement.

        Ghanaian worker’s rights legislation does not permit the use of child or forced labour
        and the Contractor’s EPC Agreement enforces this requirement. No such practices
        occur on the TTPP site (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 Bank’s 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 T1 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.




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1       INTRODUCTION

1.1     General


        GIBB Limited was commissioned by Takoradi International Company (TIC) in 1999 to
        prepare a Supplementary Environmental Impact Statement (referred to hereafter as
        the ‘1999 SEIS’) for the proposed expansion (T2) of the Takoradi Thermal Power
        Plant (TTPP), Ghana. The 1999 SEIS supplemented an environmental impact
        assessment (EIA) undertaken in 19954 in connection with the existing TTPP (referred
        to as T1) and addressed specific environmental topics as requested following
        consultation with Ghanaian Environmental Protection Agency (EPA). The 1999 SEIS
        was prepared in support of an application for an Environmental Approval from the
        EPA, as necessary under their requirements, to construct and operate T2. The
        Environmental Approval was granted in April 1999.

        TIC are now seeking to apply for funding for the third phase of the T2 project from the
        International Finance Corporation (IFC), a member of the World Bank Group, and/or
        the Overseas Private Investments Corporation (OPIC), a US Government sponsored
        body that provides financial support to US companies constructing and operating
        development projects outside the US. Initial contact with these two organisations has
        lead to the request of additional environmental information and, specifically, the
        production of an Addendum to the 1999 SEIS, a standalone Executive Summary for
        distribution, the preparation of a Public Consultation Disclosure Plan (PCDP) for
        future implementation and provision of other supportive documentation5 (see
        Appendix A, Volume 2).

        The Addendum is to address certain environmental and social areas that form the
        focus of IFC’s safeguarding policies to ensure potential investment projects are
        environmentally and socially acceptable (see section 1.2, below). It is understood that
        the content of the Addendum will also satisfy OPIC along with the provision of
        additional supportive documentation2. This document has been structured with due
        reference to IFC’s EIA guidelines.

        It is important to note that the Addendum should be read in connection with the 1999
        SEIS as, by the nature of this report, the reproduction of information contained in the
        1999 SEIS has been kept to a minimum, and cross-referencing has therefore been
        maximised accordingly.


1.2     Objectives of the Addendum


        The objectives of the Addendum are to:

•       Update and upgrade the details provided in the 1999 SEIS with due reference to the
        topics which constitute IFC’s environmental and social safeguarding policies,
        including:


4
 Acres International Ltd., Takoradi Thermal Plant Environmental Assessment, Volumes 1 and 2, 1995.
5
 Including the Spill Prevention Countercontrol Plan, Environmental Management and Monitoring Plan,
environmental and health and safety training programmes, and details of the quality of wastes/sludges to be
burnt.

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                 −        Natural Habitats (OP 4.04);
                 −        Pest Management (OP 4.09);
                 −        Safeguarding Cultural Property (OPN 11.03);
                 −        Involuntary Resettlement (OD 4.30);
                 −        Forestry (OP 4.36);
                 −        Project on International Waterways (OP 7.50); and
                 −        Policy statement on Child Labour and Forced Labour.

•       Include reference to the following:

                 −        IFC’s policy on Environmental Assessment (OP 4.01);
                 −        World Bank Group Guidelines for Pollution Prevention and Abatement
                          for new Thermal Power Plants6; and
                 −        IFC’s General Health and Safety Guidelines, 1998.

•       Provide an update to the 1999 SEIS in general, describing any project and
        environmental changes that have occurred since its preparation in March 1999, taking
        into account additional issues that have been requested by IFC and OPIC following
        their site visit on 29 May – 2 June 2000.

•       Address in more detail, where relevant, the nature of the ‘Common Facilities’ for T2
        (i.e. those facilities that will be shared with T1) and:

                 −        consider the potential environmental and social implications of the
                          facilities relative to the above topics in particular;
                 −        describe the status with regard to EIAs that may have been produced
                          or underway; and
                 −        describe any relevant environment procedures.

        A detailed listing of the specific requirements for the preparation of the Addendum
        and PCDP is contained in Appendix A, Volume 2.


1.3     Study Methodology


        The Addendum EIA has been undertaken with due reference to the IFC
        environmental guidance contained in IFC’s Environmental Policies, OP 4.01
        ‘Environmental Assessment’, and to the World Bank environmental quality criteria for
        Thermal Power Plants3.

        Tasks undertaken in connection with the Addendum EIA include the following:

•       Site visit in May 2000 by an EIA specialist from GIBB Ltd;

•       Review of current status of T2 relative to the conditions described in the 1999 SEIS,
        collection of additional project data and undertaking further consultations with key on-
        site personnel regarding various aspects of the T2 project and in connection with
        T1(see Appendix D);



6
 World Bank Group ‘Pollution Prevention and Abatement Handbook’ – Thermal Power: Guidelines for New
Plants’, July 1998.
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•       Review of documentation provided on site and relevant information previously
        provided in connection with the preparation of 1999 SEIS;

•       Updated assessment of nature and significance of any changes made to T2 design
        and activities on site during site preparation and construction, and/or for future
        operation since preparation of 1999 SEIS;

•       Assessment of nature and potential effects of T2 on specific environmental topics
        identified by IFC, OPIC (see Appendix A) and relative to World Bank criteria.

•       Identification of additional appropriate mitigation measures and amendments to the
        Environmental Management and Monitoring Plan (EMMP) where relevant, to account
        for any changes in design and/or changes in potential impacts since the preparation
        of the 1999 SEIS;

•       Identification of any information gaps and recommendations for further studies, where
        relevant.

        As required under OP 4.01, the project team involved in the preparation of this
        Addendum EIA Report is described in Appendix B, Volume 2 to this Addendum.


1.4     Structure of Addendum


        The content of this report is summarised below, and has been developed with
        reference to Appendix B of IFC’s Environmental Assessment guidance note (OP
        4.01):

        Section 2         Policy, Legal and Administrative Work;
        Section 3         Takoradi 2 Project Overview;
        Section 4         Baseline Environmental Conditions;
        Section 5         Significant Environmental Effects;
        Section 6         Mitigation Measures and Likely Net Environmental Effects;
        Section 7         Health and Safety Management for T2;
        Section 8         Environmental Management and Monitoring Programme, T2;
        Section 9         Conclusions.

        Figures prepared in support of the text and photographs are provided at the end of
        this report. Appendices containing the following, are provided as a separate volume:

        Appendix A        IFC and OPIC Addendum Requirements;
        Appendix B        List of Addendum EIA Report Preparers;
        Appendix C        References and Information Sources;
        Appendix D        Record of Consultations;
        Appendix E        Supporting Environmental Data; and
        Appendix F        List of Associated Reports.




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2       POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK

2.1     Introduction


        This section comprises a summary of any key changes to Ghanaian EPA and
        environmental procedures since the preparation of the 1999 SEIS and the procedures
        and standards associated with the main organisations involved with the realisation or
        funding or control of T2.


2.2     National Environmental Requirements


        As of July 2000 there had been no further relevant changes to Ghanaian
        environmental procedures or environmental quality criteria and standards that directly
        affect T2 since the preparation of the 1999 SEIS. It is understood that no further
        developments have occurred since then.

        The 1999 SEIS was produced in accordance with Ghanaian EIA regulations in
        support of an application for an Environmental Approval for the T2 project in March
        1999. The report was accepted and the EPA granted an Environmental Approval for
        the construction of the T2 project in April 1999. A full permit or Environmental
        Certificate will be issued after the plant has been proved to perform satisfactorily and
        comply with appropriate criteria for one year.


2.3     Project Sponsors and Stakeholders


        The following parties are either currently involved in, or potentially involved in the
        design, construction, operation and funding of the T2 project:

        Project Sponsor                   TIC (comprising a partnership between Volta River
                                          Authority (VRA) and CMS Energy);

        EPC Contractor                    Black and Veatch International, and Overland
                                          Contracting Inc.;

        Operator                          CMS International Operating Company;

        Potential Lending Agencies        IFC and OPIC.

2.3.1 TIC

        Takoradi International Company, a Cayman Islands limited company is a joint venture
        company part owned by CMS Energy and VRA. CMS Energy Corporation is an
        international energy infrastructure company with main business areas in oil and gas
        extraction, natural gas transportation, processing and storage, electricity generation,
        gas and electricity distribution, and energy marketing. VRA is a public-owned utility
        engaged in the generation, transmission and distribution of electricity in Ghana.




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        At this stage it has not yet been confirmed as to whether one single operator will be
        used to operate T1 and T2 of TTPP or whether the facilities will be operated
        separately. At this stage, TIC is responsible for T2.

2.3.2 Black and Veatch International

        Black and Veatch International (BVI) has been contracted by TIC to construct the
        plant, as assisted by appointed sub-contractors. BVI is managing the construction of
        T2 (Phase 1 and 2) under its own Safety Manual and relative to specific construction,
        mechanical and quality assurance specifications7,8. The manual and specifications
        document are held at BVI’s site offices and implemented and monitored by BVI’s
        supervisory teams under BVI’s construction quality control system9.

        BVI have also been contracted to start up and test T2 prior to handing it over to TIC
        for full-scale operation; this includes preparing appropriate operation and
        maintenance manuals, provision of training and preparation of a schedule of spare
        parts. Additional to the EPC Agreement, BVI were responsible for constructing the
        new treated LCO tank as part of a change order to the original EPC Agreement.

2.3.3 Overland Contracting Inc.

        Overland Contracting Incorporated. (OCI), a subsidiary of Black and Veatch, have
        been contracted to perform and provide all design, engineering, procurement and
        other work required to build the T2 combined cycle power plant (incorporating the
        simple cycle units 1 and 2 and the combined cycle unit).

2.3.4 CMS International Operating Company

        CMS International Operating Company (CMSI), an affiliate of the CMS Generation
        Company in the US, is a Cayman Islands limited liability company that is registered to
        operate in Ghana. It has been contracted by TIC to be the Operator of the T2
        facilities. CMSI responsibilities include staffing and training personnel in addition to
        the operation and maintenance of all equipment installed at the T2 plant site. The
        operation of the facility will be undertaken in accordance with the Restated Power
        Purchase Agreement between TIC and VRA and to the applicable rules, regulations
        and requirements associated with the T2 project documents.

2.3.5 IFC

        IFC require that projects applying for funding should be:

•       environmentally and socially acceptable in accordance with IFC environmental and
        social policies (see section 1.2);

•       in accordance with the World Bank Group’s Pollution Prevention and Abatement
        Handbook, 1998;

•       meet provisions set in the World Bank Group’s Occupational Health and Safety
        Guidelines

•       in accordance with the host country’s environmental requirements.
7
  Black and Veatch Construction Inc., Safety Manual, August 1999.
8
  Black and Veatch Construction Inc, Takoradi 2, Simple Cycle Power Plant Specification and Document for
General Construction (no date).
9
  Black and Veatch Construction Inc., Power Division Construction Quality Control System (no date).
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        After submission of the Addendum, it will be posted for public review on the World
        Bank Infoshop and will be disclosed locally for information to the Ghanaian EPA and
        Energy Commission by TIC. A provisional Public Consultation Disclosure Plan for the
        Addendum has been prepared separately and outlines the approach to be taken to
        distribute the Addendum in accordance with IFC guidance. On release into the public
        domain, a period of no less that 60 days prior to the IFC board meeting considering
        this investment is allowed for receipt of public comments.

2.3.6 OPIC

        Overseas Private Investment Corporation (OPIC) typically require compliance with
        their own draft Environmental Assessment Handbook (April 1999) and with World
        Bank and other environmental standards in force in the country where the project is to
        be located. However, specific to this project, it is understood that work undertaken to
        address IFC’s specific requirements will be sufficient to meet OPIC’s requirements
        along with the provision of the following in support of the Addendum EIA and PCDP:

•       information on oil spill prevention and control measures;

•       the Environmental Management and Monitoring plan and training details; and

•       waste sludge analyses are provided.

        OPIC also require a 60 day public comment review period during which the
        Addendum will be made available via OPIC’s web site, although this period may be
        required to extend to 120 days in order to satisfy USED requirements, as a key OPIC
        stakeholder.




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3          TAKORADI 2 PROJECT OVERVIEW

3.1        Introduction


           This section comprises the following:

•          A brief description of the background to TTPP, including an outline commentary on
           the state of progress of T1, and the development of the T2;

•          A summary description of the T2 project including its objectives, design philosophy,
           key features of the project and alternatives previously considered.

•          An outline of the main site preparation, construction and operational activities so far
           undertaken and still outstanding. In particular this part of the section highlights the
           changes to the construction phasing which have taken place since the preparation of
           the 1999 SEIS and provides updated information on T2 obtained during the May 2000
           site visit.

•          A summary of the shared facilities between T1 and T2, including a commentary on
           the current status with the transmission lines and future gas pipeline.

•          A summary of the key changes to T2 since the preparation of the 1999 SEIS.

           As this report forms an addendum to the 1999 SEIS, which in turn supplemented the
           1995 EIA Report, duplication of details contained within both these reports has been
           limited to a minimum; where appropriate, reference to the relevant section in the 1999
           SEIS and 1995 EIA Report has been made.

           Additional information sources used for this section (that is those that are additional to
           or updated versions of those listed in Section 2.1 of the 1999 SEIS) have been listed
           in Appendix B, Volume 2.

           In the context of this Addendum, ‘the site’ refers to the area on which T2 is to be
           constructed, which in turn lies within the fence erected for T1, see Figure 3.1.


3.2        Background and Status of the TTPP Development


           TTPP was largely developed in response to a consistently high level of domestic
           demand for 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 expanding Ghana’s power
           generating capacity through the use of combustion turbine technology was preferable
           to expanding the existing hydro-electric system10. TTPP (i.e. T1) was initially
           developed as a 330 MW combined cycle generating plant comprising two 110 MW
           combustion turbines, one 110 MW steam turbine with heat recovery steam
           generators, associated transmission lines and other facilities in 1995. The provision
           for the future expansion of TTPP, i.e. allowing for a doubling in generating capacity,
           was designed into T1 at the start.

10
     Ghana Generation Planning Study, 1985.

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        The current project status for T1 is as follows:

        •        December 1997       Commercial operation of first simple cycle 110 MW
                                     combustion turbine (unit 1);

        •        January 1998        Commercial operation of second simple cycle 110 MW
                                     combustion turbine (unit 2);

        •        April 1999          Start of commissioning activities on steam turbine and
                                     generator (T1 combined cycle);

        •        February 2000       Steam turbine taken out of service as a result of an
                                     electrical failure. Repair work has now been completed.

        •        March 2000          Unit 2 taken out of service due to mechanical failure.
                                     Repair work is currently underway. Combined cycle
                                     placed on hold as a consequence of repair work then
                                     commissioned in November 2000.

        Prior to the shutdown of T1’s Unit 2 in March 2000, the use of T1 has largely been in
        response to peak evening demand, as well as providing an alternative energy supply
        when imported sources have been interrupted. At this stage, T1’s Unit 1 is generally
        operating at baseload while T2’s Simple Cycle units (SC1 and SC2) are currently
        being used to provide energy during the evening peak hour, whereby each unit is
        generally used separately on alternate days, unless required to operate together to
        meet demand.

        As described in section 2.2.2 of 1999 SEIS, T2 has been developed as a fast track
        expansion project for T1 in response to the continuing and rapid growth in domestic
        demand. Consequently, T2 was designed to be constructed within the TTPP site, use
        the same technology as T1, where feasible and practical, and share and interface
        with as many of T1 systems and facilities (such as power distribution) as possible.

        A ‘Do-Nothing’ scenario (i.e. a scenario where T2 is not constructed) was described in
        section 2.2.2 of the 1999 SEIS. Significantly, it was concluded that without T2, it
        would be necessary at some point to develop a second combustion turbine plant at a
        new location. This in turn would have potentially greater environmental implications
        than those attributed to the expansion of an existing development.


3.3     T2 Project


3.3.1 Geographical Location, Site Characteristics and Land Use

        The location and site layout from TTPP, incorporating T2 is shown on Figure 3.1.
        [See also Photograph Sheet 1, Photograph 1.]

        The T2 site occupies an area of land approximately 7.5 ha in size within the existing
        TTPP site. The total TTPP area is approximately 168 ha, which comprises T1 and
        facilities (26.5 ha), township (72 ha, including recreational facilities), T2 (7.5 ha) with
        the remaining 62 ha consisting of construction laydown, wetland and the site for a
        future clinic.    The TTPP site is located on the southwest coast of Ghana

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        approximately 15 km north east of Takoradi town and between 1 to 2 km from the
        nearest settlement, Aboadze.

        In terms of land use, the site for T2 is incorporated within TTPP and had therefore
        already been cleared of vegetation and regraded as part of the site preparation and
        construction of T1 in 1996.

        The geographical location, site characteristics and former land use of the T2 site are
        described in section 2.2.1 of 1999 SEIS; a more detailed description of the site is
        provided in section 4.1 of the 1995 EIS.

3.3.2 Objectives of T2

        The objectives of T2 are described in section 2.2.2 of the 1999 SEIS.

3.3.3 Design Philosophy for T2

        This information has been provided to highlight the key criteria for the T2 project, as
        well as to highlight the positive environmental aspects already incorporated into the
        T2 design.

        The Agreement for T2 between TIC and BVI/OCI sets out the contract and
        requirements for the design, procurement, construction, start-up and test operation of
        the plant and outlines a minimum compliance with a range of standards and industry
        specifications for the mechanical, chemical, electrical, civil, structural and
        architectural design of T2, including, for example11,12:

•       World Bank’s Pollution Prevention and Abatement Guidelines for Thermal Power
        Plants (1998), Health and Safety Guidelines and Worker Rights Requirements;

•       American National Standards Institute (ANSI);

•       American Society for Testing Materials (ASTM);

•       American Petroleum Institute (API);

•       National Fire Protection Association (NFPA);

•       US Occupational Safety and Health Administration (OSHA);

•       National Electrical Code (NEC);

•       Institute of Electrical and Electronics Engineers (IEEE); and

•       Ghanaian national, regional and/or local regulations.

        Taking into account the above, key environmentally positive design features for T2
        include the following:


11
   Amended and Restated Agreement between Takoradi International Company and Overland Contracting
Incorporated for the Equipment Procurement of the Takoradi 2 Facility in Aboadze, Ghana effective as of
February 23 1999.
12
   Amended and Restated Agreement between Takoradi International Company and Black & Veatch International
Company for the Construction, Start-up and Testing of the Takoradi 2 Facility in Aboadze, Ghana effective as of
February 23 1999.

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•       Recycling of ‘waste’ heat from the simple cycle combustion turbine units to produce
        steam, which in turn will be used to drive the 110 MW steam turbine in the combined
        cycle.

•       The design specifications prepared for the plant require that appointed suppliers
        provide equipment that meets World Bank guidelines on Thermal Power plants for
        emissions of noise, gaseous and liquid effluents. Where these guidelines cannot
        initially be met for any specific item of plant, either appropriate ‘add-on’ features are
        required (such as exhaust mufflers) or future operational procedures will be
        developed and enforced to ensure the management of risk of any environmental,
        health and safety consequences.

•       The new LCO storage tanks for T2 are, as per the existing T1 tank farm, provided
        with spill containment areas.

•       The use of desalinated water will reduce demands on the local water supply.

•       Significantly, the incorporation of T2 within the existing T1 plant potentially provides
        the most environmental benefit; that is, T2 represents a relatively small scale
        incremental change compared to a situation where a plant of a similar capacity would
        be designed, constructed and operated in isolation of T1, on a new site.

3.3.4 Alternative Options Considered

        These were described in the 1999 SEIS in section 2.2.2, ‘Evolution of T2’.

        In short, as T2 is accommodated within the T1 design, which itself was subject to a
        review of alternative design and location options during the 1995 EIA, no further
        assessment was deemed necessary.

3.3.5 The T2 Layout

        The features, components, equipment and systems associated with T2 have been
        listed as per construction phase under the following sub-headings:

•       The Primary Plant; and

•       Infrastructure and Civil Works.

        The Associated, shared facilities with T1 are described separately in section 3.4 and
        are supported by a commentary on environmental issues as requested by IFC.

        Primary Plant

        T2 will involve the construction and operation of the key features listed in Section 2.3
        of the 1999 SEIS. Since the preparation of the 1999 SEIS the following modifications
        to T2 have been made:

•       The relocation of the contingency oil/water separator for transformer related oil spill
        prevention from its previous position on the northern edge of T2 to a new position to
        the south. This oil/water separator primarily provides a tertiary containment measure
        to the existing concrete containment basins for the SC1 and SC2 transformers in the
        unlikely event that a transformer ruptures and releases its oil. Water effluent from the
        contingency oil/water separator will be discharged to the existing T1 storm water
        drainage ditch to the west (rather than into the north as before) after treatment. The
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        effluent quality will be controlled to an oil and grease content of no more than 10 ppm
        (which meets the World Bank guidelines for Thermal Plant effluent discharge). It is
        understood that the Ghana EPA guidelines require that the quantity of oil and grease
        present in the treated effluent should not exceed 5 ppm. Discussions between
        TIC/OCI/Ghana EPA on this specification are ongoing. Additional oil/water collection
        facilities are to be provided with the CC stage.

•       An additional feature includes the construction of a two million gallon capacity storage
        tank for treated light crude oil (LCO). This is adjacent to the untreated LCO storage
        tank on the northern edge of the existing fuel storage tank farm to the east of the T2
        area. The primary purpose of the additional treated LCO tank is to serve as a
        receptacle for recirculated treated LCO in order to ensure that the certified, treated
        LCO tank from which LCO is taken for plant operation is not contaminated with out of
        specification LCO during changeover of the tanks.

•       Use of E-cell technology instead of mixed beds for the production of demineralised
        water; this reduces the requirement for treatment chemicals. E-cell technology
        utilises electrodeionisation (EDI) for demineralised water production. In EDI an
        electrical current is used to force a continuous migration of contaminant ions out of
        the feed water, through the resin bed and into the reject system. The current also
        splits the water molecules into hydrogen and hydroxyl ions, continuously regenerating
        the resin bed. EDI replaces the primary mixed beds in conventional water treatment
        systems predictably and consistently producing water of the highest quality.

        The key change to the T2 project since the preparation of the 1999 SEIS has been
        the re-phasing of the construction programme, and subsequent operations, such that
        the project has now been divided into 3 distinct phases, namely:

•       Phase 1, Simple Cycle 1 (SC1) – see Figure 3.2;

•       Phase 2a, Simple Cycle 2 (SC2) – see Figure 3.3; and

•       Phase 2b, Combined Cycle (CC) – see Figure 3.4.

        Figure 2.2 from the 1999 SEIS has been reproduced for the Addendum as Figure 3.2
        as there has been no change to the layout of SC1.

        Figures 3.3 to 3.4 show SC2 and CC as depicted in the TIC/BVI EPC Agreement.
        These generally show T2 in more detail than previously depicted in Figures 2.2 and
        2.3 of the 1999 SEIS. However, apart from the above, there have been no other
        significant changes to the components of T2 as described in the 1999 SEIS. The key
        components for each of the T2 phases have been listed below. It is important to note
        that details for the CC phase have yet to be finalised, however it is understood that
        the primary components are as listed below and will remain largely unchanged.




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            Phase 1 –                    Phase 2a –                     Phase 2b –
          Simple Cycle 1               Simple Cycle 2                 Combined Cycle

          As per        1999    As per SC1 with the              •   Condensing steam
          SEIS                  exception of the following           turbine generator and
                                which are excluded:                  building;

                                •   Substation and enclosure;    •   Heat recovery steam
                                •   water treatment structure;       generators (HSRG) and
                                •   demineralised      storage       exhaust stacks (x2);
                                    tank;
                                •   raw water tank;              •   Main and auxiliary
                                •   fuel treatment structure;        steam distribution
                                                                     system;
                                •   BWRO product storage         •   Boiler feedwater system;
                                    tank;
                                •   Oil/water separator; and     •   Condensate system;
                                                                 •   Cycle make-up and
                                                                     storage systems;
                                                                 •   Cooling tower;
                                Additional        features       •   Circulating water
                                associated with SC2 only             system;
                                include:                         •   closed cycle cooling
                                                                     water system and pump
                                                                     house building;
                                •   Permanent drainage ditch     •   Gas metering station;
                                    and soakaways;               •   Blowdown system;
                                •   Treated LCO storage          •   Generator step-up
                                    tank; and                        transformer;
                                •   Untreated LCO storage        •   Auxiliary boiler for steam
                                    Tank.                            generation (when
                                                                     HRSG’s out of
                                                                     operation);
                                                                 •   Relocation of
                                                                     meteorological station;
                                                                 •   Condensate storage
                                                                     tank;
                                                                 •   Potable water storage
                                                                     tank;
                                                                 •   Filtered water storage
                                                                     tank;
                                                                 •   Control/electrical
                                                                     equipment rooms;
                                                                 •   Sea water pressure
                                                                     filters;
                                                                 •   Transmission towers;
                                                                 •   Compressed gas
                                                                     system; and
                                                                 •   Pump house building for
                                                                     HSRG feed pumps.



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        Infrastructure and Civil Works

        In addition to the above, the following key infrastructure and civil works have been
        undertaken (SC1 and SC2) or will be undertaken (CC Phase) in association with T2.
        As the detailed design for the CC phase has yet to be finalised the following largely
        relates to SC1 and SC2, unless specified otherwise. Available updated details of
        quantities of materials used to date in the T2 construction phase, and forecast
        quantities for the remaining SC2 and CC phase and operational stages are provided
        in section 3.5 and 3.6, respectively below:

          Water supply          The water supply, its treatment, processing, distribution,
          and storage           recycling and storage will generally be as described in the 1999
                                SEIS. Changes will be associated with timing of construction
                                only (for example, the feed water, condensate and circulating
                                water systems will be constructed in the CC Phase).

          Access roads          In addition to the existing main access roads to TTPP, a paved
          and pavements         primary exterior access road loop has been provided in
                                association with SC1 and SC2 and will also serve CC.
                                Secondary gravel access points lead off from the exterior access
                                route to allow access to plant areas. Additional secondary
                                access points will be provided for CC. Crushed rock surfacing
                                has been provided in the immediate vicinity of the combustion
                                turbines and transformer for SC1 and SC2 and will also be
                                applied for CC. Other areas disturbed during T2 construction will
                                generally be seeded with grass, with the exception of the
                                perimeter areas that are to be specifically landscaped.

          Site drainage         A temporary surface drainage and culvert system (with a settling
                                basin) for low contamination risk surface water runoff was
                                constructed for SC1and SC2. This temporary system was
                                replaced by a permanent drainage system during construction of
                                SC2 which catches basins and storm sewer piping for areas
                                where ditches will be ineffective. The uncontaminated runoff
                                drains into a settling basin. [See Photograph Sheet 2,
                                Photographs 2a and 2b.]

          Fencing               With the exception of replacing or relocating existing TTPP
                                fencing and gates which may be affected by any of the T2
                                construction phases, no new fencing or gates will be required for
                                T2.

          Structures            Buildings have been constructed to house the water treatment
                                plant and fuel treatment plant (including other miscellaneous
                                equipment present) for SC1 and SC2. Buildings will be
                                constructed in CC Phase to house the steam turbine generator
                                area (including the control room, electrical area, boiler chemical
                                feed area and associated systems) and for the circulating water
                                pump area. Where chemicals are to be stored, the flooring will
                                be coated with appropriate protection accordingly.

          Lighting and          Lighting is being provided for outdoor installations, roadways
          grounding             and general plant area using high pressure sodium lighting for
                                T2, extending with each completed phase. An emergency indoor
                                lighting system is also being provided.

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          Relaying and          Various digital multifunction relaying systems are being provided
          Metering              for all equipment designed to generate electrical power,
                                transformers, energy conversion, transmission and distribution
                                for all phases of T2. These systems will seek to remove or
                                provide warning of abnormal conditions, protect equipment,
                                reduce the risk of fire or explosions and reduce the risk of
                                hazards to personnel.

