RADIAN- INTERNATIONALM3
Public Disclosure Authorized votS
Environmental Impact Assessment Jorf Lasfar Power Plant Public Disclosure Authorized
Sponsored by
CMS Generation Co. ABB Energy Ventures Inc. Public Disclosure Authorized
Prepared by
Radian International LLC Public Disclosure Authorized Ak* August 1,1996 * M1' i 0 - I I l RADIAN- INTERNATIONALBB
Tableof Contents
Execuive Summary ...... ES-I
1.0 Introduction ...... 1-1
1.1 Purpose of this ELA ...... 1-1 1.2 Background to this Project ...... 1-1 1.3 Scope of this EIA ...... 1-3
2.0 Policy, Legal, and Administrative Framework ...... 2-1
2.1 Requirements of Cofmancers .. 2-1 2.1.1 The World Bank .2-1 2.1.2 U.S. Overseas Private Investment Corporation (OPIC) .2-2 2.1.3 Export-Import Bank of the United States (Ex-In) Guidelines .2-2 2.1.4 Sezione Speciale per L'Assicurezione del Credito L'Esportazione (SACE).2-2 2.1.5 Comparison of Cofinancer EnviroDmentalGuidelines .2-2 2.1.6 JLPP "Project Guidelines.2-2 2.2 Applicable Moroccan and Local Laws and Regulations . .2-7 2.2.1 Moroccan Environmental Inpact Assessment .2-7 2.2.2 The Moroccan Permitting Process .2-8 2.3 Role of Moroccan Organizations .. 2-9
3.0 ProjectDescription .3-1
3.1 Project Location and Aea Description .. 3-1 3.2 Description of Existing Facility .. 3-1 3.2.1 Energy Generation .3-8 3.2.2 Fuels Used .3-8 3.23 Air Emissions .3-10 3.2.4 Water Use .3-11 3.2.5 Water Discharges ...... 3-13 3.2.6 Solid Wastes .3-17 3.2.7 Ancilary Facilities .3-17 3.2.8 Staffing .3-18 3.3 Description of Proposed Expansion .. 3-18 3.3.1 New Infrastructure and Operational Changes ...... 3-18 3.3.2 Description of Construction Activities ...... 319 3.3.3 Features of New Units ...... 3-21
ELK ii August 1, 1996 RADL^NSM INTERNATIONALM3
Table of Contents (continued)
4.0 Environmental Baseline...... 4-1
4.1 The PhysicalEnvironment .. 4.- 4.1.1 Topography,Geology, and Soils .4-1 4.1.2 Climate.4-2 4.1.3 Existing Air Quality. 4-2 4.1.4 SurfaceWater and SedimentQuality .4-5 4.1.5 Groundwater.4-16 4.1.6 Noise .4-17 4.2 The BiologicalEnvironment .. 4-21 4.2.1 TerrestrialBiota .4-21 4.2.2 Marine Biota. 4-23 4.3 The Social and CulturalEnvironment .. 4-27 4.3.1 History and Archeology.4-27 4.3.2 Demographics. 4-28 4.3.3 EconomicConditions .4-29 4.3A CommercialFisheries .4-32 4.3.5 Land Use and Transportation.4-34 4.3.6 Aestheticsand ProtectedNatural Areas. 4-38
5.0 Audit of Eisting Conditions...... 5-1
5.1 Air Quality ...... 5-1 5.2 WaterDischarges ...... 5-2 5.3 HazardousMaterials ...... 5-3 5.4 Soil and Groundwater ...... 5-4 5.5 Ash Disposal ...... 5-4 5.6 Summzary...... 5-5
6.0 Potentia Future Impacts of Proposed Expansion ...... 6-1
6.1 hmpactsof Construction .. 6-1 6.1.1 Land and Soil .6-1 6.1.2 AirQuality .6-1 6.1.3 SurfaceWater .6-2 6.1.4 Groundwater.6-3 6.1.5 BiologicalResources .6-3 6.1.6 Archeologicaland HistoricalResources from Construction.6-3 6.1.7 SocioeconomicImpacts from Construction. 6-3 6.1.8 Noise Impactsfrom Construction.6-5
EIA iii August 1, 1996 RZADIAN- INTERNATIONALM
Table of Contents (continued)
6.2 Impacts of Operation ...... 6-5 6.2.1 Land Use and Transportation ...... 6-6 6.2.2 Air Quality...... 6-7 6.2.3 Surface Water Quality .6-18 6.2.4 Thermal Discharge Impacts .6-21 6.2.5 Groundwater .6-23 6.2.6 Biological Resources-Land .6-25 6.2.7 Marine Resources .6-25 6.2.8 Archeological and Historical Resources .6-26 6.2.9 Socioeconomic Impacts .6-26 6.2.10 Noise .. 6-28 6.2.11 Worker Health and Safety .6-30
7.0 Analysis of Alternatives .7-1
7.1 Rationale for Site Selection ...... 7-1 7.2 Rationale for Coal as a Fuel ...... 7-2 7.3 Rationale for Pulverized Coal Technology ...... 7-3 7.4 Altemative Air Emission Controls ...... 7-3 7.4.1 Altemative S02 Controls ...... 7-3 7.4.2 Alternative Particulate Matter (PM) Control Options ...... 7-10 7.5 Altemative Wastewater Treatment Options ...... 7-11 7.5.1 Wastewater Production ...... 7-11 7.5.2 Present Treatment ...... 7-13 7.5.3 Treatment Criteria and Compliance ...... 7-13 7.5A Wastewater Treatnent Options for Units I and 2 ...... 7-13 7.6 Ash Disposal Alternatives ...... 7-14 7.6.1 Landfill Sites ...... 7-14 7.6.2 Description of Specific Landfilling Alternatives ...... 7-17 7.6.3 Selection of a Preferred Landfilling Altenative ...... 7-22 7.6A Identification of Non-landfilling Alternatives ...... 7-23 7.6.5 Ranking of Altematives and Conclusions ...... 7-26
8.0 Mitigation and Environmenta ManagemnentPlan. 81
8.1 Mitigation During Construction ...... 8-1 8.1.1 Air Quality ...... 8-1 8.1.2 SurfaceWaterQuality ...... 8-1 8.1.3 Groundwater Quality ...... 8-2 8.1.A Worker Health and Safety ...... 8-2 8.2 Mitigation Duing Operation ...... 8-2
EIA iv August 1, 1996 INTERNATIONALEM Tableof Contents (continued)
8.2.1 Ash Disposal...... 8-2 8.2.2 WastewaterDischarge and SurfaceWater Quality .. 8-3 8.2.3 Air Quality .. 8-3 V 8.2.4 WorkerHealth and Safety .. 8-4 8.2.5 Other OperationIrnpacts .. 8-4 8.3 EnvironmentalManagement and Training .. 8-4 8.3.1 EnvironmentalManagement Inplementation Plan .. 8-4 8.3.2 Implementationof CorporateStandards .. 8-6
9.0 Monitoring Plan .9-1
9.1 Monitoringand Reportingof ConstructionInpacts . .9-1 9.2 Monitoringof OperationalInpacts ...... 9-1 9.2.1 Air Quality ...... 9-1 9.2.2 Water Quality.9-3 9.2.3 Noise .9-4 9.2A Solid Waste Disposal. 9-4
10.0 Interagency Coordination and Public Participation ...... 10-1
10.1 Forum PresentationSummary ...... 10-2 10.1.1 ONEPresentation...... 10-2 10.1.2 ABB Presentation...... 10-2 10.1.3 CMS Presentation ...... 10-3 10.2 Summaryof Public Forum .. 10-3 10.2.1 Commentsby the Govemorof El Jadida. 10-3 10.2.2 Commentsof the Directorof the Center for Observationsand Studies of the Ministry of the Environment.10-4 10.2.3 Commentsof the Presidentof the Associationof the Region of Dukkala.10-4 10.2.4 Commentsof the Presidentof the Provinceof El Jadida.10-4 10.25 Commentsof the Moderator .10-5 10.2.6 Commentsand Questionsfrom the Public. 10-5 10.2.7 Summaryof the NGO Forum:Comments and Responses. 10-7
Appendi A: List of EIA Preparers ...... A-1
Appendix B: References ...... B-1
Appendix C: Public Participation and Interagency Coordination: List of NGOs Invited to NGO Forum ...... C-1
EIA v August 1,1996 RADL^N INTERNATIONALM3 Tableof Contents(continued)
Appendix D: Environmental Management Implementation Plan ...... D-1
Appendix E: Photo Log ...... E-1
Appendix F: Stack Emissions Calculations ...... F-i
Appendix G: Thermal Discharge Compliance of the Jorf Lasfar Power Plant ...... G-1
EIA vi August 1, 1996 r
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List of Figures
1 Locationof the Jorf-LasfarPower Plant Project ...... ES-2 2 JLPP Site Layout ...... ES-9 3 Contributionof JLPP to Morocco'sFuture Electricity Needs ...... ES-23 4 Locationof AltemativeAsh DisposalSites ...... ES-26 3-1 RegionalMap ...... 3-2 3-2 AreaMap .3-3 3-3 Jorf LasfarPlot Plan...... 3-5 3-4 iLPP Layout .. 3-6 3-5 Water Intakes . 3-12 3-6 Water Discharges. 3-15 4-1 Annual,Summer, and WinterWindroses for El Jadida,Morocco . 4-3 4-2 MarineBiology/Water Quality Samplng Sites . 4-7
4-3 Baselne Noise Survey Results . 4-20 4-4 Existing and Future Land Use in the Vicinityof the JLPP . 4-36 5-1 Issues and ExistingEnvironmental Conditions at JLPP . 5-6 6-1 Jorf LasfarArea ReceptorGrid with TerrainContours . 6-13 6-2 JorfLasfarWindrose . 6-15 6-3 TemperatureProfile at the PlumeCenterline . 6-24 6-4 YearlyElectric Power Requirementsfor Moroccoand JLPP Contributionto Supply .6.-...... 629 7-1 SchematicDiagram of SeawaterScrubber Process with BypassReheat . 7-5 7-2 SchematicDiagram of a LimestoneScrubber . 7-7 7-3 Potential LandfillSites . 7-15
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List of Tables
I JLPP Project Guidelines ...... ES-4 2 Descriptionof the JLPP...... ES-7 3 ProposedAdditions to JLPP ...... ES-10
4 4LPP MaximumAir Emissions ...... ES-18
5 Summary of Monitoring, Recordkeeping, and Reporting to be Conducted at JLPP .. ES-31
2-1 Comparison of World Bank, OPIC, and Ex-In Bank Ambient Air Guidelines .. 2-3
2-2 Comparison of World Bank, OPIC, and Ex-lm Bank Stack Emissions Guidelines .. . 2-4
2-3 Comparison of World Bank and Ex-Im Bank Liquid Effluent Guidelines .. 2-5
2-4 Comparison of Other Applicable World Bank, OPIC, and Ex-Im Guidelines .. 2-5
2-5 JLPP Project Guidelines .. 2-6
3-1 Ultimate Analysis of Coals Used at JLPP During 1995 .. 3-9 3-2 Propertiesof HeavyFuel Oil No.2 Used at JLPP .3-10
3-3 1995 Stack Emissions from JLPP Units 1 and 2 Firing and Coal . 3-11
3-4 Summary of Wastewater Characteristics . 3-16
3-5 Stack Emissions from JLPP Units 1 Through 4 . 3-22
4-1 Comparison of LPEE Ambient Monitoring Data (1994) with JLPP Project Guidelines . 4-5
4-2 Hydrographic Measurements, Gross Sediment Type, and Sample Dates and Times for Each Station . 4-8
4-3 Trace Metal Concentrations of Surface Water (pg/L) . 4-10
4-4 Surface Water Parameters (All Values Except for Chlorophyll a are in mglL) . 4-12
4-5 Trace Metal Concentrtions in Sediment (ppm) . 4-14
46 Water and Sediment Heavy Metal Toxicity Summay . 4-16
EIA viii August 1, 1996 INTERNATIONALE3
List of Tables (continued)
4-7 CommonNoise Levelsin dBA ...... 4-18 4-8 Radian Noise SurveyResults ...... 4-19 4-9 Status of Endangeredor ThreatenedSpecies That May Have Historic Ranges in Morocco...... -22
4-10 MacrobenthicSpecies and Numbersof IndividualsPer Station . 4-24 4-11 Fish and InvertebrateSpecies and Numbersof individuals (Samplestaken between4/24 and 5/4196). 4-26 4-12 PopulationGrowth for Morocco,El JadidaProvince, and CommuneMoulay Abdellah . 4-29 4-13 Morocco-PowerCapacity Balances-MW(Based on firm capacity) . 4-33 4-14 LeadingExports and Importsof the Port of Jorf Lasfar . 4-38 6-1 TypicalNoise ImpactDuring Construction...... 6-5 6-2 JLPP MaximumAir Emissions ...... 6-7 6-3 JLPP Units I and 2 - EmissionPerformance Test Results ...... 6-8 6-4 PredictedUnit 1 and 2 PM EmissionsESP Performance...... 6-9 6-5 Jorf Lasfar ModeledSource Parameters ...... 6-12 6-6 Jorf Lasfar ModeledAir QualityConcentrations ...... 6-17 7-1 Range of UltimateAnalyses of "Ultr-Low" SulfurCoals Consideredfor Use at JLPP ...... 7-9 7-2 GeneralCriteria for Selectingan Ash Landfill . 7-18 7-3 QualitativeAnalysis of Design Criteriafor Two LandfillSites Jorf Lasfar PowerPlant, Morocco . 7-20 9-1 Summaryof Monitoring,Recordkeeping, and Reportingto be Conducted at JLPP .9-2 9-2 Noise SourcePerformance Guarmtees for SpecificEquipment at JLPP Units 3 and 4 .9-4
EIA ix August 1, 1996 RADIAN- INTERNATIONALC
List of Acronyms, Abbreviations and Definitions for This EIA
ABB ABBEnergy Ventures BV. A sponsorand equity investorin the Project. Ampere A unit of electricalcurrent. avg. Average. B.C.E. Before CommonEra. BOD Biologicaloxygen demand.
BOD5 Biologicaloxygen demand after five days. CEREP Centred'Etudes et de Recherchessur 1' Environnementet la Pollution CFC Chlorofluorocarbon. cfd Computationalfluid dynamics. CHAM Combustion,Heat and MassTransfer of London. cm Centimeter. cm/hr Centimetersper hour. CMS CMSGeneration Co. A Sponsorand equityinvestor in the Project and an affiliateof CMS Energy. cm/s Centimetersper second. Co Carbonmonoxide.
COD Chemicaloxygen demandL CNE ConseilNational de l'Environnement. cp Centipoise.A unit of viscosity. dB Decibel. A unit of soundlevel, amplitude,or loudness. dBA A-weighteddecibels. A measurementadjusted to representsound levels as the humanear hearsthem. °C DegreesCelsius.
DTP Departrnentdes TravauxPublics.
EIA x August 1,1996 INTERNATIONALMI
List of Acronyms, Abbreviations and Definitions for This EIA
EA EnvironmentalAssessment. EIA EnviromnentalImpact Assessment. ERL Effects range low. ERM Effects range medium. ESP Electrostaticprecipitator. A device for controllingPM emissions. Ex-Im The Export-ImportBank of the UnitedStates. The exportcredit agency of the U.S. g Gram. A metricunit of mass equal to one one-thousandthof a kilogram. GEC Alsthom GEC Alsthom. The French constructionfirm that built Units 1 and 2. gr/MM Btu Grains per nmillonBritish thermal units. HOCI Hypochlorousacid. hr Hour. ICPAES Inductivelycoupled plasma atomicemissions spectrometer. IGCC Integratedgasification combined cycle. ISCST3 IndustrialSource ComplexShort Term model. J Joule. A unit of energy. JLPP Jorf LasfarPower Plant. Jorf Lasfar Arabic for "yellowbluff." The name for the 50-80m high bluff that forms the east edge of the JLPP and which forms a sheer cliff to north of the Port kcal Kilocalorie. The amount of heat requiredto raise the temperatureof one kilogram of water by one °C at one atmosphericpressure. kcallkg Kilocaloriesper kilogram. kcal/kWh Kilocaloriesper kilowatthour.
EIA xi August 1, 1996 RADIAN- INTERNATIONALEM
List of Acronyms, Abbreviations and Definitions for This EIA kg Kilogram. The fundamental unit of mass in the Intemational System, equal to approximately 2.2046 lb in the U.S. Customary System. kJ Kilojoule. One thousand joules. kJ/s Kilojoules per second. km Kilometer. One thousand meters. km/hr Kilometers per hour. kV Kilovolt. One thousand volts. kWh Kilowatt-hours. A unit of electric power consumption indicating the total energy developed by a power of one kilowatt acting for one hour. kWyear Kilowatt year.
L Liter. A unit of volume in the metric system, approximately equivalent to 1.056 liquid quarts in the U.S. Conventional System. lb Pound. A unit of mass in the U.S. Customary System, equal to 16 ounces. lb/MM Btu Pounds per million Btu.
Ldn Sound measurements averagd over a 24 hour period and adjusted so that night time sounds are given a greater influence.
Leq Equivalent sound level. A sound level in dBA averaged over a period of time, such as 60 seconds.
LPEE Laboratoire Public d'Essais et d'Etudes. m Meter. The fundamental unit of length in the metric system, equivalant to 39.37 inches in the U.S. Customary System. in Square meter. m3 Cubic meter. m 3 hr Cubic meters per hour. m3/sec Cubic meters per second.
ME Ministere de l'Environnement.
EIA - xii August 1, 1996 RADXAN- I NTERNATI ONAL
List of Acronyms, Abbreviations and Definitions for This EIA
mg Milligram. One one-thousandth of a gram.
mg/L Milligrams per liter.
mg/m3 Milligrams per cubic meter.
mg/Nm3 Milligrams per normal cubic meter.
mho A unit of conductancereciprocal to the ohm.
lAg fMicrogram.One one-millionth of a gram. 9/L huMicrogramsper liter.
/1g/m3 Microgms per cubic meter. 4mho One one-millionthof a mho. ismhos/cm Micromhosper centimeter. ML Milliliter. One one-thousandthof a liter. mm Millimeter. One one-thousandthof a meter. MMBtu MillionBritish thermalunits. MPN Most probablenumber. rnMs Metersper second. MW Megawatt. One millionwatts. MWh Megawatthour. N Newton. The unit of force requiredto acceleratea mass of one kg one m/s per second. NaOH Sodiumhydroxide ng Nanogram. ng/i Nanogramsper joule. NGM Niveau generaldu Maroc.
EIA xiii August 1, 1996 RADXAN INTERNATIONALM3
List of Acronyms, Abbreviations and Definitions for This EIA
NGO Non-govemmental organization.
NH3 Ammonia Nm3 Normal cubic meter (normal = at 0°C and a pressure of one atmosphere).
NO2 Nitrogen dioxide.
NO3 Nitrate.
NOVs Notice of Violations
NO° Oxides of nitrogen.
NOAA U.S. National Oceanographic and Atmospheric Administration.
03 Ozone.
O&M Cost Operation and Maintenance Cost.
OCP Office Cherifien des phosphates. The national phosphate production company of Morocco and the largest Moroccan company, the single largest exporter in Morocco, and ONE's largest individual customer.
ODEP Office d' Exploitation des Ports. The national ports authority of Morocco.
OEM Original equipment manfacturer.
ONCF Office National des chemins de fer. The railroad transportation departnent.
ONE Office National de l'Electricitd. The national electric utility of Morocco.
Operator An affiliate of CMS, who will be responsible for operation and maintenance of the Project.
OPIC Overseas Private Investment Corporation, a US govermmentagency (intemational lender). ounce A unit of mass in the U.S. Customary System, equivalent to 28.350 grams in the metric system.
% Percent
PC Pulverized coal.
EIA xiv August 1, 1996 RADUANE INTERNATIONALIM
List of Acronyms, Abbreviations and Definitions for This EIA
PCB Polychlorinatedbiphenyl. PFBC Pressurizedfluidized bed combustion. pH A measureof a solution'sacidity or alkalinity. Plan (The) The comprehensiveenvironmental management implementation plan developedby the Project Operator. PM Particulatematter. PMio Particulatematter less than 10 microns in diameter.
P0 4 Ortho Phosphate. ppb Parts per billion. ppbV Parts per billion by volume. ppm Parts per million. Project An independentpower projectat the existingJorf Lasfar coal-firedplant site consistingof two existing330 MW (gross)units and two new units of at least the same size to be completedby the Project Sponsors. Project The CMS/ABBConsortium that will acquirethe concessionto operate Sponsors the JLPP and constructtwo new units. RADEEJ RPgieautonome de distributiond'eau et d'electricitedEl Jahida. The local water utility. s Second. SACE SezioneSpeciale per L'Assicurezionedel CreditoLEsportazione.
S02 Sulfur dioxide. THC Total hydrocarbons. TKN Total Kjeldahlnitrogen. tonne Metric ton. tpd Tonnes per day. tpd/MW Tonnes per day per megawatL
EIA xv August 1, 1996 RADIAN! INTERNATIONAL
List of Acronyms, Abbreviations and Definitions for This EIA
TPH Total petroleum hydrocarbons.
TPY Tonnes per year.
TSP Total Suspended Particulates.
TSS Total Suspended Solids.
Units 1 and 2 Two existing 330 MW (gross) coal-fired units constructed by GEC Alsthom at the Jorf Lasfar project site.
Units 3 and 4 Two new coal-fired units of 348 MW (gross) to be constructed by the Contractors at the Jorf Lasfar Project site.
U.S. United States.
U.S. EPA U.S. Environmental Protection Agency.
V Volt.
VOCs Volatile Organic Compounds.
W Watt.
WB Guidelines The World Bank environmental guidelines.
YSI Manufacturers of a monitoring device.
EIA xvi August 1, 1996 S RADUINM INTERNATIONALM3
EXECUTIVESUMMARY
This Environmental Impact Assessment (EIA) describes and evaluates the proposed expansion of the Jorf Lasfar Power Plant in Morocco. Each of the 10 sections of the EIA are summarized in this Executive Summary.
1.0 Introduction
CMS Generation Co. (CMS) and ABB Energy Ventures Inc. (ABB), hereafter referred to as "Project Sponsors", have forrned a joint venture for the purpose of acquiring the right to use and operate two existing 330 Megawatt (MW) coal-fired units and the construction and operation of two additional 348 MW coal fired units at the Jorf Lasfar Power Plant (JLPP) in Morocco. This CMS/ABB consortium activity is pursuant to the terms of an agreement with Morocco's Office National de l'Electricite (ONE). The privatization and subsequent expansion of the JLPP (the "Project") is a vital part of Morocco's plans to meet a rapidly increasing demand for electric power. The location of the project is shown in Figure 1.
This ELAhas been prepared by Radian Intemational under contract to CMS and ABB. The EIA is required as a condition for obtaining project financing and loan guarantees from the World Bank, the Export-Inport Bank of the U.S. (Ex-Im), Sezione Speciale per L'Assicurezione del Credito L'Esportazione (SACE) and the U.S. Overseas Private Investment Corporation (OPIC). In addition to meeting the requirements of lending institutions, the EIA will be submitted to the Moroccan Ministry of Environment for review and approval. Although there are not yet any Moroccan EIA requirements, the Ministry of the Environment is developing EIA guidelines and this report is intended to be consistent with those guidelines.
The proposed Project is critical to meeting Morocco's energy strategy which includes the extension of electricity to the more than 40% of the population now without electric power. Through privatization of electric power production, Morocco can earn immediate revenues through sale of an operating concession on existing units and benefit from efficient power production from new units. As is documented in this EIA, the expansion of the JLPP, Morocco's largest power plant, will be accomplished in a manner that is protective of the
Executive Summary ES-1 August 1, 1996 RWAN INTERNATIONAL-
.' > Prance lNORTH
Francehtdy ' A ,
tiC~~~~~~~~
I Mali
M~oulay fi 0 Spi - .
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SCALE: KILOMCERS Power Plant JvGAo23 Figure 1. Location of the Jorf-Lasfar Power Plant Project
Executive Summary ES-2 August 1, 1996 RZADLAN- INTERNATIONAL=
environmentwhile providingmuch neededcost-effective new power supplies. The proposed projectwill meetall applicableenvironmental discharge and ambientguidelines.
2.0 Policy, Legal and Administrative Framework
The MoroccanGovernment is in the process of developingenvironmental legislation and regulations.Currently, there are no Moroccanenvironmental standards or regulationsapplicable to new projectssuch as the JLPP. However,the Project will be subjectto environmental ambientand dischargeguidelines established by the WorldBank and potentialco-financiers, includingOPIC, SACE, and Ex-ImL
ProjectEnvironmental Guidelines The WorldBank, OPIC, andEx-In have adoptedslightly different environmental guidelinesand policies. In orderto be eligiblefor financialassistance from these institutions,the Projectwill needto complywith their respectiveenvinmental guidelines.Where there are differingrequirements among the three sets of guidelines,the Projectwill complywith the most stringent one. Table I provides this most stingent combination of requirements.These are called the Project guidelines. It is notedthat adoptionof these Projectguidelines is for purposes of obtainingfinancing for this specificProject, and is not intendedto set precedentfor other projectsor facilitiesin Morocco.
Local Permitting In Morocco,an applicationfor a permit to constructa new facilitymust be presentedto the relevant local authority.For the JLPP, the local authorityis the Communeof Moulay Abdellah.The nrualcommune is the local governmentsubdivision within a province.Upon receiptof the application,the local authoritywill requestinput from variousMinistries (Public Works, Civil Protection,Employment, Health, Enviromnent, etc.). Coordinationof these authoritiescould eventuallybe done at the level of the correspondingprovince (El Jadida Province)rather than at the level of the communeitself. The followingdocuments are needed to completethe permit application:
A formal letter requesting the permit;
Engineeringdrawings of the new facility and a coresponding engineerng description;
Executive Summary ES-3 August 1, 1996 RADIANE INTERNATIONAL5
Table 1. JLPP Project Guidelines
Topic Parameter Criteria Ambient Air Quality Particulates(TSP) t- Annualmean'" 70 g/m 3 oo Maximum24 hr avg.('" 110ug/m 3 Sulfur Dioxide (SO2) Annualmean (l) 50 Ag/m3 Maximum24 hr avg.() 125 gg/m3 Maximum I hr avg. l 350 gg/m3 NitrogenOxides (NO 2) 3 Annualmean Q) 100 Asg/m Maximum24 hr avg.0) 150 ,gtm 3 3 Maximum lhravg.'" 4w0,gm/ __ Stack Emissions Particulates(TSP) (" 50 mg/m3 SulfurDioxide (1) (SO2) 0.2 txVMW NitrogenOxides °" (NO2) 260 ng/J(270 g/MM Bta) AqueousEffluent pH 0) 6 to 9 BOD0 5 50 mg/L COD(4) 250 mg/L HeavyMetals a) 10 mg/L Oil and Greasec 20 mg/L TSS ') 60 mglL ColifonMs (4) < 400 MPNI100mL ResidualFree Chlonnem 0.5 mglL CoolingWater (1) TemperatureIncrease at Edge of 5°C above ambientunless MixingZone receivingwae >28WC,then max. 3°Callowed CommunityNoise Residential 55 dBA (Ldn) Other) 70 dBA (Ldn) Occupational Noise ( 85 dBA 3 SO2 (1) 5 mgfm (8 hrday avg.) NO2 l 6 mgfmk(8hr day avg.) TSP 'l 10 mgfm 3 (8 hr day avg.) a) OPICGuidein 0Worid Bank, 1988 ° WorldBank, Ex-ha, ad OPICa identicalfor tbispm==. * Ex-Im, 1996
Executive Summary ES-4 August 1, 1996 INTERNATIONALD3
Evidenceof compliancewith the regulationsfor the design and constructionof tanks and tank farms; and
A summaryof the environmentalimpacts of the Project.
Applicationfor an operatingpermit for Units3 and 4 will be made to the Ministryof PublicWorks.
Role of Moroccan Organizations Moroccanenvironmental standards are being initiatedand draftedby an advisoryworking groupnamed "ConseilNational de l'Environnement"(CNE). CNE comprisesofficials from variousrelevant Ministries(Environment, Public Works, Agriculture, Industry-Commerce & Ardsans,Energy & Mines,Transpor Health, etc.) and also includesseveral non-governmental organizations(NGOs). These includeprofessional bodies, scientific institutions, and industrial associations.The CNE is chairedby a representativeof the Ministryof Enviromment.
The Ministryof Environmentwill reviewand approvethe JLPPEIA as requiredby the World Bank. The NGOsand the public will participatein the reviewand commenton the Project plan via the public fomm. Representativesof the public and NGOs are scheduledto meet at separateforums in July 1996 to discussthe proposedProject.
3.0 Project Description
This section describesboth the existing lLPP and the proposedexpansion of the plant. This discussionaddresses plant locationand surroundingfeatures, plant processes,and environmentaldischarges and controls.
Project Site Features The plant is locatedon a narrow stretchof landbetween a 60 m high bluffto the east and the Atlantic Oceanto the west.The plant site is generaly flat and at an elevationof approximately7 m abovethe referencelevel of Moroccoor Niveau g6neraldu Maroc (NGM) and is protectedfrom high waves and stormsby naturalsand berns, sea walls, and breakwaters. The Port of Jorf Lasfaris adjacentto the northernboundary of the site. The port has a portion of one pier dedicatedfor receivingimported coal for use by ONE. A coal conveyorsystem transportsthe coal from the port to the site.
Executive Summary ES-5 August 1, 1996 RADIALN- INTERNATIONALMB
There are several small settlementslocated on the bluff to the east of the plant. The nearest dwellingis within 75 m of JLPP fenceline.The immediatearea surroundingJLPP is in mixed agriculturaland industrialland uses with a large phosphateplant, Office Cherifiendes Phosphates(OCP), located approximately2 km northeastof the plant.
Description of Existing Facility The area within the JLPP fencelineoccupies approximately 60 hectares and was designed to accommodatesix 330 MW coal-firedsteam generatorsand support facilitiesassociated with a state-of-the-artpulvenzed-coal thermoelectric plant Constructionof the first two units (Units I and 2) was completedin 1994and 1995,respectively, by a consortiumof GEC Alsthom,B&V Espana, and DragadosConstructors. Table 2 presents the elementsof the existingfacility includingthe infrastructurethat will be used jointly by the existingand proposednew units.
In 1995,the JLPP produced4,100,000 MWh of electricity.The electricitygenerated is routed to a 225 kV substationwhich is connectedto the ONE systemgrid via five overhead225 kV transmissionlines.
Both Units 1 and 2 are designedto fire pulverized-coal,and/or heavy fuel oil No. 2; however,coal is the pnimaryfuel used to generateelectricity. Currently, coal is suppliedfrom the United States, Colombia,and SouthAfrica, with the majoritycoming from the United States.bn 1995,Units I and 2 consumeda total of 1,147,137tonnes of coal.
Coal is shippedto the Port of Jorf Lasfar and is unloadedonto a conveyorsystem which transportsthe coal from the Port to JLPP. The coal is then unloadedonto the coal pile storage area. In addition to storing coal for use at JLPP, this facility providesup to 700,000tonnes per year of coal for use at other ONE facilities.
Two types of water are used at the JLPP: 1) raw fresh water and 2) seawater. Raw fresh water is used for plant process opeations (i.e., steam genertion, equipmentcleaning) and treated for sanitarywater supply. Raw water is suppliedto the site from the El Jadida water systemvia condenseturbine exhaust steamso that it may be used again. Seawateris also used to convey bottom and fly ash to the AtlanticOcean.
Executive Summary ES-6 August 1, 1996 RZADLAN- INTERNATIONALU3
Table 2. Description of the JLPP
ExistingJLPP Facilities Two 330 MW pulverized-coalfired steamgenerators of the CEfSulzertype supplied by Babcock and WilcoxEspana; Two reheat steamturbines of the steamcondensing and bleeding type manufacturedby GEC Alsthom; Four (2/unit)cold side electrostaticprecipitators (ESP) with three fields each. The ESP'sare designedto remove99% of the flue gas partculatematter, A distibuted controland informationsystem manufactured by GEC Alsthom; Boiler buildingwith a height of 54.6 m; Turbine generatorbuilding, * Ash handlingbuilding; 1130 m stack - servingboth Units 1and 2, withseparate flues; * 225 kV indoorsubstation and five overhead225 kV transmissionlines, soliddielectric cable temination yard,a substationbuilding for equipment,and a substationcontrol house; and 60 kV switchingstation and 6.6 kV anxiliarysyste.
:E :L:g Fa- lithat wlle ommonto A1 FourUVits. Adminisuadonbuilding, Warehouse(sized for six electricgeneration units); A 1.5 km long openchannel to dischargeonce-trough condensercooling seawater to the Atlantic Ocean. The channelis sized to accommodateonce-through condenser cooling seawater from six units and widens to 26 m at the point of discharge; Two 90 cm diameterconcrete pipe wastewateroutfalls to the AtlanticOcean; * Machine shop and electonics repair shop; * Two - 50,O00 3 fuel oil storagetanks; One 500 m3 diesel-o storagetank; * One 25 m3 propanestorage tank; * Coal storageyard sized to store coal for six 330 MW steamgeneators. In 1995 the coal yard stored up to 400,000tonnes of coal at any one time; Coal handlingfacilities consisting of a conveyorsystem, transfer house, a stacker,and two reclaimers; * Fuel oil receivingand unloadingfacilities; Chlorinationsystem; Septictanks for sanitarywastewater generated onsite; Demineralizationwater productionsystem; Fire protectionsystem; Seawaterintake (sized for six units)and dikesto protectseawater intake area; > Auxiliaryboiler, Raw water supply(sized for six luits);and * Concrete-linedcoal pile stormwater runoff settlingbasin.
Executive Summary ES-7 August 1, 1996 INTERNATIONALM3
All wastewaterstreams generatedat JLPP are eventuallydischarged to the Atlantic Ocean.Water dischargesconsist of the followingtypes of wastewaterstreams: ash conveyance water,boiler blowdown,once-through condenser cooling sea water, sanitarywastewater, storm water, and demineralizerbackwash/regeneration wastewater.
Both bottom and fly ash are sluiced in two parallel pipelines (one for bottom ash and the other for fly ash) with a slip streamof incomingseawater and dischargedto the Atlantic Ocean. Both lines are submergedand extend 800 m into the Atlantic wherethe average depth is 13 m.
As of May 1996there were 144regular employeesworking at the JLPP. Accordingto the ONE managementstaff, virtuallyall of the employeeslive in El Jadida and commuteto work in companybuses. Figure 2 shows the JLPP plant layout includingthe site for Units 3 and 4.
Descriptionof ProposedExpansion The proposedexpansion consists of addingtwo new 348 MW power genemtingunits and various supportequipment. The additionalequipment is listed in Table 3.
Pendingfinancial closing, constructionof the new units is anticipatedto begin in March 1997. Constuction of Unit 3 is scheduledto take no greaterthan 33 months. Completionof Unit 4 is plannedto occur six monthsafter the completionof constructionof Unit 3. Unit 3 is currentlyscheduled to be operationalby December1999. At peak ime, approximately700 constructionworkers will be workingat the site. Both skilled (about53%) and unskilled workers (about47%) will be hired to constructthe units.
Constructionmaterials may be ttansportedto the facility via rail car or trucks. The constructionof new rail, port facilities,or roads is not requiredfor this project Moreover,all constructionand laydown areas will be insideplant site on areas that have been cleared of vegetationand previously distubed from earlier construction.Purchase or use of propery not currently ownedby ONE will not be requiredfor the constructionof Units 3 and 4. Also, no relocationof families living near the plant will be necessary.
Executive Summay ES-8 August 1, 1996 4- 1 <.1. -.
. ~ ~Alhi uckea
n E Q t~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~b:?8: a
II '~~~~~~~~~~~~~~~~~~I
Ou II'
/ \ ~~~~~~~Ash SluiceLlnesw P _7 g<
i I N Jt XTTT < z 0m~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ProposedUnits3&4
Flgure2. JLPPSlte Layout RZADIAN- INTERNATIONALE3
Table 3. Proposed Additions to JLPP
Two 348 MW pulverizedcoal-fired steam generators(Units 3 and 4) capable of firing coal or heavy fuel oil No. 2 as supportfuel only; Two steam turbinelgeneratorunits; Four (2 per unit) four-field,cold-side electrostatic precipitators designed to reducePM emissions from Units3 and 4 to 50 mg/m3 ; Two emergencydiesel generators; Expansionof the waler demineralzationsystem (including two 1000 mn3 demineralizedwater storagebasins) to providedemneralized waterfor Units3 and 4; Expansion of the seawaterintake pumping station; A 130 m stack wth separateflues to dischargeair emissionsfrom Units 3 and 4; A wastewar eatment systm designedto meet projecteffluent guidelines; Electricalbuilding-, Ash handlingsystem; Coal silos sizedfor at least 12 hours of full load operaton; Extensionof the coal staker and reclaime tracks by 300 m; Extensionof the two 750 tonneper hour coal conveyorsystems; Extensionof the coal weting system; A new raw water storage tank; and Ex*tnsionof the exising fir water sstem
In addition to the proposed new equipment, there will be several operonal changes:
Wastewater will be treated to meet World Bank effluent guidelines prior to disposal to the Atlantic Ocean. Wastewater from floor cleaning will be sent to an oil/water separator to remove oils and grease. The pH treaent of wastewater will be upgraded;
Disposal of fly and bottom ash in the Atlantic Ocean will be terminated once an apprprate alternative has becn implemented;
Fuel oil unloading operations will be modified in order to minimize fuel spillage; and
An Environmental Management Plan will be developed and implemented. The plan will address waste managnt procedures, environmental sampling, and environmental record keeping.
In order to keep emissions of SO2 from the JLPP within Project guidelines, both the existing Units I and 2 and the proposed Units 3 and 4 will use coal required to contain less than 1.25% sulfur by weight on an annual average basis. It is anticipated that the coal will be supplied
Executive Summary ES-10 August 1, 1996 RADILN- INTERNATIONALM3 from SouthAfrica, Colombia,and the UnitedStates. Units3 and 4 will use heavyfuel oil No. 2 for ignition,warm-up, and combustionstabilization below 35%load. Whenoperating at the anticipated capacity factor of 82%, Units 1 through 4 will consume approximately 3.3 million tonnes of coal per year.
Employmentat JLPP,following completion of Units3 and 4, will be approximately300. This is a net increaseof 156employees over staffinglevels in early 1996.
4.0 Environmental Baseline
This sectioncontains descriptions of the existingphysical, biological, and sociocultural environmentin the area potentiallyaffected by the proposedProject Key findingsfrom this baselinesurvey are describedbelow.
PhysicalEnvironment The most prominenttopographical feature of the immediatearea is the 50 to 80 m high bluffthat rises fromthe Atlantic Ocean.This escarpment forms a topographicalbarrier between the JLPP and the settlementsand coastalhighway that mns along the top of the bluff. The geologyof the Project site is coastalMeseta. The soil at the siteconsists of compactedsandstone, cementedby carbonates.
The climate is temperate.Winds are predominatelyeasterly and northeasterly-parallelto the coast Annualrainfall is variable,ranging from 210 to 740 mm.
Although the Project SponSOrshave begun collecting ambient air quality data for sulfur dioxide (SO2), oxides of nitrogen(NO,) and particulatematter (PM), sufficientdata are not yet availableat this time to fully characterizeair quality. Approximatelyseven weeks of ambient air qualitymonitonng conducted by the LaboratoirePublic d'Essais d'Etudes (LPEE)in 1994prior to operationof Units 1 and 2 was used in this EIA to make a preliminarydetermination of air qualityconditions. Based on these data, air qualityis generallyacceptable with the exceptionof occasionalshort-term high levelsof SO, concentrations.The S02 spikesoccurred when the wind was comnmgfrom the directionof the phosphateplant
Executive Summary ES-1I August 1,1996 RZADUIAN INTERNATIONALIM
Ocean water samplingat ten sites offshorefrom the JLPP site was conductedto determinemarine water qualityand sedimentconditions. With some exceptions,most parametersappeared to be normal for near shore conditions. Phosphatelevels in the water were uniformly high at aBlsampling stations. Two stations relativelyclose to the ash disposal site and the phosphateplant dischargechannel have copperconcentrations in the seawater abovethe acute toxicity level for marinelife. A seawatersample from a station on the north end (nearest the port) exceedsthe chronic toxicitylevel for mercury. The station nearest the phosphateplant outfall has concentrationsof mercmuyin the sedimentabove the thresholdassociated with 'possible"biological effects. In the sedimentfor all stations, copperand arsenic concentrations exceedthe thresholdfor "possible"biological effects but are below the thresholdfor "probable" biologicaleffects.
Groundwater,which is encountered6 m below the groundsurface involvesintermingling betweenfesh water and occan water. Oil and greaselevels were foundto be elevatedbut not above World Bank dischargelimits in a drinkingwater well sample.
A baselinenoise surveywas conducted.Ten of the 11 fence line measurementswere below the 70 L,, Project guideline.Noise levelsat the nearest off-siteresidential area measurementwere marginallyabove the stringent55 Ld,,level, which is the Project guidelinefor residentialareas. However,most residences are shieldedby the crest of the bluff from the direct propagationof noise from the JLPP. In general,noise conditionsare normal.There have been no complaintsfrom nearbyresidents.
Biological Environment The currentenvironment has been influencedsignificantly by several centuries of human habitation.There is only sparse vegetationimmediately outside the JLPP and virtuallynone inside. The only terrestial animalsobserved during a biologicalinvestigation were domesticated farm animals and pets outsidethe JLPP site. There are 10 endangeredor threatned species that may have Morocco as their historic range.None were observedon the biological survey and it is highly unlikelythat they are presentin the areasthat may be affectedby the proposedProject
Marine biological samplingwas conductedoffshore from the JLPP. The diversityand quantityof fish and benthos in the sediments is consideredlow. This investigationdid not determinethe cause of these apparentlylow qualitymarine biologicalconditions. The high
Executive Summary ES-12 August 1, 1996 RADIAN INTERNATIONALM energy shoreline (rocky beach and heavy wave action) may reduce marine biodiversity. High metals concentrations in seawater and sediments may also be a contributing factor.
Social and Cultural Environment No archeological or historical sites are known to exist on the site. The nearest identified sites are eight kIn to the north.
The demographics of Morocco and the area around the plant are characterized by a rapidly increasing and very young population. The annual rate of increase exceeds 2% and more than half of the population is less than 20 years old.
Despite improvements in the national economy, the unemployment rate is 15 to 20% and many rural residents in particular are underemployed and poor. Agriculture is important in the vicinity of the JLPP. The largest employers in the area are the phosphate plant, which employs 3200 persons, the port of Jorf Lasfar, which has 140 full time employees but frequently hires up to 1000 temporary dock workers, and the JLPP, which has 144 employees at present. Virually all of these workers commute in company operated buses between their homes in the El Jadida urban area and the work sites.
Economic growth is tied closely to electric power availability and reliability. Recent curtailments of electric power resulted in an estimated 1% drop in the gross national product. The expansion of the JLPP will result in increased employment and a likely multiplier effect fostenng growth of business and employment in the surrounding area.
Land use in the local area is characterized by the industrial complex currently comprising the port, the phosphate plant, and JLPP-and an encircling rural area. The rural area appears unchanged by time. Traditional methods of agriculture are practiced. There are no towns-only clusters of stucco dwellings in small settlements. The future land use projections indicate conversion of vacant lands set aside for industrial development. Aesthetic resources are high with several scenic vistas. There are no protected areas, nearby parks, or otherwise wild areas.
Executive Summary ES-13 August 1, 1996 IRADLAPN- INTERNATIONALMS
5.0 Audit of Existing Conditions
An environmentalaudit conductedat the JLPP in 1995 identifiedthe following environmentalconcerns:
Shallow soil contaminationfrom fuel oil spills, primarilyat the tank car unloading area;
Lack of sufficientambient air qualitydata to confirmearlier data by ONE that indicateoccasional, short-term, high backgroundambient SO2 concentrations (from the directionof the neighboringphosphate plant);
Occasionalexcursions of pH in wastewaterdischarges and inadequatetreatment of storm water runoff;
Disposalof fly ash and bottom ash in the ocean; and
Hazrdous chemicalshandling, storage and tracking.
The Project Sponsorswill addresseach of these concems.
6.0 Potential Future Impactsof ProposedExpansion
This section describesthe impactsof constructingUnits 3 and 4 at the JLPP and the incrementalimpacts of operatingall four units.
6.1 Impacts of Construction The land for Units 3 and 4 is alreadygraded and clearedof vegetation. The constructionsite is an industrialarea with high humanactivity and containsno wetlands or sensitive environmentalhabitats. New propertyor roads will not be required. Therefore, the constructionactivities will have little or no impact on the land resources.
During constructionactivities, unavoidable air pollutantemissions are likely to occur. The most prevalent constructionenissions are fugitivedust. Fugitivedust control measures will be implementedduring construction.Minor emissionsof NO2, S02, carbonmonoxide (CO), PM and volatile organic compounds(VOCs) are also likely during construction.Overall, the impact
Executive Summary ES-14 August 1, 1996 RAORDL^N INTERNATIONALMB
of heavyconstruction activities and site preparationon air qualitywill be short-termand confined to the immediatevicinity of the constructionactivity.
The only surfacewater body that may be affectedby the constructionat JLPP is the Atlantic Ocean. Althoughthere is a slight potentialfor oil spils or leaks to reach groundwater, the Project Sponsorswill assurethat appropriatemeasures are implementedas necessaryto prevent adverseimpacts to the oceanand to groundwater.
No impactto biologicalresources to the land are expected.The constructionsite for Units 3 and 4 is a graded,industrial area that is alreadyhighly impacted by humanactivity. The constructionsite is not habitatfor flora, fauna,wildlife and other biologicalresources. Little or no impactto biologicalresources in the marineenvironment are expectedfrom the additionof two more units to the existingJLPP facility.No constructionwill occur over water.Measures for preventingsurface water runoff and sedimentloading will protectmarine biology.
No impactto archeologicaland histoncal resourceswill occur becauseall construction will occur in areas that have beenpreviously disturbed by the constructionof Units 1 and 2.
The constructionof JLPP Units 3 and 4 will have positivesocial and economicimpacts. The constructioncontractor anticipates that at least 700 personswiDl be hired dunng peak constructionwith an averageof 500 personsduring the 39-monthperiod of construction. Approximately47% of the constructionworkers will be classifiedas unskilled.Many of these workerswill be drawn fromthe manysmall settlementsaround the JLPP. Otherswill be hired from El Jadida and otherMoroccan cities. It is likely that manyof these unskilledworkers will come from the ranks of the unemployedor underemployed.Many of the skilledworkers will also be Moroccansalthough the numberof in-countryversus foreigpworkers has not yet been determined.Although temporary, this constructionactivity will createa stimulusfor local and regionalincomes.
Anothereconomic benefit of the constructionwill be the estimated$43 million (U.S.) that will be spent to purchaseother Moroccangoods and services.Most of the heavy equipment for the power plants, such as generatorsand turbines,will be purchasedfrom Europe and the U.S. Capital equipmentpurchases will be fromthe U.S., Italy,and Switzerland.The JLPP sponsorswill purchaselocal construction material such as concretewhenever it can be procured.
Executive Summrny ES-15 August 1, 1996 IRAbL^N INTERNATIONALOB
Thus, the constructionwill createjobs and economicgrowth both in Moroccoand intemationally.
Frequently,large capital projectsin rural areas createadverse socioeconomicimpacts as a result of sudden and large demandsfor housingand other services.This "boom"effect is then followedby a "bust"as the constructionworkers and their families move on to other projects. The constructionof Units I and 2 in the early 1990sdid not create this boom and bust effect for two reasons.First, a large number of rural Moroccansare unemployedor underemployed. Therefore,there was no need to bring in non-localunskilled workers. Second, the City of El Jadida had adequatetemporary housing availability for the remainingworkers who commutedto the work site each day by bus. The bus servicewas arrangedby the constructioncontractor.
The contractorfor Units 3 and 4 has indicatedthat they anticipatea similar patternfor the future construction:unskilled workers hired from the immcdiatearea and temporaryhousing in El Jadida for the skilled and unskilledworkers who do not live in this part of Morocco.No "tent cities" or other offsite temporaryhousing is necessaryand none is planned.Because the workers will either walk to the site or will be bused in by the contractor,there shouldbe no traffic congestionor parking problemsoften associatedwith large constructionprojects.
Construction-relatednoises will be temporaryand intermittent. Moreover,the great majority of the homes in the nearestresidential areas are shieldedby the crestof the bluff from the ground-levelnoises at the power plant and thereforewill be even less affectedby constructionnoise becauseof the terram.
6.2 Impacts of Operation
Land Use and Transportation The operationof Units 1 through4 at the JLPP will have a negligibleimpact on existing land use. Constructionof the new units will not require the purchaseor use of land outside of the JLPP propertyboundaries except as neededfor an ash disposalsite. All constructionand operationwill be on land that has been previouslydisturbed and convertedto heavyindustrial land use. Becauseof local land use controlsaround the industrialarea, there will be no induced or secondarydevelopment such as housing tractsfor new workers,restaurants and grocerystores, or after-workrecreational and leisureretail establishments.
Executive Summary ES-16 August 1, 1996 INTERNATIONAL1
The proposed Project will not adversely affect transportation. The planned transport of JLPP workers using buses should effectively minimize increased traffic congestion along the El Jadida to JLPP stretch of Route 121. Increased coal use will result in a greater number of coal shipments through the port; however, the dock expansion and the current under utilization of port capacity indicates that the incremental increase in coal shipments will not create ship congestion in the port.
Air Quality
Emissions of SO2, NO., and PM from the project are expected to increase from current levels. Emissions are anticipated to be within the project environmental guidelines, with the exception that PM emissions from existing Units 1 and 2 will meet the ESP performance guarantee of 125 mg/m3.
Increases in stack emissions and their corresponding impact on ambient concentrations were evaluated as part of this environmental impact analysis. Table 4 presents a description of the emission estimation procedures for each investigated pollutant The futre ambient air concentrations were calculated using a very conservative dispersion modeling analysis, and were compared with applicable Project guidelines. The modeling results indicate that the impact of the increased emissions will not significantly impact air quality near the JLPP operations.
Ambient concentrations of SO2 and NO, were determined from imited ambient monitoring performed by the LPEE in 1994. No PM sampling was performed. This sampling was done prior to operation on JLPP Units 1 and 2 and thus are not considered baseline concentrations for the purpose of this project Project baseline ambient concentrations will include the existing impacts from JLPP Unit 1 and 2 operations. Radian is currently collecting ambient concentration data which will be included in the final version of this EIA. The results from the 1994 LPEE sampling indicate that the region surrounding the proposed project complies with Project guidelines for these two pollutants on an annual average basis. Measured NO2 concentrations were significantly below the Project guidelines and are not considered of concem for this project
Executive Summary ES-17 August 1, 1996 INTERNATIONALEM
Table 4. JLPP Maximum Air Emissions
EstimatedCurrent MalxmumPotential MamninPotentw MaximumEmissions pmissionsfrom EUIissionA, Units froin Unitsl and 2 Units land2 I throu&4 -Poflltmat (tonne~ddlY) .1 (tonnes/daY) (tonneslday) SulfurDioxide 79.2' 158.42 271.23
NitrogenOxide 34.54 35.15j 70.66
Particulate, 1.4' 5.9g 849
I - Based on 0.75% S coal (0.12tonnetMW-day) and 100%capacity factor. 2- Based on 1.5%S coal (0.24tonnMW-day) and 100%capacity factor. 3- Based on 1.25%S coal (020 tomne/MW-day)on all 4 units. 4- Based on tested emissionsof 256 ng/J,heat rates of 2065 kcalAkWh,and 100%capacity factor. 5 - Based on emissionsof 260 ng/J,heat ratesof 2065 kcalJkWh,and 100%capacity factor. 6 -Based on Predictedemissions of 260 ngIJ,heat ratesof 2065 kcal/kWhfor Units I and 2 and 2080 kcal/kWhfor Units 3 and 4. and 100%cpacity factor. 3 7- Based on tsted emissionsof 30 mg/Nm, 100%cpacity factor. '- Based on ESP guarante of 125 m/Nm3 , 100%capacity factor. Calculations located in AppendixF of themain reprt 9 -Based onemissions of 125mgNm3 onUnits I and 2 and50 mg/Nm3 on Units 3 and4and 100% capacityfactor on al 4 units.
S0 2 concentrationsvaried significantly but the annual averagehourly concentraion was 3 detmined to be 18.5 ug/m3, well below the Project guidelineof 50 pg/r annual average. 3 However, the maximumdaily S0 2 concentrationmeasured during the testing was 285 ,glm , which is abovethe Project guidelineof 125pg/mWI). Based on wind directiondata and the fact that the testing was performedprior to operationof JLPP Units 1 and 2, the source of these high 52 excursionsis believedto be the OCPphosphate plant located near JLPP. During the testing, which lasted 7 weeks, there were 7 occurrenceswhen the measuredS02 concentrationwas above the OPIC guidelineof a maximum 1-hour averagelevel of 350 tgmi?3.
Ambient dispersionmodeling for SO2, NO2, and PM was performedby Radianto predict the incrementalimpacts of the 4 unit operationrelative to the measured 1994 ambient concenrations. This approachis consideredvery conservative for the followingreasons:
3 X The Project guidelineof 125 ig/i wasdernved from the US OPICguidelines. 1988World Bank 3 Guidelinesrecommend a maximun 24 hour averageSO 2 concentrationof 500 jig/n outside theplant fence line.
Executive Summary ES-18 August 1, 1996 INTERNATIONALM
3 1. The analysis assumed an existing ambient SO2 concentrations of 285 pg/M (single highest 24 hour average) which is based upon a very limited duration sampling episode. This short sampling period will also artificially inflate the period (annual) average;
2. The project baseline was adjusted to include modeled maximum current ambient impacts of 41 pg/m3 from Units 1 and 2 operations, even though the modeled maximum impacts occur at locations different from the maximum measured concentration; and
3. Allowable incremental increases were based upon keeping ambient incremental increases of S02 to well below World Bank Criterion n guidelines.
The World Bank guideline for the allowable S02 emissions increase for an area with a maximumambient 24-hour average concentation of 326 ig/rn3 is 250 tonne/day. Based on the firing of an average 1.25 wt % S coal, the expected SO. emission increase over current operating levels is 192 tonne/day. In addition, the World Bank, Criterion II guideline for incremental increase in annual average SO2concentration for this area is 25 g/rn3 . Dispersion modeling predicts that the maximum annual average SO2 concentration due to continuous operation of all four units at 100% capacity factor, firing 1.25 wt % S coal, is 14.1 pg/m3, just over half the allowable Criterion H level. The conservative assumptions employed and the ample margins below the guideline values assure that the Project will not significantly impact local SO2 air quahity. The Project is currently collecting additional ambient air quality data and this analysis will be updated appropriately when sufficient data become available.
Maximum predicted NO2 and PM emissions from all 4 units were also modeled to evaluate the potential ambient impacts. At the Project guideline NO, emission rate of 260 ng/J, the predicted ambient impact is less than the Project guidelines of 100 pg/rm3 annual average and 150 ptg 3 maximun 24 hour average. The Project Sponsors have assured that PM emissions from Units 1 and 2 will be below the ESP performance guarantee of 125 mg/Nm3 . Although this is above the Project guideline of 50 mg/Nm3 , this emission rate on Units I and 2, even when combined with the impacts from Units 3 and 4, results in ambient concentrations that are less than 2% of the 24-hour ambient Project guideline of 110 ug/m3 and 0.4% of the annual ambient Project guideline of 70 gm3 . Thus, PM emissions from all 4 units will not pose any risk to human health or the environment.
Executive Summary ES-19 August 1, 1996 INTERNATIONALM3
Surface Water Quality Due to the topographyof the area, the only surfacewater that could be impacted by JLPP is the Atlantic Ocean. At present, JLPP dischargesits ash, wastewater,and storm water to the ocean.
The proposedexpansion of JLPP includesmajor changes in ash and water management. Ash discharge to the ocean will be discontinuedonce an acceptableoption is found. Storm water will be treated to assurecompliance with Project guidelines. Sanitarywastewater will receive biologicaltreatment and final disinfectionof effluent. Metals will be removedand pH neutralizedon cleaningwastewaters. These changes will ensure that the impact of JLPP on surfacewater will be significantlyTeduced,notwithstanding the expansionof power generation.
