E2988 v6 Azura Power West Africa Ltd. ESIA Addendum (including Air and Noise Modelling and Impact Assessment Update) For the Azura-Edo Independent Power Plant ERM Document: 0172621_131808_V8.00 October 2013 The world’s leading sustainability consultancy Azura Power West Africa Ltd. ESIS Addendum (including Air and Noise Modelling and Impact Assessment Update) For the Azura-Edo Independent Power Project ERM Document: 0172621_131018_V8.00 Prepared by: Caroline Kennedy, Chris Hazel-Marshall and Rod Linnet For and on behalf of Environmental Resources Management Approved by: Henry Camp Signed: Position: Partner Date: 18 October 2013 This report has been prepared by Environmental Resources Management the trading name of Environmental Resources Management Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk. CONTENTS EXECUTIVE SUMMARY 1  INTRODUCTION 1  1.1  PURPOSE 1  1.2  BACKGROUND 1  2  EVALUATION OF THE PROPOSED CHANGES 3  3  UPDATE TO AIR MODEL 5  3.1  INTRODUCTION 5  3.2  AIR MODELLING AND IMPACT ASSESSMENT METHODOLOGY 5  3.3  AIR MODELLING AND IMPACT ASSESSMENT RESULTS 6  3.4  AIR MODELLING AND IMPACT ASSESSMENT CONCLUSIONS 9  4  UPDATE TO NOISE MODEL 10  4.1  INTRODUCTION 10  4.2  NOISE MODELLING AND IMPACT ASSESSMENT METHODOLOGY 10  4.3  NOISE MODELLING AND IMPACT ASSESSMENT RESULTS 14  4.4  NOISE MODELLING AND IMPACT ASSESSMENT CONCLUSIONS. 19  EXECUTIVE SUMMARY ERM reviewed the Azura Project ESIA report to identify any supplementary studies required to address the proposed change in plant location within the site boundary. During the course of this review, ERM identified the need to update the air and noise modelling for the Azura Project to ensure potential impacts are identified, assessed and fully mitigated and to identify any required changes to the Azura Project ESMP. No other studies were required. The air modelling was re-run by ERM and the results are presented in Section 3 of this report. Air impacts continue to be insignificant or minor (in one case).. Adverse air impacts do not therefore differ materially from those anticipated in the original approved ESIA report. In light of the above, the mitigation and management measures that are set out in the ESIA report for air aspects continue to be considered valid and appropriate for the Azura Project. The mitigation measures that were established for air and noise impacts as part of the approved ESIA report are presented in Annex A. The noise modelling was revised by Siemens and the results were interpreted by ERM and are presented in Section 4 of this report. Impacts of Minor or Moderate significance are predicted in most cases. Major impacts are predicted to arise at four NSLs where cumulative noise levels exceed baseline levels by >10 dBA. In the majority of cases, the noise impacts that were predicted as part of the original ESIA assessment have not changed. In cases where changes have occurred, the impact significance has increased or decreased by one category as the plant has moved closer, or further away from, NSLs to the north and south respectively. Adverse noise impacts do not therefore differ materially from those anticipated in the original ESIA. In light of the current level of uncertainty with respect to NIPP noise emissions and baseline noise levels (pre-NIPP), Azura will carry out further noise monitoring and updated modelling to verify the cumulative impact of the NIPP plant and Azura plant, and develop enhanced noise mitigation where appropriate. The mitigation and management measures that are set out in the approved ESIA report for noise aspects continue to be considered valid and appropriate for the Azura Project. 1 INTRODUCTION 1.1 PURPOSE In 2012, ERM assisted Azura Power West Africa Ltd (hereafter referred to as “Azura”) in developing the Environmental and Social Impact Assessment (ESIA) for the Azura-Edo 450 MW Independent Power Project in Nigeria (hereafter referred to as “the Azura Project” or “the Project”). The final ESIA report was disclosed by the World Bank in 2012 and approved by the Nigerian government in February 2013 following a Panel Review and Public Hearing (Approval Ref: FMenv/EA/EIA/123.1693/Vol. 1/212). Following on from this approval, Azura continued with the detailed design of the Project and selected a preferred contractor to build and operate the plant. As the detailed design developed, certain aspects of the original design changed. This report assesses the environmental and social impacts of these changes and serves as an update to the original EIA Report. 1.2 BACKGROUND 1.2.1 Change in Power Evacuation Design To evacuate power from the plan, a power line is required to connect the Azura plant with the existing Benin North Substation. As part of the original project design, this power line was envisaged as a high-voltage underground cable and Azura envisaged that the alignment of the connection line would not therefore be limited by the location of other surrounding structures. However, during the course of developing the detailed design for the Project, the Transmission Company of Nigeria (TNC) were not willing to introduce a high-voltage underground cable to their network. An overhead power line was therefore required and the proposed location of the Azura plant would need to change taking account of the location of the existing Benin North Substation, and the NIPP plant. 1.2.2 Change in Exhaust Stack Design When the ESIA was drafted, potential contractors were proposing a power plant based on GE technology and a four turbine/four exhaust stack configuration. The stack height was assumed to be 50 metres high. This configuration was assessed in the ESIA. Following on from this assessment, the selected contractor (a Siemens and Julius Berger consortium) proposed a design involving a three turbines/three exhaust stack configuration. In this design the stack height was specified as 35 metres. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 1 1.2.3 Comparison of Layouts The original and new plant locations are shown in Figure 1.1. As shown in the figure, the new plant location continues to be within the Azura site boundary. Figure 1.1 Site Layout ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 2 2 EVALUATION OF THE PROPOSED CHANGES In Q2 2013, Azura took action to identify any World Bank and Nigerian regulatory ESIA requirements triggered by the change in plant design. Azura consulted representatives of the World Bank directly and Environmental Accord (Azura’s in-country consultants) reviewed the relevant regulations. The following requirements were identified.  Azura are required to formally notifyo both the World Bank and the Federal Ministry of Environment (FMEnv) to communicate the change in plant location, and any associated change in environmental or social impacts and/or required mitigation and management measures. Re- submission of the ESIA is not required in this case; and  Nigerian regulatory requirements do not necessitate any revisions to the ESIA in this circumstance but do require that any changes to the agreed mitigation measures be incorporated into the overarching Project ESMP, which must be updated and submitted to FMEnv prior to project commissioning. Resubmission of the ESIA is not required in this case. In light of the above, Azura asked ERM and EnvirAccord to review the ESIA and identify any areas where further supplementary studies would be required to assess changes in environmental or social impacts and/or required mitigation and management measures. The results of that review are summarised in Box 2.1. Box 2.1 Results of the ESIA Review  The overall site boundary presented in the approved ESIA report has not changed.  The baseline studies that informed the approved ESIA report addressed all areas within the site boundary and therefore baseline characteristics associated with the Project have not changed and no update is required.  The plant will continue to be located entirely within the site boundary. As part of the ESIA, the team assumed all areas within the site boundary would be cleared during construction. This assumption is still valid and therefore impacts within the site boundary will not change and no update is required.  As part of the ESIA, the air and noise impacts associated with Project’s operational phase were assessed using a modelling approach that incorporated the original plant location. This location has now changed. An update of the assessment air and noise impact assessment for the operational phase is therefore required.  No other changes to the ESIA report (and associated ESMP) are required. In summary, evaluation of the proposed changes indicates that the environmental and social impacts and proposed mitigation measures identified in the ESIA are still valid with the possible exception of impacts associated with air and noise emissions during the operational phase. These impacts require further evaluation. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 3 To further evaluate the change, Azura commissioned:  ERM to review and update the air modelling/ assessment for the Azura Project; and  Siemens (the design engineers) to review and update the noise modelling for the Azura Project, with ERM providing an updated impact assessment based on the results of that modelling. The next section of this report (Section 3) presents the results of ERM’s work to review and update the air modelling and impact assessment. Section 4 presents the results of Siemens’ work to review and update the noise modelling and ERM’s assessment of noise impacts. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 4 3 UPDATE TO AIR MODEL 3.1 INTRODUCTION The section is structured as follows:  Section 3.2: Air Modelling and Impact Assessment Methodology – summarises the methodology underpinning the air modelling exercise and the design parameters used as input values for the model. The design parameters that were used in the original modelling exercise are also shown in this section as a reference for the reader.  Section 3.3: Air Modelling and Impact Assessment Results – presents the results of the air modelling exercise in terms of predicted emissions and impact significance. The results from the updated model and impact assessment exercise are compared to those that were predicted as part of the original modelling exercise and impact assessment.  Section 3.4: Air Modelling and Impact Assessment Conclusions – presents summary conclusions. 3.2 AIR MODELLING AND IMPACT ASSESSMENT METHODOLOGY A detailed description of the air quality impact assessment methodology is set out in the original ESIA report (see Section 5.3 of the ESIA report). The same methodology was applied during this modelling exercise. The assessment was undertaken using computer-based dispersion modelling (USEPA AERMOD model). Please refer to Section 5.3 of the ESIA report for further information. Design and Emission Parameters The design and emission parameters that were used during the original (ESIA) modelling exercise and this more recent (Addendum) exercise are shown in Table 3.1. Table 3.1 Model Parameters: Design and Emission Data Parameter Units Design Comments Original Updated Number of stacks - 4 3  As part of the original model, the 4 stacks were assumed to be co-located.  As part of the revised model, the 3 stacks are understood to be approximately 40m apart. Number of flues 1 1  No change per stack Stack height actual m 50 35  Taken from design specifications provided by Azura. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 5 Parameter Units Design Comments Original Updated Flue diameter m 7 6.2  Per stack Stack Area m2 38.5 30.2  Per stack Emission velocity m/s 26.0 13.1  Total plant emission. Volume flow rate m3/s 3,980 1,189  The volume flow rate for this newest (actual) modelling exercise was calculated based on the mass emission data provided by the design engineers and following further detailed design. This led to a more accurate estimation of the volume flow rate, when compared to the data used in the original model. Volume rate kg/s 1,672 1,497  Total plant emission. (mass)  Taken from design specifications provided by Azura. Emission Celsius 543 544  Per stack temperature (actual) NOx emissions dry 20 25  Per stack ppmv CO emissions dry 30 30  Per stack ppmv NOx emissions g/s 36.6 9.53  Total plant emission. CO emissions g/s 50 6.96  The volume flow rate for this newest modelling exercise was calculated based on the mass emission data provided by the design engineers and following further detailed design. This led to a more accurate estimation of the volume flow rate, when compared to the data used in the original model. In order to assess the potential for cumulative impacts due to the Azura Project and NIPP plant, the NIPP plant was also included in the model. No design information is available for the NIPP plant so the plant was assumed to have design parameters and emissions similar to that of the Azura Project. This same approach was used in the original assessment. As per the previous air modelling exercise, five years of meteorological data from the Bohicon meteorological station was used to provide an indication of meteorological conditions at the site. While this station is located around 400 km from the site, the meteorological conditions are generally representative of weather conditions. 3.3 AIR MODELLING AND IMPACT ASSESSMENT RESULTS The results of the modelling exercise are shown in Table 3.2 and Table 3.3. Results are shown for the “Azura Project Only” (in isolation) in Table 3.2 and for cumulative emissions for NO2 from both the Azura Project and the NIPP (in Table 3.3). The cumulative assessment only considers NO2, as CO emissions from Azura are well below the relevant standards (between 1 and 5% of the criterion). Combined CO emissions from NIPP and Azura are therefore ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 6 expected to be well below 25% of the criterion and are therefore insignificant. In all cases, the results obtained from this modelling exercise are shown in comparison to the original results that were included in the approved ESIA report. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 7 Table 3.2 Modelling Results – Azura Project Only Pollutant Averaging Basis of Source Criterion Azura Project Only Period assessment Process Contribution Significance Overall Original Updated Original Updated Outcome µg/m3 µg/m3 µg/m3 NO2 Annual Maximum EU/WHO 40 0.330 0.394 Insignificant Insignificant No change 1 hour Maximum EU/WHO 200 60.2 34.4 Minor Insignificant Improvement 1 hour Maximum Nigerian 75-113 60.2 34.4 Minor Minor No change CO 8 hour rolling Not to be exceeded EU 10000 121 39.2 Insignificant Insignificant No change average >3 times p.a. 8 hour Maximum WHO 40,000 121 39.2 Insignificant Insignificant No change 1 hour Maximum WHO 30,000 164 47.3 Insignificant Insignificant No change 1 hour Maximum Nigerian 11,400 164 47.3 Insignificant Insignificant No change Table 3.3 Modelling Results – Azura Project with NIPP Pollutant Averaging Basis of Source Criterion Azura with NIPP Period assessment Process Contribution Significance Overall Original Updated Original Updated Outcome µg/m3 µg/m 3 µg/m 3 NO2 Annual Maximum EU/WHO 40 0.49 0.45 Insignificant Insignificant No change 1 hour Maximum EU/WHO 200 41.8 42.08 Minor Insignificant Improvement 1 hour Maximum Nigerian 75-113 41.8 42.1 Minor Minor No change 3.4 AIR MODELLING AND IMPACT ASSESSMENT CONCLUSIONS As shown Table 3.2 the revisions to the plant design, along with refined calculation of the volume flow rate, have led to a reduction in predicted emissions (“Process Contribution”). As noted in Table 3.1, the new design involves a reduction in stack height from 50 m to 35 m, and the stacks are now to be separated by 40 m (as opposed to being co-located, as was assumed in the original model). This will lead to poorer dispersion, and could potentially have led to greater Process Contribution (concentration of pollutants at ground level). However, the new design involves three stacks, rather than four stacks, and the emissions from these stacks were found to be less than that predicted as part of the original modelling exercise. As a result, process contribution has decreased significantly in most cases (1). Overall impact significance has not therefore changed since the original ESIA study, with the exception of one occasion where impact significance has reduced from “Minor” to “Insignificant” (as noted in the “Outcome” column of Table 3.2 and Table 3.3) giving a better outcome for communities. As shown in Section 3.3, all impacts are considered to be insignificant, with the exception of NO2 emissions, which when analysed relative to the (1 hour maximum limit sourced from Nigerian legislation), are predicted to have minor adverse impacts. Minor adverse impacts are predicted to occur over a small area in the immediate vicinity of the plant. Significant cumulative impacts with the adjacent NIPP plant are therefore not likely to arise. In addition, due to the absence of other major sources of emissions in the vicinity of the plant, the baseline concentrations of nitrogen dioxide are expected to be substantially below the air quality standards, and therefore there is not anticipated to be a risk of air quality standards being exceeded. In light of the above outcomes, the mitigation and management measures set out in the ESIA report continue to be considered valid and appropriate for the Azura Project. 1 More refined estimation of volume flow rate and exit velocity has now become possible with the development of the detailed design. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 9 4 UPDATE TO NOISE MODEL 4.1 INTRODUCTION The section is structured as follows:  Section 4.2: Noise Modelling and Impact Assessment Methodology – summarises the methodology underpinning the noise modelling exercise and the design parameters that were used as input values for the model. The design parameters of the original project design, which were used in the original modelling exercise, are also shown in this section as a reference for the reader.  Section 4.3: Noise Modelling and Impact Assessment Results – presents the results of the noise modelling exercise in terms of predicted emissions and impact significance. The results from the updated model are compared to those that were predicted as part of the original modelling exercise and impact assessment.  Section 4.4: Noise Modelling and Impact Assessment Conclusions. 4.2 NOISE MODELLING AND IMPACT ASSESSMENT METHODOLOGY Modelling Methodology To facilitate the update of the noise impact assessment, Siemens used the CadnaA noise modelling programme and carried out sound propagation calculations as described in Box 4.1. Box 4.1 Siemens Noise Modelling Methodology Modelling was carried out in accordance with the international standards ISO 3744/46 and ISO 10494, among others. The sound propagation calculation is based on noise emissions caused by different buildings and outdoor installed equipment. These emissions were considered for the octave band centre frequencies from 31.5 Hz to 8000 Hz. In principle the sound power level determination is described in ISO3746. The calculation of the far field sound pressure levels was executed in accordance with ISO 9613-2. For the calculation of the distance dependent level reduction the following effects were taken into account.  Attenuation due to geometrical divergence  Attenuation due to ground effects (ground factor 0,5)  Attenuation due to meteorology effects (humidity 65%, temperature 20°C and downwind conditions)  Attenuation effects due to a barrier. Source: Report on the Sound Propagation Approach Azura-Edo IPP – 3xSSC5-2000E (Siemens, 2013) Impact Assessment Methodology A detailed description of the original noise impact assessment methodology is set out in the ESIA report (see Section 5.4.1 of the approved ESIA Report). The ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 10 assessment criteria for residential receptors are taken from IFC guidelines (1) which require that noise impacts should not:  exceed 55 dBA (Criteria 1) during day-time (07:00 – 22:00);  exceed 45dBA (Criteria 2) during night-time(22:00 – 07:00); or  lead to an increase in background levels of 3 dB at the nearest receptor location off-site. ERM notes that the most stringent of the three criteria set out above is applied when interpreting the noise levels at each noise sensitive location. The impact categories that were established for residential receptors is summarised in Table 4.1. The same impact assessment methodology was applied for this updated assessment i.e. no change to the original methodology is required. Table 4.1 Impact Assessment Methodology for Operational Noise at Residential Receptors Major Moderate Minor Negligible Insignificant Noise level 3 - 5 Noise level between Noise level 6 - 10 dB Noise level below Noise below dB above >10 dB above criteria above criteria and criteria but 1-2 dB criteria and ≤ criteria and and baseline baseline above baseline baseline baseline Design Information – For Input into the Model The model parameters and input data that were used during the original (ESIA) modelling exercise are shown in Table 4.2. The model parameters and input data that were used in this more recent (Addendum) exercise are shown in Table 4.3. Table 4.2 Original Model Parameters and Input Data Noise Source Sound Power Level, Lw dBA OCGT (Turbines) 82 dBA at 1m Waste Heat Stack 92 dBA Lw (1) Fin Fan Coolers 85 dBA at 1m Other Information Number of stacks 4 Turbine Building Design Double skin cladding or equivalent Duration of Construction Phase: Approximately two years Proposed Working Hours During Construction: 0700 – 1800 Mon - Sat. (1) Sound Power Level re 10-12 Watts 1 Environmental, Health and Safety (EHS) Guidelines. General EHS Guidelines. Section 1.7 Environmental Noise Management. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 11 Table 4.3 New Model Parameters and Input Data Noise Sources Sound power level LW dBA Unit 11/12/13 114 Gas Turbine Buildings UMB (facades, doors, gates, HVAC) 104 Endorsed Gas Turbine Generators 106 Gas Turbine Filter Houses 110 Transformers 110 Power Control Centres 94 Exhaust System UNIT 11/12/13 115 Diffuser Extension Ducts 110 Elbow Casings 113 Stacks 104 Fuel Gas Systems 109 Fuel Gas Reducing Station 108 Fuel Gas Preheating Metering & Filtering Skids 103 Fuel Gas Pipes 94 Common Buildings 97 Water Treatment Plant Container 91 Control Room & Administration Building 94 Workshop & Storage Building 91 Fin Fan Cooler 107 Lube Oil Fin Fan Coolers 106 Fin Fan Cooler Pumps 101 Sound Power Level, Overall 119 Other Information Number of stacks 3 Turbine Building Design Double skin cladding or equivalent Duration of Construction Phase: Approximately two years Proposed Working Hours During Construction: 0700 – 1800 Mon - Sat. Source: Siemens Siemens note that the current plant design includes a number of sound attenuation devices, which have been incorporated into the design in order to minimise adverse noise impacts. These include:  silencers for HVAC system at suction and pressure sides;  noise suppression building for the gas turbine generators;  sound barrier walls along the exhaust system; and  silencers at air intake system and exhaust stack. ERM notes that no reliable information is available to facilitate detailed noise modelling of the NIPP plant. The design of the plant is not available for review and the noise emission data produced in the ESIA for the project is not sufficient to inform a noise modelling exercise. As a consequence of this, the ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 12 NIPP plant was assumed to be similar in design to the Azura plant, for the original ESIA assessment, except Azura understands that it has one extra turbine. For this updated modelling exercise, the team endeavoured to obtain further information regarding the NIPP plant but no information was available. As a consequence, the NIPP plant was again assumed to be similar in design to the Azura Plant except it has one extra turbine. Measures have been put in place, as described later in this report, to address this issue and refine the assumptions that underlie the model. Baseline Noise Levels In the original ESIA, the report refers to the ambient baseline monitoring that was carried out by NIPP, prior to construction of the NIPP having started. The monitoring results from those surveys are presented in Table 4.4. Table 4.4 NIPP Survey of Ambient Noise Monitoring Results Measurement Location Wet season Dry season LAeq dBA 33 33 34 33 IHVB1 34 34 33 34 33 33 33 33 IHVB2 34 35 34 35 33 33 33 31 IHVB3 34 34 35 35 34 32 34 32 IHVB4 35 35 35 31 33 31 33 33 IHVB5 34 34 34 34 34 32 33 32 IHVB6 34 35 34 35 34 32 IHVB7 35 32 ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 13 Measurement Location Wet season Dry season LAeq dBA 34 35 34 35 35 33 34 34 IHVB8 34 34 33 45 35 39 34 38 IHVB9 35 39 34 44 33 35 33 35 IHVB10 34 45 33 45 Average 34 dBA 37 dBA As indicated in Table 4.4, the average overall for the NIPP site and surrounds is 34 dB (A) during wet season and 37 dB (A) during the dry season. The baseline noise levels are therefore considered to be below the IFC Noise Level Guidelines for daytime, 55 dBA LAeq, 15hr, and 45 dBA LAeq, 9hr, for night time for residential, institutional or educational receptors. A survey of ambient noise levels was carried out at the time of ESIA development to further substantiate and validate the results obtained by the NIPP survey team. However, construction activities at the neighbouring NIPP plant, caused the measurements to be erroneously high and not representative of the ‘natural’ baseline. As a result, the initial ESIA assessment was developed using the NIPP data. NIPP continues to be under construction and some plant commissioning is already underway, which excludes the possibility of additional baseline noise monitoring at this time. As a result, the assessment that follows continues to be reliant on the NIPP data and provisions have been put in place (as described later in this report) to address this issue going forward. For the purpose of later calculations of impact, ERM has assumed an average baseline noise level of 36 dBA i.e. the logarithmic average of the wet season and dry season NIPP measurements given in Table 4.4. 4.3 NOISE MODELLING AND IMPACT ASSESSMENT RESULTS To assess noise impacts during the operational phase, Siemens calculated noise levels at a number of Noise Sensitive Locations (NSLs) around the project site. The NSLs that were selected are shown in Table 4.5 and Figure 4.1. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 14 As shown in the figure, many noise sensitive locations are along the site boundary (‘fence-line’) and at the locations of communities surrounding the site. Of these, three locations would be most representative of the village centre (ie the greatest concentration of dwellings). These are NSL1, NSL24, and NSL49. There are however individual and small clusters of dwellings scattered around the site. Table 4.5 Noise Sensitive Locations around the Project Site Coordinates, metres UTM Zone 31N Noise Sensitive Locations Easting Northing 4 796678.72 707701.84 24 796855.25 707817.12 37 797256.4 707673.51 8 798062.65 709798.84 49 797469.93 709531.98 L017 797080.9 709828.74 L053 796787.93 709753.42 1 795968.32 709474.32 SN_116 796001.52 709124.05 SN_254 796192.02 708682.39 SN_72 796626.04 710014.49 ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 15 Figure 4.1 Noise Sensitive Locations around the Project Site The predicted noise levels at each of the NSLs are shown in Table 4.6. For each NSL, three scenarios are presented:  Scenario 1: Specific noise level from the Azura plant;  Scenario 2: Specific noise level from the NIPP plant; and  Scenario 3: Cumulative noise emissions from both the NIPP plant and Azura plant. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 16 Table 4.6 Predicted Noise Levels at Selected NSLs – relative to IFC Night-time Criterion and Baseline levels Scenario 1: Azura Plant Scenario 2: NIPP Plant Scenario 3: Azura Plant & NIPP Plant (Specific) (Specific) (Cumulative) NSL Modelled Noise Exceeds Night Time Exceeds Modelled Exceeds Night Time Exceeds Calculated Exceeds Night Exceeds Level Criterion1 Baseline2 Noise Level3 Criterion1 Baseline2 Noise Level3 Time Criterion1 Baseline2 4 35 -10 -1 41 -4 5 42 -3 6 24 36 -9 0 43 -2 7 44 -1 8 37 35 -10 -1 40 -5 4 41 -4 5 8 36 -9 0 38 -7 2 40 -5 4 49 43 -2 7 44 -1 8 47 2 11 L017 43 -2 7 42 -3 6 46 1 10 L053 46 1 10 44 -1 8 48 3 12 1 43 -2 7 40 -5 4 45 0 9 SN_116 45 0 9 43 -2 7 47 2 11 SN_254 44 -1 8 46 1 10 48 3 12 SN_72 43 -2 7 40 -5 4 45 0 9 Source: Calculated based on noise modelling data provided by Siemens Note: Noise emissions that exceed the night-time threshold are illustrated in red font. The significance of exeedances relative to the night-time threshold and baseline levels is indicated by the colour coding of significance in accordance with the colour-coding approach shown in Table 4.1. 1 Night time limit is 45 LAeq dBA 2 Baseline noise level is assumed to be 36 dBA, calculated as the logarithmic average of day-time and night-time levels recorded by NIPP – see Table 4.4. 3 Buildings, sound barrier wall along plant fence and other surfaces of Azura Edo are not considered ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 17 Table 4.7 Summary Impact Assessment – Comparing Original Assessment with New Assessment = Positive change in impact significance = Negative change in impact Legend: = No change in impact significance (improvement) significance Scenario 3: Azura Plant & NIPP Plant Scenario 1: Azura Plant Scenario 2: NIPP Plant NSL (Cumulative) Impact Significance Overall Impact Significance Overall Impact Significance Overall Original New Outcome Original New Outcome Original New Outcome 4 Negligible Insignificant + Minor Minor / Moderate Moderate / 24 Negligible Insignificant + Moderate Moderate / Moderate Moderate / 37 Insignificant Insignificant / Minor Minor / Minor Minor / 8 Insignificant Insignificant / Negligible Negligible / Negligible Minor - / - 49 Insignificant Moderate - Moderate Moderate Moderate Major L017 Insignificant Moderate - Moderate Moderate / Moderate Moderate / L053 Insignificant Moderate - Moderate Moderate / Major Major / 1 Insignificant Moderate - Moderate Minor + Moderate Moderate / SN_116 Negligible Moderate - Moderate Moderate / Major Major / SN_254 Moderate Moderate / Major Moderate + Major Major / SN_72 Insignificant Moderate - Moderate Minor + Moderate Moderate / 1 Night time limit is 45 LAeq dBA 2 Baseline noise level is assumed to be 36 dBA, calculated as the logarithmic average of day-time and night-time levels recorded by NIPP – see Table 4.4. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 18 4.4 NOISE MODELLING AND IMPACT ASSESSMENT CONCLUSIONS. Noise during operation is expected to be generated by various components of the Azura Edo IPP, including the gas turbines and associated fin-fan coolers exhaust system, fuel gas systems and common buildings. The impact assessment findings as shown in Table 4.7 can be summarised as follows.  Specific Noise from the Azura Project (Scenario 1): The results of the modelling indicate that noise emissions from the Azura plant would be below the day time threshold of 55 dBA at each of the NSLs. Specific noise emissions are also generally below the night-time threshold of 45 dBA with only one exceedence (of 1 dBA) at one NSL. When compared to baseline noise levels, exceedences of 7 to 10 dBA are predicted, giving Moderate impacts.  Cumulative Noise from the NIPP Project and Azura Project (Scenario 3): Cumulative noise emissions from the NIPP and Azura plant are below 55 dBA at all NSLs and exceed the night time limit at five NSLs. When compared to baseline noise levels, exceedences of 4 to 12 dBA are predicted, giving Moderate impacts. The impact of these exceedences is considered to be Minor or Moderate in most cases (at seven out of eleven of the NSLs). Major impacts are predicted to occur at four NSLs where noise levels exceed the night time threshold by ≤3dBA but exceed the baseline by >10 dBA. The original impact assessment rating that was predicted as part of the approved ESIA Report is shown in Table 4.7 (1). As shown in the table, in the majority of cases, the predicted noise impacts have not changed. The changes that have occurred can be explained as follows:  NSLs to the south of the site are likely to experience noise impacts of lower significance as the power plant is located further away from those locations; and  NSLs to the north of the site will experience noise impacts of greater significance as the power plant is now closer their location. With respect to the interpretation of the results, the following uncertainties should be considered:  The baseline level of 36 dBA is an average estimated from the NIPP monitoring data from a number of years ago. It has not been possible to update or refine the baseline estimations as construction and commissioning of the NIPP plant was underway by the time the Azura EIA commenced; supporting noise emission data from the original assessment is (1) The presented in Annex B. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 19  The design for the NIPP plant was assumed to be the same as the Azura design. In reality this is unlikely to be the case and therefore there is some uncertainty in the estimation of cumulative noise emissions. Modelling of noise emissions from the plant at the new location indicates that at certain noise sensitive locations, the cumulative noise from the Azura Plant and NIPP plant would exceed the IFC thresholds during the night time and cause significant increase of ambient noise levels. Given the uncertainty that exists regarding baseline noise and determination of NIPP noise emissions, further study is warranted to ensure that predicted levels are accurate and to facilitate identification of any further abatement measures that may be required. The following actions are recommended.  Implement the relevant noise mitigation measures that are specified in the current approved EIA Report, as shown in Annex A.  Ensure the design of the plant continues to incorporate and reflect appropriate best practice and includes the following sound attenuation devices, which have been incorporated into the design in order to minimise adverse noise impacts: - silencers for HVAC system at suction and pressure sides; - noise suppression building for the gas turbine generators; - sound barrier walls along the exhaust system; and - silencers at air intake system and exhaust stack.  