          Electrical            Switchyard equipment and systems to connect T2 to the existing
          systems               T1 transmission lines have been provided as part of SC1 and
                                SC2 and will be expanded thereafter to accommodate the CC
                                Phase. The existing T1 AC and DC power supplies are
                                considered to be sufficient to meet the demand of T2.


3.4     Common, Shared Facilities with T1


3.4.1 Within TTPP

        As T2 represents an extension to an existing plant, various structures, services and
        systems will, by definition, be interfaced with or incorporated into those existing T1
        facilities. The T1 facilities will be extended accordingly where necessary to
        accommodate T2. The key shared facilities were described in section 2.3.1 of the
        1999 SEIS and remain unchanged. These have been listed below, along with details
        on permanent interface points between T2 and T1, in Table 3-1.
        Table 3-1: T2 Shared Facilities (SC1 and SC2) and Key Interface Points with T1.
          Permanent Interface Points with T1            Shared Facilities with T1
          Firewater loop header for T1                  Oil off-loading facilities
          Seawater pumphouse for T1                     Truck oil off-loading facilities
          Seawater discharge line to ocean              Oil metering station
          Power evacuation to existing switchyard       Sewerage and wastewater treatment
          for T1                                        facilities
          Sanitary sewer connection to T1 system        Seawater intake system and building
          Wastewater discharge to T1 sewer              Seawater discharge line to ocean
          system
          Waste oily water to T1 sewer system           Switchyard control building
          Untreated LCO to new tank                     Firewater pumps and system
          Potable water supply from T1                  Plant     facility    service      building
                                                        (maintenance buildings)
          Freshwater supply for SC2 from T1             Administration and security buildings
          SCADU RTU terminal blocks                     Existing T1 electrical cable ducts
          LDO supply                                    Existing T1 elevated outdoor pipe and
          LCO return (treated and untreated)            cable rack between the T1 combustion
          Freshwater for fuel treatment                 turbines and the industrial services
          Raw water tank supply                         building/DFO       storage      area/LCO
          Sludge water from fuel treatment              treatment building.
          Firewater for fuel treatment area             Existing T1 freshwater storage reservoir
          LCO re-circulation to tank (untreated)        and seawater pumphouse

        Temporary interfaces between T1 and T2 have been provided for the demineralised
        water supply and 6.6kV power supply.
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        In terms of those facilities where it is necessary to carry out modifications to interface
        T2 with T1 it is important to note that these do not involve activities outside the
        current TTPP boundary.

3.4.2 Transmission Line Upgrades

        The TTPP project was divided into a series of contract packages (TK-1 to TK-8) of
        which TK-6 relates to transmission line and substation modifications as listed below
        (see Figure 3.5). In general, these packages were to provide for the tie-in of TTPP
        into the National Grid system and in order to be able to evacuate the full 660 MW
        generating capacity of TTPP (i.e. T1 + T2); the existing system is capable of
        accommodating 450 – 500 MW only. These projects consist of a mixture of either
        ‘re-stringing’ existing transmission lines with 161 kV lines and/or constructing new 161
        kV transmission lines and towers as required in:

        •        TK-6A          Coast Line Transmission Project - Re-stringing of an existing 190
                                km long line.

        •        TK-6B          Tafo – Kumasi Transmission Project     -      Erection of new 165
                                km long 161 kV transmission line and towers on existing route.

        •        TK-6C          Aboadze-Prestea Transmission Project -      Erection of new
                                61.2 km long 161 kV transmission line and towers along new and
                                existing route corridor.

        •        TK-6D          Akosombo – Tafo Transmission Project -        Erection of new
                                80km long 161 kV transmission line and towers on existing route.

        These projects were all completed and turned over to the VRA between October 1997
        and December 1998 respectively. With regards to any environmental studies
        undertaken for these project packages, the environmental and social impact of the 4.2
        km TTPP-Aboadze-Inchaban transmission line (which forms part of TK-6A) was
        addressed in the 1995 EIA. The remaining transmission line upgrade projects listed
        above have not been subject to any formal environmental studies particularly as the
        EPA did not express a requirement for any such studies. However, it is understood
        that:


•       route surveys were undertaken to provide for appropriate compensation for loss of
        farm land due to the new towers;

•       disruption to any ‘newly’ populated areas within the existing corridor were minimised
        and the need for resettlement largely avoided; and

•       the new transmission line route generally followed the existing transmission line
        corridor (except, for example, where ground conditions were unsuitable and/or it was
        necessary to avoid populated areas) and shared the existing maintenance roads.

        Subsequent to the above transmission lines upgrades, one new 161 kV transmission
        line project, from Prestea to Obuasi, is currently being developed to handle the
        additional capacity from T2. A second new 161kV transmission line from Takoradi to
        Tema is proposed to improve upon the reliability of the Ghanaian electricity
        transmission network.


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           Prestea to Obuasi Transmission Line

           As World Bank funding is being sought for the new 120 km, 161 kV transmission line
           section between Prestea and Obuasi an environmental impact assessment was
           undertaken in accordance with World Bank guidance. This was undertaken by the
           joint venture of REFAST (Ghana) and Mouchel (UK). A copy of the Environmental
           Impact Statement was made available late and could not be reviewed for the
           Addendum, however it is understood that a draft report has been submitted to the
           Ghana EPA and World Bank for review.

           The key impacts were understood to be associated with the loss of trees, cropland
           and/or small scale palm tree plantations, although the amount of land affected was
           relatively small given the spacing of the towers. No significant adverse effects on
           water resources were identified and route adjustments would be provided to mitigate
           for any resettlement that may otherwise be required. In addition, the route is to be tied
           into an existing transmission line corridor as much as possible where practical and
           feasible. It is estimated that the construction programme would be 12 months. The
           World Bank is currently understood to be considering funding the project.

3.4.3 West African Gas Pipeline Project (WAGP)

           With regard to the provision of TTPP’s primary fuel, natural gas, via the WAGP, it is
           understood that the development of the gas pipeline is being undertaken by a
           consortia of stakeholders including Chevron Overseas Petroleum, Shell, Nigerian Gas
           Corporation, Ghana National Petroleum Company, Société Beninoise de Gaz and the
           Société Togolaise de Gaz. The project is still being finalised.

           The following outline details were provided directly from Chevron Overseas
           Petroleum, based on comments in discussion with CMS and other information
           sources as shown:

•          The natural gas will be sourced from Chevron’s Escravos Gas Project facilities in
           Nigeria’s delta region and the approximately 1000 km long pipeline will provide gas to
           Nigeria, Benin, Togo and Ghana13. WAGP was developed in response to plans by the
           Nigerian Government to utilise gas currently being flared off and supply this gas to
           neighbouring countries. Ghana will be the terminus for WAGP14.

•          The WAGP will largely be an offshore pipeline with spurs running onshore at the each
           of the countries in the partnership and is expected to be able to transport 180 million
           cubic feet of gas per day12.

•          Preliminary feasibility studies indicate that WAGP will have substantial economic
           benefits in the region and will help stimulate industrial growth through the new power
           supplies.

•          An EIA of the project will be undertaken and is currently being managed through
           Chevron’s appointed Environmental Manager for the project in Houston. The EIA is
           likely to be undertaken in accordance with World Bank guidance although this has yet
           to be confirmed.

•          With the exception of the direct tie-in between TTPP and the pipeline there is no other
           direct involvement with the pipeline by TIC. The tie-in facilities to be provided at TTPP

13
     The Rough Guide to West Africa, Jum Hudgens and Richard Trillo, 1999.
14
     United States Energy Information Administration, Ghana, April 1999.
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        will include a metering station and pressure let down facilities. An area in the north
        western corner of T2 has been provided for the tie-in facilities.

        In terms of the potential environmental implications of the pipeline, and in the
        absence of any further information on the route of the gas pipeline, its construction
        and design particularly with the tie-in to TTPP, the following comprises an outline of
        potential effects or issues that will need consideration, with particular reference to the
        IFC policies. The forthcoming, detailed EIA will determine the exact nature and
        significance of impacts (adverse and beneficial associated with the pipeline).

•       Further land-take along the route of the pipeline where it is on shore and for any
        associated maintenance roads. The quantity and significance of land-take (including
        any farmed plots, settlements, sites of cultural importance) will depend on the final
        route of the pipeline.

•       Further employment opportunities for the local labour force may occur depending on
        the final contract arrangements.

•       The coastal strip and the palm trees to the south of TTPP were previously identified
        as a constraint to the T1 development where the seawater intake/outfall and fuel
        pipeline to the single mooring point would pass through this area. The rehabilitation
        and restoration of the beach strip and coconut trees was a mitigation requirement in
        the 1995 EIA and will have to be taken into consideration.

•       The new metering station and/or pressure reducing facility at TTPP is provisionally
        located in the top northern corner of an area of land west of the T2 site. Any potential
        noise generation during the pressure reducing process will need to be addressed to
        ensure compliance with World Bank property boundary criteria and occupational
        impacts at one meter from the plant.

•       Disruption to the marine environment off the TTPP coast line including sediment
        loading within the water column during any trenching work and overland work
        adjacent to the coast line. It is noted that the coastline currently appears to be
        showing signs of erosion by wave undercutting at the shoreline.

•       Landscape and visual effects - this is likely to be of minor significance given the
        largely industrial nature of the background to the coastline (i.e. TTPP).



3.5     Site Preparation and Construction Details


        The following comprises an update of site preparation and construction details based
        on the information collated during the May 2000 site visit. This supports the
        information provided in section 2.3.1 of the 1999 SEIS which is considered to remain
        valid unless stated otherwise.

3.5.1 General

        The ‘Notice to Proceed’ with T2 was given in February 1999 and SC2 was completed
        in September 2000, which includes checking, start-up and testing; a total of 19
        months. The CC Phase is scheduled to last for approximately 24 months from ‘Notice
        to Proceed’.


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        In terms of general mobilisation the workforce currently comprises approximately 25%
        expatriates (principally from Europe, USA and the Philippines), with the remaining
        75% of the workforce made up of skilled and unskilled Ghanaians. Equipment,
        materials and resources have been sourced from Ghana (in particular cement and
        aggregate), and other countries including USA, Japan, Middle East, Europe and
        Taiwan. These are transported to site principally by sea (via Takoradi) or by air to
        Accra and then by road to the site.

        BVI have sub-contracted a number of the project construction activities, including:

•       The supply of miscellaneous materials such as concrete, sand, stone chippings,
        cement, sub-base and other bulk materials;

•       Provision of skilled labour resources for the project in general, as well as for specific
        activities such as sand blasting, painting, administration staff;

•       Provision of unskilled labour resources;

•       Assembly and erection of tanks on site; and

•       Performance testing.


3.5.2 Site Preparation

        Simple Cycles 1 and 2

        Updated details available on resources used during the site preparation of SC1 and
        SC2 to date include the following:

          Concrete               6,750 m3
          Cement                 2300 m3
          Sand cement            95 m3
          Sand                   3,150 m3
          Aggregate              5,030 m3
          Fill                   7,000 m3

        The BVI construction compound area (including laydown area) has been set up on an
        area of land (approximately 2 ha in size) previously used for T1. This lies near or
        adjacent to the general wetland area and adjacent to the sewage settling pond area,
        running the approximately length of this area. A concrete batching plant was erected
        on site adjacent to the BVI Compound, operated by De Simone [See Photograph
        Sheet 2 and 3, Photographs 3a and 3b]. A selection of aggregate material was also
        stockpiled within the BVI compound. Paints and thinners and other chemicals are
        kept in containers within the TTPP site and stored as per their specifications.
        Additional construction laydown areas are located within TTPP adjacent to the T2
        site. A T1 spoil disposal area adjacent to the lorry park east of the tank farm was also
        available for use.


        Combined Cycle

        There are no separate details on the likely material and resource use for the CC
        phase available at this time. The final quantities of material/resources to be used will
        be determined during the detailed design stage. Details on the combined cycle were
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        previously described in the 1999 SEIS together with SC2 which formed the original
        Phase II to T2.

        An outline programme for construction for the CC Phase has been prepared in
        connection with the EPC Agreement and is included as Figure 3.6 for information
        only. This indicates that site preparation activities will last for two months, during
        which foundations and the circulating water pipeline will also be laid and installed. It
        is anticipated that the existing BVI construction compound will also be used for CC.
        Local resources (including labour) will generally be sourced as per SC1 and SC2 for
        the CC construction phase.

3.5.3 Construction Details

        Simple Cycles 1 and 2

        Construction of SC1 and SC2 has been completed and the units are now operational
        albeit on an intermittent basis.

        As mentioned above, construction of SC2 was completed in September 2000
        including the subsequent start-up, testing and turnover to TIC activities. Further to
        the construction resource details provided in section 2.3.1 of the 1999 SEIS, the
        following details were available on the resource use for SC1 and SC2.

          Steel pipework                                          7,815 m
          High Density Polyethylene (HDPE) pipe                   1,758 m
          Power control cables                                     95 km (approx)
          Underground conduits                                    12.2 km
          Grounding                                               6.7 km (approx)
          Paint and thinners                                      2,990 gallons (approx)
          Hydrocide (water proofing)                              250 gallons
          Form Oil                                                475 gallons

        This information was accurate in July 2000, near the completion date for SC2
        construction.

        The construction labour force reached a peak average of 403 in the month of January
        2000, covering both the SC1 and SC2 phases. The maximum peak average for the
        construction labour force prior to SC2 commencing in October 1999 was recorded at
        284 in September 1999.


        Combined Cycle (CC)

        As mentioned in section 3.3.5 above, the design of the CC Phase has yet to be
        finalised. The main components of CC have also been listed in section 3.3.5 above.
        Construction resource details for CC were also previously combined with SC2 details
        in the 1999 SEIS (section 2.3.1). There were no specific resource details pertaining
        to the CC Phase alone available during this study.

        At this stage it is estimated that construction of CC would not start until late 2001 and
        would take approximately 24 months (see Figure 3.6). Key construction activities will
        include constructing the steam generating and circulating systems, and water cooling
        and condensing systems, erecting the piperacks, piping, HRSG stacks and steam
        turbine generator, constructing the water treatment facility and tying into the
        distribution station. It will also be necessary at some stage of the CC Phase to take

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        SC1 and SC2 out of service to convert to the CC cycle (approximately 11 weeks for
        each simple cycle unit). Pre-commissioning, commissioning and turnover of the CC
        unit will complete the construction stage of the T2 project.

3.5.4 Health and Safety Management and Training during Site Preparation and
      Construction

        The health and safety management and associated training procedures and activities
        have been summarised in Section 7 of the Addendum.

3.5.5 Environmental Protection during Construction

        BVI have been committed in the EPC Agreement document to construction, start up
        and test T2 with due care to the surrounding environment, such as that they are
        required to:

•       ‘prevent unnecessary destruction, scarring or defacing               of    the     natural
        surroundings…[and]... ‘prevent damage to other property…’

•       perform construction activities using ‘…‘best management practices’ that prevent
        entrance or accidental spillage of solid matter, contaminants, debris and other
        objectionable pollutants and wastes into the sea or other water courses…’

•       ‘No raw sewage is to be discharged to any watercourse…waste fuels and lubricants
        shall be contained and hauled away to an approved disposal station [and]….all spills
        of fuels, lubricants or other hazardous materials shall be cleaned up immediately.’

•       Liquid discharges shall meet specified criteria in the EPC document which related to
        Ghana EPA discharge requirements.

        BVI are also required to work in accordance with the mitigation measures developed
        as a result of the 1995 EIA – these have been reproduced as Appendix E1, Volume 2
        of the Addendum. Copies of the 1999 SEIS were also supplied to BVI for reference.


3.6     Operation Details


        Simple Cycle 1 and 2

        Since the preparation of the 1999 SEIS, SC1 and SC2 have been commissioned and
        are now operational. They have operated on an intermittent basis (as dictated by
        power demand and fuel prices) since March 2000 and September 2000 respectively.

        Prior to commissioning, Unit Performance Tests were undertaken on SC1 in February
        2000 to demonstrate compliance with contractual agreements and guarantees prior to
        turning over the plant to TIC for operational use. These tests included testing SC1’s
        unit output, heat rate, reliability, noise emissions and stack emissions. The results of
        the noise and stack emissions testing have been provided in Appendix E2, Volume 2.
        In summary these indicated that in terms of noise emissions the SC1 unit was
        compliant with World Bank guidelines at the nearest residence and property boundary
        sites surveyed, and that warning signs would need to be erected in the vicinity of
        some plant areas. In terms of air emissions, the tests indicated that with the
        exception of NOx, the results complied with the EPC Contract guaranteed emissions
        limits (see Appendix E2, Volume 2). However, NOx was found to exceed the limit on
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        account of the high fuel bound nitrogen present, compared to the design fuel.
        Although no specific reference is made to the 1998 World Bank air quality criteria for
        these guaranteed emissions limits, the 56 ppm emission limit for NOx (at 15% O2)
        equates to approximately 115 mg/Nm3 ; this complies with the 1998 World Bank
        guidance of 300 mg/Nm3. The actual emission level measured during the unit
        performance test of the SC1 unit was 69 ppm (at dry 15% O2) which equates to 142
        mg/m3 ; this is well within the World Bank standard.15 SC1 and SC2 have both been
        subject to ongoing stack emissions monitoring, albeit subject to gaps arising from
        equipment failures.

        Updated details on resource use and discharges for SC1 and SC2 are provided in
        Table 3-2 and Table 3-3. The estimations have been produced as part of an interim
        services agreement with T1 for the facilities (providing inputs and receiving outputs
        from T2) which are shared by T2.

        Table 3-2:        Main Resource Requirements for SC1.
          Resource                                                               Input
                                                                         (thousands per year)
          LCO                                                                3,168 gallons
          Firewater                                                            12 gallons
          Service water                                                       235 gallons
          Potable water                                                       941 gallons
          Demineralised water                                                1,411 gallons

        Preliminary water mass balances for SC1 and SC2 (for crude oil only) have been
        referred to in section 5.5.2 and Tables 5-1 to 5-2 respectively.

        See Table 2-2 in the 1999 SEIS for details on the types of chemicals to be used for
        T2 and the approximate volumes required. At this stage, the T2 Reverse Osmosis
        water treatment plant is not operational and therefore use of previously listed
        chemicals is currently zero.

        Table 3-3:        Main Outputs for each of SC1 and SC2.
          Resource                                                              Output
                                                                         (thousands per year)
          Oily wastewater                                                    2,100 gallons
          Chemical wastewater                                                 280 gallons
          Sanitary sewage                                                    1,000 gallons

        Noise emissions and air quality emissions specific to T2 have been described in
        section 5 of the Addendum accordingly.

        Overall there has been no significant change to the design of SC1 and SC2 over and
        above that described in the 1999 SEIS and therefore the operational details provided
        in the 1999 SEIS are expected to remain valid for SC1 and SC2 particularly once the
        plant becomes fully operational. The minor exceptions currently occurring relate to
        the following abnormal conditions:




15
   These tests were undertaken during three one-hour runs. The water injection units were also operational during
this time. The performance tests are considered to be representative of normal operating conditions.

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•       Diesel Fuel Oil consumption for turbine start up is currently greater than would
        normally be associated with a continuously run plant due to the intermittent use of the
        CTGs. The intermittent use of T1 and T2 is largely in response to escalating oil
        prices.

•       The current rate of delivery of LCO to TTPP via seagoing tankers in general has
        reduced on account of the intermittent use of the plant (T1 and T2).

•       Stack emissions for NOx at TTPP in general have been greater than expected as the
        LCO currently being used contains a higher quantity of N (i.e. 0.06% compared to the
        contract value to 0.007%16) – see section 5 for more detail.

•       A petrocarbon odour event during an SC1 start up was observed on 11 May 2000.
        This was partially associated with difficulties in starting the SC1 unit on this occasion,
        however there have also been previous odour events during start ups. This
        occurrence is being addressed by the Contractor as a warranty item.

•       For a short period diesel was mixed with the LCO to bring out-of-specification LCO up
        to the required performance standard. Further mixing is not generally anticipated.
        There are no significant environmental ramifications from this activity.

•       Greater quantities of sludge are being discharged from T2's activities on account of
        initial LCO deliveries to T1 containing a higher wax content leading to build up of
        sludge at the bottom of the T1 untreated LCO tanks.

        Combined Cycle

        Operational activities and resource requirements for the Combined Cycle, as
        described in section 2.3.2 of the 1999 SEIS (as part of the original Phase II), are
        considered to still be valid.

        As both combined cycle units for T1 have yet to be properly operational there is no
        data available to provide an indication of actual resource use and discharge rates.
        Details on the combined cycle system provided in association with the 1995 EIA are
        therefore expected to provide a reliable estimation for T2’s combined cycle.

        Preliminary water mass balances for the CC Phase have been referred to in section
        5.5.2 and shown in Table 5.3.

3.6.1 Health and Safety Management and Training during Operation

        The health and safety management and associated training procedures and activities
        are summarised in Section 7 of this Addendum.

3.6.2 Environmental Protection during Operation

        A description of the current environmental management system and environmental
        monitoring plan for T1 is provided in section 8 of the Addendum17. This is likely to be
        either expanded and updated to incorporate T2 and the issues outlined in the
        Provisional Environmental Management Plan (EMMP), or potentially to provide the
        framework for the development of a separate environmental management and
16
   Plant unit fuel bound nitrogen (FBN) levels determined during unit performance tests. FBN is not routinely
monitored.
17
   The Table of Contents and appropriate extracts from the EMS Manual and the T1 EMMP have been included in
Volume 2, Appendix F1 and F2 respectively.
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        monitoring system for T218. The Provisional EMMP for T2 is also discussed in section
        8.


3.7     Summary of Key T2 Changes Since 1999


        In summary the key changes to the construction and operation of T2, since the
        preparation of the 1999 SEIS include the following:

•       Phasing of T2 has been divided into 3 distinct phases, namely Simple Cycle 1, Simple
        Cycle 2 and Combined Cycle – this could effectively extend the total construction
        period by up to 12 months from that originally anticipated;

•       Additional treated LCO storage tank for SC2;

•       Change in demineralisation water treatment technology;

•       Minor changes to preliminary layout for CC (based on a comparison between the
        available plans in 1999 and 2000 – however the final design and layout is still pending
        confirmation);

•       Temporary, intermittent use of T2's CTGs (along with T1), i.e. either daily during peak
        evening period or every other day during 2000. This was in response to an increase
        in LCO fuel prices and the need to provide a standby power supply when imported
        energy or domestic sources are interrupted. There was a subsequent change to the
        level of resources use and discharges associated with T2 (and the plant as a whole).

•       SC1 began operating on a continuous basis in July 2000, then progressed to
        operating on alternate nights with SC2 after the latter’s commissioning in September
        2000. In the long term, all units are expected to operate at baseload for extended
        periods.

        The environmental implications of these changes, where particularly relevant to T2
        have been discussed in section 5 of this Addendum.




18
  Prepared as part of the 1999 SEIS. It also forms part of the conditions of approval for the Environmental
Permit, such that the EMMP will be formalised and applied for T2.

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                                THIS PAGE IS INTENTIONALLY BLANK




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4        BASELINE ENVIRONMENTAL CONDITIONS

4.1      Introduction


         This section consists of a description of the baseline environmental characteristics
         associated with each of the following additional environmental topics, as requested by
         IFC:

•        Natural Habitats and Forestry;

•        Pest Management;

•        Resettlement, Cultural Property and Labour;

•        Use of International Waterways.

         It is important to note that as T2 represents an extension of T1, the baseline
         environment has generally been defined as that associated with the predicted and
         observed environment associated with an operational T1 (as per 1995 EIA Report)19.
         However, the operational conditions of T1 have since changed relative to those
         described in the 1999 SEIS due to the intermittent (rather than continuous) operation
         of T1. While due comment is made to the impact of these changes in T1 below, the
         overall assessment described in section 5 will still assume a ‘worse case’ scenario
         whereby T1 is fully operational as designed.

         Where relevant, updated descriptions of the baseline environmental conditions (i.e.
         those associated with the operation of T1) previously provided in the 1999 SEIS have
         been included. These have been based on observations made during the May 2000
         site visit, and following a review of the latest Annual Environmental Reports (AERs)
         produced for T1 (1999).

         The baseline environmental conditions have been described for each of the
         environmental topics considered as per the following groups:

         •        Physical Environment                           Landscape and visual quality;

         •        Biological Environment                         Terrestrial ecology and natural habitats
                                                                 and forestry.

         •        Human Environment                              Social character, traffic, land uses and
                                                                 waste management, cultural issues,
                                                                 involuntary resettlement, child/forced
                                                                 labour;

         •        Environmental Quality of the Area              Air quality, water environment (including
                                                                 wastewater and marine issues) and
                                                                 noise.


19
  With regard to the current level of operation at TTPP, it is important to note that the existing plant is not
operated continuously, but typically during peak evenings and where other power sources are interrupted. In
addition the Reverse Osmosis/E-cell desalination plant and combined cycle are not operational and/or
commissioned.

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        Data sources obtained and used for this section have been listed in Appendix C,
        Volume 2. As noted above, data used to update the baseline environmental details of
        the 1999 SEIS has been largely obtained by site reconnaissance and through
        consultation with site personnel. A list of those consulted during the preparation of
        this document is contained in Appendix D, Volume 2.

        The updated descriptions provided in this section represent the basis upon which the
        nature and significance or any additional environmental effects associated with T2 will
        be determined and judged accordingly.


4.2     Physical Environment


4.2.1 Landscape and Visual Quality

        Since the preparation of the 1999 SEIS (see section 3.9) there have been a number
        of changes to the baseline landscape and visual character and quality of the area.
        The following were observed:

•       Replacement planting of palm trees along the beach section previously cleared during
        the construction of the LCO supply pipeline and the seawater intake/discharge
        pipelines. The palms were generally approximately one foot high and had been
        planted approximately ten rows deep. Natural regrowth of ground vegetation was
        also underway and some grass seeding has been undertaken within the vicinity of the
        plant boundary, on the beach side in particular. [See Photograph Sheet 4,
        Photograph 5]. Large blocks of rock are temporarily being stored on the beach
        adjacent to TTPP; these are being removed by another for use as aggregate.

•       Some further grass seeding and planting of areas has been undertaken within the
        vicinity of T1, particularly in areas that will not be affected by T2. Although it was
        stated in the 1999 SEIS that the majority of the aesthetic planting within the TTPP site
        (incorporating T2) would not be undertaken until all the construction activities (T1 +
        T2) have been completed, this has since been brought forward partially to reduce the
        risk of soil erosion and to achieve a more rapid integration of the plant in to the
        surrounding area. Planting in the vicinity of the T2 site is the main element of the
        planting programme still outstanding.

        Outside the immediate vicinity of TTPP, other landscape changes have included:

•       The restoration of former borrow areas used primarily for T1 has progressed such
        that exposed earth surfaces have been significantly reduced and these areas have
        become more integrated into their surroundings. Some houses for the VRA township
        (for senior management) have also been constructed on top of the borrow areas
        immediately surrounding the VRA township.

•       Grass seeding and/or natural regeneration of formerly bare areas within the VRA
        Township has been completed such that the appearance of the township within the
        landscape in general has been softened. In particular, this includes the township’s
        leisure facility which has been completed and re-grassing of the area has been
        achieved. [See Photograph Sheet 5, Photograph 6].

•       Construction activities at Aboadze are ongoing, comprising the agreed community
        facilities as compensation for T1 (see section 4.4), including a 4-block school at
        Aboadze and one block school in Abuesi. Other, independent construction work is
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        also on going on the outskirts of Aboadze, adjacent to the plant and is mainly for
        living accommodation. [See Photograph Sheet 7, Photograph 9].

        Overall, and taking into account the above, there is considered to be a relatively slight
        improvement in the appearance of the baseline landscape character and quality of
        the area. This is primarily on account of the ongoing (natural and assisted)
        regeneration of vegetation within the area which has generally helped to soften and
        integrated the TTPP development and township into the surrounding setting.