Groundwater Quality Groundwaterquality is not expectedto be adverselyimpacted by the proposed Projeco The addition of Units 3 and 4 will includea storm water and wastewatercollection and treatment systemdesigned to meet all Project dischargeguidelines. Consequently,the groundwaterwill be better protected, which is importantto localresidents who obtain their drnking water from a well near the entance to the plant JLPP will continueto obtain all its process water from a pipeline, so no local withdrawalsand concomitantlowering of the groundwatertable will occur.
Surface Water-Thermal Impacts The JLPP Units 1 and 2 condensersare cooledby way of once-throughcooling water dischargedinto the Atlantic Ocean.Histoncal ambientwater temperaturedata of the region mdicatethat the ambientwater temperaturedoes not exceed25°C. The coolingwater flow rate, temperue, and the ambient ocean water temperaturewere measuredin the field during the fall of 1995 and the spring of 1996. Tlhefield results indicatedthat the Units 1 and 2 thermal dischargesare well withinthe Project guidelines. The net temperatue increase 100 m away from the dischargepoint is about 1'C.
The field results were used to calibratea numericalmodel of the thermal dischargesfor all 4 units. The model results indicatethat the thermaldischarges of all 4 units result in a net temperatre increase at a distance of 100m away fromthe dischargepoint of less than 2.2°C, well within Project guidelines.
Executive Summary ES-20 August 1, 1996 RAORAMN INTERNATIONAL3
BiologicalResources-Land The operation of Units 1 through 4 will have no significant impact on terrestral biological resources. As described in Section 3, there are no biological resources within the area to be distrbed by the construction and to be occupied by the new facilities associated with the proposedProject. Because the land use surroundingthe JLPP will not undergochange as a result of inducedgrowth, the plant and animalhabitats will not be disturbed.
BiologicalResources-Marine The operationof Units 1 through4 will haveno adverse impacton the marine environment.It is probablethat the Projectwill benefitthe marineecology through the cessation of ocean ash disposaland improvementsin waste water quality.
SocioeconomicImpacts The socioeconomicimpacts of the operationof Units 1 through4 are positive.In particular,the proposedProject offerssignificant direct and indirecteconomic benefits to the nation.
The expansionof the JLPP will requireapproximately 156 new employees.This increase in the permanentwork force wouldincrease staff levels from 144at present to approxiimately 300. Most of these new positions will be from the local (El Jadidaarea) work force. These positiveimpacts will be direutedlargely to the El Jadidaurban area where the new employeesare likelyto reside.Although the largelyunskilled laborers in the immediatevicinity of the JLPP will benefit from constructionhiring, only a few permanentstaff positions are expectedto be filled by those living in the immediatevicinity of the JLPP.
Accordingto local planningauthorities, the City of El Jadida is expandingits low and moderateincome housing stock to ensure that adequatehousing is availablefor new workers in the area-includingthe JLPP expansion.Some 27,000 new housingunits are plannedto be developedby the year 2000 in areas that are servedby water, sewer,and electricpower utilities. By maintainingconvenient employee transportation to and from the JLPP, the Project Sponsors can assure that growthfrom new employmentwill be channeledlargely to the El Jadida area whereadequate housing and serviceswill be available.
ExecutiveSummary ES-21 August 1, 1996 R^IAN- INTERNATIONALMR
The aesthetic impacts of the proposed expansion will be minor. There will be an additional flue gas stack that will be visible for several kmnalong the coast highway. Two additional generating units will be visible closer to the JLPP. Most of the new expansion, like the existing plant, will be shielded from view as a result of the terrain.
During the local permitting of the existing facility, an objection was raised by permitting authorities to the architectural design in the original plans. The building contractor worked with local authorities to develop an architectural motif that incorporates Moroccan Arabic design and that reduces some of the typical "industrial" look to the facility. This architectural motif will be incorporated into the two new units.
The most significant benefits of the proposed Project will be the increase in quantity, availability and the reliability of electric power to the nation. The Moroccan economy has improved in recent years; however, future economic progress is challenged by relatively high unemployment levels and problems with the availability and reliability of electric power. As shown in Figure 3, JPP is expected to account for approximately one-half of Morocco's electric power generation by the end of the decade. The addition of Units 3 and 4 are absolutely essential to avoid future losses in gross national product and increases in the cost of doing business as a result of recent electric power curtailments.
The benefits of the increased capacity from Units 3 and 4 will also dectdy affect most of the Moroccan rural population that is currently without electric power. Many of these nrual villagers, who comprise approximately half of the country's population, will enjoy the benefits of electric power over the course of the next decade as a result of the rural electrification program. The success of this program depends, in part, upon the availability of electric power from Units 3 and 4.
Through the privatization of JLPP Units 1 and 2, the Government of Morocco will receive monetary benefits of an upfront payment of $263.1 million (US). Through the construction and operation of Units 3 and 4, additional power will be brought on line without the need for the increased indebtedness that would occur if JLPP were not privatized.
Noise Noise impacts from the operation of the new units will not adversely affect the off-site residential areas and will remain within Project guidelines for fence line impacts. Blowing safety valves will be the loudest sounds from the plant. These should be very rare occurrences, but
Executive Summary ES-22 August 1,1996 *INTERNATIONALMIURNL
Total Moroccan Electrc Power Requirements
lo 0
0
'U Proposed 0 Unts3&4 a,
_ - tJUnits1 & 2
1993 1994 1995 1996 1997 1998 1999 2000
SOwUMWuD Brin YEAR
Figure 3. Corntibutfon of JLPP to Morocco's Future Electricity Needs
Executive Summary ES-23 August 1, 1996 RZADUIN-K INTERNATIONALM3
when they occur, they can startle nearby employees, and to a lesser extent, wildlife and the public. The nearest off-site residential areas will be shielded from most of the JLPP noises by the crest of the bluff.
Worker Health and Safety As discussed in Section 8, the operator of the Project will institute a worker health and safety program that will minimize the potential for accidents. These measures will be in line with operating practices at plants in the U.S. and Europe.
7.0 Analysis of Alternatives
The EIA evaluated altematives relating to the project site, fuel selection, coal technology selection, air emission controls, wastewater treatment, and alternatives to ocean ash disposal.
The JLPP site is the most cost-effective site for futre base load expansion because it was originally desiped for additional units and certain common facilites for Units 3 and 4 are already installed. The incremental cost of adding these umits given the existng infrastucture is low relative to greenfield sites. The original rationale for this site is its proximity to the port (ready access to imported coal), proximity to the ocean (availability of sea water cooling), and proximity to the utility's largest customer, the phosphate plant
Although natural gas is a cleaner buming fossil fuel, natural gas pipeline supplies and pipelines are remote from the site and gas is more expensive. Heavy fuel oil is also more expensive and not appreciably cleaner burning. Light oil is appreciably more expensive. The JLPP infrastructure is designed to handle coal. Any change in fuels would lessen the advantage of using the existing infrastructure.
Clean coal technologies, such as fluidized bed combustion and integrated gasification combined cycle technologies, result in less environmental discharges than does conventional pulverized coal (PC) combustion. However, capital costs are higher and lack of operating experience on a plant of the proposed size make these impractical for Morocco at this point. Moreover, the JLPP site developers were constrained to the use of PC technology by the proposal request issued by ONE.
Executive Summary ES-24 August 1,1996 RADUIAN INTERNATIONAL1n
Several emission control altematives were examined in order to reduce SC2 and PM emissions. These include use of ultra low sulfur coal, use of "cleaned" coals, use of a seawater scrubber, or use of a limestone scrubber. It was concluded that Units 3 and 4 are capable of meeting Project guidelines using the analyzed coals. Therefore, further consideration of these strategies is not warranted due to the additional capital and operating costs.
The wastewater system for Units 3 and 4 is comprised of the following:
Coal pile runoff will be treated before offsite release;
Sanitary wastewater will be conveyed to a biological treatment system for removal of BOD5 and suspended solids. The effluent will be disinfected prior to discharge;
Effluent from the demineralizers and other chemical wastewaters will be neuwalized;
Metals-containing wastewater will be treated before discharge;
Oily wastewater will be treated before offsite discharge.
Treatment of these wastewaters will be accomplished by methods proven successful at power plants throughout the world. The Project Sponsors are committed to ending the practice of ocean ash disposal once a reasonable altemative for disposing or marketing the material can be implemented. The most advantageous alternative to ocean dumping is beneficial reuse. There are basically two general methods for achieving this advantage: returning the ash to the coal supplier for beneficial reuse outside of Morocco, or developing markets within Morocco. In either case, the ash could be put to beneficial use in the cement and concrete industry, in agricultural settings, or in the construction industry. Furthermore, the use of ash as a resource is not restricted to any particular industry, but can be put to use in all these areas.
It is currently anticipated that beneficial use of all of the ash will be either impractical or cost-prohibitive, and the most likely solution for ash disposal is land disposal. Two potential land disposal sites are shown in Figure 4. One is the quarry used to build the port jetties and dikes; the other is an area unsuitable for agriculture south of the JLPP. The area to the south of JLPP is closer, but the impediments to this site potentially include land acquisition, potential for groundwater contamination, and the inordinately high landfill elevations required to dispose of
Executive Summary ES-25 August 1, 1996 NORTH LEGEND 7- Transmaon ~~ L~uines
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CurrentAshcto ur fAlentv s Dsoa ie .~~~~Fgr 4. Loato of Altjerntv Ash DispospalStePt)s Ex DtieSummalyE-6Ags ,19
Excuiv 'SumayES2 Auut 1,99 RADANE INTERNATIONALM
the ash expectedto be generatedover the 30 yearJLPP concession.This land area may be viable as an interim landfill. However,it may be possibleto use the quarrydepending on the results of initial geotechnicalinvestigations to determinethe probablefate and transportof leachatefrom the landfill operation.Assuming the run-on and leachatecan be properlyhandled, and the groundwatertable does not directlycontact the bottomof the quarry,this location would appear to be the better altemative.
8.0 Mitigation and Environmental Management Plan
Mitigativemeasures are necessaryto protectthe environmentfrom impactsresulting from the construction and operation of the new JLPP Units 3 and 4.
Mitigation of Construction-related Impacts Potentialenvironmental and humanhealth impacts during constructioninclude: increased fugitivedust emissions,soil erosion,stormwater runoff and sedimentloading, groundwater contamination,and workerhealth hazards.
To mitigateincreased fiugitive dust emissions,dust suppressioncontrol methodssuch as spraying water on roadsor dirt areas will be applied. Tmcks cafrying fine material may be sprayed or coveredas necessaryto reducethe generationof dust. Also, vehicularspeeds will be controlledand buses will be used to transportworkers to and from the Project site.
Erosion controlmeasures such as silt curtainsand haybales may be used to prevent stormwaterrunoff from carryingsediment and/or surface water contaminationto drainageareas and the Atlantic Ocean. Site retentionareas or sedimentretention ponds may be constructedto handle storm water runoff.
Spill preventionand cleanup practiceswill be implementedas necessaryto prevent contaminationof stormwaterrunoff and possiblygroundwater from accidentalspills or leaks from constructionequipment. Dewateringmethods may be appliedto removesurface water and shallow groundwaterfrom poolingin excavationareas and preventpossible contaminationor sedimentloading from constructionactivities.
Executive Summary ES-27 August 1, 1996 RADIANN INTERNATIONAL3
Mitigation of Operations-related Impacts
Emissionsof SO2 and NO, are expectedto meet Project guidelinesfor the current coals being considered. The followingmeasures will help assure that complianceis maintained.
Monitoringcoal sulfur contenton a per shipmentbasis to control S emissions;
Proper operationand maintenanceof coal burners and registersto control NO, emissions;and
Proper operationand maintenanceof ESPs.
In addition to stack discharges,emissions from other sources will be minimizedby:
Regularlyspraying the coal pile with water to reduce fugitive dust emissions; and
Good housekeepingto minimizeVOC emissionsfrom paints, solvents, cleaning fluids, and fuel oil.
The followmgmitigative measures involving surface water, ash disposal,wastewater, traffic conditions,health and safetywill also be taken to ensure that JLPP is in full compliance withProject guidelinestandards of operation:
Settlingbasins for coal pile stormwaterrunoff will be used to interceptthe suspendedmatter.
Ash disposal at sea will be eliminatedand replacedwith land disposalutlization of ash once an acceptableoption is establishedby the Project Sponsors.
Treatmentof sanitarywastewater will be implementedto prevent contamination.
If truck tasport of coal ash is used, appropriatetraffic signalsand other controls will be implementedas necessaryto prevent highwaycongestion and accidents from increasedtraffic to the JLPP facility.Also, transportof JLPP workers is expectedto continueafter constructionof the new units and will reduce traffic congestionalong Route 121.
Lighting will be installedas requiredon stacks for aircraft warning. Also, Project Sponsorswill providelandscaping.
Efficientconstruction and operationwill minimizethe generationof waste.
ExecutiveSummary ES-28 August 1, 1996 RADUOAN- INTERNATIONALU
An environmentalmanagement plan as well as a worker health and safetyplan will be implementedto promoteand maintainsafe and environmentallysound operationpractices.
Environmental Managementand Training A subsidiaryof CMS GenerationCo., as operatorof the Project (the "Operator"),is obligatedunder the operationsand maintenanceagreement to operatethe JLPP in such a manner that it complieswith the JLPPProject guidelinesof Table 1. The Operatorhas developeda comprehensiveenvironmental management implementation plan (the Plan) that definesgeneric roles, responsibilities,and activitiesto be implementedat any facility it operates,to assure environmentalprotection and compliancewith requirements.The Plan containsan environmentalpolicy statementthat requiresthe JLPP facilityto 1) comply with environmental requirements,2) plan and performactions in supportof environmentalprotection, 3) effectively communicateenvironmental issues, 4) establishresponsibility for environmentalperformance, 5) developstandards and proceduresto implementthe policy,and 6) regularlyreview intemal conformanceof the policy.
Specificto the JLPP facility,the Operatorrequires compliance with the following corporatestandards:
Acquisitionand Possessionof Permits -JLPP shouldhave a copyof all applicable permitsand approvalson-site and obtainall permitsor approvalsrequired for site modifications.
Compliancewith Requirements- This standardensures that JLPP facility managementis aware of environmentalrequirements, and will establishthe organizationaland financialresources necessary to assurecompliance with permit and regulatoryrequirements.
CommitmentSchedule - requiresJLPP to developan annualschedule describing environmentalinspection, monitoring, reporting, notification, training, records managementand other similarperiodic commitment requirements.
Training- requiresall employeesreceive environmental training commensurate with their job responsibilities.
EnvironmentalExcellence - encouragesJLPP to achievehigh levels of compliancewith emissionand dischargelimits, and seek opportunitiesto minimizewaste.
Executive Summary ES-29 August 1, 1996 I NTERNATiONALIM
AgencyMeetings/Discussions and AgencyInspections - authorizesthe JLPP Plant Managerto communicatedirectly with representativesof govemmentalagencies on environmentalmatters.
Responseto EnvironmentalEmergencies - requiresJLPP to develop an environmentalemergency response plan to guide the plant's responseto an actual or potential significantrelease (e.g., spills, gas leaks, explosion,etc.) to the environment.
FPeriodicRoutine Reporting and NonroutineReporting - requiresJLPP to handle routine communicationwith governmentalenvironmental agencies and to report monthlyto Operatormanagement the status of its environmentalcompliance activities.
Recordkeeping- JLPP maintainsfiles of all permits,standards, requirements, corespondence,procedures, monitoring data, etc necessaryfor proper documentationof its environmentaland complianceactivities.
Audits, Assessments,and Appraisals- JLPP receivesperiodic internal and independentassessments of its complianceand environmentalmanagement actvities.
9.0 Monitoring Plan
The Project Operatorwill conductenvironmental monitoring, recordkeeping and reportingduring both constuction and operationalphases of the proposedProject as summarized in Table 5.
10.0 Interagencyand Public Participation
The interagencyand public participationprocess includesdiscussions with relevant governmentagencies, non-govermmental organizations (NGOs) and the generalpublic.
The governmentinteragency input consistedof a series of interviewswith key govermmentagencies. These agenciesinclude:
*- Office Nationalede l'Electricite (ONE);
*- Ministere de l'Environnement(ME);
Executive Summary ES-30 August 1, 1996 Table 5. Summary of Monitoring, Recordkeeping,and Reporting to be Conducted at JLPP
______-__T_--______m . S._____, __ 8~~~~~~~~~~~~~~~~~~~ 2.~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~-ik - . Rto6origl:ng Ug ~Phasie Category ; .*-:. - -* f.J. eoke1Rprd*g o- Construction FugitiveDust Ongoingbaseline ambient air monitoringwill If excessivefugitive dust is Annualreport required 2 detectconstruction dust during initial detected,mitigation measure by lendersand Moroccan >Z constructionphase. Thereafter visual appliedand recorded. government.nd _ observationof dust.
Hazardousmaterials Thecondition of tanksand drumscontaining If spill is noted,describe In annualreport spills hazardousmaterial will be routinelyinspected material,amount, cause, and clean up methodsutilized.
Operations Groundwater Annualsampling for oil and grease,heavy Maintain laboratoryanalysis and In annualreport. metals,pH, andconductivity at existingwells. watertable depthfor 5 yearsat a minimum.
WasteWater -Monthly samplingof pH. temperature,residual Maintain logs of samplingdates In annualreport chlorine. and laboratoryanalysis for 5 -Monthly samplingof heavymetals and yearsat a minimum. biological oxygendemand. -Samplingat all outfalls.
Air Emissions -Annualtesting of eachunit individually. Includestack test report in In annualreport -Pollutants- SO2, NO., PM annualreport. Maintain for S -Unit load during testingto beat 80% or yearsat a minimum greaterof ratedoutput.
BaselineAmbient Air -May 1996- May 1997(12 months) Maintain for 5 yearsat a In annualreport Quality -PollutantsS02, TSP, PMI,, NO. minimum
OperationalAmbient -12 monthsafter Unit 4 becomesoperational Maintain for 5 yearsat a In annualreport Air Quality -Pollutants- SO2,TSP, PM 1O,NO, minimum Noise/SourceTesting -Onetime only Maintain for 5 yearsat a In annualrepott -All sourcesfor which contractorguarantees minimum sourcelevels Noise/Occupational -Annualmeasurement Maintain for 5 yearsat a In annualreport -Identify zones85 dBA minimum Air -Annualmeasurement Maintain for 5 yearsat a In annualreport
%_ quality/Occupational-Pollutants - CO NOV,PM.., SO, minimum RADUPINM INTERNATIONAL1!
Office d'Exploitationdes Ports (ODEP);
Departmentdes TravauxPublics (DTP);
Office of the Governorof the provinceof El Jadida; and
Officeof the Caid of the Communeof MoulayAbdellah.
Two public fornms wereheld in Moroccoprior to the approvalof this EIA by the Moroccan Ministryof the Environment. The purposesof the forum were to informthe public about the scope of the Project,present environmentaland socioeconomicimpacts, and solicit input from the public on the Projectand the EIA methodsand results.The approach and the results of the EIA werepresented by representativesof Radian International.The forums were hosted by AFAK,a MoroccanNGO dedicatedto informingthe public and to improvingthe quality of life for the Moroccanpeople.
The first forum was for citizensliving in the vicinity of the Project. This citizens forum was held on July 11, 1996 in the auditoriumof the ODEP,which is locatednear the JLPP. More than 150persons were present resenting each of the 30 communesin the Provinceof El Jadida. Followingpresentations by the Project Sponsors,ONE, Radian,and various governmentalauthorities, including the Governorof El Jadida, there was an opporunity for public questionsand comments.Because the citizens living near the Project site are predominatelyArabic speakers, this forum was conductedlargely in Arabic.
The secondforum was for NGO representatives.It was held at the SheratonHotel in Casablancaand was attendedby approximately120 persons from among the more than 25 NGOs that had been invited to attend. The forum was conductedin French and followeda similar format to the citizens forum the day before. Iu additionto the NGOs, membersof the news media were also in attendance. Summariesand excerptsof the presentationsand the comments and responses from both forums are presentedin Section 10 of this EIA.
Executive Summary ES-32 August 1, 1996 I I RAORALN- INTERNATIONALM
1.0 INTRODUCTION
CMS GenerationCo. (CMS)and ABBEnergy Ventures Inc. (ABB),hereafter referred to as "ProjectSponsors", are forminga joint venture,the Jorf LasfarEnergy Corporation (JLEC), for the purposeof acquiringthe right to use and operatetwo existing330 Megawatt(MW) coal- fired units and the constructionand operationof two additional348 MW coal fired units at the Jorf Lasfar PowerPlant (JLPP)in Morocco. This ABB/CMSconsortium activity is pursuantto the terms of: 1) Memorandumof Understandingexecuted on September19, 1994,and 2) Protocolexecuted on April 26,1996 withMorocco's Office National de lElectricit6(ONE). The privatizationand subsequentexpansion of the JLPP (the 'Project") is a vitalpart of Morocco'splans to meet a rapidlyincreasing demand for electricpower.
1.1 Purposeof this EIA This EnvironmentalInpact Assessment(EIA) has been preparedby Radian International (Radian)under contractto CMSand ABB. The EIA is requiredas a conditionfor obaining project financingor loan guaranteesfrom the WorldBank, the Export ImportBank of the United States(Ex-1m), the SezioneSpeciale per L'Assicurezionedel CreditoL'Esportazione (SACE), and the U.S. OverseasPrivate InvestmentCorporation (OPIC). In additionto meeting the requirementsof lending institutions,the EIA will be submittedto the MoroccanMinistry of Environmentfor review and approval.Although there are not yet any MoroccanEIA requirements,the Ministryof the Environmentis developingEIA guidelines. This reportis intended to be consistentwith those guidelines,and is expectedto be acceptedby the Ministry.
The componentsof the EIA processare to describethe project,identify potential environmentalimpacts, evaluate project alternatives, and recommendmeasures for avoidingand reducingnegative impacts. An importantaspect of the process is also to engagethe public and non-governmentalorganizations (NGOs) in the reviewof the Projectplans and the probable environmental,social and economicimpacts.
1.2 Backgroundto this Project Morocco'spopulation is increasingat a rate of approximately2.5% per year while the demandfor electricpower is increasingat a rate of 7% per year. A dramaticincrease in power productionrequirements has been causedby: (1) inadequateinstalled capacity which results in
EIA 1-1 August 1, 1996 RADL^N- I NTERNATIONALOB power curtailments'; (2) an economicexpansion that is outpacingthe growth in population;and (3) Morocco'smrual electrification program. In 1994,approximately half of Morocco's26.5 million inhabitantslived in some 32,000 rural villageswith an averageof about 50 households each. Currentlyonly 16% of this rural populationis served by electricity. The rural electrificationprogram seeks to bring electricityto most of this population(Laaouina, 1996).
With encouragementand fundingsupport from the World Bank, the Moroccan governmenthas embarkedupon a major reformof its energypolicies including a pnvate sector developmentinitiative. This initiativeincludes revisions to the MoroccanElectricity Code (legal reform), the establishmentof an independentelectricity regulatory board to oversee electricity pricing, and privatzation of the country'spower production through the sale of an operating concessionon existing assets to independentpower producers (World Bank, 1995).Under this strategy,Morocco's nationalzed utility,the ONE, would be reorganizedto focus on the rural electrificationprogram and other transmissionand distributionactivities (Laaouina, 1996).
Theconcession of the 660 MW coal-firedJLPP was plannedto be the first step in this privaization initiativeby the Governmentof Morocco. Accordingly,in late 1994,ONE solicited proposals from internationalindependent power producersfor concessionof the JLPP and to construct two additional 330 MW units therebydoubling the plant's capacityto 1320MW. (To allow for plant degradationand to be able to meet its performanceguarantees to ONE on a long- term basis, the Project Sponsorshave subsequentlyproposed to increasethe total plant capacity to 1356MW.)
In February 1995,the proposal fromthe ABB/CMSconsortium was acceptedby ONE for continuednegotiation. On April 26, 1996the Project Sponsorsand ONE formally signed agreementsthat would transfer the operationof the JLPP and require the Project Sponsorsto construct and operate the two new units. Theseagreements are subject to the Project Sponsors obtainingfinancing and loan guaranteesfrom the OPIC, the World Bank,Ex-In, and other lenders.This financingis subject to the acceptanceof this EIA by the lenders and the Moroccan
'During 1993,Morocco experenced a real demandof 1850MW whilemaintining a capacityof only 1550MW. Load sheding to indusial customersaccounted for a 1% dropin the nation's gross nationalproduct (World Bank, 1994a and 1994b). The additionof JLPP Units I and 2 (660 MW) and importsfrom Algeriahave temporarily relievedthe need for "brownouts".
EIA 1-2 August 1,1996 INTERNATIONALI!
Ministryof Environment. The termsof referencedocument (the scope of work) for this EIA was reviewedand approvedby WorldBank staff in May 1996.
In sunmmary,the proposedProject is criticalto meetingMorocco's energy strategy includingthe extensionof electricityto the more than 40% of the populationnow without electricpower. Throughprivatization of electricpower production, Morocco can earn immediate revenuesthrough the sale of an operatingconcession on existingunits and benefitfrom efficient powerproduction from new units. As is documentedin this EIA, the expansionof the JLPP, Morocco'slargest powerplant, will be accomplishedin a mannerthat is protectiveof the environmentwhile providingmuch-needed, cost-effective, new power generationsupplies.
1.3 Scope of this EIA Followingthis introduction,Section 2 presentsthe policy, legal and administrative frameworkwithin which this EIA wasprepared. Thissection addressesMoroccan and intemationalenvirommental policy, legislation, standards and guidelines. Section3 describesthe existingJLPP facility and the proposedexpansion in terms of fuel consumption,environmental discharges,ancillary facilities and staffig.
Section4 describesthe physical,biological, and socio-culturalenvironmental setting for this Project Section5 sumnarie a recent environmentalaudit of the existingJLPP with a focuson areas that need to be addressedto assure continuingcompliance with World Bank, OPIC,and Ex-Im environmentalguidelines. Section6 projectsfuture impactsoutside the fence line from the operationand expansionof JLPP by the ProjectSponsors. The focus of Section 6 is on the incrementalincreases and decreasesin environmentaleffects from the Project as comparedto currentconditions.
WorldBank EIA proceduresrequire that altenatives to the Project be evaluated.This alternativesanalysis is presentedin Section7. Section8 identifiesspecific measures that will be incorporatedto reduce or avoid negativeenvironmental impacts of constructionand operationof the four units by the Project Sponsors. Proposedmonitoring of environmentalrelated operations and dischargesare identifiedin Section9. The monitoringis to ensure that mitigationmeasures are carriedout and that dischargesand ambientlevels are acceptable.
EIA 1-3 August 1, 1996 RADIAN- I NTERNATIONALM3
Section 10 of this EIA documents efforts by the Project Sponsors and Radian to coordinate Project plans with the Govenment of Morocco, and to take into account public concems regarding the project.
Fmally, there are several appendices that provide more details on material presented in the body of this EIA, photographs of the JLPP, and references.
ELA 1-4 August 1, 1996 RADUINM INTERNATIONALC
2.0 POLICY,LEGAL, AND ADMINISTRATIVEFRAMEWORK
The followingsubsections describe the environmentalregulatory guidelines and policies applicableto the construction,operation and managementof the JLPP. Further,this review identifiesthe specificrequirements to constructand operatethe JLPPUnits 3 and 4. Section 2.1 describesthe requirementsof the likelycofinancers for the Project. Sections2.2 and 2.3 describesthe Moroccangovernment and NGO involvementin the Project reviewand approach.
2.1 Requirementsof Cofinancers The Project Sponsorsare consideringdit financingor guaranteesfrom the World Bank, OPIC,Ex-Im, and SACE. Therefore,environmental policies and guidelinesfrom all four insfitutionsare evaluatedbelow.
2.1.1 The World Bank The environmentalreview procedures followed by the WorldBank for power plants are describedgenerally in WorldBank OperationalDiective 4.01 (WorldBank, 1991a)and more specificallyin the 'ThermoelectricProjects" chapter of the guidancefor implementing OperationalDirwctive 4.01 (WorldBank, 199lb). The 1988World Bank Environment,Health, and SafetyGuidelines (WorldBank, 1988)are applicableto new projectsto be eligible for World Bank funding(World Bank, 1996).
The World Bank requiresthe developmentof an EIA for new constructionprojects. This EIA for the new units describesthe project,the existingenvironment, the environmentalimpacts of the project, alternativeoptions for achievingproject goals at an equal or lower cost, and describesmeans of mitigatingproject impacts.
The World Bank encouragesenvironmental audits for bank-financedacquisition of existingfacilities. The audit shouldassess power plant impactsto land, air, surfacewater, and ground water, powerplant housekeeping,maintenance practices, and process modifications;and recommendationsof site specifictargets for emissionsand pollutionreductions. Audits addressingJLPP Units 1 and 2 were conductedin 1995. The results are summarizedin Section 5 of this E]A.
EIA 2-1 August 1,1996 INTERNATIONALMS
2.1.2 U.S. OverseasPrivate Investment Corporation(OPIC) The OPIC has adopteddraft environmentalguidelines developed by the World Bank in 1994 as noted below. In comparisonto the 1988 WorldBank Guidelines,they are more stringent in several areas. OPIC also requiresthe submissionof an EIA that is consistentwith World Bank requirements.
2.1.3 Export-ImportBank of the United States(Ex-im) Guidelines The Ex-Im 1996 Guidelinesare also applicableto this Project since financingsupport is being requestedfrom this institution(Ex-In, 1996). As withthe OPIC Guidelines,Ex-lm Guidelinesare more stringentthan the WorldBank's in severalrespects.
The Ex-Im Guidelinesspecify that chromates,chlorofluorocarbons (CFCs), polychlorinatedbiphenols (PCBs), or PCB-containingmineral oil should not be used in the water feainent system The Ex-ImGuidelines require that ash disposaland coal storage should not impact the water resourcesof the region.The Ex-lm Guidelinesalso recommendthe developmentof a comprehensivewaste managementplan and a hazardouswaste handling and disposalplan. Recyclingand reclamationis stronglyencouraged. The new 1996 Guidelinesalso adress ambientnoise impactsat the fenceline.
2.1.4 SezioneSpeciale per L'Assicurezionedel CreditoL'Esportazione (SACE) It is assumed that SACEutilizes environmentalguidelines consistent with those described above.
2.1.5 Comparisonof CofinancerEnvironmental Guidelines World Bank requirementsfor ambientair qualityand stack emissionsare comparedto OPIC and Ex-Im standardsin Tables2-1 and 2-2, respectively.Table 2-3 providesa comparison of the World Bank, OPIC, and Ex-Ii standardsfor liquid effluent. Table 2-4 comparesWorld Bank, OPIC, and Ex-Im guidelinesfor variousother environmentaland safetyparameters such as noise and worker occupationalguidelines.
2.1.6 JLPP "Project Guidelines" In order to assure eligibilityfor cofinancingfrom any of the cofinancers,this EIA will adopt as its -Project guidelines"the most stringentcriteria from any of the cofinancersfor any given parameter. Table 2-5 presentsthese '"roject guidelines". These Project guidelines are
EIA 2-2 August 1, 1996 IZADLAN- INTERNATIONALMB
Table 2-1. Comparison of World Bank OPIC, and Ex-Im Bank Ambient Air Guidelines
Pollutant f OPIC Ex-ImBank Ambient Air j Worid Bank (1988) 1 (World Bank l994) (1996) ParticulateMatter (TSP)
AnnualMean 1000/m3 70 ,ug/m3 (TSP) N/A
3 Maximum24-hr avg. ~so "g/m3 110 ,ug/m (TSP)
SulfurDioxide (SO 2 )
AnnualMean 100 zg/m3 50 sg/m 3 N/A Maximum24-hr avg. 1000 iug/m3 (insidefence) 1254gmt 500 ug/n9 (outside fence)
3 Maximum1-hr avg. N/A 350 UgIm __ NitrogenOxides (as NO2) AnnualAverage 100 jug/m3 N/A Maximum24-hr avg. N/A 150 ugem3 N/A
1-Hour Average N/A j 400 gM3
N/A = not available TSP = Total Suspended Partculs
EIA 2-3 August 1, 1996 RZADIAN- INTERNATIONALG!;
Table 2-2. Comparison of World Bank, OPIC, and Ex-lm Bank Stack Emissions Guidelines
Pollutant I OPIC Ex-1m Bank Stack Emissions World Bank (1988) 1 (World Bank 1994). (1996) Particulate Matter
3 3 3 Unpollutedareas [<500 150 mg/ 50 mg/n 1oo mg/Nm (a) pg/gM 3 inside the plant fence line and less than 260 pge 3 outsidethe fence line.]
3 3 3 All other ares 100 mgf/r 50 mg/r (TSP) 100 mg/Nm (a)
Sulur Dioxide (SO2) UnpollutedAreas 500 tpd 100 tpd 100 tpd [<50 gg/rn] (per boiler) (per boiler) (per boiler) Total Mass Emission All other areas: [>50 100 tpd 100 tpd (per boiler) 100tpd plg/r3l Total Mass (perboiler) or 0.2 txV/M (per boiler) Emission (whichever is lower)
Nitrogen Oxides(NO2) _ G;aseousFuels 0.20 lb/MMBtu 90 gIM Btu 86 nghJ ______(86 ngJ) (86 ng/J) LiquidFuels 0.30 lb/MMBtu 135 g/MMBtu 130 nug (130 ngl) (130 ugh) Solid Fuels 0.70 lb/MMBtu (300 ng/J) 270 g/MM Btu 260 nglJ Lignite:0.60 lb/MMBtu (260 ngh) ______(260 n /)
TSP = Total SuspendedPardculas Total Mass Fmicsion= Massemission weight (tpd) of emissionsper boile. ) Normalacbic meter at O°Cand pressureat one atmosphere
EIA 2-4 August 1, 1996 FRAUMN INTERNATIONALM3
Table 2-3. Comparison of World Bank and Ex-Im Bank Liquid Effluent Guidelines
Pollutant OPIC Ex-Im Bank Liquid Effluent World Bank (1988) (World Bank 1994) (1996) pH 6to9 6to9 6to9
BOD5 50 mrgL 50 mgL 50 mgtL COD N/A N/A 250 mg/L Heavy Metals (total) N/A 10 mglL IOm gL
Oil & Grease N/A 20 mg/L 20 mgtL Total Suspended Solids 60 mg/L 60 mglL 60 mg(L ITSSI Coliforms N/A N/A < 400 MPNI00CmL Residual free chlorine in N/A 0.5 mg/L 0.5 mg/L cooling water discharge Temperaur increase [edge Max 5°C above ambient Max 5°C above ambient Max 50C above ambient of mixing zone] temperate of rceiving temperat of receiving temperature of receiving water/Max 3°C if waterMax 3°C if water/Max 3C if receivingwater > 28 C. Mceiving water> 280C. receivingwater> 28°C. MPN= Most probablenumber
Table 2-4. Comparison of Other Applicable World Bank, OPIC,and Ex-im Guidelines
Parameter . World:Bank1988 - OPIC (WB 1994) Ex-Im Occupational Noise 90 dBA(' 85 dBA N/A Occupadonal SO0 Concentrations 5 ppm° 5 mg/r N/A 3 Occupational NO2 Concentrations 5 ppm ) 6 mg/m N/A 3 3 Occupational TSP 10 mg/M o) 10 mg/r N/A Commuity Noise Impacts -Farmland -70 dBA (Ldn)am N/A 60 dBA (night) -Residential 55 dBA (Ldn)m2 N/A 55 dBA (night) -lndustrial 70 dBA (24 hr Ldn)f N/A 75 dBA ' World Bank, 1991b,p. 81 2 WorldBank, 1988,p. 231 Ldn = Soundmeasurements averaged over a 24-hourperiod and adjustedso that nighttime soundsare givena greaterinfluence. ' ~~~~2.44xl10-img) pplD=IiO i molecular weAght
EIA 2-5 August 1, 1996 INTERNATIONALM
Table 2-5. JLPP Project Guidelines
Topic j Parameter Creria AmbientAir Quality Particulates(TSP) Annual mean 70 Ug/m3 Maximum 24 hr avg.(') 110Iggm 3 SulfurDioxide (SO 2) Annualmean 50 ,ggm3 Maximum24 hr avg.0)> 125 ,ug/m Maximum1 hr avg. 350 ,ug/m3 NitrogenOxides (NO2) * Annual mean 2 100 ,uglm3 * Maximum24 hr avg.-0) 150 zg/m' * Maximum1 hr avg. (4 gg/m3 Stck Emissions Particulates(TSP) () 50 mg/r 3 Sulfur Dioxide ") (SO2) 0.2 tpVMW NitrogenOxides (")(NO2) 260 ng/J (270 g/MM Btu)
AqueousEffluent pH 3) 6 to 9 4 BOD5 '3 50 mgIL COD (4) 250 mglL HeavyMetals CZ) 10 mgtL Oiland Grease 2) 20 mgJL TSS () 60 mg/L Coliforms4 <400MPNIOO mL ResidualFee Chlorinein 0.5 mg/L Cooling Water (1) Temperare Increaseat Edge of S5C above ambientunless MixdngZone receivingwater >28°C, then max. 3 Callowed
CommunityNoise Residential2) 55 dBA (dn) Other eO 70 dBA (Ldn) Occupational Noise ' 85 dBA SO2 (1) 5 mg/m3 (8 hr day avg.) NO2 t) 6 mg;mW(8hr day avg.) TSP (" 1&m/m' (8 hr day avg.)
(1) OPIC Guidelines 2) World Bank, 1988 (3)World Bank, Ex-Im, and OPIC are identical for this parameter. (4)Ex-Im, 1996
EIA 2-6 August 1, 1996 RAJDIJA INTERNATIONALMR
comparable in stringency to those recommended by the European Union (Commission of the European Communities, 1992) and the World Health Organization (World Health Organization, 1979 and 1987). As noted below, Morocco has not yet adopted ambient or discharge standards. Therefore, the Project Sponsors are proposing to meet the Project guidelines in Table 2-5, with the exception that particulate matter (PM) emissions from existing Units 1 and 2 will meet the electrostatic precipitator (ESP) performance guarantee of 125 mg/Nm3 as discussed in Section 6. It is noted that adoption of these Project guidelines is for purposes of obtaining financing for this specific Project, and is not intended to set precedent for other projects or facilities in Morocco.
22 Applicable Moroccan and Local Laws and Regulations The new Ministry of EnvironImentis developing environmental legislation in cooperation with the affected industial sectors including international private investors. No specific legislation is in place at this time. Moroccan public officials have stated that Morocco's environmental regulations will be similar in stringency to those of Greece, Portugal, Spain, and Turkey (MOE, 1996).
Morocco is planning to develop specific laws for each medium, i.e. water, air, waste, and soil rather than an integrated pollution control approach. The "potable water" regulation is currently pending final publication although it is not yet available to the public. The remainder of the environmental laws under consideration lag behind this water law and are at different stages of discussion and review. In addition to specific media-oriented laws, the "General Law for the Protection of the Environment" has been under development for nearly ten years and is intended to serve as the framework-from which other laws are to be modeled.
2.2.1 Moroccan Environmental Impact Assessment Moroccan authorities are developing an EIA Process for proposed new construction projects. Ministry of Environment officials have indicated that the successful completion of the EIA would play a role in the permit evaluation process for any new facility of significant potential environmental impact-especially if proposed by foreign investors. If the EIA indicates that the proposed project presents a significant hazard to the environment and human health, the EIA must also address and resolve these issues. Although the EIA regulations have not been proposed, the Ministry of Environment has indicated that it will review and comment on this JLPP EIA (MOE, 1996).
EIA 2-7 August 1, 1996 I NTER NATI ONAL.3
In additionto the legislativedevelopment initiatives mentioned above, the Ministry of Environmenthas contracteda studywith a multinationalteam of consultantsto identify economicand financialinstruments that could be used to promotemore environmentallysound behaviorof companies. The study is intendedto be translatedinto specificlegal instrumentsby 1997. The Ministry intendsto use this law to encouragethe developmentof responsible investmentpattems. Their statedintention is for "'foreigncompanies investing in Morocco to act as examplesthat could be followedby local companies"(MOE, 1996).
2.2.2 The Moroccan Permitting Process In Morocco,there are no requiredenvironmental permits M se. However,an application for a permit to constructa new facilitymust be presentedto the relevantlocal authority. For the JLPP, althoughthe local authorityis the Communeof MoulayAbdellah, the activities,including input from vanous Ministies (PublicWorks, Civil Protection,Employment, Health, Environment,etc.) are being coordinatedat the level of the correspondingprovince (El Jadida Province)rather than at the level of the communeitself. The followingdocuments are part of the permit application:
A formal letter requestingthe permit;
Engineeringdrawings of the new facilityand a correspondingengineering description;
A particularstudy following the regulationsfor the design and constructionof tanks and tank farms;and
A summay of the envionmental impactsof the Project
These documentsare presentedto the local authorityby an authorizedrepresentative of the Project Sponsors. The Communerequires up to six weeksto respond. If the consultation process runs into excessivedelays, the Communemay issue a temporarypermit to allow the start of the constuction.
Applicationfor an operatingpermit for Units 3 and 4 will be made to the Ministry of Public Works.
EIA 2-8 August 1,1996 RADIAN- INTERNATIONAL3
2.3 Role of Moroccan Organizations All new enviromnentalstandards are initiatedand draftedby an advisoryworking group named"Conseil National de l'Environnement"(CNE). CNE is comprisedof officialsfrom variousrelevant Ministries (Environment, Public Works, Agriculture,Industry-Commerce & Artisans,Energy & Mines,Transport, Health, etc.) and also includesseveral NGOs. These includeprofessional bodies; scientific institutions; and industrialassociations. The CNE is chairedby a representativeof the Ministryof Environment.
The role of CNEis to initiateand draft the technicalaspects of the laws. Oncethe text reachesa certain degreeof technicalmaturity, it is passed to the legalcabinet of the Ministryof Environmentto shape the draft into a legal document The CNEworks in differentconmnittees that focus on specifictopics (e.g.,air issues)and the Ministryencourages specific relevant industriesto participatein thesecommittees. The time requiredfor this level of technical preparationcan rangefrom six monthsto severalyears. All throughthis process,the Ministryof Environmentviews itself in the role of promoterand coordinatorand encouragesdiscussion and negotiationas approachesfor developingthe laws.
As described in Section 10, representatives of NGOs met in Casablanca on July 12 to review and commenton JLPPproject plans. The coordinationof this EIA with NGOs is an impotant part of the public participationprocess.
EIA 2-9 August 1, 1996 I RZADXAN- INTERNATIONALMB
3.0 PROJECTDESCRIPTION
This section describesboth the existingJLPP and the proposedexpansion of the plant. This discussionaddresses plant locationand surroundingfeatures, plant processes,and environmentaldischarges and controls.
3.1 ProjectLocation and Area Description As shown in Figure 3-1, the JLPPis located 127km southwestof Casablanca,Morocco on the Atlantic coast. Figure3-2 depictsthe immediatevicinity surrounding the JLPP. El Jadida,with a populationof approximately150,000, is the nearest city to the site and is located on the Atlantic coast approximately17 km to the northeastof JLPP. Key featuresof the project site and the surroundingarea are describedbelow.
The plant occupies60 hectaresand is locatedon a narrow stretch of land betweena 60 m high bluff to the east and the AtlanticOcean to the west. The plant site is generallyflat and at an elevationof approximately7 m abovethe ReferenceLevel of Moroccoor Niveau g6n6raldu Maroc (NGM) and is protectedfrom highwaves and stormsby naturalsand berms, sea walls, and breakwaters.
The Port of Jorf Lasfaris adjacentto the northernboundary of the site. This modem port is designedto handle bulk materialimports and exports. In addition,the port has a portion of one pier dedicatedfor receivingimported coal for use by ONE. A coal conveyorsystem transports the coal from the port to the site. Thereare several smallsettlements located on the bluff to the east of the plant. The nearestdwelling is within75 m of the JLPP fenceline. The immediatearea surroundingJLPP is in mixed agricultWaland industrialland uses with a large phosphateplant locatedapproximately 2 kannortheast of the plant.
3.2 Descriptionof ExistingFacility The area Within the JLPP fencelinewas designedto accommodatesix 330 MW coal-fired steamgenerators and supportfacilities associated with a state-of-the-artpulverized-coal thermoelectricplant. Constructionof the first two units (Units 1 and 2) was completedin 1994 and 1995,respectively, by a consortiumof GEC Alsthom,B&V Espafia,and Dragados
BIA 3-1 August 1, 1996 INTERNATIONALMR NORTH .g T m7c France f L
: : Spain .-
,-_--'/" \'t ~~~~ ~ ~~Lik)Ya Algeria m0j>r *6 N 9rF
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SCALE:KLOMERs Power/ Plant ; JVG04= Figure 3-1. Regional Map
EIA 3-2 August 1, 1996 0N
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------RADIANN INTERNATIONAL
Constructors.A generallayout of the entire site is depictedin Figure 3-3. A plot plan of the portion of the plant containingthe existingUnits I and 2 and the proposedlocation of Units 3 and 4 is presentedin Figure 3-4. The facilityinfrastructure related to Units 1 and 2 includes (ABBProject, 1996):
Two 330 MW pulverizedcoal-fired steam generatorsof the CE/Sulzertype suppliedby Babcockand WilcoxEspafia;
Two reheat steamturbines of the steam condensingand bleedingtype manufacturedby GEC Alsthom;
Four (2/unit)cold side electrostaticprecipitators (ESP) with three fields each. The ESP's are designedto remove at least 99% of the flue gas particulatematter,
A distibuted controland informationsystem manufactured by GEC Alsthom;
Boiler buildingwith a height of 54.6 m;
Turbinegeneror building;
Ash handlingbuilding;
l30 m stack - servingboth Units 1 and 2 with separateflues;
225 kV indoor substationand five overhead225 kV transmissionlines, solid dielectriccable terminationyard, a substationbuilding for equipment,and a substationcontrol house; and
60 kV switchingstation and 6.6 kV auxiliarysystem. lafrastructurethat will be commonto the existingUnits 1 and 2 and the proposedadditional Units 3 and 4 are (ABBProject, 1996 and EPC, 1995):
Administrationbuilding;
Warehouse(sized for six electricgeneration units);
EIA 3-4 August 1,1996 W~~~~~~~~~~~~~~~~~~~~~~~~~~~~~m1 i\ X J--4 _ | sTo~~~AgdlAM_CS|
E X t _ / JVGM3~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~.
Ch~~~~~~a N~~~~~~~~Fgr 3-.Jr afrPo lnV NORTH
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| tW~~~ater2 Pipe/ 0~~~~~~~~~~~~~~~~~ul0 \
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T i z 0 Ele Rl>v< Buliding t \\ - - ~~~~~Proposed J|
Figure3-4. JLPP Layout RADIAN- INTERNATIONALU
A 1.5kmn long open channelto dischargeonce-through condenser cooling seawaterto the AtlanticOcean. The channelis sized to accommodateonce- throughcondenser coolingseawater from six units and widensto 26 m at the point of discharge;
Two 90 cm diameterconcrete pipe wastewateroutfalls to the AtlanticOcean;
Machineshop and electronicsrepair shop;
Two - 50,000m 3 fuel oil storagetanks;
One 50O m3 diesel-oilstorage tank;
One 25 in3 propane storagetank;
Coal storageyard sized to store coal for six 330 MW steamgenerators. In 1995 the coal yard stored up to 400,000tonnes of coal at any one time;
-. Coal handlingfacilities consisting of a conveyorsystem, ransferhouse, a stacker, and two reclaimers;
Fuel oil receivingand unloadingfacilites;
Chlorinationsystem;
Septic tanksfor sanitarywastewater generated onsite;
Demineralizationwater productionsystem;
Fire protectionsystem;
Seawaterintake (sizedfor six units) and dikes to protectseawater intake area;
Auxiliaryboiler,
Raw water supply (sizedfor six units); and
Concrete-linedcoal pile stormwater runoff settlingbasin.
EIA 3-7 August 1,1996 RtADIAN- INTERNATIONALES
3.2.1 EnergyGeneration In 1995,the JLPP produced4,100,000 MWh of electricityfrom the two 330 MW units (71%of rated capacity). However,because the units were recentlystarted up, shake down testing has artificiallylowered the capacityfactors.
Raw coal from the coal pile is routedto an air drier/pulverizer.This equipmentreduces the coal's moisturecontent and feeds the pulverizedcoal directlyto the boilers. The heat given off during combustionof the coal is used to produce steam, which the turbine-generatorconverts into electricity. The electricitygenerated is routed to a 225 kV substationwhich is connectedto the ONE systemgrid via five overhead225 kV transmissionlines.
322 Fuels Used Both Units I and 2 are designedto fire pulverizedcoal and/orheavy fuel oil No. 2 (EPC, 1995).However, coal is the pimary fuel used to gcnerateelectricity. Currentcoal is supplied from the UnitedStates, Colombia,and South Afnca, with the majoritycoming from the United States. The ultimateanalyses, lower heatingvalues and higherheating values of the coals used are providedin Table 3-1. In 1995,Units 1 and 2 consumeda total of 1,147,137tonnes of coal (Radian, 1996).
Coal is shippedto the Port of Jorf Lasfar and is unloadedonto a conveyorsystem which transportsthe coal from the Port to JLPP. The coal is then unloadedonto the coal pile storage area. The coal yard is lined with bentonitein orderto minimizegroundwater infiltration of coal pile storm water. In additionto storingcoal for use at JLPP, this facilityprovides up to 700,000 tonnes per year of coal for use at other ONE facilities(ABB Project, 1996).
The heavyfuel oil No. 2 is shippedto the Port of Jorf Lasfarwhere it is unloadedonto rail tank cars, transportedto JLPP, and is then unloadedinto a pipe networkthat transportsthe fuel oil to one of the two 50,000m 3 storagetanks. A concretewall and a compactedclay floor surroundsthe fuel oil storagetanks in order to containany spills. The fuel oil is routed to the units via a pipingnetwork fromthe storagetanks to the boilers. The fuel oil is heated to allow it to be properlyatomized in the boilers. Physicalproperties of the heavyfuel oil No. 2 are presented in Table 3-2 (EPC, 1995).
EIA 3-8 August 1, 1996 Table 3-1. Ultimate Analysis of Coals Used at JLPP During 1995 -4
SoUithAMe*A ;nited ViI Sat (
1 r.a,teter Ratige l ,A,e,e. kangy A4eta2e. . an Averbr.e | % By Weight -Sulfur 0.49 - 0.81 0.66 0.62 -0.66 0.64 0.71 - 1.47 1.28 -Ash 11.60 - 15.60 13.47 6.00 - 7.88 7.06 7.50 - 14.70 10.97 -Moisture 6.83 - 9.20 7.73 7.69 - 10.77 8.90 6.55 - 11.62 9.26 -Volatiles 22.40 - 28.40 25.99 31.50 - 34.90 32.87 28.02 - 32.40 30.97 -Carbon 65.50 - 68.20 67.30 69.43 69.43 62.45 - 69.75 66.58 -Hydrogen 3.35 - 4.00 3.66 4.45 - 4.78 4.56 4.13 - 5.34 4.52 -Nitrogen NA NA 1.37 1.37 1.25 - 1.45 1.33 -Oxygen 7.85 - 8.38 8.12 10.08 10.08 4.81 - 8.30 6.34 -Chlorine NA NA 0.03 0.03 0.01 - 0.26 0.10 Higher Heating Value (kcalVKg) 6,146 - 6,479 6,318 6,578 - 7,082 6,801 6,280 - 6,747 6,575 Lower HeatingValue (kcalXKg) 5,924 - 6,245 6,105 6,287 - 6,835 6,529 6,258 - 6,472 6,301
NA=Not available Source:Radian. 1996
0% RADIANE INTERNATIONAL
Table3-2. Propertiesof HeavyFuel Oil No. 2 Usedat JLPP
Parameter RangeR of Values:' Weight % - Sulfur s4 - Hydrogen 12 - Carbon 85.2 - Ash 0.01 - Waterand Sediment 1.5 Specific Gravity ~~~~~~~0.92-1.00 Viscosity@ 50°C (cp3 0.110 -0.380 Heating Value (kcallKg) -Higher 10,070 - Lower 9,600 F;lashlPoint a270 0 C
Valucstaken fom ONE (1996).
3.2.3 Air Emissions Sourcesof air emissionsat JLPP currentlyinclude, in order of mianitude: 1) combustion byproductsfrom the two boilers,2) wind blownparticulate emissions from the coal pile, and 3) evaporativeemissions of volatile organiccompounds (VOCs) from the two 50,000 m 3 fuel oil storagetanks and other miscellaneoussolvent and paint use.
Stack emissionsfrom the boilersare a result of the combustionof coal and primarily consistsof carbonmonoxide (CO), oxidesof nitrogen(NOx), particulate matter (PM), and sulfr dioxide (SO2). Each of the boilers is equippedwith a cold-sideESP which reduces PM emissionsby approximately99% (Radian,1996). Air emissionsfrom both of the boilers are dischargedto the atmospherethrough a 130 m high stack.
Esuimatedstack emissionsfrom Units 1 and 2 duing 1995 are presentedin Table 3-3. Annual emissionsof NOx and PM are based on emissionstesting conductedby GEC Alsthom Corporationin 1995 (Radian, 1995). Annualemissions of SO, are based on the amount of coal used in 1995 and the averagesulfur contentof the coal. Stack emissioncalculations are presented in Appendix F.
EIA 3-10 August 1, 1996 RADUIN INTERNATIONALM
The coal pile is periodically wetted to prevent coal fires and to reduce wind-blown dust emissions from the coal pile.
Table 3-3. 1995 Stack Emissions from JLPP Units 1 and 2 Firing Coal
I I Standards Pollutant Emis-ions - Units [ Moroccan I Project S02 0.20 a tpdMW NA 0.20
NO. (maximumload) 0.53 b lbs/M Btu NA 0.60
NO, (minimumload) 0.59b lbs/MMBtu NA 0.60
PM 1 30 b m1m3 NA 50
' See AppendixF forSO 2 emisson calalations Data from1995 GEC Alsthomperformance tesL NA = no applicablestmxlards
Evaporative emissions of VOCs from the heavy fuel oil No. 2 storage tanks, gasoline storage, painting, and metal parts degreasing and cleaning are considered insignificant due to the limited quantity of these materials used and the low vapor pressure of the fuel oil.
3.2.4 Water Use Two types of water are used at the JLPP: 1) raw fresh water and 2) seawater. Raw fresh water is used as makeup for plant process operations (i.e., steam generation, equipment cleaning) and treated for sanitary water supply. Raw fresh water is supplied to the site from the El Jadida water system via the Regie autonome de distribution deau et d'lectricit6 dlEl Jadida (RADEEJ) aqueduct. Seawater from the Atlantic Ocean is used in a once-through configuration to condense turbine exhaust steam so that it may be used again. A process flow diagram of water used at JLPP is presented in Figure 3-5.
Prior to using the raw fresh water to produce steam, it is demineralized in order to prevent scale formation in the boilers. The demineralization process involves passing the raw fresh water through cation, anion, and mixed cation/anion exchange beds. The cation exchange bed removes cations such as Mg2 , Ca?,2 Mn2+,Fe 2 t, etc., while the anion exchange bed removes anions such 1 as S042-,NO 3 -, HC03 '-, etc.
EIA 3-11 August 1,1996 EL-JADIDA RAWFRESH WATER SANITARY SANITARY FRESH WATER - WATER USE…* WASTEWATER SYSTEM
BOILER z 5 PLANT DEMINERALIZER BLOWDOWN PROCESS r - BACKWASH/REGENERATION t OPERATIONS j WASTEWATER
l ~~~~~BACKWASHBACKWASH ~~~~~DEMINERALIZED j|WATER~~~~~~WAE |WTR t
I ___ HYDRAZINE AMMONIA < N~~~~~~~~~ACKWASHI . WATER STEAM
REGENERATION H2S04 AND NaOH WATER 2 SEAWATER
ATLANTICCODNR OCEAN CONDENSOR
LEGEND SEAWATER WalevOt1achuigeeODEST WaterIntge CONDENSATE Waerntkos^ BOTTOMAND * WATER - | Intermflsnl OW - - - * *Flow FLY ASH SODIUM ChemicalAddlilon HYPOCHLORITE
Flgure 3-5. Water Intakes INTERNATIONALM3
The mixed cation/anionexchange bed is used to polish the treated water. The cation bed exchangesH' for the cationsin the water, while the anion bed exchangesOH- for anions in the water. Followingexhaustion of the ion exchangebeds, the bed is backwashedand then regenerated. The cation exchangebed is regeneratedby passingH 2SO4 throughthe bed, while the anion exchangebed is regeneratedby passingNaOH throughthe bed. The backwashand regenerationwastewaters are collectedin a neutralizationtank whereeither acid or base is added to adjust the pH of the wastewaterbetween 6.5 and 8.5. FollowingpH adjustmnentthe backwash/regenerationwastewater is dischargedinto the circulatingwater dischargechannel which dischargesto the AtlanticOcean (EPC, 1995).
