HFO Power Generation Project

56 Pages·2015·1.49 MB·English

by  Arundhati Inamdar Willetts

ENVIRONMENTAL AND SOCIAL IMPACT ASSESSMENT SUMMARY

Project Title: CEC Africa (SL) HFO Power Generation Project
Project Number: P-SL-F00-008
Country: Sierra Leone Department: OPSD
Division: OPSD.3 Project Category: 1

1. Introduction

CEC Africa (Sierra Leone) Limited (CECASL) is a joint venture established to develop an
electricity-generating, heavy fuel oil (HFO) power plant (hereafter referred to as the project)
located on a site in the Kissy Dock area, approximately 4 km east of the centre of Freetown, Sierra
Leone. The power plant will be developed first as a 50 megawatts electrical (MWe) installation
and then an additional two phases of 39MWe, resulting in a potential total output of 128 MWe to
the transmission network. This ESIA summary covers the first 50MWe capacity only, as design,
timing and feasibility details of the subsequent phases are not confirmed at this stage.

The project is sponsored by a consortium of two firms, each with a 50% shareholding: CEC Africa
Investments Limited (a subsidiary of Copperbelt Energy Corporation plc [CEC]) and TCQ Power
Limited (TCQ). The consortium has formed the CECASL joint venture to develop the project.

Map 1: Project Location

The project has been in development since early 2013 and the ESIA initially commenced in
December 2013. However, since June 2014 the ongoing Ebola crisis in West Africa has
significantly impacted Sierra Leone and prevented continued survey work. As part of ongoing
discussions, the development partners have indicated that the project is critical to the post-Ebola
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rebuilding of Sierra Leone’s economy. Therefore, CECASL proceeded with a preliminary ESIA
in order to highlight key environmental and social issues required to support ongoing project
financing and technical design discussions. The ESIA was subsequently updated and finalized in
October 2015.

2. Policy, Legal and Administrative Framework

The main policy documents applicable to the project are the National Environmental Policy,
National Energy Policy, National Land Policy (2005) and the National Water and Sanitation Policy
(Draft).

Key legislation of relevance to the project include the Environment Protection Agency Act, 2008
(No. 11 of 2008) as amended in 2010; National Electricity Act, 2011; Fisheries Management and
Development Act, 1988 (Act No. 4); Factories Act, 1974; and the Town and Country Planning
Act.

The Environmental Protection Agency of Sierra Leone (EPA-SL) was established by an act of
parliament entitled ‘The Environment Protection Agency Act, 2008’ and contained in
Vol.CXXXIX No. 44 dated 11th September, 2008. EPA- SL is overall responsible for the effective
protection of our environment (i.e. land, air, water and all flora, fauna and human beings living
therein and their inter relationship). However, several Ministries, Departments and Agencies
(MDAs) also collaborate with the EPA-SL to varying degrees. These include the Ministry of
Finance (fiscal and tax matters), the Ministry of Lands, Country Planning and the Environment,
the Ministry of Local Government and Community Development (communal lands) and the
Ministry of Works, Housing and Technical Maintenance.

Sierra Leone is a signatory to the following international treaties that are relevant to the project:
 Abidjan Convention for Cooperation in the Protection, Management and Development of
the Marine and Coastal Environment of the West and Central African Region;
 Convention on Migratory Species (CMS);
 Ramsar Convention on Wetlands of International Importance, especially as a Waterfowl
Habitat;
 Protocol to the Convention on the Prevention of Marine Pollution by Dumping of Wastes
and Other Matter, 1972;
 United Nations Framework Convention on Climate Change, its Montreal Protocol on
Substances that Deplete the Ozone Layer, and the Kyoto Protocol;
 The Stockholm Convention on Persistent Organic Pollutants;
 Aarhus Convention.

All the African Development Bank’s Operational Safeguards are triggered by the project, namely:

Operational Safeguard 1: Environmental and social assessment;
Operational Safeguard 2: Involuntary resettlement: land acquisition, population
displacement and compensation;
Operational Safeguard 3: Biodiversity, renewable resources and ecosystem services;
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Operational Safeguard 4: Pollution prevention and control, hazardous materials and
resource efficiency;
Operational Safeguard 5: Labour conditions, health and safety.