        In terms of changes to the visual aspects described in 1999 SEIS, the above are
        reflected accordingly, such that there is a general slight improvement in the baseline
        conditions, again, associated with the regeneration of vegetation on those areas
        formerly left exposed by T1 construction activities. The exception is in the vicinity of
        the Aboadze where construction work for the school blocks is underway.

        Changes to the landscape and visual character and quality of the area strictly
        associated with the ongoing construction of T2 are discussed in section 5.2.1.


4.3     Biological Environment


4.3.1 General

        Section 3.8 of 1999 SEIS summarised the existing ecological character and quality of
        the study area, taking into account the changes that had occurred with the
        construction and operation of T1 since the 1995 ecological assessment undertaken
        for the 1995 EIA Report for T1.

        The following comprises an updated commentary on the 1999 SEIS baseline
        ecological conditions and specifically relates to the baseline conditions for T2
        pertaining to Natural Habitats and Forestry; both of which are covered by IFC policies
        OP 4.04 and 4.36, respectively.

4.3.2 Terrestrial Ecology – Flora and Fauna

        Within the T2 site, where construction is ongoing, there was no significant change to
        the description provided in section the 1999 SEIS, that is the T2 area comprised
        generally very little vegetation and where present it largely comprised grass of little
        ecological value. The exception relates to the small quantities of borrow material
        required for T2 which were obtained from an alternative, existing area off-site, and not
        as shown in Figure 3.3 of the 1999 SEIS. Approximately 7000 m3 of material for T2
        has been sourced from the privately owned borrow area which is located at
        Mpentsen, approximately 10 km west of the site. The borrow area is approximately
        10 ha in size and supplies material mainly for road improvement projects.

        Since the completion of T1, a number of areas formerly affected by T1 construction
        activities outside the TTPP boundary have either been restored or are in the process
        of being restored to their former character. These comprise the borrow areas, the
        wetlands and beach strip. Some houses for senior TTPP management have also
        been built on former borrow areas (T1) surrounding the VRA township.

        The area used for BVI’s construction administration offices, the concrete batching
        plant and workers’ transport collection point was, prior to commencement of T2
        activities, used as a construction laydown area for T1. Further discussion of the

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           potential environmental impacts of use of this area for the T2 project is provided in
           section 5.3 of this report.

           It was noted previously in the 1999 SEIS that very little wildlife, save for lizards, was
           observed on the T2 site during the previous GIBB site visits. This remained the case
           during the May 2000 site visit on account of the construction activities underway. It
           was noted, however, that numerous species of birds were present generally within the
           TTPP site, township and immediately surrounding area. These included pied crows,
           vultures, raptors (buzzards/hawks), weaver birds, various finches, egrets and
           wagtails, and at least another three unidentified bird species. The sewage lagoons in
           particular were observed to contain/support a variety of wildlife including frogs, fish,
           pied kingfishers, a species of cormorant, geese and coots, as well as aquatic insects.

4.3.3 Natural Habitats and Forestry

           The IFC policy on Natural Habitats defines natural habitats by the presence of
           predominantly native plants and animal species and by the absence of human
           activity. As noted in section 3.8.2 of the 1999 SEIS, prior to the commencement of T2
           construction, there was little vegetation present within the T2 site due to site
           clearance undertaken during with T1. Areas to be used for borrow for T2 had also
           been previously used for T1 and had therefore already been cleared of vegetation.

           There were no forests present within the areas to be affected by T2 and as noted in
           section 3.8.2, the area prior to the construction of T1 largely comprised coastal stand,
           seasonal swampland and/or coastal thicket, intermixed with farm plots.


4.4        Human Environment


4.4.1 General

           Section 3.3 of 1999 SEIS summarises the social character of the study area since the
           development of T1 and prior to the development of T2.

           The following comprises an updated commentary on the 1999 SEIS baseline social
           character based on the May 2000 site visit. It also specifically relates to the baseline
           conditions for T2 pertaining to IFC policy topics of cultural property (OPN 11.03),
           involuntary resettlement (OD 4.30) child forced labour (policy statement), and pest
           management (OP 4.09).

4.4.2 Update on Baseline Social Character, Traffic, Land Issues and Waste
      Management

           Social Character

           The main changes observed on the baseline social character for the area during the
           May 2000 site visit were related to the construction of ongoing community
           improvement projects mentioned in section 3.3 of the 1999 SEIS. The current status
           of these projects is as follows20

•          Construction of the four schools in Aboadze and one school in Abuesi are 90%
           complete. [See Photograph Sheet 5, Photograph 7 from May 2000].
20
     VRA, Takoradi Thermal Power Project, Monthly Progress Report, March 2000.
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•       The road improvements between Inchaban – Dwomo and Inchaban – Aboadze –
        Abuesi (a total of approximately 5 km) are complete.

•       Sites have been identified for the community latrines at Aboadze and Abuesi and
        members of the Regional EPA were on site on 10 May 2000 to inspect the suitability
        of these sites. The contract for the construction of these has been awarded and work
        started. These are approximately 90% complete and include:

        •        Aboadze cluster of four schools    Two (2) six- seater biogas latrines.

        •        Abuesi school                      One (1) six-seater latrine.

        •        Aboadze and Abuesi communities will be provided with three (3) and one (1)
                 ten- seater biogas latrines respectively.

•       The completion of an 80-ton capacity cold storage facility at Aboadze was completed
        and commissioned in November 2000.

•       Plans for a health clinic have been developed – the clinic will now serve both the
        Aboadze community and the TTPP township. The Arab Bank for Economic
        Development in Africa (BADEA) has given a "no objection" to using local contractors
        for construction of the clinic, the procurement process will proceed shortly.

•       A Planning layout to guide future development of the two towns has been completed
        by the Town and Country Planning Department on behalf of VRA but the Plan has not
        yet been formally submitted to VRA. This comprises proposed land use zoning for
        future development of Aboadze in a westerly direction from its current position
        towards the Aboadze-Inchaban road, surrounding the VRA township. Zoning includes
        residential plots (approximately 400), plots for light industrial use, 27 areas of Open
        Space, nine places of worship, a community centre, two petrol filling stations, two
        hotels, one bank, one supermarket, one nursery, one day-care centre, one fire station
        and one post office.


        Additional measures that have been implemented since the 1999 SEIS include
        installing a community water tap on the edge of Aboadze. This directly draws from
        TTPP’s water supply connection, which is received via pipeline from Inchaban, and
        has been installed to help provide a stable water supply, which is otherwise currently
        inconsistent. TTPP have provided the connection and the community are responsible
        for negotiating and paying the water company directly.

        On the basis of informal discussions undertaken for this Addendum with site
        personnel and members of Aboadze community and Shama Ahanta District
        Assembly, it is understood that there has been a general growth in the size of the
        immediate communities since the development of T1. This has largely been in
        response to the presence of direct employment at T1 (during its construction and
        operation) and in association with opportunities to generate an income providing
        support and services to the T1 (and now T2) workforce. Most notably a small food
        market of approximately 25 people working at 20 stalls was established adjacent to
        the T2 construction laydown area, providing food and drink to the local workers.

        In general, those people spoken to in Aboadze were happy with the arrangements
        with TTPP and did not have any further specific concerns to those already raised in
        the past and handled by TTPP. Additional comments were made regarding further
        facilities that would be appreciated by the communities, such as power supply and

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        extending the water supply into the centre of the Aboadze. However, strictly
        speaking, the provision of these facilities are technically out of the remit of VRA’s
        activities and additional to the original Community Improvements Agreement.

        As mentioned in section 3.5.1 above, the majority of the project workforce (skilled and
        unskilled) is sourced locally.

        Road Traffic

        It is understood that there has been one serious road traffic accident on the Aboadze-
        Inchaban road at the junction with the site since the preparation of the 1999 SEIS
        (see section 3.6 of the 1999 SEIS). This was reportedly largely due to driver error.
        The junction has since been regraded and no further accidents have occurred. VRA
        drivers have attended defensive driver courses.

        The local police force have erected a number of signposts and warning notices for
        drivers to reduce speeds along the length of the road and have also carried out
        periodic vehicle speed spot-checks to ensure compliance.

        Land Issues

        There have been no further changes to the land issues associated with T2 since the
        preparation of the 1999 SEIS (see section 3.7 of the 1999 SEIS).

        Waste Management

        In terms of waste management, in addition to the information on wastes produced
        and methods of disposal provided in Table 3.7 of the 1999 SEIS for T1, there have
        been the following changes:

•       The waste oil sludge is not all being burned on site as originally planned. At the time
        of the May 2000 visit T1 had disposed of waste oil as follows:

                  Incinerated:                               90 m3

                  Sold to third parties:                    300 m3

                  Sent to TOR:                            1500 m3

                  TOTAL:                                  1890 m3



•       This pattern has reportedly continued and is expected to do so. Due to the high cost
        of incineration and the commercial market for this product, it is expected that 5-10%
        of the waste generated will be incinerated, 15-25% would be sold to third parties with
        the balance going to the Tema Oil Refinery (TOR).

•       Waste oil sludge is currently removed off-site via road tanker under an arrangement
        made between TTPP and TOR where it is then reprocessed. It is understood from
        TOR that waste oil sludge received from TTPP is currently mixed with a residual fuel
        oil in storage tanks that are fitted with heated coils to maintain a good mixing regime.
        The resulting product is then either sold locally or exported for use in firing boilers or
        for mixing with chemicals to produce products such as wood preservatives etc. Prior
        to mixing, it is understood that the waste oil sludge received from TTPP is tested for
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          the presence and content of heavy metals and toxic substances by TOR. The final
          product produced is also tested, but primarily to determine its physical properties,
          such as pour point, density and sulphur content: the presence and content of heavy
          metals or toxic substances is not normally tested at this stage.

•         Discussions are also ongoing for the use of waste oil at a local steel manufacturing
          company and by another company for use as boiler fuel.

•         As there is no burning of the waste oil/sludge on site, regular monitoring of the quality
          of waste oil/sludge commenced only in February 2001, in follow up to IFC and OPIC
          suggestions. However, prior to setting up the arrangement with TOR, samples of the
          waste oil/sludge were analysed in order to determine its suitability for TOR. The
          results are shown in Table 4-1. It is important to note that the quality of waste
          oil/sludges produced will vary with the nature of the LCO supplied to TTPP.

          An analysis of the physical properties of waste oil/sludge was undertaken on 25
          November 1999, the results of which are presented below:

            Density                        937.9 kg/m3
            Viscosity at 50°C              259 cSt
            Water Content                  >20 % volume
            Pour Point                     51°C
            Flash Point                    <12°C


          Table 4-1:       Waste Oil/Sludge Analysis Results for T1.
Waste Source           Date       Calcium    Potassium   Sodium   Magnesium    Nickel      Lead     Vanadium
                                   (ppm)       (ppm)      (ppm)     (ppm)      (ppm)      (ppm)       (ppm)
Oily Waste Lagoon1     1/5/99       101         80        511         31         2           0         1.7
Tank 101               3/7/99       11          24        83          3          1         0.05        0.6

                       1/11/99      91          31        600         16         0.6         0         0.6
Tank 102               3/7/99       11          4         20          2           1          0         0.3

                       3/12/99      38          26        270         12          3          0         0.8
Centrifuge 1           27/10/99     48          17        289         10         0.4       0.03        0.9

                       28/10/99     33          12        202         6          0.4         0         0.8

                       12/6/00     303.9       26.6      327.4       41.6       1.94       0.52        3.0
Centrifuge 2           6/11/99      24          13        174         7          0.7       0.02         0

                       18/11/99    692         185        1114       211          6         7.5        9.6
T2 Fuel Treatment      12/6/00    1261.3       21.4       90.6       47.6        2.1        2.5        9.9
Plant
Note: 1 = viscosity measured on 27/10/99 at 2725.4 cSt.

          A report was prepared in March 2000 by VRA on the environmental management of
          waste oil sludge disposal options at TTPP where a number of waste disposal options
          were discussed and conclusions drawn on the most appropriate method to adopt (see
          Appendix E3, Volume 2)21. Options included construction of a temporary storage
          facility, controlled incineration (i.e. the original option), waste oil recycling (including
          using a chemical treatment process) and open-air incineration. It was concluded that
          the waste oil recycling option would be adopted as the primary method for waste
          oil/sludge disposal at TTPP, on the basis that the environmental implications that

21
     VRA (TTPP) Environmental Management Plan for Disposal of Waste Oil Sludge, March 2000.

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        would otherwise be associated with incineration (controlled or open air) would be
        reduced. It is understood that the incinerator will only be used when the collection of
        the waste oil/sludge by others is interrupted and it becomes necessary to empty the
        collection tank.

        The plant operators have implemented a monthly programme of waste oil sludge
        analysis to identify the nature and concentrations of the heavy metals Vanadium,
        Lead and Nickel present in waste oil sludge. This will enable the Environmental
        Manager to identify possible metals concerns before TOR (or another) removes the
        sludge and/or before any incineration is undertaken on site (where necessary). The
        T1 laboratory is used for this sludge analysis. Equipment available for this sampling
        programme and for any further analysis that becomes necessary includes:

        •    ICP-AES for trace metals.
        •    Centrifuge for water and sediment.
        •    Hydrometer for specific gravity.
        •    Viscometer for Viscosity.

4.4.3 Baseline Social Issues Specific to IFC Social Topics

        Cultural Property

        The IFC policy statement on Safeguarding Cultural Property (OP 4.11) is forthcoming,
        however, information was provided by the IFC on the World Bank Operational Note
        on the Management of Cultural Property22. This defines cultural property as having
        ‘archaeological (prehistoric), palaeontological, historical, religious and unique natural
        value’ and that financing for projects would be declined where these involved
        significant damage to such property, unless efforts are taken to minimise such
        damage. It is noted in section 3.3.2 of the 1999 SEIS that, based on available
        information, there were no sites of archaeological/historical significance in the TTPP
        site and surrounding area. It is also understood that no material of archaeological or
        historical interest was encountered during the construction of T1 (including in the
        borrow areas).

        With regard to cultural/religious features present, it is noted in the EPC Agreement for
        T2, that care would need to be exercised during construction owing to the location of
        a cemetery in the vicinity of T2 activities. In addition, at least three minor shrines were
        also identified as possibly being affected by the T1 construction activities. The
        presence and significance of these items were confirmed before T2 construction
        activities commenced and it is understood that, in practice, no shrines were found to
        be present within the vicinity of areas to be affected by T2. The cemetery (which is
        adjacent to the T1 lorry park, east of the fuel storage tank farm) was also found to be
        outside the main construction activity areas for T2.

        Involuntary Resettlement

        Involuntary Resettlement is defined in OD 4.30 as the involuntary removal of people
        resulting in significant disruption to social, economic, environmental, cultural and
        social/physical infrastructure.

        The 1995 EIA for T1 identified that prior to the construction of T1 there were no
        residences or squatters present on the proposed plant site. The main impacts on the

22
  World Bank Operational Policy Note No. 11.03, Management of Cultural Property in Bank Financed Projects,
1986
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           local community at the time were associated with the loss of farming plots for which
           compensation was negotiated and alternative plots located (see sections 5.1.2.5,
           5.2.2.5 and 7.3 of the 1995 EIA).

           As T2 is contained within T1, there were no residences or other community land uses
           present within the T2 site area prior to its construction, and at the site for the T2
           construction compound which was previously used for T1 construction activities.

           Child/Forced Labour

           Worker rights legislation within Ghana includes the prohibition of forced or
           compulsory labour, setting a minimum age for employment at 15, and restricting
           certain types of hazardous labour for workers under 18. While it is reported that
           forced labour is not practised in Ghana, it has also been reported that the violation of
           child labour laws is common particularly in the agricultural sector and both
           enforcement and prosecution for violations are erratic23.

           It is understood that at no time during the construction and subsequent operation of
           T1 (prior to commencing T2 construction activities) were these worker rights violated
           on the project. The current status of this issue for T2 construction is covered in
           section 5.4.2 below.

           Pest Management

           The IFC policy on pest management (OP 4.09) focuses on large scale agricultural
           sector pest control projects involving the use, transportation, handling, application and
           disposal of pest controlling chemicals (for flora or fauna).

           The primary pest management activities currently undertaken at T1 are relatively
           small scale operations in comparison to the scope of the IFC policy. They include
           controlling the prevalence of mosquitoes and hence reducing the risk of malaria within
           the plant and at the VRA Township. A programme for ‘disinfestation and fumigation’
           of the township and project site offices is undertaken on a quarterly basis.
           Employees and families are given prior notice of the next spraying which is
           undertaken over a period of 6 days, typically in the morning, and focuses on the
           drains, gutters, lawns, offices and immediately surrounding areas. This operation is
           undertaken under contract by an outside company.

           It is also understood that the growth of vegetation within the fenced substation area
           for T1 (and the future T2) is managed using chemical herbicides. This currently
           comprises an area of approximately 135 m2 for T1.

           Information on the nature of herbicide, ‘galigan’, used has been included in Appendix
           E4, Volume 2. It acts on both a pre-emergence and post emergence basis and
           controls a range of weeds and grasses. No further information was available during
           the May 2000 site visit on the frequency and qualities applied for either the insect
           spraying or herbicides.       In the absence of this information at this time,
           recommendations for mitigation measures have been included in section 6.4 in order
           to ensure that appropriate attention is given to the use of the chemicals on site.




23
     United States Department of State Country Report on Economic Policy and Trade Practices, Ghana, 1998.

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4.5     Environmental Quality of the Area


4.5.1 Introduction

        Further to the baseline descriptions on air, water and noise in the 1999 SEIS, this
        section draws on recent T1, baseline environmental monitoring data contained in the
        following reports and separately available data:

•       Annual Environmental Report for 1999 (January – December 1999) (see Appendix
        E5, Volume 2)24;

•       Quarterly Environmental Monitoring Data Report to EPA (January 2000 – March
        2000) (see Appendix E6, Volume 2)23.

•       T1 Stack Emissions Monitoring Data (including NOx) collated for the Environmental
        Management Programme between the dates of 1 June 1999 and 29 April 2000.

        These reports have been produced by VRA with due reference to the T1 EMMP
        which includes details of monitoring procedures, parameters to monitor and the
        application of environmental standards and criteria (see section 8.2). In particular, the
        environmental standards and criteria pertinent to T1 represent those applicable during
        the preparation of the 1995 EIA, namely 1988 World Bank emissions criteria and
        earlier versions of Ghanaian criteria to those used in the 1999 SEIS. Table 4-2
        summarises the parameters monitored for T1.

        Current World Bank and Ghanaian EPA criteria for thermal power plants (as
        applicable to T2) have been listed in Section 5, and reproduced in Appendix E7,
        Volume 2.25
        Table 4-2:        Summary of Air, Noise and Water Parameters Monitored for T1.
          Parameter                                                           Measurements Recorded
          NOx Stack Emissions                                                 Hourly – ng/J
                                                                              Daily – t/d
          NOx Ground Level Concentrations                                     Annual average – µg/m3
                                                                              24 hour average – µg/m3
          SO2 Stack Emissions                                                 Hourly – ng/J
                                                                              Daily – t/d
          SO2 Ground Level Concentrations                                     Annual average – µg/m3
                                                                              24 hour average – µg/m3
          Suspended Particulates Stack Emissions                              Hourly – ng/J
          Suspended Particulates Ground Level                                 Annual average – µg/m3
          Concentrations                                                      24 hour average – µg/m3
          Carbon Monoxide Ground Level Concentrations                         Annual average – mg/Nm3
          Noise (dBA)                                                         Power plant
                                                                              Perimeter Fence




24
   Note: In addition to the construction of T2 during these monitoring periods, T2’s SC1 Unit became operational
in March 2000 and start up procedures and testing will have been undertaken.
25
   World Bank Group, Pollution Prevention and Abatement Handbook, 1998.
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        Table 4.2:        Summary of Air, Noise and Water Parameters Monitored for T1
                          (continued).
          Discharge Water (cooling tower)                          Salinity (ppt)
          At common discharge sump:                                Tmax (°C)
          Service and Make Up Water                                BOD5 (mg/l)
                                                                   Suspended solids (mg/l)
                                                                   Faecal coliforms (~/100ml)
                                                                   Residual chlorine (mg/l)
                                                                   pH
                                                                   Phenols (µg/l)
                                                                   Oil and grease (mg/l)
                                                                   Phosphorous (mg/l)
        Source: 1995 EIA.



4.5.2 Air Quality

        The baseline air quality for the area in the vicinity of TTPP was described in section
        3.2 of the 1999 SEIS comprising a review of the 1995 EIA, a commentary on the
        available air quality monitoring results for T1 and a description of the meteorological
        conditions.

        Air quality monitoring has been ongoing since the preparation of the 1999 SEIS and
        the available results for T1 have been described below. It is important to note that
        there have been a series of mechanical and electrical problems with the monitoring
        equipment in general, particularly with the ground level air quality monitoring
        equipment. Data sets are therefore incomplete. Actions are being taken to resolve
        these problems (including inviting the EPA to undertake their own monitoring
        programme for a temporary period) and the EPA have been kept informed of the
        difficulties and the progress in resolving them.

        In the SEIS it was noted that Sulphur Dioxide emissions would be minimised through
        use of LCO and diesel fuels with a sulphur content of less than 0.2%. Supplier
        specifications for the diesel fuel show that it has less than 0.2% Sulphur content and
        regular laboratory analysis of the LCO shows that it has consistently remained below
        0.2% also.

        1999 Annual Environmental Report (AER)

        The available results of the ground level air quality and stack emissions monitoring for
        1999 have been summarised below in Table 4.3. Overall, it was concluded in the
        AER that the 1999 results of the SO2 emissions and ground level concentrations
        monitoring are largely within the relevant T1 criteria. NOx emissions are discussed
        below.

        For ground level monitoring results problems were experienced with the ground level
        air quality monitoring equipment as a whole and as a result all monitoring analysers,
        save for the SO2 analyser at Beposo Village were subject to lengthy data gaps
        (generally between 8 to 12 months).




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        Table 4-3:        Air Quality Monitoring Results – Ground Level and Stack
                          Emissions Monitoring – January 1999 to December 1999.
          Air Quality                                             Monitoring
          Parameter                                                Results
          NO2 Ground Level Concentration
          24 hour average – µg/m3                                 19.9 – 49.8
          SO2 Stack Emissions
          Hourly – ng/J                                              28-249
          SO2 Ground Level Concentrations
          24 hour average – µg/m3                                  1.43-20.0
          PM10 Ground Level Concentrations
          24 hour average – µg/m3                                    12-92
        See Table 4.5 for NOx Stack Emissions

        It should be noted that current (1998) World Bank and more recent Ghanaian criteria
        (see section 5) are similar to the standards used in the 1995 EIA. As a consequence
        similar relationships between monitored concentrations and relevant criteria generally
        apply as described above with the exception that the ground level PM10 reading will
        exceed the ‘new’ Ghanaian Limit of 70 µg/m3. However, this may be a reflection of
        high dust levels typical during the dry season.

        Quarterly Environmental Monitoring Data Report

        The results of the ground level air quality and T1 stack emissions monitoring for the
        period of January – March 2000 are listed Table 4-4below26.
        Table 4-4:        Air Quality Monitoring Results – Ground Level and Emissions
                          Monitoring – January 2000 to March 2000.
          Sampling Location      Jan         Feb         March   Applicable Standard
                                2000        2000          2000
          Ground Level PM10 Monitoring Data (24 hour average) (µg/m3)
          Aboadze Village/ VRA  19-37       43-74          NA        Ghana EPA:
          Township                                                    260 µg/m3
                                                             3
          Ground Level SO2 Levels (24 hour average) (µg/m )
          Plant site             The SO2 analyser was out of         Ghana EPA:
          Aboadze Village          service during this period.    200 µg/m3 or 0.07
          Beposo Village         1.45        23.1         24.7           ppm
          Ground Level NOx Levels (24 hour average) (µg/m3)
          Plant site             The NOx analyser was out of         Ghana EPA:
          Aboadze Village          service during this period.    320 µg/m3 or 0.156
          Beposo Village                                                 ppm
          SO2 Stack Emissions Monitoring (1 hour average) (ng/J)
          T1 Gas Turbine 1     83-173       25-57        38-47       World Bank
          T1 Gas Turbine 2     72-183       35-70        37-47    Equivalent27 1 hour
                                                                       average:
                                                                       258 ng/J
        See Table 4.5 for NOx Stack Emissions

26
   In addition to the construction of T2 during these monitoring periods, T2’s SC1 became operational in March
2000 and start-up procedures and testing will have been undertaken.
27
   The Canadian standard has been used here in lieu of an appropriate World Bank standard based on emission
rate.
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        In 2000, a combination of natural disaster (rainstorm), equipment breakdown, and the
        difficulty in obtaining replacement spares in time meant considerable disruptions to
        the ambient NOx and SO2 monitoring programme. Only SO2 data was available and
        then only for the first quarter of the year. This situation is being addressed and
        monitoring equipment is presently with the suppliers undergoing modification. The
        equipment should be back in commission by early May 2001.

        In short, and relative to the relevant T1 stack emissions and ground level air quality
        criteria, the first quarterly results for 2000 for T1 indicate that:

•       Ground level PM10 concentrations within Aboadze/VRA Township are well within the
        260 µg/m3 criteria concentration;

•       Ground level SO2 concentrations for Beposo village are well within the equivalent
        200 µg/m3 criteria concentration;

•       Where data was available, SO2 stack emissions were generally within 1988 World
        Bank air emissions criteria.

•       As mentioned above, NOx stack emissions during this periods were also generally
        within World Bank NOx emissions standards, except where the NOx control systems
        were out of service (see below).

        T1 NOx Emissions Monitoring Data – 1 June 1999 to 29 April 2000.

        Recent NOx stack emissions data for T1, (units SC1 and SC2) are shown as monthly
        averages in Table 4-5 below. The measured results have been converted to the
        appropriate units for direct comparison against the 1998 World Bank NOx emissions
        standard of 300 mg/m3.28

        For the purposes of this assessment, these results replace those NOx emissions
        results described in the Annual and First Quarterly Environmental Monitoring Data
        Reports only (see Appendix E5 and E6 of Volume 2 of the Addendum).

        The results indicate that despite initial problems with NOx equipment leading to
        sporadic increases in NOx emissions both SC1 and SC2 are generally in good
        compliance with the 1998 World Bank NOx emissions criteria.

        The exceptions occurred in June and July 1999 for units SC1 and SC2 respectively,
        where NOx emissions were in excess of the criteria. The maximum concentration of
        433 mg/m3 for both SC1 and SC2 were monitored during the month of June 1999.
        These exceedances were due to the water injection units being off-line.          It is
        understood that in order to reduce the likelihood of further water injection system
        failures, steps are being undertaken to ensure that the demineralised water treatment
        plant operates more efficiently. Similarly, these instances lead to higher emissions
        than the 100 ng/J level proposed in the 1995 EIA.




28
  T1 emissions are actually measured in the presence of CO2 , which is typically in the order of 4%. This is
assumed to be roughly equivalent to the 15% O 2, correction factor against which World Bank emissions standards
are corrected.

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        Table 4-5:        NOx Emissions Results for T1 between June 1999 and April 2000.

                                Month1                           NOx Emissions         NOx Emissions
                                                                  (mg/m3 ) 2, 3          (mg/m3)2, 3
                                                                      GT1                   GT2
            June 1999         (GT1-21, GT2 –22)                       333                   218
            July 1999         (GT1-0, GT2-11)                          0                    353
            September 1999    (GT1-15, GT2-15)                        163                   169
            October 1999      (GT1-7, GT2-18)                         144                   157
            November 1999     (GT1-6, GT2-18)                          77                   157
            February 2000     (GT1-14, GT2-12)                        138                   151
            March 2000        (GT1-13, GT2-14)                        142                   123
            April 2000        (GT1-12, GT2-0)                         172                    0
            Period Average 4                                          190                   185
            Maximum Concentration during Period                       433                   433
            Minimum Concentration during Period                        24                    71
        Note:
        1        Figures in brackets represent the number of days during which each of the units were
                 operational in the given month.
        2        Converted using the conversion factor shown in Table D.1 of the World Bank Guidelines (see
                 Appendix E7, Volume 2, Addendum Report).
        3        Corrected for dry 15% O2, 0 °C at 1 atmospheric pressure
        4        Total number of operational days during this period for GT1 and GT2 were 88 and 110
                 respectively.