Followingdemineralization, hydrazine and ammoniaare addedto the water. Hydrazineis addedto scavengeoxygen in the demineralizedwater in orderto reduce corrosionof the boiler tubes. Ammoniais addedto the water to inhibit rust.
Seawateris used at JLPP to conveybottom and fly ash to the Atlantic Oceanand to cool the steam and condenseit so that it can be used again. The seawateris used in a once-through configuration(i.e., is used onoethen returnedto the ocean). Priorto entering the plant, the seawateris chlorinatedusing sodiumhypochlorite to prevent biofoulingof the condensers(EPC, 1995).
3.2.5 Water Discharges All wastewaterstreams generated at 3LPPare eventuallydischarged to the Atlantic Ocean. Water dischargesconsist of the followingtypes of wastewaterstreams:
Ash conveyancewater,
Once-throughcondenser cooling sea water,
Sanitarywastewater,
Boiler blowdown,lab, and in-plantdrains, etc.;
Storm water,and
Demnineralizerbackwash/regeneration wastewater.
EIIA 3-13 August 1, 1996 RADIAN- I NTERNATIONALM
A flow diagram of water discharges including any pre-treatment and the ultimate disposal is shown in Figure 3-6. Characteristics of the wastewater discharges based on sampling performed by Radian in 1995 and the conrespondingproject effluent standards are presented in Table 3-4 (Radian, 1995).
Once-through condenser cooling sea water is discharged directly into the Atlantic ocean via a 1.5 km long open channel. The average temperature difference between the intake and discharged seawater is 9° C (Radian, 1995).
Sanitary wastewater is routed to septic tanks for solids removal. The liquid phase from the septic tanks is combined with other wastewater streams and discharged to the Atlantic Ocean.
Storm water runoff is collected from the following areas within JLPP: 1) coal pile, 2) fuel stomge and unloading area, and 3) all other areas. Storm water from the coal pile area is routed to a concrete settig basin to allow suspended solids to settle out; storm water is discharged to the Atlantic Ocean. Storm water collected from the fuel oil storage and loading areas is routed to an oil/water separator to remove oils. The oils are recovered for reuse or sent off site to an incinerator and the treated storm water is discharged to the Atlantic Ocean. Storm water from all other areas is discharged direcdy to the Atlantic Ocean.
Demineralizer backwash/regeneration wat is collected in two 1,000 m 3 neutralization basins. Neutralization is accomplished by either adding acid (112S04)or base (NaOH). The tratd deineralizer backwash/regeneration water is then discharged to the Atlantic Ocean.
3.2.6 Solid Wastes Solid waste streams produced at JLPP include the following-
Fly and bottom ash;
Office trash/refuse;
Sanitary wastes from workers (i.e., sludge from septic tanks); and
Industrial wastes such as spent solvent, paints, spent demineralizer resins, and used oils.
EIA 3-14 August 1, 1996 REUSEOR zI OFF-SITE
SANITARY _ ATLANTIC INCINERATON WASTEWATER- TA Nk2k" OCEAN >
SOLIDS3TOSOLIDS TO WASTEWATER~~~~~OILY ATLANTIC LANDFILLOCA OILIWATER SEPARATOR
H2SO4 ANDNaOH OTHER STORMWATER N RUNOFF N DEMINERALIZER~ALNI - BACKWASH/-- OCEAN REGENERATION WASTEWATER ONCE-THROUGH-_-_- ATLANTIC CONDENSORCOOLING OCEAN 2 -1,000 m3 SEAWATER ,w, NEUTRALIZATIONBASINS - SEAWATERSLUICED - - WITH BOTTOM AND FLY ASH /
COALPILE ATLANTIC BOILERBLOWDOWN ' TUC | sTORMWATER- - P,OCEAN______RUNOFF LEGEND CONCRETE-LINED LEGOil DETENTIONPOND RawWastewater
TreatedWastewaler ChemicalAddition
0' Figure 3-6. WaterDischarges Table3-4. Summaryof WastewaterCharacteristics
~~~~~~~~~~~~~~~~~~tit1_m SOU: Nthh 0 ehi' s Project |AhatyW..^; e l AhFlif ,utfall,______bOUC*I:. ; blFchXrdIatg:,::: l"ideidzines pH (average) 9.00 9.00 7.65 7.60 6 to 9 > DissolvedO (mg Q/L) 7.0 7.4 7.6 7.6 NS BOD,(mg 02AL) 1.0 1.9 1.0 1.1 50 COD(mg O2A1) NAP NAP NAF NAP 250 TotalSuspended Solids (mg/L) 66.6 20.2 18 16.2 60 Residualfree chlorine in coolingwater NAF NAF NAP NAP 0.5 discharge(mg/L) . Redoxpotential (mV) 411.3 418.5 352.0 387.5 NS Oilsand grease (mg/L) NAP NAF NAP NAF 20 TPH(mg/kg) 0.85 1.41 0.83 1.25 NS Hg (mg/L) 0.0001 0.00023 0.00002 0.00005 NS Cr total(mg/I) 0.01 0.013 0.001 0.001 NS As(mg/L) 0.015 0.015 0.002 0.002 NS Mn(mrgt) 0.06 0.18 0.01 0.01 NS Cd (mg/L) 0.0008 0.0005 0.0004 0.0003 NS Pb (rng1I) 0.01 0.015 0.001 0.001 NS Ni (mg/L) 0.005 0.001 0.001 0.001 0.5 Mg(mg/L) 47.6 26.7 1368.0 1365.7 NS > |Heavy metals (mg/L) 0.1 0.23 0.01 0.01 10.0 fPI m'Data fromRadian Phase 11Audit of JLPP NS = No applicablestandard NAP= Notanalyzed for this analyte '0 0% RADIANE INTERNATIONALC5
Bottomand fly ash are sluicedin two parallelpipelines (one for bottomash and the other for fly ash) with a slip stream of incomingseawater and dischargedto the AtlanticOcean. Both lines are submergedand extend800 m into the Atlanticwhere the averagedepth is 13 m. The bottom ash disposalline has experiencedproblems due to bottom ash accumulatingon the ocean floor to the point that the disposalline is clogged. When this occurs,bottom ash is trucked to an existingtrash disposalsite locatedsouth of the plant and adjacentto the dischargechannel on the plant site.
Under currentoperations, solids collected in the septic tanks are periodicallypumped into a truck and transportedto an offsitemunicipal sewage treatment plant. Officetrash/refuse generatedat the facilityis disposedof in an off-sitelandfill.
Industrialwastes generatedat the site are shippedto landfillfor disposal. Used oil is stored in drumsand either returnedto the fuel oil tanks or sold to local companiesfor recycling or other uses.
3.2.7 Ancillary Facilities Ancillaryfacilities include: 1) a rail line from the Port of Jorf Lasfarto JLPP, 2) a coal conveyorsystem from the Port to JLPP, 3) a portion of a dedicatedpier for coal unloading at the Port, and 4) five - 225 kV overheadtansmission lines connectingJLPP to the power grid (ABB Project, 1996).
The rail line betweenthe Port of Jorf Lasfarand JLPP is primarilyused to transportheavy fuel oil No. 2, sulfuric acid (H2SO4), caustic(NaOH), diesel fuel, propane,and equipmentto JLPP. The conveyorsystem is used to transportcoal fromthe Port to JLPP. Coal is unloaded at JLPP onto a series of coal piles. The two conveyorscan each tansport 750 tonnes of coal per hour. Hydrazineand ammoniaare shippedto the site via trucks.
Electicity generatedat ILPP is connectedto the ONE systemgrid via five - 225 kV overheadtransmission lines.
EIA 3-17 August 1, 1996 RZADIAN- INTERNATIONALE3
3.2.8 Staffing As of May 1996 there were 144regular employeesworking at the JLPP. Accordingto ONEmanagement staff, virtuallyall of the employeeslive in El Jadida and commuteto work in companybuses.
3.3 Descriptionof ProposedExpansion This section presentsa discussionof the new infrastructure,operational changes, constructionactivities, and featuresof the new Units 3 and 4 (i.e., powergeneration, material usages, dischargesto the environment,ancillary facilities, and staffing).
3.3.1. New Infrastructureand OperationalChanges The proposedexpansion consists of addingtwo new 348 MW power plants and various supportequipment. Specifically,the expansionwill involvethe additionof (ABB Project, 1996 and EPC, 1995):
Two 348 MW pulverizedcoal-fired steam generators (Units 3 and 4) capable of fning coal or heavyfuel oil No. 2 as supportfuel only;
Two steam turbine/generatorunits;
Four (2 per unit) four-field,cold-side electrostatic precipitators designed to reduce PM emissionsfrom Units 3 and 4 to 50 mg/n3;
Two emergency diesel generators;
3 Expansionof the water demineralizationsystem (including two 1000 mn demineralizedwatr storagetanks) to providedemineralized water for Units 3 and 4;
Expansionof the seawaterintake pumping station;
A 130 m stack with separateflues to dischargeair emissionsfrom Units 3 and 4;
A wastewatertreatment system designed to meetproject effluent guidelines;
Electrcal building,
Ash handlingsystem;
* Coal silos sized for at least 12 hours of full load operation;
EIA 3-18 August 1, 1996 RADLANN INTERNATIONAL3
Extensionof the coal stacker and reclaimertracks by 300 m;
Extensionof the two 750 tonne per hour coal conveyorsystems;
Extensionof the coal wettingsystem;
A new raw water storagetank; and
Extensionof the existingfire watersystem.
Figure 3-4 showsthe proposedlocation of Units 3 and 4. In additionto the proposednew equipment,there will be severaloperational changes:
Wastewaterwill be teated to meetProject effluent guidelines prior to disposal to the Atlantic Ocean. Wastewaterfrom floor cleaningwill be sent to an oil/water separatorto removeoils and grease. pH teatment of wastewaterwill be upgraded;
Disposalof fly and bottom ash in the Atlantic Oceanwill be terminatedonce an approprate altemativehas been implemented;
Fuel oil unloadingoperations will be modifiedin orderto reduce fuel spillage; and
An EnvironmentalManagement Plan will be developedand implemented. The plan will addresswaste managementprocedures, environmental sampling, and environmentalrecord keeping.
3.3.2 Description of Construction Activties Schedule Pendingfinancial closing, construction of the new units is anticipatedto begin in March 1997. Constructionof Unit 3 is scheduledto take no greaterthan 33 months. Completionof Unit 4 is plannedto occur six monthsafter the completionof constructionof Unit 3. Unit 3 is scheduled to be operationalby December1999.
EIA 3-19 August 1, 1996 INTERNATIONALE!
ConstructionAccess Site access to the JLPP is via Route 121. Constructionmaterials may also be transported to the facility via rail car or barge.The constructionof new rail, port facilities,or roads is not requiredfor this project.
Site Preparation The site for Units 3 and 4 was mostlygraded and clearedof vegetationduring the initial constructionof Units 1 and 2. Purchaseor use of propertynot currentlyowned by ONE will not be required(except as necessaryfor off-siteland disposalof ash). Also, no relocation of families living near the plant will be necessary(ABB, 1996b). Figure 3-4 showsthe site layout for Units 3 and 4. The clearedarea reservedfor Units5 and 6 will be used for equipmentlaydown (ABB, 1996b). This area will also housethe constructionoffices, fuel storagefor the construction phase, and a batch plant.
t is not anticipatedthat there will be any large quantityof excavatedmaterial for disposal. Most of the excavatedmaterial will be used for fill and berms. A smalldisposal site will be requiredfor the clean materialunsuitable for fill. Constructiondebris will be taken to an authorizednearby landfill.
Constructionmaterials may be transportedto the facilityvia rail car or trucks. The constructionof new rail, port facilites, or roads is not requiredfor this project.
At peak of construction,approximately 700 workerswill be workingat the site. Both skilled (about 53%) and unskilled workers(about 47%) will be hired to constructthe units. The majorityof the work force will be recuited locally. Workersfrom other countriessuch as Switzerland, MIaly,and the U.S. will also be used for the constructionand will be housed in the city of El Jadida (ABB, 1996b).
For the durationof the project, all workers are rquired to follow OPICand Ex-In health and safety guidelinesand complywith Moroccanlegal requirements
Buses will tansport workersto the constructionsite from El Jadida. It is expected that the constructionwork force will reside primarilyin El Jadida. No plans have been made to provide temporaryhousing for the workers. Constructionwill occur primarilyduring daylight
EIA 3-20 August 1, 1996 RAIAN- INTERNATIONALEM hours. The startup, commissioning, and operation will be performed continuously based on three shifts (ABB, 1996b).
Solid Wastes Solid wastesfrom Units 3 and 4 will be generatedduring construction.Construction activities will result in the following solid waste streams:
Construction debris such as packaging material, wood, brick, concrete, and steel;
Sanitary wastes generated by the construction workers; and
Used oils, paint, and solvents.
Construction debris and industrial waste will be disposed of in an off-site landfill as directed by local authorities. Sanitary wastes will be collected from portable bathrooms via vacuum trucks and ransported to a wastewater tatment plant.
3.3.3 Features of New Units This sectionpresents a discussionof powergeneration, fuels used, air emissions,water usage, water discharges, solid waste, ancillary facilities, and staffing associated with proposed Units 3 and 4.
Power Generation The maximum continuous rating of Units 3 and 4 will be 348 MW each. Total capacity from all four units will be 1356 MW. JLPP is expected to be operated at a capacity factor of approximately82%.
Fuels Used In order to limit emissionsof S from JLPP, boththe existingUnits 1 and 2 and the proposedUnits 3 and 4 wil use coal requiredto containno more than 1.25%sulfur by weight on an annual averagebasis. It is anticipatedthat the coal will be suppliedprimarily from South Africa, Colombia,and the UnitedStates. As with Units I and 2, Units 3 and 4 will normallyuse heavyfuel oil No. 2 for ignition,warm-up, and combustionstabilization below 35% load. Unlike Units 1 and 2 which can operateup to full load on oil, Units 3 and 4 can only achieve 15%load while firing only oil. Coal and heavyfuel oil No. 2 will continueto be deliveredto the Port of Jorf Lasfarand routed to JLPP via a conveyorsystem and railcar,respectively. When
EIA 3-21 August 1, 1996 RADIAN- INTERNATIONALI
operating at the anticipated capacity factor of 82%, Units 1 through 4 will consume approximately 3.3 million tonnes of coal per year.
Stack Emissions Stack emissions from Units 1 and 2 and Units 3 and 4 are presented in Table 3-5. Also included in Table 3-5 are the guaranteed, not-to-exceed emissions from Units 3 and 4 (EPC, 1995).
PM emissions will be reduced to 50 mg/m3 via cold-side electrostatic precipitators installed on each of the units. Emissions from Units 3 and 4 will be discharged through a 130 m stack.
Water Use The raw fresh water consumption of Units 1 and 2 is approximately 68 m3/hour. Raw fresh water and seawater usage rates for Units 3 and 4 will be similar to the usage rates of Units 1 and 2. In addition, uement of raw water and seawater will be similar to that of Units 1 and 2.
Table3-5. StackEmissions from JLPPUnits 1 Through4
-. 700i-.: j- hissio: Uni7S : gUnits. .,t-xinili for .Project IsMboroa Pollutant : ____: i -:.-and2 3-d4 U*ilta :-& GeiinesE StSdards
SO2 TdIW 0.20w 20ob 0.20 0.20 NA NO. (maximum lb/MMBtu 0.53 <0.60d 0.60 0.60 NA load)
NO. (minimum lb/MM Btu 0.59C . 0.60d 0.60 0.60 NA load ) I ______I______
PM mtln9 30c' cSOd 50 50 NA
'See AppendixF for SO2 emissioncalcuaions b Basedon a 125% sulfur coal (See hppedix F for calculations). 'Data from 1995 CEC Alsthompefformance tsL 'NO,, and PM emissionsbased on performanceguar s (EPC 1995). NA = No applicablestandars
EIA 3-22 August 1, 1996 NZADUIAN INTERNATIONALM
Water Discharges Additionof Units 3 and 4 will approximatelydouble current dischargesof: 1) once- throughcondenser cooling seawater, 2) demineralizerregeneration/backwash water, 3) storm drains,and 4) sanitarywastewater.
A new wastewatertreatuent systemwill be constructedas part of the JLPP expansion. The wastewatertreatment system will be designedto ensureall wastewaterdischarges from JLPP meet the Project effluentguidelines presented in Table2-5.
Solid Waste Operationof Units 3 and 4 will increaseall of the wastestreams identifiedin Section3.2.6; however,both bottomand fly ash will no longerbe disposedof in the Atlantic Ocean once an appropnatealtemative has been implemented.Options for altemnativedisposal and uses are describedin Section7.6.
AncillaryFacilities Ancillaryfacilities for Units 3 and 4 willbe the same as those for Units 1 and 2.
Staffing Employmentat JLPP, followingcompletion of Units 3 and 4, will be approximately300. This is a net increaseof 156 employeesover staffmnglevels in early 1996.
EIA 3-23 August 1, 1996 I I RADIAN- INTERNATIONAL
4.0 ENVIRONMENTALBASELINE
This section describes the existing physical, biological, and sociocultural environment in the vicinity of the proposed Project.
4.1 The Physical Environment
4.1.1 Topography, Geology, and Soils The salient topographical feature in the vicinity of the JLPP is the 50 to 80 m bluff that gives this area its name "Jorf Lasfar"which is Arabic for "yellowbluff." As shown in Figure 3-2, this escarpmentforms a sheer cliff from the rockyshoreline immediately north of the port of Jorf Lasfar.To the east of the port the bluff transitionsfrom a steep slopeto a more gentle slopein the vicinityof the JLPP.
Southof the JLPP, the bluff becomesless pronounced. To the souththe interface betweensea and shorebecomes more complexwith marshes,tidal flats, and sand dune c*omplexes.Inland, the area is hilly to gently sloping with elevation of generally less than 150 m.
The site topographyof JLPP is level at 7 m aboveNGM with the exceptionof the coal storagearea which is 6 m NGM (ONE, 1994).
The geologyof the project site is coastalMeseta area. The geologicalstructure belongs to the successionof geologicallayers which stretchfrom Casablancato Safi. The geologicallayers from the groundlevel down are the following(ONE, 1994):
Tufa and loosely compacted sea sand (recent quaternary)- The quaternary terrain gentlyslopes towardthe Atlantic Ocean. The thicknessof the terrain is not preciselyknown, but varies froma few metersto tens of meters. The tufa, rarely found near the seashorebecause of erosion,is a powderycalcareous formation which could presentnodular or superficialencrustations because of the combined action of dissolutionand evaporation.
Dune "sandstone" (consolidatedquaternary)-The dune "sandstone"is a soft rock formation,generally calcareous, with looselycemented intercalations of sand. Its appearanceis like that of sandstone;however, the percentageof silica is negligible. The layer may also be characterizedas calcareousshell.
EIA 4-1 August 1, 1996 INTERNATIONALUEI
Cretaceous bedrock-The cretaceousbedrock consistsof alternatingbands of pure marl,soft, and induratemarl, as well as marlous limestone.
The soil at JLPP consistsof compactedsandstone, cemented by carbonateswith a fine stratification,in which shells are easilyfound, and with a depth of severaltens of meters (Radian, 1995).
4.1.2 Climate The climate of the Jorf Lasfar area is influencedby the proximityof the Atlantic Oceanto the west and the expansivecoastal plain to the east. Overallthe climateis temperate,with generallyhot summers(May through September) and mild winters(ONE, 1994).
The coastalplain is relativelyflat, extendingeastward toward the Atlas Mountans. While blowing over the coastalplain, windsare unaffectedby topographyor vegetation,yet the reported speeds are not excessive. No sandstorns have been reportedin the area. The annual windrose(Figure 4-1) obtainedat El Jadida from 1950-1961,indicates a predominantwind flow from the north-northeastand northeast(i.e., from land towardwater). As shown in the figure, the wind is from these directionsalmost half the time (48%).The predominanceof the annual northeasterlypattem is causedprimarily by the summerseason winds. During the winter rainy season (Novemberuntil May),winds are more variablewith about half of the winds blowing from south throughnorthwest (i.e., generallyfrom water towardland).
Air temperes range from a minimumwinter tmperature of 4°C to a maximum summer temperatureof 42"C. Averge annualtemperaurs ae about 18C, with average maximum monthlytempera s rangingfrom 18 to 27°C. The averagerelative humidity for the area is about 65%. Oceantemperares range from a minimumof 12°C to a maximumof 25 °C. Rainfall dunng the seasonalrainy periodaverages about 450 mm, but is extremelyvariable, with an annual range of 210 mm to 740 mm.
4.1.3 Existing Air Quality The air qualityof the immediateregion around the JLPP was evaluatedby the Laboratoire Public d'Essais et d'Etudes (LPEE)prior to constructionof Units 1 and 2 (LPEE, 1994).The monitoringprogram was conductedover a seven-weekperiod in 1994 (February14 - March 31). The monitoring site was located about 1 kannortheast of the power plant at an elevation of approximately60 m NGM.
EIA 4-2 August 1, 1996 IIt
I- U iii';St~~~~~~l I /------l
%%~~~~~~~~ / / I ~~~~~~~~~~~I ~ ~ ~ ~ ~ %
rL~~~~~~~~~~~~~I : ui RAJUIAN- INTERNATIONALMI
The atmosphericconstituents monitored included SO 2, NO2, NO., VOCs, and 03. Hourly measurementsin parts per billion by volume(ppbV) were reported for each monitored constituent.These hourly valueswere then used to form daily (24-hour)and period averages.The meteorologicalparameters, wind speedand directionwere concurrentlymonitored to provide supportingdata. Wind directionsreported during the period agreedfavorably with those reported during the winterperiod at El Jadida The results are summarizedin Table 4-1.
Of the monitoredconstituents, only S and NO2 have applicableProject ambient air guidelines.The averagehourly monitored values for the entire seven-weekperiod for these two 3 pollutantswere 7.1 ppb (18.5 gi ) and 3.7 ppb (6.9 jig/n') for SO2 and NO2 respectively.The reportedconcentrations varied sijnificantly over the course of the monitoringprogram. The maximumdaily concentration of SO2 was 109.2 ppb (285 g/rm') and the maximum daily 3 concenrtaion of NO2 was 7.2 ppb (14 pg/r ). The maximumhourly concentations during the monitoringperiod were in excess of 1000ppb of S02 and 25 ppb NO2.
The occurrencesof these high hourlyconcentrations of SO2were rare. During the monitoring period, 96% of the hourly values were less than 25 ppb (65 pg/rn) with 93% less than 10 ppb and 88% reportedas less than 5 ppb. Only 0.7%(7 occurrences)of the hourly values exceededthe Project guidelinefor the maximum1-hour average of 350 jig/ (134 ppb).
Each of the periods of high SO2concentrations occufred with winds blowingfrom the directionof the Officech6rifien des phosphates(OCP) phosphate plant These elevated concentrationsprobably result from penods of start-p and shut-downassociated with the sulfuricacid plant operationsat the OCP. Becauseof the type of opcration,these start-up and shut-downperiods can produce short durationsof high emissionlevels of SO2. The high one- hour concentrationsindicated in the data recordare thoughtto reflectthese types of non-typical releases. During other penods with wind blowingfrom the OCP towardthe monitonng site, the normal low backgroundconcentrations were found, indicating the atypicalnature of these elevatedconcentrations.
The Project begancollecting one year of ambientair qualitydata (SO2, NO., and PM) at the JLPP site beginning in May 1996. Analysisof these data will be presented as a supplement to this EIA as soon as sufficientdata have been collectedto form salient conclusions.
EIA 4-4 August 1, 1996 INTERNATIONALS
Table 4-1. Comparison of LPEE Ambient Monitoring Data (1994)with JLPP Project guidelines
LPE Ambient JLPP Project Monitored Values ' guidelines Atimospheric Constituent PeriodoAvera - ug,C m 3 ) (2gfm3 Sulfur Dioxide Annual Mean 19 50 Maximum 24-hour avg. 285 125
Maximum 1-hour avg. 4675 350 Nitrogen Oxides Annual Mean 7 100
(expressed as NO2) Maximum 24-hour avg. 14 150
l______.__ Maximum1-hour avg. 27 400
Fwrom the sevenweek monitoring data paiod in 1994.prior to cxstucton of UnitsI & 2 (Fuy - Marc, 1994)
4.1.4 Surface Water And Sediment Quality Hydrographic, sedimentological, and geochemical sampling was conducted in the Atlantic Ocean at JLPP prior to the completion of Units 1 and 2 (LPEE, 1994; ONE, 1994). In April 1996, additional surface water and sediment samples were taken in the Atlantic Ocean near the JLPP in order to assess baseline conditions of the surface water, sediment, and biological environment (see Section 4.2) prior to construction of Units 3 and 4 of the JLPP.
The nearshore Atlantic Ocean near the JLPP is a relatively high-energy environment characterized by a rocky shoreline, and rocky subsurface out to 300 m offshore. Tides are semi- diural, with two highs and two lows daily (ONE, 1994). The maximum amplitude at Jorf Lasfar is 3.5 m, and extremes are 3.9 and 0.4 m relative to hydrographic zero at -2.2 m NGM (ONE, 1994). Currents taken in the bay of Jorf Lasfar indicate an intensity of 20 cm/s, both at the surface and 3 m below the surface. Current direction is generally from the northeast to southwest offshore. Due to the coastal topography, the nearshore current direction is variable (ONE, 1994). In the shallow water near the rocky cliffs along the shoreline, currents could attain and surpass 1 m/s as a result of reflection from the cliffs.
EIA 4-5 August 1, 1996 RADIAN- INTERNATIONALE9
Materials and Methods Surface water and sedimentsamples were taken at 10 stations in the nearshore,sublittoral zone in the Atlantic Oceannear the JLPP. Water sampleswere taken on April 24 and 25, 1996 and sedimentsamples on April 26, 1996. Five stationswere located 300 m offshorein water depths of 5.5 to 15 m, and five stationswere 500 m offshorein water depths of 9.5 to 15 m (see Figure 4-2). Navigationtechniques involved preplotting stations and triangulation. Sampleswere taken in the momings, generallyduring high tides, with windsfrom the north at approximately 15 to 30 km/h.
Water for laboratoryanalyses was taken 10 cm below the surfacewith a two liter Niskin Bottle (see photo in AppendixE). Hydrographicdata, includingtemperature, conductivity, salinity,and dissolvedoxygen, were measured at each stationwith a YSI Meter. A Secchi disc was used to measure water clarity. Surficial sediment samples were taken with a Wildco Ponar grabsampler (volumeof 8,200mIL) (see photo in AppendixE). Four replicatesamples were takenat each station. Sampleswere describedat the time of collectionfor sediment type and other visual characteristicsand later subsampledand storedfor sedimentological,geochemical, and biological analysesin the laboratory. Water depths were taken with a Ratheonfathometer.
Laboratoryanalyses of the water and sedimentswere conductedby the LPEE in Casablanca.The samples wereanalyzed for Cd, Cu, Fe, Mn, Ni, Pb, Se, Zn, As, total Cr (Crt), and V using an inductivelycoupled plasma atomicemission spectrometer (ICP-AES). Hg was also analyzedvia cold vaporatomic absorptionspectrophotometry.
Results and Discussion Hydrorahy-As shown in Table 4-2, the hydrographicparameters of temperature, conductivity,salinity, dissolved oxygen, and pH varied little between stations. Temperatures ranged from 16.2 to 17°C; salinities,from 33.9 to 34.1 mg/L;conductivities, from 42,920 to 43,750 gmhos/cm; dissolvedoxygen, from 5.93 to 6.96 mg/L; and pH, from 7.22 to 7.47. Ranges and values appear to be normalfor nearshore,sublittoral surface waters at this time of year. Secchi disc values from 2.12 to 2.9 m indicategood water clarity (LPEE, 1996).Oxygen levels appearhigh enoughto not be limitingto the fauna. Seawaterwith meandissolved oxygen values above 5 mg/L is characterizedas water with "exceptionalaquatic life use" and typically has high speciesdiversity and a balancedtrophic structureCrNRCC, 1995).
EIA 4-6 August 1, 1996 \P¢d Le~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~4 ; a $ > 4 (- 0 X 0 ;Lt'S'U't'''<'i u?ean I~~~~Appr~oimt locations of marinebiology and waterquality sampling :: : ' ': .: ... " " 0 I" ' :::4": : ': : ":: . : . : ' .0...... ii '' 4 .. \.... ...... -...... 11 ...... , .. J .; ...... ,...... si , ; .. ...r '---- Gad::; :j-.-.-i...... -;...... ,^...... fNf~iiiIATIONA[U . CALE:METEAs. .. FigAshurUne42. Marines Bioogy/Water Qualty SampingSite XTAadir v<.; < SCALE.METER9 X . _ _ zf lBG~~~~~~~~~~~~~~~~~~~~~~ADINN Figure4-2. Marine Biology/WaterQuality Sampilng Site 9 Table4-2. HydrographicMeasurements, Gross SedimentType, and SampleDates and Times for Each Station - :|0|Cohdttc~IvIty/ - | - 00 0:400 -0t0 I;|:'i Sai nity I Temperature itcromhoskht) i)0 beAdH Set.chl Sauptle |IA1 0!LC) :::'i:: : (me.. :pH : I-e .., c(' nt eD j SamyleDate 1 16.2 42,920/34 7.36 6.5 15 Sand 2.75 9:20 April24, 1996 2 16.4 43,150/34 7.39 6.93 12 Sand 2.3 10:00 April24, 1996 3 16.3 43,000/34 7.47 6.96 15 Muddysand 2.7 10:20 April24, 1996 4 16.5 43,150/34 7.42 6.9 15 Sand 2.3 10:35 April24, 1996 5 16.6 43,120/33.9 7.22 6.73 11.5 Sand 2.12 8:00 April25, 1996 6 16.3 43,120/34 7.33 6.62 12.5 Sand 2.6 8:20 April25, 1996 7 16.3 43,070/34 7.33 6.61 6.5 Shellysand 2.5 8:55 April25, 1996 8 16.4 43,130/34 7.38 6.42 10 Sand 2.2 9:10 April25, 1996 9 16.4 43,200/34.1 7.4 6.47 5.5 SheIlysand 2.3 9:35 April25, 1996 10 17 43,750/34 7.38 5.93 9.5 Sand 2.9 9:55 April25, 1996 DO* Dissolvedoxygen '. 'V INTERNATIONALM Surface water and sediment samples were taken by LPEE in June, July, and August 1994 (LPEE, 1994) at 32 stations in the sarne general area as the stations sampled in April 1996. Surface water temperature, conductivity, and pH were taken at each station. As expected, water temperatures were higher in the summer of 1994, 18°C at all stations, as compared to the spring average temperature in 1996 of 16.4°C. Conductivities and pH were also higher. The pH values were between 7.7 and 8.05; conductivities were between 58,300 and 61,600 amhos/cm. Surface Water-With a few exceptions trace metal concentrations in surface waters were generally low, as shown in Table 4-3. Also, no clear distribution trends could be detected. Concentrations of vanadium, selenium, and arsenic were either below or just above detection limits at all stations. Most concentrations of cadmium and manganese were either below, at, or just above detection limits. The range for cadmium was from <0.08 to 0.19 ,ugL, and for manganese, from <0.04 to 0.20 ,ug/L Concentrations of iron, nickel, lead, zinc, and total chromium were relatively low. Copper concentrations were high at two stations. Copper values ranged from <0.08 to 20.9 ug/L Copper values for stations 2 (20.9 Azg/L)and 4 (18.8 ug/L) were high, although the mean of 558 ug/Lfor all samples was low. Mercuiy concentrations were relatively low, except for Station 10 at 1.49 Azg/L. Ranges in trace metal concentrations in surface waters taken from near the JLPP in the previous LPEE study (LPEE, 1994) were compared to values for the same elements analyzed from samples taken in 1996. For some metals, the range in values was similar. For example, values for total chromium from the 1994 study ranged from 0.8 to 3.0 AzglL.Values based on the 1996 water samples ranged from <0.76 to 3.34 ug/L Also, values for lead were similar, ranging from 0.8 to 3.0 AuglLin 1994 and <1.2 to 3.73 in 1996. Values for arsenic and nickel were generally higher in 1994 than in 1996. Arsenic values ranged from 0.5 to 2.0,ug/L, whereas, most concentrations were below detection limits in 1996. Nickel values ranged from 0.9 to 2.5 in 1994 and < 0.2 to 1.94 Ag/L in 1996. Values for cadmium, copper, mercury, and zinc were generally higher in samples taken in 1996 than in samples from 1994. In 1996, cadmium ranged from <0.08 to 0.19 Azg/L.In 1994, the range was from 0.02 to 0.07 aglIL Copper ranged from <0.08 to 21 agtL in 1996, but in 1994, copper ranged only from 1 to 3.5 gglL. Zinc values ranged from 0.27 to 17.6 ug/L in 1996, and 0.9 to 2.5 AggLin 1994. Mercury values ranged from 0.11 to 1.49 Ag/L in 1996, and 0.01 to 0.04ugfL in 1994. Surface waters were not analyzed for iron, manganese, selenium, and vanadium in 1994, and, therefore, could not be compared to results from the 1996 samples. EIA 4-9 August 1, 1996 Table4-3. TraceMetal Concentrations of SurfaceWater (mgIL) d eCd ... i :N ph Se. n Crt 1 0.16 0.87 12.5 0.04 0.83 3.73 <1.2 1.26 <0.22 0.52 0.22 0.51 2 0.18 20.9 18.6 0.04 1.54 2.46 <1.2 3.70 <0.8 0.82 <0.08 0.63 3 0.12 3.87 5.93 0.06 0.61 1.36 <1.2 11.7 <0.8 0.51 <0.08 0.61 4 0.19 18.8 14.7 0.15 1.94 2.17 <1.2 17.6 <0.8 1.04 <0.08 0.31 S5 01 2.86 3.66 <0.04 0.76 <1.2 1.2 3.31 <0.8 1.10 <0.08 0.58 6 0.08 0.15 5.19 0.06 0.29 <1.2 <1.2 1.80 <0.8 <0.16 <0.08 0.11 7 <0.08 0.88 6.34 <0.04 0.46 <1.2 <1.2 2.06 <0.8 0.80 <0.08 0.63 8 <0.08 <0.08 3.13 0.09 0.33 <1.2 <1.2 2.07 <0.8 <0.16 <0.08 0.17 o t 9 <0.08 1.16 16.6 <0.04 1.32 <1.2 <1.2 0.27 <0.8 3.34 <0.08 0.96 10 <0.08 4.12 13,6 0.20 <0.2 1.4 I- '0 %0 o~ INTERNATIONALM3 A.l values for trace metals from surface waters near the JLPP, except copper at stations 2 and 4 and mercury at Station 10, were generally well below the generally accepted values for marine acute or chronic toxicity (rNRCC, 1995). Acute toxicity kills in the short term (rninutes to days); chronic toxicity causes cunmulativeeffects over the long term (months to years), including illness and death. The marine acute toxicity criterion for copper is 16.27 ,u.g/L,and 4.37 jug/Lfor chronic toxicity. Copper concentrations from stations 2 and 4 were above both values. The marine acute toxicity criterion for mercury is 2.1 p,gIL,and 1.1 I gL for chronic toxicity. The mercury concentration at Station 10 was above the chronic toxicity value. Note that Station 10 is furthest removed from JLPP and the closest to the port Table 4-4 shows measurements for a diverse set of water quality parameters, including total suspended solids (TSS); the nutrients, Total Kjeldahl Nitrogen (TN), nitrate (NO3), nitrite (NO2), ammonia (NH4), and orthophosphate (P04 ); potential contaminants, total hydrocarbons (THC), and phenols; and chlorophyll I Total suspended solid values, or the concentraton of suspended sediment in water, were low, less than 10 mglL Concentrations of the various forms of nitrogen were also low. However, phosphate levels appear to be relatively high, ranging from 0.748 to 1.08 mgIL. Concentrations of the contaminant, total hydrocarbon, were mostly below detection limits. Phenol concentrations were all below the detection limit Of the water quality parameters taken in 1996, only total hydrocarbons and phenols were also measured in 1994 (LPEE, 1994). Total hydrocarbons concenaions in 1994 were generally near zero, except for a station with a relatively high concentration of 9.97 mg/L. Phenol concentrations were all very low in 1994. Although there are no numerical standards for nutrients in manne waters, accepted screening levels for coastal waters (INRCC, 1994b) can be applied to nutrient values from surface waters near the JLPP. Concentations for all nutrients, except orthophosphate, were below accepted screening levels. Concentrations of orthophosphate at all 10 stations were above the accepted screening level for coastal waters of 0.2 mglL, indicating nutrient enrichment may result in algal blooms and impairment to aquatic life habitats. As shown in Figure 4-2, the outfall from the OCP phosphate plant is just south of the JLPP site. EIA 4-11 August 1, 1996 Table4-4. Surface Water Parameters (All ValuesExcept for m Chlorophylla areIn mglL) M 1 5.43 0.624 0.027 0.012 0.02 0.768 <0.5 1.28 <0.025 2 8.28 0.55 0.015 0.014 0.012 0.791 <0.5 0.96 <0.025 3 6.86 0.902 0.02 0.013 0.016 0.748 <0.5 0.64 <0.025 4 5.7 0.485 0.028 0.014 0.014 0.78 <0.5 0.96 <0.025 5 6.3 0.118 0.022 0.01 0.012 1.08 <0.5 0.801 <0.025 6 5.3 0.058 0.018 0.011 0.016 0.825 <0.5 1.068 <0.025 7 9 0.1 0.011 0.015 0.012 1.05 <0.5 1.068 <0.025 8 5.7 0.15 0.01 0.018 0.009 0.906 <0.5 0.534 <0.025 9 4.7 0.063 0.013 0.015 0.007 0.924 <0.5 0.802 <0.025 10 6 0.14 0.016 0.014 0.008 0.954 <0.5 0.534 <0.025 TSS Total suspendedsolids TKN - Total kjeldahlnitrogen THC = Totalhydrocarbons P04 = Orthophosphate e~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~' RADIAN- INTERNATIONALM Sediment-Trace metal concentrationsin surficialsediments range from vety low to high, as shown in Table 4-5. Sedimentat all stationsis predominantlysand, with some mud and shell, as shown in Table 4-2. Seleniumlevels at all stationswere below the detectionlimit of <3.0. Also, nearly all valuesfor cadmium,except in sedimentsat station 1 (0.62ppm), were below the detectionlimit of <0.2 ppm. Concentrationsfor the othermetals wereabove detection limits at all ten stations. The followingare ranges and means (in parentheses)in ppm for the other trace metals: copper,36.3 to 56.7 (49.2);iron, 4,539to 17,402(8,476); manganese, 39.8 to 87.3 (67.2);nickel, 4.55 to 18.2 (10.04);lead, 23.2 to 63 (44.72);zinc, 25 to 63.2 (39.21); arsenic,32.1 to 48.2 (41.74);chromium, 17.2 to 68.3 (39.49);vanadium, 14.9 to 60.4 (34.73); and mercury,0.023 to 0.264 (0.091). The highest metal concentrationstended to occur at stations 1 or 3. For example,high concentrationsfor 8 of the 12 trace metals werefrom sedimentsat either station I or 3. Both station 1 and 3 were 300 m offshore,in water depths of 15 m, as shown in Figure 4-2 and Table 4-2. Cadmium,nickel, lead, chromium,and mercurywere highestat station 1; copper,zinc, and arsenic were highestat station3. Of the metals abovedetection limits, only iron (station2), manganese(station 9), and vanadium(station 5) were highestat other stations. In comparingthe results of the LPEE (1994)study with results from samplestaken in 1996,the range in concentrationsfor most tracemetals in sedimentstaken in 1994 was similarto or greaterthan those concentrationsfound in 1996sediment. For example,the range in concentations for copperwas 18 to 66 ppm in 1994samples, as comparedto 36.3 to 56.7 ppm in 1996 sediments. Also, the range for zinc was 24 to 94 ppm in 1994 samples,but 25 to 63.2 ppm in 1996.The range in concentraionsfor nickel and lead was similar. On the other hand, arsenic valueswere much higherin sedimentsamples from 1996. The highestarsenic value in 1994was 8.6 ppm; whereas,the highestvalue from sedimenttaken in 1996was 48.2 ppm. Sedimentswere not analyzedfor iron, manganese,selenium, vanadium, and mercuryin 1994. Data on the mixturesand concentrationsof contaminants,alone, do not provide an effective basis for estimatingthe potentialfor adverseeffects to organisms(Long et aL, 1995). The United StatesNational Oceanic and AtmosphericAdministration (NOAA), in conjunction with Canada and Florida,developed effects-based guidelines to help identifymarine and estuarine sedimentsin which the potentialfor biologicaleffects is greatest(Long et al., 1995). Briefly,the approachin developingthe guidelinesinvolved: (1) assembling,evaluating, and collatingall availableinformation in whichmeasures of adversebiological effects and chemical EIA 4-13 August 1, 1996 Table 4-5. Trace Metal Concentrations In Sediment (ppm) _an d NI . P,. ._._-._ A ___, v1 l 0.62 55.1 5493 39.9 18.2 63.0 <3.0 54.2 47.8 68.3 42.1 0.264 2 <0.2 37.0 17402 59.6 15.3 26.2 <3.0 32.3 38.1 44.6 53.6 0.080 3 <0.2 56.7 8085 65.9 8.81 53.1 <3.0 63.2 48.2 55.5 45.6 0.098 4 <0.2 36.3 13152 62.1 9.1 23.1 <3.0 26.8 32.1 29.8 33.8 0.060 5 <0.2 52.1 11662 55.2 12.9 52.4 <3.0 52.1 45.2 65.9 60.4 0.093 6 <0.2 51.5 4539 55.7 12.6 48.8 <3.0 51.8 35.7 44.2 40.2 0.073 7 <0.2 45.7 5947 76.4 5.54 47.3 <3.0 25.0 40.8 17.6 14.9 0.090 8 <0.2 55.5 6293 84.8 4.55 42.2 <3.0 26.5 41.8 17.2 16.4 0.064 9 <0.2 48.9 5326 87.3 5.60 46.2 <3.0 26.1 42.4 22.3 16.5 0.062 10 <0.2 53.6 5865 85.4 7.70 44.8 <3.0 34.1 45.3 29.5 23.8 0.023 _- --- 0o RAIANN INTERNATIONAL3 concentrations in sediments were reported; (2) identifying the ranges in chemical concentrations that were rarely, occasionally, or frequently associated with effects; and (3) determining the incidence of biological effects within each of the ranges in concentrations for each chemical as an estimate of guideline accuracy (Long et al., 1995). The distributions of the effects data were determined using percentiles. The lower 10th percentile of the effects data for each chemical was identified and referred to as effects range-low (ERL). The median, or 50th percentile of the effects data, was identified and refenred to as the effects range-median (ERM). The two guideline values, ERL and ERM, delineate three concentration ranges for trace metals: (1) concentrations below the ERL value represent minimal-effects range (effects on organisms would rarely be observed); (2) concentrations equal to and above the ERL, but below the ERM, represent a possible-effects range, within which effects could occasionally occur, and concentrations equivalent to and above the ERM value represent a probable-effects range within which effects would frequently occur. In companng concentrations from sediments near the JLPP with published ERL and ERM values, mean concenions for most metals are below the ERL values, meaning adverse effects would rarely be observed. All trace metal concentrations in the sediments fall below ERL values, except values for copper and arsenic, and one for mercury. All values for copper and arsenic are above the ERL values of 34 and 8.2 ppm, respectively, but well below the ERM values of 270 and 70 ppm, meaning adverse biological effects on organisms could occasionally occur. All mercury values are below ERL (0.15 ppm) and ERM (0.71 ppm), except for samples from Station 1, which exceed the ERL. Table 4-6 presents an overview of how the measured heavy metal concentrations compare with criteria of ecological toxicity as described in this section. The following issues emerge: Stations 2 and 4 (relatively close to the ash outfall and the OCP discharge channel) have copper concentrations in the seawater above the acute toxicity criterion. Station 1 (close to the OCP outfall) has sediment mercury levels above the ERL criterion (biological effects possible). Station 10 (near the port) exceeds the chronic toxicity criterion for mercury in seawater. EIA 4-15 August 1, 1996 RADIANS INTERNATIONALM3 In the sediment of all stations, copper and arsenic exceed ERL (biological effects possible), but are well below ERM (biological effects probable). Table 4-6. Water and Sediment Heavy Metal Toxicity Summary MarineWater Acute and : -hronicToiciy, Criteria' 'ERLand ERM SedimentGuiddine? Cd All statons well below both critena All stationsbelow both crteria Cu Stations2 and 4 aboveboth criteia, all All staions aboveERL, but well belowERM other stationsbelow both cnteria Fe All stationswell belowboth criteria All stationsbelow both criteria Mn All stationswell belowboth cnteria All stationsbelow both criteria Ni All stationswel belowboth cnteria All stationsbelow both criteria Pb Ad stons wel belowboth critera All stationsbelow both cnteria Se All stationswell belowboth criteria All stationsbelow both criteria Zn All stationswell belowboth cnteria All stationsbelow both critera As All stationsweD below bothcnteria All statons aboveERL, but well belowERM Cr All stationswell belowboth cnteria All stationsbelow both criteria V All stationswel belowboth citera All stationsbelow both cnteria Hg Station10 abovechronic criterion, all Station1 abovethe ERL, all other stationsbelow other stationsbelow both cntena both criteria 'TNRCC,1995 bLong eal, 1995.At or aboveERL. biological effects cold occasionallyoccur. At or aboveERM, biological effects will frequy occur. 4.1.5 Groundwater The groundwater is encountered about 6 m below ground level. Typically at such close proximity to the sea, saltwater intrudes below a freshwater lens. The interface between the two is usually well-defined and referred to as the halocline. It moves up and down with the tides. At this site, the freshwater lens is probably recharged from the plains between Casablanca and Safi (Radian, 1995). EIA 4-16 August 1, 1996 RZADL^N- INTERNATIONALM3 Local residents use a drinking water well located outside the fence line near the main entrance of JLPP. During the Phase I EA, water from the drinking water well was sampled. Concentrations of oil and grease (11.5 mgfL) and total petroleum hydrocarbons (TPH) (0.2 mg/kg) were found in the drinking water. The Project guideline discharge criterion for oil and grease is 20 mg/L, but no drinking water standard was found. Similar levels of oil and grease were found in sampling wells around the site. The cause of this is unclear, but the uniformity of the data suggests a source other than point contamination from JLPP operations. Metals were also detected in the groundwater, but these were attributed to the regional content of metals in the subsurface soil, rather than to JLPP site activities (Radian, 1995). 4.1.6 Noise Noise can be defined as unwanted sound. Its volume is measured in units of energy or pressure called decibels (dB). Noise has both quantity and quality. The quality of the noise is affected by its pitch, or frequency. Sound levels that are weighted to approximate the frequency detected by the human ear are called A-weighted decibels or dBA. Table 4-7 presents common sounds and typical dBA that are associated with these sounds. Community noise guidelines rely on "day-night" average sound levels measured in dBA. The day-night average, or Ldn, weights nighttime noise 10 dBA higher because communities are more sensitive to night time noises. As shown in Table 2-5, the Project guideline for community noise is 55 Ldn at the nearest residential are-a This level was set to avoid interference from enjoyment of outdoor activities and is more protective than is necessary from a human health standpoint. The level of 70 dBA is adequate to protect against hearing loss for anyone exposed to this level on a long term basis (EPA, 1974). A baseline noise survey was conducted around the fenceline of the JLPP in May 1996 using a hand held instrument that measures dBA averaged over a 30-second period. The 11 noise sampling locations are shown in Figure 4-3 along with the Ldn levels for these locations. Also, an additional sampling location (Site No. 11) was established on top of the bluff opposite the ILPP. This point is representative of the residentialareas located on top of the bluff, although not at any specificresidence. The resultsof the baselinesurvey are as follows: EIA 4-17 August 1, 1996 INTERNATIONALM3 Table 4-7. Common Noise Levels in dBA Sound dBA Thresholdof hearing 0 Bmatiing 10 Quiet bedroomat night 20 Library ~~~~~~~~~40 U.S. EPA guidelinefor avoidanceof interferencewith 55 Ldn quietresidential outdoor enjoyment Normalconversation. 60 Busy trafficintersection 90 Power lawnmower 100 Loud motorcycle 110 Jet aircraftat 6 m 140 Refeence(Radian 1993) When compared with the World Bank 1988 gaidelines, 10 of the 11 fenceline measurementswere belowthe 70 In guidelinefor industial and agriculturalland uses. (The immediateamea surrounding the power plant is industrialwith somecultivated farmland on the bluff.) The one measurementabove the 70 Ldn guidelinewas onlymarginally above at 70.9 UAn. As shown in Table 4-8and Figure4-3, the dominantnoise source for sites on the south end of the plant was the generatingunits. Only one of the units was in operationat the time of the measurements. However,the operationof the seconduimt would be expectedto increasesound levels by no more than 3 dBA. On the other hand, wind conditionsduring the surveymay have accountedfor several decibels. The dominantnoise sourcesfor the sitesto the north werethe equipmentassociated with the port or coal handling. For some of the sites, the dominant nighttime noise source were naturalsounds such as the roar of the ocean, croakingfrogs, and chirpingcnckets. Given that the 70 Ldn level was initiallyset by the U.S. Environmental ProtectionAgency (UJ.S.EPA) to be fully protectiveof hearing "with an ample margin of safety," the fenceline levels do not pose a problemwith respectto the immediatesurrounding land uses (port,rail line, cultivatedland beyondthe railroad,power plant site area outside of the security fence). EIA 4-18 August 1, 1996 Table4-8. RadianNoise Survey Results D*Yte, .t , -Ii Ae . uidiele_V e Sie:.hohina:nt_Notaranivi. . -I (IA); N . , Ldh (Ldb) 1. Maingate 65.3 Oeneratingunit 63.2 Generatingunits 69.9 70.0 2. East fenceline 63.4 Generatingunit 59.9 Generatingunits 67.0 70.0 3. East fenceline 61.7 Generatingunit 56.6 Frogs 64.2 70.0 4. East fenceline 57.6 Pumpyard motors 52.4 Generatingunits 60.0 70.0 5. East fenceline 60.5 Portequipment 44.0 Generatingunits 59.0 70.0 6. Northeastcorner 64.0 Port equipment 45.6 Crickets 62.3 70.0 7. West fenceline 54.2 Port equipment 48.8 Ocean 56.5 70.0 8. West fenceline 57.2 Ocean 57.4 Ocean 63.8 70.0 9. West fenceline 61.7 Generatingunits 62.8 Generatingunits 69.1 70.0 10. Southwestcorner 64.1 Generatingunits 64.6 Generatingunits 70.9 70.0 It. Offsite- residential 53.3 Generatingunits 49.3 Generatingunit 56.6 55.0 receptor 12. Northwestcorner 66.6 Portequipment 47.6 Port equipment 64.8 70.0 'All readingsare 30 second Leq 'WorldBank 1988 guidelines %O '. ~00o g~~~~~~~~4 o~~~~~~~~~~~~~~~~I z - l r XS ;; ;< ; ;~~~~~~ . = ;S Portfxf :\ l I -g- offsite0 0 ; sensitive receptor m ~~~Day-nightavg. noiselevel In II~ ~ ~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ...... dPor ,.'- .,:"'0.;; ':I:'.0.:,'::,.:,,'t".''t;;;i .:',''' .- ,.- - 8 64dnd >~~~, Prpoe Unlt:..s...... :..:3....,, 4- :.&.;: ...... >.:/i <,"~~~~~~~~~~~~.tf.'0 D :'- t-',S-:0 E' gS'''',,,': .,.' dn'', 0~~~~~~~~~ ' ' : : : '' . ::' : . ':'- : :11' .E ':::f:' : ':' ':': ' 'f : < ' .. .: . . ', . f !A: ::CA:M ME:'';n "''S' ;' ' - "'''11 ' ' f' ' '; '' ' '" '" '' "- '-' '''; }"" ''NT'ERN'TIO''A'"''td M JV0--31 ON) ' ';'''10'! f f'; e'' 8S'st ''s0'lT f o w ' ; ' S ' ' ' ~ ~~ ~'f ...~ ~f.',. ~ -,,4'~ Fgr -3 Baeln Nois Suve Results.: CR~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ RADIAN- INTERNATIONAL Site number 11 is locatedon top of the bluff in view of the JLPP. It is a conservative representationof the nearest residentialarea outsidethe JLPP site' . The singlemeasurement of 56.6 Ldn is marginallyabove the 55 Ldn annualaverage World Bank 1988 Guidelinelevel. This level was set by the U.S. EPA to avoid interferencefrom outdoorenjoyment of quiet residential areas. Most of the residencesin the settlementson top of the bluff are locatedfurther away from the edge of the bluff and thereforeshielded from ground levelpower plant noises. We would expect these residencesto be subjectto even lowernoise. 42 The BiologicalEnvironment 4.2.1 TerrestrialBiota Flora and Fauna A vegetationmap of Africaclassifies the naturalvegetation for the Atlantic and Mediterraneancoastal areas of Morocco,including the area near the JLPP, as Mediterranean evergreenforest-hard-leaf scrub. However,few remnantsof the naturalvegetation appear to curently remainin the area. The current vegetationin the area is probablymost accurately classifiedas a MediterraneanAnthropic Landscape (White, 1983).White (1983) states that "most fertilelowlands have been cultivatedsince Romantimes, and few vestigesof natural vegetation remain.Wheat is the most widelyplanted crop,but peas, beans, and onionsare plentiful,and there are many groves of olive, citrus,fig, and grape." Hedgerowsare composedof Agave, Acacia karro,Anido donax,and Opuntia. Eucalyptusand Pinus halepensisare planted locally as windbreaksand for fuel and timber (White,1983). Sparseplant cover of shallowersoils are grazed by sheepand cattle,and overstockingcauses soil erosion. Rocky areas supportZiziphus lotus, dwarf Chamaerops,and unpalatableherbs such as Ferulacomuwzis, Asphodelus microcarpus,and Urgineamaritima. Vegetationobserved in April near the JLPP includedwild flowers of the family Compositae(possibly of the genusHelianthes), thistles, Daucus sp. of the carrotfamily, Umbelliferae,the grass, Sporobolussp., and a scrubbyoak or Quercussp. On slopes abovethe JLPP, a bloomingsucculent or halophyticspecies (cf. Portulaca-oleracea)was abundant The Tnes is a residenqe apparently on the JLPP site but outside the security fence. It is located beyond site number 2 and thefore wouldbe expectedto have an Ldnof below 65. EIA 4-21 August 1,1996 RADIANE INTERNATIONALM same species was also seen growingon beach dunesnear El Jadida- There were also several areasnear the lLPP that were devoidof vegetation. Fields of com and wheat are commonnear the JLPP. Along the roadto Agadir,to the southof the JLPP, "truckfarms" of carrots,onions, tomatoes, and other species were seen growingnear the road or betweenthe road and the Atlanticshoreline. Hedgerows along the road were composedof Arndo donar and Tamarixsp. Palustrineor estuarinewetlands were not observednear the powerplant,nor were seagrassesor submergedaquatic vegetation seen in the shallow, subtidalareas. Green algaewere commonon the rocks along the shoreline. The onlyterrestrial animals observed in the immediatevicinity of the JLPP during the field trip in April 1996were domesticatedfarm animal and pets. Endangered or Threatened Species A total of 10 endangered or threatened species are listedas having their historic range or mayhave their historic range in Morocco(IJSFWS, 1994). These are shown in Table 4-9. None of these were observedduring biologicalfield investigationsin April 1996. It is considered unlily that these specieswould be withinJLPP boundanes. Five of the 10 species are endangeredrnammals, one is an endangeredbird, and four are endangeredor threatenedsea tures. The sea turtles' historic rangesare listedas either circumglobalin tropical and temperate oceansor tropical and temperateseas, and, therefore,may occur on the Atlanticcoast of Morocco. The loggerheadsea turtle has been observedon the AtlanticCoast of Morocco (Brongersna, 1972). None of these specieswas observedor is believedto be present at the JLPP site. Table 4-9. Status of Endangeredor ThreatenedSpecies That May Have HistoricRanges in Morocco CommonName ScientificName Status Barbarydeer Cervuscaphus barbarus E Cuviee'sgazelle Gazellacuvieri E Mhorrgazelle GazcUadama mhorr E Moroccangazelle Gazelladorcas massaesyla E Barbarybyena Hyaea hyaenabarbara E Spanishimperial eagle Aquilaheliaca -Adabeni E Green sea e Cheloniamydas E Kemp'sridley sea turtle Lepidochetyskempii E Leatherbacksea turtle Dermochelyscoriacea E Loggerheadsea nure Carenacarena T E=endangaed,T=teatned EIA 4-22 August 1,1996 RZADLAN- INTERNATIONALM3 4.22 Marine Biota Macrobenthos Bottomsediments develop communities of invertebratesthat live on and in these sediments. Includedin the fauna,referred to as the benthos,are polychaeteannelid worms; clams or bivalves(Molluscs of the ClassPelecypoda); snails or gastropods(Molluscs of the Class Gastropoda);species of crabsand other smallercrustaceans; echinoderms, such as brittlestars(Class Ophiuroidea);and other groups. Macrobenthicinvertebrates are here defined as those invertebrateslarger than 2 mm. This studyis generallya qualitativeor semiquantitativecharacterization of the macrobenthosnear the JLPP. This is probablythe first studyof the macrobenthosin the nearshoreAtlantic near the JLPP. Previoussampling efforts (LPEE,1944; ONE, 1994)did not includethe macrobenthos. Materials and Methods-As mentionedin a previoussection on surfacewater and sedimentquality, surficial sediment samples were taken at each station (Figure4-2) wiffia WildcoPonar grab sampler. Approximatelyone grab sampleper station was analyzedfor macrobenthos.Sediment samples were washedthrough a 2.0 mm screenand storedin a solution of 10% formalin. Sampleswere then examinedmicroscopically at the LPEElaboratories, and organismswere identifiedto specieslevel, whenpossible, and counted. Results and Discussion-A totalof 19 macrobenthicspecies were foundin surficial sedimentsfrom the 10 stationsnear the JLPP. Four invertebratephyla were represented. Molluscsdominated, both in numberof species(15) and individuals(57). The most abundant molluscanspecies were the pelecypods,Donax sp. and Mactrasp., and the gastropod,Vermetus sp. Donax was the only molluscanspecies with more than two individualsat a station. Barnacles(Balas sp. and B. perforans)were relatively abundant at two stations. Although polychaeteswere not abundantin any of the samplesand onlypresent at two stations,sediments from stations 6 and 10 had wormtubes of cementedsand grains,possibly of the polychaete familiesOweniidae or Pectinariidae.The limpets(molluscan family Patellidae),bamacles, and the gastropod,Vermets sp., may be found on the rocksnear the shoreline. These results are summarizedin Table 4-10. EIA 4-23 August 1, 1996 StADI0ANE INTERNATIONALM3 Table 4-10. MacrobenthicSpecies and Numbersof IndividualsPer Station Staions Spedes 1 2j 1 3 4 5 _6 T7 8_ 9 10 PhylumMollusca Class Pelecypoda FamilyMyilidae Mynusi barbaws 1 2 - - Perna pecra I Mytlus galloprovbicials 2 1 Mynuls eduids 2 FamilyDonawidae Donax sp. 6 5 4 FamilyThrciidae -- Thraczasp. - 2 - FamilyMacridae Mactrasp. - 1 2 1 1 FamilyVencridac - - - Venarzupissp. 2 CircmphalMssp. 1 Family Cwrdiidae------Acarthocardiasp. 2 ClassGasopod__- - - a FamilyVermetidae Vermermssp. 2 1 2 2 FamilyPatellidae Patella mngra 1 1 2 PateUacaerl_ea 2 2 1 FamilyLioinidae Linorinasaxatilis 2 FamilyNassaridae - Hinia reticul 1 2 Phylum Arthropoda- - - - - a- - - - Clas SubclassCiripedia Balanusperforans 10 Ba__us_sp. = 10 Sublass Maaostraca= Pagurus sp. 3 2 Phylun Annelida_ Class Polychacta 3 2 Phylum Echinodermata ClassOphiuroidea O4hiuraustI 1,9 EIA 4-24 August 1, 1996 RADIAN- INTERNATIONAL3 Stations4, 8, and 9 werethe most diversein terms of numbersof species,with seven speciesat each station. Station7 had no macrobenthicspecies, and stations I and 2, only one species apiece. Althoughspecies richness and abundancewas generallyvery low, this may be typical for this high-energy,nearshore benthic environment(LPEE, 1996). Pelagicand DemersalFish and Invertebrates Pelagicand demersalfish and invertebrateswere collectedin the nearshoreAtlantic Oceannear the JLPP. Tbe term pelagic,in this case, refers to those fish speciesthat were caught primarilynear the surfaceor in the water colum and that probablyfeed on zooplankton (microscopicanimals) or nekton(other smaller fish or invertebrates)in the water column. Demersal fish and invertebratesare those speciesthat were caughtprimarily on or near the bottom, and feed, primaily, on benthicinvertebrates that live on or in the sedimentsor vegetationattached to the rocks. The line betweenplankton or demersalfeeding is generallynot sharp. This part of the marinebiology study is a qualitativecharacterization of the fish and invertebratefauna living in the nearshoreAtlantic Ocean near the lLPP. Previoussampling efforts (LPEE, 1994;ONE, 1994)did not includefish samplingin their studies.Although commercialand recreationalfishing is conductednear the JLPP, this is probablythe first timethe fish communitynear the JLPPhas been described. Materials and Methods-Both pelagic and demersal fish and invertebrates were collectedwith a gillnet.The net used for surfacefishing was 80 m by 5.6 in, the one used for bottom fishingwas 70 m by 2.8 m. The fish and invertebrateswere collected overa 5 day period, primarilynear stations 1 and 2 and stations 7 and 8, as shown inFigure 4-2 and Table4-11. The gillnetwas set at 7 pm each sampleday and then retrievedat 8 am the next day. htwas set up at different distancesfrom shore,hence the terms ocean-sideor shore-sidesamples, as shown in Table 4-11. Tides during the samplingperiods weregenerally high whenthe net was set during the early evening,low in the early momninghours, then high again when the net was retrieved. EIA 4-25 August 1,1996 Table4-11. Flsh and Invertebrate _,pecles and Numbers of Individuals (Samplestaken between 4124 and 514196) I'eIagh:Specl0-;it. t:ettet94vuiASjede8 ______''.,,,;,,',i,; Odct 91 i ,'t' ' , ,OO0'A,'''t,(,'..t>.'. ______Sid Sb. SIdE Side '~ii ~SLSididd Sot Ie tet Side. ghiiie Side Fish_ Diplodusvulgaris . 4 2 Diplodussargus 3 Diplodussenegalensfs 2 I Belonesvetovidivi I Trachinolusovalus I Trachurustrachurus 1 2 Scomberjaponicus 3* 1 2 ON Lepidopuscaudatus I Sardinellaaurifa I Sardinapllchardus 4 Dicologoglossacuneala 2 2 Campogrammnagloycos 1 2 Sarpasalpa 3 _ Crustaceans Majasquinado . . 2 3 3 3 Scyllarusarcfus I Callinectesgallidus - 4 * IOOmSouthwest, ocean side -RADIAN INTERNATIONAL3 Results and Discussion A total of 13 fish and 3 invertebratesspecies were collectedfrom the nearshoreAtlantic Oceannear the JL?P (Table4- 1). Fish abundanceand diversityat each samplelocation and in the area, in general,was low. Of the pelagicspecies, the ocean-sidesample near stations 1 and 2 was the most diversein termisof speciesrichness, with five total species.Demersal fish species were also most abundantin the ocean-sidesample near stations1 and 2 (five total species).The most abundantpelagic fish specieswas the sardine,Sardina pilchard=s; however, with only 4 individualsfrom near stations7 and 8, it was not very abundant.The most abundantdemersal fish species was the porgy,Diplodus vulgaris, occurring at 3 of the 4 demersalsample locations. Demersalspecies also includedcrustaceans, the spider crab,Maja squinado,the lobster, Scylarus arctus, and the porunid or swimning crab, Callinectes pallidus. Maja squinado was relativelyabundant, occurring in all four demersalsamples. The ocean-sidesample near stations 1 and 2 containedall three crustaceanspecies. The diversityand quantityof fish and benthosin the sedimentsis consideredlow. This investigationdid not determinethe cause of these apparentlylow qualitymarine biolopical conditions. The high energyshoreline (rocky beach and heavywave action)may reduce marine biodiversity. High metals concentrationsin seawaterand sedimentsmay also be a contributing factor. 