In addition, the project developer will be required to conform with IFC Performance Standards
throughout the life of the investment by IFC, specifically:

Performance Standard 1 (PS1): Assessment and Management of Environmental and Social
Risks and Impacts;
Performance Standard 2 (PS2): Labour and Working Conditions;
Performance Standard 3 (PS3): Resource Efficiency and Pollution Prevention;
Performance Standard 4 (PS4): Community Health, Safety, and Security;
Performance Standard 5 (PS5): Land Acquisition and Involuntary Resettlement;
Performance Standard 6 (PS6): Biodiversity Conservation and Sustainable Management
Performance Standard 8 (PS8): Cultural Heritage.

The World Bank Group’s General Environmental, Health, and Safety Guidelines, and EHS
Guidelines for Thermal Power Plants, Waste Management Facilities and Electric Power
Transmission and Distribution also apply.

3. Project Description and Justification

Project Description

The first phase of the project will be to develop 50MW of HFO fueled (thermal) power. Details of
design and timing of Phases 2 and 3 have not been confirmed at this time.

The current design comprises a single engine house in the centre of the site that can be extended
as each phase is developed. A single tank for untreated HFO, two treated HFO storage tanks
together with a service tank and a smaller light fuel oil storage tank are planned. In the final
configuration, diesel generators are connected to six generator transformers that are connected by
cables to the indoor 33kV substation. A central control room will be provided, along with
workshops, water treatment and effluent facilities, fuel oil treatment and other normal services.
Exhaust from the Phase 1 stacks will be grouped into a shared enclosure, which will appear as a
single stack from surrounding views and will assist with stack emissions dispersion. Water is
currently will be sourced from a single borehole on the current site the capacity of which has
recently been confirmed. This could potentially be supplemented by the local municipal supply.

Permanent plant buildings will consist of:
 A totally enclosed, fan ventilated engine hall;
 A control building;
 A combined administration and workshop building (reuse of existing building on site);
 A security (gatehouse) building;
 A fuel oil pump house; and,
 A substation building.
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Other elements of the power plant will include:
 Perimeter site fencing and gates;
 A road way connection to the public highway, plus on-site roads, parking with sunshades
and sealed areas;
 A 1300m pipeline from Addax Jetty to the site for delivery of HFO (mainly above ground,
but the last section will be below ground), together with a pump station and buffer tank;
 The refurbishment and reuse of buildings on the site to create administration offices and
workshop facilities;
 A heavy oil filtration and treatment plant;
 Bunded storage for treated heavy oil and diesel oil;
 11kV to 33kV step-up transformers;
 An indoor 33kV substation and overhead lines to connect from the generator step-up
transformers to allow connection, at choice, with the existing 33kV line running to the
west;
 Air cooling system;
 Water supply and associated borehole;
 Tanks for filtered raw water (including fire water) and potable water;
 A sewage and effluent treatment plant;
 An observation pond for treated effluent prior to discharge to the environment, to allow
inspection to confirm that no visible potential contaminants (such as fuel oil or diesel) are
present in the discharged effluent;
 Waste incinerator;
 Messing, toilet and first-aid facilities; and,
 Civil works including roads, fencing and lighting.

Figure 1 below illustrates the layout of the project on the site.

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Figure 1: Project Site Plan

The proposed construction schedule for Phase 1 is anticipated to be completed 18 months from
financial close. At the peak of construction, the project is anticipated to employ up to 200
construction workers from the surrounding communities including Shell, Hotel 5-10, Kissy
Thunderhill and Kissy Brook communities, where unemployment levels are currently high. There
are currently no plans for a workers’ camp.

A contract for operations and maintenance services for the debt repayment period of 10 years is
expected to be in place from the date of commercial operation. During operations, the power plant
is expected to employ approximately 45 permanent employees.