Conduct a new noise survey to: - verify baseline noise levels at identified sensitive noise locations for the daytime and night time periods and obtain noise measurements that are representative of the rural nature of the area, without interference from industrial activity; and - determine and evaluate noise emissions from the operating NIPP plant.  Revise the noise model and noise emission calculations to reflect the new data obtained.  If predicted noise levels at sensitive locations are confirmed to above the relevant criteria through modelling and/ or direct measurement, develop further mitigation measures to reduce noise levels at the NSLs to within the IFC thresholds of 45 dBA (nighttime). Such measures may include further abatement at the noise sensitive locations e.g. barriers or earthen bunds, insulation of dwellings or resettlement of individual households where applicable. Collaboration with the NIPP plant may also be required in the future to maximise the efficiency and effectiveness of any investment in further noise abatement. As per the original ESIA Report (Non-Technical Summary pXXXV), the cumulative noise impacts are considered to be Major prior to mitigation, but are considered insignificant after the implementation of further design ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 20 alterations and modelling prior to operation, monitoring and construction of barriers if necessary. ENVIRONMENTAL RESOURCES MANAGEMENT AZURA POWER WEST AFRICA LTD. 21 Annex A Excerpts of the approved ESIA Report Section 7: Project ESMP Highlighting Air and Noise Mitigation and Management Commitments The mitigation measures for air quality and noise impacts are set out in the following sections of the approved ESIA Report:  Subsections of Section 7 Environmental and Social Management Plan;  Annex C: Traffic Control Management Plan  Annex E: Occupational Health and Safety Management Plan (Construction); and  Annex G: Unplanned Events and Emergency Response Plan The Environmental and Social Management Plan (Section 7), which was approved as part of the ESIA Report is presented overleaf. The noise and air mitigation measures are highlighted and underlined in blue. Table 1 Design Phase: Environmental and Social Management Measures Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Costs USD) 1.1 Waste Impacts Ensure  Identify a licensed waste disposal facility in Port In Copies of Prior to Azura Power Costs responsible Harcourt for general and hazardous wastes and accordance corresponden construction associated waste disposal confirm that required capacity exists for disposal with ce with and minimise during construction and operational phases. Nigerian identification contamination legislation and inspection (approx 2,000 USD) 1.2 Key impacts Minimise  Implementation of an international standard RAP. Adherence to The RAP will Pre- Azura Power To be identified due to amount of  Ensure that sacred sites are relocated in close the IFC set out construction determined physical physical consultation and negotiation with traditional Performance monitoring phase and based on the resettlement: resettlement religious leaders, with appropriate monitoring. The Standards requirements throughout outcome of  Loss of physical required, implementation measures will be outlined in the the Project RAP assets; where possible. Physical Cultural Resources Management Plan; Grievance  Loss of cultural mechanism sites; records  Loss of land; and  Loss of productive agricultural land. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Costs USD) 1.3 Key economic Minimise  Implementation of a RAP to WB/ IFC standards. Adherence to The RAP will Pre- Azura Power To be resettlement impacts on the IFC set out construction determined impacts include: employment Performance monitoring phase and based on the  Loss of on-going legacy issues Standards requirements monitoring outcome of income; associated with throughout RAP  Loss of initial the change in Grievance the Project investment for land use. mechanism establishing records crops;  Inability to repay loans;  Reduced income and economic activity;  Increased food insecurity; and  Increased tensions between stakeholders and the government. 1.4 Anticipated impacts Ensure good  Appoint CLO to liaise with the local communities. Grievance Ensure that Prior to EHS Cordinator Salary cost on local culture communicatio  Implementation of the Physical Cultural Resources mechanism grievance contruction for CLO resources n between Management Plan; and records mechanism is (approximate Azura and  Establish a Grievance Mechanism. in place ly 15,000 local USD per communities annum) Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Costs USD) 1.5 Anticipated impacts Ensure the  Site design to consider retaining as many floral Biodiversity Ensure that Prior to Azura Power Approximate on biodiversity protection and species as possible, and the relocation of those that Management the measures contruction ly 10,000 preservation of cannot be retained and protected; and Plan (BMP) identified in USD endangered  Mark and protect any Threatened floral species on including a the BMP are and vulnerable site. record of the implemented faunal and abundance floral species and distribution of threatened floral and faunal species 1.6 Noise impacts Ensure that  Undertake further modelling and design refinement Modeling Confirmation During Azura Power Approximate cumulative to confirm cumulative noise impact results prior to results of detailed 15,000 USD noise impacts operation and construct noise barriers at the nearest Documented requirement design are minimised noise sensitive locations (see Chapter 9) if required. grievance for barrier to Submit results to FMENv; mechanism reduce noise  Establish grievance mechanism for local community document at the nearest members to register complaints; noise sensitive locations Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Table 2 Construction Phase: Environmental and Social Management Measures Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD) 2.1 The anticipated Minimise  Apply liquid asphalt to prevent surface erosion: loosely The IFC Visual Daily EHS Part of HSE negative deterioration bonded coarse-grained surfaces: 1.4 ℓ/ m2 or 3.6 ℓ/ m2; Performance inspection Coordinator Coordinator’ ambient air of current  Use binder material for erosion and dust control for long Standards and Azura Power s duties quality impacts ambient air term exposed surfaces; photographic are: quality by  Use covered trucks for the transportation of materials that The WHO record  Dust minimising release dust emissions; and EU emissions; dust  Regular cleaning of equipment, drains and roads to avoid Emission and emissions. excessive build up of dirt and mud; Standards  Vehicle  Water suppression or dust extraction fitted to construction Emissions. equipment where possible; Nigerian  Spray surfaces prior to excavation and clearing; Emission  Speed limit on-site of 15 kph on unhardened roads and Standards surfaces; and  Avoid dropping material from heights.  Avoid heating bitumen with an open flame and avoid overheating. 2.2 Noise impacts Minimise  Develop a detailed plan that relates to noise control for Noise at Noise Weekly HSE Cost from general noise relevant work practices and discuss this with construction sensitive monitoring at Coordinator, associated construction nuisance to staff during health & safety briefings; receptors to sensitive Azura Power with monthly noise sensitive  Avoid dropping materials from height, where practicable; not exceed receptors noise receptors  Avoid metal-to-metal contact on equipment; Nigerian and monitoring  Avoid mobile plant clustering near residences and other WHO limits (approx 500 sensitive land uses; USD)  Ensure periods of respite are provided in the case of unavoidable maximum noise level events; No other  Inform all potentially impacted residents of the nature of costs works to be carried out, the expected noise levels and assuming duration, as well as providing the contact details of the that further CLO; noise  Train construction staff on noise control plan during reduction health & safety briefings; controls are  Enforce rest periods for unavoidable maximum noise level not needed events;  Select ‘low noise’ equipment, or methods of work; Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD)  Use most effective mufflers, enclosures and low-noise tool bits and blades;  Investigate use of alternatives to audible reversing alarms (such as broadband noise emitting models) or configure to maximise forward movements of mobile plant;  Use alternatives to diesel/petrol engines and pneumatic units, such as hydraulic or electric-controlled units, where feasible and reasonable;  Use temporary noise barriers for small equipment, where required;  Reduce throttle settings and turn off equipment and plant when not used; and  Regular inspection and maintenance of all plant and equipment; and  Perform ongoing monitoring of noise levels at the nearest noise sensitive locations (see Chapter 9) and submit results to FMEnv. 2.3 Terrestrial Soils Minimise soil  Effective site drainage including cut-off drains to divert Visual Visual Daily HSE Part of HSE and Geology loss, reduce surface runoff from exposed soils or construction areas; inspection inspection Coordinator, Coordinator’  Removal of erosion and  Construct temporary drainage channels to channel and and Azura Power s duties soils and decrease, risk divert surface water away from any down slope land and photographic earthworks of siltation of agricultural plots; record  Soil water  Install oil/ water separators and silt traps before effluent compaction resources leaves the site;  Increased and risk of  Implement low impact excavation, in-fill and trenching erosion and contaminatio methods; sedimentatio n  Minimise bare ground and stockpiles to avoid silt runoff; n of water  Rehabilitate and revegetate cleared areas before the next resources wet season;  Potential  Bunding of areas where hazardous substances are stored contaminatio (eg fuel, waste areas); and n from spills  Develop and implement of a waste management plan (as part of the ESMP). 2.4 Water Resource Prevent  Placement soil stock piles to reduce exposure to wind or Effluent Water quality Every HSE Cost for impacts: contaminatio water; quality monitoring three Coordinator, sampling and  Potential n of water  Reduce or prevent off-site sediment transport using meeting before months Azura Power analysis of Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD) contaminatio resources appropriate methods such as effective site drainage, and Nigerian, effluent liquid n from sediment/silt trapping mechanism. WHO and leaves the effluent and borehole  Use cut-off drains to divert surface runoff from exposed World Bank site receiving construction, soils or construction areas; requirements water bodies accidental  Install oil/water separators and silt traps before effluent spills and leaves the site; (approx 1,000 increased  Design permanent drainage installations for heavy rainfall USD for set- erosion events and protect stormwater channels using slope up and 5,000  Water use limitation techniques, rip-rap and lining; USD for each  Store hydrocarbons, fuels, lubricants and chemicals in monitoring bunded and lockable oil storage containers, with hoses and event) gauges kept within the bund.  