4.3 The Socialand CulturalEnvironment This sectionbriefly describes the history,demography, economics, and land use of the country and the area aroundthe JLPP. Becauseof the coastallocation of the JLPP and the importanceof fishingto Moroccaneconomy, Moroccan fisheries are discussedin this section as well. Fmally,local infrastucture, aesthetics,and proximityof parksand naturalareas to the JLPP are briefly addressed. 4.3.1 History and Archeology The first identifiedgroup of people in Moroccowas the Berberpopulation which is believedto have enterednorthwest Africa from Asia in the secondmillennium BC. From the earliest days of its history,the Moroccancoasts attacted variouscivilizations in searchof trading ports, agriculturalresources, and raw materials.There was some Roman influencealong the Mediterraneanand north Atlanticcoastal areas, but the Roman influencewas superficialand did EIA 4-27 August 1, 1996 INTERNATIONALM3 not extend down to El Jadida and Jorf Lasfarareas. From the 8th throughthe 12thcenturies Arabicinvasions resulted in the spread of Islam in urban areas of Morocco.Over the next two centuriesIslam dominatedthe entirecountry (Nelson, 1985). From the 11ththrough the 13thcenturies, three Berberdynasties ruled Morocco,building an empirethat extendedfrom Libyato Spainwith Marrakeshas its capital. In the 15thcentury this "Moorish"culture and reign beganto decline.By the early 16thcentury the Portuguesehad establisheda series of forts along the AtlanticCoast. The last of the fortress cities to remain in Portuguesehands was Mazagan.Founded at the site of an older Almohadfortress, Mazagan fell to local forces in 1769.Mazagan is now the city of El Jadida and is the closest site to the JLPP of predominanthistorical significance (Simonis, 1995). The site of the old Portuguesecity in El Jadida and the MoulayAbdellah Amghar site are located 17 Ian north of the JLPP (Elhaiba, 1996). During the 19thcentuy Europeansbegan to establishtrade with Morocco. Various European powers contestedfor controlof NorthAfrica with the Frenchgaining the upper hand in late 19thand early 20th centuries. The Frenchcontrolled Morocco until the countrybecame independentin 1956.Spain still retains authorityover a few small coastalenclaves. The French developedports and highwaysand beganthe process of industrialization.French along with Arabic is widely spoken amongurban educatedMoroccans. The nearest archeologicalsite to the JLPP has been identifiedas Tit's Minaret and archeologicalwall, locatedeight km north of the JLPP (Elhaiba,1996) in MoulayAbdellah. There are no historicalor archeologicalresources located on land that wouldbe affected by the constructionand operationof Units 3 and 4 of the JLPP. 4.3.2 Demographics As shown in Table 4-12, the 1994 censusshowed that Morocco'spopulation was more than 26.5 million. The mid-1995population estimate for the countrywas 29.2 million. The current rate of populationincrmase is estimatedat 2.2%.By contrastthe annualgrowth rate in France is 03*; the annual worldpopulation growth rate is 1.5%(Johnson, 1996). High birth rates have resultedin an incremasinglyyouthful median age. Morethan half of the population is under 20 years old (Simonis, 1995).The growth in populationhas been focusedin the country's largest urban areas.During the 1980sannual urban populationgrowth rates were about 4.5%, EIA 4-28 August 1, 1996 RADIANX INTERNATIONALM3 compared to about 1.5% for the rural areas (EIU, 1990). Rural areas still account for about half of Morocco's population. Literacy rates in rural areas are 23% compared to about 64% in urban areas (Simonis, 1995). Table 4-12. Populafion Growth for Morocco, El Jadida Province, and Commune Moulay Abdellah .1982. J 1994 1 AnnualChane Morocco 20,265,000 26,544,000 +2.2 El JadidaProvince 766,198 970,894 +2.2 MoulayAbdellab Commune 24,718 30,926 +2.0 Somc Moroccncaws datagfomEuiba, 1996and Fintlay, 1985 Morocco consists of 40 provinces. The JLPP is located in El Jadida Province which has as its provincial capital the city of El Jadida. Outside of the urban areas, the provinces are composed of rural communes of which there are more than 750 (Nelson, 1985). The JLPP and the immediate surrounding area is in the Commune of Moulay Abdellah. As shown in Table 4- 12, the population of El Jadida province is almost I million, while the population of Moulay Abdellah Commune was just over 30,000. The cluster of settlements on the bluff above the JLPP is called Oulad Ghadbane Center. It consists of 489 families (Elhaiba, 1996). More than two- thirds of the population of El Jadida province lives in rural conmmunes(Nelson, 1985). At least one-fourth of the population are native Berber-speakers and the most of the remainder are native Arabic speakers. The distinction between Berbers and Arabs in Morocco is largely linguistic because of the centuries of intermarriage between the two groups. Those living in the vicinity of the JLPP are Arabic speakers. 4.3.3 Economic Conditions The Moroccan economy is composed of three principal sectors: mining, agricultural, and everything else. The mining sector is dominated by phosphates. Morocco has the largest reserves of phosphates in the world and is the largest exporter of phosphates and the third largest EIA 4-29 August 1,1996 INTERNATIONALM3 producingcountry. The phosphateindustry includes mining and exportof phosphaterock and mranufacturingof phosphatederivatives such as phosphoricacid and fertilizers.Phosphate and its derivativesare the single most importantexport (U.S. State Department,1994). The largest phosphatemanufacturing complex in the countryis located immediatelyadjacent to the JLPP. Most of the phosphateis minedbetween 100and 200 km to the east of the Jorf Lasfar area at the Khouribgaand the Youssoufiamines. More than 24,000 personsare employeddirectly by the OCP. Agricultureemploys about 40% of the work force and generatesalmost one fifth of the nation's gross domesticproduct Morocco is a net exporterof fruits and vegetablesand a net importerof cereals.The main cropsin Moroccoare sugar beets, sugar cane,vegetables and cereals.(Nelson, 1985).With only about 3% of the nation'spopulation, the Provinceof El Jadida accountsfor 38% of the country'sfruit production,35% of the sugarproduction, 13% of the milk and meat production,and 11 % of the cerealproduction (Elhaiba, 1996). Vegetables,such as carrotsand tomatoes,and cereals, such as barley,are grown in the farms around the JLPP. The farmingis done on smallplots usingtraditional methods and relativelylittle modem equipmentsuch as tractors.Large scale hot housesare common south of the lLPP where tomatoes are grownbydroponically. Sheep, cattle,and goats graze in areas not suitablefor cultivation.The fishingindustry has developedrapidly duringthe 20th centmy. See Section4.3.4 for a discussionof commercialfisheries. The third leg of the Moroccanindustry is a rapidly growingand a diversifiedmix of industries,such as textiles,and services such as tourism. Tourismis becomingan important growthindustry in El Jadida provinceas mainlyEuropean visitors discover the beauty of the MoroccanAtlantic Coast The beachesbetween Jorf Lasfar and El Jadida are becominga popular tourist area; the coastal stretchsouth of the JLPP also appearsto be conduciveto future beach resorts. Political Systemand EconomicPrivatization The Moroccangovemment is a constitutionalmonarchy. The countryis transitioningto a modem marketeconomy. Throughthe appointmentof the provincialgovemors and the administrativechiefs that overseethe rural communes,the king still maintainsconsiderable EIA 4-30 August 1, 1996 INTERNATIONALM3 authority.Much of the planningfunction and the recommendationof legislativematters is in the handsof elected officials. In additionto movingthe countryin the directionof a Westernstyle democracy,the king is also promotingprivatization of many previouslygovemment-owned industries. Privatization and other economicreforms (such as fiscalrestraint, removing trade barriers,reduced barriers to businessformation) are creditedwith reducing inflation and povertyrates. The rate of inflation has been reducedfrom 12% per year in the mid-1980sto 5% in the mid-1990s.According to the Moroccangovernment, between 1985 and 1994 the numberof familiesliving in poverty dropped by one third and per capitaincome doubled to an equivalentof $1100 (U.S.) (Simonis, 1995). Privatizationhas the supportof the king and the elected officials.The National Assembly voted overwhelminglyto sell 113government-owned enterprises in 1989(EU, 1990). During the 1990sthe pace of privatizationhas continued.The proposedacquisition and expansionof the LPP by the Project Sponsorswill be the singlelargest privatizationinitiative for Moroccoand will be the first of the countrys electricpower facilities to be privatized. Employment and Unemployment Despitethe relative improvementof the Moroccaneconomy, the grossdomestic product per capita in Moroccois still onlyabout one half the world averageof U.S. $5200 in 1993 (Simonis,1995). The economyis havinga difficulttime outpacingits populationgrowth. This results in relativelyhigh unemploymentrates. Unemploymentis a problem-particularlyamong the growingranks of young adults. The governmentreports an unemploymentrate of 16%in 1993 which is roughlytwice that of most developedcountries (Johnson,1996). Others report higher unemployment rates nearing 20%. The unemploymentrate for young adultsis twicethe generalrate (Simonis,1995). No unemploymentrate data were availablefor the local area:El JadidaProvince and Moulay AbdellahCommune. Agricultureemploys 60% of the activepopulation of the MoulayAbdellah Commune. The largest employerin the area is the OCPphosphates plant which employs3200 persons. The Officed'Exploitation des Ports (ODEP)employs 140 personsfull timebut providestemporary work for about 1000 dock workers(Elhaiba, 1996). The JLPP employs144 persons full time. EIA 4-31 August 1, 1996 RADUAN- INTERNATIONAL The activitiesof the port are discussedmore fully below.The great majorityof the full time personnelat the ODEP, OCP, and JLPP live in El Jadidaand are transportedto their jobs by bus. Importance of Electric Power to the Future of Economic Growth More than 80% of Morocco'srural populationis withoutelectric power. During the late 1980sand early 1990s,electric power supplieswere not sufficientto meet power demands.Ih 1993,demand for electricpower reached 1850MW-20% higherthan available supplies.The lack of availablepower resultedin load shedding,"blackouts" and "brownouts."These curtailmentsresulted in an estimated 1%drop in the gross nationalproduct (World Bank, 1994a and 1994b).The power shortagessignificantly reduced productivity and raised product costs. The cause of the power shortageswas a combinationof reducedhydroelectric output as a result of droughtconditions, increased operating problems at thermalelectric plants, and failure to bring on new powerplants (WorldBank 1994b). In order to keep pace with the growingdemand for power-which will increase much faster thn ov-rall populationand economicgrowth because of the extensionof electric power to rual villages. -NE has initiatedan ambitiouspower expansion plan. Table 4-13 presents the projectedpov~ ~r demandgrowth for the 1993through year 2000 penod (WorldBank, 1994a). The Jorf Lasfar Units I and 2 togetherwith the proposedUnits 3 and 4 play a criticalrole in Morocco'splans to establishadequate supplies. By the year 2000, the four JLPP units will account for one third of Morocco'stotal installed Macity and (as discussed in Section 6) approximatelyhalf of its projectedgeneration of electricity.Clearly, the proposedexpansion of the JLPP is vital to the economyof Morocco. 4.3.4 Commercial Fisheries Commercialfishing is importantto the Moroccaneconomy. In 1991,the Moroccancatch was 600,082tonnes. It has ranged between500,000 and 600,000tonnes since 1986,the first time it exceeded500,000 tonnes. This suggeststhat, overall, some limit of fisheriesproductivity has been reached off Moroccancoasts. In 1986,the Moroccanfishing industryemployed 100,000people (AmericanConsulate General, 1987). No more recent data on fisheries employmentwere found, but, based on the stable annual catch,there is no reason to believe that the number would have risen substantiallysince then. Approximatelythree-quarters of the catch is from coastalfisheries; the rest is from deep sea fisheries. Approximately87% of the coastal EIA 4-32 August 1, 1996 INTERNATIONALMB Table 4-13.Morocco - Power Capacity Balances - MW. (Based on firm capacity) .______ii3 in 4 '95 J 197 1998 1999 A. PeakDemand 1850 1925 2060 2205 2360 2525 2700 2890 B.Existing Hydro 50 50 50 50 50 50 50 50 C.Planned Hydro -MatMaia(240MW) 160 160 160 160 160 160 160 -Alwahda(248 MW) 80 80 80 80 - M'Dez (52MW) 35 35 -ElMenzel (148 MW) 73 -DMEO. (92MW) 65 D.TotalFirm Hydro Capacity 50 210 210 210 290 290 325 463 E.Existing Therb al 1520 1605 1605 1605 1650 1470 1470 1470 F. PlannedThermal -Gas Turbines(200MW) 200 200 200 200 200 200 200 -J.Lasfar(330 MW) 330 330 330 330 330 330 330 - J. Lasfar (330 MW) 330 330 330 330 330 330 - IPPComb. Cycle (350 MW) 125 350 350 - IPPHeavy Fuel (350 MW) 350 350 350 - J. Lasfar m (330 MW) 330 330 -J. LasfarIV (330 MW) 330 330 G. Total ThermalCapacity 1520 2135 2465 2465 2510 2805 3690 3690 HLLess ThermalPlant Outags 360 523 682 682 684 699 743 743 L TotalFirn hermalCapacity 1160 1612 1783 1783 1826 2106 2947 2947 J.Ihpor fromAlgeria 150 150 150 300 300 300 0 0 K CapacityBalance -490 47 83 88 56 171 572 520 L % Reserve -26 2 4 4 2 7 21 18 Sowc: WorldBark. 1994a EIA 4-33 August 1, 1996 INTERNATIONAL productionis pelagic, with sardinesaccounting for almost the entire tonnageof pelagic catch. Sardines represent55% of the total Moroccancatch (InstitutScientifique de PechesMaritimes, 1991). The differentspecies caught have widelydifferent monetary value, however,so that the distributionof the tonnagesdoes not at all correlatewith the contributionof each species to the total economicvalue of the catch. For example,pelagic fish have a low unit value and contribute only 14% of the total value. In 1991,the high seas fisherywas responsiblefor 64% of the total value of the Moroccancatch. Note that almost all the coastalfishery is on the Atlantic side of Morocco. Of the 1991coastal catch, 34% was consumed,36% was processedinto byproducts, 27% was canned,and 3% was frozen. Of four commerciallyvaluable species (sardine, pandora, large-eyed dentex, and rose shrimp),only one (pandora)has a populationconcentration reported within 100km of JLPP. Large crustaceanslike lobstersare present all along the coast, wherethere is extensivebut undocumentedsubsistence fishing by localpeople using lobsterpots and trammels. In Moulay Abdellahthese people are thoughtto numberapproximately 200. Commercia fishingout of the port of Jorf Lasfaronly started in 1990. During the second quarter of 1995, 139tons of fish were landed comparedto 3,830 tons in El Jadida during the same time penod. The port of Jorf Lasfaris thus a verysmall commercialfishing base (Direction Provincialed'El Jadida, 1995). There is no evidencethat the existingpower plant at Jorf Lasfarhas had any impact on fishenes. Considenngthe plannedimprovements in water managementand ash disposal accompanyingthe two proposedunits, all marine biologicalresources should be even better protected in the future. 4.3.5 LandUse and Transportation Land Use-Existing Prior to the 1970s,the area aroundthe current JLPPwas characteized by scattered settlements(clusters of homes) and individualfarms and residences.The land above the bluff has been a major agriculturalarea comprisedof nany smallplots of foragegrasses, grains,and EIA 4-34 August 1, 1996 RADIALN- INTERNATIONALU occasional vegetables. There is some irrigated agriculture south of the power plant where vegetables, such as carrots and tomatoes, are grown. Along the coastal highway south of the plant there are many large greenhouses for hydroponically grown tomatoes. In the 1970s, the Jorf Lasfar area was selected for the site of the OCP phosphates plant. One of the largest of its kind in the world, the OCP plant was constructed on the plain above the escarpment that rises immediately east of the shoreline. The port of Jorf Lasfar was expanded to serve the OCP by shipping in sulfur and other raw materials and exporting phosphate product. The new modem port was opened in the early 1980s and serves other users including the JLPP. Figure 4-4 generally shows the existing land uses. The three large industrial uses are the JLPP, the port, and the OCP phosphates plant. Most of the remaining land use is in agriculture. The residential land uses are the traditional settlements-clusters of stucco houses consisting of extended families. There are no new modem residential developments, such as apartments or subdivisions, to house workers at the three major industries. The workers are mainly from El Jadida and are tasported to work in buses in less than a half hour commute. The land use presents an interesting contrast of the traditonal agrarian economy and lifestyle existing side-by-side with new state-of-the-art industrial facilities. The presence of the industrial activities does not seem to have affected the traditional pattems of land use and activities. In the area depicted in Figure 4-4, the predominant land use is still agriculture including hundreds of individual scattered residences. Industrial land uses are second in areal extent, the third ranking land use is the area that is not in agriculture and is either vacant or used for grazing of sheep or goats. Within the OCP-owned property, much of the land formerly owned by small farmers has been reserved for future growth of the phosphate or related industries. Other "vacant" areas are not suitable for tillage. The quarry, which is described in Section 7, was created by the need for rock to construct the long jetties and piers at the port and at the JLPP. Land Use-Future Figure 4-4 also shows a projection of future land uses. Two marked areas currently not used or in agricultural use are projected to be converted to industrial or heavy commercial uses. The vacant area currently within the OCP property boundary could become occupied with expanded OCP operations or phosphate-related industries. Conceivably, this area could be EIA 4-35 August 1, 1996 INTERNATIONAL LEGEND Incdus1naIcommerca r~Fams (crops) Steens(homes) T Other(grazing or vacant) I 1aFutureODEP indJcomn. L2 Posble OCPindicor.SCIE:ETR Ocef-antC Figure 4-4. Existing and Future Land Use in the Vicinity of the JLPP EIA 4-36 August 1, 1996 RADIANE INTERNATIONALCB occupiedby other chemicalor manufacturingfirms. The secondarea projectedto be convertedto industrialuse is north of the OCP property,east of the port, and west and southwestof the quarry.The ODEP owns, or is acquiring,this land for use as an industrialpark. There are plans for subdividingthis propertyand developingit in phases. Severalnew industrialtenants have alreadybeen identified.Factors attracting the futureindustrial growth are the proximityof the port and the easy accessto expandedelectricity supplies. With the varied industrialand commercialuses plannedfor this area, retail and multifamilyresidential uses mayultimately be developed.It is not possible at this timeto project when or where these will occur.Current land use controlsdiscourage construction worker housingnear this complex(Elhaiba, 1996). Transportation The Jorf Lasfararea is servedby pavedhighways, a large port, and railmad. The nearest commercialairport is in Casablanca. Route 121 is the coastalroad that connectsEl Jadida and Casablancato the north with Safi, Agadir,and Morocco'ssouthem provinces. It is a two-lane highwaywith small segmentsof four lanes in the immediatevicinity of the highwayexchange leadingdown to the port. The railroad,and multipleside tracksand spurs,connects the OCP, JLPP, and port with El Jadida and points inland. The port of Jorf Lasfaris located 110 km southwestof Casablancaand 150 km northeast of Safi. The port was openedto intemationaltrade in 1982 and is currentlyone of the main ports in Morocco.Its prinary cargo is phosphateand its derivedproducts from the OCP phosphate plant. The port infrastructureincludes a cumulativelength of wharf of 1955 m, 2 jetties, a water reservoirof 200 hectares,platforms of 110hectares, 13 piers including9 specializedpiers, warehousesof 6,600mn 2, sulfur warehouseof 150,000in 2, refrigeratedwarehouse of 1,800in 2, and 5 km of railroads. In 1993,the port of Jorf Lasfarhandled 5.6 million tonnes of goods. Most of that (80%) was phosphateand phosphate-derivedproducts. It is expectedto becomethe largest mineralport in Africa. A businessvolume summaryis providedin Table 4-14. EIA 4-37 August 1, 1996 RADUIN-E INTERNATIONALMB Table 4-14. LeadingExports and Imports of the Port of Jorf Lasfar Export1993 in milliontons Import 1993in mlion tons Phosphoric Acid 1.1 Cereal 0.25 Ferdtlizes 1.7 Ammonia 0.46 Phosphate 0.4 Coal 0.34 Sulfur 1.4 4.3.6 Aestheticsand ProtectedNatural Areas The west coast of Morocco south of El Jadidaoffers many scenic vistas. The land-water interfaceoffers a varietyof landscapesranging from long stretchesof white sandybeaches to ruggedcliffs and rocky shorelines.Inland are gentlerocky hillsideswith picturesquevillages seeminglyunchanged from the 19thcentury. The aestheticresources are valuablein their own right but also offerthe prospectsof increasedtourism with revenuesand job opportunitiesfor underemployedlocal unskilled labor. Accordingto the Provincal Departmentof Tourism(DTP), toursm is a major economicboon to the area Thereare more than 40,000 tourist visits a year to more than 1000hotel rooms and restaurants(Elhaiba, 1996). The Jorf Lasfararea with its vertical cliffs, windswepthillsides, and pastoralscenes still retamsmuch of the originalscenic value that it held prior to the developmentof the port, the OCP plant, and the JLPP. This is particularlytrue to those who view the southwestfacing verticalcliffs from the escarpmentabove the port The actualport and most of the JLPP facilities are not visible from distancesbeyond the escarpment.The JLPP stack does protrudeabove the escarpment.However, even the stack is not vis. e for more than a few kilometerson either side of the plant entrancefrom Route 121,the coasta nighway.Photographs of the area are shown in AppendixE. The most visuallyintrusive elements to the currentlandscape are (1) the large tanmsmissiontowers leadingeast from the plant acrossthe coast highway and (2) the OCP facility with its complex of storagetanks, port-to-plantconduits and pipe racks, processingfacilities, and many stacks emittingvisible white discharges.(The emissionsfrom the JLPP stack were only barely visible during site visits in April 1996).The OCP facilitiesare more visuallyintrusive, in part, becausethey are built on the high groundabove the escarpment,whereas the JLPP and port are screenedfrom view by the terrain. EIA 4-38 August 1, 1996 RADIAN INTERNATIONALM The blue waters of the Atlantic Ocean are part of the scenic resource in the immediate vicinity. The discharges from the OCP outfall create a clearly visible brown plume in the water at the outfall just south of the JLPP cooling water discharge outlet. There are no visible discharges in the water from JLPP. There are no "wildlands", natural areas, public park, or other protected areas in the vicinity of the JLPP. The nearest public park of any kind is a beach recreational area in Sidi Bouzid, 21 km north of the JLPP (Elhaiba, 1996). EIA 4-39 August 1, 1996 I RADL^N- INTERNATIONALM 5.0 AUDIT OF EXISTINGCONDITIONS The purposeof this section is to identifyenvironmental conditions associated with the existingJLPP basedlargely on PhaseI and PhaseI environmentalassessments (EA) conducted by Radian Intemational(Radian) in 1995. Additionalinformation is providedfrom operational assessmentsby the ProjectSponsors, and from subsequentRadian plant visits and information providedby JLPP staff. The PhaseI EA includedthe followingtasks: a surveyof the projectsite; preliminary evaluationof potentialsources of soil, water,and air contamination;and a preliminaryreview of the relevantMoroccan envinmental regulationsapplicable to the site (ABBProject, 1996).The Phase1 EA includedthe followingtasks: a review of the draft WB Guidelines;a reviewof the Ex-In Bank Guidelines;research of the Moroccoenvironmental regulations and permitting process;and an examinationof the JLPP wastewaterdischarge, thermal discharge analysis, and atmosphericemissions compliance analysis (Radian, 1995). The followingis a discussionof potentialissues related to ambientair quality, water discharges,the handlingof hazardousmaterials, soil and groundwatercontamination, and ocean ash disposal. 5.1 Air Quality In the Phase II EA, Radian reviewed the emissions from ILPP to determine compliance with World Bank guidelines based on preliminary atmospheric emissions data from a performance guarantee test for Units 1 and 2 conducted by GEC Alsthom. The performance test included an evaluation of gaseous emissions at various boiler operating loads, burner and dampers settings with and without overfire air. NO1 , CO, and PM were measured and analyzed. S02 emissions were not measured; the SO2emissions were calculated using the sulfur content of the coal. 3LPP Units I and 2 comply with the 1988 World Bank, OPIC, and Ex-In emission limits of these three pollutants (see Table 3-3). However, there are insufficient ambient air quality monitonng data to determine whether the ambient guidelines are achieved. Ambient monitoring data were collected for seven weeks prior to the construction of the JLPP Units 1 and 2. These EIA 5-1 August 1, 1996 RZADL^N-E INTERNATIONALM preliminary data indicate that the OCP facility located northeast of the JLPP may be the source of occasional significant short-term SO2 concentrations in the area. These preliminary data indicated that SO2 ambient levels, prior to construction of Units I and 2, may be above Project guidelines. To address this concern, the Project Sponsors contracted with Radian to conduct one year of ambient monitoring at the JLPP. Data from the first several weeks of this monitonng are used in this EIA for the air quality analyses in Sections 4 and 6. 5.2 WaterDischarges The JLPP discharges three types of aqueous streams: process wastewater, thermal discharges, and storm water runoff. As a result of the findings described below, the Project Sponsors will install wastewater treatment processes that will meet Project guidelines. The specific details of the types and number of wastewater treatment systems have not been determined at this time. During the Phase II investigation, a total of 12 samples were collected from wastewater discharge sampling points and near the cooling water intakes to determine the background ocean water quality. The samples were tested for their pH, temperare, conductivity, and ambient temperature. The samples were then combined to form a composite sample. The composite samples as well as background samples were analyzed for TPH, oils and grease, heavy metals, total organics, dissolved oxygen, total suspended solids, redox potential, and five-day biological oxygen demand. A 24-hour monitoring of wastewater quality indicated that there were two exceedances of the pH guidelines from the north outfall. The cause of these pH fluctuations is unknown. With the exception of a single TSS value, the sample results for the other parameters as stated above complied with the Project guidelines (Radian, 1995). During the Phase II EA, the ambient temperature and the water temperature were measured at the plant intake, the discharge point for condenser Units 1 and 2, and the point of channel discharge into the ocean. The data indicated a 9°C increase between intake and discharge to the ocean. Thermal modeling was conducted to see if the thermal discharges exceeded Project guidelines. These guidelines specify the net temperature increase must not exceed 5' C at the edge of the mixing zone, for seawater under 28°C. Note that no seawater ELIA 5-2 August 1, 1996 RADIAN INTERNATIONAL3 temperatures above 250C are expected in the area. The modeled increases ranged from 0.9° to 1.30 C, well withinthe guidelines. In addition,chlorine levels in condensercooling waters currentlybeing dischargedfrom the JLPP facilitymeet Projectguidelines of 0.2 mg/l (Radian, 1995). The third type of aqueousdischarge is storm waterrunoff. Stormwater runoff from the coal pile area is routed to a runoff basin, from which it is dischargeddirectly into the Atlantic Ocean. Stormwater runofffrom other areassurrounding the plant is routedto the two 36-inch concretedischarge pipes and is dischargedwithout further treatment to the AtlanticOcean via an open channel. Plans to improvethe controlof coal storagerunoff and potentialoil spillsfrom plant equipmentat all units of the JLPP facilityare in progressand will protectagainst an exceedance of Project guidelinesfor total suspendedsolids and oils and grease. 5.3 Hazardous Materials Hazardousmaterials handled at a typicalcoal fired powerplant includePCBs, asbestos, fuel oil, and bulk chemicals.However, the Phase I EA indicatesthat the existingplant is free of PCBs and the insulationof the facility is determinedto be free of asbestos(ABB Project, 1996). A diesel-poweredemergency power generator is used to allowan orderlyshutdown of the plant in case of a blackout Currentlythe plant has one storagetank with a capacityof 500 rn3 to storethe diesel fuel for this emergencygenerator. JLPP also has two reservoirscontaining 50,000 m3 of fuel oil used for flame stabilization and start-up of the two existing units, and one 3 reservoircontaining 25 m of propane. The JLPP has a garage and petrol station for maintaining the facilityvehicles (CMS,1996). Used oil is storedin drums and returnedto the fuel oil storagetanks for reuse or sold to local companiesfor recyclingor other uses. In the event of an oil spill,the employeesuse sand and rags as an absorbent,both of whichare disposedof in normaltrash removal. No formal notificationis performedwhen any type of spill occurs. The plant indicatedthat they had no spills last year (1995),other than fuel oil spillagenext to the fuel oil dischargestation (CMS, 1996). EIA 5-3 August 1, 1996 INTERNATIONALM During the Phase I EA, underground storage tanks were found to be constructed with adequate leak detection and containment measures and above ground storage tanks had adequate leak containment systems. However, the investigation showed that past practice in unloading fuel oil tank cars has resulted in spillage and shallow hydrocarbon contamination of subsurface soil in the oil unloading area. Adjacent to the demineralizer building there are two rooms, one for resin storage and the other for ammonia and hydrazine. Currently the resins, empty hydrazine and sodium hypochlorite (NaOCl) drums are stored in one room, and full hydrazine and NaOCl drums are stored in the other. There is no required manifesting or documentation. Labeling of containers is accomplished, but not extensively (CMS, 1996). 5.4 Soil and Groundwater The Phase II analysis of the soil (based on six soil borings and piezometer sampling) indicatedthat the concentrations of metals varied significantly. No comparative background soil heavy metals data are available. However, the variation in the data suggests that the heavy metals concentrations are probably not the result of plant operations. Low levels of total petroleum hydrocarbons were found in soil in the fuel oil handling and storage area This was attributed to improper fuel oil handling and surface oil spills that were noted during investigation. During groundwater analysis, the water levels in the piezometers were recorded at different times to assess the interaction between the groundwater and -ie ocean tides. The results showed a strong interaction between the groundwater and ocean water surface elevations. Groundwater was detected at a depth of approximately six meters. Also, the metal concentrations detected in the groundwater are believed to be related to the regional content of metals in the subsurface soil rather than plant activities. Groundwater, which is encountered 6 m below the surface was found to contain oils and grease at levels above the World Bank discharge limits. No direct relationship between existing JLPP operaions and these oil and grease levels were determined. 5.5 AshDisposal Currently, ash is disposed of in the ocean. Both bottom ash and fly ash are sluiced through pipes to a point about 800 m from the shoreline where the ocean depth is 13 m. On EIA 5-4 August 1, 1996 RADIAN- INTERNATIONALMB occasions, there are bottom ash discharge pipe pluggage problems. On these occasions, the plant disposes of the ash by trucking it to a disposal site located south of the plant adjacent to the discharge channel. This temporary disposal site is not large enough for long term ash disposal (CMS, 1996). Analysis demonstrates that total metal concentrations at the ash discharge point are well below Project guidelines for water quality. However, as discussed in Section 4, elevated levels of mercury were measured in the vicinity of the OCP and ash outfalls. Nevertheless, World Bank recommendations are that ash disposal should be in landfills or in lined disposal cells (World Bank, 1996). The Project Sponsors intend to terminate ocean disposal as soon as an appropnate alternative can be implemented. An analysis of these options is presented in Section 7. 5.6 Summary As depicted in Figure 5-1, the environmental conditions that were identified during past audits at the existing JLPP were: Shallow soil contamination from fuel oil spills primarily at the tank car unloading area; Lack of sufficient ambient air quality data to confinm data collected by ONE that indicate occasional, short-term, high background ambient SO2 concentrations (from the diretion of the neighboring phosphate plant); Occasional excursions of pH in wastewater discharges and inadequate treatment of storm wat runoff; Disposal of fly ash and bottom ash in the ocean; and Hazardous chemicals handling, storage and tracking. The Project Sponsors are addressing each of these concerns as documented in Section 6, 7, and 8. EIA 5-5 August 1, 1996 -4 ri DisposalOenAsh . ; ;4' X~~~~~~~~~~~Wsewt _ | gS-ToAadr\ II1etr Figure 5-1. issues and ExistingEnvironmental Conditlons at JLPP INTERNATIONALES 6.0 POTENTIALFUTURE IMPACTSOF PROPOSED EXPANSION This sectiondescribes the impactsof constructingUnits 3 and 4 at the JLPP and the incrementalimpacts of operatingall four units. 6.1 Impactsof Construction This sectionexamines the potentialimpacts from construction of Units 3 and 4 at the 3LPP. The constructionof the unitsmay impactland, soil,air, surfacewater, groundwater, socioeconomic,noise level, archeologicalor historicalresources. The potentialimpacts are addressedbelow. 6.1.1 Land and Soil The land for Units3 and 4 is alreadygraded and clearedof vegetation. The construction site is an industrialarea withhigh humlanactivity and containsno wetlandsor sensitive environmentalhabitats. No new propertyor roads will be purchasedor built as part of the conuction activities. Therefore,the constructionactivities will have little or no impacton the land resources. 6.1.2 Air Quality During constructionactivities, unavoidable air pollutantemissions are likely to occur. The most prevalentconstruction emissions are fugitivedust Construction-phasefugitive dust emiissionswill be generatedduring excavation and vehicularactivity. Shouldthe projectrequire an onsiteconcrete batch plant, this plant could also constitutea sourceof fugitivedust The quantitiesof fugitivedust emittedby the site constructionvehicular traffic dependson a numberof factors,including the frequencyof operations,specific operations being conducted,weather, and soil conditions. A large portionof the constructionoperations, such as foundationexcavation, will be intermittentand of a temporarynature. Standardconstruction practices used to controldust, such as wet suppression and control of vehicularspeed, will help rminmize the air qualityimpact of construction actvities. It is anticipatedthat total gaseousemissions released into the atmosphereduring constructionwill be small. Potentialsources of VOC emissionsare evaporativelosses associated EIA 6-1 August 1, 1996 RORALN- INTERNATIONALM withonsite painting,refueling of constructionequipment, and the applicationof adhesivesand waterproofingchemicals. The frequencyand extent of these activitiesare anticipatedto be limitedand wouldhave minimalimpact on air quality. Use of the constructionequipment will result in temporary,short-term emissions of VOC, NO1, PM, and SO2. Thesepollutants will be presentin the exhaust. The exhaustemissions will be similar in nature and extent to those from vehicleson the nearby highway. Therefore,there should be no impactfrom constructionequipment exhaust emissions. Open bumingof constructiondebris is expectedto occur if allowedby local authorities and if the compositionof that debris consistsof wood productsand other relativelyclean-burning components. Pollutantemissions of PM, CO, hydrocarbons,and NO, will depend on the amount and moisturecontent of the debris. Only minor, short-termair qualityimpacts are expectedto result from open buring since these operationswill be intermittent. Overall,the impact of heavyconstruction activities and site preparationon air qualitywill be short-termand confinedto the immediatevicinity of the constructionactivity. This is because most of the fugitivedust createdby constructiontraffic and aMth-movingoperations consist of particulates(total suspendedparticulates), which tend to settle quickly ratherthan remaining suspendedfor long distances.In summary,it is not expectedthat vehicularemissions, fugitive dust, or smoke from open-bumingoperations will presentany significantair qualityproblems dunringthe constructionperiod. 6.1.3 Surface Water The only surfacewater body that may be affectedby the constructionat JLPP is the Atlantic Ocean. Constructionactivities may increasethe suspendedsediment load of storm water runoff from the site. Oil and greasefrom constructionequipment may be leaked or spilled on the ground,potentially contaminating storm water runoff. The constructioncontractor will implementgood housekeepingpractices to minimizethe potentialfor such construction-relatedimpacts on storm water nmoff. These practicesinclude prompt disposal of trash and constructionmaterials, collection of refuse and oily rags, and prompt cleanup of spills of flammableliquids. Site drainagewill be designedto prevent the creationof muddyor pooled water areas. If observationof storm water runoff from the EIA 6-2 August 1,1996 R^DIAN INTERNATIONALM construction site reveals offsite discharge of sediment-contaminated storimwater,additional control measures may be employed. 6.1.4 Groundwater There is a slight potential for oil spills or leaks to reach groundwater, especially during excavation for the construction of Units 3 and 4. Groundwater movement and quality during construction can be monitored at observation wells onsite to detect contamination. Also, seepage of surface water in deep and shallow excavations may impact the aquiferous zone which is 6 m below ground level. Dewatering practices during excavation can be implemented to prevent potential cross-media groundwater contamination. 6.1.5 Biological Resources No construction-related impact to biological resources to the land are expected. The construction site for Units 3 and 4 is a graded, industrial area that is already highly impacted by human activity. The construction site is not habitat for flora, fauna, wildlife and other biological resources. Very little terestial wildlife was observed in the immediate vicinity of the JLPP during the field trip in April 1996. None was seen on the JLPP property, also, no endangered or threatened species were observed or are believed to be present at the JLPP. Little or no impact to biological resources in the marine environment are expected from the construction of two more units at the existing JLPP facility. No constrcion will occur over water. 6.1.6 Archeologicaland Historical Resourcesfrom Construction No impact to archeological and historical resources will occur because all construction will occur in areas that have been previously disturbed by the construction of Units 1 and 2. As identified in Section 4.3.1, the nearest archeological site is 8 lkmnorth of the JLPP. EIA 6-3 August 1, 1996 RADAUN INTERNATIONALM3 6.1.7 Socioeconomic Impacts from Construction The constructionof JLPP Units 3 and 4 will have a positive social and economicimpact locally and in other parts of the world. Moreover,there will be no significantadverse impactsas a result of demandson local housingand other infrastructureand services. The constructioncontractor anticipates that at least 700 persons will be hired during peak constructionwith an averageof 500 personsduring the 39-monthperiod of construction. Approximately47% of the constructionworkers wilI be classifiedas unskilled (ABB, 1996b). Many of these workerswill be drawnfrom the many small settlementsaround the JLPP. Others will be hired from El Jadidaand otherMoroccan cities. It is likely that many of these unskilled workers will come from the ranks of the unemployedor underemployed.Many of the skilled workers will also be Moroccans,although the numberof in-countryversus foreign workershas not yet been determined. Althoughtemporary, this constructionactivity will create a stimulusfor local and regionalincomes. Another economicbenefit of the constructionwill be the estimated $43 million (U.S.) that will be spent to purchaseother Moroccangoods and services. Most of the heavyequipment for the power plants, such as generatorsand turbines,will be purchasedfrom Europe and the U.S. Capital equipmentpurchases will be from the U.S., Italy, and Switzerland(ABB, 1996a). The JLPP Sponsorswill purchaselocal constructionmaterial such as concretewhenever it can be procured. Thus, the constructionwill createjobs and economicgrowth both in Morocco and intemationally. Frequently,large capital projectsin rual areas createadverse socioeconomic impacts as a result of sudden and large demandsfor housingand other services. This 'boom" effect is then followed by a "bust" as the constructionworkers and their familiesmove on to other projects . The constructionof Units 1 and 2 in the early 1990sdid not createthis boom and bust effect for two reasons. First, a large numberof rualMoroccans are unemployedor underemployed. Tberefore,there was no need to bring in non-localunskilled workers.Second, the City of El Jadida had adequatetemporary housing availability for the remainingworkers who commutedto the work site each day by bus. The bus servicewas arrangedby the constructioncontractor. The contractorfor Units 3 and 4 has indicatedthat they anticipatea similarpater for the future construction:unskilled workers hired from the immediatearea and temporaryhousing in EIA 6-4 August 1, 1996 RADUIN- INTERNATIONALE[ El Jadidafor the skilled and unskilledworkers who do not live in this part of Morocco (ABB, 1996b). No "tent cities" or other offsitetemporary housing is necessaryand none is planned. Becausethe workerswill either walk to the site or will be bused in by the contractor,there should be no traffic congestionor parkingproblems often associatedwith large constructionprojects. 6.1.8 Noise Impactsfrom Construction Construction-relatednoise impactswill occur largelyin three phases:foundation preparationand pouring, steel erectionand equipmentinstallation, and site cleanupand plant start up. Typicalnoise levels at 15 m for constructionequipment from the first two phases are as follows: Table 6-1. Typical NoiseImpact DuringConstruction I:-aximumNoisel-evel Eq-ipment At15--m (dBA) Concretepouring trucks 87 Cranes 86 Air compressors 89 Excavationequipment 90 Welders 73 Diesellocomotives 97 Dump trucks 87 These noiseswill not adverselyimpact the nearestsensitive off-property receptors-the residentialareas on top of the bluff east of the JLPP.This is becausethe distanceto the nearest off-propertyresidential areas is great enoughto attenuatethese sounds. Also, almost all of the residencesare behind the edge of the bluff and thereforeshielded by the tenrainfrom the sound pattems. This shieldingshould reduceconstruction related noises to levelsthat are typicalof residentialareas. In summary,construction-related noises will be temporaryand intermittent. Moreover, the great majorityof the homes in the nearestresidential areas are shieldedby the crest of the bluff from the ground-levelnoises at the powerplant and thereforewill be even less affected by constructionnoise. EIA 6-5 August 1, 1996 INTERNATIONALES 62 Impactsof Operation This section describesthe incrementalimpacts that are anticipatedfrom the operationof all four units at the JLPP. 6.2.1 Land Use and Transportation The operationof Units I through4 at the JLPP will have a negligibleimpact on existing land use. The constructionof the new units will not require the purchaseor use of land outside of the JLPP propertyboundaries. All constructionand operationwill be on land that has been previouslydisturbed and convertedto heavyindustrial land use. Becauseof local land use controls aroundthe industrialarea, there will be no inducedor secondarydevelopment such as housingtrcts for new workers,restaurmts and grocerystores, or after-workrecreational and leisure retail elishments (Elhaiba,1996). Developmentof a landfill for disposal of fly ash and bottom ash will require some off-sitedevelopment as discussedbelow and in Section 7 of this reporL No new conversionof non-industrialland uses to industrialuses is anticipated. Instead,the indirect effectson land use will be almost entirelyfocused on the already developedEl Jadida urban area Workerresidences and servicesfor workersfor the existing JLPP are confinedto El Jadida. Therefore,it is presumedthat this new increment of activity will also be confinedto El Jadida. The residential,commercial, and urban infastuctural developmentof El Jadida is matureand large. The incrementalimpact of the lLPP expansionon this developmentwill be relativelysmall (Elhaiba,1996). If the quarry area is used for ash disposal,the ultimatelong term effect would be to convert this currentlyunusable site to industrialuse. As the quarry is filled and sections reclaimed,it could become availablefor productiveuse. Altematively,this area at the reclaimed quarry site could potentiallybe used for agriculturaluse. The proposed Project willnot adverselyaffect transportation. The planned ransport of JLPP workersusing buses shouldavoid any significantincrease in traffic congestion along the El Jadida to JLPP stretch of Route 121. Increasedcoal use will result in greaternumber of coal shipmentsthrough the port. The masterplan for Port operationsprovides for coal shipmentsfor up to six units at the JLPP. Cunrently,the coal dock is being expandedby ODEP under contract to ONE. The dock expansionand the current under-uilizationof port capacityindicates that the incrementalincrease in coal shipmentswill not createship congestionin the port. EIA 6-6 August 1,1996 R^ADIANE INTERNATIONAL1M Truck tasport of ash to the quarry, or other land disposal area, could create the potential for increased highway congestion. However, rail transport, which would require construction of new track, would use grade-separated crossings as necessary to avoid interference with highway traffic. If truck transport of coal ash is used-either for land disposal or to market the ash as a construction material-appropriate traffic signals and other controls may be necessary to avoid highway congestion and accidents. 6.2.2 Air Quality This section describes future air quality impacts of the four-unit, JLPP operation on the surrounding environment. Emissions of sulfur dioxide, nitrogen oxides, and particulate matter from the project are expected to increase as compared to current levels as shown in Table 6-2. A description of the emission estimation procedures for each investigated pollutant is provided in Appendix F. This section also compares future ambient air concentrations, as calculated through a very conservative dispersion modeling analysis, with the applicable Project guidelines. The modeling results indicate that the impact of the increased emissions will not significantly impact air quality near the JLPP operations. Table 6-2. JLPP Maximum Stack Emissions --Esdm tedCurrent - MaximumPotential a Potet M-.ifunumEmbisons.c I Eniionsfrom infom Units Ir*n-- -toms1nd2 UziIsl.aud2 -- |- i4tgh rolutant I (tonnlda)_ j (Om iday3 tonLa SulfurDioxide 79.2' 158.42 271.23 NitrogenOxide 34-' 35.15 70.66 Parficulate 1 1.47 5.9 8.49 '- Based on 0.75%S coal (0.12 tonnelMW-day)and 100%capacity factor. 2- Based on 1.5% S coal (0.24 tonne/MW-day)and 100%capacity factor. 3- Based on 1.25%S coal (0.20 tonnelMW-day)on all 4 units. 4- Based on tested emissionsof 256 ng/J,beat ratmesof 2065 kcallWi, and 100%capacity factor. - Based on eniissionsof 260 ng(0,heat rates of 2065 kcal/kWh,and 100%capacity factor. _Based- on predictedemissions of 260 ngfJ,beat rates of 2065 kcaltkWhfor Units I and 2 and 2080 kcal/kWhfor Units 3 and 4, and 100%capacity factor. 7- Based on tested emissionsof 30 mg/Nm3, 100%capacity factor. --Based on ESP guaranteeof 125mglNm3, 100% capacity factor. Calculations located in AppendixF. 9- Based on emissionsof 125 mg/Nm3 on Units I and 2 and 50 mg/Nm3 on Units 3 and 4 and 100% capacityfactor on all 4 units. EIA 6-7 August 1, 1996 RDIAN- INTERNATIONALES Emission Estimation The units that comprise the Jorf Lasfarpower plant are designedto fire a medium volatile,low sulfur, high ash bitumiinouscoal. Since becomingoperational in 1994,the plant has fired coal from the United States,South Africa, and Colombia. Radian has studiedthe impactthat representativecoals from these sources may have on emissionsfrom the Jorf Lasfarplant. Data for this studywas based on historic coal use, anticipatedfuture coal sources,plant operationalexperience, and emnissionstests performedat Jorf Lasfar. The currentPM and NO. emissionsfrom Units 1 and 2 were measured during performancetestng conductedby GEC Alsthom in 1995and are presented in Table 6-3. As shown each of the tested pollutantemission rates are below the Project guidelinevalues. The S02 emissionrate was calculatedbased on fuel sulfur analysis. Table 6-3. JLPP Units I and 2 - Emission Performance Test Results - PolV-utant ft0 Emif,ioa,. Parilate later (PM) 30 mglNm3 NO,(full load) 0.53Ib0IM Btu NO, (minmumload) 0.59 lbMMBtu ParticulateMatter Units 1 and 2-Currently particulatematter emissions from Units 1 and 2 are controlledby electrostaticprecipitators guarateed to meet an emissionrate of 125 mg/Nm3. Each ESP handles half the boilerflue gas flow and has tbree fields. The ESP manufacturer'sperformance correction curves were used to adjust the collection efficiencyfor specificcoals in terms of flue gas flow,moisture, inlet dust loading,and fuel sulfur. Table 6-4 shows the predictedESP collectionefficiency and particulateemissions for variousrepresentative coals that have been fired at the plant. EIA 6-8 August 1, 1996 RADXAN INTERNATIONALa Table 6-4. Predicted Unit 1 and 2 PM Emissions and ESPPerformance |______COa Soub Performance | South ' South -Prameter j Tests' j US. U.S. Africa Africa _-Colombia Sulfur (Wt %) 1.19 0.71 1.4 0.46 0.67 0.62 Ash (Wt %) 8.36 7.50 7.82 12.80 11.60 6.00 ESP Efficiency, % 98.57 99.11 98.74 98.67 98.39 PM Emissions 30.0 94.5 60.3 140.8 134.5 80.9 (mgNm3 ) - , Coal fired duringCiEC Alstbom 1995 petformance esingof Units 1 and2 "Datareceived from ABB (1996a). As shown in the table, actual tested emissions were below the Project guideline of 50 mg/Nm3 and well below the ESP guaranteeof 125 mg/Nm3. However, based on predicted ESP pnerformance,potential PM emissions could vary greatly, depending on the ash and sulfur content of the coal (sulfur reduces ash resistivity and improves collector performance). Although the test data would indicate that PM emissions will be substantially below the ESP guarantee, the Project Sponsors cannot assure performance such as that observed during the emissions test throughout the range of coals burned or the life of the equipment. Therefore, the Project guideline adopted for PM emissions for Units 1 and 2 is 125 mgNm3 . As shown later in this section, the air quality impact which would result from adopting this guideline is negligible. Potential alternative measures that could be utilized in the unlikely event that future testing shows the 125 mgfNm3 guideline cannot be consistently met while buming representative coals are discussed in Section 7. .Units 3 and 4-Units 3 and 4 have a slightly greater capacity (348 MW) and a higher heat rate (2,080 kcal/kWh) than Units 1 and 2. However they will also be equipped with more efficient ESP's with guaranteed outlet emissions that are less than 50 mg/Nm3 , even with one field out of service. EIA 6-9 August 1,1996 RADIAM INTERNATIONALIM SO2 Emissions SO2 emissionsare primarilya functionof the fuel sulfur con nt and quantityof coal consumed. The analysisused to predictSO 2 emissionsfrom the plant was based on the assumptionthat all of the fuel sulfur is convertedto S02. The SO2 emissioncalculations are based on an annual averagesulfur content of 1.25%,which correspondsto the Project guideline of 0.20 tonne/day-MW. NOxEmissions Emissions of NO. are a functionof fuel nitrogencontent, fumace cleanliness(slagging), furnace size, burner design,excess 02, pulverizerperformance, and pulverizer selection. Tangentiallyfired boilerstypically have the lowest emissionsof large electricutility boilers. Firing differentcoals in a boiler maycause NO, emissionsto increaseor decrease. This is not necessarilydue to a differentconstituent analysis, but more likelydue to the physicalproperties such as grindabilityand ash fusion temperaturewhich affect the fineness of the grind and the furace cleanliness,respectively. A finelyground coal could improvefuel/air mixing while a low ash fusion temperaturecoal may result in greateraccumulations of slag on the furnace walls, inhibitingfurnace heat transferand raising flame temperatures.Each of these instancesmay cause NO. to increase. For JLPP, the excess 02 and selectionof activeburner levels will have the greatest impact on NO,. NO, emissionswere measuredduring performancetesting conducted by GEC Alsthom in 1995 (Table 6-3). The results indicatethat NO. emissionsat full load are 12%lower than the Project guidelinesand NOxemissions at minimumload are 1.7%lower than the Project guidelines. MaximumNO. was producedat minimumload, a characteristicof tangentiallyfired boilers. The normal load profile of the plant will be for the units to be operatednear mxu rated output for 24 hours per day. ThIusthe daily emissionswould be expectedto be weighted closer to the full load NO. emissionslevel. NO, might be expectedto vary ±10%from the reporteddata due to operationaland fuel variations. Of particularnote is the location of the activeburners. The boiler is equipped with five levels of burners but only four levels are required(or used)to achievenornal full load. Plant operatingpersonnel prefer to fire the lower four levels, but in practicethis may not always be so. Experience at similarplants shows that NO, can be reducedwhen fuel is biased to lower bumer levels; however,the use of upper bumer levelsusually does not significantlyincrease NO. EIA 6-10 August 1, 1996 RADIAN- INTERNATIONALEL in tangential furnaces since the burner tilts would be somewhat more negative in this configurationto control excessivesteam temperature.This will help to minimiizeany NO. increase. The testing was performed with the lower level of bumers out of service and should represent the highest NO. emissions of any of the possible burner level configurations. The test results were obtained with the use of some over fire air, which is an effective NO, control technique. Radian estimates based on past experience, that NO, reduction of 20 - 30% would be possible using proven techniques of combustion modifications of existing controls and hardware if additional NO, reduction were to become necessary at some time in the future. Units 3 and 4 are will retain a tangentially fired burner arrangement. NO, emission from these units are guaranteed to meet project emission guidelines. Ambient Air Quality Dispersion Modeling Analysis Using the above emission estimations as input, an air quality dispersion modeling analysis was conducted to assess the potential incremental impact of all four units operating at the JLPP. Because of limited data, the modeling analysis was designed to produce the most conservative assessment of the potential impact possible. The analysis consisted of: calculating representative emission rates based on annual usage; determming an appropriate dispersion model; developing an appropriate receptor grid for the region; and defining a representative meteorlogical data set. The modeled emission rates and stack parameters are tabulated below (Table 6-5). The emissions modeled were incremental increases in Unit I and 2 emissions over current levels and the maximum of the pollutant-specific Project emissions guideline values for Units 3 and 4. EIA 6-11 August 1, 1996 INTERNATIONALMB Table 6-5. Jorf Lasfar Modeled Source Parameters ModeledEmission Rates ModeledStack Paraneters ; : : ~~~~ ~ ~~~~~~~~ExitEDit Esit l _ _: So2 NO2 PM Height Temperature Velocty Diameter Sourcea (tonne/dav) (tonneday) (In) (K) . (ms) (m) UnitIand 2 52.8 T 0 6. b [E 45-5 130 403 33 5.6 Unit3 and4 | 1391 | 36.1e f 2.4f | 130 403 1 33 5.6 'Bsed on fiing .25 wt %W coaland a capcityfactor of 100%.Units I and 2 emissionsare incremental inceas from cunentlevels based on Sring0.75 wt %S coaL b Basedon incrmental creasefrom tested (Units I and2) emmssionsof 0.59 Ib/MM Bt vs Projectguideline of 0.60lb/MM Btu. c Based on the incrementalince betweentested (Units I and 2) emssions of 30 mgJNm3 and ESP performance 3 gaantee of 125 mg/Nm . 'Based on Units 3 and 4 at 0.20 tonnelMW-day(1.25% S coal) and 100%capacity factor. 'eBased on Units 3 and 4 at 0.60 Ibs/MMBtu and 100%capacity factor. 