Project Justification

The power sector in Sierra Leone suffers from severe supply constraints, with electricity supply
limited to a very small proportion of households in the country, estimated at less than 10%. This
is well below the average for Sub-Saharan Africa. Bio-energy is the main source of fuel for
approximately 75% to 80% of the country’s population (both rural and urban). Petroleum,
hydropower and coal are the major sources of commercial energy in the country. Power supply is
restricted to mines or the major towns, where it is irregular and does not provide for minimum
requirements. Blackouts and power rationing, as a result of low water levels in the hydro dams
are currently common. Freetown is supplied with electricity by four power stations; a hydro plant
at Bumbuna (40MW), thermal installation at Blackhall Road (16.5 MW), Kingtom (10MW) and
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Addax Bioenergy Station (16MW). Bumbuna dam’s output varies between 10 MW in the dry
season to a maximum of 40 MW in the wet season.

In November 2008, the Sierra Leone Ministry of Energy and Power formulated the “statement of
energy sector policy and strategic action plan” which contained a number of short, medium and
long-term goals for the development of electricity capacity in Sierra Leone. The GOSL has a
stated policy to expand the installed capacity from around 75MW in 2013 to 1000MW by 2018.
The following key goals have been identified for attainment by the year 2017:
 75% of the population should have access to individual electricity supplies (access is
currently around 6%1);
 15% access to electricity in rural areas (in 2009 this was 1%);
 Integration of the electricity grid with neighbouring countries; and
 Establishment of a framework for development and growth in the sector.

The current energy demand of Freetown is estimated at 105MW and projected to grow to 135MW
by 2020, in part driven by the mining sector. The total installed capacity in Sierra Leone at present
is nearly 92MW (of which 82.5 MW is supplied to Freetown). There is also a high level of
suppressed demand in the country, with many consumers using self-generating diesel plants -
installed capacity from the stand-alone captive plants is estimated to be around 59MW.

The primary objective of the project is therefore to provide additional reliable and efficient
electricity-generating capacity in Sierra Leone.

4. Description of the Project Environment

Land Use

Land use in the immediate environs of the plant is illustrated in Figure 2 below. In general, the
area is characterised by industrial and commercial uses with some formal and informal shanty
dwellings and school dispersed in between. To the north of the site lies the disused refinery and
other primarily commercial and industrial properties, reflecting the industrial zoning of the project
site and local area. There is a polio treatment compound on the northern side of South Road and
some residential dwellings on the southern side of South Road. There are also some shanty housing
and stores located directly adjacent to the site entrance. A school/mosque/health clinic is located
at the southern end of the eastern boundary. Commercial properties are located adjacent to the
remainder of the eastern boundary. The German Academy and the Winston Churchill Secondary
School are located along Factory Road to the west of the site. There are some artisanal farming
areas within the storm drain overflows along South Road. To the south of the site are residential
buildings along the length of the western portion of the southern boundary, with commercial uses
to the southeast. Some shanty developments are present behind shops to the southeast.

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http://archive.crossborderinformation.com/Article/%EF%BB%BFNew+schemes+line+up+as+Sierra+Leon
e+promotes+baseload%2c+off-grid+options.aspx?date=20130627# (last accessed 15th April 2014)

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Figure 2: Land Use in the Project Vicinity

Social Baseline

The project area of socio-economic influence is considered to be a 5 km radius around the site.
Freetown’s estimated population in 2012 was projected to be 1,069,437, but could almost double
between 2012 and 2030 to 1,933,341. Approximately 73% of the population current live in slum
areas. Within the (more urban) Western Region, 29% of the population under 15, but only 3.5%
over 60. Households surveyed during the study were generally equally divided (44.7%) into those
supporting between one to five members and those with six to 10 members. Dwelling houses in
the project area are typically single unit buildings, adjoining units in a compound as well as several
single units in a compound. Co-existing households in dwelling units are quite common in the
community. The main ethnicity of the Kissy area is not known, but is assumed to be Creole - the
same as for Freetown as a whole. According to the household survey, 79% of the local community
are Muslim and 21% are Christian.

Water supply problems in the community were reported by 73% of households surveyed (these
being water cuts, access issues, unclean water). There is no adequate means of refuse disposal in
Freetown, so waste is either dumped at undesignated sites or burned. Much of Freetown’s road
network has been neglected and is in poor condition.