        Monitoring data for the remainder of 2000 has shown that when compared with the
        revised 1998 World Bank limit, the SC1 plant complied 98% of the time, rising to
        99.5% if considered against the limit that applies during NOx equipment failure (SC2
        was under repair during this period). SC1 complied with the 1988 World Bank
        guidelines, against which the plant was originally considered, on 89% of occasions
        when the Fuel Bound Nitrogen (FBN) uplift is applied. The FBN uplift was introduced
        shortly after the 1995 EIA was completed and is an allowance that attempts to
        account for the fuel Nitrogen variability that occurs in practice.

4.5.3 Water Environment

        Water Supply

        Given the current intermittent operation of T1, it is expected that the actual water
        supply requirement will currently be less than that previously stated in the 1999 SEIS.

        Waste Water

        Wastewater quality monitoring results for the plant effluent provided in the 1999 AER
        for T1 are summarised in Table 4-6.

        A comparison of the relevant monitoring results and the T1 environmental criteria
        (see Table 4.6 below) indicate that with the exception of suspended solids, monitored
        results for 1999 were within relevant T1 criteria limits. In terms of 1998 World Bank
        criteria and more recent Ghanaian EPA guidance (see section 5) it is of note that the
        same relationships apply.



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        Seawater temperature is monitored in Aboadze village, approximately ½ km east of
        the power plant property line and down current from the seawater discharge point.
        The temperature readings are taken on a regular basis (at least once a week)
        approximately three metres from the shoreline. A summary of the results collected for
        the 12 months up to April 2000 is provided in Table 4-7.

        Table 4-6:        Summary of 1999 Wastewater Quality Monitoring Results.
          Parameter                       Applicable WB/USA/Can                 Monitoring
                                                 Standard                Results (TTPP + others)
          BOD5 (mg/l)                                30                             NA1
          Suspended solids (mg/l)                    30                           0.6-802
          Total coliforms (100 ml)                 100 3                             0
          pH                                        6-9                            6.5-9
          Oil and grease (mg/l)                   5+NVS                             <5
          Temperature (°C)                 <3o above ambient at          0.12 °C below ambient at
                                           edge of mixing zone                    beach4
        Note:    1        Not applicable
                 2        Limit exceeded 4 times in the year
                 3        Standard for Faecal Coliforms
                 4        Ambient taken as 1998 baseline annual average beach sea temperature at Aboadze
                          (26.29°C).

        In future there will be periodical seawater temperature readings taken offshore and
        down current of the seawater discharge in order to monitor any changes in
        temperature. However, the main emphasis will be on monitoring the temperature of
        water in the discharge sump prior to evacuation through the seawater discharge. At
        present the current seawater temperature monitoring provides additional ambient
        seawater temperature data.

        Table 4-7:        Seawater Temperature Results between the period of May 1999 to
                          April 2000.
          Month                     Temperature Range (°C)            Average Temperature(°C)
          May 1999                       27.5 - 29.0                           28.4
          June 1999                           -                                  -
          July 1999                      22.0 - 25.5                           23.3
          August 1999                    21.0 – 23.5                           22.2
          September 1999                 21.5 – 24.0                           22.3
          October 1999                   21.5 – 28.0                           25.3
          November 1999                  27.5 – 29.0                           28.5
          December 1999                  27.0 – 30.0                           28.7
          January 2000                   24.0 – 28.0                           26.0
          February 2000                  26.0 – 29.0                           27.4
          March 2000                     28.0 – 30.5                           29.5
          April 2000                     26.5 – 29.7                           28.4

        The following information was available on ‘existing’ wastewater quality monitoring
        with T1 in operation between January to March 2000:

•       Estimated quantity of liquid waste per month during this period was 500m3 and was
        composed of discharges from the neutralisation sump, oil waste lagoon, chemical
        lagoon and boiler effluent/cooling tower waste water.



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•         Monitoring results from the neutralisation sump, oil waste plant and chemical lagoon
          are shown in below (the main storm drain was not monitored during this period as it
          was dry for most of the time);

          Table 4-8:        Water Quality Monitoring Results, T1, January to March 2000.
Sampling                        pH         Oil and          TSS         Coliforms1       Conductivity
Locations                                  grease          (ppm)                           (uS/cm)
                                           (mg/l)
Neutralisation sump            7.5-8.8      NVS          4.0-22.0            A                210-340
Oily Waste plant               6.9-7.7      NVS          16-1082             A                332-7800
Chemical Lagoon               6.9-10.2      NVS          10-1162             A                 47-541
          Note:       1         presence (P) or absence (A) identified only.
                      NVS       No visible sheen.
                      2         Due to wind blown solids, HRSG operation and from oily waste lagoon
                                sources.

          These readings were taken prior to the effluent being fed to the common discharge
          sump where mixing with other operational effluents would occur prior to discharge
          (provided the quality of the combined effluent was identified as acceptable).

          Oil Spill and Contamination Events

          While there have been no major releases of LCO at sea with T1, there have been
          some minor incidents on land. These have been primarily associated with spills of
          LCO, diesel and/or waste oil sludge onto the immediately surrounding area (e.g. pipe
          trench, soil, grass or concrete) or into the storm drain. These have largely been
          associated with a combination of causes which mainly relate to defective equipment,
          pumping problems, mishandling and causes unknown.

          The estimated quantities of hydrocarbons released during these incidents have
          typically ranged from one litre to 100 litres (with the majority in the lower range). The
          exceptions include two events in 1998 where ‘considerable’ spills of approximately
          1000 gallons were recorded. In both instances the spill was contained (by existing
          berms or by depositing soil as a flow resisting material) and removed by either
          pumping into road tankers for transfer to the untreated LCO tanks for use or by
          pumping the spilt oil into drums, applying oil absorbent pads in the affected areas.
          These incidents have been recorded as required under Environmental Procedure 10
          of the T1 Environmental Management System Manual29. The EPA visited the site
          after the clean up operations to determine whether there had been any significant
          environmental effects. They did not require any further actions and no written
          response was made.

          International Waterways

          IFC policy OP 7.50 on International Waterways relates to projects that directly affect
          waterways that form a boundary between states, affects a water body that is a
          component of such a water way or affects a water body that is bounded by any
          number of states and forms a necessary ‘channel of communication’ to the open seas
          for these states. Specific projects highlighted as applicable to this policy do not
          directly include thermal power plants although any project that could result in the
          pollution of such water bodies would be relevant.


29
     ESB International Takoradi Power Station, Environmental Management System Manual 1998.
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        The existing power plant is situated on the west coast of Ghana, approximately 15 km
        east of the key port of Takoradi which in turn is at least 150 km east of Côte d’Ivoire
        and approximately 360 km west of Togo. The oil supply pipeline which runs in a
        southeasterly direction from the coast into the Gulf of Guinea is approximately 4.5 km
        long and terminates at a single point mooring (SPM). The typical size of tankers
        berthing at the SPM is 40,000 tonnes and the duration of a visit by a tanker at the
        SPM is in the order of 24-48 hours [see Photograph Sheet 4, Photograph 5]. At the
        current rate of fuel usage for the existing plant, a delivery of LCO is made once every
        four months. It is understood from consultations on site that ships accessing the
        pipeline and SPM do not obstruct or affect any shipping lanes leading into and/or out
        of the port of Takoradi during the length of time they are present at SPM. Shipping
        lanes typically tend to form a direct approach to a port from out to sea, rather than
        following the coastline which would have to be the case if TTPP activities were to
        have an effect. The location of the pipeline and SPM does not affect any water body
        that may be classified as a ‘international waterway’ as defined in the IFC policy OP
        7.50. The implications of any oil spills in the vicinity of the SPM affecting international
        waterways are discussed in section 5.5.3.

4.5.4 Noise

        The baseline noise climate in the vicinity of T1 and T2 was provided in section 3.5 of
        the 1999 SEIS. Subsequent to the noise monitoring results summarised in section
        3.5 of the 1999 SEIS, the following have been recorded as part of the on going noise
        monitoring programme for T1 and have been extracted from the following documents:

•       Annual Environmental Report for 1999 (January – December 1999)27; and

•       Quarterly Environmental Monitoring Data Report to EPA (January 2000 – March
        2000).30

        These results incorporate T1 only (although there is likely to be some influence from
        ongoing T2 construction activities being undertaken during the monitoring periods);
        data incorporating T2 has been included in section 5.5.4 of the Addendum.

        1999 Annual Environmental Report (AER)

        The summary of the weekly noise monitoring results for 1999 (as detailed in the 1999
        AER) have been listed in Table 4-9 below. It was noted in the 1999 AER that noise
        levels for the selected T1 plant were generally within the World Bank criteria of 85
        dB(A) at one meter from the plant in question. However, noise levels at the fuel
        treatment plant in particular, were in excess of the 85 dB(A) limit. As a consequence,
        health and safety notices were erected to notify workers to wear ear protection and it
        is mandatory for such equipment to be worn in the fuel treatment room.

        It was noted that maximum level (LAeq) noise levels at to the plant fence line exceeded
        the 1988 World Bank noise level of 55 dB(A) on a number of occasions due to noisy
        construction activities for T1 and T2 (later in the year) involving heavy plant vehicles
        and the periodic use of diesel generators.

        With regards to current 1998 World Bank noise levels, the criteria applies to
        maximum noise levels at the property boundary compared to the perimeter fence as
        per 1988 World Bank criteria used for T1. The area beyond the eastern boundary

30
 Note: In addition to the construction of T2 during these monitoring periods, T2’s SC1 became operational in
March 2000 and start-up procedures and testing will have been undertaken.

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        fence is generally not densely populated, however residences and other buildings are
        currently under construction close to TTPP [see Photograph Sheet 7, Photographs 9].
        It is of note that beyond the TTPP acquisition boundary, TTPP do not have any
        control on land use planning (this is the role of the Shama Ahanta East Metropolitan
        Assembly) such that people can erect houses directly adjacent to the plant boundary
        should they choose to do so.

        Table 4-9:        Noise Monitoring Results, T1 (dB(A)) – Jan 1999 to Dec 1999.
                    Plant Fenceline                T1 Gas             Fuel          Transformers
Month              East     N, S and W           Turbine Area   Treatment Room
March              53-58       55-78                64-98            67-101               71-84
April              55-64       57-65                86-92            83-97                71-83
May                54-56       56-61                62-89            82-91                74-82
June               54-58       60-77                60-89            80-92                72-81
July               53-55       55-74                64-89            87-95                74-79
August             63-70       50-59                   -             90-96                69-76
September          55-68       59-66                62-87            77-95                74-82
October            52-55       55-80                68-90            54-96                73-78
November           54-57       56-78                69-89              NA                 73-78
December           54-57       55-77                87-91            84-90                71-78
Note: NA = noise monitoring equipment out of service.

        Quarterly Environmental Monitoring Data Report

        It was noted in the quarterly report that the exceedances recorded were either due to,
        or counterbalanced by the following:

•       Construction noise (primarily T2) and one steam blowing event for T1 which affected
        plant boundary noise levels;

•       Despite the high noise levels monitored for the gas turbines and fuel treatment plant,
        noise levels at Aboadze were stated as not being significantly affected. Workers are
        required to comply with noise protection measures throughout the site where noise
        levels are high, as indicated by posted health and safety signs.

        Table 4-10: Noise Monitoring Results, T1 (dBA) – Jan 2000 to Mar 2000.
         Sampling Location        Jan       Feb       March    Applicable Standard
                                 2000       2000       2000             (dBA)
         Plant fence boundaries  56-78     58-77     41-110               55
         (N, S, E and W fences)
         Gas turbines area       87-88     87-88      86-90     85 at one meter from
                                                                         plant
         Fuel Treatment room     85-94     87-90      87-93     85 at one meter from
                                                                         plant
         Transformers            74-78     72-75      76-80     85 at one meter from
                                                                         plant

        Overall the baseline results collected for both 1999 and 2000 indicate that operational
        noise levels for T1 are roughly comparable to those reported in Appendix 8, Volume 2
        of the 1999 SEIS (these have been reproduced in Appendix E, Volume 2 to the
        Addendum). Plant fenceline noise measurements generally tend to show an increase
        relative to the measurements undertaken in association with the 1999 EIA, however,

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        as construction and start-up activities are still ongoing these levels are not expected
        to represent a ‘normal’ operations noise environment. It is expected that beyond the
        TTPP acquisition boundary the high monitored noise levels will have reduced,
        particularly in the direction of the VRA township and Aboadze.




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5       SIGNIFICANT ENVIRONMENTAL EFFECTS

5.1     Introduction


        The following comprises a description of the likely nature and significance of
        additional and/or new environmental effects that would occur relative to the updated
        information for T2 and for the new topics addressed in the Addendum.

        Unless stated otherwise the same assessment approaches and assumptions
        described in section 4 of the 1999 SEIS have been used for the Addendum EIA. The
        exceptions are for noise and air quality assessments as no further monitoring or
        modelling was undertaken for this study.


5.2     Physical Environment


5.2.1 Landscape and Visual Effects

        Construction Effects

        Based on the May 2000 site visit, the main changes to the construction landscape
        and visual effects over and above those described in section 4.9 of the 1999 SEIS
        comprise the following:

•       The BVI construction compound immediately adjacent to the plant was particularly
        noticeable within the landscape when approaching the site on the Inchaban-Aboadze
        road. This is largely due to the presence of the concrete batching plant tanks and the
        stockpiles of material of different colours to the surrounding land use.

•       The establishment of a food market adjacent to the BVI Compound and worker’s bus
        parking areas also represented a minor adverse change to the landscape and/visual
        character of the site when looking towards these areas due to the largely cluttered
        appearance of these areas. This has since been removed.

•       The construction of T2 is largely screened by T1, particularly from the north and
        eastern approaches to TTPP and the populated areas.

        Operational

        It is anticipated that there will be no further significant adverse impacts on the
        landscape/visual character and quality of the area surrounding and overlooking TTPP
        (incorporating T2) for the operational stage over and above those effects described in
        the 1999 SEIS.

        The rehabilitation of the areas currently used by BVI for construction purposes
        (including the dismantling of the concrete batching plant) after completion of
        construction activities represents an improvement.

        The maturation of planting already undertaken at TTPP and after completion of T2 will
        continue to help soften and break up the appearance of the plant within the landscape
        at ground level. However, given the scale of the plant it will not be possible to

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        completely screen the plant from views, particularly from view-points on higher
        ground.

        It is important to bear in mind that within the cultural context of the area, local
        perceptions of the visual and landscape effects of the plant are expected to be of a
        generally reduced significance, compared to the significance of TTPP on socio-
        economic factors, such as land-use.



5.3     Biological Environment


5.3.1 Terrestrial Ecology – Flora and Fauna

        Site Preparation and Construction Effects

        In terms of vegetation clearance, habitat loss and disturbance to wildlife, there is
        expected to be no significant change to the effects described in 4.8.2 on account of
        the fact that the T2 site is largely contained within an area already affected by T1
        (including the BVI construction area and other laydown areas) and that the
        construction phases for T1 and T2 have been concurrent.

        While the construction period for T2 is longer than that considered in the 1999 SEIS,
        it is thought that this will not represent a significant change to the conditions
        described in the 1999 SEIS. This is on the basis that the extension is cumulative
        (rather than a new occurrence) and that the surrounding area is not particularly
        ecological sensitive to noise. Given the number of birds observed in the vicinity of
        TTPP in general and at the sewage lagoons which lie between the BVI construction
        compound and the T2 site, it is considered that the previous comment made in the
        1999 SEIS that a degree of acclimatisation by birds to noise levels may occur
        remains valid.

        With regard to habitat contamination, BVI have been required to limit habitat
        contamination due to, for example, silt loading into the wet lands that surround the
        construction compound and off the T2 site and from spills and dust emissions as
        described in the EPC contract (see section 3.5.5 and Appendix E1, Volume 2). This
        included, for example:

•       laying straw at the main surface runoff channels from the construction compound to
        retain any silt contained within the runoff;

•       constructing a temporary drainage system for T2 during SC1 to collect and channel
        runoff from the T2 site into settling basins and the existing T1 drainage system. This
        temporary system has been replaced by a permanent system under T2, SC2 Phase.
        [See Photograph Sheet 2, Photographs 2a and 2b].

•       removal off site of waste slurry produced at the concrete batching plant by the
        subcontractor to an appropriate site for disposal.




        Operational Effects

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        It is anticipated that as there is no adverse change to the main plant components of
        the T2 plant, relative to the details available for the 1999 SEIS or additional land-take,
        there will be no significant change to the nature and significance of the ecological
        effects described in section 4.8.3 of the 1999 SEIS.

        It is of note that under current operations, the T2 units are used on an intermittent
        basis rather than continuously (i.e. they are typically operational for evening peak
        periods only). Consequently there is expected to be a reduction in the degree of
        impact on disturbance to wildlife and habitat contamination through the settling of
        stack emissions compared to that described in the 1999 SEIS. This would be
        expected to continue for the duration of the reduced operations of TTPP.

        Similarly the change in waste oil disposal will also potentially have a benefit on the
        surrounding environment.

5.3.2 Natural Habitats and Forestry

        Site Preparation and Construction Effects

        Given the following, it is concluded that T2 will have no effect on natural habitats and
        forestry:

•       The T2 site, which is incorporated within the existing TTPP site, was previously
        cleared during T1;

•       Borrow material required for T2 has been supplied from existing borrow areas off site;

•       The BVI construction compound (including the concrete batching plant and spoil
        storage area) were sited on land previously used or disturbed in connection with T1;

        Operational Effects

        The main impacts associated with TTPP (including T2) that may affect any natural
        habitats and forested areas would be associated with the settling of stack emissions
        downwind of TTPP. However, as described in section 4.8.3, the area downwind of
        TTPP is largely comprised of land modified for subsistence farming and generally of
        little ecological value.



5.4     Human Environment


        The methodology used for this assessment comprises a mixture of the approach
        adopted and described in section 4.3.1 of the 1999 SEIS and incorporating the
        observations and data collected during the May 2000 site visit.

5.4.1 Social Character, Traffic, Land Issues and Waste Management

        Site Preparation and Construction Effects

        Relative to the specific issues raised in section 4.3.2 of the 1999 SEIS, the following
        updated comments associated with the effects of the T2 construction phase to date
        are listed below:


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•       Effects on the community infrastructure – no change to the conclusions of the 1999
        SEIS given that the infrastructure had already been set up for T1.

•       Actual labour requirements for T2 SC1 and SC2 exceeded the figure originally quoted
        (350) in the 1999 SEIS for the then Phase I and Phase II. The highest average
        monthly construction labour force (403) was recorded in the T2 Project Progress
        Report no 12 and covered both SC1 and SC2 labour requirements.

•       Save for a food market that was temporarily sited adjacent to the BVI construction
        compound by local people to cater for the Ghanaian site workers, there is no other
        evidence of temporary shanty towns having been set up adjacent to the site and/or an
        uncontrolled influx of migrant workers for T2 to date. This is unlikely to change with
        the remaining T2 construction phase.

•       No significant changes to the 1999 SEIS conclusions on food supply competition for
        T2 have either been observed with the T2 construction phases already underway. It is
        therefore expected that there would be no change with the remaining construction
        period for CC.

•       No significant problems with regards to anti-social behaviour by immigrant workers
        have been recorded for T2 since the preparation of the 1999 SEIS. It is expected on
        the basis of previous experience on site that there will be no change to the
        conclusions of the 1999 SEIS on this matter (see chapter 4.3.2 of the 1999 SEIS).

•       Public health –no significant change to the conclusions of the 1999 SEIS on the risk
        of an increase in HIV/AIDS and sexually transmitted diseases, and in mosquito
        breeding areas.

        In terms of traffic and access impacts (see section 4.6.2 of the 1999 SEIS) there is no
        updated information on the levels of traffic generation associated with the completed
        SC1 and SC2 Phases and for the future CC phase. However, traffic levels and their
        knock-on effects on road side air quality, noise and risk for road traffic accidents, are
        still expected to be of a similar magnitude and significance to those described in
        section 4.6.2 of the 1999 SEIS. However, the cumulative length over which these
        effects may occur may potentially increase due to the change in construction phasing
        of T2. Such that, the previously predicted three year construction period of T2 may
        extend to almost four years.

        It is expected that there will be no significant change to the potential land use effects
        (i.e. within the vicinity of the T2 borrow areas) described in section 4.7.2 of the 1999
        SEIS.

        In terms of waste management there is no significant change to the general types of
        waste generated during site preparation and construction phase. It is understood that
        subcontractors are responsible for removing generated waste offsite, and or recycling
        construction materials accordingly. For example, wood packaging and former form
        work is made available to the labour force on a reward basis such that those teams or
        individuals working particularly efficiently will be given a quantity of wood for domestic
        use. No burning of waste is undertaken on site.

        Operational Effects

        There is expected to be no significant change to the conclusions of the 1999 SEIS
        due to the fact that there has been no significant change to T2’s components and
        hence its operation. The fact that some of the TTPP plant is not operating on a
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        continuous basis would be expected to result in a general reduction in the level and
        significance of environmental effects.

        Community relations between TTPP and the surrounding communities continue to be
        very good on account of the activities of the community improvements project
        programme, TTPP Public Relations’ officer, and that VRA encourage an open-door
        approach to receiving and handling complaints and requests for assistance or
        information. Informal consultations with Assembly members and townsfolk of
        Aboadze during the May 2000 site visit indicated that they continue to be happy with
        the community improvement projects underway. There were generally no specific
        concerns raised regarding the impact of TTPP, although it was mentioned that initially
        there were fears regarding impacts on fish stocks and health due to air emissions.

5.4.2 Social Issues Specific to IFC Social Topics

        Site Preparation and Construction Effects

        Based on the following, it is concluded that there has been no significant effect on
        cultural property and resettlement due to elements of T2 so far undertaken.

•       No features of cultural, archaeological, historical or religious significance were
        discovered during the construction works for T1 (which incorporated the main T2);

•       The cemetery and shrines highlighted as being potentially affected in the construction
        mitigation plan included in the EPC Agreement have not been directly affected by T2
        phase to date;

•       The T2 site is contained within the existing T1 site and consequently there were no
        residences or squatters present on the T2 site prior to construction commencing
        (including the BVI construction compound area). Therefore there was no requirement
        to remove and resettle people for T2.

        With regard to the use of child and or forced labour during the remaining T2
        construction phase, labour at the site is provided via a number of resourcing
        subcontractors, supplying both skilled and unskilled workers from within Ghana for
        construction, mechanical, electrical, civil and administration activities. It is stated in
        Article 15 of the EPC Agreement that:

        ‘…the Contractor further agrees to observe applicable laws relating to a minimum age
        for employment of children, acceptable conditions of work with respect to minimum
        wages, hours of work, and occupational health and safety, and not to use forced
        labour.’ 31

        The ‘disinfestation and fumigation’ programme currently undertaken on TTPP
        property (including the township and project offices) is an ongoing programme but
        has not been extended, as yet to incorporate the BVI construction areas of T2. Other
        T2 related project offices have been accommodated within the existing offices on the
        northern edge of the plant which are already subject to periodic spraying. This is
        expected to represent a relatively small incremental increase in the area affected
        during spraying and the volumes of spray applied. Given the health benefits, this
        incremental change is not expected to represent a significant impact.

31
   Amended and Restated Agreement between Takoradi International Company and Black and Veatch
International Company for the Construction, Start-up and Testing of Takoradi 2 Facility in Aboadze, Ghana,
effective as of 23 February 1999.

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        Operational Effects

        There will be no further impacts on cultural properties or requirements for
        resettlement during the operation of T2. An exception may be the food market
        (comprising shelters and stalls used for providing food only) which appeared in the
        earlier phases of T2 and was removed once construction of SC1 and SC2 was
        complete. This is because the market was in operation against VRA/TIC policy,
        however as it has been recognised as providing a useful service during the T2
        construction phase it may be allowed in the remaining phase of T2.

        There will continue to be a policy of appropriate recruitment and employment for the
        operational phase of T2, as applied throughout the lifespan of TTPP to date. There
        will be no use for child or forced labour at T2 and TTPP.

        In terms of pest management, there will be a slight increase in the area of land within
        the vicinity of the substations over which herbicide will be applied to manage
        vegetation growth in this area. This will represent an increase in the application area
        from 135 m2 to approximately 190 m2 (including CC phase requirements) which is
        considered to be a minor, incremental change over and above the current application
        area. The quantity of herbicide will also increase, however this is again not expected
        to represent a significant increase over and above the quantities already applied in
        the area under T1. It is of note that the area immediately surrounding the substation
        (i.e. within 10 m of the substation fencing) comprises a mixture of T1 plant, fencing
        and the TTPP perimeter access road. In addition, the grading of the area beyond the
        northern TTPP fence is raised above the substation area and the vegetation present
        is largely, relatively recently planted grass. Consequently it is expected that
        irrespective of the chemicals used to manage vegetation regrowth, the impact of any
        drift during application would be reduced due:

•       to the low sensitivity of the surrounding area; and

•       the shielding provided by the lower elevation of the substation compared to the land
        immediately to the north.

        See section 6.4 for a discussion on appropriate mitigation measures.


5.5     Environmental Quality of the Area


5.5.1 Introduction

        Due to the circumstances under which the 1999 SEIS was produced the significance
        of the results of the air, water and noise assessments were determined relative to
        primarily Ghanaian environmental quality criteria. As IFC and OPIC have requested
        that compliance with 1998 World Bank criteria is shown, the following largely
        comprises a review of the available monitoring data for TTPP as a whole and T2’s
        SCI (where available) and a commentary on the implications of applying the 1998
        World Bank criteria to the results of the 1999 SEIS assessments.

        The 1998 World Bank criteria for thermal power plants are listed as per topic in this
        section. Full details of the criteria are reproduced in Appendix E7, Volume 2.


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        Environmental monitoring has shown that T2 generation equipment has achieved
        excellent compliance with relevant emission guidelines. With some discharges 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.

        The T2 plant is expected to reliably meet the relevant environmental guidelines.

5.5.2 Air Quality

        The Ghanaian and 1998 World Bank ground level air quality criteria are shown in
        Table 3.1 of the 1999 SEIS. 1998 World Bank emissions criteria are shown below
        (there are no Ghanaian emissions criteria).

        Table 5-1:        1998 World Bank Stack Emissions Criteria.
                                              Maximum Emissions Level
          Parameter        Metric tons per day     Milligrams per     Parts per million
                                   (tpd)            cubic meter            (ppm)2
                                                             3 1
                                                      (mg/m )
          NOx                        -                   300                 146
          SO2               0.2 tpd/MW plus              2000                700
                           2000 mg/Nm3 (dry,
                            excess O2 15%),
                            with max. 500 tpd
          PM10                       -                    50                  -
        Source:     World Bank Group Pollution Prevention and Abatement Handbook – Thermal Power:
                    Guidelines for New Plants, 1998
                              3
        Note:       1.   mg/m is dry, 1 atmospheric pressure, zero degrees centigrade, excess O2 15%
                    2.   See Table D.1 in the World Bank guidance for conversion chart.

        Site Preparation and Construction Effects

        There is expected to be no change to the nature and significance of the impacts
        described in section 4.2.2 of the 1999 SEIS (which in turn specifically related to the
        conditions described in the 1995 EIA Report). However, the period over which the
        construction related effects may last may be extended by up to one year beyond the
        construction phase considered in the 1999 SEIS.

        Operational Effects

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           Overall it is expected that, given there is no significant change to the design and plant
           previously considered in the 1999 SEIS, there will be no significant change to the
           conclusions of the air quality modelling assessment presented in section 4.2.3 of the
           1999 SEIS. This assessment addressed the cumulative effect of all four simple cycle
           units operating simultaneously and running on LCO.