'tBased on Units 3 and 4 at 50 mgNm 3 nd at 100% capacity factor. The emissionrates were modeledusing the U.S. EPA-approvedIndustial Source Complex Short-Term(ISCST3 version dated 96113) model. The ISCST3model is a steady-state Gaussianplume model designedto calculateground-level concentrations in simple, intermediate, and complex-terrainfor both short- and long-termaveraging periods. All U.S. EPA regulatory defaultparameters were invokedin the model selectionsand rural dispersioncoefficients were used. A receptor grid was developedfor the Jorf Lasfararea A polar ring of receptorswas centered on the existingUnits 1 and 2 stack extendingoutward to a distance of 15 lam. Within this radius, the terrain variesfrom sea level to about 80 m above sea level. Because of the variable tenain, elevationswere determined for each receptorlocation. The nearby receptor grid (0-5lkn) with terrain contoursis depictedin Figure 6-1. The ISCST3model requires sequential,hourly-aveage representative meteorological data to calculate concentrations at each receptor location. The hourly data needed include wind speed and flow vector (directiontoward which wind is blowing),atmospheric stability, ambient temnperature,and mixing height. There is little routine meteorologicaldata readilyavailable from the El Jadida/JorfLasfar area to support dispersionmodeling. EIA 6-12 August 1,1996 RABL^N- INTERNATIONALM3 JLPP Air Quality Receptor Grid -5000 -4000 -3000 -2000 -1000 0 1000 2000 3000 4000 5000 5000 j 5000 4000 -I4000 3000 3000 2000 v _ 2000 1000 _000 0 -1000 10 -2000 20 -3000 . -3000 -4000 -- 5 -4000 -5000 -5000 -5000 -4000 -3000 -2000 -1000 0 1000 2000 3000 4000 5000 Meters I NTERNATIONAM Figure 6-1. JaorLasfar Area Receptor Gridwith TerrainContours EIA 6-13 August 1, 1996 RADIAMN INTERNATIONALm As descrbed in Section4.1.3, meteorologicalparameters (wind speed and direction)were measuredin support of the ONE ambientmonitoring program. The data were obtainedduring the seven week samplingperiod from February 15, 1994 throughMarch 30, 1994. A windroseof the data obtained for the periodis shown in Figure 6-2. The relative frequencyof direction comparesfavorably with the winterperiod windroseobtained at the El Jadida site (Figure4-1). The averagewind speedfor the seven weekperiod was about 4 m/s. Because some data gaps werefound in the meteorologicalrecord, missing data periods were consideredinvalid and discarded. There was no attemptto interpolateor fill missing wind speed or wind directiondata. A total of nearly700 sequentialhours of data were used in the modelinganalysis to dete$minedifferent averaging period concentations (24-hourand period). The hourly atmosphericstability classifications were determinedbased on the U.S. EPA sigma-thetacriteria. The sigma-thetamethod identifies an initial stabilityclass (1-6) depending on the variabilityof the winddirection during the previoushour and the time of day (dayor night). The initial class is refinedaccording to the hourly wind speed. Sigma-theta measurements(a surrogatemeasurement for the degree of lateral dispersion)were not taken during the 7 week monitoringperiod, hence only the wind speed and time of day criteria were used to developthe stabilityclassifications. All nighttimestabilities were set to neutral (4) and daytime stabilitieswere set accordingto wind speed (windsless than 3 m/s were set to stability 1, winds between3 and 4 m/s were set to stability2, windsbetween 4 and 6 m/s were set to stability 3, and winds greaterthan 6 m/s were set to stability4). No stabilityclass was allowedto vary by more than 1 classificationper hour and the hours of sunriseand sunset were set to neutral stability in accordancewith U.S. EPA criteria The stabilityclassifications modeled should yield a conservativeassessment of potentialair qualityconcentrations. Because of the seasidelocation of the power plant, there is potentialfor funmigation(penetration of air from the ocean on shore). However, the rather persistentwinds from land towardwater will minimizepotential fuimigation, therefore,no attemptswere made to quantifyfumigation impacts. No ambient temperaturesor mixing heightswere availablefor the seven week data period; therefore,conservative surrogates were used. Becausethe stack exhaust temperaturesare well above ambient temperatures,hourly averagetemperaure data is not an important modeling criterion. Further, to ensure that no interactionbetween plume height and mixing height would occur (i.e., once abovethe mixingheight, plumes do not repenetratethe boundarylayer) the mixing height was set at 5000 m above sea level. Under relativelycalm (1 m/s wind speed) and EIA 6-14 August 1, 1996 ReADLAN- INTERNATIONALM FREQUENCYOF WIND DIRECTIONAND SPEED N N -, _ _ w_ E m~~ N~~~~~~~ / _ _N _ _ v ~ ~~~~~ INTRNTIOAL JORFLASFAR e===III ~~~~~ON-SITE 1-3 4-6 7-10 11-1617-2122-99 (12 s) t30 X) (40 x) (14 s) (3 s) (I x) METEOROLOGICALDATA WIND SPEEDSCALE (KNOTS) (2/15/94 through 3130/94) NOTE - WINDDIRECTION IS THE WINDFROSE DIRECTION WIND IS BLOWING ROM Figure 6-2. Jorf LasfairWmndrose EIA 6-15 August 1, 1996 INTERNATIONALIM unstable conditions(stability class 1),the effectiveplume heights from all four units at the power plant would be near 2000 m abovegrade. Any mixing heights abovethat would maintain plume heights below the mixed layer. In additionto the conservativeassumptions built into the model and its parameters,the followingadditional conservatism was built into the analysis: "Annual"averages calculated by the model are based on the 693-hourperiod of record. Due to the persistenceof meteorologicalconditions over the short term, maximumconcentrations calculated for a period of shorter durationare usually higher than those calculatedfor a longerperiod (i.e., the actualannual average concentraionshould be less than the "annual" averageconcentration calculated by the model). Predictedambient impactsfrom Project operationsare based on maximum emissionsfrom Units 3 and 4, as well as the followingincreases at Units 1 and 2 over estimatedcurrent emissions: SO2 emissionsincreased to a 1.25%sulfur contentbasis over estimated current emissionsbased on 0.75% sulfur, and - >PMemissions from Units 1 and 2 increasedto a 125mg;/Nm 3 (ESP performanceguarantee) basis over estimatedcurrent emissionbased on tested concentrationof 30 mgfNm3. As shown in Figure 6-1, almost half the model receptorsare overwater, where there are no people, animalsor vegetationto be impactedby plant emissions; however,no atempt was madeto limit the analysisto any specificreceptors. Radian believesthat this conservatismprovides an ample margin of safety to accountfor the limited availablemonitoring data. We expectthat when additionalair qualitydata (now being collected)and more realisticassumptions can be incorporatedinto the analysis,the results will show even smallerProject impacts. Results of the ISCST3 modelinganalysis are shown in Table 6-6. As shown, the maximum impactsfrom the Jorf Lasfarpower plant occur between 1.5 and 4 km from the source, over water. Comparisonof the maximumconcentrations with the JLPP guidelineambient air qualitystandards is also shown in the table. For SO2, PM and NO, impacts,the incremental impacts associatedwith the Project were modeled. The incrementalimpact included the change in coal qualityon Units 1 and 2 as comparedto current operations,and the additionalimpacts of Units 3 and 4. This approachwas straight forwardfor PM and NO. . For PM the emissionfrom EIA 6-16 August 1,1996 PtADIANE INTERNATIONALM Units 1 and 2 were increased to the ESP guarantee of 125 mg/Nm3 from current emissions of 30 mg/Nm 3 . For NO. the increase from Units I and 2 were increased from 0.59 lbs/MM Btu (tested levels) to 0.60 Ibs/MM Btu. Table 6-6. Jorf LasfarModeled Air QualityConcentrations Locationof aximum . ,:,.pa . JLPP Project Averaging.istance -a (d:* I MAximum jGuideline Ambient Air A:v.r:aginettg. Distance Dion . C oneelton Qualt Standards :Pllutant Period - S -d(m) -______- (Pfm3) (pm 3 ) SO2 24-hour 1500 290 96.9 125 Annual' 4000 280 14.1 50 NO2 24-hour 1500 290 18.5 150 Annualc 4000 290 2.7 100 PM 24-hour 1500 290 2.4 110 =______==_Annual' 4000 J 290 0.3 70 iGrid origincentered on Unit 1 and2 stack b DCtion is measuredclockwise from north. 290' is approximatelywest-northwest of lLPP over the Atlantic Ocean -Periodaverages from the 693 hours of meteorologicaldata were used to compareto the annualstandards. Usually shorter-termaveraging peiods producehigber concentrations han annual periods, hence the period average comparisonis usuallyconservative. S presented a special case due to the provisions of the World Bank guidelines. One of the guideline criteria is to maintain incremental impacts to below the World Bank Criterion IL levels for SO2 concentations reflective of the surrounding environment. Because the measurements reported in Section 4.1.3 were obtained before JLPP Units 1 and 2 were operational (7 week ambient monitoring), to properly analyze the incremental impact from the project, the monitored background concentrations were increased to include the contribution from current Unit 1 and 2 operations. The methodology employed to increase the monitored SO2 background concentration is discussed below. The highest 24-hour interval S02 concentration (285 zg/m3 ) reported in Section 4.1.3 was increased to include the highest modeled concentration resulting from current Units 1 and 2 emissions of 79 tonnelday. The maximum predicted 24-hour impact from current JLPP Units I EIA 6-17 August 1, 1996 INTERNATIONALM 3 and 2 operationsis 41,ug/m, which was used to adjustthe baseline24-hour SO 2 concentration up to 326 ,ugtm3 (it should be noted that the measuredvalue of 285,uglm3 is at a different location than was predictedby the dispersionmodel). From the World Bank Criterion IItable, interpolationcalculates a maximumallowable annual averageincrement of 25 ,g/M3. This approachwas used only for the annual averagebecause the World Bank Criterion 1iis specificto this averagingperiod. Using the emissionrates on Table 6-2, modelingshows an incremental annual average impactfor the Project(change in coal on Units 1 and 2 and new Units 3 and 4) of 14.1 Azg/m3, just overhalf the allowableCriterion E level. The Project guidelinesinclude a maximum l-hour averagefor both SO2and NO=. Dispersionmodeling to predict short-term,1-hour impacts was not performeddue to the limited amount of meteorologicaldata. Dispersionmodeling for annualand 24-houraverages utilized the data collectedby LPEE in 1994which onlycovered a seven weekperiod. It is Radian's opinion that this limited data was not sufficientto predictstatistically significant impacts for the short-termaveragig periods. After the one year of ambient monitonngdata is collected,short- term dispersionmodeling will be performed. The Project Sponsorshave assuredthat PM emissionsfrom Units 1 and 2 will be below the ESP performanceguarantee of 125 mg/Nm3. As shownin the modelinganalysis, this emissionrate on Units 1 and 2, even whencombined with the impactsfrom Units 3 and 4, results in ambient concentrationsthat are only2% of the 24-hourambient Project guidelineand 0.4% of the annual ambient Project guideline. Thus, PM emissionsfrom all 4 units will not pose any risk to human health or the environment. As noted above,results of the analysisindicated that impactsassociated with the increasedemissions do not significantlyimpact air qualityof the immediateregion. This modelinganalysis demonstratesthat Project air qualityguidelines are achievedfor SO2, NO,, and PM even with the conservativeassumptions employed. 62.3 Surface Water Quality The only surface water to be impactedin the area is the Atlantic Ocean. JLPP potentially impacts it locally via dischargesof ash and wastewater. In this section we will briefly review the nature and magnitudeof any discharges,the potentialconcem associated with each, any observed impacts, and possible mitigationmeasures. EIA 6-18 August 1, 1996 RAJDL^NE INTERNATIONALQ Discharges to the Ocean Water usage and discharges at JLPP are discussed in Section 3. A detailed review of ocean discharges by JLPP is provided in Section 7.6; a summary of these discharges follows. Bottom ash and fly ash are sluiced into the ocean using seawater as the transport medium. The point of discharge is 800 m off shore in 13 m of depth and in an area of breakers, to maximize dispersion. Approximately 140,000 dry tonnes per year of ash are discharged in this manner. The large coal storage area north of the plant is I m lower than the powerhouse, isolating the coal pile runoff from other JLPP drainage. Coal yard runoff is directed to the ocean via three outlets, one for each pair of units in the original JLPP design. Prior to discharge, storm water from the area of the coal yard serving Units 1 and 2 passes through a settling basin. A second seting basin will be added for the area serving Units 3 and 4. Other storm waters and wastewaters are conveyed to the ocean via a combined sewer system, and discharged from two outfalls near the plant. Oily wastewater is pretreated in an oil/water separator. Sanitary wastewater flows through septic tanks for solids settling before entering the sewer network. Demineralizer backwash and regeneration water, boiler acid cleaning water, and air preheater cleaning water are neutralized in a settling basin before discharge to the sea. Seawater is used to cool the JLPP condensers. Except during a heavy rainstorm (rare for this arid region), this stream of cooling water dwarfs the storm water and wastewater streams. The cooling water is chlorinated to control biofouling of the condensers. Its temperature rises by approximately 9°C between intake and discharge. Potential Concems Specific environmental concerns are associated with each type of discharge. They are briefly listed here. Note that these are typical potential concems; they may or may not be relevant to JLPP. Later in this section, we describe how these concems will be addressed. EIA 6-19 August 1,1996 RAIAN- INTERNATIONAL3 Ash Dischargeto the Atlantic Ocean: Heavy metals could be concentratedin the ash and leach out into the seawater, exceedingdesirable limits. Turbidity,smothering of benthos, sea floor elevation. The turbulencearound the outfall should disperseand dilute the ash. Nevertheless,it has been observedthat the bottom ash outfall sometimesplugs up temporarily,which may indicatelocal heapingof the bottom ash. Stormwater: Hydrocarbons:oil/water separators may not stop emulsions,and can allow dissolvedorganics to reachthe ocean. Althoughsome of these organics are toxic (e.g.benzene), they are generallyalso very biodegradable,and the discharged amountsappear to be very small. Turbidity:storm events are likely to entrin large amountsof particulates, espeiay from the coal storageyard. These can interferewith marine life by reducingvisibility, and by their coveringand cloggingaction. However, storm eventsare rare and bnef, probablyallowing quick recovery. Wastewater. Sanitarywastcwater Withoutdisinfection, organisms harmful to human health could be dischargedto the near shore zone, where they can accumulatein harvested speciesof molluscs,crustaceans, and fish. This representsa potential health hazard to bathersand consumersof seafood. No evidenceof related health problemswas found; however,no testing for such organismswas carried out. Toxics: Metals, cleaningsolutions, and corrosivesmay be dischargedeither directly or after pH neutralization. pH excursions: pH extremes could cause marne life kills near the outfalls. No apparent damagewas found during the site visiL CoolingWater TIhermaldischarge: Many near shore organismshave a narrow temperaturerange, or cannot tolerate sudden temperaturechanges. Temperatureincreases will also decrease the solubilityof oxygenin water. EIA 6-20 August 1, 1996 RADCLIAN- INTERNATIONALM Observed Impacts Some foaming of the cooling water was observed; its origin is unknown. Note that a spectrum of naturally occurring compounds can cause foaming. Some red staining of the outfall channel was also observed. The temperature rise of the water between intake and outlet is approximately 9°C. Modeling shows that the resulting rise at the edge of the mixing zone is 0.9 to 1.3 C, well within Project guidelines of 5.00 C. A pH excursion above 9 was observed in one of the wastewater outfalls. At the sampling points nearest the ash outfall and the OCP discharge (points 2 and 4), seawater copper and iron concentations were found that were approximately three times higher than at the other sampling points. Mercury was highest near the harbor (see Section 4). Otherwise, no evidence of major water quality impacts was found. Although no major water quality impacts were found, the Project Sponsors will take steps to ensure ongoing compliance with Project guidelines as discussed in Section 8. Some areas of concern remain such as the long term impact of ocean ash disposal, the potential discharge of organisms harmful to human health, the release of untreated dissolved organics from cleaning solutions, oil/water underflow, etc. The following mitigation approaches will address the potential concerns listed carlier in this section: Land disposal! utilization of ash will eliminate problems associated with ash disposal at sea. Properly sized settling basins for the entire coal pile runoff will intercept most of the particulate matter in the runoff. Improved monitorng and control of neutralizon system discharges will ensure continuous adherence to project effluent guidelines. Secondary treatent and disinfection (chlorination) of sanitary effluent, sized for 300 people, will be added during the construction of Units 3 and 4. 6.2.4 Thermal Discharge Impacts Radian performed an evaluation of the impacts of JLPP's thermal discharges on the Atlantic Ocean as compared to the Project guidelines. The analysis focused on the impact of the thermal discharges while all 4 units are in operation and at full load. EIA 6-21 August 1, 1996 INTERNATIONAL The condenserdesign rejected heat load is 363,470kJJs. At this load, the predicted condenserpressure is 0.049bar at a coolingwater inlet temperatureof 20°C and a cooling water volumeflow of 11.2m iS.3 Eachcondenser's cooling water is dischargedinto a common open concretechannel. The channelwidth at the dischargeof the 1.5 km length channelis 26 m outside the fence. A serratedcascade weir is constructedat about the midpoint along the channel lengthto dissipatethe potential energyof the channelwater as it drops in elevation. The channelwater temperatureprofile was measuredin September1995 and in April 1996. The condensercooling water net temperatureincrease was measuredto be less than 9°C. The Project guidelinesfor ocean thermaldischarges dictate that the net temperatureincreases at 100 m away from the dischargeshould be less than 5°C, since the receivingwater temperatureis less than 28°C. The impactsof the JLPP Units 1 and 2 thermal dischargeswere measuredin the ocean durng the water qualitysampling activities. The thermal impactsof JLPP were also determined via modelingtechniques to determinethe net ocean water temperatur incease at :30 m away from the discharge,with all 4 boilers opeating at full load. The thermal dischargeanalysis consisted of an integratedfield testing and mathematical modelingof the thermalplume discharges. The model simulationscover reasonablethermal dischargescenarios. For this analysis,the edge of the mixing zone was defined to be 100 m to assure adherencewith the Project guidelines. An order of magnitudeanalysis indicated that the followingfactors dominatethe JLPP cooling water dispersionrate: Ocean bottom depth and gradient; * Mean oceanwave motion and currentvelocity; Geometricshape of the dischargechannel; Maximumdischarge plume mass flow rate; Mean dischargeplume water temperature;and Mean oceanwater temperature. Field activitieswere caried out to quantifythese parameters.Where field data was not available,conservative estimates were made. EIA 6-22 August 1,1996 ,RADAL^N INTERNATIONALM The dissipation of the thermal discharges into the ocean were evaluated using a full capability computational fluid dynamics (CFD) simulation developed by Combustion, Heat and Mass Transfer (CHAM) based in London, United Kingdom. Specific environmental flow applications include ocean thermal discharges (Markatos and Simitovic, 1983), waste water discharges into reservoirs (Rizk, 1992), and flow over aerating weirs (Hadjenouah, 1993). Data gathered during the field investigations was used to calibrate the model. The model was then tested against actual thermal data collected during 2-unit full-load operation in order to ensure accurate calibration. Once calibrated, the model input parameters were adjusted for 4-unit full- load operation and the simulation was run. Modeling analysis confirms that the Project guidelines for thermal discharges will be achieved with all four JLPP units operating at full load at all historical ocean temperatures. Figure 6-3 shows the temperature profile of the plume at increasing distances from the shoreline as modeled by the CFD simulation for full load operation of all four boiler units. The data from the model indicate a 2.20 C rise in the ambient water temperature at 100 m offshore. A detailed discussion of the modeling parameters and approach may be found in appendix G. 6.2.5 Groundwater At Jorf Lasfar, groundwater is encountered about 6 m below ground level. Typically at such close proximityto the sea, saltwaterintrudes below a freshwaterlens. The interface between the two may be well-defined and is referred to as the halocline. It moves up and down with the tides. At Jorf Lasfar, the lens is probably recharged from the plains between Casablanca and Safi. During the Phase IIEA, Radian sampled the groundwater around JLPP and also sampled a drinking water well just outside the fence line near the main entrance. As expected, some salt water intrusion from the sea was noted in the nearshore wells. Metals concentations correlate with those in the surrounding formation. As described in Section 4.1.5, somewhat elevated levels of oil and grease were found in monitoring wells around the site. The addition of Units 3 and 4 will include stormwater and wastewater collection and treatment systems designed to meet all Project discharge guidelines. Consequently, no impacts on groundwaterare expected. JLPP will continueto obtainall its raw water suppliedfrom a EIA 6-23 August 1, 1996 W1 S~~~~~~~~~~~~~~~~~~~~~, ) i~3 a T mpramtumProfieatthePlume Contriline 0~~~~~~~~~~~~~~~~~ EXt4~~~~~~~~~...... 8"...... I...... 4 ...... I...... <...... 3 2 ~~~~...... I...... I...... -. -~~- I 9 I ...... v >~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~*-a~npua t8~ i o 20 40 e: so 100 120 140 160 Te eDratuncefrofl ahoe Pm) INTERNATIONALEM municipalwater system,so no localwithdrawals and concomitantlowering of the groundwater table are expected. 6.2.6 Biological Resources-Land The vegetationin the area was describedin Section4 as profoundlymodified by agriculture,with little or no naturalvegetation remaining. This situationis commonaround the MediterraneanSea and other areas that have been agriculturalfor manycenturies. Thereis some soil erosiondue to overgrazing. Fieldsof com and wheat are common,and vegetablefarms are found south of JLPP. No palustrineor estuarinewetlands were observed near JLPP. No endangeredanimal species were observedor are believedpresent near the plant. The expansionof JLPP will occur withinthe existingfenceline. The land that will be used is essentiallya vacant lot on the existingJLPP site. For thesereasons it not likely that the proposedexpansion could have any direct additionalimpact on local terrestrialbiological resources. 6.2.7 Marine Resources The operationof Units I through4 will haveno adverseimpact on the marine environment.It is possiblethat the Projectwill benefitthe marineecology. Water qualityand sedimentanalyses showed relatively high concentrationsof copperand mercury.The marinebiological baseline survey found a relativelylow varietyand quantityof fish and benthic organisms. Theseobservations may be due to one or more of the following: a naturallylow occurrenceof marinelife as a result of the high energybeach environment (rugged shorelineand heavywave action),JLPP surfacewater runoff and plant discharges,the deposition of fly ash and bottom ash from the JLPP on the oceanbottom approximately800 m offshore,and other dischargesfrom neighboringfacilities. It is not necessaryto know whetherand to what extentthese causesmay contributeto low qualitymarine conditions in orderto determinethat the futre impactsof the proposedaction to the marineenvironment will be either negligibleor, more likely,positive. The Project Sponsors will end the practice of ocean disposalof ash as soon as an appropriatealtemative can be implemented.To the extent that ash disposalmay have been a factorin any adversemarine EIA 6-25 August 1, 1996 RADLAN- INTERNATIONALM biologicaleffects, the proposedProject will improvemarine conditions by avoiding future impactsfrom additionaldisposal. Similarly,improvements that the Project Sponsorsare proposing for wastewater dischargeswil reduce impactsthat may be occurringas a result of existing treatmentof wastewater. To the extent that surfacewater qualityimproves as a result of these planned improvements,marine life will be positivelyaffected. 6.2.8 Archeologicaland HistoricalResources The operationof Units 1 through4 at the JLPP will have no impacton archeologicalor historicalresources. As noted earlier,all constructionand operationsfor the proposedProject involve land that has been previouslydisturbed and convertedto industial uses. For this reason, no archeologicalsurvey was requiredor conducted. 62.9 SocioeconomicImpacts The socioeconomicimpacts of the operationof Units I through4 are positive. In parucular,the proposedProject offerssignificant direct and indirect economicbenefits to Morocco.This section addresseslocal, national,and internationalsocial and economiceffects of the proposed Project. Local Effects The expansionof the JLPP will createnew, long-termemployment opportunities for approximately156 personnelduring normalplant operations,plus a doublingof the total workforcetemporarily during plant maintenanceand overhaulactivities. This increase in the permanentwork force would increasestaff levelsfrom 144 at present to 300. Most of these new positions will be from the local work force. Currentemployees will be given the option of remainingwith ONE or joinig the Project Sponsorsstaff. The terms and conditionof the privatizaton of the JLPP obligethe ProjectSponsors to maintainsalaries at current or higher levels. For these reasons,the impactson localemployment (and existig employees)will be positive. in addition,there will be indirectpositive impacts as a result of increasedspending by new employees.These positive impacts will be manifestedlargely in the El Jadida urban area where the new employeesare likelyto reside.Although the largelyunskilled laborers in the inmediate vicinityof the JLPP will benefitfrom constructionhiring and periodicmaintenance EIA 6-26 August 1, 1996 RADIAN- INTERNATIONALOB activities, only a few permanent staff positions are expected to be filled by those living in the immediate vicinity of the JLPP. According to local planmingauthorities, the City of El Jadida is expanding its low and moderate income housing stock to ensure that adequate housing is available for new workers in the area-including the JLPP expansion. Some 27,000 new housing units are expected to be developed by the year 2000 in areas that are served by water, sewer, and power utilities. By contrast, much of the existing housing stock closer to the JLPP is judged to be inadequate (Elhaiba, 1996). By maintaining convenient employee transportation to and from the JLPP, the Project Sponsors can assure that growth from new employment will be channeled largely to the El Jadida area where adequate housing and services will be available. The aesthetic impacts of the proposed expansion will be minor. There will be an additional flue gas stack that will be visible for several km along the coast highway. Two additonal generating units wi}lbe visible from locations closer to the JI*P. Most of the new expansion, iike most of the existing plant, will be shielded from view as a result of the terrain. During the local permitting of the existing facility, an objection was raised by permitting authorities to the architectural design in the original plans. The building contractor worked with local authoritiesto developan architecturalmotif that incorporatesMoroccan Arabic design and that reduces some of the typical "industrial" look to the facility. This architectral motif will be incorporated into the two new units. The onlyadverse aesthetic mpact that may result from the expansionwill be additional high voltage transmission lines and towers. Improvements in Morocco's electric power transmission system are being evaluated in a separate World Bank-sponsored study and are not in the scope of this EIA. National Effects The most significantbenefits of the proposedProject will be the increasein quantity, availabilityand the reliabilityof electricpower to the nation. EIA 6-27 August 1,1996 INTERNATIONALMS As discussedin Section4, the Moroccaneconomy has improvedin recent years. However,future economicprogress is challengedby relativelyhigh unemploymentlevels and problemswith the availabilityand reliabilityof electricpower. As shown in Figure 6-4, JLPP will accountfor approximatelyone-half of Morocco'selectric power generationby the end of the decade'. The additionof Units 3 and 4 are absolutelyessential to avoid futurelosses in gross nationalproduct and increasesin the cost of doing businessas a result of recent electric power curtailments. The benefitsof the increasedcapacity from Units3 and 4 will also direcdy affect 80% of the Moroccanrural populationthat is currentlywithout electricpower. Many of these rural villagers,who compriseapproximately half of the country'spopulation, will enjoy the benefitsof electricpower over the course of next decadeas a result of the rural electrificationprogram. The success of this programdepends, in part, upon the availabilityof electricpower from Units 3 and 4. Throughthe privaization of JLPP Units 1 and 2, the Governmentof Morocco will receivethe monetarybenefits of an upfrontpayment of $263.1million (U.S.). Throughthe constructionand operationof Units 3 and 4, additionalpower will be broughton line without the need for the increasedmdebtedness that would occur if JLPP were not privatized. InternationalEffects Morocco has extensivebusiness relationships with its Europeanneighbors to the north and cultural connectionsand businessrelationships with its Arab neighborsto the east. The proposedProject, with both Americanand Europeanpartners, will continueto expand Moroccan commercialrelationships with bothEurope and the U.S. 62.10 Noise Noise impacts from the operationof the new units will not adverselyaffect the off- propertyresidential areas and will remainwithin Project guidelinesfor fence line impacts. As notedin Section4. the four LPP units waccaot for approximely one third of Morocco's installed c by the end of year 2001. BecauseJLPP is a base load powerplant, its sbareof power ation (ie..,kWh produced) wil be approximateyhalf of the country'stotal electricty production. EIA 6-28 August 1,1996 INTE NATIONALI Total Moroccan Electrc Power Requirements 10-_ U. Proposed O Units3&4 z t~~~nt1 Sm c e. laYEAR Figure6-4. YearlyElectric PowerRequirements for Morocco and JLPP Contributionto Supply EIA 6-29 Aueust 1, 1996 RADIANE INTERNATIONALIM The construction contract has guaranteed the following source noise levels (i.e., I m from source) from the new equipment at Units 3 and 4: Safety valves (when blowing) at 30 m <95 dBA * HP and LP turbine bypass <110 dBA Turbine generator <90 dBA All other equipment <88 dIBA Blowing safety valves will be loudest sounds from the plant. These should be very rare occurrences, but when they occur, they can create a startle effect on nearby employees, and to a lesser extent, wildlife and the public. The nearest off-site residential areas are shielded from most of the JLPP noises by the crest of the bluff. Most of these residences are at least 500 m from the new units. However, the nearest residence is only about 75 m. At this point, the safety valve blasts would be attenuated to about 70 dBA which is well below occupation limits set to protect hearing loss. Such levels would be a nuisance but considening their infrequency of occurrence, this is not considered a significant impact. In addition to source noise limitations, the construction contractor has guaranteed that site boundary impacts would be below 65 dBA. This does not include the effect of Units 1 and 2, which, at most, would be an additional 6 dBA. Thus, the boundary line guarantee would result in a maximum potential boundary line impact of 71 dBA, which is marginally above the Project guideline of 70 Ldn (dBA). Further tesdng as described in Section 9 will be used to monitor noise levels to determine if mitigation is necessary. Most off-property residential receptors would experience no more than a 5 to 6 dBA maximum increase in noise, and most of the residences would be below the 55 Tln annual average guideline because of the shielding effect of the terrain. All of the residences would be below health-based (hearing preservation) guidelines. 6.2.11 Worker Health and Safety As discussed in Section 8, the Project Sponsors will institute a worker health and safety program that will minimize the potential for accidents. These measures will be in line with operating practices at plants in the U.S. and Europe. EIA 6-30 August 1, 1996 RADUINM INTERNATIONALE3 7.0 ANALYSISOF ALTERNATIVES This section explains why and how certain decisions regarding e proposed Project were made and analyzes options for issues including: site selection, fuel selection, alternative coal technologies, alternative air emission controls, coal sources, altemnativewastewater treatment options, and alternatives to ocean ash disposal. 7.1 Rationale for Site Selection In 1994,the ONErequested proposals from intemationalindependent power producers to acquirethe concessionto operateUnits 1 and 2 at JLPP and to add two additionalunits of at least the same size as the existingunits at the site. The ProjectSponsors, as well as other proposers, were constrainedby the terms of the requestto the existingJLPP site. The JLPP was originally designedfor the constructionof a total of six generatingunits. Given that there is substantial existingiucure alreadyin place for the additionalunits, the least-costbaseload power generationoption for ONEis the expansionof the JLPP. Moreover,the environmentalimpacts of a plant expansionwould almostcertainly be less than a "greenfield"project. The originaldecision to site Morocco'slargest power plant at Jorf Lasfarwas made by ONE during the late 1980s.The rationalefor locatingat this site is its proximityto: (l) the ocean; (2) the Port of Jorf Lasfar, and (3) the large phosphate production plant owned and operated,bythe OCP, which alreadymakes the locationan "industrial"aea. The proximityto the oceanallows for once-throughcooling using ocean water without the need for coolingtowers or constructionof a coolingreservoir. The proximityto the Port, with its ship and rail infrastrucure,allows for easy deliveryof constructionmaterials and plant equipmentand providesready accessto coal and fuel oil shipments.The proximityto the OCP plant reduces power transmissioncosts. The OCPplant is one of the largest of its kind in the world and is ONE'slargest singlecustomer. (Laaouina, 1996). The JLPP, the Port of Jorf Lasfar, and the OCP facility are the core of an industrial complex that will be developedover the course of the next severaldecades. This industral complexwas sited awayfrom existingurban centers,such as Casablanca,as a means of decentalizing industryfor social and environmentalreasons (Laaouina,1996). EIA 7-1 August 1, 1996 INTERNATIONALEM In summary,there were severalcompelling reasons for selecting the location of the JLPP at the Jorf Lasfar location. Moreover,the Project Sponsorswere constrainedthrough the intemationaltender from proposingaltemative sites. 7.2 Rationalefor Coalas a Fuel The two existinggenerating units at JLPP use coal as the primaryfuel with No. 2 heavy fuel oil as a backup. The two proposedunits will use coal as the primaryfuel and heavy fuel oil No. 2 for start-up and flame stabiliation only. As with the siting decisiondiscussed above, the selectionof a fuel otherthan coal was not an option for the Project Sponsorsin their responseto the public tender from ONE. The only reasons for changingthe fuel selectionfor the additional new units would be ovemding economicor environmentalones. The only fossil fuel optionsfor the futureJLPP units are coal, fuel oil, and natural gas. Fuel oil storage capabilitywould have to be increasedsignificantly in order to provide a reasonable supply for Six units. Given the lack of available suitable space at the immediate site, this amount of storagewould require constructionof oil tanks on the bluff above the plant. The use of fuel oil could providefor margimallyreduced emissions, depending upon the qualityof the oil, but would pose higherrisks of oil spills and contaminationof soil and water. In addition,the cost premium of burningoil instead of coal in units the size of Umts 3 and 4 is estimated to be more than $50 million (U.S.) per year. Natural gas is the cleanestfuel for powerproduction. However,natural gas can only be tansported economicallythrough large diameterpipelines. Very little naturalgas is producedin Morocco and this productionis remotefrom Jorf Lasfar.A large naturalgas pipeline is being constructedfrom Algeriato Europe crossingover the Straits of Gibraltarfrom Morocco. Of the 1435 km total length, 540 kmntaverses throughthe northernpart of Morocco. Of the 18.5 billion m3 annual throughput of the pipeline, some 8.5 billion n3 will be marketed in Morocco. However,no trunk lines are plannedfor the El Jadida regionand thereforeuse of natural gas in Units 3 and 4 is not considereda viable option (Laaouina,1996). In summary,the JLPP was originallydesigned and constructedto bum coal on all six units. The use of altenative fossil fuels (otherthan for back up and start up) for Units 3 and 4 is not reasonable. EIA 7-2 August 1,1996 RADIAN- INTERNATIONALEM 7.3 Rationale for Pulverized Coal Technology The JLPP uses conventional pulverized coal (PC) technology to generate electric power. Clean coal technologies, such as pressurized fluidized bed combustion (PFBC) and integrated gasification combined cycle (IGCC) are being demonstrated at several sites throughout the world. These technologies, particularly IGCC, offer the prospects of lower air emissions than the best controlled PC technologies combined with higher plant efficiencies and therefore lower fuel costs (DOE, 1994). However, the high capital costs and lack of operating experience of these technologies make them currently unattractive for most developing countries. Also, as noted above, the original design of the JLPP is for units that are similar to the existing PC boilers. The siting constraints, increased construction costs, and operational issues associated with adding a new technology at the existing JLPP also render the use of clean coal technologies impractical for this site at this time. 7.4 AltemnativeAir Emission Controls Although continued use of coals from existing sources results in (SO2)emissions from all four units that meet the Project emissions guideline of 0.20 tpd per MW, the preliminary ambient air quality data (ONE, 1994) indicated that there are occasional episodes when high ambient levels of SO2 concentrations are experienced. Since these data were collected in 1994 prior to the construction of Units 1 and 2, the source of these intermittent elevated short-term S02 concentrations is not JLPP. To ensure adequate protection of ambient air quality, in light of existing levels, alternatives for reducing SO2 emissions from JLPP were evaluated. 7.4.1 Altemative SO2 Controls This section presents four altemative SO, air emission control strategies considered for Unlits3 and 4. The control strategies evaluated include the use of: 1) a seawater scrubber, 2) a limestone scrubber, 3) "ultra-low" sulfur coals, and 4) "cleaned" coals. Seawater Scrubber In a seawater scrubber, seawater and flue gas are brought into contact in a packed scrubber tower. The seawater flows down the scrubber while the flue gas flows up the scrubber (i.e., a counter-current design). The S02 in the flue gas is absorbed by the seawater and quickly reacts with water to produce sulfite ions (S3Q). The spent seawater is then routed to an aeration basin where the SO3-'is oxidizedto sulfate (SO472), a major constituentof seawater. EIA 7-3 August 1, 1996 RADIAKE INTERNATIONAL The seawater scrubberproduces no solid waste streams,and the increasedS042 concentrationin the spent seawateris well within the naturalvariations of seawater. However, trace heavy metals in the coal, such as chromium,can be transferredfrom the flue gas to the seawater,possibly requiring wastewater treatment systems to achieveproject effluent guidelines. The seawater scrubberprocess is shown schematicallyin Figure 7-1. The seawater scrubberdesign and cost data are based on the following assumptions: A 90% SO, removalefficiency-, Labor rate of 12 dirhams($150 U.S)/hr, 20 workerstotal for all shifts; Seawaterfrom condenseroutlet at a rate of 40,500 ml/hr. Coal lowerheating values ranging from 5,800 to 6,930 kcal/kg-coal; Coal sulfurcontent ranging from 0.25% to 1.0%i; Specificheat rate of 2,140kcal/kWh; and Annual fixed chargerate of 17.25%. Based on these assumptions,the total annual cost (annualcharges on the capital investment+ variableannual cost + fixed annual cost) of the seawaterscrubber is $14.47(U.S.)JkW-yearand the SO2emission rate would be 0.012 tonnes/day-MW(for a coal with an averageSO, content of 0.75%). The cost per tonne of S removedranges from $297 (U.S.) to $984 (U.S.), dependingupon the fuel sulfur content,with lower sulfur fuels having a higher cost per tonne due to the fLxedcapital equipmentcost necessaryto teat the volume of flue gas gened Althoughthe seawaterscrubber produces no solidbyproducts that must be landfilled,it does reduce the generatingunit's net electricaloutput approximately2.2 MW by increasingthe station's auxiliarypower requirements.The increasedauxiliary power requirementsresult from the increasedflue gas fan power needed to compensatefor the flue gas pressuredrop across the scrubber and from the power requiredby the scrubber's absorberpumps and seawatertreatment plant aeration fans. 1 The fuel sulfwrlevel of the seawaterscubbing process is hlited by the economicsrather than for stictly technical reasons. Aboveapproximaty 1% sulfur,the volumeof seawaterthat mtustbe usedto provide suffiaent alkalne eagentbecomes verylarge, and both capitalcosts and operating (pimarilyassocia withseawat pumpsand pumpingcosts) rapidlyincrase to the point wherethis system is not economicallycompetitve with altenanve SO2 controlprocesses. EIA 7-4 August 1,1996 M- OUTLET~~~~~~~ J 100%6 Cv STACK BYPASS FROM SEAWAtER < ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~PUMPS & m E 3 ~~~~~~ ~~BYPASS AERFATItON DAMPER EM~~ERGMETNCY.0 FA U'\ ELECTROSTATIC PRECIPITATOR - PUMP R N INLET DISO{ROEDISCHARGE FROMBOILER a BASIN AE E FAN DAMPER SEAWATERTREATMENT PLANT INTERNATINAiL Figure7-1. Schematic Dlagram of SeawaterScrubber Process with Bypass Reheat RADIAN- INTERNATIONALM3 Limestone Scrubber In a limestonescrubber process, the flue gas exitingthe ESP is passed upward throughan absorber tower where it comes into intimatecontact with a downwardflow of a slurry of limestone (CaCO3) in water. The SO, in the flue gas is removedby reactionwith the limestone to produce calciumsulfite (CaSO3*2H20). The CaSO3-2H20 is then oxidized by air injectedinto the hold tank to produce gypsum(CaSO 4-1/2H20) which can be dewatered,mixed with fly ash, and landfilled. If the gypsumis washedfollowing dewatering, it can producea commercial- qualityproduct. The entire process is shown schematicallyin Figure 7-2. The limestonescrubber design and cost data are based on the followingassumptions: A 90% S02 removalefficiency; Coal lower heatingvalue of 6,930 kcalfKg-coal; Coal sulfur contentof 1.0%22; Limestonecost of $13 (U.S.)/tonne; Waste disposal cost of $5.50(UJ.S.)htonne; Labor rate of 12 dirhams ($1.50U.S.)/hr, *- 32 workers on all shifts3; *- Specificheat rate of 2,140kcalJkWh; and PI Annual fixed chargerate of 17.25%. Based on these assumptionsthe total annual cost (annualcharges on the capital investment+ variable annualcost + fixed annualcost) of the limestonescrubber is $59.41(LT.S.)IkW-yearand the S02 emissionrate will be 0.012 tonne/day-MW(for a coal with an average S02 content of 0.75%). The cost per tonne of SO2 removedis $1221 (U.S.). Like the seawaterscrubber, the limestonescrubber reduces the generatingunit's net electrical output by increasingthe auxiliay power requirements;however, the limestone scrubber's auxiliarypower requirement(2.9 MW) is approximately30% greater, when buming 2Ahene scrubberis capableof utang finegas fiom coal witha sulfr contentmuch greater than 1%. The 1% sulfur assumptionwas selectedbased on providingan apprpriate cost comparisonwith the previouslydiscussed seawater scrubber and on the observationthat world-marketpnces for 1% and 2.5% sulfur coals are approximatly the same, on a cost per kcal basis (reerence: Mr. ManfredRaschke, PhD.). 31he limestonescrubber reqires moreoperating and manmtenacelabor than the seawaterscrubber because of its more complexmechanical equipmnt and the scalingand erosivenature of the slurriesbeing circulated throgh the process. EIA 7-6 August 1, 1996 INTERNATIONALM; Reheater Clean flue gas to stack Mist eliminator washwater _Scrubber Flue gas { Scrubbing slurry Ground / iimestone s Effluent Mku hold tank a water. To disposal Thic14w Mixer Vacuumfilter overflow tank SOURCE: Cooper and Alley, 1986. Figure 7-2. Schematic Diagram of a Limestone Scrubber EIA 7-7- August 1, 1996 RADIANE INTERNATIONALMB the same 1%sulfur coal. Thesepower requirementsare for the increasedpower requirementsof the flue gas fans and the power requirementsof the scrubberpumps, reagentpreparation system, and waste dewateringsystem. The limestonescrubber also producesa large quantityof gypsum solids (approximately3.6 tonnes of gypsumper tonne of SO2 removed). This material must be either landfilledor disposedof as a commercialproduct. 'Ultra-Low'Sulfur Coals Since the amountof SO2 producedis dependenton both the amountof fuel used and the sulfur content of the fuel, it is possibleto reduce SO, emissionsby substitutingthe existing low sulfur coal with an "ultra-low"sulfur coal. The ultimate analysesfor a range of "ultra-low" sulfur coals consideredfor use at JLPP are presentedin Table 7-1. The SO2 emissionsproduced by an aveage "ultra-low"sulfur coal, as presentedin Table 7-1, is approximately0.03 tonnesIday-MW, well below the projectemission guideline of 0.20 tonnes/day-MW.However, the cost differentialfor the "ultra-low' sulfurcoals consideredfor use at JLPP is estimated to be approximately4.3% greaterthan the cost for other low sulfur coals, whichmeet project guidelines. In addition,the use of an "ultra-low"sulfur coal wouldbe expectedto increase PM emissions,since the existingESP's collectionefficiency would decreaseas the coal sulfur content decreases. Therefore,the use of "ultra-low"sulfur coals at JLPP is not recommended. CleanedCoals Coal cleaningcan be achievedthrough five processes: *Crushiing; Sizing; Cleaning; Product dewatering,and; Water clarification. EIA 7-8 August 1,1996 RADIAN- INTERNATIONALU Table 7-1. Range of Ultimate Analyses of "Ultra-Low" Sulfur Coals Considered for Use at JLPP Parmeter 11 Range' Composition(% by weight) -Sulfur 0.10 - 0.29 -Ash 9.29 -11.10 -Moisture 7.20- 8.09 -Volatiles NA -Carbon 65.86 - 71.53 -Hydrogen 3.92 -4.13 -Nitrogen NA -Oxygen NA -Chlorine NA |HigherHeating Value (kcallKg) 6,939 - 7,225 LowerHeating Value (kcallKg) 6,695 - 6,975 NA=Not available aMaufed Raschke (1996). Coal cleaning is typically performed at the mine to reduce both the ash and sulfur content of the coal. By reducing the ash and sulfur content of the coal, emissions of S and PM are reduced. In addition, the amount of bottom ash produced is reduced. The five cleaning processes can be combined for six degrees of coal cleaning, ranging from a simple system providing coal sizng and removal of tash to full coal preparation system that produces a highly clean coal and a moderately cleaned "middle product" coal. In the U.S., nearly all of the coal mined underground is cleaned to some degree to reduce the ash content. More extensive cleaning is usually necessary to reduce the sulfr content Although coal cleaning can be utilized to reduce SO2 and PM emissions, no data have yet been obtained from the potential coal suppliers on the effectiveness of, or costs for, cleaning their respective coals to fully evaluate this altemative. Project Sponsors have requested these data from potential coal suppliers. Conclusion The coals being considered for JLPP Units 3 and 4 appear to be capable of achieving both project emission guidelines and project ambient guidelines. SO2 emission reduction alternatives EIA 7-9 August 1, 1996 INTERNATIONALMl are not wanranteddue to the additionalcapital and operatingcosts that would be incurred. The additionalcosts for a seawaterscrubber would have a 30-yearpresent value of over $24 million (U.S.). The additionalcosts of a limestonescrubber would have a 30-yearpresent value of over $96 million (U.S.).4 7.4.2 Altemative ParticulateMatter (PM) Control Options The Project Sponsorsare confidentthat PM emissionsfrom Units 1 and 2 can be kept below the ESP guaranteeof 125 mg/Nm3. As discussedin Section 6.2.2, variationsin coal ash and sulfur contentaffect PM emissions. This sectiondiscusses PM mitigationstrategies that can be used as a means of making adjustmentsto PM emissionlevels which have changed as a result of using differentcoals or decreasedESP performance. The most often used strategiesare flue gas conditioningand modificationsto the electricpower waveforms appliedto the ESP. Additivesare used as a meansof controllingthe resistivityof the fly ash in the ESP. Collectionefficiency is improvedas fly ash resistivityis reduced. Additivescan generallyregain lost efficiency and regain the originalperformance level following a fuel change. The common means of modifyingresistivity include the injectionof: *ammonia; sulfur trioxide; dual use of ammoniaand sulfur trioxide; ADA-23 (propietary acidiccompound); sodium sulfate and bisulfate; water, and others. The key to the applicationof additivesis a combinationof detailedanalysis of compositionof the coal fly ash, the temperatureenvironment, and particle size, and the proper vaporizationand mixing of the additivewith the particle-ladenflue gas. 4nhee ralues are based oan30 ye= of opamion at an avrage unitcapacity fato of 82%.A leveized fixed charge rate of 18.85%was appliedto the initialcapital investnmen Annual costs wer estimaedto escalateat a me of 6% per year. Ibe present value discount valueused was 1958%. EIA 7-10 August 1, 1996 RADCIAN-E INTERNATIONALM3 The other prime means of adjusting PM emissions is through modification of the wave shape, wave height, and frequency of the voltage signals applied to the electrodes and collector sections. Saw tooth waves (as opposed to square waves) of higher voltage at varying pulse frequencies have been found effective as an ESP performance adjustment factor. Wave height and frequencies are determined by test and experience. These modifications have been found to achieve significant reductions in PM emissions with only moderate installation expenses, although unit outages would have to be taken into account. Other approaches that have been proven useful include flow balancing to reduce "sneaking" of flue gas and adjusting flue gas flows between channels to make these more uniform. Combustion improvement can be used to reduce the carbon content of the fly ash, so reducing this portion of the fly ash reduces inlet loading and improves resistivity. Coal washing can be used to reduce ash content. Electrical controls and rapping sequence can also be optimized Radian emphasizes that the potential of excessive particulate emissions is low, even based on relatively conservative predictions. Before any of the options listed above is considered, the performance of the actual ESP's will be verified to determine the ESP outlet particulate emissions. If emission testing shows that the particulate emissions exceed 125 mg/Nm3 when representative fuels are fired, Project Sponsors will investigate the necessity and cost effectiveness of applying any of the solutions above to reduce particulate emissions. 7.5 Altemative Wastewater Treatment Options This sectionreviews the presentwastewater production of JLPP, the present treatment processes,and a possiblealternative process. 7.5.1 WastewaterProduction JLPP producesthree types of effluents: Ash is sluiced to the ocean using seawater. The ash is discharged approximately 800 m offshorein 13 m of depth. The powerplant condensersare cooledwith a verylarge streamof seawater. The seawateris chlorinatedupstream of the plant for controlof biofouling,and ultimately discharged back to the ocean. EIA 7-11 August 1, 1996 RADLA^N INTERNATIONAL3 A varietyof storm water and wastewaterflows are producedand eventually dischargedinto the ocean. Some pretreatmentof these effluentsoccurs. Ash disposalis a solid waste managementissue and so is discussedlater in this section. The disposalof ash at sea will be discontinuedand will be replacedwith landfillingor beneficial reuse. As noted in Section 6.2.4 of this report,the thermaldischarge, although large and continuous,appears to have minimalimpact on the environmentand is well withinproject and World Bank guidelines. The focus of the remainderof this subsectionis on storm water and wastewater. The differentstreams present at JLPP are summarizedon Figure 3-6. Except for the condenser cooling water, most of these streams are intermittent. Storm Water The unrealisticdesign storm of 10 cm/hrwould temporarilycreate a potential storm water stream of 36,000 m3 /hr over thejareaof JLPP. The large coal storagearea north of the plant by itself could prodce 17,000m 3 of runoff per hour. This coal yardis I m lower than the powerhouse,thus isolatingthe coal pile runoff fromother JLPP drainage. Units 1 and 2 coal pile runoff is directedto the ocean via a singleoudet which passesthrough a settlingbasin. Storm water away from the powerhouseis collectedin catchbasins and drains to the sea via an open channel. Any storm water that may containoil, such as runoff from the transformer pad or from oil storagetank areas, is directedto an oil/waterseparator prior to discharge. The recoveredoil is used as No. 2 fuel oil, while the aqueousphase goes to the JLPP sewer system, and from there is dischargedinto the ocean via two 90 cm diameterconcrete outfalls situated near the JLPP plant Wastewater Boiler blowdown,and floor and equipmentwash water are dischargeddirectly to the sewer system. Sanitarywastewater flows throughseptic tanks for settlingbefore entenng the sewer network. Every buildingwith bathroomshas such a septictank, sized accordingto the expectednumber of users in the building. EIA 7-12 August 1, 1996 RADIAN- INTERNATIONAL9 Derriineralizer backwash and regeneration water, boiler acid cleaning wastewater, and air heater cleaning water are neutralized in a settling basin before discharge to the sea. 7.5.2 Present Treatment As discussedin the previoussection, wastewater treatment at presentconsists of the following: Settlingof storm water runofffrom the Units I and 2 coal pile; Oil/waterseparation of oily wastewater, Settlingand pH adjustmentof air heater/boilerwash water; Septictank settlingof sanitay wastewater,and pH neutralizationof veryacidic or basic effluents. 7.5.3 Treatment Criteria and Compliance The JLPP Projectguidelines are summarizedin Table 2-5. The existingplant condition as discussedin Section6.2.3 indicates that compliancewith Projectguidelines may not alwaysbe achieved: Two pH excursionsabove pH 9 weremeasured; It is unlikelythat the septic systemcan reduceBOD to the 50 mg/L level by itself, and no disinfectionof the effluentis performed;and TSS exceededthe 60 mglL standardin one of the wastewatersamples. Variousoptions are availableto addressthese concernsfor Units 1 and 2, as discussed below. Units 3 and 4 will be designedto meet Projectguidelines. 7.5.4 Wastewater Treatnent Options for Units 1 and 2 The followingoptions for treatmentof wastewatereffluents from Units I and 2 will be evaluatedfor possibleimplementation should monitoring indicate that Projectguidelines cannot be consistentlybe met EIA -7-13 August 1, 1996 RADIANE INTERNATIONALM 1) Unit 1 and 2 coal pile runoffis collectedin a settlingbasin. Effluents from this basin will be monitoredfor TSS and pH. If measuredvalues exceedProject guidelines,altematives such as increasingbasin size, adding neutralization capability,or combiningthe runoff water with that from the coal pile for Units 3 and 4 will be evaluated,and cost-effectivemeasures will be implemented. 2) Unit 1 and 2 sanitarywastewater effluents will be monitoredfor BOD5. If the measuredlevels exceedProject guidelines,altematives such as routing these effluentsto the sanitarywastewater treatment system for Units 3 and 4 will be evaluatedand cost-effectivemeasures will be implemented.The sanitary wastewatertreatment system for Units 3 and 4 will be sized for 300 people, and will employcomminuting pumps to lift the wastewaterto a treatmentsystem for removalof BOD and suspendedsolids. The effluentwill be disinfectedprior to discharge. 3) Location,calibration and use of pH monitoringequipment will be reviewedand upgradedas necessaryto assurethat effluentsfrom the neutralizationbasins are accuratelymonitored and pH adjustedprior to discharge. 7.6 Ash Disposal Alternatives The Project Sponsorsare committedto endingthe practiceof oceanash disposal once a reasonablealternative for disposingor marketingthe material can be implemented.To that end, an ash disposal optionsanalysis was conducted(Radian, 1996). Based on an analysisof the coal ash and projectedfuture coal consumptionrates for all four units, the volume of coal ash that wouldbe producedover the 30-yearconcession to operate the plant is approximately6.8 millionm 3 . The coal ash disposaloptions analysis considered disposalof this quantityof ash in a landfilland also evaluatedbeneficial reuse. 7.6.1 Landfill Sites Two areas were identifiedas potentiallandfill sites: a large abandonedquarry under the control of the Departmentof PublicWorks and a vacant area not suitable for farminglocated south of the JLPP. Theseare describedbelow and shown in Figure 7-3. The Quarry Site The quarryis located 5 kamnortheast of the plant, directlynorth of the main entranceto OCP. Paved roads lead from JLPP to the quarry and there is a well-gradedunpaved road that leads down into the quarry at the southwestcorner. The quarry is an irregularshape characterized EIA 7-14 August 1, 1996 " -AML INTERNATIONALM3 NTERNATIONAL .. 1 ) ~~~~~NORTH LEGEND ; : ~~~Tlanmifssion:^fg L~~~~~~~~~~~~~~ ."'~ ,~ ~ SCALE.METEfRS '-4,h000 *°*~A~'.' "~ 0 * EI 7-15 Augut 1, 199 site~~~~~~~~~~h Figure7^3. PotentialLandfill Siteslant EIA~ ~ ~ ~~iu 7-3. Potetia Lanfil996e RADIANE INTERNATIONAL by a fairly straight and long north face. There is a large shelf locatedon the east face starting in the northeast comer, and a lesser shelf about midwayalong the westem face. The land from which the quariy was mined had little naturalrelief, thus the top of the quarryhas very little change in elevation.The bottom of the quarrywas excavatedgenerally flat as well. The depth of the quarry,as measuredin severalplaces along the east vertical waUs,is approximately22 m. The surface area is approximately441,000 M 2 and the volume of the quarry is approximately 9.7 milion m3. The quarry has been knownto hold water from rains, howeverthere are no data yet availableto determinethe depth to groundwater.During the April 1996 site visit, shallowwater covereda relativelylarge area on the floor of the quarry,apparently not more than 1/2m deep. The major considerationfor use of the quarry as a landfillinclude the porous nature of the rock in the quarry floor and walls that was observedduring the site visit, uncertaintyof the depth to groundwater,and the potentialfor large volumesof surfacerun-on dunng storm events. Site South of the JLPP The land area south of the OCP dischargecanal betweenthe route and the ocean is characterzed by rollinghills. It is not in cultivationdue to the rocky soils. Based on observationsmade in the field, the rock that is exposedto the surfaceis boulder size or larger and thereforeit is improbablethat the land can be madearable. Also, the visiblemixture of rock and soil creates macro poreswhich make the rock and soil substrateporous in nature. This plot of land is roughly a parallelogramwith the long sides delineatedby the route and the beach or bluff. The short sides are delineatedby the OCPcanal and the bend in Route 121 at the south. The length along the highwayis approximately1200 m and the perpendicularwidth betweenthe route and the bluff is approximately375 m The area of this plot of land is 450,000m 2. However, allowing for a buffer and traffic in this area aroundthe landfill itself,the usable parcel for landflllingis assumedto be 350 m wide and 900 m long. Therefore,to hold the estimated 6.8 million m3 of ash, with an assumed3H: IV side slope on the ash pile, the landfill would have to be built to a maximumof approximately26 m high. This estimatedoes not account for the valley in the middle of the parcel of land. Themajor concemsfor considerationof this parcel of land for a landfill, from strictlya technical perspective,include the proximityto the ocean, the visibilityof the landfill from the EIA 7-16 August 1, 1996 RADIANU INTERNATIONALM route, the porous nature of the rock and soil substrate, and the proximity to the groundwater table. Comparison of the Two Sites The selectionof a landfill site should consider engineering,environmental, econormic, and political aspects as presented in Table 7-2. When the two sites are compared against these criteria, the quany emerges as the preferred site as shown in Table 7-3. Of the 21 specific criteria, the quarry is judged to be "acceptable" for all but six, "moderately acceptable" for five, and only "marginally acceptable" for one. The fields south of the JLPP are relatively less acceptable in several areas. 