Regular checking and maintenance of all plant and machinery to minimise the risk of fuel or lubricant leakages;  Remove all water accumulation within bunds using manually controlled positive lift pumps not gravity drains;  Training of relevant staff in safe storage and handling practices, and rapid spill response and cleanup techniques;  Minimise stockpiling, 10 m buffer zone between drainage channels and stockpiles (leaving existing vegetation in place and shield stockpiles using geotextiles if necessary;  Minimise vegetation clearing and re-vegetate bare soil before the wet season;  Adequate sewage collection and treatment of sewage on site;  Adequate collection and disposal of sludge on site;  Line all areas for concrete mixing; and  Separate all waste on site and locate waste storage areas on hardstanding (or bunded). 2.5 Biodiversity Minimise  Limit vegetation clearing to what is absolutely necessary; Hectares of Visual After HSE Part of HSE Impacts related habitat loss,  Cleared areas not required for buildings, facilities or rehabilitatedinspection constructi Coordinator, Coordinator’ to: potential infrastructure should be revegetated or covered with land and on Azura Power s duties  Clearing of soil/ water hardstanding; photographic vegetation contaminatio  Clearly demarcate work areas to limit disturbance; Implementati record and habitat, n and  Mark and protect any Threatened floral species on site; on of  disturbance disturbance  Development of a BMP enlisting the services of an measure Daily Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD) of fauna due of fauna entymologist and botanist. This will include demarcation to noise, of floral and faunal species to avoid accidental damage dust, traffic during construction, and the retention or relocation of  potential Threatened species creating suitable habitats; contaminatio  Establish habitat corridors where possible; n of soil and  Ensure driver training on ecological sensitivities and water driving techniques to minimise fauna disturbance  Establish and enforce speed limits of 25 km/h on site;  Train all staff on ecological sensitivities to ensure that they are aware of any specific migratory routes for faunal species, are able to identify species of a Threatened status and an enforcement of an anti-poaching policy;  Implement effective site drainage, and sediment/silt trapping mechanism;  Implement dust suppression measures (such as spraying) if required;  Protect storm water channels from erosion to reduce downstream siltation;  Use excavation, infill and trenching methods that minimise the disturbance on soils and vegetation directly on and around the site;  Design permanent drainage installations for heavy rainfall events with sufficient capacity for 1: 50 year rainfall events;  After construction, rehabilitated and revegetated disturbed areas as this is feasible; and  Avoid tall mast lights if possible. 2.6 Waste impacts Reduce  The EPC contractor will develop a waste management plan Visual Visual Daily, HSE Part of HSE related to contaminatio with requirements for separation, handling and disposal of inspection inspection throughou Coordinator, Coordinator’ potential n of water all wastes. This will be complemented by the development and t Azura Power, s duties contamination and soil of waste management license by Azura Power across all photographic constructi EPC contractor of water resources Project phases ; record on resources and  All waste disposal in line with Nigerian requirements at a soil suitable and licensed waste disposal facility. It is proposed that the services of a waste disposal facility in Port Harcourt will be used;  Use spoil for on-site levelling and compaction as much as possible; Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD)  Make cleared vegetation available for removal by local communities; and  Separate and store waste on hardstanding. 2.7 Impacts to the Minimise  Protocols for camp and workforce management; Adherence to Internal Througho Internal Part of demographic impacts on  Prioritising local employment; the IFC monitoring ut Monitoring normal profile due to local  Transparent recruitment process; and Performance regarding constructi Azura Power operations influx of demographic  Establishing a grievance mechanism. Standards local on is responsible workers and job s due to employment and for seekers include: influx should be external  Population done by HR monitoring increase; Manager and related to  Change to or influx, stress the gender Communicati on balance; on Manager infrastructure  Change in and external should be age profile; monitoring done by  Increased should be government. social either done tensions; and by  Change to government the ethnic or structure. consortium of industry. 2.8 Anticipated Minimise  Develop and implement a Local Employment Strategy; Adherence to RAP will Througho RAP will Part of CLO impacts on local disruption to  Management protocols for camp and workforce; the IFC outline ut define the routine culture during traditional  Establish a grievance mechanism; Performance monitoring constructi responsibility duties construction practices and  Ensure that traditional leaders are formally involved in the Standards requirements on include: worship due Project development process; and . Religious  Disruption of to influx  Carry out the RAP and implement proposed mitigation Chiefs and traditional measures. traditional customs in leader should local be involved communities; in  Disruption of monitoring. existing authority systems due to formal Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD) approval and development process of the Project; and  Disruption of local worship practices potentially creating significant tension with the communities. 2.9 Impacts to Maximise  Continued operation of the Local Supplier and Contractor Nigerian The Local Througho The Local Cost of employment impacts on Development Unit; labour law Employment ut Employment training and economy employment  Local Employment and Local Procurement Policies and the IFC and Local constructi and Local programmes are likely to and the local including requirements for local worker, engagement with Performance Procurement on Procurement (approx include: economy local communities and clear communication of Standards Policies will Policies will 10,000 USD  Generation of during procurement policies and criteria for employment outline define the over the direct, operation. opportunities; monitoring responsibility. construction indirect and  Training programmes to develop local workforce and requirements period) induced supplier capacity; employment;  On-the-job training to all Project staff associated with their  Increase in role; and household  Disclosure of employment and procurement information. income through wages and Project spending;  Increase in economic activity among local businesses; and  Development of skills Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD) through job training and applied work experience. 2.10 The main Minimise any  Develop and implement Community Investment plan Adherence to The Througho The Part of EHS impacts to increase in which will include the potential distribution of power to the IFC Community ut Community Coordinator’ infrastructure pressure on local communities (it will not include payment for Performance Investment constructi Investment s duties will be infrastructure transformers, pre-paid metres etc); Standards and Influx on and Influx associated with and services  Influx Management Plan; Management, Management, the influx of associated  Traffic Management Plan and conduct associated detailed Plans and the Plans along opportunistic with influx of Traffic Study to inform its development; RAP will with RAP will job seekers, workers and  Detailed rehabilitation and implementation framework as outline define the including: job seekers a part of the RAP; and monitoring responsibility.  Increased  Regular monitoring of water quality in local communities requirements pressure onto to identify incidences of contamination and respond Azura Power overburdene appropriately. is primary d responsible for infrastructure preparing the services; plans.  Increased household waste and the inability to dispose of this safely;  Pressure on water resources; and  Disruption to road access from Project vehicles. 2.11 Possible health Minimise  Local Employment Strategy; Nigerian The Througho The Part of impacts: impacts of a  Traffic Management Plan; labour law Occupational ut Occupational normal  Psychological new  Workforce management protocols; and the Health and constructi Health and operations impacts workforce on  Encourage the construction workforce to undergo testing Adherence to Safety on Safety associated community (Azura and contractors) for sexually transmitted infections the IFC Management Management Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD) with influx of health and (STIs); Performance Plan and Plan and outsiders and wellbeing  Health awareness programme incorporating an HIV/AIDS Standards Community Community disruption to during awareness and prevention program which will include Health and Health and local culture construction. voluntary testing, the provision of condoms, and education Safety Safety and impacts of the workforce and local communities; Management Management due to unmet  Communication of Project transport plans; Plan will set Plan will expectations  Grievance mechanism; out define the for local  Establish parameters around use of security forces to monitoring responsibility employment support the Project; requirements for managing and  Risk Assessment reviewing the safety risks of the gas the procurement; pipeline and transmission line. The results of which will be performance.  Physical included in the updated EMP; Azura Power impacts due  Ensure that all contractors maintain HSE plans and review will be to noise and plans for prior to contract awards. All contractors to responsible for dust comply with Azura Power’s occupational health and safety the preparing pollution; guidelines and standards for general work practices, hours the concerned  Impacts to of work, air emissions, noise and light; and. plan. physical  Consider investing in local health care facilities, and health due to supporting them in carrying out ongoing monitoring of the community health profile in the area. interactions;  Safety risk associated with heavy traffic and laying of the gas pipeline and the transmission line; and  Psychological stress and possible physical impacts associated with tensions. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD) 2.12 Potential Minimise the  Registration and regular communication with the nearby Nigerian Emergency Prior to Azura Power Part of workplace likelihood of health care facilities; H&S law Response and will have the normal health and incidents  Treatment of any cases of infectious diseases contracted (Nigerian Plan, throughou responsibility operations safety impacts: occurring in and accidents that occur in the workplace; Institute of Occupational t to prepare the  Physical the  Worker induction and awareness-raising regarding disease Safety Health and constructi plans, within health workplace. In vectors. Professionals, Safety on the plans impacts addition  Daily toolbox talks prior to commencement of construction Factories Act Management individual associated protecting activities; 1990), the Plan, responsibilities with noise the health of  First aid training with first aid certificates; adherence to Employment will be and dust employees the IFC and detailed  The provision and enforcement of use of appropriate PPE; pollution; from Occupational Workforce  Mandatory job-specific H&S;  Physical contracting Health and Policy and  Develop camp and workforce management protocols that health infectious Safety Spill reflects Azura Power’s H&S standards and contractually impacts of diseases. Guideline Response require all contractors to comply as minimum standard; infectious and incidents Plan  Conduct Risk Assessment for gas pipeline and power diseases record will set out station and update EMP with results; prevalent in monitoring  First aid kits and defibrillators made available at several the area requirements locations at the plant; (vector,  Warning signs in place, including those for the electrical water and and mechanical equipment safety warning, and chemical food borne hazard warning; diseases)  Establish a reporting system for reporting to the Edo State  Exacerbation Government’s Ministry of Employment, Labour and of health Productivity; and impacts due  Plan clearance and construction techniques to reduce to interaction potential breeding grounds for disease vectors and with implement spray programme if necessary. residents from the surrounding area.  Impacts relating to any accidents that occur on and around site including safety risks posed by the Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # impact Outcome Indicator Frequency Cost (USD) gas pipeline and laying of the transmission line. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Table 3 Operational Phase: Environmental and Social Management Measures Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.1 The negative air Emissions  Dry low NOx combustion system; The IFC Emissions Monthly HSE Cost of quality impacts limited to  However all vehicles used should be regularly Performance monitoring. Coordinator, ambient air predicted during minimise maintained; and Standards Details to be Azura Power monitoring operation are impact on  Emissions monitoring for NOx. The WHO agreed with with programme: related to the human and EU FMEnv prior subcontractors (approx 1,000 following: health. Emission to operation. if necessary USD for set-  Process Standards up costs; emissions (NOx Nigerian 2,000 USD and CO); Emission for sampling  Cumulative Standards and analysis process per emissions (NOx monitoring and CO); event. Stack  Greenhouse gas monitoring: emissions approx (which exceed 20,000 USD the IFC per year) Performance Standard 3 for Pollution Prevention and Abatement threshold for a single project/ development of 100 kilo tonnes CO2- equivalents per year) Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.2 Noise nuisance Reduce  Air conditioning/air flow requirements shall be designed Noise levels Noise Monthly HSE Cost impacts from noise to take account of noise breakout; below IFC monitoring. Coordinator, associated general operations nuisance at  The fitting of a silencer into the exhaust gas system; limits Details to be Azura Power with monthly receptors  Design gas turbine building (including air conditioning, agreed with with noise walls, roof, windows and doors) to have a high noise FMEnv prior subcontractors monitoring reduction rating and ensure that there are no significant to operation. if necessary (approx 500 gaps; USD)  Configure plant layout and orientation to minimise noise;  Use acoustic enclosure/ absorption materials in internal No other walls; costs  In cases where noise levels cannot be reduced below assuming guideline levels, the Project will investigate the relocation that further of these households; noise  Implementing design measures such as attenuators on reduction the stacks, cladding on the turbine building and/ or controls are noise barriers to reduce noise level requirements of not needed 45dBA at the closest noise sensitive receptors; and  Establish a grievance mechanism. 3.3 Terrestrial Soils Minimise  No open ground left unpaved or rehabilitated and Visual Visual Daily HSE Part of HSE and Geology soil loss, revegetated. inspection inspection Coordinator, Coordinator’ including: reduce  To the extent possible covering large areas of the site with and Azura Power s duties  Increased runoff erosion and gravel (or similar material) to allow for greater photographic and potential decrease, permeability particularly during heavy rains. record erosion risk of  Development and implementation of a waste  Potential siltation of management plan. contamination water  Effective operation of the wastewater treatment plant. from spills resources  Effluent flowing offsite to comply with FMEnv and risk of requirements for disposal of effluent offsite. contaminati on Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.4 Water Resource Prevent  Ensure location of storage areas for hazardous substances Effluent Water quality Monthly HSE Cost for impacts: contaminati on hardstanding (or bunded, if suitable) to prevent quality monitoring Coordinator, sampling and  Potential on of water potential contamination, including areas around gauges, meeting before Azura Power analysis of contamination resources pumps, sumps and loading /unloading areas; Nigerian, effluent liquid from accidental  Diesel storage tanks and components to meet WHO and leaves the effluent and spills and international standards for structural design and World Bank site receiving increased integrity; requirements water bodies erosion and  Provide cathodic protection inside steel tanks and piping, runoff if required. (approx 1,000  Water use  Periodic inspection for corrosion and integrity of storage USD for set- tanks, pipes and components and regular maintenance up and 5,000 pipes, seals, connectors and valves and other USD for each components. monitoring  All tanks to be equipped with alarms, automatic shut-off event) devices and catch basins.  Construct stormwater channels and oilwater separators in diesel storage, handling and transfer areas.  Develop Spill Control and Response plans.  Monthly monitoring programme of effluent released from the site.  Monthly groundwater monitoring, especially for hydrocarbon leaks. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.5 Biodiversity Minimise  Security and work lighting (both during construction and Implementati Visual Daily HSE Part of HSE impacts resulting soil/ water operation) will be shielded and directed downwards to on of inspection Coordinator, Coordinator’ from disturbance contaminati prevent side-spill; measure and Azura Power s duties of fauna due to on and  Avoid tall mast lights if possible; photographic noise, dust, traffic disturbance  Ensure driver training on ecological sensitivities and record to fauna driving techniques to minimise fauna disturbance  Establish and enforce speed limits of 25 km/h on site;  Implement the BMP enlisting the services of an entymologist and botanist where necessary;  Train all staff on ecological sensitivities to ensure that they are aware of any specific migratory routes for faunal species, are able to identify species of a Threatened status and enforce an anti-poaching policy;  Mark and protect any Threatened floral species on site; and  Implement effective site drainage, and sediment/silt trapping mechanism. 3.6 Waste impacts Reduce  The Operator to develop and implement a waste Effluent Visual Monthly HSE Part of HSE related to potential contaminati management plan which includes requirements for quality inspection Coordinator, Coordinator’ contamination of on of water separation, handling and disposal of waste including the meeting and Azura Power. s duties water resources and soil production of sludge; Nigerian, photographic EPC contractor and soil resources  Waste to be disposed of in line with Nigerian WHO and record requirements at a suitable and licensed waste disposal World Bank facility. It is proposed that the services of a waste disposal requirements Water quality facility in Port Harcourt will be used once a facility that monitoring meets the standards of the Project is selected; before  Waste should be separated on site and waste storage effluent areas should be located on hardstanding (or bunded, if leaves the suitable) to prevent potential contamination; site  All waste disposal in line with Nigerian requirements at a suitable and licensed waste disposal facility;  Separate and store waste on hardstanding;  Recycle spent oils (including transformer oil); and  Regular monitoring of wastewater discharged (before it is discharged from the site). Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.7 Operational Minimise  Camp and workforce management protocols; Adherence to The Local Througho The Local Part of HSE impacts to impacts of a  Transparent recruitment process; the IFC Employment ut Employment Coordinator’ demographic worker  Local employment where possible; and Performance and Local operation and Local s duties profile include: influx and  Establish a grievance mechanism for communities. Standards Procurement Procurement  Reversal of increased Policies will Policy in youth population and Influx addition to the outmigration on Management Influx trends; community Plan will Management  Population demographi outline Plan will increase due to cs monitoring define the influx; requirements responsibility.  Change to the Azura Power ethnic structure would be due to influx. responsible for preparing the plan. 3.8 Impacts to cultural Minimise  Camp and workforce management protocols; Adherence to RAP will Througho RAP will Part of institutions during impacts of a  Ensure that traditional leaders are formally involved in the IFC outline ut define the normal operations include: new the Project operations; Performance monitoring operation responsibility. operations  Ongoing workforce  Implementation of the Physical Cultural Resources Standards requirements disruption of on existing Management Plan; Religious traditional community  Maintain a grievance mechanism; Chiefs and religious traditions  Carry out the RAP and implement proposed mitigation traditional observance due and measures. leader should to with customs be involved removal/ into relocation of monitoring. sacred sites; and The Physical  Influx affecting Cultural the ethnic Resources structure and Management associated Plan customs, rites, language, etc. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.9 Positive impacts to Maximise  Local Employment and Procurement Policies and Local Nigerian The Local Througho For Internal Part of HSE employment and impacts on Employment Strategy; labour law Employment ut mitigation HR Coordinator’ the economy are employmen  Identify training priorities and the and Local operation department of s duties expected during t and the  Procedures to ensure transparent recruitment and Adherence to Procurement Azura Power operation: local training; the IFC Policies will would be  Generation of economy  Communication about local employment and contracting Performance outline responsible for approximately during opportunities; Standards monitoring external 90 permanent operation  Implement internal training and promotion initiatives; requirements aspects positions; due to and government  Generation of increased  Transparent communication on hiring policies amongst and NGO induced livelihood local communities. would be employment; opportuniti responsible.  