The majority of households surveyed are connected to the national power grid. Alternative sources
of energy for lighting include Chinese-made battery powered lanterns or generators. A significant
number of households do not have any alternative lighting source. Only 40% of the schools
surveyed are connected to electricity supply. Most businesses rely on the national grid for their
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power/electricity needs. However, businesses typically own generators to supplement power needs
when there are outages.

Significant health threats in the project area include HIV/AIDS, malaria and cholera, intestinal
worms, typhoid and dysentery. The recent outbreak of Ebola has also impacted Freetown and
affected both people and health service provision. The household survey reported that knowledge
of HIV/AIDS and Ebola virus disease is common and widespread. Among the most prevalent
chronic diseases reported during the household survey were hypertension, diabetes and cardio-
vascular disease. Health treatment facilities typically visited by the local community are generally
located within a 500m radius of people’s homes and include government hospitals, satellite clinics,
or pharmacies; however, emergency health services at the community level are scarce.

Literacy within the Western Area was double the national average at 70%. The household survey
indicated that most of the households with children aged 6 to 15 years confirmed that their children
were attending school.

Petty trading is the main source of livelihood for the majority of households surveyed. Other
occupations included driver, mechanic, health worker, teaching, general labour, craftsman, farmer,
security guard and retired. Some households practiced farming within the project site – currently
16 farmers cultivate within the project site, and will experience economic displacement due to the
clearance of the site. Most households do not have an additional source of income. About 20% of
households surveyed had an average total monthly income per month (including cash and other
goods received) of Le 551,000 to Le 1,000,000 (USD 126 – 230) while 18% of households earned
Le 351,000 to Le 500,000 (USD 80 – 115) per month.

Given the developed nature and current use of the site, it is considered unlikely that the site has
cultural resource value of note – this was corroborated by desktop review of documentation and
with representatives of identified users of the site.

Environmental Setting

Freetown, as with Sierra Leone and other West African countries has a tropical climate with two
distinct seasons; the dry season which occurs between November and April and the wet season
which occurs between May and October, with a peak of up to 800mm rain during August. The
temperature generally ranges between 22oC and 32oC. As the project site is located approximately
500m from the sea, it is likely to experience higher wind speeds than inshore locations. The
regional geology in the project area is known as the Freetown Complex, a major intrusion
characterized by prominent layering of repeated sequences of troctolitic, gabbroic and anorthositic
rocks, together with transitional rock types. The surface of the site is primarily sand/gravel with
patchy weed-type vegetation. There are areas of hard laterite pan outcropping across the ground
surface within the site compound, which indicates that shallow hard rock is likely to be
encountered across the site. Local soils in the area are known to be well drained with dusky reddish
gravelly sandy clay loam to clay loam with sand content increasing with depth with some laterite
and quartz gravel materials. Borehole samples indicate the possibility of existing contamination of
the soil, particularly around the old fuel pump area.

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The area surrounding and including the project boundary is zoned by Freetown City Council as
commercial/industrial land use. Noise monitoring results showed that the average measured night-
time noise levels around the site are well below the WBG EHS Guideline noise level for industrial
areas of 70dB L . At residential, institutional and educational locations in the project area, the
Aeq
average measured levels are currently below the IFC limit during the daytime (55dB L ), but
Aeq
exceed the IFC night-time guideline level (45dB L ) at two sampling points (59-63 dBA), these
Aeq
levels being attributed to generators and/or traffic along the roads.

Air quality baseline measurements indicated that monitoring parameters for NO , SO and CO
2 2
were within acceptable WHO guidelines, but PM10 and PM2.5 concentrations indicated a

degraded airshed.

Groundwater was encountered at depths between 7.5 and 16.0m below ground level. No
significant contamination of groundwater was encountered, although extracted petroleum
hydrocarbon concentrations were elevated suggesting that a potential hydrocarbon contamination
plume may be present in the area. The key sensitive hydrological feature is the Sierra Leone River
Estuary (SLRE). This is located some 400m to the north of the project site. Principal threats to the
SLRE are vegetation clearance, unsustainable fishing and plastic waste. The other significant
surface water feature in proximity to the project site is the Wellington Creek which is located some
200m to the east of the project site and discharges to the SLRE.