7.6.2 Description of Specific Landfilling Alternatives Six specificalternatives are identifiedand discussedbelow: Quarryfill in conditioned(moist) state using trucks. Quarryfill in conditionedstate usingrail. Fill in a slurrythat is piped to the quarry with leachatereturn to JLPP. Abovegroundfill in conditionedstate usingtrucks. Abovegroundfill in conditionedstate usingrail. Slurryfill in abovegroundimpoundment with leachatereturn to JLPP. Quarry Fill in Condffioned State Using Trucks This alternativemay be the casiestfrom the perspectiveof placingthe fill in the quarry,however the most difficultat the point where the ash is accumulated In this scenario,the ash is transferredto the storagesilos as it is now, and the fly ash is moistened(with approximately20% moisturecontent) through dustless unloaders into trucks. The trucks then drive to the quarryusing 7.5 km of existingroads and dump the ash to be spread and compacted by the landfill operator. The daily generationof ash is estimatedto be approximately620 m3, or approximately42 trucks per day. EIA 7-17 August 1, 1996 RALDLAN- INTERNATIONALU3 Table 7-2. General Criteria for Selecting an Ash Landfill Enineering Physical Size Sufficientarea must be providedto accommodatethe coal combustionby- Environumental productmaterial and related facilitiesfor their design life. The activeportion Criteria of the site shouldbe surroundedby at least 30 m of unoccupiedspace which servesas a bufferzone betweenthe disposalarea and the site boundary. Proximity * The landfillsite shouldbe as close as possibleto the powerplant to minimize _ansporaoncosts. Site Access * The selectedsite must have sufficientaccess for constructionpurposes as well as for deliveryof by-productduring operation.Using trucks to transport the ash to the landfillsite includesconsideration of environmentalfactors such as safety,noise, and fugitivedust emissions.Further, the transportation route must be of adequatewidth and load capacity. Topography The site shouldbe able to be developedwith a minimnumof earnhmoving activityby using the natual contourof the land. Minimalsite preparation shouldbe requiredfor divertingsurface drainage away from the active disposaloperations. Small valleys and ravinesmay be advantageoussince they are capableof receivinglarge volumeswithout cxtensivemodifications to the naturaltopography. Geolouy Geotechnicalhazard areas (suchas thoseprone to slides and faults), as well as areas vwthunderlying, adjacent, or interconnectedmines, quarries, sikholes, or solutioncavitics should be avoided.The strengthof the underlyingstrata shouldbe capableof supportingany of the necessary surfacestructures. Soils * There shouldbe an adequatedepth of soil betweenthe base of the disposal area and groundwater.The availabilityof sufficientclay materialfor use as a low-permeabilityin situ or remoldedliner is also an advantage.Suitable constructionmaterials for dikes, besms,and final cover shouldbe available. The finalcover materialshould be capableof inhibitingwater flow and of developinga good standof vegetation,if growingconditions permit Surface Water * Thesite shouldbe locatedoutside the 10-year flood plain to prevent inundation.Locations near surfacewater should be avoidedwhenever possible. Groundwater * Groundwatcrcontamination is less likelyto occur where there is sufficient depth betweenthe bottomof the landfilland the historicalseasonal high groundwatertable. Preventingcontammation is particularlyimportant where the site overliesan aquiferwhich is eitherpotentially or presentlyused as a watersupply. The potentialeffect on water supplies,both groundwaterand surfacewater, should be consideredin the site location.In addition,the site's effecton groundwaterquantity and qualityshould be minmzed by locating awayfom groundwaterrecharge areas. Air Wind intensityand diretion shouldbe considered,particularly with regardto minimiing the effectsof fugitiveemissions from dry transportand disposal. EIA 7-18 August 1, 1996 RADUIN- INTERNATIONALES Table 7-2. (Continued) Engineering/ Terrestrial and . The alteration of any unique habitat should be avoided. Detrimental effects Environmental Aquatic Ecology on any rare or endangered species (resident or migratory) must be prevented. Criteria (Confinued) Noise * The local effects of transportation, construction, and operation should be minimized. Land Use Populated areas and areas of conflicting land use, such as parks, nature preserves,wilderness areas, and airports,should be avoided.The use of potentialfarm and timberland shouldbe minimized.The site shouldhave the capabilityfor beneficialland use at the terminationof disposaloperations. Scenicand * Sitesshould be visuallyisolated as muchas possible.Visual effects should be Aesthetic minimizedby maintainingnatural barriers such as a ridge of groundor a belt Effects of trees.The presenceof suchnatural barriers may precludethe need for constructingartificial screening devices. Cultural Uniquearchaeological, historical, and paleontologicalareas should be Resources avoided.A thorougharchaeological investigation should be performedat each site. Economic Transportation Considerthe distanceby-products will be transported.Tne major cost Criteria Costs considerationin siteselection is locatingthe disposalsite as closeto the generatingstation as possibleso as to minimizetransport costs. Property Considerease of acquisition,actual land costs, and indirectcosts suchas Acquisition legalfees, realtorcosts, and relateditems. Considerations Site * Considerfactors relating to site developmentand constructionsuch as Development excavation,grading, and newroads. Costs Conditioning Consideron-site availability of clay,gravel, and other constructionmaterials. costs Cosure Costs Considerthe expenseof the finalcovering of the site and preparingit for subsequentland use. Post-Closure * Costof maintainingand monitoringthe site duringthe post-closureperiod, Costs whichmay extend 30 yearsafter closure. Salvage Costs Considerthe valueof land afterthe site is closed. EIA 7-19 August 1, 1996 [NTERNATIONALM Table 7-3. Qualitative Analysis of Design Criteria for Two Landfill Sites Jorf Lasfar Power Plant, Morocco EngineenngtEnvxronrnentalCntena Physical Size I I Proximity O I Site Access aO Topography I I Geology I I Soils D 0 SurfaceWater I Groundwater O O Air I Ecology I I Noise I I LandUs AestheticEffects I O CulturalResources _ EconomicCriteria TransportationCosts ! ° Property AcquisitionConsiderations | O SiteDevelopment Costs | ConditioningCosts O ClosureCosts I O Post-ClosureCosts U O SalvageCosts T 3=Acceptable O = Moderate 0 = Marginal EIA 7-20 August 1, 1996 RADIANX INTERNATIONALDIS The use of the quarnyas a fill site, regardless of the method of transport, has an added benefit of the potential reuse of the land for industrial development. The quarry in its current state is not a desirable location for a manufacturing or other industrial operation. However, if the quarry is filled to the original grade, it could be developed for other use. The fill could be staged in 5-yearor 10-year cells such that a portion of the quarnycould be released for further development at the end of each period, assuming the density of the fill material would meet applicable building codes. A protective liner and leachate collection system may be required to prevent contamination of the groundwater. QuarryFill in MoistenedState UsingRail Using this alternative, the ash is transfenred from the existing silos into rail cars. This would require the construction of new rail sidings at the plant to route rail cars under the existing hoppers. Furthermore, a rail spur off the existing system leading into the quany with an ash off- loading system would need to be constructed. Although much is required in capital investments, this altemative is more attractive operationally. There is no increase in automotive traffic, either in the plant or on the road. The ash would need to be transferred at the quarry using heavy equipment to the permanent landfill area. A protective liner and leachate collection system may be required to prevent contamination of the groundwater. Quarry Fill in SlurryState In this altemative, the ash is slurned with plant water and pumped up to the quarry. The elevation difference between the plant site and the current bottom of the quarry is approximately 31 m. This represents a significant head requirement and subsequent power requirement to pump the slurry up 31 m and over 5 1CnLAlso, the supemate would need to be collected and retumed to the plant for reuse. Capital costs will be greater for this option than hauling but operational costs may be lower. The leachate that would drain from such an operation is voluminous, therefore a large and elaborate settling basin and leachate collection system would be needed. A liner would need tobe EIA 7-21 August 1, 1996 RADLANE INTERNATIONALM constructedbeneath the landfillin orderto assureprotection of the groundwaterfrom the leachate,which will likely containheavy metals from the ash. Aboveground Fill in Conditioned State The disadvantagesand advantagesof a truck systemare no differentwhether the ash goes to the quarTyor to the field south of the plant. However,the distanceto the fields south of the plant is much less. Operationally,the fill would be placed in lifts on the existingterrain and compactedin place. It wouldbe necessaryto develophaul roads and heavyequipment maintenancefacilities. Protectionof the surroundingenvironment would be necessary,such as fugitive dust control and storm water run-onprevention and run-offcontrol. A protectiveliner and leachatecollection system may be requiredto preventcontaniination of the groundwater. Aboveground Fill Using Rail The requirementfor using this site as a landfillwith a rail deliverysystem are no different than using the quarry,except more considerationmust be givento preventingdust from wind erosion. The same capital improvementswould be required. The rail spurto this site would be requiredto cross the canal from the OCP,thus requiringa railroadbridge or, at least, a large culvert Aboveground Fill in Slurry State Due to proximityto the oceanand the assumedshallow groundwater table, a landfillliner and supematereturn system would need to be built to supportand collectthe large volume of liquid inherentin this system. The retentionof solids as the liquiddrains out would also need to be considered. 7.6.3 Selection of a Preferred Landfilling Altemative If there are no unforeseenimpediments to land acquisition,backfill of the quarry would appearto be the better land disposalaltemative based on the site selectioncriteria and the potentialfor reuse once the quarryis partiallyor completelyfilled. How the ash would be transportedis a matter of designand cost The major advantagefor the southernfields site is the shortertransportation distance. The ProjectSponsors have initiatedactivities to determinethe availabilityand detailedtechnical suitability of both sites. EIA 7-22 August 1, 1996 RZADIAN- INTERNATIONALM3 7.6.4 Identification of Non-landfilling Alternatives The two primary non-landfilling alternatives are beneficial uses within Morocco and retuming the ash to the coal supplier, in the same ships that carry the imported coal, for beneficial use elsewhere. Retum Ash to Coal Supplier The option of remuningthe fly ash and bottom ash to the coal supplier may be implemented provided the supplier is willing and able to accept these materials at a cost less than that of other options. Several power plants on the Mediterranean Sea currently have coal supply contracts that provide for this (Odom, 1996). The transporting mechanisms however, may require modification for transferring the ash to the port location and for loading of the ships with the ash. For example, the ash materials (in a dry state) could be transferred from the existing storage silo and into rail cars for transport along the existing rail spur. The ash materials could be pneumatically off-loaded via the ship. A major consideration with this alternative is that the rail cars could be used as the temporary storage mechanism at the seaport when coordinating schedules for off-loading the by-products to the transporting ship. The advantages and disadvantages of this altemnativeare summarized below. Advantages: future liability associated with disposal is limited, dryness of the by-products would be maintained, engineering/design modifications to existing strctures could be easily retrofitted, ash could be batch loaded in bulk shipments, and operation and maintenance (O&M) cost for maintaining transfer equipment are expected to be minimal due to limited manpower and maintenance requirements. Disadvantages include: 0. all collected ash material must be kept dry, *- initial capital cost may be required for adding storage capacity dependent on schedule to coordinate ash shipments, and emissions during tramsfer operations will require controls. EIA 7-23 August 1, 1996 RADUtN- INTERNATIONALm BeneficialUse of Ash The quantityof ash utilized as raw materialsor replacementmaterials has increased over the last two decades. Specifically,high volumeuses of fly ash are typifiedby structure fills, embanrkments,base courses for road surfaces,soil stabilization,soil amendmentand as partial replacementin concrete. Other uses includeadding fly ash to flue gas desulfurizationprocesses either as an absorbentor absorbentamendment, and for waste stabilization. The use and marketabilityof fly ash in making concreteis predicatedon the specification requirementsand specificconstruction codes. The localmunicipalities and constructioncodes in Moroccowould need to be assessedto determineif the fly ash meetsthe appropriate specificationsand to determineif there are interestedvendors within the immediatearea. If the marketappears to be positive,then an assessmentof the qualityand quantityof the fly ash needed could be verified. There are severalpotential advantages for selectingthis alternative,including reduction of disposalliability, reductionof O&Mcost, and acceptanceby environmentalgroups and public. 'Thedisadvantages include exacting specifications by vendorsand the distanceto ready-mix concreteand cement plantsmay result in transportationcost in excess of the valueof the ash. Use in Cement Manufacturing Fly ash can be used as partialreplacement for feedstockto the kiln in the manufactureof Portlandcement. For example,cement manufacturers require certainproportions of silica, alumina,calcium, magnesium, iron, and other trace and majorelements and oxides. This replacementis acceptableas longas the mineral compositioncan supplementother feedstocks, such as clay, limestone,shell, or cementrock. The advantagesof feedingdirectly to the kiln, as opposedto adding to the product (admiixture),is that specificationsfor loss on ignitionand moistur content are not nearly as stringent. Agricultural Use By blendingfly ash with compactedsoil the pore space betweensoil particlesis increased and surface crustingis diminished. As additionalporosity is provided,the soil retains more water and nutients for plant growth. Also increasingthe pore space in the soil enhancesplant root growth into the subsurfacesoil. Otherapplications where soil amendmentshave been shown to be beneficialinclude mixing fly ash to promotegrowth of turf-grass(e.g., golf courses). EIA 7-24 August 1, 1996 RADIAN- INTERNATIONAL!3 An assessment of farmlands located within the proximity of the power station would be required to determine if such applications are feasible. For this option to be viable, the farnlands would have to be of sufficient size to support periodic applications of the fly ash to the native soils. An assessment of the soil conditioning requirement for certain crops also would have to be evaluated to ensure that the chemical properties (e.g., pH, metals) of the fly ash would not be detrimental to crop species. Beneficial Use in Road Construction and Other Fill Applications Recent surveys have shown beneficial use of fly ash and bottom ash for road grade and base foundations to support construction of roads, parking lots, and runways (EPRI, 1988). Fly ash can be used to amend soils and strengthen the subgrade at a relatively low cost. Fly ash as part of base or subbase courses can be used in the following three principal ways: (1) in combination with lime and/or Portland cement; (2) in combination with lime or Portland cement separately; and (3) in combination with on-site borrow soils with or without the inclusion of lime. The formulation of these materials for a subsurface preparation is used as an alternative to a full depth asphalt base course, or an all aggregate base course. Fill Use Fll application of fly ash has been used successfully as reported by various power companies (DOE, 1990). FllWapplications include backfills, embankments, and site fills. The utilization of fly ash as a fill material is a direct result of the physical/engineering properties that the coal combustion by-products offer (e.g., low unit weight, high strength, low compressibility), and cost when compared to natural borrow material. The coal by-products may be conditioned before transporting to allow delivery at a specified moisture content dependent on application. Flll material can be broken down into four general applications: (1) backfills for bridge abutments and utility trenches, (2) roadway embankments, (3) site development fills, and (4) repair or stabilization of landslides. Coal Ash Utilization Summary In summary combustion byproducts such as fly ash and bottom ash can be a viable resource that offset the use of raw materials and mitigate disposal liability. In many countries, social, economic, and political incentives to avoid disposal of coal ash are present. The avoided cost of disposal weighs heavily in the overall economics, directly fostering utilization of by- products. As a result of these factors, the Europeans, for example, have focused their markets to EIA 7-25 August 1, 1996 RADIAN- INTERNATIONALE3 use fly ash in productionof clay bricks,aerated constructionblocks, and syntheticaggregates to be used in a varietyof concreteapplications. 7.6.5 Ranking of Altematives and Conclusions The most advantageousalternative to oceandumping of the ash by-productmaterial is beneficialreuse. There are basicaly two generalmethods for achievingthis advantage:returning the ash to the coal supplierfor beneficialreuse outsideof Morocco,or developingmarkets within Morocco.In either case, the ash could be put to beneficialuse in the cementand concrete industry,in agncultunalsettings, or in the constructionindustry. Furthermore, the use of ash as a resourceis not resticted to any particularindustry but can be put to use in all these areas. It is currentlyanticipated that beneficialuse of all of the ash will be either impracticalor cost-prohibitive.Therefore, the ProjectSponsors have initiatedactivities to determinethe availabilityand detailedtechnical suitability of two sites which appearto meet generlly accepted criteria for siting an ash landfill. The result of these activities will be a preliminarydesign and cost estimatefor developingand using an ash landfillwhich is protectiveof the environmentand capableof reeiving all of the ash anticipatedto be generatedover the 30 yearsof the JLPP concession. EIA 7-26 August 1, 1996 INTERNATIONALM 8.0 MITIGATIONAND ENVIRONMENTALMANAGEMENT PLAN This section describes the measures that will be taken to avoid, reduce, or compensate for any potential impacts from the proposed Project. The mitigation measures described below are based on best professional judgments from the environment assessment team and thorough review of mitigation measures recommended by the World Bank (World Bank, 1995). 8.1 MitigationDuring Construction Potential environmental and human health impacts during construction include: increased fugitive dust emissions, soil erosion, storm water runoff and sediment loading, groundwater contamination, and worker health hazards. The mitigation measures are discussed below. 8.1.1 Air Quality Fugitive dust emissions from excavation, construction, and vehicular traffic at the construction site can affect the air quality of the site. To mitigate increased fugitive dust emissions, dust suppression control methods, such as spraying water on roads or dirt areas will be applied. Trucks carying fine material may be sprayed or covered as necessary to reduce the generation of dust. To futher reduce dust generation and exhaust emissions, vehicular speeds will be controlled, and buses will be used to wansport workers to and from the Project site. 8.1.2 Surface Water Quality Erosion control measures will be implemented as necessary to prevent storm water runoff from carrying sediment and/or surface water contamination to drainage areas and the Atlantic Ocean. Some typical construction practices which may be used to control storm water runoff and sediment loading from the Project site include: Construction of site retention areas or sediment retention ponds to handle storm water runoff; Installation of silt curtains, hay bales, or other temporary erosion control measures; EIA 8-1 August 1, 1996 INTERNATIONALM Diversionof runoff from undisturbedareas aroundconstruction areas; and Implementationof spillprevention and clean up practicesto prevent contaminationof storm water runoff(e.g., oil and grease from construction equipment). 8.1.3 Groundwater Quality During construction,suspended solids and other contaminants(e.g., oil and grease) can infiltrateto the shallowaquiferous zone and impactthe groundwater. Spill preventionmeasures and clean up will be implementedas necessaryto prevent groundwatercontamination. Also, dewateringmethods may be appliedto remove surfacewater and shalow groundwaterfrom pooling in excavationareas and prevent possiblecontamination or sedimentloading from constructionactivities. 8.1.4 Worker Health and Safety A health and safetyplan incorporatmgOPIC and Ex-In safetystandards and Moroccan codes for worker health and safetywill be implementedfor the constructionof Units 3 and 4. 8.2 MitigationDuring Operation This section discussesthe mitigationmeasures that will be implementedduring operation of the JLPP facility by the Project Sponsors. Potentialimpacts related to ash disposal, wastewatertreatment, surface water quality,groundwater quality, air quality and worker health and safetyare addressedbelow. 8.2.1 Ash Disposal Ash disposalat sea will be eliminatedand replacedwith land disposaland/or utilization of the ash once an acceptableoption is establishedby the Project Sponsors. The landfill will be designedand constructedwith appropriategroundwater protection systems to prevent leaching into the soil and groundwater. The designof the systemwill be predicatedupon the geologyof the site. If truck transportof coal ash is used, appropriatetraffic signalsand other controls will be implementedto prevent highwaycongestion and accidentsfrom increasedtraffic. Also, measureswill be taken to prevent fugitivedust generationwhile haulingthe ash to its destination. EIA 8-2 August 1, 1996 RADIANN INTERNATIONAL3 Ash placed in the landfill will be compacted so that the site can be beneficially utilized after it is filled. 8.2.2 Wastewater Discharge and Surface Water Quality As described in previous sections, wastewater will be treated and discharged to the Atlantic Ocean. As indicated in Section 9, a wastewater monitoring program will be implemented to monitor discharges. Although aD discharges are expected to be within Project gliidelines, monitored values outside of those guidelines will be cause for prompt investigation and corrective action. 8.2.3 Air Quality Emissions of SO2 and NO. from the four JLPP Units are expected to meet Project gwudelinesfor the current coals being considered. The use of low sulfur coals (annual average sulfur content of less than 1.25 wt %) will meet both the stack emissions and ambient air quality Project guidelines. Section 9 details the monitoring methods that will be utilized by the JLPP Operator to assure adherence to the Project guidelines for SO2 emissions. NO. emissions within the Project guidelines can be maintained through the proper operation and maintenance of coal bumers and registers. All four units are designed to achieve the Project guidelines. Therefore, no mitigation is required. Particulate emissions from Units 3 and 4 are expected to achieve compliance with the Project guidelines at all times for all coals being considered. The ESP supplier has provided a performance guarantee that corresponds to the Project guideline of 50 mg/m3 . Adherence to the Project guidelines for PM emissions on Units 1 and 2 has been demonsted through stack testng. The Project Sponsors will conduct periodic testing of particulate emissions while burning representative coals to assure that adherence with the Project guideline of 125 mg/m3 will be maintained. In the event that emissions of PM exceed Project guidelines, the Project Sponsors will initiate a study to determine which cost effective alternative PM control measures can be used for mitigation. EIA 8-3 August 1, 1996 RADIANE INTERNATIONALL3 In additionto stack discharges,emissions from other sources can be minimizedby regularly sprayingthe coal pile and unpavedroads with water to reduce fugitivedust emissions, and by implementinggood housekeepingto minimizeVOC emissionsfrom paints, solvents, cleaningfluids, and fuel oil. 8.2.4 Worker Health and Safety An environmentalmanagement plan (as describedin Section8.3) as well as a worker health and safetyplan will be implementedto promoteand maintainsafe and environmentally soundoperation practices at lLPP. 8.2.5 Other Operation Impacts Lighting will be installedas requiredon stacks for aircraft waming. Additionally,the Project Sponsorswill provide landscaping. Traffic signalsand other controls will be installedalong roadwaysto the plant if deemed necessary.Bus tansport of JLPP workersis expectedto continueafter the constructon of the new units, which will reduce trafficcongestion along Route 121. Project Sponsorshave the incentiveto build and operatethe JLPP in the most efficient mannerpossible. Efficientconstruction and operationwill minimizethe generationof waste and its adverseeffects on the environment. 8.3 EnvironmentalManagement and Training 8.3.1 EnvironmentalManagement Implementation Plan A subsidiaryof CMS GenerationCo., as Oprator of the Project,is obligatedunder the operationsand mantenance agreementto operatethe JLPP in such a manner that it complies with the JLPP Project guidelinesin Table 2-5. In additionto the specificmitigation and monitoringactivities to be implementedas describedin other sectionsof this EIA, the Operator has developeda comprehensiveenvirnmental managementimplementation plan (the Plan) which defines genericroles, responsibilitiesand activitiesto be implementedat any facilityit operates,to assureenvironmental protection and compliancewith requirements.A copy of the EIA 8-4 August 1, 1996 INTERNATIONAL3 Plan is included in Appendix D. Major elements of the plan, with specific applicability to the Jorf Lasfar project, are described below: Environmental Policy Statement-All CMS environmental activities are based on implementation of this policy. It requires compliance with environmental requirements, planning and actions in support of environmental protection, communication of enviromnental issues, establishment of responsibility for environmental performance, development of standards and procedures to implement the policy, and regular review of internal conformance with the policy. It is endorsed by the President and Chief Executive Officer of CMS. jOrg -As described in the Plan, CMS has assigned responsibility for environmental management activities throughout the organizaton. For the day- to-day activities associated with operation of the Project, the Plant Manager or a designated Site Environmental Coordinator will talce the lead responsibility for environmental managementand protection activities at the site. The CMS Manager of Environmental Affairs will, as needed, provide support to the site and periodic assessment of site envirommentalmanagement activities. Co_porate Standards-CMS corporate environmental standards establish expectations and responsibilities for the performance of generic enviromnental management activities. A complete set of these standards is also included in Appendix D. A detailed description of how these standards will be implemented at the Jorf Lasfar site is given in Section 83.2 below. Environmental Reauirements-Applicable environmental requirements are required to be documented at each CMS-operated facility. Upon take-over of operations, the Plant Manager or Site Environmental Coordinator will work with the Manager of EnvironmentalAffairs to identify applicable regulatory and permit environmental requirements to assure that they are understood and documented at the site. French and English copies of this EIA will also be maintained at the site to document mitigation and monitoring commitments. Plant Proldures-The Plant Manager or Site Environmental Coordinator will determine the content of specific plant procedures to implement environmental protection and compliance activities at the site. At a minimum, procedures or plans to be developed during the first year of operation will address the following: - an environmental emergency response plan, as described in Corporate Standard ENV-CMS-008; EIA 8-5 August 1,1996 RARIAN- INTERNATIONALIM a hazardousmaterials management plan, to assure that hazardousmaterials and their associatedrisks are identified,and that appropriatematerial purchasing,handling, storage, use and disposalcontrols are in place; a waste managementplan, to includeevaluation of plant waste streams, and proceduresfor wastehandling, storage,labeling, shipping and disposal,with the goal of identifyingopportunities to reduce the toxicityor volume of specificwastes, change formulationsto less pollutingmaterials, or find beneficialuse for plant wastes (e.g.,ash); operations,maintenance, test and calibrationprocedures for environmental monitoringand controlequipment; and - bulk chemicaland liquidfuel unloadingprocedures. Feedbackand Improvement- Processesand activitiesare built into the Plan to assure continuousimprovement of the environmentalmanagement program. Audits, assessments,reportng, commuimcationand trainingwill providefeedback and improvement,as describedin Section 8.3.2 below. 8.3.2 Implementationof CorporateStandards CMS requires compliancewith the CorporateStandards included in AppendixD by each facility it operates. The significanceof these standardsfor the JLPP project is describedbelow. Acguisitionand Possessionof Permits (ENV-CMS-001)requires the facility to have a copy of all applicablepermits and approvalson-site and to obtain all permits or approvalsrequired for site modifications. Compliancewith Requirements(ENV-CMS-002) requires the facilityto comply with all permit and non-permitenvironmental requirements, and to develop facility-specificprocedues as neededto documentand implementenvironmental complianceactivities. It also recommendsthe designationof a Site EnvironmentalCoordinator. This standardensures that facility managementis awareof environmentalrequirements, and will put in place the organizationaland financial resourcesnecessary to assure compliancewith permit and regulatory requirements. CommitmentSchedule (ENV-CMS-003) requires the facility to developan annual schedule describingenvironmental inspection, monitoring, reporting, notification, training, recordsmanagement and other similarpenodic commitment requirements. This ensures that the facilitywill have an organizedsummary of all periodic requirements,including those requiredby pennit, regulation,and EIA 8-6 August 1,1996 RADUIAN I NTERNATIONALM3 commitments made in this EIA. This schedule will be developed during the first year of operation. Trainins (ENV-CMS-004) requires that all employees receive environmental training commensurate with their job responsibilities. This ensures that all employees will have a basic awareness of how their work potentially impacts the environment and of things they can do to minimize those impacts. It also assures that employees whose jobs involve specific environmental compliance or protection activities receive training, as needed, to properly carry out those activities. Initial training on the CMS Generation environmental management implementation plan, CMS Corporate Standards, applicable permit and regulatory environmental requirements and other commitments will be provided to the Plant Manager and Site Environmental Coordinator by the CMS Generation Environmental Affairs Departnent. The first round of envirommentaltraining will be completed during the first year of operation. Environmental Excellence (ENV-CMS-005) encourages CMS-operated facilities to achieve high levels of compliance with emission and discharge limits, and seek opportnities to minimize waste. Annual awards are given to the top peiforming facilities, and the Plant Manager will be asked to accept the challenge of operating at the high compliance levels necessary to win an award. Age_ncvMeetingslDiscussions (ENV-CMS-006) and Agencv Inspections (ENV- CMS-007) authorize the Plant Manager or other facility staff to communicate directly with representatives of govemmental agencies on environmental matters. Significant issues are required to be communicated to CMS management Response to Environmental Emergencies(ENV-CMS-008) requires the facility to develop an environmental emergency response plan to guide facility response to an actual or potential significant release (spill, gas leak, explosion, etc.) to the environment, and to notify CMS management if an environmental emergency occurs. The plan will enable plant personnel to take proper actions to prevent, minimize or control and contain releases, to notify the proper authorties as necessary, and to initate any aproprnate clean-up and disposal activities. Periodic Routine Reporuing(ENTV-CMS-009). Nonroutine Reporting (ENV-CMS- 010). and Notice of Violations (NOVs). Citations. Enforcement Actions (ENV- CMS-411) require the facility to handle routine communication with govemment environmental agencies and to keep CMS management informed monthly on the status of facility environmental compliance activities. The facility is also required to notify CMS management as soon as possible of any unusual or significant environmental issue or action taken against the facility. EIA 8-7 August 1, 1996 RAMDIANE INTERNATIONALM Recordkeeping(ENV-CMS-012) requires the facility to maintain site environmentalfiles for the primarystorage of all permits,standards, requirements, procedures,monitoring data, reports, subnittals, correspondence,training documentationand other site-relatedenvironmental records (such as a copy of this EIA). Audits, Assessmentsand Appiraisals(ENV-CMS-013) requires that the facility receiveperiodic internal and independentassessments of its compliancewith requirementsand commitmentsand of the qualityof its environmental managementactivities. Such assessmentswill be scheduledfor two out of every three years, and the results will be used to improvesite complianceprograms. EIA 8-8 August 1, 1996 RADIAN- INTERNATIONALIM 9.0 MONITORINGPLAN This section describesthe proposedactivities, methods, and frequenciesfor monitoring, recordkeeping, and.reporting environmental discharges and potentialimpacts from the proposed Project.Table 9-1 sumnmarizesthe monitoring,record keeping and reportingactivities that will occur during the constructionphase and during operationsof the existingtwo units and after Units 3 and 4 are completed. As requiredby the lendersand the Moroccanauthorities, the Project Sponsorswill developan annualenvironmental report which will includethe data describedbelow. Recordswill be maintainedat the site for a periodof at least five years. 9.1 Monitoringand Reportingof ConstructionImpacts Duringthe constructionphase of the Project,fugitive dust monitoringwill be accom- plishedvia two methods: 1) ongoingambient air qualitysampling being conductedby the Project Sponsors, includingPM and PM1O,will take placeuntil May of 1997;and 2) visualobservations of road dust will be madeby Projectrepresentatives when conditions exist that fosterhigh fugitive dust releases. Drums, tanks, and hazardousmaterial storage areas will be routinelyinspected by Project representativesto confirmthat properhousekeeping and hazardousmaterial handling procedures are being followed. Any spills or leaks foundduring the inspectionwill be reportedto the constructioncontractor for cleanup. 92 Monitoringof OperationalImpacts Ongoingmonitonng, record keeping and reportng for the operationalunits will be performedby the Operator. The needfor monitoringis delineatedin the lenders' guidelinesas well as in the CMS CorporateStandards. The subsectionsbelow describethe types of monitoring,record keeping and reportingthat the Operatorwill be performing. Table 9-1 summarizesthe types of operationalmonitoring that will occur at JLPP. 9.2.1 Air Quality Currently,JLPP is conductingambient air monitoringto determinethe baseline NO,, S02, and PM and PM1Oconcentrations that exist in the vicinityof JLPP. Thisbaseline will include the existingimpacts associated with al emissionsources of SO2, NO1, and PM in the region, includingJLPP Units 1 and 2. After 12 monthsof monitoringis complete,the Project Sponsorswill re-examinethe air dispersionmodeling analysis performed for this report EIA 9-1 August 1,1996 Table9-1. Summaryof Monitoring,Recordkeeping, and Reportingto be Conductedat JLPP |:ihase ... Categor: I Uequey. , ;- .,.I~kdkeepln [. Reporttng Construction FugitiveDust Ongoingbaseline ambient air monitoring will If excessivefugitive dust is Annualreport required O detectconstruction dust during Initial detected,mitigation measure by lendersand Moroccan z constructionphase. Thereafter visual appliedand recorded. government. r observationof dust, Hazardousmaterials Thecondition of tanksand drums containing If spill is noted,describe In annualreport spills hazardousmaterial will beroutinely Inspected material,amount, cause, and cleanup methods utilized. Operations Groundwater Annualsampling for oil andgrease, heavy Maintainlaboratory analysis and In annualreport. metals,pH, and conductivity at existingwells. watertable depth for 5 yearsat a minimum. WasteWater -Monthlysampling of pH,temperature, residual Maintainlogs of samplingdates In annualreport chlorine. andlaboratory analysis for 5 -Monthlysampling of heavymetals and yearsat a minimum. biologicaloxygen demand. -Samplingat all outfalls. Air Emissions -Annualtesting of eachunit individually. Includestack test report in In annualreport -Pollutants-SO 2, NO, PM annualreport. Maintain for 5 -Unitload during testing to beat 80%or yearsat a minimum greaterof ratedoutput. BaselineAmbient Air -May1996 - May 1997(12 months) Maintainfor 5 yearsat a In annualreport Quality -PollutantsSO2, TSP. PM 1O,NO. minimum OperationalAmbient -12months after Unit 4 becomesoperational Maintainfor 5 yearsat a In annualreport > Air Quality -Pollutants- S02, TSP,PM 10, NO. minimum Noise/SourceTesting -Onetime only Maintainfor 5 yearsat a In annualreport -All sourcesfor whichcontractor guarantees minimum sourcelevels Noise/Occupational -Annualmeasurement Maintainfor 5 yearsat a In annualreport a______-Identifyzones 85 dBA minimum Air -Annualmeasurement r Maintainfor 5 yearsat a In annualreport . quality/Occupaonal-Pollutants - CO NO 1, PM10, SO, minimum RAD1INA INTERNATIONAL3 Results of the 12 month ambient air quality monitoring will be used to establish the background/baseline air quality. These data will be compared with the project ambient air quality guidelines to determine the following: The classification of the region with respect to the project guidelines for each monitored pollutant; The allowable World Bank Criterion II incremental impact for SO2; The predicted incremental impact of JLPP Units 3 and 4 on ambient air quality for each pollutant monitored; and The predicted ambient concentration of monitored pollutants compared with the project ambient air quality guidelines, both long and short term. The Operator will perform annual stack tests for SO2 , NO., and PM for all units, while runming at 80% capacity or greater. The results of the stack tests will be reported to the appropriate lending institution annually along with all other environmental monitoring results. World Bank guidance indicates that additional ambient air quality monitoring should be per- formed after completion and start-up of Unit 4. The Project Sponsors will use the same equipment that is currently being used to establish the baseline concentrations to perform this post-construction monitoring. The duration of this additional ambient monitoring will be negotiated with the lending institLtions after Unit 4 construction is completed. Occupational air quality testing for CO, NO., PM and SO2 will be performed annually by the Operator to determine potential exposure levels to JLPP workers. Results of this sampling will be included in the annual environmental report 9.2.2 Water Quality Monthly sampling and analysis of all wastewater outfalls for pH, temperature, oils and grease, and total suspended solids will be performed by the Operator. Total residual chlorine will be monitored once per month in the condenser cooling water discharge and BOD5 will be monitored in the sanitary wastewater outfall. EIA 9-3 August 1, 1996 INTERNATIONAL15 Annual groundwater sampling of the existing wells will also be conducted and analyzed for oil and grease, heavy metals, pH and conductivity. The results of all wastewater analysis and groundwater analysis will be summarized and included in the annual environmental report for the lending institutions. All data will be maintained at the site for at least five years. 92.3 Noise Both occupational and source testing will be performed to determine if the facility is producing unacceptable noise levels. The equipment listed in Table 9-2 will be source tested once to determine if it complies with vendor guarntees (also shown in Table 9-2). Occupational testing will occur annually. Based on this testing, the JLPP Operator will identify any areas in the plant that require hearing protection. Table 9-2. Noise Source Performance Guarantees1 for Specific Equipment at JLPP Units 3 and 4 Equipment (a~Lt1m unless otherwisenoftd) Safety valves (when blowing) <95 dBA at 30 m -HP and LPtubine bypass <1lO dBA Turbine generator < 90 dBA _ All other equipment <88 dBA a Diesel building exteior < 85 dBA Along site boundary < 65 dBA 'Perfonance guatees in Tecal ScopeDocmut AppendixB. TurnkCyConsuion Apeemeat (OcL9, 1995). 2A11maasuremeus and calculationsate acwrdingto ANSISL36, 1979edition (dBA is A-weighteddecibels). 9.2.4 Solid Waste Disposal The loading and hauling of coal ash, if handled via trucks, may produce an additional source of fugitive dust at the JLPP. Therefore, the handling of coal ash before disposal will be visually monitored to determine if unacceptable levels of fugitive dust are being generated. Mitigative measures such as covering or wetting the ash before being hauled off the facility will be taken to reduce the quantity of dust released. EIA 9-4 August 1, 1996 INTERNATIONALM The Operatorwill maintainrecords of the amountsof fly ash and bottom ash that are beneficiallyre-used and a summaryof the amountsand correspondinguses will be reportedto the lendinginstitutions in the annualenvironmental report. EIA 9-5 August 1, 1996 I INTERNATIONAL3 10.0 INTERAGENCYCOORDINATION AND PUBLIC PARTICIPATION The interagency coordination and public participation process included meetings between the Project Sponsors and various Moroccan agencies and discussions with the public and various non-governmental organizations. In addition, this EIA has been reviewed by the Moroccan Ministry of the Environment and several other Moroccan government ministries. Prior to the preparation of this EIA, the Project Sponsors and Radian met with the following agencies to gather information and establish contacts: Office Nationale de l'Electricite (ONE); Ministere de l¶Environnement(ME); Office d¶Exploitationdes Ports (ODEP); Office of the Govemnorof the Province of El Jadida, and Office of the Caid of the Commune of Moulay Abdellah. The remainder of this section summarizes the two meetings held with public. Pursuant to the World Bank Operational Directive 4.0, Chapter 7, public and NGO forums to discuss the proposed Project were held in El Jadida and Casablanca on July 11 and July 12, 1996, respectively. The forums were hosted by AFAK, (meaning "Horizon" in Arabic) a Moroccan NGO dedicated to informing the Moroccan public and to improving the quality of life for the people of Morocco. The purpose of the forums was to: 1) inform the public about the scope of the proposed Project; 2) inform the public of the environmental and socioeconomic impacts associated with the proposed Project; and 3) solicit input from the public conceming the scope of the EIA, the methodologies employed, the data and information presented in the ElIAand other concerns. According to AFAK and other NGOs, this was the first forum of its type in Morocco and thus there was strong interest from the Moroccan government, the public, and the participating NGOs. EIA 10-1 August 1, 1996 RADIAN- INTERNATIONAL1 10.1 Forum Presentation Summary Both the citizens forum and the NGO forum consisted of a series of presentations by AFAK, ONE, the Project Sponsors, and Radian International, who was the EIA preparer. A brief summary of the presentations by the ONE and the Project Sponsors follows. The presentation of the ELAby Radian is not summarized here as this EIA provides the materials that were presented. 10.1.1 ONE Presentation The first presentation was made by Mr. Boudlal of ONE who explained the need for additional electrical capacity in Morocco to meet growing industrial and residential electrical demands. A summary of Mr. Boudlal's comments are as follows: The importance of JLPP to the ability of ONE to meet the current and future demands of the Moroccan economy and residential demand for electricity was described. The bidding process associated with the privatization of Jorf Lasfar included 34 companies who responded to the request for proposal. Each of the proposals were reviewed by the ONE with assistance from an international consulting firm. The evaluation criteria for the proposals included technical, commercial, and financial competence of each bidder. From the 34 original respondents to the RFP, four were short listed for final evaluations and were asked to provide technical, commercial, and financial proposals. The ABB/CMS proposal was chosen as the finalist and negotiations were begun. The protocol between ABB/CMS and the ONE was signed on April 26, 1996. The ONE will continue to own the land and all the equipment at the JLPP, and will own Units 3 and 4 when construction is complete. ABBICMS will operate JLPP and have posted a security bond of 500 million dirham. The privatization of JLPP will enable ONE to dedicate its limited resources to continuing their rural electrification program and to meet increasing industrial and residential electrical demand. 10.1.2 ABB Presentation Mr. Zaoui, the Managing Director of ABB Maroc gave the next presentation which provided an overview of ABB and its qualifications for the proposed Project. EIA 10-2 August 1, 1996 INTERNATIONALMB 10.1.3 CMS Presentation Mr. Saheb of CMS GenerationCo. providedan overviewof CMS and its role in the Project. He also provideda descriptionof the Project as in Section3.0 of this ETA. 10.2 Summary of Public Forum The public forum was held on July 11, 1996in the auditoriumof the ODEP,which is adjacentto JLPP. Publicnotification was madethrough the local newspapersand via informationalposters announcingthe forum. Attendanceat the forum was excellent,with over 150people present representing each of the 30 communesin the Provinceof El Jadida. The Moroccanand El Jadidaprovincial government were also well represented.The dignitaries present includedthe Govemorof the Provinceof El Jadida,the Directorof the Centerof Observationand Studiesin Ministryof the Environment,the Directorof the MoroccanLPEE, the Presidentof the Parliamentof the Provinceof El Jadida,and the Presidentof the Associationof Dukkala,the specificsection of the provincein whichJLPP is located. The most commonly used languagein the Provinceof El Jadidais Arabic. Althoughthe presentationmaterials were developedin French,most of the actualverbal presentation was in Arabic. The public forumwas openedby Mr. Hakimi,the Directorof LPEE,who introduced the dignitariesand the host/moderatorof the forum. Introductorystatements concerning the purposeof the forum and the importanceof public inputinto the BIAprocess were madeby the Govemorof El JadidaProvince, the Directorof the Centerfor Observationsand Studiesof the Ministryof the Environent, and the Presidentof the Associationof Dukkala.The groundrles for the sessionwere discussedby Dr. Iraqiof AFAK,the forum Moderator.Summaries of the openingcomments of the govenment officialsand the moderatorare providedbelow. 10.2.1 Comments by the Govemor of El Jadida Summaryof the commentsfrom the Governorare as follows: The Provinceof El Jadidahas entereda new experiment. The investorsof the new powerplant are reachingout to you for input. The responsibilityis on your shouldersto not be afraidof this forum but to take ownershipof your community. (Thegovernor then provideda brief explanationof the overallproject). The investorswould like to presentto you the impactsof this project, both good and bad. They wantyou to providesubstantive input EIA 10-3 August 1,1996 RADIAN- INTERNATIONALIS and for the communityto be their partner. In my opinion, this demonstratesgood will and the importanceof you taking ownershipof your own destiny. This meetingand your comments are not merelysymbolic. 10.2.2 Commentsof the Directorof the Centerfor Observationsand Studies of the Ministryof the Environment Summaryof the Director's commentsare as follows: This event opensthe possibilityfor the citizensto express and present their views on the subjectof the protectionof the environmentat JLPP. This projecthas local and international impacts. The Ministryof the Environmentand the Provinceof El Jadida and the Communeof MoulayAbdellah have developeda partnershipto install a center for the analysisand studiesof pollution.This projectis financedby the MediterraneanAction Plan (MEITAP)and the center will be built very soon. The objectiveis to identifythe existingenvirommental problems. JLPP impactsare important. The Projectguidelines must conformto intemationallaws includingthose of the EuropeanUnion and the WorldHealth Organization.This plant must be an exampleto follow in Morocco. 10.2.3 Comments of the President of the Association of the Region of Dukkala The Deputy of the Associationof the Regionof Dukkalathanked AFAK, LPEE, the World Bank, and ABB/CMSfor this event, which is the first of its kind in Morocco. 10.2.4 Commentsof the Presidentof the Provinceof El Jadida The Presidentof the Parliamentof the Provinceof El Jadidathanked AFAK, LPEE, ABB/CMS,the WorldBank, and Radian. He said, 'Ve want an honest assessmentof the project. There are those who believethat this is a dangerousproject This meetingmust be a workingsession to adequatelyaddress the environmentalconditions at JLPP." EIA 10-4 August 1, 1996 RADIAN- INTERNATIONAL3 10.2.5 Comments of the Moderator The forum Moderator stated that this Project is a partnership between the investors and all those who are impacted by this Project. The Moderator said, "The problems of the environment are international. Adequate environmental protection must be achieved via a partnership between the government and the citizens. Holding the first forum of its kind in Morocco here in El Jadida, prior to the Casablanca (NGO) forum, is a statement that the highest priority is the protection of the people in the vicinity of JLPP. The objective of AFAK in hosting this forum is to serve the people." 10.2.6 Commentsand Questionsfrom the Public After the presentations of ONE, ABB, and CMS, the floor was opened to questions and comments from the public. The following summarizes comments/questions that were asked along with the corresponding responses: Comment: The greenery was replaced with cement. What will you do about this? Response: ONE: It was necessary as part of the construction of Units 1 and 2; and the construction contract includes replanting. Comment: A very important aspect is pollution. Whuatis the environmental impact of Units 1 and 2 and then 3 and 4? What are the measures that will be taken to protect the environment? Response: Dr. Iraqi: The answer to this question will be dealt with in the second part of the meeting when Radian makes its presentation. Comment: What is the specific experience of ABB in construction and operation internationally ? Response: ABB: ABB was involved with a 5000 MW project in Italy and has 10 years of experience in the U.S. with similar projects. ABB also has contacts with the World Bank and other lenders. Comment: Identify the investmentsfor the protection of the environment. Response: ABB: During construction there will jobs for local people, local materials will be purchased, and there will be an increase in employment (during operation). Comment: The technology of thermal power plants is ancient technology. Why are we not evaluating nuclear power? Response: ONE: ONE has conducted a study for a nuclear plant near Safi and there are other clean fuel projects that are being examined in the country. ONE has expertise in this area EIA 10-5 August 1, 1996 INTERNATIONALM! At this point, Radian presented an overview of the EIA and the anticipated environmental impacts. Comment: What is the impact of the JLPP on the air quality now and in the fiuure? Please present numbers. Response: Radian: There is concern about the impacts of air emissions. Particulate and NO, are below Project guidelines. Radian has conducted a dispersion modeling study of Units I and 2 and of all four units and found that the SO2 daily average currently exceeds the ambient air quality Project guidelines. Comment: What are the impacts on the environment of Units 1 and 2 without Units 3 and 4? Response: Radian:The informationis in a reportwhich has been providedto Ministry of the Environmentfor evaluation. There are many details. One thing that is known is that the baselinemeasurements of the air near the plant indicatethat it is polluted. The intemationalorganizations have laws concerningair pollution. If the air is polluted,the new installationwill not have the right to increaseemissions by more than the amountspecified in the guidelines. This is why ABB/CMSwill use low sulfurcoal even thoughit is more expensive. Comment: What is the current condition of the soil? Response: Radian:Fuel oil pollutionwas found in the soil. Thiswas immediatelyrelayed to ABB/CMS,who in turn told ONE, and cleanupplans were begun. Comment: What are the conditions in water dischargedfrom JLPP? Response: Radian:There is one wastewaterstueam containing a volume of water (that is small compared to other JLPP discharges) in which the pH inceases and decreases. This informationwas relayedto ABB/CMSand ONE and the problem was resolved. Radianalso found that ash is being disposedof in the ocean. Even though international studies on the environmental impact of ash disposal in the ocean were not conclusive, ABB/CMS has decided to discontinue the disposal of ash in the ocean. Comment: Discuss the Project guidelines. Response: Radian:The source and the developmentof the Projectguideline numbers are discussed in detail in the ELI The EIA is at the Ministy of the Environment. AD these guidelinesare at least as stringentas the internationalguidelines considered for this report. Comment: Why do you perform a study if there are no significant unpacts as you have reported? Response: Radian:The study is doneto ensurethat if there are impacts, they are quantified and methods are exploredto minimizethat impact There is a small impact on the air quality but it is still within the Project guidelines. Conceming the water EIA 10-6 August 1, 1996 RADIAN INTERNATIONALI quality, when ash disposal in the ocean is discontinued, the marine biology and water quality in the ocean will improve. Comment: How did you decide that this is the best technology? Response: Radian: When the technology is evaluated, technical feasibility, cost of equipment, cost for environmental protection, and the time available to bring the technology into operation are all considered. For Morocco, to produce additional electficity quickly in the desired time frame, the construction of Units 3 and 4 that are identical to Units 1 and 2 is the best choice. Comment: Concerning the technology requiredfor environmentalprotection, what is it, and what is the cost, and who paysfor it? Response: Radian: The quantification of costs is outside of Radian's mission. The technologies that will be implemented include electrostatic precipitators, low NO, burners, and a water treatment system. There are also strategies that include low sulfur coal use and stopping ash disposal in the ocean. Also there are numerous systems for monitoring of the emissions and there will be a program for the managementof hazardous materials. However, cost determination is not in our mission. Mr. Saheb from CMS responded that, in general, all these technologies are in the Project and the Project wiI respect the guidelines. Comment: I believe that the session has been excellent. It is obvious that we have choices to make. Development has associated with it environmental dangers. The people are active in improving the environment. We demand that the new investors be loyal guardians in the service of the citizens and the protection of their health. To conclude the forum a representative of AFAK restated the objectives of the forum, reviewed the events of the day, and thanked everyone for their participation. 