Increase in es household Azura West income; would be  Increase in responsible for regional and preparing local economic Local activity; and Employment  Development of and skills and Procurement capacity. Policy. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.10 Impacts to Minimise  Investments to upgrade services where the Project makes Adherence to The Througho Government Cost for infrastructure any use of local infrastructure; the IFC Community ut Planning service include: increased  Regular monitoring of water quality in local rivers to Performance Investment operation Department. upgrades  Influx of pressure on identify incidences of contamination and respond Standards Plan will vary opportunistic existing appropriately; and outline according to job seekers, infrastructu  Comprehensive Community Investment Plan. monitoring infrastructur increasing re due to requirements e type (Azura pressure on influx and has budgeted local increased more than $1 infrastructure Project million per services; usage annum for its  Pollution of the Community river from Investment which residents Plan) source their water;  Project use of local roads could further reduce their capacity; and  Increased local power supply in addition to the national power grid. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.11 Impacts to Minimise  Local Employment Strategy; Adherence to The Througho The Part of physical and impacts to  Encourage the construction workforce to undergo testing the IFC Occupational ut Occupational normal psychological physical (Azura and contractors) for sexually transmitted Performance Health and operation Health and operations health will less and infections (STIs); Standards Safety Safety than during the psychologic  Health awareness programme incorporating an Management Management construction al health as HIV/AIDS awareness and prevention program which Plan and Plan and phase, but may a result of will include voluntary testing, the provision of condoms, Community Community include: worker and and education of the workforce and local communities; Health and Health and  Psychological jobseeker  Camp and workforce management protocols; Safety Safety impacts influx  Traffic Management Plan; Management Management associate with  Communicate Project transport plans; Plan will set Plan will unmet  Grievance mechanism; out define the expectations for  Consider investing in local health care facilities, and monitoring responsibility local supporting them in carrying out ongoing monitoring of requirements for managing employment the health profile in the area; . the opportunities or  Fire and explosion risk management including routine performance. with safety checks, training, first aid boxes, emergency spill Azura Power community prevention plans; and will be tension and  Conduct community safety awareness campaigns responsible for opposition to regarding presence of the gas pipeline and the dangers of the preparing the Project; sabotage and what to do in the event of an emergency. the concerned  Impacts to plan. physical health due to community interactions with foreign workers;  Safety risk associated with Project traffic and explosions/spill ages from the gas pipeline; and  Health impacts associated with Project contamination ofAlternate Footnote 1: mitigations may be implemented to meet the Desired Outcome. surrounding environment. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequency Cost (USD) 3.12 Potential Minimise  Routine safety checks in line with standard safety Nigerian Emergency Througho Azura Power As part of workplace health the procedures for power plants; H&S law Response ut will have the normal and safety impacts: likelihood  The provision and use of PPE at all times during (Nigerian Plan, Operation responsibility operations  Accidents in the of incidents operation; Institute of Occupational to prepare the and around site occurring in  Warning signs in place, including those for the electrical Safety Health and plans, within (operation of the and mechanical equipment safety warning, and chemical Professionals, Safety the plans machinery, workplace. hazard warning; Factories Act Management individual accidental slips, In addition  Specific H&S training programmes should be provided 1990), the Plan, responsibilities explosions/spill protecting for workers assigned to tasks associated with particular adherence to Employment will be ages from the the health H&S risks; the IFC and detailed gas pipeline etc) of  Mandatory health and safety training programmes Occupational Workforce ; employees (including awareness-raising of disease vectors) will be Health and Policy and  Traffic related from provided to all employees, including contractors to Safety Spill accidents on contracting ensure staff are aware of the health and safety guidelines; Guideline Response site; and infectious  Develop and maintain emergency and spill prevention and incidents Plan  Impacts to diseases. and response/countermeasures plans for all phases of the record will set out physical health project; and monitoring due to  Toolbox talks or health and safety meeting on a weekly requirements infectious basis - ensure that procedures are being adhered to, and disease. to discuss any incidents that have occurred. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Table 4 Decommissioning Phase: Environmental and Social Management Measures Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.1 The negative Minimise  Apply liquid asphalt to prevent surface erosion: loosely The IFC Dust Impleme Azura Power Cost for non- ambient air health and bonded coarse-grained surfaces: 1.4 ℓ/ m2 or 3.6 ℓ/ m2; Performance mitigation nted in routine dust quality impacts nuisance  Use binder material for erosion and dust control for long Standards programme the suppression identified during impacts on term exposed surfaces; as part of the decommi measures decommissionin local  Use covered trucks for the transportation of materials The WHO Site Closure ssioning will be part g activities are: communities that release dust emissions; and EU and phase , of normal  Dust  Regular cleaning of equipment , drains and roads to Emission Restoration and to be operations. emissions avoid excessive build up of dirt and mud; Standards Plan monitore building  Water suppression or dust extraction fitted to d demolition, construction equipment where possible; Nigerian througho site levelling  Spray surfaces prior to excavation and clearing; Emission ut and and filling.  Speed limit on-site of 15 kph on unhardened roads and Standards past the  The emissions surfaces; decommi arising from  Avoid dropping material from heights; ssioning traffic.  Do not release sulphur hexafluoride from the phase  Site vehicle transformers to the atmosphere and reclaimed for reuse, emissions and if possible. vehicles  Avoid heating bitumen with an open flame and avoid accessing site overheating. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.2 Noise nuisance Minimise  Develop a detailed plan that relates to noise control for Noise at Noise Monthly HSE Cost impacts from noise nuisance relevant work practices and discuss this with sensitive monitoring at Coordinator, associated demolition to sensitive construction staff during health & safety briefings; receptors to sensitive Azura Power with monthly activities receptors  Avoid dropping materials from height, where practicable; not exceed receptors noise  Avoid metal-to-metal contact on equipment; Nigerian and monitoring  Avoid mobile plant clustering near residences and other WHO limits (approx 500 sensitive land uses; USD)  Ensure periods of respite are provided in the case of unavoidable maximum noise level events;  Inform all potentially impacted residents of the nature of works to be carried out, the expected noise levels and duration, as well as providing the contact details of the CLO;  Train construction staff on noise control plan during health & safety briefings;  Select ‘low noise’ equipment, or methods of work;  Use most effective mufflers, enclosures and low-noise tool bits and blades;  Investigate use of alternatives to audible reversing alarms (such as broadband noise emitting models) or configure to maximise forward movements of mobile plant;  Use alternatives to diesel/petrol engines and pneumatic units, such as hydraulic or electric-controlled units, where feasible and reasonable;  Use temporary noise barriers for small equipment, where required;  Reduce throttle settings and turn off equipment and plant when not used; and  Regular inspection and maintenance of all plant and equipment. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.3 Terrestrial Soils Minimise soil  Minimisation of concentrated transportation and  Visual  Visual  Daily HSE Part of HSE and Geology: loss, reduce excavation during decommissioning to reduce erosion; inspection inspection  Prior Coordinator, Coordinator’  Earthworks erosion and  Rehabilitation and revegetation of the site following  Updated and to Azura Power s duties and soil decrease, risk demolition and levelling before the next wet season; Site photograp initiati compaction of siltation of  Update and implement waste management plan, to be Closure hic record on of  Increased water updated as part of the Site Closure and Restoration Plan. and  Check on decom erosion and resources and Restoratio file missio sedimentation risk of n Plan on ning of water contamination file phase resources  Potential contamination from spills 4.4 Water Resource Prevent  Store hydrocarbons, fuels, lubricants and chemicals in  Effluent  Water  Month HSE Cost for impacts: contamination bunded and lockable oil storage containers, with hoses quality quality ly Coordinator, sampling and  Potential of water and gauges kept within the bund. meeting monitorin  Weekl Azura Power analysis of contamination resources  Regular checking and maintenance of all plant and FMEnv, g before y liquid from machinery to minimise the risk of fuel or lubricant WHO and effluent visual effluent and accidental leakages; World leaves the inspec receiving spills and  Training of relevant staff in safe storage and handling Bank site tions water bodies increased practices, and rapid spill response and cleanup requireme  Visual erosion and techniques; nts inspection (approx 1,000 runoff  Minimise stockpiling, 10 m buffer zone between drainage  Training and USD for set-  Water use channels and stockpiles (leaving existing vegetation in Records photograp up and 5,000 place and shield stockpiles using geotextiles if necessary;  Visual hic record USD for each  Correct and timeous waste separation, storage and inspection monitoring disposal of demolition waste and chemicals (including event) transformer oil, residual sludge from the wastewater treatment works and diesel) and/ or incidents and spills at licensed waste disposal facility; and  Decommission or cap (if to remain in use) the groundwater abstraction borehole(s) to prevent the development of a potential pathway for contaminants. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.5 Biodiversity Minimise soil/  Demarcate work and demolition areas to avoid Visual Visual Daily HSE Part of HSE impacts: water unnecessary disruption to neighbouring areas; inspection inspection Coordinator, Coordinator’ Disturbance of contamination  Minimise dust emissions using dust suppression and Azura Power s duties fauna due to and techniques listed in dust emissions arising from the roads photographic noise, dust, disturbance to used is minimised; record traffic and fauna  Restore species diversity and structure in the disturbed potential areas through rehabilitation and revegetation of the site contamination of using native floral species (except where non-native soil and water species are appropriate) taking into consideration the Threatened floral and faunal species identified in the Study area;  Train all staff on ecological sensitivities to ensure that they are aware of any specific migratory routes for faunal species, are able to identify species of a Threatened status and enforce an anti-poaching policy;  Implement measures outlined in the BMP including rehabilitation and revegetation before the wet season and using locally indigenous species; and  Monitor and train staff to ensure that there is no poaching in the area. 4.6 Waste impacts Reduce  Update and implement a waste management plan with  Visual  Visual  Daily, HSE Part of HSE related to contamination requirements for separation, handling and disposal of all inspection inspection throug Coordinator, Coordinator’ potential of water and wastes as part of a Site Closure and Restoration Plan;  Updated and hout Azura Power, s duties contamination of soil resources  Azura Power should identify suitable disposal sites and Site photograp constr EPC contractor water and soil confirm capacities for disposal for general and hazardous Closure hic record uction resources wastes prior to decommissioning; and  Confirm  Prior  All waste disposal in line with Nigerian requirements at a Restoratio Site to suitable and licensed waste disposal facility, and store n Plan Closure decom waste on hardstanding. It is proposed that the services of and missio a waste disposal facility in Port Harcourt will be used, Restoratio ning following the identification of a suitable facility; n Plan is  Use spoil and excavated soil for on-site levelling and on file compaction as much as possible;  All metal should be sold for scrap and machinery, infrastructure and buildings should be dismantled such that as much of this waste can be reused or recycled. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.7 Impacts to Minimise  Facilitate SME development and support sustainable Adherence to Government Annually Azura Power Cost for demographic impacts to development and implementation of new technologies the IFC department support to re- profile: local through the provision of training annually to local Performance deals with training  Decline in demographics communities for three years prior to decommissioning; Standards population programmes population,; through  Invest in infrastructure development; monitors the (approx  Rebalance of facilitating  Identify and facilitate training opportunities for local decline in $10,000 per age parallel workforce; and population year for 3 demographic,; development  Establish Influx Management Plan. and loss on years) and of industry ethnic  Some loss of and livelihood diversity. ethnic opportunities The Influx diversity. in the Project Management area Plan will establish monitoring responsibility . Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.8 Impacts to Minimise any  Continue to work with traditional leadership structures Adherence to RAP and Through RAP and Influx Part of HSE cultural ongoing during the decommissioning process; the IFC Influx out Management Coordinator’ institutions impacts and  Ensure that Project plans and decommissioning activities Performance Management operatio Plan should set s duties include: impacts to are clearly communicated to stakeholders; and Standards should set nal phase out the  Ongoing cultural  Ensure effective completion and, where appropriate, out the role responsibility. impacts due heritage and handover of responsibilities identified through the RAP. for Azura Power to the existing monitoring. would be permanent cultural responsible for removal of practices as a preparing RAP sacred sites; result of and Influx  any decommissioni Management unresolved ng Plan. issues between the resettled and host community;  Removal of sources of authority and influence for traditional leaders; and  Departure of foreign workers. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.9 Employment Minimise  Facilitate SME development and support sustainable Nigerian The Local Through For Internal Cost and economy impacts on development and implementation of new technologies labour law Employment out mitigation HR captured in issues include: employment through the provision of training annually to local and the and Local Operatio department of 4.7  Loss of direct legacy issues communities for three years prior to decommissioning; Adherence to Procurement nal Phase Azura Power and associated  Develop credit and loan programmes for small business the IFC Policies will would be contracted with loss of development; Performance outline responsible for employment; employment  Identify and facilitate training opportunities for local Standards monitoring external aspects  Loss of following workforce; requirements government and indirect decommissioni  Provide training to local and regional workforce on career NGO would be business ng of the development and management of personal finances; and responsible for opportunities; Project  Provide training to local and regional contractors on managing  Decline in effective business management. impact. economic productivity Azura Power and would be household responsible for income; and preparing Local  Decline in Employment regional and and local Procurement economic Policy. activity. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.10 Potential Minimising  Implementation of recommended mitigation measures Adherence to As per infrastructure impacts to for impacts to demographics and employment and the IFC mitigations implications local economy will effectively mitigate negative impacts to Performance for include: infrastructure infrastructure, by reducing population decline and Standards decommissio  Some loss of as a result of reduction in economic activity. ning impacts power to the population to national grid; decline and demographic  Associated reduced s and loss of power economic employment at the local activity and economy level;  Decline in infrastructure investment and maintenance by the Project; and  Decline in government investment in infrastructure. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.11 Decommissionin Minimise any  Establish a contingency fund to address contamination of Adherence to The Through The Negligible g will not result impacts the surrounding environment prior to Project closure; the IFC Occupational out Occupational (without in any new caused as a  Health awareness programme incorporating an Performance Health and Operatio Health and contaminatio impacts to result of the HIV/AIDS awareness and prevention program which Standards Safety nal Phase Safety n) health; however presence of the will include voluntary testing, the provision of condoms, Management Management closure of the Project and education of the workforce and local communities; Plan and Plan and Project could workforce  Ensure that any victims of health or safety impacts of the Community Community remove any during Project are rehabilitated with treatment and support that Health and Health and treatment or construction can continue after closure of the Project; and Safety Safety support for and operation  Consider providing sustainable investment in local health Management Management victims of health on community care facilities during the operation phase to provide Plan will set Plan will set out impacts health and ongoing capacity for support beyond the life of the out monitoring manifested wellbeing. Project. monitoring requirements. during Project requirements construction or Prior to Azura Power operation. closure of the will be PPA, a responsible for detailed preparing the Decommissio detailed ning Plan Decommissioni should be ng Plan prepared. Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Ref Potential impact Desired Description of Mitigation (see Footnote 1) Performance Monitoring Timing/ Responsibility Estimated # Outcome Indicator Frequenc Cost (USD) y 4.12 As with the Minimise any  Conduct toolbox talks on a daily basis; Nigerian Emergency Through Azura Power All costs will construction and potential  The provision and use of PPE at all times during H&S law Response out will have the be operation accidents that decommissioning; (Nigerian Plan, decommi responsibility to incorporated phases the may occur  Warning signs in place, including those for the electrical Institute of Occupational ssioning prepare the into the potential during and mechanical equipment safety warning, and chemical Safety Health and plans, within decommissio workplace decommissioni hazard warning; Professionals, Safety the plans ning phase health and safety ng particularly  Ensure that all employees (including contractors) are Factories Act Management individual impacts will be: with aware and adhere to health and safety procedures; 1990), the Plan, responsibilities  Accidents due demolition  Review health and safety procedures of any additional adherence to Employment will be detailed to the and removal contractors that may be employed during the IFC and including increased activities decommissioning; and Occupational Workforce contractor presence of  Ensure that any victims of incidents on site are Health and Policy and responsibilities temporary rehabilitated with treatment and support that can Safety Spill workforce; continue after closure of the Project if necessary. Guideline Response  Traffic related  Plan decommissioning and site rehabilitation techniques and incidents Plan accidents; to reduce potential breeding grounds for disease vectors record will set out  Safety related and implement spray programme if necessary. monitoring to the requirements dismantling of cables and pylons, and explosions from gas pipeline; and  Health impacts of workforce interacting with the surrounding communities (particularly temporary workforce) Footnote 1: Alternate mitigations may be implemented to meet the Desired Outcome. Annex B Noise Impact Assessment from the Approved ESIA Report (original data) Table B1: Original Impact Assessment from the Approved ESIA Report Scenario 3: Azura Plant & NIPP Plant Scenario 1: Azura Plant Scenario 2: NIPP Plant (Cumulative) NSL Exceeds Exceeds Exceeds Modelled Modelled Calculated Night Exceeds Impact Night Exceeds Impact Night Exceeds Impact Noise Noise Noise Time Baseline2 Rating Time Baseline2 Rating Time Baseline2 Rating Level Level Level Criterion1 Criterion1 Criterion1 NSL 4 37 -8 1 Negligible 40 -5 4 Minor 42 -3 6 Moderate NSL 24 38 -7 2 Negligible 42 -3 6 Moderate 43 -2 7 Moderate NSL 37 34 -11 -2 Insignificant 39 -6 3 Minor 40 -5 4 Minor NSL 8 29 -16 -7 Insignificant 37 -8 1 Negligible 37 -8 1 Negligible NSL 49 33 -12 -3 Insignificant 44 -1 8 Moderate 44 -1 8 Moderate NSL L017 32 -13 -4 Insignificant 44 -1 8 Moderate 44 -1 8 Moderate NSL L053 34 -11 -2 Insignificant 46 1 10 Moderate 46 1 10 Major NSL 1 35 -10 -1 Insignificant 44 -1 8 Moderate 44 -1 8 Moderate NSL SN_116 38 -7 2 Negligible 46 1 10 Moderate 47 2 11 Major NSL SN_254 45 0 9 Moderate 49 4 13 Major 51 6 15 Major NSL SN_72 32 -13 -4 Insignificant 42 -3 6 Moderate 42 -3 6 Moderate 1Night time limit is 45 LAeq dBA 2Baseline noise level is assumed to be 36 dBA, calculated as the logarithmic average of day-time and night-time levels recorded by NIPP – see Table 4.4.