           Taking into account the requirement by IFC and OPIC to confirm compliance with the
           1998 World Bank Guidelines it is noted that:

•          Maximum predicted ground level NO2 and SO2 concentrations depicted in Table 4.3
           of the 1999 SEIS are all significantly within the appropriate World Bank ground level
           air quality criteria as listed on the World Bank’s web page.32

           T2’s SC1 unit has been operational since 1 March 2000, and at this stage, and prior
           to the finalisation of the EMMP for T2, only NOx emissions are currently monitored
           from the SC1’s stack. Emissions data for SCI was provided for the specific periods
           during which the unit has been operational between 6 March – 31 March 2000. The
           unit was typically operational from 1700 to 0000 hours on a total of 15 days during
           this period, with 2 occasions during this time when the unit was in operation for up 12
           hours during the 24 hour period.

           Table 5-2 summarises the results of the emissions monitoring undertaken during this
           time and shows the daily average for the both the original measurement in parts per
           million volume (ppmv) and the converted concentration (mg/m3) for comparison with
           the 1998 World Bank NOx emissions standard.

           Table 5-2:       NOx Emissions Results for T2’s SC1, March 2000.
                                 Date 1                          NOx Emissions      NOx Emissions
                                                                    (ppmv)            (mg/m3)2,3
                       6/3/00 (7 hours)                               75                 153
                       7/3/00 (7 hours)                               65                 134
                       8/3/00 (7 hours)                               62                 128
                      11/3/00 (7 hours)                               66                 134
                      12/3/00 (7 hours)                               65                 134
                     14/3/00 (12 hours)                               64                 131
                     15/3/00 (12 Hours)                               66                 134
                      163/00 (7 hours)                                65                 133
                      17/3/00 (7 hours)                               65                 133
                      23/3/00 (7 hours)                               67                 137
                      25/3/00 (7 hours)                               66                 135
                      26/3/00 (6 hours)                               64                 132
                      28/3/00 (8 hours)                               65                 133
                      29/3/00 (5 hours)                               68                 139
                      30/3/00 (8 hours)                               63                 128
                      Period Average 4                                 66                134
             Maximum Concentration during period                      115                236
             Minimum Concentration during period                      38                  77
           Note:
           1. Figures in brackets represent the number of hours during the 24 hour period that the unit was
               operational.


32
     http://www.worldbank.org/html/fpd/em/power/standards/airqstd.stm
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        2.   Converted using the conversion factor shown in Table D.1 of the World Bank Guidelines (see
             Appendix E7, Volume 2, Addendum Report).
        3.   Corrected for dry 15% O2, 0 °C at 1 atmospheric pressure
        4.   Total number of operational hours during this period was 114 over a period of 15 days in March
             2000.

        It can be seen that the results for T2, including the maximum concentrations
        measured during this period, are well within the 1998 World Bank NOx emissions
        criteria of 300 mg/m3.

        T2’s SC2 was commissioned in September 2000 and its operation has alternated with
        SC1 during evenings. Table 5-3, taken from the Annual Environmental Report 2000
        (AER 2000) shows the results for the operation of both T2 SC units in 2000. These
        results show that the T2 plant is achieving excellent compliance with World Bank
        Limits. However, there have been instances where NOx control equipment has
        suffered outages, as well as some problems with NOx monitoring equipment.

        All ambient NOx and SO2 analysers had been taken out of service at time of writing
        and were being shipped to the Colorado, USA supplier for repairs. Increased spares
        were also being purchased as a result. They were expected to be back in
        commission in late April2001. Particulate equipment has also failed, and a request
        has been placed for repair and for the purchase of additional back-up equipment.
        Failure of the site meteorological station has been addressed with purchase of parts
        and the station was due to be repaired in late March. However, the location has been
        identified as inappropriate due to the influence of recent buildings placed in the
        vicinity. A new station has been selected and a purchase request made. An
        appropriate site will be selected for this station.

        For the purposes of this assessment the monitoring details in Table 5-3 replace the
        details presented for NOx stack emissions monitoring in the First Quarterly Report to
        the Ghanaian EPA for T2 (see Appendix E8, Volume 2).
        Table 5-3 NOx Emissions results for T2, AER 2000
             Unit         NOx Emission 1 Hr Average (ppm)                  Applicable        Remarks
                                                                           Standard1
                       March       Apr-Jun      Jul-Sep       Oct-Dec      300 mg/m3          ~100%
                       2000         2000         2000          2000           or (400       compliance
          G T1          287          na         140-318       68-4083         mg/m3           with the
          (SC1)                                                              without        World Bank
          GT2            na           na             162      80-3492         water             1hr.
          (SC2)                                                             injection)       maximum
                                                                                             allowable
                                                                                                limit
        1. World Bank Pollution Prevention and Abatement Handbook 1998, Thermal Power: Guidelines for New
        Plants. Combustion Turbine Units maximum NOx emissions limit=300mg/Nm3 (146ppm) with water
        injection and 400mg/Nm3 (195ppm) without water injection.
        2. Due to problems associated with the water injection system, SC2 was operated without NOx control
        water injection.
                                                                       3
        3. World Bank 1hr. maximum allowable limit exceeded by 8 mg/m



        There would be no change to the effect of the T2 cooling towers over and above that
        described in 4.2.3 of the 1999 SEIS.

        It is important to note that taking into account the current operating regime at TTPP
        (see section 3.7 above) it is expected that the following changes to the cumulative


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        impact of T1 and T2 will occur until ‘normal’ operating conditions are established once
        T2 is complete:

•       There is a likely, relative increase in localised odour emissions due to the increased
        frequency of turbine firing up required with the intermittent use of the units. It was
        noted during the site visit that the firing up of T2’s SC1 combustion turbine on 11 May
        2000 produced a distinct petrocarbon odour event, coupled with a short lived period
        of smoke release (light brown in colour). The units are fired up using diesel. While
        this odour event was observed to be relatively short-lived i.e. lasting the duration of
        the firing up procedure, it was an acute event. However, it is understood that there
        was a problem with the firing up procedure on that occasion which resulted in a more
        acute episode than normally associated with the procedure. This is being treated as
        a warranty issue to be resolved shortly by the Contractor.

•       There is a relative increase in the quantities of diesel being used under the current
        conditions than would be associated with a continuous operation of a fully functional
        T1 and T2.

        Although not strictly associated with T2, it is of note that there will be a slight air
        quality benefit linked with TTPP (i.e. T1 and T2) due to the change in waste oil sludge
        disposal options. This will be achieved by removing a potential source of pollution.

        Global Considerations – Carbon Dioxide

        As there has been no change to the specific design and method of operation for T2
        and TTPP as a whole it is expected that there will be no change to the nature and
        significance of the conclusions previously drawn for CO2 emissions.



5.5.3 Water Environment

        Site Preparation and Construction Effects

        In terms of water supply and wastewater, there is considered to be no significant
        change to the impacts described in section 4.4.2 of the 1999 SEIS. BVI are
        contractually required to minimise the potential implications of construction activities
        on the surrounding water environment (see section 3.5.5 of the Addendum).

        Operational Effects

        Tables 5.4 to 5.6 list updated mass balances of water for each of the phases for T2.
        These indicate that relative to the details available for the preparation of the 1999
        SEIS (see Tables 4.4 to 4.7 in section 4.4.3 of the 1999 SEIS) there have been some
        minor reductions to the quantities of water demand and water loss for each of the
        phases (under LCO or natural gas use). The commentary on the operational effects
        on water supply issues in the 1999 SEIS are therefore considered to remain valid.
        [T1 sanitary waste treatment and the T1 wastewater and brine disposal are included
        as they are an integral part of the common water supply system].

        It is worthwhile making an additional note concerning the combined water demands of
        T1 and T2. The 1995 EIA quantified the freshwater demands of T1 at around
        1500m3/d. Consideration of the data given in table 5-4 shows that a peak T2
        desalination supply of 382gpm (requiring 1135gpm influent seawater) will eventually
        meet the freshwater requirements of T2. In the event that all four CTG’s are required
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        to operate concurrently for extended periods, the total T1 and T2 plant freshwater
        demand would exceed the freshwater supply by a small margin until the T2
        Desalination plant is operative. Once the T2 desalination plant is operative, plant
        water supply will meet water demand for all modes of plant operation. Temporary
        process modifications and use of reservoir water can allow four-CTG operation in the
        interim, but regularly operating in this modified mode is not desirable from a
        maintenance and financial perspective.




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        Table 5-4:        T2, Simple Cycle 1 – LCO and Natural Gas Fuel (in brackets)
          Description                                     Water Demand          Water Loss
                                                               (gpm)              (gpm)
                                                        Summer     Winter    Summer    Winter
          Water Supply                                    119         159
                                                         (139)       (170)
          Water Injection to Reduce              NOx                            73            103
          Emissions                                                            (88)          (111)
          T1 Sanitary Waste Treatment                                           1.5            1.5
                                                                              (1.5)          (1.5)
          T1 Wastewater                                                         44             54
                                                                               (49)           (57)
          Total Input/Output                                 119     159      118.5          158.5
                                                            (139)   (170)    (138.5)        (169.5)
                 Source: Black and Veatch, Power Division


        Table 5-5:        T2, Simple Cycle 1 + 2 – LCO and Natural Gas Fuel (in brackets)
          Description                                     Water Demand          Water Loss
                                                               (gpm)              (gpm)
                                                        Summer     Winter    Summer    Winter
          Water Supply                                    221         302
                                                         (261)       (323)
          Water Injection to Reduce              NOx                           145            206
          Emissions                                                           (175)          (222)
          T1 Sanitary Waste Treatment                                           1.5            1.5
                                                                              (1.5)          (1.5)
          T1 Wastewater                                                         73             94
                                                                               (83)           (99)
          Total Input/Output                                 221     302      219.5          301.5
                                                            (261)   (323)    (259.5)        (322.5)
                 Source: Black and Veatch, Power Division

        Since the preparation of the 1999 SEIS there has been no significant change to the
        arrangements for wastewater management (in terms of discharge points and
        processing). The minor exception comprises the relocation of the contingency
        oil/water separator for the transformers (see section 3.3.5 above). Otherwise it is
        considered that the assessment of the wastewater issues in section 4.4.3 of the 1999
        SEIS are still applicable. During the May 2000 site visit attention was drawn to the
        current low use of the sewage lagoons which were described by TIC as being
        underused compared to the design specifications [See Photograph Sheet 6,
        Photographs 8 a to 8c].




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        Table 5-6:        T2, Combined Cycle – LCO and Natural Gas Fuel (in brackets)
          Description                                        Water Demand                   Water Loss
                                                                  (gpm)                       (gpm)
                                                          Summer      Winter             Summer     Winter
          Seawater supply                                   8933        8767
                                                          (10106)     (9819)
          Seawater to T2 Desalination              (a)       822        1057
                                                            (952)     (1135)
          Seawater to T2 Cooling Tower             (b)      8112        7709
                                                           (9154)     (8684)
          Evaporation (Cooling Tower)                                                       1352          1285
                                                                                           (1526)        (1447)
          Drift (Cooling Tower)                                                                6             6
                                                                                              (6)           (6)
          Water Injection to Reduce NOx                                                      145           206
          Emissions                                                                         (175)         (222)
          Vent Losses (Steam)                                                                 14            15
                                                                                             (16)          (16)
          T1 Sanitary Waste Treatment                                                         1.5           1.5
                                                                                            (1.5)         (1.5)
          T1 Wastewater and Brine Disposal                                                  7415          7253
                                                                                           (8382)        (8123)
          Total Input/Output                                 8933           8767          8933.5         8766.5
                                                                                         (10106.5)      (9815.5)
                 Source: Black and Veatch, Power Division
                 Note: (a) and (b) – these constitute proportions of the total seawater supply.

        In terms of potential spill and contamination issues the details relating to the oil spill
        contingency plan provided in section 4.4.3 and section 7 (Risk Management) of the
        1999 SEIS remain valid. Further, the Spill Prevention Plan is presently under review,
        while a Spill Risk assessment and Prevention Plan are also under development and
        due for release shortly. It is of note that under the current operations, the
        consumption of LCO is reduced from one delivery a month to one delivery every four
        months which would effectively reduce the frequency of risk for an oil spill to occur
        during LCO offloading.

        Since the preparation of the 1999 SEIS, two mock oil spill exercise have been
        undertaken at the plant, as required in the plant’s EMS. In summary, the purpose of
        the exercise was to test the Oil Spill Response Plan33, which was prepared in
        accordance with the requirements of the National Oil Spill Contingency Plan. A copy
        of the plant’s Oil Spill Response Plan has been included, at the request of OPIC, in
        Appendix F1, Volume 2 of the Addendum34. Copies of the Mock Spill Exercise
        reports have also been included in Appendix F2, Volume 2.35 The conclusions and
        actions from the exercises included:

•       The exercise involved eight organisations and 58 individuals and was considered to
        be a successful test run in terms of the response applied, the collaboration achieved
        between the organisations involved, and the scope of improvements identified.
33
   ERM Northeast Inc, Final Draft Oil Spill Response Plan, Takoradi Thermal Plant, Takoradi, Ghana Final Draft
July 1997.
34
   A copy of the Marine Investigations Survey (Volume 6, TK2 Specification Documents, Mott Ewbank Preece,
March 1996) was provided with the submission of the Second Issue of the Addendum Environmental Report for
T2, in support of the Oil Spill Response Plan at the request of OPIC.
35
   VRA Takoradi Thermal Power Plant, Report on First Mock Spill Exercise, Held on 27 May 1999.

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•       Areas requiring further action included improving the state of preparedness of plant
        personnel, obtaining a boom and skimmer suited to rough seas and other minor
        equipment modifications.

        With regards to any operational impacts on international waterways, it is considered
        that there would be no effect on this issue given that TTPP or its associated fuel
        pipeline do not extend into waters that meet the specific IFC definitions for
        ‘international waterways’. In terms of any polluting effect on an international
        waterway, it was noted in the 1995 EIA that any oil spill from the pipeline would flow
        in an easterly direction (away from the Côte d’Ivoire) along the Ghanaian Coast. The
        formulation of the Oil Spill Response Plan, Prevention Plan and Risk Assessment
        along with other built in features designed to limit equipment failure are expected to
        prevent a major oil spill occurring that could potentially affect international water or
        shipping lanes beyond the site.

5.5.4 Noise

        The Ghanaian and 1998 World Bank noise level criteria are shown below and are
        shown to be comparable for residential areas in particular. The time periods over
        which maximum noise levels are measured are different by one hour. Consequently
        the significance of the results of the 1999 SEIS for the residential areas in particular
        may be seen as comparable with the 1998 World Bank criteria. A comparison of the
        levels is given in Table 5-7, while noise levels measured at the various monitoring
        sites during 2000 are summarised in Table 5.8.
        Table 5-7:        Comparison of Ghanaian and 1998 World Bank Noise Level
                          Criteria.
             Zone           Description of Area of Noise        Permissible Noise Level
                                     Receptor                      Day           Night
          Ghana EPA                                          (06.00-22.00)   (22.00-06.00)
              A      Residential                                   55              48
             B1      Educational                                   55              50
             B2      Light commercial industry                     60              55
          1998 World Bank                                    (07.00-22.00)   (22.00-07.00)
              -      Residential,    institutional     and         55              45
                     educational
              -      Industrial, commercial                        70                  70

        Continuous noise generated by the transformers were in compliance with the 85dBA
        limit, however noise levels at the fuel treatment room and in the vicinity of the gas
        turbines exceeded this limit. To mitigate this adverse impact on worker health,
        appropriate warning signs have been posted and the wearing of ear protective gear
        has been made mandatory in these areas.

        While ambient noise at the eastern fence (nearest to Aboadze) was most of the time
        within limits, levels beyond the 55dBA limit were recorded at the north, south and
        western fences. This was the situation for the 1999 monitoring results, which included
        only T1’s influence, but may have been exacerbated by the two additional gas
        turbines.

        It can be observed from the community noise monitoring results that even though
        noise levels at the fenceline have increased, the Aboadze village has not been
        adversely impacted by noise from the operational activities of the station.


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        Table 5-8 Noise Monitoring Results, T1 and T2 (dB(A)) – Jan 2000 to Dec 2000.
        Month             Plant           Gas         Fuel       Transformers         Community
                        Fenceline       Turbine    Treatment                            Noise
                                         Area        Room
    January                56-78         87-89        88-94           75-78                N/A
    February              58-61          87-88       87-90            72-75                N/A
    March                 31-110         86-90        88-93           76-80                N/A
    April                 41-66         89-118       80-109           76-80                N/A
    May                    47-68        89-102        89-96           73-74                N/A
    June                   50-61         87-90       86-94            75-77               47-53
    July                  48-62          88-91       89-95            77-79               41-47
    August                 49-58         88-91       88-92            78-79               44-53
    September             52-62          88-90       87-89             N/A                44-54
    October               40-72          86-89       87-88             N/A                 N/A
    November               40-72         87-89        86-87            N/A                44-54
    December              44-61           N/A          N/A             N/A                49-62
    EIA Limits              55            85           85              85                 48/55
        N/A: Equipment not in service



        Site Preparation and Construction

        Since the preparation of the 1999 SEIS, the construction of T2's SC1 and SC2 has
        been completed.

        Noise monitoring data presented in section 4.5.4 above indicates that recent noise
        levels at the TTPP fenceline have been in excess of the 55 dB(A). The high noise
        levels at the plant fenceline were largely due to the continuing construction activities
        and start-up, commissioning activities that are primarily associated with the on going
        T2 construction programme. These exceedances are likely to be more important to
        areas adjacent to the eastern and northern fencelines due to the presence of
        residential areas beyond. While there was no recent monitoring data available for
        the stations within Aboadze and the VRA Township or at the receptors used in the
        1999 SEIS, it is likely that with greater distances from the plant fenceline the noise
        level and significance of any exceedances beyond 55 dB(A) will decrease
        accordingly. The exception is likely to remain at the lorry park which was predicted to
        experience noise levels in excess of 55 dB(A) in the 1999 SEIS. A similar condition is
        still expected to occur as predicted and will be due to its proximity to the eastern plant
        fenceline which is currently showing noise levels in excess of 55 dB(A) on a periodic
        basis.

        However, it is important to note that the exact wording of the 1998 World Bank
        guidance on ground level noise states that ‘measurements are to be taken at noise
        receptors located outside the project property boundary.’ This approach was adopted
        for the 1999 SEIS. In the case of TTPP, this extends beyond the plant fenceline and
        includes the VRA township.

        The construction period for the CC phase is estimated to be 24 months (see Figure
        3.5) and was hoped to be tied directly onto the end of SC2, which has proved not to
        be the case. In the 1999 SEIS it was estimated that the construction programme for
        T2 as a whole would last for three years from the time of receipt of the Environmental
        Approval. Under the re-phasing of T2, the construction programme can potentially
        extend beyond 4 years (depending on the actual date of ‘Notice to Proceed’ for the


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        CC Phase). Consequently there will be an extension to the period over which
        construction noise effects will occur and or potentially result in high noise levels,
        relative to the period described in 1999 SEIS.

        It is understood that during steam blowing activities, which were short-lived very noisy
        events, a number of complaints from the local communities were made regarding the
        disturbance caused. Measures are to be ensured in future to provide prior warning of
        steam blowing and other particularly noisy activities to reduce the degree of
        disruption.

        Operational Effects

        Given that there has been no significant change to the plant and or design of T2
        compared to that considered in the 1999 SEIS, it is assumed that under normal
        operating conditions, for a fully functional TTPP (T1+T2), there would be no
        significant adverse change to the noise predictions present in section 4.5.3 of the
        1999 SEIS. In short, the predictions for the selected receptors modelled showed that
        under either simple cycle or combined cycle mode noise levels from TTPP (i.e.
        T1+T2) would be within 1998 World Bank criteria. The cumulative effect associated
        with T2 was considered to be minor to negligible.

        This conclusion is made on the basis that the assumptions developed for the 1999
        EIA on likely noise levels associated with elements of T1 SC1 (which were not
        operational at the time) remain valid. The ongoing noise monitoring programme will
        seek to confirm the results of the 1999 SEIS as well as ensure compliance with
        Ghanaian and 1998 World Bank environmental criteria.




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6       MITIGATION   MEASURES                             AND           LIKELY               NET
        ENVIRONMENTAL EFFECTS

6.1     Introduction


        The following comprises recommendations for additional mitigation measures to be
        incorporated into the remaining construction phase and operational phase of T2 only
        and is based on the findings of this Addendum report.

        In general those mitigation measures described in the 1999 SEIS are considered to
        be valid and relevant (see section 5 of the 1999 SEIS).

        An update on the nature and significance of any residual impacts from the
        construction and operational phases of T2 is also provided.


6.2     Physical Environment


6.2.1 Landscape and Visual Effects

        Beyond continuing with the remaining elements of the existing TTPP landscape
        planting plan (as included in the 1999 SEIS) for those areas affected by T2 activities
        and maintaining the landscape planting, no further mitigation measures specific to T2
        are considered necessary.

        In terms of any changes to the net or residual environmental effects associated with
        T2, it is anticipated that there is no significant change to the comments in section
        5.4.8 of the 1999 SEIS.


6.3     Biological Environment


        No further mitigation measures are recommended over and above those detailed for
        the construction and operational phases in the 1999 SEIS (see sections 5.2.7 and
        5.3.7).

        It is expected that overall there is no significant change to the nature and significance
        of the net or residual environmental effects described in section 5.4.7 of the 1999
        SEIS.


6.4     Human Environment


        In general it is expected that no further mitigation measures are required over and
        above those detailed in sections 5.2 and 5.3 of the 1999 SEIS for social issues,
        traffic, land use and waste management. Exceptions to this includes the following:




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        •        Pest management36 In the absence of detailed information on the spraying of
                                   the substation area to limit vegetation growth, it is
                                   recommended that the following actions are considered
                                   to limit the impact and/or drifting of sprayed chemicals
                                   beyond the target area:

                                        −        Use an environmentally acceptable chemical
                                                 where practical.
                                        −        Avoid spraying the area in windy conditions to
                                                 prevent accidental drift beyond the target area,
                                                 and/or when the wind direction would be
                                                 conducive to non target areas.
                                        −        Appropriate storage, handling and disposal of
                                                 unused chemicals;

        •        Waste management37In order to control the distribution of waste oil sludge
                                   containing high levels of heavy metals from TTPP to
                                   other sites (such as TOR), regular monitoring of the
                                   waste oil sludge is undertaken Monthly samples are
                                   taken from the oily-waste treatment area and analysed
                                   for Vanadium, Lead and Nickel content using on site
                                   facilities .

        Net or residual effects are expected to remain as described for social issues (section
        5.4.2), access and traffic (section 5.4.5), land use and waste management (section
        5.4.6) in the 1999 SEIS.

        With regards to cultural property, involuntary resettlement and child/forced labour, as
        there are no significant effects anticipated during either the construction and
        operations phase, there are no residual/net effects.

        In terms of the use of herbicides there remains the possibility of affecting areas
        beyond the target area however, the significance and extent of this effect should be
        reduced by applying the recommended mitigation measures.


6.5     Environmental Quality of the Area


6.5.1 Air Quality

        In terms of limiting construction related air quality effects during the remaining
        construction phase for T2 CC no further measures to those listed in section 5.2.1 of
        the 1999 SEIS are proposed.

        For operational air quality effects it is recommended that consideration is given to
        providing a similar programme of stack emissions monitoring and ground level air
        quality monitoring as undertaken for T1 for T2. Unlike the scope of the T1 monitoring
        programme, the aim of the T2 programme should be to confirm compliance with 1998
        World Bank pollution prevention and abatement emissions criteria and with Ghanaian
        guidelines.

36
   Although not strictly associated with T2 alone, these measures have been implemented on the basis of
comments made by OPIC and IFC during their site visit to review T2 in May 2000.
37
   As previous note.
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        Further financial provisions will be made by TIC in order to provide for the proper
        operation and maintenance of monitoring equipment that will also be used to monitor
        T2 operations.

        Construction and operations related residual effects would remain as described in
        section 5.4.1 of the 1999 SEIS.

6.5.2 Water Resources

        No further mitigation measures for the remaining construction phase of T2 are
        recommended beyond those issues already highlighted in the 1999 SEIS.

        Monitoring plans in line with the recommendations outlined for the operations phase
        of T2 are already in place for T1 and will inevitably monitor T2 effluent on account of
        T2 sharing these facilities. Bermed areas and other protection areas have also been
        provided for the relevant features of T2’s SC1 and SC2 and are to be incorporated in
        the remaining T2 plant. The monitoring programme will be updated to provide for
        1998 World Bank effluent criteria as well as Ghanaian EPA criteria (focusing on the
        most stringent criteria levels).

        In terms of any residual effects, the significance and nature of any construction or
        operational effects are expected to be as per those described in section 5.4.3 of the
        1999 SEIS.

6.5.3 Noise

        No further mitigation measures are recommended over and above those detailed for
        the construction and operational phases in the 1999 SEIS (see sections 5.2.4 and
        5.3.4), with the exception that it is reiterated that:

•       Measures are taken to pre-warn the surrounding communities of noisy construction
        activities (and where necessary similar activities during operations and maintenance)
        in order to prevent undue concern/disturbance.

•       Noise monitoring is undertaken at the receptors addressed in the 1999 SEIS.

        It is expected that overall there is no significant change to the nature and significance
        of the net or residual environmental effects described in section 5.4.4 of the 1999
        SEIS.




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                                THIS PAGE IS INTENTIONALLY BLANK




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7          HEALTH AND SAFETY MANAGEMENT FOR T2

7.1        Introduction


           IFC have requested that details relating to the management of health and safety
           (H&S) issues for the T2 project are provided as part of the Addendum Report in order
           to indicate compliance with the IFC General Health and Safety Guidelines.

           In summary the IFC General H&S Guidelines outline key topics for which policies and
           procedures should be prepared (where relevant) in order to maintain a safe and
           healthy working environment for all those engaged in a given project. These topics
           include workplace noise and air quality, work in confined spaces, general measures
           for health and safety, provision of drinking water, training, occupational health and
           safety monitoring, records and reporting.

           The following comprises a summary of the current H&S systems that are being
           operated by key parties associated with the construction and operation of T2 and the
           operation of T1.

           The following documents were reviewed for this section:

•          BVI Safety Manual, 1999;

•          T2 Project Progress Reports, No.s 1 to 14 (from 31 December 1998 to 31 March
           2000);

•          BVI T2 Simple Cycle Power Plant Specification and Documents for General
           Construction;

•          CMS International Operating Company, Takoradi 2 Thermal Power Plant (T2) Health
           and Safety Manual, 2000.



7.2        Site Preparation and Construction Phases, T2


7.2.1 BVI Safety Manual

           BVI are committed to operate under a corporate health and safety (H&S) plan which
           outlines a commitment to providing ‘all employees with a safe and healthful work
           environment as free as possible from recognised hazards [and] to maintain and
           actively support a comprehensive employee safety and health program [as well as to]
           continue to improve in incident prevention.38

           The main objectives of BVI H&S are as follows:

•          Protect people (employees and others), property, and the environment from potential
           hazards


38
     Black and Veatch Construction Inc, Safety Manual, 1999.

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•       Provide a uniform policy of safety management consistent with the requirements of
        governmental safety, health and environmental regulations.

•       Establish and maintain an effective safety and health program involving all levels of
        the organisation including managers, supervisors and employees.

•       Co-operate and assist clients, customers and others involved in the work area to
        maintain a safe and healthful workplace.’

        In summary, the BVI Safety Manual includes policy and procedure guidance on the
        following topics, which include those topics listed in the IFC General Health and
        Safety Guidelines:

•       Training – including education and training, safety orientation, supervisor safety
        training, ‘tool-box’ safety meetings, pre-employment procedures, procedures for
        correcting safety and health hazards;

•       Emergency/Medical Injury Management – including injury management, managing
        incidents, duties and responsibilities of employees and supervisors, reporting, crisis
        communication plan, incident investigations, providing medical services, emergency
        procedure flow charts and blood borne pathogen exposure control plan

•       General Safety Procedures – these cover a broad range of topics including
        housekeeping, site sanitation, personal protective equipment, fall protection, hearing
        protection, fire protection and prevention, working with various pieces of equipment

•       Reporting Requirements

•       Environmental Protection – covering the transportation, storage and disposal of
        hazardous materials.