10.2.7 Summary of the NGO Forum: Comments and Responses The NGO forum, hosted and moderated by AFAK, was held on July 12, 1996 at the Sheraton Hotel in Casablanca It was attended by approximately 120 people. Invitations to NGOs identified by AFAK, ONE, and the Ministry of the Environment were sent to each organization via mail. The list of NGOs who were invited is contained in Appendix C. Additionally, posters and banners were prepared to announce the forum. In addition to the NGOs, several members of the press were present. The forum was opened by Dr. Haroushi, the president of AFAK, who explained the purpose of the session and the ground rules for public input, questions and comments. All discussions and presentations were in French. A summary of comments and responses follows. EIA 10-7 August 1, 1996 RADIAN- INTERNATIONALM3 Morning Session Comment: Whyuse this technology instead of nuclear power? Response: ONE: We have evaluated nuclear plants as well as other thermal technologies such as IGCC. Comment: What do you plan to do to control the price of electricity for the consumers? Response: ONE: We acknowledge that tariffs are high. The revenues from Jorf Lasfar will be used for rural electrification and the tariffs are being negotiated with the foreign investors. Comment: Please discuss the solar energy program. Response: ONE: The solar energy program is being developed. It will be used for the rural electrical grid that we are designing. Comment: What is the difference in cost between nuclear and thermal power plants? Response: Mr. Zaoui (ABB): The cost of nuclear plants is four to five times higher than thermal power plants. Comment: What is the relationship between ABB and ONE? Response: Mr. Zaoui: At this time, ABB is working with ONE on hydropower plants. Comment: What about wood as a source offuel? Response: Mr. Zaoui: Burning wood would have a very negative impact on the environment. Comment: Why is there a meeting with the NGOs if the ONE has already made their decisions? Response: Radian: This is a new forum. Our mission is not to explain the past. Your concems will be documented in the EIA. The World Bank may include your concerns as conditions of financing. ABB/CMS are committed to listen and to make the effort to address your concerns. Comment: What studies were done on the epidemiological impacts, or the impact of the Project on the health of the citizens? Response: Radian: The epidemiological issues are not the responsibility of the power plant JLPP has the responsibility to document the contaminants in their discharges which have the potential to impact epidemiology. However, the responsibility to do the epidemiological studies rests with the commune of Moulay Abdellah and the region of Dukkala and the Province of El Jadida. Comment: The communes do not have the resources. Study the impact of the plant's expansion on the health of the citizens, not with the objective of incriminating the power plant, but document the risk to the citizen. EIA 10-8 August 1, 1996 RADIANU INTERNATIONAL Response: Radian: Yesterday,we leamedthat there is financingfor a center for environmentalprotection at Jorf Lasfar(parmership between the Ministry of the Environmentand the cormmune).The JLPP has responsibilityto documentthe contaminantsin the dischargesthat have the potentialto impacthuman health and the environment.For example,if ash disposalin the ocean is stopped,the marine biologywill improve. If disposalin the oceancontinues, ABB/CMS are responsiblefor monitoringthe water qualityand the biologyin the vicinityof the ash dischargepoint. Comment: Do you know the true baselineconditions? Response: Radian: We have measuredthe qualityof the air, the water,and the sedimentsin 1994,prior to operationof Units 1 and 2 and againin 1996prior to the constructionof Units3 and 4. Comment: Pleaserepeat and discussthe Projectguidelines. Response: Radiandiscussed the Projectguidelines in greaterdetail. Comment: Thisforwn is an exceUentinitiative, however the EU alternativetechnologies analysisshould have been donebefore UnitsI and 2, not after. Response: Radian: ONE's decisionto build JLPP wasprudent. Even thoughthere was no formalEIA, ONE did considerenvironmental impacts. Comment: Whyare you hidingffromus a copy of the EA? Youmust provide us with a copy of the reportin French. Response: Radian: Everythinghere is transparent The ELAis the propertyof ABB/CMS. Theyhave providedthe EIA to the Ministryof the Environmentfor evaluation. The protocolrequires that to obtaincopies of the report,a requestmust be madeto the Ministryof the Environmentor ABB/CMS. Comment: Is there a programfor the reuseof water at the JLPP? Response: Radian: ABBJCMSare evaluatinga programfor reutilizaion of the water, howeverno decisionhas been madeat this time. For example,process water can be used to controldust in thetransport of the ash. Waste minimizationis a sciencethat protectsthe environmentand is profitable. Comment: Are there any studiesof the terrestrialfloraandfauna? Response: Radian: There is no terrestrialbiology at the ILPP. The marinebiology and the fauna were evaluated.The populationdiversity and densitywas foundto be very low. This is not surprisingin regionswith such violentocean wave action and rock as is foundoffshore from the JLPP. Comment: What abouta study of the terrestrialbiology of the region? Response: Radian: Our missionwas to focuson the immediatearea of the JLPP. EIA 10-9 August 1, 1996 RADWANE INTERNATIONALM Comment: 7heparticipation of the NGOs and citizensis temporary. Will there be other forwns for the NGOs? The citizensare not informed. Citizenforums have no value. Willyou be committingfunds for the NGOs and to inform the citizens? Response: Radian: There will be other forums in the future. These are required by the World Bank. Also, you are responsible to request information according to a protocol. Finally, the population of El Jadida may be poor and uneducated, but they are informed. Yesterday, they posed many very important and relevant questions. ABB/CMS will hold forums to inform the citizens. Comment: Whyare the noise levels measuredannually and how would the ash be transported? Response: CMS responded that the noise levels are continually measured using the equipment at the JLPP according to the Project guidelines. The Moderator indicated that the ash disposal information would be presented later in the afternoon. Commnt Why is there no impactstudy on agriculture? Response: Radian: There are no agricultural activities at the JLPP. The predominant wind dircfion is towards the ocean. Consequently, the power plant should not have impact on the agriculture in the region. Further, agricultural impact studies are the responsibility of the goverment. Comment: Haveyou participatedwith the Universityof El J to analyze the regional marinebiology? Response: Radian: Our studies have documented elevated metals in the water before the first two units were started. Our mission is not to identify the sources of these metals. However, we welcome the opportunity to learn more from any studies by the university. Comment: Yougave the impressionthat Moroccois ignorantand that there are no other studies exceptthose by JLPP. Response: Radian: Morocco is a pioneer. This is why the foreigners are investing in Morocco. We have obtained many reports done by Moroccan laboratories. I regret the impression that you have. I assure you that this was not our intention. Comment: Whatare the incrementa impactsof UnitsI and 2 and then Units3 and 4 and why did you not do a regionalimpact study? Response: Radian: The impacts of Units 1 and 2 and Units 3 and 4 have been evaluated and they will be presented later. To answer your second question, our mission is to evaluate JLPP, not other sources in the region. Comment: Whoworked on this study? ElA 10-10 August 1, 1996 RADIAN- I NTERNATIONAL3 Response: Radian: Approximately 35 people from Radian including engineers, scientists, and support staff were assisted by 20 scientists and support staff from LPEE and 5 Moroccan university faculty members and support from Morocco. Afternoon Session Comment: Ash disposal in the quarry will impact groundwater. Response: Radian: Regardless of where the ash is disposed of, it will be disposed of in a responsible manner that will protect groundwater. Comment: You need to study, at leastfour times per year, during each season, the levels of phosphate and contaminants in the water. Response: Radian: Our mission is the impact of the power plant on the environment only. We have adequately described the air and water conditions and the discharges of the power plant Comment: Why do you assess the regional socioeconomic impact but only the local environmental impact? Response: Radian: There has to be a balance between socioeconomic and environmental impacts. Comment: The guidelines for the Project are consistent. Further, the principal of causality is respected. These guidelines are applicable in hwnid not arid environments. Explain Also, you are making estimates based on estimates. You must do exhaustivefield impact studies. Response: Radian: The international guidelines are established for humid and arid countries. We have conducted exhaustive field studies. We have used these data to predict the future impacts of JLPP. Comment: I do not believe in models, you must use extensive data collection. Response: Radian: Your point of view is noted. Comment: Will there be continuous monitoring? Response: Radian: Continuous monitoring is part of the ABBICMS monitoring plan that is part of the EIA. Comment: Why do you not use the energy of the waves and the wind to produce electrcity? Response: ONE: We are evaluating altemative technologies in our overall supply strategy. Comment: You evaluate the levels of each metaL What about the cumulative effects? Response: Radian: We thank you for expressing your opinion. You are posing very important questions. The debate process in Morocco is mature. ABB/CMS and Radian thank you. With regard to the cumulative effects we have toxicity information in the EIA. EIA 10-11 August 1,1996 RZADIAN- INTERNATIONALI3 Comment: The JLPP has dischargedlarge levels of contaminantsinto the region. This is unacceptable. Response: Radian: The air and water data collectedbefore and after Units 1 and 2 conclusivelyproves that the power plant has not impactedthe environment. Comment: How would you use the water in the transportof ash? Response: Radian: It will be used to control dust. Comment: Wheredoes the pollutionfor the baselineconditions come from? Response: Radian: Our objectivewas to identifythe levelsof pollutionpresent rather than the source. Comment: Is JLPP the sourceof the elevatedmetal levels? Response: Radian: Theseelevated levels existed beforeUnits 1 and 2 and have not changed. The emissionsof metalsfrom JLPP are negligible. Comment: Are these levelsnatural? Response: A memberof the audienceresponded that this is not possible. Anothermember of the audienceindicated that the OCP is the source. Radianrestated that the objectiveof the EIA is to evaluatethe impactof the powerplant only. Comment: Whatare the correctivemeasures? Response: Radian: The list of correctivemeasures in the E1Awere presented by Radian. Comment: Willyou be commitvingfunds to evaluatethe regionaliacts? Response: Radian: The new powerplant should not have to pay to studythe regional pollution. Comment: Whatcan you tell us about the use of ash in cement? Response: ABB: There are 10 cementplants in Moroccoand there have been many discussionsof this issue. The issue is economicviability. Comment ~rThe ash disposalin the oceanas not acceptable. If you ship the ash how can you control the disposal? Response: A memberof the audienceresponded that the investorshave decidedto stop ash disposalin the ocean. They cannotcontrol the disposalof ash once it has been shippedby boat. Radianresponded that the design of disposalof ash in the quarry or on land is under development. Comment: Whatare the impactsand recommendations? Response: The Project impactscomply with the Project guidelines.The water impacts are positive;the air impactsmeet the guidelines. EIA 10-12 August 1, 1996 RADIANN INTERNATIONALI3 Comment: This EIA is controlled by the terms of reference. This debate is extremely important. It is thefirst of its kind not only in Morocco but in this region of Africa. Morocco is a model. The NGOs must work together to improve the environmental conditions in the area. The World Bank should not have any reasons to not finance the project as it has been presented. Radian has very well explained that there has to be a balance between the socioeconomic and environmental impacts and that we shouldfind ways to minimize these impacts. Comment: The ONE is concerned about the environment. Are there studies to include solar energy? Response: ONE: ONE intendsto use solarenergy. Comment: General commentsffrom the audience: "I am very proud to be here representing my NGO. 1 thank AFAKfor their excellentjob at thisforwn. We would like access to the EIA. This project is being done in an environment of openness and we should not be concerned about the inmpactof this project on ourfuture. " To concludethe fomma representativeof AFAKrestated the objectivesof the forum, reviewedthe eventsof the day,and thankedeveryone for their participation. EIA 10-13 August 1, 1996 I I I I t RADIAN- INTERNATIONAL Appendix A Listeof EIAPreparers t I I I RADIANE INTERNATIONALE9 List of Preparers This EIA was prepared by Radian Intemational LLC under a contract from the ABB/CMS Project Sponsors. Radian Intemational LLC subcontracted with the Lboratoire Public dEssais et dEtudes (LPEE) in Casablanca, Morocco, for some of the on-site data collection. The following list of preparers is presented in alphabetical order within each of these three groups. ABB/CMSPersonnel Tony Shea: Role: Overall EIA oversight and review. Credentials: Project Engineer, ABB Energy Ventures Inc. One year experience in independent power production. Mike Weber Role: Overall EIA oversight and review. Responsible for preparation of the section on environmental management and amining. Credentials: Manager of Environmental Affairs, CMS Generation Co. Total of 22 years experience in meteorology, air quality, and environmental management. Responsible for assuring that CMS Generation has adequate environmental programs in place to assure compliance with corporate policies and external requirements at all facilities it operates. RadianPersonnel Steve Barnard Role: Responsible for ambient air quality sections and dispersion modeling, including discussions of existing air quality as measured by the ONE and future impact of JLPP operations on air quality as calculated through air quality modeling. Credentials: Atmospheric Scientist, Radian Intenational, LLC. Total of 18 years expenence in atmospheric research/meteorology, with five years of dispersion modeling experience supporting domestic and intemational permitting and air quality analyses. Richard C. Booth Role: Evaluated the impact of firing coals from several potential sources in Units I and 2 and the proposed Units 3 and 4 on stack emissions of S02, NO., and particulate matter (PM). Credentials: Senior Staff Engineer, Radian International LLC. 29 years combustion and emission experience, the last 23 years spent as consultant to electric utilities solving operational combustion and emissions problems. EIA A-1 August 1, 1996 INTERNATIONALEM Tom Calnan Role: Providedoversight for and participatedin the biological and marinewater qualitybaseline investigations (under subcontractto RadianInternational LLC). Credentials: CoastalBiologist, State of Texas GeneralLand Office. Over 20 years experiencein coastalmarine biology studies. Bob Davis Role: EIA Task Leader. Directedthe organization,preparation, and initial editingof the EIA and had individualwriting responsibilitiesfor the noise, socioeconomic,and the executivesummaxy sections. Also wroteportions of the altemativesanalysis section. Credentials: SeniorStaff Scientist,Radian IntemationalLLC. Over 20 yearsexperience directing multimedia, interdisciplinary projectsand in U.S. and intemationalEIA methodologyand documentpreparation. Holls Flora Role: ProjectManager. Responsiblefor the daily administration of the project,including other activitiesassociated with gatheringdata for the EIA, such as ambient air monitoring station,air dispersionmodeling, etc. Credentials: SeniorProject Manager,Radian InternationalLLC. 19 years experienceworking with electricutilities. Has previouslyacted as manageron many and varied Radian projects. Ardeth Hadley Role: Performedword processing,formatting, and compilationof the report Credentials: SupportAssistant IV, RadianIntemational LLC. Has workedon numerousrisk assessmentreports, as well as severalother EIAAEDDAreports. Larry Holcombe Role: Providedpeer reviewfor and consultedon Coal Ash Managementfeasibility study for the EIA. Credentials: PrincipalScientist, Radian International LLC, with 19 years experienceat Radian on utility solidwaste managements and wastemanagement feasibility assessments. Robert Legrand Role: Wrote sectionson impactsto surfacewaters and groundwater,wastewater treatment, and fisheries. Directed the translationof the EIA fromEnglish to French. Assisted in water qualityand marinebiology section preparations. Credentials: Senior ScientistU, RadianIntemational LLC. M.S. in Agronomy(major in hydrobiology),University of Gent, Belgium. M.S. in EnvironmentalEngineering, Cornell EIA A-2 August 1, 1996 INTERNATIONALM3 University, U.S.A. Professional Engineer (chermical engineering), registered in the State of Florida. Tenry Naulty Role: Peer reviewer for entire EIA. Credentials: Senior Project Manager, Radian International LLC. B.S. in environmental engineering, Purdue University. 14 years direct electric utility enviromnental experience, including Environmental Impact Statements, siting, regulatory analysis, and management. Holly Prather Role: Responsible for preparing and designing all graphics and the cover for the report. Credentials: Specialist, Radian International LLC. Six years experience in graphic design and layout. Past experience in designing logos, covers, posters, newsletters, and other printed materials. John Reddy Role: Responsible for evaluating potential options for discontinuing ocean dumping of fly ash and bottom ash. Credentials: Senior Civil Engineer, Radian International LLC. 15 years experience in civil engineering design, construction management, site investigation, and remediation. Past performance as lead engimeerfor landfill design projects for U.S. Army Corps of Engineers. Tony Rizk Role: Morocco in-country coordinator and task leader for the thermal discharge analysis. Credentials: Senior Engineer, Radian International LLC. PhD. in mechanical engineering. 12 years electric utility experience and experience in power plant thermal discharge analysis. French and Arabic speaker. Helen Smith Role: Reviewed sections of document. Credentials: Scientist, Radian IntemnationalLLC. M.S. in Toxicology. Experienced in human health screening and baseline risk assessments, toxicity literature reviews, and industrial hygiene assessments (occupational exposure assessments). Has participated in document preparation for RCRA and CERCLA sites for private-sector clients. Stephanie Smith Role: Assisted in obtaining maps of site. Assisted in writing, proofreading, and production of document. Credentials: Associate Scientist, Radian Intemational LLC. B.A. in Environmental Science (pending), Concordia University, EIA A-3 August 1, 1996 RADIAN- INTERNATIONALM3 Austin,Texas. Experienceassisting with ecologicaland humanhealth risk assessments. BarbaraStabeno Role: Coordinatingsecretary for this project. Assistedin typing the reportand preparingthe finished notebooks. Also assistedin coordinatingthe makeupof the covers with Graphics. Credentials: Senior Secretary,Radian InternationalLLC. Has assisted in preparationof proposals,reports, and technical correspondence. ValerieValderrama Role: Responsiblefor researchingportions of the socio- economicssection of the report. Assistedin translatingthe EIA fromEnglish to French. Reviewedthe socio-economic sectionto ensure that completeinformation from Moroccan literaturewas included. Credentials: EuropeanBusiness Coordinator, Radian IntemationalLLC. M.S. in Agronomicand EnvironmentalEngineering. Holds Frenchequivalent of an MBA3. Born and educatedin France,fluent in Frenchand English. Barry Walker Role: Preparedsections on projectdescription and air quality control alternatives.Performed air emissionscalculations. Credentials: Staff Engineer,Radian International LLC. M.S. in EnvironmentalEngineering, University of CentralFlorida. B.S. in ElectricalEngineering, Aubum University. B.S. in Chemistry,University of Florida. RegisteredIntem Engineerin the State of Florida. Has expertisein conductingand preparingEnvironmental Impact Analyses GretchenWelsbofer Role: Summarizedand wrotethe audit of existingconditions and preparedthe mitigationand monitoringsections of the report Task leaderfor organizingreport production. Credentials: Scientist,Radian IntemationalLLC. Total of five years experiencein the areas of NEPA,pollution prevention, environmentalcompliance, and risk assessment. LPEE Personnel Dr. A. Benzekri Role: ManagedLPEE marine biology work for EIA project. Credentials: Engineer,LPEE. PhD. in hydrobiology. EIA A4 August 1,1996 RADIAN- INTERNATIONALE Dr. E. Jabry Role: Coordinated and supervised LPEE project activities. Credentials: Director, Centre dEtudes at de Recherches sur YEnvironnementet la Pollution (CEREP). Sc.D. Mr. A. Karioun Role: Assisted in noise survey. Credentials: Engineer, head of Water-Air Services, LPEE. Mr. S. Lakranbi Role: Worked with discharge studies and oceanic pollution information for the ELA. Credentials: Engineer, head of the Marine PoUution and Impact Studies Department, LPEE. Dr. A. Marzouki Role: Executed the laboratory measurements and analyses. Credentials: Engineer in charge of the CEREP laboratories. Ph.D. in biochemistry. EIA A-5 August 1, 1996 I RZADL^N! INTERNATIONALC Appendix B References I RADUSAN- INTERNATIONAL, References ABB Project & Trade Finance (International)Ltd. (ABB Project). Jorf Lasfar Project 4 x 330 MW Coal-fired Power Plant at Jorf Lasfar, Morocco Preliminary Information Memorandum Volume 1. 1996. ABB. Technical documentation received from ABB in May 1996a. ABB. Information received from Tony Shea via conversations and fax. May 1996. H.P. Laeuchli, ABB, EPC contractor. 1996b. American Consulate General, Casablanca. Marine Fisheries of Morocco. Prepared for National Marine Fisheries Service, Washington, DC. PB88-148622. 11 Aug 1987. American National Standards Institate (ANSI). S136, 1979 edition. Brongersma, L.D. European Atlantic Turtles. Zoologische Verhandelingen, number 122. Leiden, The Netherlands. 319 pp. 1972. Charef, Abdeslam. Interview with Mr. Abdeslam Charef, Director of the Centre d'Etudes des Mat6riaux, April 26,1996, in Casablanca, Morocco. Mr. Charef is primarily concerned with finding a beneficial use for ash generated at power plants in Morocco. 1996. CMS. Jorf Lasfar O&M Assessment, Section IV, Environmental. February 1996. Commission of the European Communities. European Community Environment Legislation. 1992. Cooper, David C. and Alley, F.C. Air Pollution Control A Design ADrnoach. Prospect Heights, Illinois: Waveland Press, Inc. 1986. Direction Provinciale d'EI Jadida. Rapport Economique et Social - 2ame Semestre 1995. Economist Intelligence Unit (EIU). Morocco: Country Profile. The Economist Intelligence Unit, London. 1990. Electric Power Research Institute (EPRI). High-Volume Fly Ash Utilization Projects in the United States and Canada, Second Edition. March 1988. Elhaiba. Information provided to Radian by Professor Elhaiba of Casablanca in May 1996. EPC. Jorf Lasfar Units 3 and 4 Appendix A of the EPC agreement "Outline Specification," October 13, 1995. EIA B-B August 1, 1996 INTERNATIONALE3 Export-ImportBank of the United States(Ex-Im). EnvironmentalProcedures and Guidelines, Washington,DC, April 1, 1996. Findlay, Allen and Anne. "RegionalEconomic Disparities and PopulationChange in Morocco", Scottish GeographicalMagazine, pp. 28-41. 1985. Hadjeriouah,B. Hydrodynamicsof Aerating Weirs" Dissertation.University of Arizona, Tucson. 1993. Institut Scientifiquedes PechesMaritimes (Office National des Peches,Royaume du Maroc). Bulletin Annuel des Statistiquesde la PecheNationale - Annee 1991. Jirka, G.H., and RL. Doneker. HydrodynamicClassification of SubmergedSingle-Port Discharges,Vol. 117, No. 9. September1991. Johnson, Otto (ed). 1996Information Please Almanac.Houghton Mifflin Co.:Sourcesof informationfrom the UnitedNations Statistics Dept. and the PopulationReference Bureau. 1996. Laaouina,Abdelmouttalib. Interview with AbdelmouttalibIaaouina, Ph-D.,April 24, 1996in El Jadida, Morocco.(Dr. Laaouina is directorof "Societea Eau-Energie-Environment"of Marrakech,Morocco and a consultantto the govermmenton energyissues). LaboratoirePublic d'Essais et d'Etudes (LPEE).Etude de l'EratInitial de l 'Environnement Atmospheriquea Proxmiti de la Future CentraleThermique de Jorf Lasfar.Casablanca, Morocco. 1994. LPEE. Jorf Lasfarsampling campaign, April - May 1996. Long, E.R, D.D. MacDonald,SI Smith,and FD. Calder. Incidenceof adversebiological effects within ranges of chemicalconcentrations in marne and estuaninesediments. EnvironmentalManagement. 19(1):81-97. 1995. Markatos,N.C. and R. Simitovic. NumericalPrediction of Sea Flow and TemperatureRange BetweenPower Station Intake and DischargePorts in a Bay" Intemationalconference on NmnericalMethods in aminarand TurbulentFlow: 3rd: Universityof Washington,Seattle. 1983. MOE. MoroccanMinistry of Environment Meetingbetween Radian, ABB/CMS, and Moroccan MOE in April 1996. National Officeof ElectricPower (ONE).Part IV, Site Informationof The Kingdomof Morocco Nanonal Office of ElectricPower-the Jorf Lafar Thernal ElectricPower Plant. Public Tender Number33500. October 1994. EIA B-2 August 1, 1996 RADUIA INTERNATIONAL9 Nelson, Harold (ed). Morocco: A Countrv Study. U.S. Government, Dept. of the Army. 1985. Odom, John. CMS Generation Co.. Telephone conversation with John Reddy and Richard Booth, Radian International LLC on May 2, 1996. Radian Corporation (Radian). "Screening Study of Noise Impacts from the Holly Street Power Plant," June, 1993. Radian. Phase II Environmental Assessment of the JorfLasfar Power Plant, Morocco. October 1995. Radian. Data package received from JLPP personnel during site visit on April 22-24 1996. Rizk, T. HydrodynamicAnalysis of Thermal and Waste Water Discharges in Reservoirs and Embayments, 1992 Annual North American Lake Management Society (NALMS), Cincinnati, Ohio. 1992. Simonis, Damien and Crowther, Geoff. Morocco. Lonely Planet, April, 1995. Texas Natural Conservation Commission (TNRCC). The State of Texas Water Quality Inventory, Prepared Pursuant to Section 305(b) Federal Clean Water Act. Volume 1: Surface and Groundwater Assessments and TNRCC Water Quality Management Programs. November 1994a. TNRCC. Texas Water Quality: a Summary of River Basin Assessments. The Texas Clean Rivers Program. SFR-10. 255pp. 1994b. TNRCC.Texas Surface Water Quality Standards. TAC Title 30 § 307. 1995. U.S. State Department. Morocco: BackgroundNotes. U.S. Department of State, Bureau of Public Affairs, 1994. U.S. Fish and Wildlife Service (USFWS). Endangered and Threatened Wildlife and Plants. 50 CFR 17.11 & 17.12. August20, 1994. United States Environmental Protection Agency (EPA). "Information on Levels of Environmental Noise Required to Protect Public Health and Welfare with an Adequate Margin of Safety,(EPA 550/9-74-004). March 1974. United States Department of Energy (DOE). U.S. Department of Energy, Waste Disposal/Utilization Study. June 1990. United States Department of Energy (DOE). U.S. Department of Energy, Foreign Markets for U.S. Clean Coal Technologies, Report to the U.S. Congress, May 2, 1994. EIA B-3 August 1,1996 RADIAMN- INTERNATIONALMB White,F. Fluid Mechanics. 1975. White, F. The Vegetation of Africa: a Descriptive Memoir to Accompany the Unexco/AETFAT/UNSO Vegetation Map of Africa. Unesco. Switzerland. 356 pp. 1983. World Bank. Environmental Guidelines. Environmental Department, Washington, DC, September 1988. World Bank. OperationalDirective 4.01 EnvironmentalAssessment, Oct. 3, 1991a. World Bank Environmental Assessment Sourcebook. Vol m Guidelines for Environmental Assessment of Energy and Industry Projects, pp 74-82, ThermoelectricProjects. World Bank Technical Paper Number 154. EnvirommentDepartment. Washington, D.C. 199 lb. World Bank. "Morocco: Repowerng of Power Plant Project." September 2, 1994. 1994a. World Bank. "Kingdom of Morocco, Preparing for the 21st Century: Strengthening the Private Sector in Morocco (June 30, 1994). Rep. No. 11894-Mor. 1994b. World Bank. Morocco-Private Sector Development (PSD I1 Power). Project MAPA5464, March, 1995. World Bank. Environmental Guidelines. Environmental Department, Washington, DC, September 1988 (excerpts applicable to this project provided to CMS, ABB, and Radian at meeting in March, 1996). 1996. World Health Organization (WHO). Environmental Health and Criteria. Geneva, Switzerland. 1979. WHO. Air Quality Guidelinesfor Europe. WHO Regional Publications, European Series 23. Regional Office for Europe, Copenhagen. 1987. EIA B4 August 1, 1996 11 I 0 i - I I I RADUAE INTERNATIONAL3 AppendixC Public Participationand InteragencyCoordination: List of NGOsInvited to NGOForum I~ ~~~~ I ~~~ RADIAME I NTERNATIONALM3 PARTICIPANTSOF THE NGO FORUM The followingis a list of NGOsthat were invitedto the NGOforum held on July 12, 1996 at the SheratonHotel in Casablanca. AssociationClub des Jeunes au Servicede I'Environnement ForumMaghr6bin pour IEnvirornementet le Developpement AssociationMarocaine pour la Protectionde 1YEnvironnement(ASPANA) Associationdes Anis de la Culture,de l¶Environnementet du Sport AssociationEcologique Marocaine GroupedEtudes et de Recherchessur les EnergiesRenouvelables (GERER) Associationdes Alli6sde l"Environnement AssociationMarocaine des Sciencesde la Mer AssociationMarocaine de G6omorphologie AsscociationMarocaine des Sciencesdu Sol ComiteEnvironnement des AssociationsRegionales et Specialisees GroupementdEtudes et de Recherchespour la ProtectiondEssaouira (GERPE) MouvementNational de IEnvironnement Organisationdu ScoutismeNational Le Comitede l'AmicaleMarocain des Ing6nieursAgronomes Forestiers (AMIAF) AssociationMarocaine dEtudes et de RecherchesIntemationales (AMERI) Associationdu MouvementTouiza (2 adresses) Le ClubMarocain dtEducation en Matierede Populationet d¶Environnement (CMEPE) Associationdu Bassinde Safi AssociationSociale Al-Hassania de la Cultureet de l'Art EIA C-i August 1, 1996 RADIAN! INTERNATIONALM AssociationChantier et Environnement Organisationdes Jeunes pour le D6veloppementet lEnvironnement Associationpour la Lutte contre IErosion,la S6cheresseet la D6sertificationau Maroc (ALCSEDAM) Associationdes Habitantsd'Anfa II pour la Protectionde IEnvironnement AssociationMarocaine pour lEnvironnementet le Developpement(bureau nationalet bureaude Mohammadia) SocieteMarocaine pour le Droit de I'Environnement EIA C-2 August 1, 1996 r t~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ I I INTERNATIONAL! Appendix D Environmental ManagementImplementation Plan i I i GENERATION ENVIRONMENTAL MANAGEMENT IMPLEMENTATION PLAN Approved January 4, 1996 Prsiwet ndCEO I t I CMS GENERATION ENVIONMENTAL MANAGEMENTIMNPLEMENTAnON PLAN CONTENTS DESPCRTITON PAGE INTRODUCTION 1 ENVIRONMENTALPOLICY STAMENT 2 ORGANIZATION 3 RESOURCES 9 CORPORATESTANDARDS 10 ENVIRONMENTALREQUIREMENTS 12 PLANT PROCEDURES 13 NON-OPERATIONSACTIVITIES 14 FEEDBACKAND IMPROV2AENT 17 DOCUIMENTS 19 I I I CMSGENERA TION ENVRONMENTALMANAGEMENT IMIPLEMENTATION PLAN This EnvironmentalManagement Implementation Plan describesthe elementsof CMS Genera- tion's (CMSGor the Company)comprehensive Environmental Management System (EMS) and supportingframework, including organization, resources, and documents. Althoughthe primary focus is on operations-relatedactivities, non-opertions activitiesare addressed as well. The subjects coveredby this plan are: Polcy - providesthe CMSGEnvironmental Policy Statement, Organzation - describesthe orgzation, roles and responsibilitiesof the various partcipants mnCMSG environmental activities, Resources - describesresources available in support of CMSGenvironmental activities, Corporte Standards- describespurpose, subjectsand generalcontent of generic standards for enviromental performance, Envionmentel Requirements - describes scope and subjects for environmental program-specificrequirements, Plant Procedures- describespurpose and rcommended subjectsfor plant procedures, Non-OperztionsActivities - describesapplication of the Policyto CMSG activities not related to plant operations, Feedbackand Inprovement - describesthe variousvehicles for improvingall aspects of the Company's comprehensiveEMS, and Documents - descrbes documentsused in supportof the Company'scomprehensive EMS. 01104/96 ENVIRONMENTALMANAGEMENT IAPLEMENTATION PLAN CMS GENERATION The ife of any buinss cnnot be separatcdfrom its bapat on the naurl environmentin whUichi operes. CS Gnemon Co.,one of the ladng temnonal dpndt powercomms, akes seriouslyits role in protectingand enhancingthe envirnmme of he conmuone and cowCSis in which it operates. Environmeal xiewadirh is always a pnmary objective. A secondarygoal is to lead the businss comnuoznyand the ndependentpower inda in eablishig wcl-fo,wded imemal policies and backingprograms achiev o hem oTds end, our aiv wl be consstent with sound environ- mental praices a counes in which wc ow and/or operate. In recogning the Company'sdtverse rok osan owner, somneimesas operator,and always as an advocate for wexnplaryeninmapracices, we wil manageour busines to. * Complywith appicabk nvronmezal kam and regulations * Uilze the WorldBank smdads in our internationalbusiness aia to evaluateour environ- menal practicesand newproject designs. - Advocatesowcid enronmenal practices in al our diversepnenhps. * integrte enirmeal protectin condeations ito Comny planningand decision makingin al phoses of our domesicand intemnonal business. 3 Encorge actve emloyee pacpaton in efforsfor environmentalprotecti and ensureopen conzwzicann amongall employeesto ldma5esitutns were the Conpanymay improveis pracCS w.z regardto ea s dtchip. * Seek oppornouitis mnm the generationof wte materios, couragerecyclg and enwre proper haning and dsposal of %wots. V Assesspotnti sfety. healthand enronma impas pnor to transactionsnvolving the sale. lase, mtnfer or purchaseof rea propeny. * Work wih appropnrateenvomenal agences and organeator and ensuretme,y. reasonable and cst-ejf,ctive soutions to eniomntal issues. ° Partcipe tough CS EnrDwn the delopment of applicabl vrnme gislation. reguation and policyissues that may siisctty impactour businss. * Establishguidelins and more detal procedures. whenappropriate,for implementation of ths Environmen Polieyincluding the designaton of dividualsaccountablefor environmena smrngemem results. * Review coormhy withthis EnvironmentalPolicy on a regularbasis ro ncuurcompliance throughoutthe Company. Rodney E. Boulanger, Presidentand C.E.O. 2 01104196 CMSGENERATION ENVIRONMIENALMANAGEMENT IMPLEMENTATION PLAN ORGANTZAnos In supportof the Policy, the Companyhas establishedand mainminsa strucured environmen- tal managementorganization. This organizationindudes environmentalprofessionals, senior management,staff and support personnelat both the corporateand site level. Each of these individualshave specific responsibilitieswhich are presented throughoutthe CMSGEnviron- mental Manual, and whichare summaized below. Qrganfrt =inaIR=nsihiijq. The cunrentCMSG environmental management organizationalstructre is shown in Plg. 1. Whilespecific responsibilides of employees involvedin environmentalmanagenent are describedim each of the CorporateStandards and Environmental1Requiremeats, general responsibilites of key positions within the organizion are as follows: CMSG Presidentand CE.O. The primaryrole of the CMSG Presidentand C.E.O. is to establishand require adherenceto the Company'sEnvironmental Policy, and to addressthe organization, humanand other resourceneeds of the Company'scompre- hensiveEMS. CMSG Vice Presidentof Opeations. The role of the CMSG Vice Presidentof Opertons is to assure that all CMSG-operatedfaciliies are operatedin complianmc with all applicable nvironmentalrequirements, and to assure that an appropriate orgnization and resourcesare in placeto developand implementthe Company's comprhensive EMS. CMSGManager of EnwronmentLAffairs. The role of the CMSGManager of EnvironmentalAffairs is to establish,implement, review and update the Company's comprehensiveEMS, and to serveas a resourceto CMSG-operatedfacilities. Typical responsibilitiesare to: * maintai the necessarylevel of competencywith exisig fedeal and state eavironmentallaws and regulationsand assist CMSG-operatedfacilities with resolution of siespecific issues, * work with CMS Govermental Affairsand Legal departmentsin identfying and analyzing the impactof new or emergingfederal and state environmental regulations on opertions, * communicatenew or revisedfederal and state environmentalrequirements to operating facilities, * as needed, developand disseminateprogram tools and standardsfor required envronmental activitiescommon to CMSG-operatedfacilities, 01/04/96 3 ENVRONMENTAL MANAGEMEN IMPLEMENTATIONPLAN CMS GENERATION FIGURE 1: CMSG ENVIRONMENTALMANAGEMENT ORGANIZATION PRESIDENT OPERATION OlllERl I~~ VIEPRSDETOIERS__ I GENERAL X . NAGER OF MANAGERS .... ENVl3ONMENTAL 1. CMS...... LEGAL| [|I REALTHAND . SAFETY PLANT 1 .. . MANAGERS l PLANTENVIRONMENTAL| * HUMAN COORDIIATOR ...... RESOURCES 4 01104/96 CMS GENERATrON ENV.RONMENTALMANAGEMEN IMPLEMENTATIONPLAN * provide or arrange for environmentalprotection tnining for site management and environmentalcoordinators as necessary, * arrange for independentassessment of facility compliancewith applicable environmentalrequirements and regulations,and monitorcorrective actions to resolve identifiedconcerns, * engage the services of and receive informationfrom extemnalresources as necessary, * as needed,provide planninginformation to CMSG-opemtedfacilities on new environmentalinitiatives, * maintaincorporate enironmental files, * consultwith the CMSG Vice Presidet of Operations,when necessary, to appnse corporatemanagement of outstandingenvironmental issues, and 3 assure that apppriate consideramionis given to signficant environmentalissues duinig the preparaion of annual strategicplans and budgets. CMSG Genenl Managers. The role of CMSG GeneralManagers is to assure that CMSG-opert facilities for which they are responsibleare opeated in compliance with all applicableevionmentl requirments, and to assure timelyresolution of site- speific ennmtal issues. CMSGPlant Managens. The primary role of CMSG Plant Managersis compliance with all applicablefderal, state, local and CMSG-intxnalenviromental requirements. The Plant Manageris responsiblefor all aspectsof adsting and implementingthe OomprehensiveEMS at the faCilityleve. If resourCesallow, the Plant Manager is stronglyencouraged to appoint a SitmEnvirmental Coordinatorto have prmary responsibilityfor iplemention of the site envronmentalprogram. Typical responsi- bite for the Plant Manager and/or Site EnvironmentalCoordinator are to: * stress the importance that managementattaches to environmentalprotection and assure that all employeesare aware of the CMSG CorporateEnvironmental Policy, * ensure employeejob descriptionsappropriately reflect environmental responsibilitiesas defined by this documentand other site specificprocedures, * ensure environmentalissues are integated app tly into the annual site operatingplan/budget, 01104/96 5 ENVEROINMENTALMANAGEMENT EMPLEMENTATION PLAN CUS GENERATION * maintain knowledgeof applicablelaws, regulations and internal standards elating to environmentalprotection at the site, * maintain awarenessof any local environmental regulationswhich could impact facility operations, * review potential effectsof new or revised raw material use, fuel use or power generating activities whichmay have a significant impact on the environment, * develop, review and approve standard operating proceduresto ensure compli- ance with applicableenvironmental requirements and rgulons, * provide or arrange for needed ennmental protection taining for site employ- ees, * regularly assess facilitycompliance with applicable environmentalrequirements and regulations, and developcorrective actions as necessary, * assure that pollution monitonngand control devcwesare functioningproperly, * assure that all requiredroutine and incident reporting is madeto environmental agencies and to CMSGcorporate offices, * maintain site enviomarecords, 3 resolve any potentialnon-compliance conces and ensure completionof any identified corective actions,and - consult with the CMSGManager of Environmental Affirs and/or the CMS Legal department, as necessary,on outstanding or unresolvedenvironmental CMSLegal Departaw At the requestof the CMSG President, Vice Presidentof Operations, Manager of EnvironmentalAffairs, General Managersor Plant Managers, the CMS Legal Departmentprovides legal and regulatory advice to implementand maintain the comprehensiveEMS. Typical responsibilites of the CMS Legal Depart- ment are to: * mantain the necessarylevel of competency with applicablelaws, regulations and internal stdards rdating to envrnmental protecdon and liability, * establish appropnate confidenialityprocedures as necessaryfor documentsand activities associatedwith the comprehensiveEMS, 6 01/04/96 CMSGENERATION ENVRONMENTALMANAGEMENT IMLEMENTATION PLAN * engagethe servicesof and receive informationfrom external resources as necssary, * lead in the resolutionof findingsof potentialnon-compliance as requested by the Plant Mager, GeneralManager, Manager of EnvironmentalAffairs, or the CMSGVice Presidentof Operations, * reviewall environmentalcontracts, permits, notices of violation,and similar documents,to facilitateparticipation in negotiationsas necessary, and * provideiput as necessaryto upgradethe oDmprhensiveEMS and associated elements. CMS HwmanResources Depanment. The primaryrole of CME HumanResources is the review of the comprehensive EMS to assure consistency with other corporate policiesand standards,and to assure that high standardsof environmentalperformance axeestablished and consistentlyenforced for all CMSGemployees. Other CMSGOfficers. CMSG Officersare responsiblefor assuringthat employeesin their respectiveareas are aware of the CMSGEnvironmental Policy, the organization for iplementing the comprehensiveEMS, and the appropriatenon-operations respon- sibilites describedin detail in a subsequentsecton of this implementationplan. Persona1lRCnmsibic. In addition to the responsiilides of individuals within the com- pany's environmentalorganization descibed above, CMSGassigns a certain level of environ- mental accountabili to all employees. Specifically,CMSG expects every employeeto understandthe company'senvironmental commitment and recognizethat personalsuccess within the companyincludes a measureof each individual'scontnbution to that commitment. To encourageemployee contribution, CMSG maintainssystems to ensure that: * all employeeshave access to the CMSG CorporateStandards and Eivironmental Requirementsand supportingprocedures which applyto assignedduties, * employeecontibutions to the success of the CMSGcomprehensive EMS are evaluated and includedas part of the annual performancereview, * each employee has acces to a confidential reporing system to assure that reports of a suspectednon-compliance with any laws or internalrequirements can be made without fear of retribution,and * failure to comply with applicable regulations or intenal Company requirements may be cause for disciplinary action, up to and including termination. 0104/96 7 ENVIRONMWNALMANAGEMENT IMPLEMENTATION PLAN CMS GENERATION CMSG supervisors, managers and officers are encouraged to ask employees to help identify areas of concern and to suggest ideas for improving Company environmental management efforts. 8 01/04/96 CMSGENERA 77ON ENVIRONMENTALMANAGEMENT IMeLEMENTATION PLAN RESOTRS The organizadonaland humanresources which CMSG has dedicatedto environmental managementare describedin a previoussection of this implementationplan. Financial resourcesfor environmentalcompliance and environmentalmanagement activities are allocated in the CMSG annual planningand budgetingprmcess. Audit schedulesfor operating facilities are determinedduring this budgetprocess. The consequenceof compliancewith applicable new laws or regulationsis also presentedso that the financialimpact of futureenvironmental compliancemay be assessed. Proforma financialanalysis of projectsduring the developmentstage includes O&M expense for environmentalcompliance and training, and capital expense for environmentalprotection systms and equipmentreqired for the plant design. In cascs such as internationalacquisi- tions, when upgradesto environmentalcontrol and monitoringfacilities are planned, the cost and schedulingof expendituresare incorporatedin financialanalysis and financingplans. Staff from CMS Energy GovernmentalAffairs and Communicationsdepartments are relied upon to assist, as appropriate,in articulting the Company's viewsconcerning projects in developmentor opeaon, with respectto the developmentof envinmental legislation, includingthe wrting of rules implementnglegislation. Other resourcesavailable for supportof the Company's environmentalactivities include the environmentalstaff of other CMS companiesand qualifiedenvironmental consultants. 01/04/96 9 ENVIRONMNTALMANAGEMENT IMLEMENTATION PLAN CMS GENERATION £QCRPRATFLSTANiARDS CMSG has establishedcorporate standards for how we, as a Company, address a number of generic subjects,as describedbelow: Possessionof Pemuts. Requires CMSG personnelresponsible for developing a new project to obtainall necessaryenvironmental permits and approvals, and requires CMSG pesoMnnelresponsible for operatinga facility to have a copy of all such penimts and approvalson-site or readily available, and to assure that any new permits, approv- als or permit modificationsneeded for new or modified site equipment, fuels or opetions are obtained. Compliancewith Pennit Requirements. Requiresthat CMSG personnel responsible for developingor opeting a project or facility comply with all applicable permit requimets. Commitment Schdue. Requires CMSG-opeated failities to develop and use an annual scheduleor mawixdescibing e onmentalinpecton, monitoring, reporting, noftficatin and/orsimilar commitment equirements. Trasuzg. Requiresthat all CMSG employeesreceive at least a c=ain minimumrlevel of enArometal taining appropria to their job responsbilities. zEnvinnmewlErcellence. Descibes criteia and performancelevels expectedto be achievedby CMSG-operatedfacilities to obtain annual awards for environmentl excellencc. Agency Meetings/ Discussions. Establishesguidelines and requirements for CMSG- operated facilitiesrelated to communcating and documentingthe results of meetings and discussionswith fedeal, stte and local environmentalagencies. Agency Inspections. Establishesguidelines and requirementsfor CMSG-operated faciLtiesdealing with a site inspecton by personnel from federal, state or local environmentalpotection/enforcement agencies. Response to EnvironmentalEmergencies. RequiresCMSG-operated facilities to notify the Managerof Environental Affairs (after initiationof other critical response activities)in the eventof an emergencywhich could impact the environment (e.g., oil or chemical spills, toxic gas releases, ex.). Periodic Routine Reporting. Requires monthlyreporting by CMSG-operatedfacilities to CMSG coxporateoffices, and quarteiy reportng by the Manager of Environmental 10 01/04/9 CMS GENERATION ENVIRONMENTALMANAGEMENT IMPLEMENTATION PLAN Affairs to the facilitiesand CMSG management,and establishesguidelines for routine submittalsby CMSG-operatedfacilies to environmentalagencies. Nonuatine Reporiing. Requiresreporting of nonroutineitems such as formalagency informationrequests, apparentnon-compliance, submittals of plans, or requestsfor agency approvalsby CMSG-operatedfacilities to the Managerof Environmental Affairs, and reviewof such items by EnvironmentalAffairs and, as necessary,CMS Legal NOVsILOVs, ons and EnforcementActions. RequiresCMSG-operated facilities to respond to officialenforcement documents and processesin consultationwith the Managerof Enviromental Affairsand CMS Legal department. Recordkeeping. Requies CMSG-operatedfacilities to establishand maintainfiles for pimnarystorage of all site-relatedenvironmental records. Auits. Requimespeiodic independentcompliance audits at CMSG-operatedfacilities and periodic idependent evaluationsof the effectivenessof the comprehensiveEMS. Copiesof current standardsare includedin the CMSG EnvironmentalManagement Manual. Standardsare issued and may be revisedfrom time to time by the Managerof Environmental Affairs in consultationwith the GaeeralManagers and the Vice Presidentof opertions. Standardswill be written in a consistentformat and will be reviewed-by at least the Plant Managers, Generl Managersand CMSLegal departmentprior to approvalby the Vice President of Operations. 01/04196 11 ENVIRONMENTALMANAGEYENT IMPLEMENTATION PLAN CMS GENERA2ION ENIRANMrIIALREQMRENrS, Program- and site-specificFederal and State environmentalrequirements are developed for the followingareas: Air Qualty. Includes federal, state and/or local air pollutioncontrol requirements not otherwise addressed by permits, such as NO. RACT, partscleaner, and refrigerant recycling requirements. Hazanous Mageri^a. Includesfederal, state and/or local hamrdousmatials control requirements,such as emergencyresponse planning, and annualinventory and notifica- tion requirements. Spills and Releas. Includesfederal, state and/or local spill or releaseresponse requirements, such as planning,reporting, and clean-up requirements. Waste Mana:emen. Includesfederal, state and/or local solid, liquid, and/or hazard- ous waste control requirements,such as identification, segregation,testing and tracldng reweents. WaterQuality. Includesfederal, state and/or local water pollutioncontrol require- ments not otherwise addressedby permits, such as wastewater,stornwater, and wetlandspermitting, and drinkingwater testing requirements. Copiesof current federal environmentalrequirements are includedin the CMSG Environmen- tal Maement Manual. Stale and/or local requirements(including those applicable to non- US facilities) wil be added in 1996. Ruirements are issued and may be revised from time to tme by the Manager of EnvironmentalAffairs m consultationwith the GeneralManagers and CMS Legal department. Requirementswill be wnitn in a consistentfornat and will be reviewed by at least the Plant Managers,General Managers, Vice Presidentof Operations and CMS Legal department prior to approvalby the Manager of EnvironmentalAffairs. 12 .01104/96 CMSGENERATION ENVIRONMEAL MANAGEMENTIMPLMENTATION PLAN ELANT RQrFIDRF-S The need for site-specificplant implementingprocedures is determmedon a case-by-casebasis by the Plant Manager. The overriding principleis to assurethat critical functions could continueto be correctlyperformed upon the loss of key personnelwith specfic environmental complianceresponsibilities. It is recommendedthat each facilitydevelop implementing proceduresfor at least the following areas, as apprope: * an emergencyresponse procedure or check3istfor use in the event of a spill,accideztal relas or similarunplanned or emergencysiuation, if not otherwis addressedby a siteemergency or spil plan, * a materalsinventory, material safety data sheets,procedures and/or checklsts which constitutethe programfor managementand disposalof hazardous and nonhazardous mteTrials, * operations,maintenance, test and calibrationprocedures for environmental monitoring (e.g., CEMs,wastewater) and environmentalcontrol equipment, and * a bulk chemical / liquid fuel unloading and refilling procedure. Upon development,copies of plant-specificprocedures should be included or referencedin the appropriatesecdon of rnvronmentalrequirements(i.e., air quality, watr quality, waste management,spills and relaseS, or hazardousmatrials) in the CMSG Environmental ManagementManual. Proceduresare issued and maybe rvsed from time to time by the Plant Managerin consultationwith the Managerof Envmental Affairs and the appropriate Geneal Mang. 01104/96 13 ENVIRONMENTALMANAGEMENT IMPLEMENTATION PLAN CMSGENERATION This section of the plan describesenvironmental management requirements and measuresfor the following: environmentalreview of sitesand acquisitionprospects, selectionof EPC contractors and technologies,establishment of environmentalrequirements for international projects, environmentalcompliance during construction,establishing environmental files, the construction turn-overand start-upproess, sale of existing assets, and projectsin which CMSG does not have a controllingmterest. CMSG officers responsiblefor development, enginering and constructionwill prepareprocedures, issue insructions, and/or conduct training or staff meeting discussionsas appropra to assure that these requirments are implemnented. De±zlo=ent- Developmentoccurs by acquisitionof an existingproject or by development and constructionof a new project. Projectscovered by this section are generting plants and related businessessucb as fuel supply companies. Acquisitions of land or edsting projectswill not be undertken unless a Phase I Environmental Assessment (and Phase II if needed)is performedprior to the tansction to assess environ- mentalliabilities and risksto development During a Phase I review, an examiation of the site and apprope recordsis conductedand the envirnmental impact of pnor uses is assessed, the status of environmentalcompliance with applicableair, water, waste disposal, and other environmenl requirementsis assessed,and the impact of nearby activitieswhich could potenially affect enviometal conditionsat the site is determined. The review shouldbe performedearly enoughin the developmentcycle so that knowledgeof environmentalissues can be used to assess the risk to developmentand the ability to secure financing. Phase I (and Phase II if needed)reports will be reviewed by the Mamger of EnvironmentalAffairs and CMS Legal departnmetprior to being finalized. The CMSG Project Managerin charge of the developmentactivity will establishtiming for the review, and with the input of the CMS Legal department,the Managerof EnvironmentalAffairs, and the Vice President of Engineeing and Construction, will determine how the project can address issues and risim, and if there is need for further action by perts familiar with the financial market's current view towardsimilar environmental risks. In analyzing conclusionsfrom the assCesment,distnctions wi be made betweenrisks that CMSG would agree to assumeand risks that may call for specialmeasures (such as remediationor indemnification)in order to complete fiancing. The project profoima wil be revised as necessary to reflect the results of the analysis of issues identifiedby an environmentalreview. EPC contacs and equipmentsuppliers Will be sdected based on assurance that their designs and equipment includeenvironmental control featuresrequired to comply with permit and other environmentalrequirements for each precLt. Flrms supplyingdesign servicesand equipment should provide guaranteesthat the project will meet environmentalrequirements, and these guaranteesshoudd be sufficientfor reasonableassumnce of meetng requirmen.ts 14 01104/96 CMS GENERATION ENVIRONMENTALMANAGEMENT IMPLEIENTATION PLAN The guarantees and the reqmirements are incorporated in the EPC agreement for each project. Ile CMSG Project Manager assures that the CMS Legal department, the Manager of Environmental Affairs and the Vice President of Engineering and Construction are consulted for this activity. The CMSG Project Manager is responsible for maintining environmental files during the development and construction phase of a project. International Projects. In establishing environmental requirements for international projects, local or World Bank guidelines (whichever are more stringent) which are consistent with competitive power costs in the region are used for new construction. These requirements are incorporated in the project EPC agreement. In the case of international acquisitions, environmental requirements consistent with power purche agreement rates are developed using local requirements and World Bank guidelines. The CMSG Project Manager assures that a description of planned environmental improvements is prepared in consultation with the Manager of Environmental Affairs and the Vice President of Engineering and Consduction. The project profomza is updated as necessaxy to include finnCial impacts of impro ts. If an interational project does not conform to the latest guidelines of the World Bank due to the desire of project partners and/or the host country to proceed along a path which pemiits other, less costly but otherwise effective environmental control measures, the CMSG Project Manager will consult with the CMS Legal department, the Manager of Environmental Affairs and the Vice President of Engineering and Construction to direct the completion of an assessment which states the basis for environmental requirements for the project. The assessment will be part of the review and the decision to proceed with the project by responsi- ble Officers of CMSG. Constiont Rponsibility for environmental performance and risk management during construction authorized by CMSG rests with the contractor. The contractor will be required by the Vice President of Engineering and Construction to provide notice to the Company of spills, accidental releases or other envnmental anomalies which occur dunng the construc- tion period. The notice requirement will be incorporated in the construction contract as appropriate. The CMSG Construction Manager at the site monitors the contractor's perfor- mance. When CMSG does not manage construction, it will advocate that the owner's representative and contractors fulfill similar responsibilities. Turn-over and Start-up. The CMSG Site Construcdon Manager and Plant Manager work together to oversee the contactor's work to prperly handle and remove general and hazardous waste materials durng and at the end of construction. They also work with the contractor, equipment suppliers and regulators to establish procedures, conduct tests and report results concerning the environmental control and monitoring equipment. 