No designated/protected areas overlap with the project site boundary. However, there are two such
areas in the vicinity of the site, namely the Sierra Leone River Estuary (SLRE) and the Western
Area Peninsula National Park (WAPNP). The SLRE is a Ramsar site, and BirdLife International
has designated it as an International Bird Area (IBA). The area supports mangrove forests and
significant numbers of bird species, including 23 species of global conservation concern and of
those, 12 are globally threatened. The nearest section of the Western Area Peninsula National
Park (WAPNP) to the project site is located c.1.5 km to the south of the site. The park is a no-
hunting reserve consists of 17,688 ha of closed rainforest as well as two reservoirs. A total of 374
bird species, include two threatened species, have been recorded in the park, as well as 50 species
of mammals. Five of the seven primate species, four other mammals and two amphibians found
in the park are threatened or are of conservation importance. The Addax Jetty is located
approximately 1 km from the site. Several endemic, endangered and vulnerable species of
butterflies, birds and reptiles are found in the jetty environs.

5. Project Alternatives

‘Do Nothing’ Scenario

As noted above, significant capacity deficit exists with regards to power supply in Sierra Leone,
and the use of the electricity distribution network in Freetown area is severely constrained by
insufficient transport capacity and frequent outages. The “do-nothing” scenario would not alleviate
the current limitations of low power generating capacity, high transmission and distribution losses,
poor revenue collection and limited access. The limitations to power supply development could
adversely affect the economic development of Sierra Leone. The opportunity to develop future
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generations of solutions that enhance efficiency and profitability, contribute to economic
diversification, accelerate human development and other growth drivers (such as international
competitiveness, labour and employment, governance and public sector reform) would be lost.
Therefore the “do-nothing” scenario is not a viable option.

Alternative Sites

A number of sites were considered by the GOSL with regard to the potential for new power
generation 568 installations as part of a power sector masterplan produced for the GOSL by the
Japan International Cooperation Agency (JICA) in 2003. The GOSL has indicated that the
proposed site is the only government-owned land available in the area and that there were no viable
alternatives under government ownership as other potential sites with sufficient access proved to
be difficult to identify in the area. CECASL found the size to be adequate and proceeded with the
lease negotiation on the current site. The layout for the project was also amended several times
considering potential noise effects on adjacent neighbours as well as visual and other potential
nuisance effects. The current brownfield site in a designated industrial zone and proposed layout
are likely to have considerable environmental advantages over the alternative of constructing new
power generating facilities on a greenfield location or in a more heavily populated residential area.
Although a comparative environmental assessment of alternative sites has not been carried out,
alternative sites have been screened out on the basis that there are no viable alternatives under
government ownership with sufficient access requirements.

Alternative Technologies

Although there may be air quality emissions reductions associated with other fuel types,
reciprocating engines firing HFO were selected as the most appropriate technology for the project
primarily due to the absence of existing gas supply infrastructure. In addition, there were two
environmental aspects that resulted in alternative design proposals for water supply and waste
disposal. First, the original design potentially required substantial cooling water intake and
discharge with associated structures, which could have the potential to cause significant impacts
on marine ecology. The design now accommodates for air cooling using the diesel engines that
use ‘fin-fan’ radiators, which require negligible amounts of water to fill internal closed loop pipe
circuits. This will not require a seawater abstraction and the associated infrastructure. Also, on the
advice of the EPA-SL, it is clear that Sierra Leone does not have appropriate landfill facilities for
hazardous waste. Therefore, the design alternative to address this gap was to include the
installation of an on-site incinerator in the design proposals. With regard to air quality mitigation
technologies, control measures for reducing process contributions from particulate emissions were
been considered, including the potential to import low ash fuel versus high ash fuel and the
installation of particulate filtration equipment. However, the difference in cost per year for low
ash fuel would be approximately USD 2-2.5 million. The installation of an Electrostatic
Precipitator (ESP) filtration system was also considered but at a cost of over Euro 3 million this
was deemed unfeasible. Instead, stack heights for the Phase 1 exhausts have been established at
65m, allowing for acceptable dispersion of emissions.

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