        Other areas covered include Drug and Alcohol Programme, Confined/enclosed
        spaces and entry procedures, Hazard Communication Programme, Industrial hygiene
        and OSHA Inspection Procedures.

        BVI also require that sub-contractors comply with relevant Governmental and client
        regulations and develop H&S policies and procedures that either meet or exceed
        BVI’s system in general, as well as any specific requirements identified by the client
        (in this case TIC).

        A copy of the Table of Contents of the BVI Safety Manual is included in Appendix F3,
        Volume 2 for reference.

7.2.2 Project Progress Reports – Health and Safety Issues

        A review of the progress reports for T2 indicated that in a total of over half a million
        man-hours for SC1 and SC2 (up to the end of March 2000) there was only one lost
        time incident due to a fall, and two incidents involving the loss and/or damage to BVI
        property due to theft. Since the incident one quarter of a million safe man-hours have
        been completed on the construction site (as of end of March 2000).




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7.2.3 BVI Specification and Documents for General Construction

        This document sets out requirements for undertaking specific construction and
        mechanical activities. These include reference to relevant laws and ordinances,
        procedures and processes to be used, inspection, examination and testing
        requirements, checklists and qualification requirements for personnel undertaking
        these activities.

        Within the structure of these construction and mechanical activity specifications,
        health and safety issues are invariably incorporated into the procedures. For
        example under the Start-up and Testing Specifications, equipment checks should
        include confirming the presence of appropriate safety equipment and also refers to
        confirming the establishment of systems to protect personnel and equipment.


7.3     Operational Phase, T2


        The Operations and Maintenance H&S Manual has been prepared by CMS
        International Operating Company (CMSI) and is being set up and implemented on
        site by CMSI personal.

        BVI will also be responsible as part of their existing contract with TIC to provide
        operations and maintenance manuals for engineering, mechanical, electrical and
        other components of the T2 facility. BVI are also required to provide training for T2
        operations supervisors, operations, maintenance and technical personnel in order for
        them to ‘test, operate and maintain the Facility safely and efficiently’.39

7.3.1 CMSI Operations and Maintenance Health and Safety Manual

        The Safety Policy Statement40, states CMSI’s commitment to provide for, protect and
        maintain safe and healthy working conditions for their employees and the residents of
        communities adjacent to their operations. In summary the policy statement states
        that CMSI will seek:

•       ‘To comply with all applicable laws and regulations…[and in particular, will] … strive
        to achieve recognised safety standards that may exceed legal obligations.’

•       ‘To expect commitment from all employees…to create a safe work environment, with
        the goal of freedom from personal injury or occupational illness.’

•       ‘To devote adequate resources to safety and health protection…utilising programmes
        and procedures that will provide ongoing, diligent attention to safety and health
        issues…[and will]…provide necessary training, equipment and controls to assure a
        safe working environment for all employees.’

•       ‘To insist that each employee and all contractors be responsible for performing
        assigned tasks in a safe manner.’



39
   Amended and Restated Agreement between Takoradi International Company and Black and Veatch
International Company for the Construction, Start-up and Testing of the Takoradi 2 Facility in Aboadze, Ghana,
effective as of February 23 1999.
40
   CMS International Operating Company, Safety Policy Statement, April 2000.

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                                      TIC Takoradi Thermal Power Plant, Proposed Expansion


•       ‘Opportunities to continually improve safety performance…[and will]…promptly
        assess any safety and health incidents…[and will]…monitor and assess progress
        toward achieving our safety and health goals through regular audit programmes and
        performance evaluations.’

        The CMSI H&S Manual has been prepared with due reference to CMSI’s parent
        company’s Health and Safety Manual which has in turn been produced in accordance
        with the requirements of the US Occupational Safety and Health Act, 1970. The
        Manual includes policies and procedure guidance on the subjects listed below, such
        that those procedures denoted by SH relate to Safety and Health issues and those
        with SP are defined as Safety Procedures:

•       Safety and Health Training (SH1);

•       Hearing Conservation Programme (SH2), Respiratory Protection (SH3), and First Aid
        and Cardio-Pulmonary Resuscitation (SH4);

•       Hazard Recognition and Self Inspection Procedures (SP5); Hazard Communications
        Programme (SP6); and Confined Space Programme (SP7);

•       Accident Investigation and Reporting (SP8);

•       Plant Safety System and Guidelines (SP9), Safety Procedures in Operations and
        Maintenance (SP10) and Safety for Contractors and Other Contracted Employees
        (SP11);

•       Safety Clearance Procedures (Lockout and Tagout) (SP12A), Safety Clearance
        Administration Document (Lockout and Tagout) (SP12B); and

•       Hotwork Permit Procedures (SP13).

        Specifically, topics referred to in the IFC General Health and Safety Guidelines (as
        listed below) are provided for in the following policies and procedures in the CMSI
        H&S Manual:

•       Workplace air quality and noise – are provided for in SH2 and SH3.

•       Confined space – covered in SP07 which includes reference to identifying and
        evaluating confined spaces, setting up certification process and an access permitting
        system with prevention of access procedures, procedures to be adopted for
        accessing confined space, training and provision for the review of certified confined
        spaces.

•       General Health - generally covered in SH1, SH2, SH3 and SH4.

•       General Safety – covered in SP09 and SP10 which includes a broad range of topics
        such as safe work habits, use of unknown equipment, use of other equipment (such
        as ladders, hoses and welding tools), carrying loads, crossing plant roads and traffic
        standards, personal protection, and other general operations and maintenance
        procedures. SP11 details responsibilities and procedures for contractors.

•       Drinking Water – there are no specific procedures which directly relate to the
        provision of suitable drinking water, however, all plant systems are marked/labelled
        and bottled water is provided to CMSI site employees. Office building tap water is
        provided by T1 which obtains initial potable water stocks from the Ghana Water Co.
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        and then injects chlorine and monitors potable water for contaminants on a regular
        basis.

•       Training – specifically covered in SP01, but also in other procedures as required.

•       Occupational H&S monitoring and records and reporting – there are no specific
        procedures relating to the overall reporting of H&S, however, each manual section
        contains specific reporting forms. The CMSI Plant Manager does report monthly to
        TICO GM regarding any safety issues, including lost time accidents (LTA), safety
        training held, total hours worked without a LTA.

•       Internal/External Audits – CMS does audit all of its plants on a regular basis for all
        aspects of operations and maintenance, including H&S. CMSI/TICO, in co-operation
        with a T1 environmental engineer, send quarterly emission reports to the Ghana EPA.
        Arrangements will be made for any Ghana H&S entity who wish to inspect the site.




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8       ENVIRONMENTAL                 MANAGEMENT                AND        MONITORING
        PROGRAMME, T2

8.1     Provisional EMMP for T2


8.1.1 1999 EMMP

        A provisional Environmental Management and Monitoring Plan (EMMP) was prepared
        for the 1999 SEIS in accordance with the requirements of the Ghanaian EPA. This
        was contained in section 8 of 1999 SEIS and outlined environmental and social work
        programmes to reduce and prevent adverse environmental and social effects as well
        as the financial, staffing and training commitments required to implement the EMMP.
        It was anticipated at the time that the provisional framework would be incorporated
        into an environmental management system that would accommodate both T1 and T2.

        The Environmental Approval for T2 was granted by the EPA on the basis that a series
        of conditions are met, one of which included implementing the provisional EMMP.

8.1.2 Actions to Date

        As yet, the 1999 provisional EMMP has not been formally finalised or submitted to the
        EPA as required under the terms of the Environmental Approval. This does not
        represent a non-compliance with Ghanaian legislation as there is a window of 18
        months from date of operations commencing (i.e. March 2000 for T2’s SC1) before a
        formal EMMP is submitted to the EPA.

        Since the preparation of the 1999 provisional EMMP, various elements of the plan
        have either been addressed (either independently or as part of the T1 Environmental
        Management Plan) and/or are pending further attention. Actions taken to date and
        additional comments received in consultation with the T1 Environmental Officer and
        Deputy Project Director for T2 have been listed in Table 8.1 which repeats the 1999
        Provisional EMMP with the addition of these update comments.

        T1’s Environmental Staff are currently undertaking some of the monitoring
        programmes for T2 under an informal basis. This is due to be formalised such that
        TIC will draw up an appropriate arrangement with T1 to share staffing costs and other
        associated costs (e.g. equipment maintenance) as and when required. The need for
        employing additional, appropriately qualified staff for T2 EMMP activities will also be
        reviewed on a regular basis. A budget of $100,000 has been allocated to the CC
        stage of T2 for the proper operation and maintenance of monitoring equipment and
        for provision of training: this will be reviewed as the project continues.

        The T2 operator, CMSI has Instrumentation and Controls personnel (including
        expatriate staff) who are fully trained to maintain the CEM equipment and also to
        collect emissions data.

        TIC has also purchased spare parts for two years operation of the CEM systems at a
        total cost of approximately US$14,300.00.

        VRA (T1) will be issuing a purchase order for spare parts and personnel to refurbish
        the ambient monitors as well as procurement of a new meteorological station. The
        total estimated cost is 355,901 South African Rands (approx US$52,000).

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8.2     T1 EMMP

        It is generally anticipated that the existing T1 EMMP (which was prepared with
        reference to the results of the 1995 EIA) will be expanded to accommodate T2 and/or
        provide the framework for a separate programme if deemed necessary. This update
        will reflect the results of the 1999 SEIS, the Addendum and current environmental
        criteria and standards.

        In summary the T1 EMMP was originally developed to ensure compliance with the
        conditions of the environmental permit issued by the EPA for T1, which in turn
        required that the commitments of the 1995 EIA were accommodated in the EMMP41.
        It forms section 7 of the T1 Environmental Management System (see below). The
        EMMP provides for the following:

•       Staffing organisation and training;

•       Monitoring procedures (for releases to air, water, noise, ambient air and general site
        management);

•       Relevant environmental control standards;

•       Record keeping;

•       Reporting and Auditing; and

•       Forms for use in monitoring, site management, external complaints and non
        compliance notice.

        Tables of Contents for the T1 EMS Manual, selected sections contents lists and the
        environmental aspects addressed by the T1 EMS Manual have been reproduced in
        Appendix F4, Volume 2. The T1 EMMP has been included as Appendix F5, Volume
        2.


8.3     T1 Environmental Management System


        ESB International has developed an Environmental Management System for T1
        which has been prepared in accordance with ISO 14001. At this stage it has not
        been confirmed as to whether the T1 EMS will be expanded to accommodate T2
        operations or a separate EMS will be developed for T2, using a similar format to the
        T1 EMS. A brief summary of the content of the T1 EMS is provided below, for
        reference and as an indication of the likely content of the T2 EMS should a separate
        system be adopted:

•       The T1 EMS is divided into seven sections which cover the policy manual,
        environmental aspects, register of legislation and licenses, environmental
        programme, environmental procedures, internal audit manual and environmental
        monitoring manual for operational phase.


41
  The T1 EMS provides for the regular updating of the environmental quality criteria which form the basis for
defining plant operations compliance as assessed through the Environmental Management and Monitoring
Manual.
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•       A summary list of current environmental objectives, targets and programme schedule
        for T1 is provided in Section 4. The scope of targets and objectives include, for
        example, air emissions and ground level air quality monitoring, introducing waste
        disposal plans and developing an Oil Spill Contingency Plan.

•       The Environmental Procedures section includes procedures on evaluating
        compliance with relevant environmental legislation, the role of the environmental
        management group, environmental awareness and training, dealing with
        environmental queries/complaints, minimising environmental impacts during
        operations and maintenance, corrective actions for incidents, record keeping and
        reviewing the EMS.

•       The environmental management and monitoring manual has been summarised in
        section 8.2 above.




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TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN (EMP)

EMP Issue              Description of Action                   Individual (s)    Standards       Timing of          Responsible   Comments and Actions to Date         Financial
                                                               Responsible       and Guideline   Action             Authority/    (March 2001)                         Commitment
                                                               for Action        Documents                          Agency
1. GENERIC             Mitigation Measures and Monitoring
RESPONSIBILITIES
AND ROLES              1.   Setting up the EMP. Define         TIC to appoint    TIC Policy      Prior to           TIC           The same Environmental               Budget for
                            job descriptions for and appoint   to criteria set                   commencement                     Management Group (EMG)               salaries and
                            staff to positions of :            by Contract                       of site                          currently implementing the T1        overheads and
                       a) Environmental Manager (EM)                                             preparation/                     EMMP and Environmental               support staff
                       b) Assistant to Environmental                                             construction                     Management System (EMS) are          $30,000
                            Manager (AEM)                                                        phase                            monitoring the environmental
                       Note: EM for T1 will be able to                                                                            issues associated with the
                       cover T2. AEM to be an                                                                                     operation of T2 (SC1).
                       instrument technician for                                                                                  Operation and maintenance of the
                       maintenance of                                                                                             T2 (SC1) CEM system is,
                       lab/environmental monitoring                                                                               however, handled by CMSI
                       equipment.                                                                                                 personnel (i.e. instrument
                                                                                                                                  technicians).
                       2. TIC Environmental Policy.            Contractor and    CMS             Prior to           TIC           As yet no action has been taken      Budget for
                       Draft and agree environmental           EM with liaison   Environmental   commencement                     on this issue. VRA’s and/or CMS’s    policy included
                       policy                                  with TIC          policy/VRA      of site                          policy statements provide interim    in above
                                                                                 Environmental   preparation/                     coverage, along with the policy
                                                                                 Policy          construction                     statement prepared for the EMS
                                                                                                 phase                            system developed for T1 by ESB
                                                                                                                                  International in 1997.
                       3. Complete EMP.                        TIC               EIS/EMP         For submission     TIC           No action has been taken on this     Budget for
                       Modify and expand on provisional                                          at                               issue as yet, however this remains   EMP
                       EMP provided in contract                                                  commencement                     compliant with Ghanaian              completion
                       documents                                                                 of operation                     requirements.                        $1,000
                                                                                                 phase




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TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN (EMP)

EMP Issue              Description of Action                 Individual (s)    Standards        Timing of             Responsible   Comments and Actions to Date            Financial
                                                             Responsible       and Guideline    Action                Authority/    (March 2001)                            Commitment
                                                             for Action        Documents                              Agency
1. GENERIC             4. Annual Environmental Report        EM with           EPA EIA          During                EPA           Annual Environmental Reports are        Budget
RESPONSIBILITIES       (AER). Develop report structure for   assistance        guidelines       site preparation/                   already produced for reporting the      included in 1
AND ROLES              AER which links environmental         from                               construction                        environmental monitoring results        above
                       team into operational and             contractor or     VRA AER,         phase, prior to                     for T1. As the monitoring
                       administrative activities, and        consultants, as   Jan-Dec 1998     end of year one,                    programme will be expanded to
                       produce report for submission to      necessary                          eg end of 1999,                     incorporate the operational effects
                       EPA                                                                      to link with T1                     of T2 (which, save for direct air
                                                                                                activities                          emissions monitoring and plant
                                                                                                                                    noise levels, are not strictly easily
                                                                                                                                    distinguishable from T1) the AER
                                                                                                                                    has been expanded accordingly.
                                                                                                                                    It incorporates a commentary on
                                                                                                                                    the overall effect of TTPP (i.e. T1
                                                                                                                                    + T2) as well as on individual T1
                                                                                                                                    and T2 contributions.
                       5. Environmental technical            EM supported      International    During                TIC           Training has been undertaken by         Budget
                       training. Technical training for      by contractor     standards in     site preparation/                   the T1 and T2 EMG and is                included in 1
                       environmental staff (AEM and          and/or            environmental    construction                        ongoing as required. The training       above
                       others) on inter alia;                consultants as    management       phase                               on the use of equipment etc.
                       1. use of monitoring equipment        necessary         and monitoring                                       already undertaken for T1 will be
                       2. data collation                                       methods such                                         equally applicable to T2.
                       3. data interpretation and                              as world bank
                            reporting                                          guidelines
                       4. maintenance of equipment
                       6. Awareness training. Provide        EM                EIA/EMP          During                TIC           This process is ongoing for T1          Budget
                       environmental awareness training                                         site preparation/                   (and will be expanded for T2), but      included in 1
                       for all management staff and site                                        construction                        has not been formalised as per          above
                       staff teams in the implementation                                        phase                               the Environmental Procedure
                       aspects of the EMP                                                                                           EP003 in section 5 of the T1 EMS
                                                                                                                                    Manual. Now being incorporated
                                                                                                                                    into the plant weekly safety
                                                                                                                                    meetings.




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TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN (EMP)

EMP Issue              Description of Action                   Individual (s)   Standards       Timing of          Responsible   Comments and Actions to Date        Financial
                                                               Responsible      and Guideline   Action             Authority/    (March 2001)                        Commitment
                                                               for Action       Documents                          Agency
1. GENERIC             7. Documentation                        EM               EIA/EMP/        At                 TIC              Copies of the 1999 SEIS         Budget
RESPONSIBILITIES       Ensure environmental manager and                         contractors     commencement                         have been distributed to the    included in 1
AND ROLES              EPC contractor have copies of EIA,                       i.e. EPC        of site                              relevant parties accordingly.   above
                       EMP, site plans, contractual                             contract        preparation work                    Construction phase mitigation
                       documents and the EMP is copied                                                                               measures were incorporated
                       to site office and site manager(s)                                                                            into the EPC Agreement
                                                                                                                                     (although these are from the
                                                                                                                                     1995 EIA as the 1999 SEIS
                                                                                                                                     had not been prepared at the
                                                                                                                                     time of formulating the EPC
                                                                                                                                     Agreement).
                       8. Record site conditions prior to      EM               EIA/EMP         Prior to           TIC              The 1999 SEIS was used as       Budget
                       any construction work. Take                                              commencement                         the basis for providing a       included in 1
                       photographic records of site prior to                                    of site                              record of the baseline          above
                       site preparation work and notes                                          preparation work                     conditions prior to
                                                                                                                                     construction work
                                                                                                                                     commencing.
                                                                                                                                    No other recording of site
                                                                                                                                     conditions was identified.
                       9. Prepare site plans and               EM and           EIA/EMP         At start of        EM, TIC          The landscape planting plan     Budget within
                       restoration plans                       Contractor       EPC             site preparation/                    included in the 1999 SEIS       construction
                       Ensure site plans available which                        Contractor      construction and                     has been used on site and is    budget
                       show environmental                                                       during all phases.                   largely completed save for
                       sites/issues/risks and                                                                                        the planting to be provided
                       restoration/landscape plan                                                                                    after construction of T2 has
                       produced                                                                                                      been completed.
                                                                                                                                    Plans have been prepared
                                                                                                                                     showing hazardous areas.
                                                                                                                                    A commentary of potentially
                                                                                                                                     sensitive areas has been
                                                                                                                                     incorporated into the EPC
                                                                                                                                     Agreement.
                                                                                                                                 The various EIAs undertaken for
                                                                                                                                 T1 and T2 provide details of
                                                                                                                                 environmental constraints.




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TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN (EMP)


EMP Issue              Description of Action               Individual (s)   Standards         Timing of          Responsible   Comments and Actions to Date         Financial
                                                           Responsible      and Guideline     Action             Authority/    (March 2001)                         Commitment
                                                           for Action       Documents                            Agency
1. GENERIC             10. Public and Authority/Agency     EM               EIA/EMP           Prior to and       TIC              As part of an ongoing            Budget
RESPONSIBILITIES       Liaison. Set up liaison meetings                                       during each                          programme for T1 (which will     included in 1
AND ROLES              with community and                                   Previous          phase, meetings                      incorporate T2), meetings are    above
                       authorities/EPA. These will cover                    procedures for    will be arranged                     held with the local Assembly
                       construction and operational                         T1 will be used   with EPA and                         as and when required by
                       management of environmental                          as a guide or     others as                            either the Assembly or by
                       issues and emergency response                        be considered     required                             VRA. An open door policy is
                       preparedness, response plans and                     suitable                                               maintained by VRA and the
                       communication                                                                                               Assembly.
                                                                                                                                  Regular contact is maintained
                                                                                                                                   with the EPA through the
                                                                                                                                   submission of quarterly and
                                                                                                                                   annual environmental
                                                                                                                                   monitoring reports. The EPA
                                                                                                                                   are also being regularly
                                                                                                                                   updated on the status of the
                                                                                                                                   monitoring equipment and
                                                                                                                                   have been invited to
                                                                                                                                   undertake independent
                                                                                                                                   monitoring as they see fit,
                                                                                                                                   and comment on alternative
                                                                                                                                   waste oil disposal options and
                                                                                                                                   so on.
                                                                                                                                  Inputs on additional aspects
                                                                                                                                   of the TTPP project as a
                                                                                                                                   whole include seeking advice
                                                                                                                                   on the siting of the community
                                                                                                                                   improvement programme
                                                                                                                                   schools and biolatrines.




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TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN (EMP)

EMP Issue              Description of Action                  Individual (s)    Standards         Timing of             Responsible   Comments and Actions to Date         Financial
                                                              Responsible       and Guideline     Action                Authority/    (March 2001)                         Commitment
                                                              for Action        Documents                               Agency
1. GENERIC             11. Development of an                  EM and AEM,       EIA/EMP           Prior to and          TIC           The existing EMS will be formally    Budget
RESPONSIBILITIES       Environmental Management               technical staff   EMS for           during early                        updated and expanded                 included in 1
AND ROLES              System (EMS) to implement the                            contractors on    stages of                           accordingly. In the meantime and     above
                       EMP on a day to day basis                                T1 will be used   site preparation/                   given the integrated nature of T1
                       throughout the organisation.                             as a guide        construction                        and T2, the principles of the
                       Develop simple operational                                                 phase                               existing EMS and the resources of
                       procedures/guidance for staff                                                                                  the EMG are already being
                       undertaking or responsible for key                                                                             applied and used for T2.
                       tasks related to implementation of
                       EMP.

                       12. Audit Review Programme. Set        EM and AEM        EIA/EMP           At least annually     TIC              No external audits for T1 (and   Budget
                       up an audit and review programme                                           from the start of                       T2) have been commissioned       included in 1
                       covering all activities to assess                        EMP for T1        construction                            as yet.                          above
                       compliance with contract                                                   phase and                              Internal audits for T1 have
                       requirements and ensure meeting                                            through the                             been undertaken in
                       requirements of EMP, EPA and                                               operation phase                         accordance with Section 6
                       other stakeholders including the                                                                                   ‘Internal Audit Manual’ of the
                       general public. The programme                                                                                      T1 EMS Manual.
                       may include two types of
                       component:

                       1.   internal review – undertaken by
                            TIC staff reporting internally;
                            and /or
                       2.   external audit – undertaken by
                            independent consultants
                            reporting to TIC.




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TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                  Individual (s)   Standards       Timing of             Responsible   Comments and Actions to Date          Financial
                                                              Responsible      and Guideline   Action                Authority/    (March 2001)                          Commitment
                                                              for Action       Documents                             Agency
2. AIR QUALITY         Mitigation Measures

                       1. Ensure measures taken to control    Environmental    EIA/EMP         At                    EPA           Requirements were included in         Budget within
                       dust emissions                         Manager with                     commencement                        the EPC Agreement.                    construction
                                                              TIC and                          of site                                                                   budget
                                                              Contractor                       preparation
                                                                                               phase to
                                                                                               operation phase

                       2. Ensure measures taken to install    Environmental    EIA/EMP         Prior to              EPA           Completed. This primarily             Budget of
                       and efficiently operate NOx control    Manager with                     commencement                        consisted of water injection to       $1,500,000
                       equipment                              TIC and          World bank      of                                  reduce NOx emissions.                 made
                                                              Contractor       guidelines      site preparation/                                                         available for
                                                                                               construction                                                              NOx control
                                                                                               phase                                                                     equipment
                                                                                                                                                                         within EPC
                                                                                                                                                                         contract

                       3. Ensure stack height is adequate     Environmental    EIA/EMP         Prior to              EPA              Work has been undertaken to       Budget of
                       for dispersion of emissions from       Manager with                     purchase of                             confirm stack heights are         $2,000,000
                       turbines determined from air quality   TIC and          Ghanaian Air    equipment                               sufficient for pollution          made
                       modelling                              Contractor       quality                                                 dispersal.                        available for
                                                                               guidelines                                             T1 stacks were increased to       stack of 40m
                                                                                                                                       40m to facilitate better
                                                                               WHO Air                                                 dispersion.
                                                                               quality                                                T2 simple cycle have
                                                                               guidelines                                              temporary stacks which will
                                                                                                                                       be tied into the HRSG’s
                                                                                                                                       during the CC Phase.
                                                                                                                                      Should the CC Phase not go
                                                                                                                                       ahead then monitoring may
                                                                                                                                       be undertaken to confirm
                                                                                                                                       need for replacing the
                                                                                                                                       temporary 10m stacks
                                                                                                                                       currently being used foT2.




Addendum Environmental Report                                                       8-10                                                                            J98404B
JacobsGIBB Limited                                                                                                                                 Issue 3.0 / November 2001
                                                                                                                  TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                 Individual (s)   Standards       Timing of             Responsible   Comments and Actions to Date         Financial
                                                             Responsible      and Guideline   Action                Authority/    (March 2001)                         Commitment
                                                             for Action       Documents                             Agency
2. AIR QUALITY         4. Ensure sufficient emission         Environmental    EIA/EMP         Prior to              EPA           Regular servicing is undertaken.     Budget within
                       controls and adequate maintenance     Manager with                     commencement                                                             construction
                       of plant vehicles                     TIC and                          of                                                                       budget
                                                             Contractor                       site preparation
                                                                                              phase, and
                                                                                              ongoing during
                                                                                              construction

                       Monitoring

                       1. Design monitoring programme.       EM               EIA/EMP         During                TIC with         See T1 EMMP -This will be        Budget
                       Set up monitoring sites for ambient                                    site preparation/     overall           updated to incorporate T2        already spent
                       monitoring and boundary/off site                                       construction          agreement         considerations as well as        during T1
                       monitoring tests and meteorological                                    work                  with EPA          include the appropriate          development.
                       data collection for parameters:                                                                                updated emissions criteria for   T2 uses same
                       PM10, NOx and SO2. Review will be                                                                              T2; 1998 Guidelines. T1          monitoring
                       based on modelling results for T2.                                                                             EMMP refers to 1988 World        arrangement
                                                                                                                                      Bank criteria (with              as for T1
                                                                                                                                      modifications).                  phase.
                                                                                                                                     Ambient SOx, and NOx are
                                                                                                                                      continuously monitored at
                                                                                                                                      western plant boundary, at
                                                                                                                                      Aboadze and at Beposo.
                                                                                                                                      Ambient 24hr averages of
                                                                                                                                      PM10 are monitored weekly
                                                                                                                                      using hi-volume sampling at
                                                                                                                                      the VRA Township and at
                                                                                                                                      Aboadze.




Addendum Environmental Report                                                     8-11                                                                            J98404B
JacobsGIBB Limited                                                                                                                               Issue 3.0 / November 2001
                                                                                                        TIC Takoradi Thermal Power Plant, Proposed Expansion

                       2. Purchase and install air          EM/ EPC      EIA/EMP    During                TIC with         Completed for T2 SC1.           CEMS
                       emissions monitoring equipment for   Contractor              site preparation/     overall          Completed for T2 SC2.           equipment to
                       T2.                                                          construction          agreement        At this stage, continuous       monitor air
                                                                                    work                  with EPA          emissions monitoring is         emissions for
                                                                                                                            undertaken at T2 for NOx.       T2 =
                                                                                                                            The S content of the LCO will   $800,000
                                                                                                                            be maintained less than 0.2%
                                                                                                                            by weight. Further, PM10
                                                                                                                            emissions are low for this
                                                                                                                            technology and fuel type,
                                                                                                                            ensuring SO2 and PM stack
                                                                                                                            emissions will be within
                                                                                                                            specified criteria.




Addendum Environmental Report                                                8-12                                                                      J98404B
JacobsGIBB Limited                                                                                                                    Issue 3.0 / November 2001
                                                                                                                   TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                  Individual (s)   Standards       Timing of             Responsible   Comments and Actions to Date          Financial
                                                              Responsible      and Guideline   Action                Authority/    (March 2001)                          Commitment
                                                              for Action       Documents                             Agency
2. AIR QUALITY         3. Develop air quality monitoring      EM               EIA/EMP         During                TIC with      See T1 EMMP.                          Budget of
                       procedures to include appropriate                                       site preparation/     overall                                             $5,000
                       calibration and maintenance                                             construction          agreement
                                                                                               work                  with EPA
                       4. Undertake staff training            EM/TIC           EIA/EMP,        During                TIC with      Undertaken as part of T1.             Budget of
                                                                               international   site preparation/     overall       Although a programme for              $31,000
                                                                               standards for   construction          agreement     ongoing training has not be           already spent
                                                                               environmental   work                  with EPA      formalised, this will be undertaken   on T1
                                                                               management                                          as and when identified. See
                                                                                                                                   Appendix F6, Volume 2 for details     T2 budget
                                                                                                                                   of training on procedures for use.    within
                                                                                                                                                                         construction
                                                                                                                                                                         budget
                       5. Undertake air quality monitoring    EM and AEM       EIA/EMP         During                TIC with      NOx, SOx, CO and CO2 are              Staff time in
                       at sources and boundary and off                                         site preparation/     overall       continuously monitored for T1.        construction
                       site where appropriate, in                              World bank      construction,         approval by   NOx, is continuously monitored for    budget.
                       accordance with methods and                             guidelines      commissioning         EPA           T2. The T1 EMMP will be revised       Budget will be
                       procedures                                                              and operation                       to include annual stack testing of    made
                                                                                                                                   PM10 for T1, and of PM10 and          available to
                                                                                                                                   SOx for T2.                           allow for stack
                                                                                                                                                                         testing.
                       6. Tabulate emission and air quality   EM and AEM       EIA/EMP         During                TIC with      Undertaken as part of T1 and T2       Budget
                       data and interpret ready for                            Ghanaian EPA    site preparation/     overall       (SC1&SC2). Fuel Sulphur content       included in
                       inclusion in AER                                        and IFC Air     construction,         approval by   tested by supplier and checked        construction
                                                                               quality         commissioning         EPA           against <0.2% limit with each         budget
                                                                               guidelines      and operation                       receipt of fuel.




Addendum Environmental Report                                                      8-13                                                                             J98404B
JacobsGIBB Limited                                                                                                                                 Issue 3.0 / November 2001
                                                                                                                    TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                   Individual (s)   Standards       Timing of             Responsible     Comments and Actions to Date        Financial
                                                               Responsible      and Guideline   Action                Authority/Age   (March 2001)                        Commitment
                                                               for Action       Documents                             ncy
2. AIR QUALITY         7. Provide commitment to                EM and AEM       EIA/EMP         During                TIC with        Problems currently with the         Budget of
                       preventative maintenance of                                              site preparation/     overall         monitoring equipment                $10,000
                       monitoring equipment ( 3 monthly                                         construction,         approval by     (breakdowns and obtaining
                       intervals) and consider holding                                          commissioning         EPA             replacement/spare parts). Actions
                       spare parts and good                                                     and operation                         are being taken to improve the
                       communication with service                                                                                     situation. Some spares already
                       engineers to avoid down time                                                                                   bought and used.

                                                                                                                                      T2 budget for maintenance of
                                                                                                                                      equipment and a stock of spares
                                                                                                                                      for 2 years' operation of CEMs.
                                                                                                                                      Recent equipment training and
                                                                                                                                      rehabilitation using T2 budget
3. SOCIO-              Mitigation Measures
ECONOMIC AND
PUBLIC HEALTH          1. Public Health. Ensure air            Environmental    EIA/EMP         At                    EPA             See Above.                          Budget
ISSUES                 quality mitigation measures are         Manager with                     commencement                                                              covered under
                       adequately controlled, in particular,   TIC and                          of site                                                                   provisions for
                       control of dust and efficiency of NOx   Contractor                       preparation/                                                              air quality
                       control, so that Ghanaian air quality                                    construction
                       guidelines are not exceeded.                                             phase to end
                                                                                                operation phase




Addendum Environmental Report                                                       8-14                                                                             J98404B
JacobsGIBB Limited                                                                                                                                  Issue 3.0 / November 2001
                                                                                                               TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                Individual (s)   Standards       Timing of           Responsible   Comments and Actions to Date          Financial
                                                            Responsible      and Guideline   Action              Authority/    (March 2001)                          Commitment
                                                            for Action       Documents                           Agency
3. SOCIO-              Mitigation
ECONOMIC AND
PUBLIC HEALTH          2. Socio-economics                   Environmental    EIA/EMP         Ongoing             EPA           Given integrated nature of T1 and     Budget of $7.6
ISSUES                                                      Manager with                                                       T2, this will automatically be        million in T1
                        1. Maintain the Community Impact    VRA/ and                                                           maintained under T2.                  construction
                       Agreement set up under T1            Contractor
                        2. Measures to reduce risks of      Environmental    EIA/EMP         At                  EPA           The police have placed speed          Budget in T1
                       accidents on improved roads. For     Manager with                     commencement                      restriction signs along the           construction
                       example by raising risk awareness.   TIC and                          of site             Ghana         improved Aboadze-Inchaban road        and operations
                                                            Contractor                       preparation/        Highways      and periodically monitor              and
                                                                                             construction        Authority     compliance. Appointed drivers         maintenance
                                                                                             phase to end of                   have been provided with               budget
                                                                                             operation phase                   appropriate driver safety training,
                                                                                                                               The junction of the road between
                                                                                                                               the T1 and T2 Site Offices and the
                                                                                                                               main Inchaban-Aboadze road has
                                                                                                                               been improved.
                       3. Raise the awareness of the risk   Environmental                    At                  Western       This is not strictly undertaken by    Budget in T1
                       posed by HIV /AIDS with respect to   Manager with                     commencement        Regional      VRA/TIC as it is considered to be     and T2
                       prostitution. Education programmes   TIC                              of site             Authority     covered under the National            construction
                       to inform workers of the possible                                     preparation/                      HIV/AIDS awareness programme.         budgets
                       consequences of their actions.                                        construction
                                                                                             phase.




Addendum Environmental Report                                                    8-15                                                                          J98404B
JacobsGIBB Limited                                                                                                                            Issue 3.0 / November 2001
                                                                                                                  TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                Individual (s)   Standards        Timing of             Responsible        Comments and Actions to Date       Financial
                                                            Responsible      and Guideline    Action                Authority/         (March 2001)                       Commitment
                                                            for Action       Documents                              Agency
3. SOCIO-              Monitoring
ECONOMIC AND
PUBLIC HEALTH          1. Public health.                    EM               EIA/EMP          During                TIC with overall    See Above.                        Budget
ISSUES                 1. Ensure air quality monitoring                                       site preparation/     agreement with      Measures are being undertaken     covered by air
                       programme is operating efficiently                    EPA              construction          EPA                 to improve monitoring             quality
                       and results are within EPA                            guidelines for   work,                                     equipment’s performance.          mitigation
                       guidelines.                                           ambient air      commissioning
                                                                             quality          and operation

                                                                             WHO
                                                                             guidelines for
                                                                             protection of
                                                                             human health




Addendum Environmental Report                                                     8-16                                                                               J98404B
JacobsGIBB Limited                                                                                                                                  Issue 3.0 / November 2001
                                                                                                                      TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                     Individual (s)   Standards       Timing of             Responsible        Comments and Actions to              Financial
                                                                 Responsible      and Guideline   Action                Authority/         Date (March 2001)                    Commitment
                                                                 for Action       Documents                             Agency
3. SOCIO-               2. Socio-economics                       EM               EIA/EMP         During                TIC with overall   As above, an open door policy is     Budget with T1
ECONOMIC AND                                                                                      site preparation/     agreement with     maintained so the community’s        construction
PUBLIC HEALTH          1. VRA to continue with current                                            construction          EPA                assembly may raise any               and operations
ISSUES                 monitoring with additional                                                 work,                                    concerns, make requests etc as       and
                       monitoring to ensure the mitigation                                        commissioning                            and when the issues arise.           maintenance
                       measures in place for T1 are                                               and operation                                                                 budgets
                       sufficient to cope with the demands                                                                                 Special meetings can be
                       of T2. This will comprise reviewing                                                                                 arranged periodically to assess
                       available local social statistics and                                                                               the impacts of the project (T1
                       assessing feedback from the                                                                                         and T2). This is ongoing
                       community meetings; the objective
                       being to ensure no decline in living
                       standards is occurring due to TTPP
                       (T1+T2).
                       2. Monitor local traffic accident and     EM               EIA/EMP         During                TIC with overall       Road traffic accidents on       Budget with T1
                       health statistics for change in traffic                                    site preparation/     agreement with          the immediate road network      construction
                       related accidents. Monitor                                                 construction          EPA                     are not currently monitored     and operations
                       attendance and success of                                                  work,                                         in relation to T1 or T2.        and
                       awareness raising measures with                                            commissioning                                 Accidents for T2 are            maintenance
                       public consultation.                                                       and operation                                 recorded in terms of            budgets
                                                                                                                                                disruption to construction
                                                                                                                                                phase only.
                                                                                                                                           Transport section of VRA
                                                                                                                                           regularly meet with appointed
                                                                                                                                           drivers to instruct on defensive
                                                                                                                                           driving techniques.
                       3. Monitor the landuse in the area        EM               EIA/EMP         During                TIC with overall   BVI use designated areas only.       Budget from
                       immediately surrounding the site.                                          site preparation/     agreement with     These comprise areas                 T1
                       Check that farmland is not damaged                                         construction          EPA                previously used for T1.
                       or encroached on by construction                                           work,                                    A small food market (non
                       related activities and that squatter                                       commissioning                            residential) was sited adjacent to
                       camps are not established.                                                 and operation                            the BVI complex and was
                                                                                                                                           removed once T2 Ph IIa
                                                                                                                                           construction stage was
                                                                                                                                           completed.




Addendum Environmental Report                                                         8-17                                                                                J98404B
JacobsGIBB Limited                                                                                                                                       Issue 3.0 / November 2001
                                                                                                                   TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                   Individual (s)   Standards       Timing of            Responsible   Comments and Actions to Date          Financial
                                                               Responsible      and Guideline   Action               Authority/    (March 2001)                          Commitment
                                                               for Action       Documents                            Agency
4. WATER AND           Mitigation Measures
WASTEWATER
ISSUES                 1.Water supply. Potable water for       Environmental    EIA/EMP         Construction of      EPA           With commissioning of the             Budget of
                       Phase 1 of the plant will be supplied   Manager with                     desalination                       dedicated water supply line from      $4,000,000 for
                       by GWSC. A desalination plant to        TIC and                          plant will be at                   the GWC Treatment Plant at            desalination
                       produce NOx injection water and         Contractor                       commencement                       Inchaban to the Plant, the            plant
                       also potable supply for T2 will be                                       of construction                    extraction of water from the          equipment and
                       provided. This will minimise effects                                     Phase 2.                           pipeline serving the local            installation for
                       on local water supply. Water supply                                                                         communities has ceased.               Phase I of T2
                       for plant site T1 and T2 will not
                                                  3
                       utilise more than 378.5m per day
                       from existing water supply pipeline
                       to local communities.
                       2. Waste water treatment                Environmental    EIA/EMP         Prior to             EPA              Discharge from final sewage       Budget of
                       facilities. Wastewater treatment        Manager with                     commencement                           lagoon will be monitored prior    $5,555,615
                       facilities to treat the domestic        TIC and                          of construction                        to release. The discharge will    made
                       effluents from the plant. These         Contractor                       phase and then                         be recycled if deemed to be       available for
                       include the sewage lagoons already                                       ongoing.                               unsuitable for discharge.         installation of
                       installed for T1, which are suitable                                                                           The three stage sewage            T1 facilities
                       for combined operation of T1 and                                                                                lagoons are currently under-
                       T2. Effluents are discharged to                                                                                 utilised due to lower inputs      Maintenance
                       local surface waters (Anankwari                                                                                 than previously calculated for.   will be
                       River feeder stream) initially, and                                                                             Therefore the production of       provided by
                       then into the ocean upon completion                                                                             sewage sludge has been            T-1
                       of the seawater discharge pipeline                                                                              reduced.                          Operations
                       to be installed under contract T1                                                                              The discharge pipeline from
                       (estimated completion mid 1999).                                                                                the sewage lagoons (treated
                       Prior to operation of the oxidation                                                                             sewer line) has now been re-
                       ponds, septic tanks have been                                                                                   routed to the common
                       installed.                                                                                                      discharge sump.




Addendum Environmental Report                                                       8-18                                                                           J98404B
JacobsGIBB Limited                                                                                                                                Issue 3.0 / November 2001
                                                                                                                  TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                    Individual (s)   Standards       Timing of          Responsible   Comments and Actions to Date         Financial
                                                                Responsible      and Guideline   Action             Authority/    (March 2001)                         Commitment
                                                                for Action       Documents                          Agency
4. WATER AND           3. Stormwater site drainage. This        Environmental    EIA/EMP         Prior to           EPA           Storm drainage system is             Budget for
WASTEWATER             is collected by the drainage channel     Manager with                     commencement                     monitored regularly during the wet   maintenance
ISSUES                 at the site boundary. This drainage      TIC and                          of site                          season in particular. All through    in T1
                       water is released to the marsh land      Contractor                       preparation and                  the year
                       to the west of the site. Drains will                                      during
                       be maintained and cleared of silt                                         construction and
                       and other obstructions as                                                 operation.
                       appropriate. If a spillage occurs,
                       waters are not released to
                       marshland and are held within
                       drainage channel for treatment until
                       cleaned.

                       4. Wastewaters from the plant            Environmental    EIA/EMP         Ongoing during     EPA           See above:                           Budget
                       effluents. These include the water       Manager with                     commissioning                    Water from desalination plant,
                       from desalination, cooling towers, oil   TIC and                          and operation                    cooling tower, and chemical          $100,000
                       water drains and demineralisation of     Contractor                       phase Systems                    lagoon are discharged to sea via
                       water (for NOx injection) which will                                      are provided                     the final discharge sump
                       be collected in a sump, prior to                                          under T1 and
                       discharge into the seawater outfall.                                      are being                        Water from demineralisation
                       The wastewater is given appropriate                                       commissioned.                    plant/neutralisation sump, oily
                       treatment (eg neutralisation and oil                                                                       water separator, and storm water
                       separation) prior to discharge into                                                                        are discharged into the marshland
                       the sump.                                                                                                  via the storm water drain




Addendum Environmental Report                                                        8-19                                                                         J98404B
JacobsGIBB Limited                                                                                                                               Issue 3.0 / November 2001
                                                                                                                 TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                    Individual (s)   Standards       Timing of         Responsible      Comments and Actions to Date        Financial
                                                                Responsible      and Guideline   Action            Authority/       (March 2001)                        Commitment
                                                                for Action       Documents                         Agency
4. WATER AND           Monitoring
WASTEWATER
ISSUES                 1. Establish Monitoring Programme        EM               EIA/EMP         Prior to site     TIC with         See T1 EMMP                         Budget
                       which will comprise monitoring of                                         preparation       overall                                              already spent
                       both the effluents and also the local                     EPA             work              agreement                                            on T1
                       surface waters.                                                                             with EPA.
                                                                                 VRA EMMM                                                                               Budget of
                       a)   Monitoring locations are as                                                            EPA (Sekondi)                                        $6,000 per
                            follows:                                                                               carry out the                                        year
                       (a) On-site                                                                                 offsite
                           Oxidation ponds effluent                                                               monitoring
                           Water sump prior to discharge                                                          with the co-
                           Neutralisation sump                                                                    operation of
                           Oily water separator                                                                   TIC
                           Surface drainage channel at
                            point of discharge                                                                     The other
                       (b) Offsite                                                                                 water and
                       In sea waters after dispersion                                                              wastewater
                       At three locations to be decided                                                            monitoring is
                       within the wetland to the west of site                                                      carried out by
                       At two locations within the                                                                 T1 staff for
                       Anankwari feeder streams                                                                    TTPP.




Addendum Environmental Report                                                          8-20                                                                        J98404B
JacobsGIBB Limited                                                                                                                                Issue 3.0 / November 2001
                                                                                                                    TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue             Description of Action                     Individual (s)   Standards       Timing of            Responsible   Comments and Actions to Date        Financial
                                                                Responsible      and Guideline   Action               Authority/    (March 2001)                        Commitment
                                                                for Action       Documents                            Agency
4. WATER AND          1. continued.                             EM and           EIA/EMP         Prior to site                      As above:                           Budget
WASTEWATER            b) Parameters to be analysed include      contractor                       preparation work                                                       included in
ISSUES                pH, coliform, Oil and grease, total                        EPA                                                                                    operation
                      suspended solids, temperature                                                                                                                     budget for T1
                      increase of sea for cooling water                          VRA EMMM                                                                               and T2
                      releases, (Daily Beach Sea
                      Temperature monitoring), turbidity,
                      Iron, Copper, Magnesium, Lead
                      and conductivity. See EPA
                      guidelines for further details.
                      c) frequency of monitoring will include
                      monitoring prior to discharge or every
                      3 months (if no discharge) for on-site
                      sampling for effluents, and every 6
                      months for off site sampling.

                      2. Purchase water effluent monitoring     EM and           EIA/EMP         Prior to             TIC with      Undertaken under T1.                Budget of
                      equipment and install as necessary in     contractor                       site preparation     overall                                           $760 already
                      laboratory (already covered by T1)                         EPA             work                 agreement                                         spent on T1
                                                                                                                      with EPA
                                                                                 VRA EMMM




Addendum Environmental Report                                                          8-21                                                                        J98404B
JacobsGIBB Limited                                                                                                                                Issue 3.0 / November 2001
                                                                                                                    TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                   Individual (s)   Standards       Timing of             Responsible   Comments and Actions to Date         Financial
                                                               Responsible      and Guideline   Action                Authority/    (March 2001)                         Commitment
                                                               for Action       Documents                             Agency
4. WATER AND           3. Develop water effluent quality       EM               EIA/EMP         Prior to site         TIC with      See T1 EMMP.                         Budget
WASTEWATER             monitoring procedures in                                                 preparation work      overall                                            included in T1
ISSUES                 accordance with parameters and                           EPA                                   agreement                                          operational
                       testing requirements of EPA                                                                    with EPA                                           budget
                       guidelines.                                              VRA EMMM

                       4. Undertake staff training             EM/TIC           EIA/EMP,        Prior to              TIC with      Undertaken as per T1 EMMP.           Budget of
                                                                                international   site preparation      overall                                            $31,000
                                                                                standards for   work                  agreement                                          already spent
                                                                                environmental                         with EPA                                           on T1
                                                                                management

                       5. Undertake water quality              EM and AEM       EIA/EMP         During                TIC with      Undertaken as per T1 EMMP.           Budget of
                       monitoring at agreed locations. This                                     site preparation/     overall                                            $5000 already
                       will include visual inspection of the                    EPA             construction,         approval by                                        spent on
                       stormwater drains on a daily basis.                                      commissioning         EPA                                                baseline
                                                                                VRA EMMM        and operation                                                            monitoring at
                                                                                                                                                                         the three off
                                                                                                                                                                         site monitoring
                                                                                                                                                                         stations

                                                                                                                                                                         Budget of
                                                                                                                                                                         $6,000 per
                                                                                                                                                                         year included
                                                                                                                                                                         in operational
                                                                                                                                                                         budget




Addendum Environmental Report                                                         8-22                                                                          J98404B
JacobsGIBB Limited                                                                                                                                 Issue 3.0 / November 2001
                                                                                                                  TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue             Description of Action                  Individual (s)   Standards       Timing of             Responsible   Comments and Actions to Date       Financial
                                                             Responsible      and Guideline   Action                Authority/    (March 2001)                       Commitment
                                                             for Action       Documents                             Agency
4. WATER AND          6. Tabulate data and interpret ready   EM and AEM       EIA/EMP         During                TIC with      Undertaken as per T1 EMMP.         Budget
WASTEWATER            for inclusion in AER                                                    site preparation/     overall                                          included in 1
ISSUES                                                                        EPA             construction,         approval by                                      above
                                                                                              commissioning         EPA
                                                                              VRA EMMM        and operation

                      7. Provide commitment to               EM and AEM       EIA/EMP         During                TIC           Undertaken as per T1 EMMP.         Within
                      maintenance including spare parts                                       site preparation/                                                      operational
                      and service engineers to avoid down                     EPA             construction,                                                          and
                      time of laboratory equipment.                                           commissioning                                                          maintenance
                                                                                              and operation                                                          budget for
                                                                                                                                                                     T1and T2.




Addendum Environmental Report                                                       8-23                                                                        J98404B
JacobsGIBB Limited                                                                                                                             Issue 3.0 / November 2001
                                                                                                                    TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue             Description of Action                    Individual (s)   Standards       Timing of             Responsible   Comments and Actions to Date         Financial
                                                               Responsible      and Guideline   Action                Authority/    (March 2001)                         Commitment
                                                               for Action       Documents                             Agency
5. NOISE              Mitigation Measures

                      1. Ensure measures taken to select       Environmental    EIA/EMP         Prior to              TIC            EPC Agreement includes              Budget part of
                      plant components and site                Manager with                     commencement                         performance guarantees.             EPC
                      plant/vehicles using noise               TIC and          World bank      of site                              Steam blowing events have           Engineering
                      specifications. Ensure that plant type   Contractor       guidelines      preparation/                         represented a significant noise     costs
                      and condition is checked before                                           construction                         source, but are of short duration
                      delivery to site and meets                                                phase                                and associated with start up of
                      specification.                                                                                                 HRSG’s only.

                      2. Ensure sufficient noise controls at   Environmental    EIA/EMP         Prior to              EPA            Required under EPC                  Budget of
                      source.                                  Manager with                     commencement                         Agreement.                          $1,500,000 will
                                                               TIC and                          of site                                                                  be made
                                                               Contractor                       preparation/                                                             available for
                                                                                                construction                                                             noise
                                                                                                phase, and                                                               abatement of
                                                                                                ongoing during                                                           turbines
                                                                                                construction
                      3. Ensure noise bund is as required      Environmental    EIA/EMP         During first          EPA            This has been provided              Included in T1
                                                               Manager with                     month of                                                                 budget
                                                               TIC and                          site preparation/
                                                               Contractor                       construction
                                                                                                phase
                      4. Ensure that construction work is      Environmental    EIA/EMP         Throughout            EPA            Required under EPC                  In EPC
                      only carried out during designated       Manager with                     site preparation/                    Agreement. The working              construction
                      working days and times.                  TIC and                          construction                         comprises a 60 hour week from       budget
                                                               Contractor                       phase                                Monday to Saturday.




Addendum Environmental Report                                                       8-24                                                                            J98404B
JacobsGIBB Limited                                                                                                                                 Issue 3.0 / November 2001
                                                                                                              TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue             Description of Action                   Individual (s)   Standards       Timing of Action    Responsible   Comments and Actions to             Financial
                                                              Responsible      and Guideline                       Authority/    Date (March 2001)                   Commitment
                                                              for Action       Documents                           Agency
5. NOISE              Monitoring

                      1. Design monitoring programme          EM               EIA/EMP         During              TIC with      See T1 EMMP.                        Budget part of
                      Set up monitoring site locations for                                     commissioning       overall                                           EPC Contract
                      noise source compliance tests and                                        and testing phase   agreement
                      boundary tests.Sites not permanent.                                                          with EPA

                      2. Purchase noise monitoring            EM               EIA/EMP         During              TIC with      Purchased under T2.                 Budget of
                      equipment (part of start up and                                          site preparation/   overall       Replacements are being sought       $5,000 part of
                      testing effort) if required.                                             construction work   agreement     for the old T1 instrumentation.     EPC Contract
                      Some noise monitoring equipment                                                              with EPA
                      already purchased under T1 is
                      beyond repair. Check the condition of
                      this equipment and make sure it is
                      regularly calibrated.


                      3. Enhance noise monitoring             EM               EIA/EMP         During              TIC with      See T1 EMMP.                        Budget of
                      procedures and actions in the event                                      site preparation/   overall                                           $1,000
                      of a non-compliance.                                     World bank      construction work   agreement
                                                                               guidelines                          with EPA

                      4. Undertake/continue staff training.   EM/TIC           EIA/EMP,        During              TIC with      Staff training undertaken for T2.   Budget as in 1
                      Some staff training already done                         international   site preparation/   overall       See Appendix F6, Volume 2 for       above
                      under T1.                                                standards for   construction work   agreement     details of noise monitoring
                                                                               environmental                       with EPA      training provided by GIBB
                                                                               management                                        Limited




Addendum Environmental Report                                                      8-25                                                                         J98404B
JacobsGIBB Limited                                                                                                                             Issue 3.0 / November 2001
                                                                                                                     TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                    Individual (s)   Standards       Timing of             Responsible   Comments and Actions to Date         Financial
                                                                Responsible      and Guideline   Action                Authority/    (March 2001)                         Commitment
                                                                for Action       Documents                             Agency
5. NOISE               5. Undertake monthly 24hour noise        EM and AEM       EIA/EMP         During                TIC with      As per T1 EMMP.                      Budgeted in 1
                       monitoring at Aboadze monitoring                                          site preparation/     overall                                            above
                       station, Aboadze near Lorry Park,                         World bank      construction,         approval by
                       VRA township, and the North,                              guidelines      commissioning         EPA
                       South, East and West boundaries.                                          and operation
                       Also at various onsite locations in
                       relation to key plant weekly for five
                       minute periods equipment, in
                       accordance with methods and
                       procedures
                       6. Tabulate data and interpret ready     EM and AEM       EIA/EMP         During                TIC/EPA       As per T1 EMMP.                      Budget within
                       for inclusion in AER                                                      site preparation/                                                        EM salary
                                                                                                 construction,                                                            budget
                                                                                                 commissioning
                                                                                                 and operation
                       7. Monitor site operations to identify   EM and AEM       EIA/EMP         During                TIC/EPA       Undertaken as part of routine        Budget to be
                       where careless practices are                                              site preparation/                   monitoring for T1.                   made
                       contributing to noise emissions. For                                      construction,                                                            available
                       example, doors left open in plant                                         commissioning
                       housing or maintenance hatches left                                       and operation
                       open on machinery.
6. ACCESS AND          Mitigation Measures
TRAFFIC
                       1. Existing access and haul routes       Environmental    EIA/EMP         At                    EPA/GHA       Confirmed.                           Budget
                       will be used for transport of            Manager                          commencement                                                             included in
                       construction materials.                                                   of site                                                                  EPC contract
                                                                                                 preparation/
                                                                                                 construction
                                                                                                 phase and
                                                                                                 ongoing through
                                                                                                 operation phase.




Addendum Environmental Report                                                        8-26                                                                            J98404B
JacobsGIBB Limited                                                                                                                                  Issue 3.0 / November 2001
                                                                                                        TIC Takoradi Thermal Power Plant, Proposed Expansion

                       2. Careful loading of materials on     Environmental   EIA/EMP    At                 EPA/GHA     A requirement of EPC Agreement.     Budget in EPC
                       and off vehicles. Measures taken to    Manager with               commencement                                                       construction
                       ensure vehicles are not overloaded     TIC                        of site                                                            contract
                       and loads are safe as vehicles leave                              preparation/
                       to and from the site.                                             construction
                                                                                         phase and
                                                                                         ongoing through
                                                                                         operation phase.




Addendum Environmental Report                                                     8-27                                                                 J98404B
JacobsGIBB Limited                                                                                                                    Issue 3.0 / November 2001
                                                                                                                   TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                     Individual (s)   Standards       Timing of          Responsible    Comments and Actions to Date         Financial
                                                                 Responsible      and Guideline   Action             Authority/     (March 2001)                         Commitment
                                                                 for Action       Documents                          Agency
6. ACCESS AND          3. Appropriate Speed Limits will be       Environmental    EIA/EMP         At                 EPA combined   2   See above. The signs have        Budget
TRAFFIC                set on all roads used by plant traffic.   Manager with                     commencement       with Police,       been placed by the police.       included in
                       These will be agreed with National        TIC                              of site            MTTU           3   No meeting with the National     EPC contract
                       Road Safety Committee.                                                     preparation/                          Road Safety Committee has
                                                                                                  construction                          been set up as yet.
                                                                                                  phase and on
                                                                                                  going
                                                                                                  throughout the
                                                                                                  operation
                       4. Proper maintenance of site             Environmental    EIA/EMP         At                 EPA combined   Regular maintenance is currently     Budget
                       vehicles.                                 Manager with                     commencement       with GHA       undertaken.                          included in
                                                                 TIC                              of site                                                                EPC contract
                                                                                                  preparation/
                                                                                                  construction
                                                                                                  phase and on
                                                                                                  going
                                                                                                  throughout the
                                                                                                  operation
                       5. Provision of bus service bringing      TIC/EPC          EIA/EMP         At                 EPA            Confirmed.                           Budget in
                       construction workers to the site          contractor                       commencement                                                           construction
                       during peak construction period to                                         of site                                                                contract
                       reduce road traffic.                                                       preparation/
                                                                                                  construction
                                                                                                  phase and on
                                                                                                  going
                                                                                                  throughout the
                                                                                                  operation




Addendum Environmental Report                                                         8-28                                                                          J98404B
JacobsGIBB Limited                                                                                                                                 Issue 3.0 / November 2001
                                                                                                             TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                    Individual (s)   Standards       Timing of        Responsible    Comments and Actions to Date            Financial
                                                                Responsible      and Guideline   Action           Authority/     (March 2001)                            Commitment
                                                                for Action       Documents                        Agency
6. ACCESS AND          6. Measures to control vehicle speeds    Environmental    EIA/EMP         At               EPA combined   Confirmed (with the exception of        Budget
TRAFFIC                on the access road to the plant, the     Manager with                     commencement     with GHA       discussions with the National           included in
                       haul roads within the plant site and     TIC                              of site                         Road Safety Committee).                 T1/T2
                       feeder roads from the plant to local                                      preparation/                                                            construction
                       villages will be agreed through                                           construction                                                            budget
                       negotiation and discussion with the                                       phase and
                       National Road Safety Committee.                                           throughout the
                       These will include road signs, traffic                                    operation
                       calming measures and improved
                       enforcement by transport police. Brief
                       education programmes will inform
                       workers of hazards of speeding/drink-
                       driving.

                       Monitoring

                       No monitoring proposed




Addendum Environmental Report                                                      8-29                                                                       J98404B
JacobsGIBB Limited                                                                                                                           Issue 3.0 / November 2001
                                                                                                                    TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                   Individual (s)   Standards       Timing of             Responsible   Comments and Actions to Date         Financial
                                                               Responsible      and Guideline   Action                Authority/    (March 2001)                         Commitment
                                                               for Action       Documents                             Agency
7. LAND ISSUES         Mitigation Measures
AND WASTE
MANAGEMNENT            1. Rehabilitation of Borrow Areas.      EM/T1/T2         EIA/EMP         After materials       EPA           Completed.                           Budget
                       Local borrow areas will be              contractor                       have been                           Some properties for the VRA          included in
                       rehabilitated to former condition by                                     extracted from                      Township (senior management          construction
                       contractor. Details of rehabilitation                                    borrow pits,                        housing) have been built on          budgets for
                       to be written into contractors                                           during                              former borrow areas that surround    T1/T2
                       contracts and an audit of                                                site preparation/                   the main Township.
                       contractors activities will be                                           construction
                       undertaken by EM                                                         phase.

                       2. Waste Management                     Contractor to    EIA/EMP         At                    EPA           See Waste Management Plan for        Budget
                       procedures. Waste management            be audited by                    commencement                        Waste Oil Disposal and Plan for
                       procedures will be developed for the    Environmental                    of site                             SC1 and SC2 (transformer) oily       Included in
                       site and a waste management             Manager with                     preparation/                        waste collection and spill           EPC
                       manual produced. This will include      TIC                              construction                        prevention.                          Contractor
                       segregation of wastes, storage,                                          phase.                              Domestic wastes for total facility   budget.
                       handling, on-site management of                                                                              are collected and removed from       Hazardous
                       hazardous waste, personal                                                                                    site by local council three times    Waste to be
                       protective equipment. The waste                                                                              per week.                            handled by
                       management procedures will                                                                                   There are no other routine           VRA.
                       include initiatives for waste                                                                                hazardous wastes produced save
                       reduction, re-use and recycling and                                                                          for the waste oil sludge.
                       treatment of hazardous wastes.

                       3. Training of staff.                   Environmental    EIA/EMP         At                    EPA           As laid out in T1 EMMP. Training     Budget in
                       All site personnel involved in waste    Manager with                     commencement                        programme to be formalised.          T1/T2
                       management will be trained in the       TIC                              of site                             Training incorporated into plant     construction
                       implementation of the waste                                              preparation/                        weekly safety meeting                budget
                       management procedures. Staff will                                        construction
                       be provided with appropriate                                             phase
                       personal protective equipment and
                       given guidance on environmental
                       hazards associated with on-site
                       wastes.




Addendum Environmental Report                                                       8-30                                                                            J98404B
JacobsGIBB Limited                                                                                                                                 Issue 3.0 / November 2001
                                                                                                                  TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                     Individual (s)   Standards       Timing of          Responsible   Comments and Actions to Date          Financial
                                                                 Responsible      and Guideline   Action             Authority/    (March 2001)                          Commitment
                                                                 for Action       Documents                          Agency
7. LAND ISSUES         4. Treatment of Waste Oils. The           Environmental    EIA/EMP         During operation   EPA           The incinerator was installed for     Budget in T1
AND WASTE              waste oils are isolated from the          Manager with                                                      T1 and is now in operation.           contract sum
MANAGEMNENT            surface drainage system and stored        TIC and T1                                                        However , an alternative primary
                       in an on-site pool, which will be         contractor                                                        waste oil disposal option has been
                       removed offsite, or if this is not                                                                          identified – waste oil recycling to
                       possible then incinerated. The                                                                              Tema Oil Refinery and other
                       efficient and timely operation of the                                                                       private sector companies.
                       incinerator will be ensured.

                       5. Sludge Waste from Oxidation            Environmental    EIA/EMP         At 10 year         EPA           The sewage lagoons are currently      Budget to be
                       Ponds. Sewage sludge will be              Manager with                     intervals.                       under-utilised. Sludge removal        determined
                       generated from the oxidation ponds        TIC                                                               and disposal not likely to happen     when dredging
                       which will be dredged every 10                                                                              in the next 10 years.                 is required
                       years. This will be landfilled or used
                       locally for agriculture. The disposal
                       option of the sludge will be carefully
                       selected and monitored.

                       6. Solid wastes from construction         Environmental    EIA/EMP         Construction       EPA           Confirmed. Wood is currently          Budget
                       and operation phases. These will          Manager with                     and operation                    recycled to the local workforce as    included in
                       include wood, metals, glass and           TIC                              phases.                          part of a performance reward          T1/T2
                       plastic etc. The solid waste will be                                                                        scheme.                               contracts and
                       collected by Shama Ahanta East                                                                              Not Applicable anymore at the         then in annual
                       Metropolitan Authority and                                                                                  operational phase                     operations and
                       transported to its local landfill site.                                                                                                           maintenance
                                                                                                                                                                         budget




Addendum Environmental Report                                                         8-31                                                                         J98404B
JacobsGIBB Limited                                                                                                                                Issue 3.0 / November 2001
                                                                                                                 TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                  Individual (s)   Standards       Timing of           Responsible    Comments and Actions to              Financial
                                                              Responsible      and Guideline   Action              Authority/     Date (March 2001)                    Commitment
                                                              for Action       Documents                           Agency
7. LAND ISSUES         Monitoring
AND WASTE
MANAGEMNENT            1. Operation of Oil Incinerator        Environmental    EIA/EMP         Waste               EPA            This has only been undertaken        Budget
                       and oilywater separator. The           Manager with                     management                         to determine sludge oil content      included in T1
                       operation of the waste oil             TIC                              audit will be                      prior to arranging agreement for     operational
                       incinerator, oilywater separator                                        undertaken.                        removal of waste oil for recycling   and
                       and collection system will be                                                                              by TOR.                              maintenance
                       monitored and audited to ensure                                                                                                                 budget
                       efficient operation and satisfactory                                                                       Regular monitoring to be
                       management.                                                                                                undertaken to check levels of
                                                                                                                                  trace metals and toxics was
                                                                                                                                  commenced in February 2000
                       2. Audit waste management              Environmental    EIA/EMP         Waste               EPA            Provided for in T1 EMMP.             Budget
                       procedures and practices. An           Manager with                     management                                                              included in T2
                       audit of waste management              TIC                              audit will be                                                           operational
                       procedures and practices will be                                        undertaken and                                                          and
                       undertaken focussing on the                                             repeated                                                                maintenance
                       operation of T1. An audit of waste                                      annually.                                                               budget
                       carrier and landfill site will be                                       Results will be
                       undertaken to ensure satisfactory                                       reported in the
                       disposal at appropriately regulated                                     AER.
                       landfill site. Where mitigation
                       measures or changes in waste
                       management practices are
                       required, then mitigation
                       measures will be developed in the
                       final supplementary EIA.




Addendum Environmental Report                                                      8-32                                                                          J98404B
JacobsGIBB Limited                                                                                                                              Issue 3.0 / November 2001
                                                                                                                  TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                  Individual (s)   Standards       Timing of            Responsible    Comments and Actions to             Financial
                                                              Responsible      and Guideline   Action               Authority/     Date (March 2001)                   Commitment
                                                              for Action       Documents                            Agency
8. ECOLOGICAL          Mitigation Measures
EFFECTS
                       1. All operations will remain within   Environmental    EIA/EMP         At                   EPA            Confirmed. Parts of the BVI         Budget in T2
                       the existing site fence line.          Manager with                     commencement                        Construction area will be           EPC contract
                       Additional encroachment into the       TIC                              of site                             returned to wetland on
                       wetland area west of the site will                                      preparation/                        completion of construction while
                       be avoided. Areas already                                               construction                        other construction areas outside
                       cleared of vegetation for the                                           phase and                           the TTPP plant boundary will
                       construction lay down sites during                                      ongoing through                     also be reinstated.
                       construction of T1 will be used                                         operation phase.
                       during T2.

                       2. Revegetation of areas following     Environmental    EIA/EMP         Revegetation of      EPA            Confirmed.                          Budget
                       construction.                          Manager with                     T1 areas                                                                included in
                                                              TIC                              ongoing. Any                                                            EPC contract
                                                                                               T2 areas will be
                                                                                               addressed
                                                                                               during the
                                                                                               construction
                                                                                               phase.
                       3. Landscape screen planting will      Environmental    EIA/EMP         During               EPA            Confirmed particularly for the      Budget
                       be undertaken using appropriate        Manager with                     construction                        coastal strip.                      included in
                       native species.                        TIC                              phase                                                                   EPC contract




Addendum Environmental Report                                                      8-33                                                                           J98404B
JacobsGIBB Limited                                                                                                                               Issue 3.0 / November 2001
                                                                                                              TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                 Individual (s)   Standards       Timing of         Responsible        Comments and Actions to            Financial
                                                             Responsible      and Guideline   Action            Authority/         Date (March 2001)                  Commitment
                                                             for Action       Documents                         Agency
8. ECOLOGICAL          Mitigation measures
EFFECTS
                       4. Restoration of borrow areas by     Environmental    EIA/EMP         During            EPA                Confirmed, although some VRA       Budget in EPC
                       contractor. Selection of              Manager with                     construction                         Township properties have been      contract
                       appropriate native species for        TIC                              phase                                constructed on former borrow
                       planting.                                                                                                   areas. Ornamental planting has
                                                                                                                                   been used in these areas.

                       5. Specific routes for construction   Environmental    EIA/EMP         At                EPA                Same routes used as per T1.        Budget in EPC
                       vehicles will be established, to      Manager with                     commencement                                                            contract
                       avoid any off-road vehicle            TIC                              of site
                       movements for site plant and                                           preparation/
                       vehicles                                                               construction
                                                                                              phase and
                                                                                              throughout
                                                                                              project life
                       Monitoring

                       1.Brief annual ecological walkover    EM               EIA/EMP         During            TIC with overall    No action to date.                Budget of
                       survey to assess ecological                                            construction      agreement with                                        $3,000 per
                       effects. This will cover the plant                                     work,             EPA                                                   year
                       site and the wetland area to a                                         commissioning
                       distance of 2km from the western                                       and operation
                       boundary.
                       2. Borrow areas will be               EM               EIA/EMP         Following         TIC with overall    No action to date.Borrow          Budget in EM
                       periodically assessed to ensure                                        completion of     agreement with      areas have been assessed,         staff salaries
                       effective restoration has been                                         construction      EPA                 revegetation is proceeding
                       undertaken.                                                                                                  satisfactorily even though at
                                                                                                                                    slow pace




Addendum Environmental Report                                                     8-34                                                                           J98404B
JacobsGIBB Limited                                                                                                                              Issue 3.0 / November 2001
                                                                                                                  TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                 Individual (s)   Standards       Timing of           Responsible   Comments and Actions to Date         Financial
                                                             Responsible      and Guideline   Action              Authority/    (March 2001)                         Commitment
                                                             for Action       Documents                           Agency
9. LANDSCAPE           Mitigation Measures
AND VISUAL
EFFECTS                1. Ensure that no vegetation          Environmental    EIA/EMP         During              EPA           Confirmed no further major loss of   Budget in EPC
                       clearance or other disturbance/       Manager with                     site preparation/                 vegetation.                          contract
                       encroachment occurs in areas not      TIC / EPC                        construction
                       previously effected by T1.            Contractor                       phase
                       2. Design landscape scheme            Environmental    EIA/EMP         At                  EPA           Confirmed and largely in place.      Budget in EPC
                       including suitable native trees and   Manager with                     commencement                                                           contract
                       other local species. This will        TIC / EPC                        of construction
                       include native grass species for      Contractor                       phase and
                       proposed grassed areas of the                                          ongoing into
                       site.                                                                  operation phase

                       3. Implement planting scheme for      Environmental    EIA/EMP         At                  EPA           See above.                           Budget in EPC
                       site and adjacent areas. Planting     Manager with                     commencement                                                           contract
                       will be carried out as quickly as     TIC                              of construction
                       practically possible.                 EPC                              phase and
                                                             Contractor                       ongoing into
                                                                                              operation phase

                       Monitoring

                       1.Commitment to tree planting         EM               EIA/EMP         During              TIC with      EMG monitoring process.              Budget in EPC
                       maintenance. Ensure planting                                           construction        overall                                            contract
                       programme is effective by                                              work,               agreement
                       monitoring tree health and                                             commissioning       with EPA
                       replanting as necessary                                                and operation.
                                                                                              The monitoring
                                                                                              will be
                                                                                              undertaken on a
                                                                                              6 monthly basis.




Addendum Environmental Report                                                       8-35                                                                          J98404B
JacobsGIBB Limited                                                                                                                               Issue 3.0 / November 2001
                                                                                                              TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                  Individual (s)   Standards       Timing of      Responsible   Comments and Actions to Date          Financial
                                                              Responsible      and Guideline   Action         Authority/    (March 2001)                          Commitment
                                                              for Action       Documents                      Agency
10. RISK               Mitigation Measures
MANAGEMENT
                       1. Staff will be made aware of the     Environmental    EIA/EMP         During         EPA               H&S training has been            Budget
                       risks posed by oil spillage,           Manager with                     construction                      provided.
                       chemical spillage, fire and            TIC and          OSCP            and ongoing                      Confirmed.                       $300,000
                       explosion. Staff will be educated      Contractor                       through                          Two Mock Spill Exercises
                       on how to minimise risks by using                                       operational                       were undertaken in May 1999
                       good practice and on how to                                             phase.                            and November 2000, the
                       respond to an incident. Training                                                                          results if which have been
                       programme to include.                                                                                     documented for distribution to
                                                                                                                                 the EPA and internally.
                           Fire fighting practice                                                                          An Evacuation drill plan has been
                           Precautions for safe storage                                                                    prepared for T1. This is still
                            and handling of fuels and                                                                       believed to be in draft form.
                            hazardous chemicals.
                           -A mock Oil Spill Response
                            exercise and details of the Oil
                            Spill Contingency Plan
                            (OSCP).

                       2. Review of existing contingency
                       plans for incident management.
                       This is to be updated as required.




Addendum Environmental Report                                                         8-36                                                                    J98404B
JacobsGIBB Limited                                                                                                                           Issue 3.0 / November 2001
                                                                                                            TIC Takoradi Thermal Power Plant, Proposed Expansion

TIC – PROPOSED EXPANSION TO TAKORADI THERMAL POWER PLANT

PROVISIONAL ENVIRONMENTAL MANAGEMENT PLAN

EMP Issue              Description of Action                Individual (s)   Standards       Timing of      Responsible   Comments and Actions to           Financial
                                                            Responsible      and Guideline   Action         Authority/    Date (March 2001)                 Commitment
                                                            for Action       Documents                      Agency
10. RISK               Monitoring Measures
MANAGEMENT
                       1.Check accident records and the     Environmental    EIA/EMP         During         EPA              Incidents are documented      Budget included
                       procedures which are used to         Manager with                     construction                     according to Procedure EP     in operational
                       record incidents.                    TIC and          OSCP            and ongoing                      010, ‘Procedure for           and
                                                            Contractor                       through                          Corrective Action to Deal     maintenance
                       2. Audit clean up operations for                                      operational                      with Environmental            costs
                       any spillages that occur.                                             phase.                           Incidents and Non-
                                                                                                                              Conformances’, of the T1
                       3. Check standard and integrity of                                                                     EMS Manual.
                       storage facilities and general                                                                        Audits are undertaken as
                       housekeeping. Repair facilities                                                                        required under Section 6
                       and upgrade as required.                                                                               ‘Internal Audit Manual’ of
                       Inspection will be carried out at                                                                      the T1 EMS Manual.
                       least every 6 months.                                                                                 Plant Inspection is
                                                                                                                              undertaken daily.




Addendum Environmental Report                                                       8-37                                                                   J98404B
JacobsGIBB Limited                                                                                                                        Issue 3.0 / November 2001
                            THIS PAGE IS INTENTIONALLY BLANK




Addendum Environmental Report                                                   J98404B
JacobsGIBB Limited                                             Issue 3.0 / November 2001
TIC Takoradi Thermal Power Plant, Proposed Expansion


9       CONCLUSIONS

9.1     Introduction


        The following section draws on the conclusions of the EIA undertaken for the 1999
        SEIS and of this Addendum with regards to the Takoradi 2 expansion project, and is
        subdivided as follows:

•       The overall impact associated with constructing and operating T2 alone

•       The overall impact of operating T1 and T2;

•       The nature and significance of any change to the conclusions drawn in the 1999 SEIS
        after taking into account the additional environmental and social topics, changes and
        updates addressed in the Addendum.



9.2     Conclusions on Overall Effect of T2


        On balance, after taking into account the following points, it is concluded that the
        construction and operation of T2 would have a relatively minor adverse effect on the
        surrounding environment.

•       T2 represents an extension of an existing plant and by definition shares an existing
        infrastructure, services and facilities which would otherwise have to be constructed if
        the plant was developed on a new site;

•       The construction phase for T2 has run concurrently with T1 whereby areas previously
        affected by the T1 construction activities (laydown areas, compound sites and spoil
        storage areas) have been taken over for the T2 construction phase. This has
        minimised the temporary loss of any further land-take over and above that used for
        T1.

•       The T2 plant has been designed to comply with World Bank criteria for thermal power
        plants and Ghanaian regulations.

•       A programme of community improvements is currently being implemented as
        compensation for T1 for the local communities (which includes T2). These
        improvements include, but are not limited to, school buildings, cold storage, local
        employment and ongoing public consultation.



9.3     Conclusions on Overall Effect of T1 + T2


        When considering the cumulative effect of operating both T1 and T2 as a combined
        cycle plant it is expected that, as described in the 1999 SEIS, it will have at most a
        moderate adverse effect on the surrounding environment provided environmental
        management and monitoring programmes are implemented as described.

Addendum Environmental Report                                                              J98404B
JacobsGIBB Limited                        9-1                             Issue 3.0 / November 2001
                                        TIC Takoradi Thermal Power Plant, Proposed Expansion




9.4     Conclusions of Addendum


        In specifically addressing the environmental and social issues requested by IFC, it is
        concluded that due largely to the former land use of the T2 construction site and
        temporary storage and compound areas (i.e. it had already been cleared and/or in
        use for T1) there has been no effect on the following issues:

•       Natural habitats (as defined in OP 4.04);

•       Forestry;

•       Cultural property; and

•       Involuntary resettlement.

        Ghanaian worker’s rights legislation does not permit the use of child or forced labour
        and the Contractor’s EPC Agreement enforces this requirement. No such practices
        occur on the TTPP site (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, and comprise reducing
        the prevalence of mosquitoes at the plant and VRA township and to reduce weed
        growth within the substation areas. 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 (as defined in OP 7.50), that current fuel supply deliveries are quarterly and
        T2 will share the existing facilities, it is concluded that there is no adverse effect on
        this issue.

        In terms of addressing the changes that have occurred since the preparation of the
        1999 SEIS, it is considered that overall, there is no significant adverse change to the
        environmental impacts (beneficial and adverse) described in the 1999 SEIS. This is
        on account of the fact that there is no substantial change to the design of the plant.
        The plant during normal operation should meet the relevant environmental guidelines
        of both Ghana and the World Bank.

        While the construction phase has essentially extended, provided the appropriate
        construction phase mitigation measures are employed as discussed, any associated
        construction effects should last for the duration of the construction period only.

        Overall, and with the implementation of appropriate management policies and
        procedures during T2’s operation, environmental quality monitoring and pollution
        prevention and response procedures, and health and safety frameworks, it is
        expected that any residual environmental effects will be kept to a minimum, under
        normal operating conditions. The recommendations laid out in the Provisional
        Environmental Management and Monitoring Plan for T2 (as per 1999 SEIS) and in
        the Addendum should also ensure a high level of environmental protection is
        maintained.

Addendum Environmental Report
JacobsGIBB Limited                         9-2                              Issue 3.0 / November 2001
                        FIGURES



Figure 3.1   Location Plan

Figure 3.2   T2 Structures and Layout, Simple Cycle 1, Phase 1

Figure 3.3   T2 Structures and Layout, Simple Cycle 2, Phase 2a

Figure 3.4   T2 Structures and Layout, Combined Cycle, Phase 2b

Figure 3.5   Transmission Line Routes Associated with TTPP

Figure 3.6   Construction Schedule Phase 2b Combined Cycle
Key
      Transmission Line Completed Under TK-6 (T1)
      Proposed Transmission Line to Evacuate Total
      T1 and T2 Generation
      Proposed Transmission Line to improve Ghana’s
      Electricity Transmission Network

                             Takoradi International Company        Date         Figure


                   Transmission Line Routes Associated With TTPP    July 2001       3.5
                                                                             FIGURE 3.6 CONSTRUCTION SCHEDULE PHASE 2B COMBINED CYCLE
DESCRIPTION                                                  1   2   3         4       5   6       7   8   9    10     11     12    13   14    15      16           17   18   19   20   21   22    23       24
PROJECT MANAGEMENT & ADMINISTRATION
ENGINEERING
    CIVIL STRUCTURAL
   MECHANICAL
   CHEMICAL

MAJOR PROCUREMENT
   HRSO #1                                                   A                                                                                DDDDDDDDDDDD
   HRSO #2                                                   A                                                                           DDDD D D D D D D D D
   STEAM TURBINE                                             A                                                                                DDDDDDDD
   STEAM TURBINE BUILDING                                                A                                            DDDD
   GSU TRANSFORMER (ST)                                                  A                                                                     D
   SWITCHYARD EQUIPMENT                                                            A                                                D
   WATER TREATMENT EQUIPMENT                                                                   A                                                                D
   BOP EQUIPMENT (CC)                                                    AAAAAAAAAAAAA                         DDDD   DDDD   DDDD
   COOLING TOWER                                                                 A                                                            DDDDDDDD
   PIPE RACK                                                             A                                     DDDD   DDDD
CONSTRUCTION
   SITE PREPARATION
   UNDERGROUND UTILITIES (CC)
   FOUNDATIONS (CC)
   CIRC WATER LINE
   CIRC WATER PUMPHOUSE
   COMBUSTION TURBINE 1 OUTAGE
   COMBUSTION TURBINE 2 OUTAGE
   HRSG #1 ERECTION
   HRSG #2 ERECTION
   STEAM TURBINE BUILDING ERECTION
   CONDENSER ERECTION
   STEAM TURBINE ERECTION
   PIPE RACK ERECTION
   OSU TRANSFORMER (ST) INSTALLATION
   SWITCHYARD ERECTION
   WATER TREATMENT EQUIPMENT INSTALLATION

   COOLING TOWER ERECTION/COMMISSIONING
   BOP EQUIPMENT INSTALLATION
   MECHANICAL PIPING ERECTION
   ELECTRICAL CABLE ERECTION
COMMISSIONING, TESTING & STARTUP
   ENERGIZE AUX ELECT SYSTEM
   COMMISSION WATER TREATMENT

   HYDRO HRSG's
   CHEMICAL CLEANING
   CT2 REFIRE - CHECKOUT
   CT1 REFIRE - CHECKOUT
   STEAM BLOWS/RESTORE

   UNIT SYNCH / COMMISSIONING / TEST RUNS
   SUBSTANTIAL COMPLETION
                                            Combined Cycle                                                                                           Energize                                     Combined Cycle
                                                  EPC MTP                                                                                           Aux Elect                                         Substantial
                                                                                                                                                                                                      Completion
PHOTOGRAPHS


Photograph Sheet 1   Photograph 1

Photograph Sheet 2   Photographs 2a to 3a

Photograph Sheet 3   Photographs 3b to 4b

Photograph Sheet 4   Photograph 5

Photograph Sheet 5   Photographs 6 to 7

Photograph Sheet 6   Photographs 8a to 8c

Photograph Sheet 7   Photograph 9
SC2   1. SC1 and SC2 of T2           SC1




                             Takoradi International Company
                             Takoradi Environmental Impact Assessment

                                      Photograph Sheet 1
2a. Temporary drainage ditch running east-west at southern end of T2 area.
    Settling basin adjacent to road crossing point.




                                                                             3a. Worker bus collection/deposit point, the ‘shanty’ town on the edge of the BVI
                                                                                 construction compound, including the cement batching plant




                                                                                                                   Takoradi International Company
                                                                                                                   Takoradi Environmental Impact Assessment

  2b. Tie in of temporary drainage system into existing T1 drainage system                                                      Photograph Sheet 2
3b. Cement batching plant and aggregrate storage area in the BVI construction compound




                                                                                         4b. Untreated LCO storage tank for SC2 under construction




                                                                                                                 Takoradi International Company
                                                                                                                 Takoradi Environmental Impact Assessment

      4a. Treated LCO storage tank for SC2 and bermed area (additional feature)                                             Photograph Sheet 3
5. Coastal Strip Replanting
   (tanker delivering LCO in
   background)




                               Takoradi International Company
                               Takoradi Environmental Impact Assessment

                                        Photograph Sheet 4
6. Completed VRA township leisure facility. Sewerage lagoons in background.




                                                                              Takoradi International Company
                                                                              Takoradi Environmental Impact Assessment
        7. Laying of foundations for 4-block school at Aboadze
                                                                                       Photograph Sheet 5
8a. Sewage lagoon 1




                      8c. Sewage lagoon 3




                           Takoradi International Company
                           Takoradi Environmental Impact Assessment

8b. Sewage lagoon 2                   Photograph Sheet 6
9. Aboadze at TTPP boundary




                              Takoradi International Company
                              Takoradi Environmental Impact Assessment

                                       Photograph Sheet 7