01/04/96 15 ENVIONME£NTALMANAGEMENT IMPLEMENTATION PLAN CMS GENERATION As part of theturn-over and start-up program, the CMSG Site ConstructionManager and Plant Managerwill consult with the Manager of EnvironmentalAffairs to provide assurance that all reasonablesteps have been taken to enable the project to conformwith environmental requirements. Start-up related permit requirementsshould be revewed at least 90 days pnor to anticipatedfirst use of combustion equipment,to assure that appropriate notificationsare made. It is also recommended hat permit requirementsbe reviewed with regulators to confirm that there is agreementas to interpretationand that the interpretationshave been reflectedin plant procedures, instructions to operationspersonnel, and training. After financialdosing and commecement of commercialoperation, environmentalfiles from developmentand closing actity are tansferred to those responsiblefor sset management. DIVetift. An environmentalreview of an assetmay be performed prior to its sale or transfer where there is a need to establisha mors completerecord of environmentalperfor- mance by CMSG. The CMS Legal departmentand the CMSG Officer responsiblefor the transacton make the judgement on the need to conducta review. Partner~hfp I NoTi-controTling_mIted TntermThis EnvironmentaIManagement ImplementaionPlan indicatesactons which willbe undertakn by CMSG employeeswhen the Companycontrols or performs developmentor operationsactivities for a partcular project When CMSGis an investor but is not controllingor performingthese fnmctions,it will advocateenvironmental management measures which paralle and meet the intent of those presented hee. 16 01104196 CMSGENERATION ENVIRONMENTALMANAGEMENT IMPLEMENTATION PLAN The comprehensiveEMS is not just a book of requirementsstuck on a shelf, but an evolving program, with built-invehicles for improvement. Audits, assessments,reporting, communica- tions and training are all designedto provide continuousimprovement. Autits. As describedin the corporatestandard on audits and assessments,audits of operating facilites and of the other aspectsof the environmentalmanagement program are conducted on a regular basis. Informationfrom the audits is used to pinpointareas for improvementand to identifycbnges to the envionmental managementprogram whichmay be needed. An en'iromnental comnplianceaudit is an evaluation of the current state of compliance of a particular facility with all applicableenvironmental requirements identified for the audit. To assure that CMSG can perform such detiled self-examinaton while minimizingexposure to enforement risk associatedwith discovery of apparent discrepancieswith requirements, the documentsassociated with an audit are communicatedto and from CMS Legal department, for the purpose of gatheing factsto render legal advice. Control of audit documentsin this manner is to preserveattorney-client privilege. Complianceaudits are conductedat least once every three years at each facility,are performed by an independentthird-party auditor, and as a practcmatter, are scheduledand managed by the Managerof EnvironmentalAffairs. An environmenal operanonal asessmen is that portion of a formal internal assessment of compliancewith CMSG operationalstandards which deals specificallywith environmental issues. The purposeof an internalOPaional assessmentis to reviewplant methodsand practices, with the goal of identifyingbest practicesto be shared with other facilities, and area for imProvementto be addrssed by the assessedfadlity. Operaional assessmentsare conductedby plant and/or CMSGcorporate pesonnel at least once every three years. The goal of these formal facilityevaluations is to have reviewsperformed two out of every three years. The need for more or less frequent formal reviewsfor a specificfacility may be recommendedby the Managerof EnvironmentalAffairs after consultationwith the appropriate Plant and GeneralManagers and CMS Legal department. Informalassesusmem may be conductedfrom time to time by the Plant Mlanager,the Managerof EnvironmentalAffairs, or other corporateor plant staff,as needed. An audit or appraisalofthe comprehensiveEMS is an evaluationof the adequacyand efficien- cy of the elementsof that systemin carrying out the CMSG environmentalpolicy and assuring all CMSG stakeholdersthat the Companytakes appropnate actionsto protect the environment while remaining competitive. The appraisal provides an assessmentof whether the appropriate tools, resources, trainingand documentationare in place to assure compliancewith the Company's environmentalpolicy. In addition, the appraisal examinescompliance with corporate standardsand non-opertions requirements describedin this EnvironmentalManage- ment Implementaton Plan applicableto individuals and groups not coveredby facility compli- 01/04/96 17 ENVIRONMENTALMANAGEMENT MPLEMENTATION PLAN CMS GENERATION ance audits. Apprisals of the comprehensiveEMS's effectivenessshould be conducted at least once every three years. The audit is conducted under the direction of the President of CMSG who will appoint an employeeof the Companyto coordinatethe audit and follow up actions. Repollng and CoMiniCafions. As described in corpoate standardson reporting, plants are required to provide monthlyreporting of envirnmental performance measures to the Manager of Envirnmental Affairs. These measuresare used to track and trend facility environmental performance,and to determie recipientsof awards for environmental excel- lence. Reportingon trendsof these measures and trends in environmentalreguation is provided to the plantsand CMSGofficers by the Managerof EnvironmentalAffairs on a quarterly basis. Both existing and new ental requiremnentsapplicable to specific facilities operatedby CMSG are commid to employeesat their respectv locations. The Manager of Environmental Affairs is responsiblefor such commu on to General and Plant Managers. Each Plant Manageris responile for assuring that such informationis communicated to employees at the plant. Requirementsfor project in the developmentstage are commuicated to employees workingan those projects by the hanager of EnvironmentalAffairs. Every employeeis encouragedto work throughhis or her Supervo and/or Plant Managerto identify and resolvespeific facility envimnmentalcompliance concems. If the nature of the concern prcvents such communication,the employeemay contactthe Manager of Environmen- ta Affais or CMS Legal departmentdirectly. 2ining As describedin the corporate standardon taining, all CMSG employeesare expected to receve a level of environmental training commensrate with their job responsibili- ties. Addidonal trainingneeds for improved performanceare identifiedthrough audits, assessments and appaisals. 18 01104/96 CMS GENERATION ENVRONMENTALMANAGEMENT IMLEMENTATION PLAN DOCUTF7 In addition to this Environmental ManagementImplementation Plan, major documents which make up the written portion of the Company's comprehensive EMS include the Environmental Policy Statement, Corporate Standards, Environmental Requirements, and Plant Procedures. Together, these documents comprise the CMSG Environmental Management Manual, which compiles the major written elements of Company's comprehensive EMS into one location. Except for Plant Procedures, which are generated/updated by the Plant Manager or his or her designee, the Manager of Envimnmental Affairs (EA) is responsible for geneating draft (new or revised) versions of these documents. Responsibilities for review and approval of these documents are sumnarized below: Domument Rviewers A=mYal Policy Staement General Managers CEO VP, Operations Other Officers CMS Legal Implementation Plan Plant Managers CEO GeneralManagers VP, Operations Other Officers CMS Human Resources CMS Legal Corporate Standards Plant Managers VP, Operations General Managers CMS Legal Environmental Requirements Plant Managers Manager, EA Genl Managers VP, Operations CMS Legal Plant Procedures General Manager Plant Manager Manager, EA The purpose of the Environmental ManagementManual is to have a specific location for current descriptions of all facility-related environmental requirements, corporate standards and other EMS program elements. The Manual may be distributed in paper andlor electronic form, and it is the responsibility of the Manager of Environmental Affairs to maintin a list of Manual holders and the most current version of each document, and to assure that the most current version of each document is distributedto the appropriate Manual holders. 01/04/96 19 I I I I GEORATETONIK~~~~~~~~~ CORPORATE STANDARDS p *~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ CORPORATE STANDARDS NUMB SUBJES ISSUE DATE ENV-CMS-001 ACQUISMON AND POSSESSION OF PERMITS 01/09/96 ENV-CMS-002 COMPLIANCE WITH REQUIEMENTS 01/05/96 ENV-CMS-003 COMMINENT SCHEDULE 01/05/96 ENV-CMS-004 TRAINING 01105/96 ENV-CMS-005 ENVIRONNTAL EXCELLENCE 01/09/96 ENV-CMS-006 AGENCY MEETINGS/DISCUSSIONS 01/08196 ENV-CMS-007 AGENCY INSPECTIONS 01/09/96 ENV-CMS-008 RESPONSE TO ENVIRONMENTAL EMERGENCIES 01/09196 ENV-CMSl09 PERIODIC ROUTI REPORTING 01109/96 ENV-CMS-o10 NONROUTINE REPORTING 01/09/96 ENV-CMS-Oll NOVs, CITATIONS, EFORCEMENT ACTIONS 01109/96 ENV-CMS-0 12 RECORDKEEPING 01/09/96 ENV-CMS-013 AUDITS, ASSESSMENTS AND APPRAISALS 01/09196 I ENVIRONMENTAL IOO1 STANDARDS ______ENV-CMS-001 * Q~~1I45 Corporate ACQU1SMONAND POSSESSON OF PERM[S STANDARD: CMSGCpersonnd responsiblefor devdeopinga newproject will amre that aDlneca evironmentl permits and approvalsare obtained. CMSGCpesonnel responsillefor opaatig a faiTy wi have a copy of ad appricablepemits and approvals on-ste or readily avaable, and wIl asure that any new permits, approvalsor permitmodificions for new or modiriedsite equipment, fuels or operat are obtained. CMSGC i t Affairs wMasum ihata sy is in plae to provideCMSGC-opad facties wtaion of other applble (non-pemi) eniromnta I AC77ON: _ DEYELOZ-MENERo MA -A * conut wih Envioena Affairs to detanni ppcab envi- ronmeaa enfs ad pennung needs for ne prjects ea* in project cis. * hie anardanW conhw& wih ouside envwneal seric *0 wan ta al reqrdpennt a obtaindor to coRnIgent projectactii * prove a cop of ach einmenipennp qapcoo, drft penit andfinalpenit o EtironmenaAffai, d on appoi nt, thnw ant Manager. * tWer en ronm ais to facility no lter &a commrcia UwU9. 01109/961 ENV-CMI&OO1 ACQUISITON ANDPOSSFSON OF PERMIT AC7ION (cont): FAC1,L77 * coazuakwith Fnvironmena Affairs to detedmineappliabk eWn- ronmna rr s d pembing eedsfor new or mod#e ste peauos or equ4ent Cadyin proje aotes. * hire and contrmts of ouide aonmentl servce providersas eeded, am that all nqrudpenikts a obtaied por to coingent prjec advt e. * prid a CoPyOf e4ch permftappficatiof, draft pazei anifnapem to Envmr ental Afirs, and maintain a copy of acw at thefacily. RNWRQNMZ&AL PA * revie plsforew d projectsand new or revisedsite peons or equmen andprovide sfor p- preachcsto sigaca ises, pmng a tegies and/oroutsi saice p ,videas reuese by te Development Prjeca Ma- ager or Pan Manager. a prvide tech review ad/rore of oside envron- Y,ntal sa*e provWrs as requeste * riew perit od dn* pernits and censut as neces- iI1:iwr CAtSLeZg4 CMSGC lAntSuppontj andlor the Develop- met Projec Manageror Pant Manageron any siguLcnt isues p e (or w Sheprovision oj) copiesof ppicabl (non- perit) Fdlnd state en r irementsto each fSGC.ope,dfailt. * adise Enviromntal Affairs as requestedon egal or rruasotry issesassoiated withpermio ordnfpereft. * riew aplcabl (non-permit)Fedal andste cnronmnta reqbmen&s developedby EnvironanentalAffair, prior toisuanc to CMSCGC-opeedfacit. 2 01/09196 ACQUISITION ANDPOSSESSION OF PERMIS ENV-CM-001 ACTON (cont): =LANTEWPM * advse Envnmental Affairsas requestedon opermionsussues associatedwith permit appications or dnift penmits. RECORDS: DEVELDPENT PROTFC MANAGfER *copies of all permitapplcations and finl permitsduring develop- mentand construction. FACILtIY * op of all permitapplications, final permits and other envirm- mentaleinents duringoperation, for life of facility. BASIS: CMSGCEnvironmental Policy Statementand Envionmental Manage- ment Implntation Plan DErAIL: Complancewith i enal requiremes beginswith lmowledgeof what those req ns are. CMSGC Envimamental Affairs can reviewproposed new projects and changesm fuels,equipment or opera- tions whiChcould impact the evironment at existingfacilities, and assist deelopmentor opations managersin detrminingappLicable envirn- men uimnts anddeveloping srtegies to addressthose require- ments. EnviromentalAffais can alsorview pmt applicationsand draftpermis receivedfrom environmental agencies to asure that com- mits madeare const wifthapplicable requirements, CMSGC environmnal policy, and CbSGC oprtonal pracces. Fialy, Environme=talAffairs has the toolsand mandate to tack applicable Fedeal and stateenvmental regulations,and to assue that opeafing facilitiesare providedwiffi cpies of applicablerequirements. It is importantthat personsreponsible for currentactvities on a project (whetherin developmentor opamt) haveailable to them the current veon of any applicablepmits and othe appicable ennmental requiements as a referencedocument and a remminderof comtments. Therefore, maintainingcurrent copie of applicablepermits is the rponsility of the appropriate(development or opeatons) manager (see also ENV-CMS-012). CONTACTS: Questionson this standardmay be directed to the Manager of Envirm- mentalAffain. 01109196 3 II£ i El~ I to' U~~~~~~~~P ENV-CMS-002 COMPLIANCE WTH REQUREMENMS ACTION (coat): Ei4C7rl ai * put intoplace the organizationalandfunacial resourcesnecessay to assre compliancewih al penit wadother einmmental requimnens (see sw EWCAS-03). * devedopfacL*6-jpecc prcedures sae to im ent envi- rvnenal complianceactvte, and prvide to Envnmental Affausfor rviw (see CMSGEnvnentoa Managemet Impl- mentton P1wfor recommendpcedre subiects). advsec Devdopmen ProjectManager as req ed on technicaland qlaotoy aspectsof environmentalcontrl and monitonag eqgp adse Conson A ger as requestedon environmental requirementdwing coo, wnm-overand stanup. * advisePlant Manager as requestd en environmentaleureet during tS-owerap and operation. * reiw plontproedures devloped to implme envrnmental £MSLRGAL review nd rovecostrudion co ts priorto CfSGC sign- fng. * rview consuction contractorsubmisduwing um-overand "ur"p, as rqueste * adviseConst on Manageras reested on kegolor regulaory requirementsduring construaion,turn-ever and startap. * advisePlant Manager as requestedon kgal and regudatoryre- quireentsduring tun-over, st p wd operion. RECORDS: None BASIS: CMSGCEnviren al Policy Stamet and En tal Manage- ment ImplementationPlan 2 01/QSt96 COMPLUNCEWrTH REQUIRMNTS ENV-CMS-002 DETAIL Ongoing compliancewith environmentalrequirements requires dt persons responsiblefor currentactivities on a project(whether in develop- met, consuction or operation)take the lead role in ssug that those. activities are done correctly. If resources allow, Plant Managers are urged to assign responsbilityfor monitoringand auring plant environ- mental complianceto a site environmentalcoordinator. Environmental Affauis can prvide tchnical and regulatoy advice and support and CMS Legal can provide regulatoryand legal advice and support CONTACTS: Questionson this standardmay be directedto the Managerof Environ- menl Affairs. 01/05/96 3 # l t~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ENVIRONMENTAL ENV-CMS003 STANDARDS, CA45' Corporate ~~AT~~J commmT SCHEDULE STANDARD: CMSGC-opeMtedfaCElieS iW developand use an annl sched- ule or matrix descriWg environmentalinspection, monitoring, reporting, notification,triing, records managemnt and/or scmomtr -A AC7ON:.FAL * developan annualscdule or matir descuibingenvomental Fction,monitoing, reporing, notcation, tdning, recoris wwwzgeawatand/or similar commient reqrmen, andpro- vide a copyto Avironwnzal Affaim. * rviwfacility commitment schedulefor completenessand accu- rac, and peixdal=y reviewfaciliy suausagainst the schedule. CMSL-rAL rvnewfaci'liy commtmn schedukfor completenessand accu- racy. RECORDS: None BASIS: CMSGCEnvimental PolicyStatement and EnvionmentalManage- ment i Plan DErAIL: Ananual scheduleor matrixdescnibing peiodic e metal commit- ments is a usefl tool for assuringthat persons responsile for environ- mentalcompliance actvities act on all of thosecommitnwts (especially the oneswhids occur less frequentlythan monthlyor quartery). The formatof theschedule or its location(e.g., a wallchart, pages in a planner,part of a compute trcgd srstem, ec.) is not particularly importt, as longas the tool is easilyaccessible to thosewho need to refer to iL Sourcesfor commumentrequirems may iclude suchthings as permis, spilland/or pollution preveion plans,consen orders, monitoring plans, Federal state,or localregulatons, etc. 01/05/96 1 ENV-CMS-003 cobrNET SCHEDULE CONTACMS: Questionson this stanrd maybe directedto the Managerof Environmen- tal Afirs. 2 0105/96 ENVIRONMENTAL APPVWA0 STANDARDS 0115 Corporate I_ S ~~~~~~~~TRAINING STANDARD: MI CMSGC employees wM receive a level of e mental train- ing appropriate to their job responsibies. AC77ON: ACILl * iclude envimnmeta awarness training as part of new employee oriaton, aid prvvide annl environmentu awareness re- fisher runing to all employees,as needed. * ass 3 assure tha trinng requd by specificenvinmnta reguaion, progrmn, pent condition, ae., is conductedat the required interals. anist he facily with training needs awlysis, conducdng traning, and/or recommending ounsidetraig resomes, as needed * developor obtain an environmenal awarenesstgprogrmn for use byfacwes * asses ongoingfacilty envnmenta tining effectiveness and assist with updatn or n ing trainingprograms and materials as needed. OWAlEJ A ARS * assre that Plant Managers (and, f applcabe, site enironmnentl coorditors) receive initia tining on CMSGC, Federl and state environmental reqzirements. * aist the Manager of Training with specificationof the scope and content of an environmentalawareness training program. 01/05/96 1 ENV-CMS-004 TRAING RECORDS: FACIL * documentationof environmentaltaining providedto each em- ployee,for 3 years. BASIS: CMSGCEnvironmental Policy Statementand EnvironmentalManage- ment lmplementationPlan DETAIL: Tee are threelevels of facity envirnmental taining: * Eromiww al awaees rining. Basicen awareess trnin is an intrducio to the various v mental media,and plant equpmentand operaos whichcould have a dimrt impacton thosemedia It can be an effectivetool in preventingthe escalation of equipmet or opefional problems into major envirnmen- tal concerns.As such, initialen entl awarenesstaining is for each new faity employee, and annual refeser trAinn is I m for al &cility employees. This training is developedby the Mimagerof Trainingand deliveredby facility staff. * Job-specficaen w lining. This is taining whichis not neily requiredby s or reguation, but is necessaryfor employeeswith speific evionmental complianceresponsibilities to cary out thoseresobilities iman efficientmanner whfile ensuring complian. The taining mayconsist of on-the-jobtraining (e.g., CElS opertions, maintenance,andor calibraion)andor training providedby outsideexperts (&g., idvidual aining for Plant Maers and site mental cdt on CMSGC and appcable Federaland state vmental reguons by Envim- mentl Affairs,smin on mentalreuations by outside fims, ec.). Jo-pecfic taining is requred inially wh a person te on a newjob or new responsibilitiesinlving irnmm cmplianceacivities, or whenchges in mreqre- mentsdictat the needfor changesin the waythose activities are perfox * requd Cronmma ing. Unlie OSHA few envonmentalstattes *requirtining as a programelement. Thosegmat do (eg., spillplan, int eand repairof CFC- conmining figeation equipment,etc.) may or may not be applica- ble to a patcula faity. It is the PlantManager's resposibility tD reviewthe envirwnal r enapplicable to his/her 2 01/05/96 TRAINING ENV-CMS-004 DETIA (cont): paricular facility providedas part of the CMSGCcomprehensive EnvironmentalManagement System for specific raining require- ments, and to assure that those requirementsare met. Training requirementsfor OSHAprograms are addressedin the CMSGC comprehensiveSafety & Health Reference Manualand the CMSGC SafetyTraining Manual. The Managerof Trainmg can assess the effectivenessof facility envimn- mental mtainingand assist with updating or improving trainingprogams and materials as needed. CONTACTS: Questons on this standardmay be directed to the Manager of Environ- mental Affairs. Questionson taining needs, contentor resourcesmay be diected to the Manger of Traning. 01/05196 3 4 l 4 E NTA ENVTALECMS005 STANDARDS C445S Corporate ' ~~~~~ENVIRONMENTAL 1E1 ENC STANDARD: CMSGC-operatedfacilities may qalfy for annual awards for environmental ezcellence,based on criteriaand performance levels described below. AC1ION: E NAfXW,ILmVRO EFAA * establishciteriafor anal Environmental ExcellenceAwardsfor CMSGC-qperafedfaes (see DETAIL below). * estabis crkeriafor EnvironmentalManager's SpecialAwardfor CMSGC-op,ratedfaiis (see DETAIL below). * evaluatefacily perfonnae against award criena and recom- mend awardreckies to Generd Managers and Vice-Presidentof Openztions PAC * comply withpemt and other environmentalre ents to qualiyfor anum Enwirnental ErcelZenceAwards (see DE- TAL below). - rduce szons4discharpes, and/or wastegenertion, or take otherproaci e stepsto nprvve or enhancefacilify environmentul perfonae to qualifyfor the Envionmental Manager's Special Award (see DEAL below). GENEE-L MANA iES * r Enerw nnzentaAffai' evauon offacayperfonrance against awardcritea and recommendaward recwipentsto the ice-Predent of Operations. WCEWn)EEv OF OPI7ONS * sdect awad recipientsbased on recommendationsreceivedfrom Environmenal Affairs and General Managers. 01/09196 ENV-CMS-005 ENVIRONTENTAL EXCE I ENCE ACION (coat): CMSCO CA TON.S * communicate jafonnamionon awani reczpiens and baAssfor awans to ap4prvpriate news media. RECORDS: None. BASIS: CMSGC Environmentl Policy SLttementand Envirnmental Manage- ment ImplementationPlan DETAIL-: EnvronmentaErlknce Aiwzrds. CMSGC recognie exceptional nvironment performce of the faciliti it opertes through annual Envionmental Fcellen Awards. Awards are given to faciiies achieving outstanding compliance records, according to the following aiteria. * 999%or greaterannual average compliance with all applicable air emissionlimits combined(e.g., SQ2, NO., CO, opacity, etc.).[NOT compliancewith all applicable... lmits com- bined"means average compliance for all parametrs measured (e.g., 100% annual compliance with applicable SO2, NOx, and CO limits, combined with 96% amiual average compliance with an opacity limit would average to 99% overall). In addition, compiance is measured aainst all applicable requiments (ie.., if emission exceedences are eompted during sttup or shutdown by regulation or permit condition, such exceedecs are not counted 2gainst complin percentage).] * 99% ar greater annual average compliance with all applicable wat discharg limits combined (e.g., pH, teperature, sus- pended or dissolved solids, chemical or metal cotration hmt, toict, cm.). * 95% or greater annual average CEMS availability (all parame- ts combined). * conduct vimtal ar taining for all employees at last once per year. * no fedealy rporable spills or releses (see ENV-SPL-US02 and ENV-SPL-US03). 2 01109196 ENVMRONMENTALEXCELLENCE ENV-CMS-O05 DETAIL (cont): * no letters of violation (LOVs),notices of violation (NOVs), citationsor other enforcementactions received which result in a fine, consent or other admiirative order, or any other sanc- tion against the facility or its employees. * 99% or greater annual aveage compliancewith all appicable wat quality requirementscombined (e.g., dissolved oxygen, clarity, hmal limits, and assoiated ronse activities). * 99% or greater annualaverage compliance with all applicable fish passage, biologal monitoing, rver flow or other related facility-specific reAiemIt combined. * conductenimental awarenesstraining for all employeesat least once per year. * no federally reportablespills or rlases (see ENV-SPL-US02 and ENV-SPL-US03). * no letters of violation(LOVs), notices of violation(NOVs), citaions or other enforcementactions receivedwhich result in a fine, consent or other administtve order, or any other sanc- nio against the facility or its eWployees. F:ed PnDeessngand Ofher FadMa * 99% or greater annual compliancewith all inspection, monitor- ing, nodfication, repoting and rerdping re ments containedin permits or plans (spillplans, emergencyresponse plans, stormwaterpollution pweention plans, etc.)combined. * conductenviomental aware Wainingfor all employeesat least once per yer * no federally reportablespls or relases (see ENV-SPL-US02 and ENV-SPL-US03). * no letters of violation(LOVs), notices of violation (NOVs), citationsor other enforcementactions receivedwhich result in a fine, consent or other administrativeorder, or any other sanc- tion against the ficity or its employees. 01109196 3 ENV-CMS-005 ENVIONENTAL EXCELLENCE DETAIL(cont): Documtion of ffity performanceis providedto CMScopoZate officeson a monthlybasis, as descnbedin ENV-CMS-009and in the operatingstandard on plant reporting. Everyfacility which meetsthe aplicable crteria aboveon a calendar-yearbasis receives an award. Envimnalz Manager'sSpecial Awms. CMSGCalso recognizes erceptionalenvironmental perfbrmance of the facilitiesit operates thrugh Enonmtal M ger's SpecialAwards. Theseawards are givento faciliti thatgo beyondcompliance to developand implementa proactive nvironmentalethic at the site. Kindsof actvities which enablea fiity to qualifyfor this awardinclude, but are not limitedto: * redu s m emsons, dischargesand/or solidwaste on a massper imitof production(tonslMWhr) basis, resultingfrom changesin fuel treatment, equipment,or operatingpractices. * reductionsin nnualvolume (cu yd) or mass (tons)of solidand/or hazardouswaste genra due to changes to less polluting matei- als, rcuse of materialsor wastes, or recycing of material previously siderd wae (used oil, offlce paper, adboard, metal, plastic, glass, etc.)., evionmental ncementactivities, such as establishinghabitats on otherwiseunused site land, or working with state or pnvate cosvafton groupsto pct or enhancelocal envimmentally sensitv areasnot an the immediat plant site. * taining, educationand/or community outreach activines designed to or enhanc enimtal awarenessof site employees, loca schoolsand/or community groups. Reductio in emimions,disharges, and wastegenerated will be calcu- latedby irmental Affairs. However,docmention specific activitiesor measues which coniuted tD such reductions, and docu- mentain on othersim nmentalenhncement or outreachactivi- ties, should be sent to the Mana of al Affairs no later than January 31 followingthe calendar year during which the actvity began or took place. Generl Managers,Plant Managers, siLteenvio- mentalcoordinators or other site employeesinvolved m evnental enhancenientacivies are encouragedto providea brief writtendescrip- tion of the activity and resulting benefits. Although ongong activities wi be consideredfor theSpecial Award, new or innovativeacthivties wi be moreheavfly weighted. An awardwill be madeto each cility that, in the opinionof the Manager of Envirmmental Affairs, exhibits 4 01109/96 ENVIRONMENTALEXCEENCE ENV-CMS-005 DETAIL(cont): outstandingenvironmental leadership through activities that meet the intent of the criteria describedabove. CONTACTS: Questionson this standardmay be directd to the Manager of Environ- mental Affairs. 01109196 - t I I I - pp-. ENVIRONNENTAL _ENV-CMS-006 STAN)ARDS OLJS Corporate AGENCY MEETINGS/DISCUSSIONS STANDARD: CMSGC-opeated fac"ites ar authorized to communicate directly with federl, state and local environmental agencies Significant results of meetin and discssions wih such agencies will be reported to Environmental Affairs, following the guideIlinespro- vided below. ACIION: FACZL7 * whenpossbibl, inform Environmental Affain at lea one week in advanceof meetings with eranmental agence at which signifi- can issues ae expectedto be discusseL o fterf/ace-to-faceor telephonediscussions with environmental agencis, contactEnvironmental Affairs wihn one businessday by phone orfax, if sgnfc issus werediscussed or specific commtments made. ENMR!MEN3TAL AM IRS * provide aistnce tofacily, as requested n preparingfor, paicpating in, and/orfollowing uqpon meeings with environ- ment agencies. * drmine needforadionalfoow-p orkgal suppon. GENERAL MANAGER * as Ennronmental Affas, as necessy, to asswurnely com- pleton offo/low-p actives. RECORDS: FACDLTTY * documentation/ summaryof significantissues and/or commtments made in discussionswith environmentalagencies, for life of faciliy. BASIS: CMSGCEnvironmental Policy Statement and EnvironmentalManage- ment p ion Plan 01108/96 ENV-CMS-006 AGENCY MEETINGS/DISCUSSIONS DETAIL Meetngsor discussionswith pesonel fromenvirommental agencies can occurat any time, and are mostapopriately handledby facilitystaff mostdirectly involved in facilty environmentalcompliance activities. EnvironmentalAffairs can provide technical and regulatoryadvice and sWportto assistthe faility in developingaproches to significant issue or strtegies for dealingwith agencystaff. It is not nemry to contactEninmeotal Affairsfor every meetingor tephone call with an env ntal agency. Dowever,those at which signifa nt issues PlantMaager's judgement)are discussedor specfic commitments made should be documentedboth to file and to Environ- mental Affairs. Dependingon the natue of the issuesinvolved, Environmenta Affairs may reViewthe needto involveCMS Legal, the appiate Genel Manager, and/or others, as needed. CONTACrS: Quesis an this standardmay be directedto the Managerof Environ- mental Affairs. 2 01/08/96 ENVIRONMENTALA NMS-0 STANDARDS_ C445 Corporate AGENCYINSPECTIONS STANDARD: CMSGC-operatedfacilites dealing with a site inspectionby person- nel fromfederal, state or localenvironmental protection or enforce- ment agencieswill attempt to cooperte with the inspector(s), followingthe guidelinesprovided below. AC77ON: E-LA * upon arwal of an inspeaorfrom an envronmntal agency, det- Rune the purpose of &eviit, incate wlngnes to cooperate,and rrngefor a knowedgebk escort (see DETALLbelow). * as a geurd rkde,provide smples and copiesof recordsrequested (se DETAILbelow). determinec whether anyfollow-up actionis reqsired * providea briefwritt summy of thevisit to Enironmentl Affas and 1wqppriate Gened Managerwithin one wek (see DETALLbelow). ERQAMEFL A F4A reew inspectionrport smmay and dermine nedfor ad- tonalfoilow-u or legalsupport GENERAL MANAGER * Envirovnm Affars, as nway, to ssure timy conple- fion offfow-p ac*ivite * a facilitywith im niateresponse to semh warrs and crial snveugations(see DETAIL bedow). RECORDS: EA£&ILrr * copiesof recods providedto envimn tentainspts, for 3 years. 01109196 ENV-CMS-007 AGENCY INSPECrIONS RECORDS (coat): PAMC=(rrr * copiesof all correspondencewith environmentalagemnces, for life of facilityor untilexpiration of retentionperiod associated with a specfic req t BASIS: CMSGCEnvironmental Policy Statement and EnvironmentalManage- ment Iementaton Plan DETAIL- Site inspectionsby personnelfrom ental protectionor enforce- mentagences can occurat any fme, althoughmany environmental regulationsspecify ta they happenat reasonabletimes (eg., normal buin hours). Sometmesvisits are scduled in advance,while at otherfimes they may be unannounced.They may be targetedtowards a sitespecificssu (cg., repored exceedencesof permitlimit; neighbor complaints,etr.), but moreoften, theyare simplygeneral or routine. Frequently,they cover one tal programarea (e.g., air, water,waste manat, etc.), but theycan covermultiple ars (mulimediia inpcc&ns). As a general ru, indicamewilingness to cooperate. Thr is rarely, if cv, anyting to be gainedby fuin rasonablerequests or antagoniz- ing ft inspector. Cooperon graly leadsto greaterflexibilty and discon on thepart of the inspector,whic can resultin a better inpcto outcome.Be responsiveto quesons, but be focused. There is no need to vohmnte u ested iformation. Detmin thepwpose of the vis. Usuy, thiswill be explainedby the inspect up-nt, but if not, ask. Unlessthe inspectorindicates that the inspectionis part of a criminal inestg, s/he wil not have a searchwarran, nor shuld s/he be asked produceone. However,if the insctor doesproduce a search warrant, the facily has no choicebut to coperat withinthe specificsope of that warnant,and should eontact Bob Schroderat (313)441-276 or (810) 229-8401(home), r Neil Fellowsat (313)436-9250. Inspectoncontent. An inspetion usualy consistsof: an initialmeeting for intoductons and to explainthe purpose and scopeof the visi; a tour of the fility (or keyareas reated to the scopeof the visit); eaminaton of key records;and a dosing meetingto disc obsenions and follow- up actions. Arangefor a kowledgeabk escowr The pla manager should, if at all possible,parcipate m at least the openg and closingmeetings. 2 01/09/96 AGENCYINSPECTIONS ENV-CMS-007 DETAIL (cont.): Appropriat facility envimentl, engineering and/or opafions managementstaff shouldaccompany the inspector throughoutthe ispec- tion. InspectorRequet. In some cases, the inspector may request fuel, other raw mateial, or waste samples. These should be obtamed according to plant and/or EPA-approvedsampling procedures, and the faility should request split samplesfor its own use later, should the results of the rnS~)ectO'ssampling and analysis indicate problems. Copies of recordsare also frequentlyrequested. In geneal, provide requested copiesof recordsrelated to the scope of the inspecti6n,unless they are marked Confidentiamlor Attorney-ClientPrivilege". Make two copies of everything- one for the inspector, and one for plant file, so that a separdt file recordis made of exactly what was provided. In some cases, the amountof infomaion requested will be so voluminous as to requie considerabletime to compile and copy. Usually,a reason- able inspecor wi allow toe copies to be providedin a follow-up tansmittal withinthe next week or so. Deminc w*edheraryflow-up acuionis equred. At the conlusion of the insPecdon,facility staff should have an idea of the inspector's impressionsand whetherslhe expects any follow-upactivifies. Although awnen reportwill probablynot be prvided at that time (if evier),the inspector shouldbe able to explainwhat (if anything)to expt next, and whoto contactfor follow-up. Sunary Report. After compleion of the vist, provide a narraive ummary of the visit to Envirnmental Affairs and the appoae GeneralManag. nlude the inspe's name, the agency resented, the date, timeand durtio of the inspection, the scope of the hLspectin, facfity personnelinvolved in meeigs and acting as escorts, a descrip- tion of any samplestaken and records provided, an evaluationof the results of the inspeion, and a description of any requestedfollow-p activities. CONTACTS: It is not necessaryto contactEnvironmental Affairs before or during an inspection;howev, the Managerof EnvironmentalAffairs may be contactedif questionsarise or spport is needed. Questio reLatedto protecion of documents, criminalinspections or mvstgato should be directed to CMS Legal. 01/09/96 3 1 1~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~. ENV-CMS-O09 PERODIC ROUTI REPORTNG RECORDS: FACL:TY * coies of all corespondencewith envirommentalagencies, for life of fcility or until expirationof retention period assodated with a spcfcrequiremenL BWVRQNiME-IATLAEBATRS * copiesof quarterlystatus reports, for two years. BAMSI: CMSGCEnvironmntal Policy Staement and EnvironmentalManage- ment Impenattio Plan DETAI Copliance and communi are two of the comerstonesof the CMSGCenvimeal policy. Penodic reporting is used to keep managementinformd on the status of fcilitY compliance,performance trends,and the outlookfor changes which could impact coporate asseu or opetions. Periodicrportig is also used to kep optg fcilites iformed as to currentand changingenmental uiremerem. Periodicreoting reuired by permit or other commitment(see ENV- CMS-003)is submittedby the fciity direcy to the app iate envi- ronmentalagency. unless the report meets the cteria for nonroutine reporting(see ENV-CMS-OlO),no prior review of the report by Envi- ronmentalAffairs and no copyingof the report to Environental Affairs is required. For example,roufine monthly or quarterly monitoring reports, includingthose which show exceednces of permit limits (e.g., ecess emissionreports), are not requiredto be sent to Environental Affais. Note, however,that the tansmttal letters for such reports shouldavoid use of the term vioation' in reporting operationsor data outsideof pemit lmits. Phrases such as 'a;ess emions, discharge in exceedenceof permitlimits or the like, are preferable ways of expressing the samecncep. MondhlyRepots. Each facilityprovides a monthlyhard copy or elmc- tronc report to the CMSGC corporate office mmarng fclity operations,as descied in the CMSGCoperational standard on plant reoting. This reportincudes mmary infomation on onS, discharges,CEMS availability,spilis, and LOVlNOVs,and is used to track compliancetrends and calculateannual compliancepercentages for envionmentalexcdllnce awards (see ENV-CMS-005). Quarerly Report. Enviromental Afairs provides a quarterly report to the faciliies and CMSGCmanagement smmaing the information 2 01/09/96 P1RIODIC ROUTINE REPORTING ENV-CMS-O09 DErAU (cout): provide by the faciities, idmtifng trends, and describing anticipated or actul changesin environmentalrequirements, as follows: * Compliance Summary of monthlynumerical data on emion and discharge monitoring, number of spills and NOVs. Includesan analysis of trends, as applicable. -* Brief descriptionof emergingissues sated for or havingrecently had regulatoy acdon, and potential impact on asss and facility opmatons. * Oer Oth signifimt information, such as successes, Best Pactices, l leaned, and status of ental management systemimplementafion. CONTACTS: Quesnonson this standard may be directed to the Manager of Environ- mentalAf 01/09/96 3 EN'VIRONMENIAL 7N-MSO1 STANDARDSTy OHS5 Corporate NONROlUTINEREPORTING STANDARD: CMSGC-operated facities wil report siifiant nonotme iems such as fonnal agency infoon requests, apparent noncompli- ance, submftta1sof plaM, or requests for agencYapprovals to Envirnmental Affairs. CMSGC Enviomnenl Affairs and, as necemax, CMS Legl, wM provide counsel and advice on appropriate response. ACMION: FALIZ * rapoit agency wfen anmdsuiglant ver*alinfomazon reests, potealy rpotable spills, and contons which appear to be inconstentwth site en viomena quiremenus to E5nvionmen- ta Affain aan he apropriate Gewerl Manager by the end of Me fte buine day folowing e event or its discovery. * cop Enviromntl Affair on tine-cridea nonroutine agency wten reporing such as excess anion incident reports, spl rports, requesfor iwiance, etc. prvde a copy of odthrnonrsaine agenc sbmital such as notifications;plans (e.g., fugitive dst controlplans, monitoring pkns Ctc.)or rqusefor agency aprovals to Environmentl Affaiui for rew at least one weekpnor to scheduled submitaL QNM0MEhAL A EA R * rvview nonruune repoAfingrornfacaiies and consult with CMS Legal and the appropriateGeneral Manager on any significant * provide technic and regulory guidance to assistfaciities with resonse to agences. 01t09/96 ENV-CMS-010 NONROUJTINEREPORTING ACTION (cont): GERALMAArE * assi EnvironmentalAffairs, as necessary,to assuretimely resolu- ton of issues. a proide regulaoey and lgal guidance as requestd to assisfacl- des with responseto agences. RECORDS: FAM17T * copiesof all pondence wit ennmental agencies,for life of bacily or imtilexpiration of reteto penod assocated witha specfic reurma BAS: CMGC v Policy Statementand Envmental Manage- mml at l Plan DET'AIL Nonmute reportinginvolves actal or potentialcommunication with evironmentalagecies regarding nificantissues of an unusmalor nonecug natue. ronmentalAffairs can providetechnical and regulay adviceand supportand CMSLegl can providezegulatory and lepl adviceand sppot in tbe reviewof suchissues and associated communications,and assist faclty managersin reviewing applcable nviromental uements and dveloping ppiate responses. Nowutie reot of a time-cricl natue reqired to be sentto anv- romenta agenci within a shot peiod of time after an event (spill, exceedenceetc.), are not requiredto be reviewedby Environmental Afirs in advance,but shouldbe copiedto EnvuonmentalAffairs. Transmittalletters for such reportsshould avoid use of the term vwola- tonm' in reporfingopmtms or dataoutside of permitlimits. Phrases such as 'mce ons', 'discharge in exceedenceof permit limitc' or the lihk, are preerable ways of expressingthe sameconcepL CONTACTS: Questionson this sndard may be directedtD the Manager of Environ- mentalAffairs. 2 01J09J96 ENVIRONMENAqTA.L ENV-CM&1i STANDARDST.. Corporate NOVs, CITATIONS, ENFORCEAMENTACTIONS STANDARD: CMlSGC-operatedfiliites will respond to official enforcement documents and processes only after constaion ith CMPSLegal and Environmental Affairs. ACTION: FACiTPZ lvpo,tm any wntten agency Notice of Violation (NOV), Leter of Violation (L0o1, citaon or other enforcement document alleging or possible violton of or noncompliancewith environ- entalreqiremets to CMSLega4l Environmental Affaus and th aFFpropriaeGneml Manageras son as possibk (no later than the end of thefirst businessdayfollowing receiptof the docu- Dinen). £&fSEGAL view docaeMl provded byfacilty and developresponse stint- egy in constion with the facilty, Geneml Manager and Envi- vnmentalAffairs. EN3!IRNmENrAL AEEA aistCMS Lea andthe faity, as rquested in the develop- ment, reew and impleon of appopriate responseactvi- ties. GERNERALMANA GER * assi CMS Leg and the faciity in the development, rview and implementationof appropriaterewonse activities. RECORDS: FACLTrY *copies of all crespondence with environmentalagencies, for life of facity or until ePiraion of retntion period assoiated with a specific requirenent. Oi110996 ENV-CMS-01 1 NOVs, CrrATIONS, ENFORCEMENT ACTIONS BASIS: CMSGC Envinmental Policy Statementand Envnm etal Manage ment Implementation Plan DETAML Officialnodes from onmal agenciesalleging violation of enviroamentl states, rguais, and/or permit conditions ar always ak seriously. Prmpt and pproiate rview and response can frequenty MiniMi or eliminatepotential assoCiated penalties CMS Legal can pide rgatry and legaladvice and supportm the review of the issuesand socid communitions, and assistfaility managers in reviewing a le enrmnta rand develing apppIl Wresponses. CONTACTS: Quesi on enforcmet authonties, penalti, and any other legal isme may be diected to CMS Legal department Any other quests on this standard may be direcd to the Manager of Environmental Affaim 2 01109/96 ENVIRONMENTAL .ENV-CMS-012 STANDARDS .EVCS0 OHS *Corporate . | - J--XW RiCORDKEEING STANDARD: CMSGC-operated facities wM establish and maintain site environmental files for primary storage of all site-related environ- mental records. ACTION: D_EWE&FAIEROJECTMAMA establih and mainain projed envrxmetfilesforpnmWy storge of oUperms requiements, reports, submitals, corr- spocndcc, and otherproject-reated envonmentl records duing the developnent mad constnion phases of a project. * establifshand mafifa site envir;nmentaljflesfor prnay storage of allpermts, sandafs, procedures,monitoring dat repo4, subttal, conspondow0, trning documentaton, andother site-relatedenvirnment records. * establishand maintain a separteflefor doamens coveredby aoney-cln.t pivlege, accordingto gddnce provided by CMS LegL wnallypurgefies of rewrds for whih the retention period has EAJIOHMIENIALAEAR estbia and man coaporte environtaenentIsfordupliae storge ofpenzs standards, ir , procedres, and other sitelrcaed environent records, as needed to support site acavi- fim CMSLEGAL s fact with developinga processforapplying attorney- cdienpriviege to specfc reconds, d wih detenaon of whichdocumets Miht re such prvilege. 01109/96 1 ENV-CMS-012 R01CORDKEEPING RECORDS: N * as describedabove and in any otherapplicable corporate standard or environmentl rquiremezL FACUTTY * as described above and in any oth applicable coporate standard or eniomentalreqirement. ENROT-rAL APAR * as describedabove and m any otherapplicable corporat standardor environmentalreuemn BASIS: CMSGCEnvironuMntl Policy Statementand EnvironmentalManage- mentlemeation P2fL DErA:L~ Mostrecards assodated with site menal complianceactivities are eihr essental as referencedocunmt or requred by regulationto be kept on-site Manyrequired records, such as monitoxingdata, have specificrettin perods. To conseve file spaceand assure that only necesry recordsare maintined, recordswhich have exceeded thdir oqured retenti peiod shouldbe purgedfrom site fis at least once per year. For secui, it is srongly recommendedthat vimn recordsbe storedin a fireprooflockble cabnet Transferof e iental files fromdevelopment to operationsis coveredin the CMSGCEnvironmenti Management Ipl n Plan and ENV-CS-OO1. CONTACTS: Questionson this standardmay be directedto the Managerof Environ- menl Affairs. Questis on what kindsof recordsmight reqie arey-client prvi- legeand how to handlethose records may be died to CS Legal 2 oL/09/96 ENVIRONMENTAL ENV-CMS-013 STANDARDS aus Corporate WE?AI(W AUXITS,ASSESSMENTS A APRASLS STANDARD: Formal evahlation of CMSGC environmental management systems and CMSGC-operatedfacily evironmenal complance pro- gams wi be performed on a periodic bass Results wl be used to provide CMSGC managementand the affected facities the opportunity to improve the performance of these environmental MR m system and progms. ACTiON: ERA NMENTALEAEARS * in consulation with CfS Leal and the Generl Managers, deveop and qWdateas necessay, a schle for conductrngem- nrunemal compnce a d operatonal assmeit=, so that at last one audit and one assessmentis completedfor each facity evr three years. fiaize, by May 15 of each year, the list of specflcfaffWs to have enviro_mnnta compiance s complet during that caendar year, and derelopa list of those facfiites expected to have adits completeddwing thefolowing calendaryear. = definethe sope of eah auditand selecti ndentti-party audtorsfamilarwith en merualregqutions andfaciliy openztionsto perfonmthe scheduekididua audt basedon availabiy of keyfaciiy stcffand auditors. *rview dmft audit repor*tad coor&inateresolution of comment. * as neaed, thefacility with the idnt ion and evaluation of appropriae correctveactons. * use the final audit reportto identfy areas of paular strength adareafrovn ment forshaing with otherfaciaties. tckprogress on com tion of correctiveactions and work*wi the appropriateGeneml Manager to assure tiey resolution. 01J09/96 ENV-CMS-013 AUDITS, ASSESSMENTS AND ArPRAISAlS ACIION (corn): ENMONMENrAr A FFAM * assure thaan apprasal of the adequacy of the complete eniron- meal m8aneme system is condut at leat once every thr years. Take on the actons assigne to PFacility beJow dwing such an apprisl (see DETAIL below). * work with Envirnmnt Affau to detnmine sutable datesfora whedu audit. * riew and comment on dirft aud repots * dvelop proposed comredive actfons and schedul to address audt fndings. * use the fia audit repolt as a guide to ide /ti of and acion n aras for iprovement. * update the Genal Manager and Managerof Envionmena Affairs on a monthly basis on the status of unresolvedauditfid- mxgs. - complee correctve actions accoring to shedul, and return the fina audit rport to CMS Legal upon conmpwetonof aU cometive actions. Q;mVE0ALMANAGER * asis wih obtining apprafrom projectpartners, as necessary, for expenses aociated with audits. * assist the facity and ironmental Affausz, as needed, to asue tmey schedufing of a nd compltion of corretive actions. CMS&EAL * after co on with EviromentaAffas and the appropriate GenenuadMager, send afonmal leer requesing the thi-pany auditor to conduct an enio l compiance audit of a specfi facdlity. 2 01/09196 AUDITS, APPRAIALS AND ASSESSMS ENV-CMS-013 ACHON (cont): CMfLAL (o.W * receivethefonnal tansm of the dftaud rportfom the thid-pany auditor, and distribute to thefacty and Envinmen- adAffar for review ad comment. * reque the ret of al drft audi reportsand trwnmft comments and descriptionof proposed correcve actions to the thn-pany auditrfor incorporationin hefina aud report. * ai thefaciliy in addmng any potential noncomplance wu. * reve thefia audit reportfrom the hirdpany auditor, and tramit to the CM;SGCPresden4 Vice Presidentof Operations, Manager of Envirnmenal Affaim and the appropriateGeneral Manager andfacflt manager. * reque the retna of al ou aing copiesof fina audil repots upon cmapktion of &Ucorrective acons. RECORDS: CDSLEQAL * copies of all final audit reports and documentaton of completed coreci actins, for life of ciity. BAR : ClSGC Enviomental Policy Satemet and Eaviomtal Manage- meat Implemenatim Plan DETAIL In order to assure ha the envirmental compliae program is both effctive and provides for continuous improve t CMSGC manage- ment has included a program evaluan lement m iIs eimenal policy. EvaluadonType. This standard idenifies tee kinds of environmental evaluations: * an enfromal complance audit is an evaluation of the current stt of complianceof a particular fcility with all applicable envi- ronmental rqiements identified for te audiL To asse that CMSGC can perform such detied self-examinato while minimiz- ing exposure to enforcement risk assocated with discovery of apparent disc with rn, te documents aswsoiaed wifthan audit are commicated t ad from CMS Legal, for the 01109/96 3 ENV-CMS-013 AUDITS,ASSESSIENTS AND APPRAISALS DETAIL (cont): purpose of gathering cts to render lega adice. Control of audit doeuments in this manner is to preserve attomey-clientprivilege. * an e oental opaional sseent is that portion of a formal intemal assessmentof compliance with CMSGC opemtional standardswhich deals specificallywith envimental ssues. The conductof operationalassessments is describedin the CMSGC standardon Operatonl Assessments. * an appraisal of the enironmental management system is an ealuation of theadequacy and effidencyof the elementsof that systemin carryingout the aMSGC vronenta policyand assur- ing all CMGC stOkholders that the Company tkes apprpriate acbionsto proect the 'vinmuent whfle remaining compedtive. The conductof an apaisal is desried at the end of thisDETAL Schedulng.Scheduling of facilities to be auditedis dictted primarily by the amount of tixm since the previous audt and the number of current or rct compliance ssue Scope. In most situations,an audit will usually be a full-soopeevalua- monof compliancewithironmental ents, as describd in wt corporatesandards and all aplicable federl, stat and loml laws, regulaons and permits. In some cases, an audit may seekless detil in some areas(e.g., if recet evaluatios or compliancehistory shw snths m those armas)and/or more del in oes (eg., com- plete evaluationof wat streams for initial or rssment of hazardous waste geneator classificationand/or polution prevendon and waste minlii7fipn OPPo i). Other areas for evaluationmay include adequay of tining. too%s,communiations, resources, and/or attitudes and commtmet In all cases, the audito are expected tO xamime aprpit rcords, procedures,equipment and facilities, and to inter- view ficility staff having nvionmental sponsibities. SiuePrelimby Dra Report.The auditors will be asked to compUethe relts of their assessent into a site piminary draft report to be dismssed with facilitymanagement before the auditors leave the site. The st peminary draft report contains a narrave summaryof strengths and amas withoutfindings, followed by individual findings. Each finding includesa sgmplestatement of the specific requirmt and reference, the COndit as found by the auditors, and a ranking of Priority Action, Action Requhrd, or Action Recommended, based on 4 01109/96 AUIDrS,APPRASAS ANDASSESSNTS ENV-CMS-013 DETAIL (cont): the auditors'profesional evaluafionof the severityand niskof the specificfinding, as follows: * Prioty Aidon- The conditi is ongoing,and if allowedto con- tinue,represts significantepoure to enforcementand/or rsk of evronmental damage(e.g., lackof a requiredspi prevention plan). Coreive acto shouldbegin immediately and be com- pleted as soon as possible, not to exceed 30 days (my be extended by the GeneralManager and/or Manager of EnvironmentalAffairs as ccstances dic). * ATionRrn The conditionappears to be isolatedor doesnot represen significantexposure to enforcmet or risk of eavirmen- tal damage(geneally applies to reportingor reCOrdkeepg discrep- ancies).Corrective action is necessary,and shouldbe completedas soonas possible,not to exceed60 days. D Thecondition does not currentlyinvolve ncomphance,but if allowedto continue,could lead to exposureto nformt or risk of vnmtal damage(e.g., lackof a non- mandatoryspill prevention plan). Correctiveaction is recmmend- ad, andshould be implementedas soonas fimeand resourcesallow. Mhe auditors will also be asked to develop and present to the facility one or more possible actions to corect each finding. The fcility is encour- aged to discuss its options with the auditors and, if possible, commit to or complet appropae coretive actions before the auditors leave the Draf Au& Repont.The audit will be asked to providea draft audit report to CM Legalwithin 14 daysof the end of the on-siteaudiL This reportcontains the informationdeveloped for the sitepreiminary draft reportand any respomseactions or comtitmentsaready madeby the facility,in the followingformat. * Exe=iyeSummaiy No morethan a half-pagesummary of signifi- cant findings and orrectiv actons. * Audit So= 2nd Team. A brief descriptionof the regulatorypro- gramareas covered by theaudit and the namesand expeienceof the audit teammembe. 01/09/96 5 ENV-CMS-013 AUDWI, ASSESSMENTS AND APPRAISALS DErAIL (cont): * Facility and CotPct. A bri descriptionof the fakclityaudited and the names and positions of the fcility staff who provided infor- mationused duing the audit * Audit Aeas Withnut Findings- A brief descripfon of areas which appearto be in compiace th all aplicable ru . Note anyareas of particularstrength or innovativeapproach which may be tansferable to other facilities. * AuditFindings ant rorrective Acions As write for the site prdiminay draft report. Includeany actionsalready camed out or committedtD by thefacility to correctthe finding(if none, includea recommended corete action). Repon Review. Tbe fos of the reviewis on the accurAcyof the report, the rankingof findings, and the correctiveactions. All Priority Action or Action Requhrd findings musthave an associatedcorrective action and schedulefor completo tD be inwludedin the fial reporL In no case wi CMSGC ask the auitos to change obsevatios or accurate stateents of fact, regardless how damaing such statemets might appear to be. However, the reviewingpardes may determine that editorial, emphasis, or content changeswould imrove rort accuracy or that a finding should be ranked higheror lower, or not included at all. nvronmental Affair coordinatesthe resoldon of comments, and CMS Leg en assists mt auditors in mking corrections to the report that are demed necsry to accuatey represe the audit results Fn AmW&Repot The audio will be askd to return to CMS Legal, within 14 days of recept of commentson the draft report from CM Legal the copies of the final audit rept inpog those com- ments. CMS Le retains one copy for file, provides one copy to the faciity manager, and routesone coDpytohe Mfanagerof nvrnm Sental Agws, the General Manager, the Vice Presidentof Operations, and the CMSGCPeint Con i Action ConqpkoL v mental Affairs and CMS Legal assist the fcility as needed to addressany potentil noncompliance issues. Crectve actions are implementedin as timely a manner as possible, consistent with the ranking of the finding. If a scheduled commin camnotbe met, it shouldbe dicussed wih fte appropnate Geneal Manager and the Manager of EnvironmentalAfirs, for estab- lishmentof an alternate schedule. The fcilty promid an update on the stats of open corective acions to te appropiate General Manager and Managerof EnvironmentalAffairs at the end of each month, until all 6 01/9996 AUDITS, APPRAISALSAND ASSESSMENAS ENV-CMS-013 DETAIL (coat): corective actions are complete. At tt time, all copies of the final audit report are retrned to CMS Legal. Apprasals. An appraisalevaluates the effecveness of the vanous elementsof the envnmental managementsystem (standards,proce- dures, training, communication, tools, etc) in supporting the Company's environmentalpolicy statementand minimizingrisk. Sine the entity udie is primarily EnvironmentalAffairs, this audit is directed by the Vice President of Operations. Since the scope of an appraisal is to evalu managementsystems, it is not expect that attorney-client privilege procon is necessaiy. CONTACTS: Questionson this standardmay be diected to the Managerof Environ- mental Affairs. 01/09/96 7 I ENVIRONMENTAL ENV-CMS-008 STANDARDS 0A45 Corporate RESPONSE TO ENVIRONMNTAL EMERGENCS STANDARD: CMSGC-operated facilities will notify the appropriate General Manager, CNS Communications departnent and Environmental Affairs in the event of an emergencywhich has actual or potential impact on the environment. AC7ION:- FAILI * fnodewvo aspart of anotherplan (e.&, spilpl emergenc repons;epan, etc.), dvlop aplanfor respon&ingto environmental nergaeias (e.g, oil or cemial Viffsh tic gas releses, etc.). 3 npof ay enOnmentl emergenywto the appropiate General Maager, CMS Condepaent and Envronenta A4ffbis as soon as possble (after iniiton of other cial re- spose actias, but no aerthanthe end of thefirst bus day folowing *w event). GENERAL MANA E - assist thefacilty with responseto an envinmental emergency and consuk with CMSGCsenior mngemnt and/or CUS Legal depanent, as needed. * a hefay h reonse to newsmedia regar&ngan envi- ronmenta emeagency. ENYONENMENTALA "A 1RS a =ss thefacity with identfying approprate reponse actions and resourcesforan environmental ergency. MANAGER M~1NR * assistthefaciy wth i refresher,orfollowu tzmnirg on rponse acions, as needed. 01/09/96 ENV-CMS-008 RESPONSETO ENVIRONMENTAL EMERGENCIES RECORDS: FAILl * copiesof currentplans and proceduresfor responseto environmental emergencies,for life of facilityor until supersededby updates. * copiesof all correspondencewith environmentalagencies, for life of facilityor until expiationof retentionperiod associatedwith a specfic requrment A$SS: CMSGCEnvironmental Policy Statement and EnvironmentalManage- ment mlentation Plan DETAIL: An envronmentl emergncy invokes a sudden or unexpected lase of raw material, product, or waste to the air, water, or grund. Depending on the nature and amount of maral released and the rciving medium, the reease may or may not be rep ble tO el agencies (see ENV-SPL-USO2,ENV-SPLUS03 and applicableENV-SPL state requirmegnts). An mental emergency respose plan shoud be available on-site, either as a stnd-alone document, or as part of another respon plan (spiIlplan, general emergency action plan, eac.),to guide faility responseto ninmeaMl emergencis with an actualor poten- tial sgnificant rlease the en met At a minimum,the plan should identify: the material on-sitewith potental for significantrelease 3 the locations of tankm,drums and large containers of material * the equpment and stues available on-site tD containor slow the spread of a release * ponle Ofany employee discovaing a release * the pmary releaseresponse coordiator and hisb/herresponsibilities * the namesof reputbe clean-up contractors availablefor ast re- * nofication andfolbow-up reporing requirements,including ifor- mation on reportable quantifies for on-site materials, as applicable Training on env tal emergencyresponse actions shouldbe part of general awaeness u-ainingprovided to all employees(see 2 01/09/96 RESPONSE TO ENVIRONMENTALEMERGENCIs ENV-CMS-008 DETAIL (cont): ENV-CMS-004). It is recommendedthat the plan be tested via a drill or simulationat least once per year. CONTACTS: Questionson this standardmay be direcd to the Managerof Environ- mental Affairs. Questionson trainingmay be directed to theManager of Training. O091/096 3 I I I H~~~~~c to)3V Z a ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ RADIAN- INTERNAT10N A LM AppendixE Photo Log I £~~~ Figure1. ExistingJLPP Units 1 and2. Lookingeast northeast from a berm(left foreground) separating the Atlantic from the JLPP site, Unit 1 is at (1):Unit 2 isat (2).The cleared area (3) is site of two new units. Between the cleared area and the securityfence (4) is debris from original construction. Theash disposal pipelines are at (5). RADIAN I NTEER N AT I ONA Figure2. Siteof NewUnits. Lookingnorthwest across future site of Units 3 and4 (1)from partway up the escarpment. The nearest residence is in lowerright (2). Other features include: themain gate (3), the security fence (4), the cooling water discharge canal (5), the ash disposal pipelines (6), the cooling water intake area (7), Units1 and2 (8),the switchyard and substation (9) and the two fuel oil tanks(10). RADIAN- INiTER NATIONAL C Figure3. SouthPart of JLPP Site. Lookingsouthwest from the same location as Figures 4. Thecooling water discharge canal (1) flows more than 1 kmto its discharge(2) in theAtlantic. The road(3) leadsright to theplant gate and left upthe escarpment tothe maincoastal highway (Route 121). The ash discharge pipeline (4) entersthe Atlantic near(2). RADIANN INTERNATIONAL M.77 b > lr-r I-f1. i I Figure4. Sitesof Units 3 and4. Looking northfrom the southeast corner of JLPP. Main gate is at (1),cooling water discharge is at (2),site of proposed Units 3 and4 is at (3),existing units areat (4),cooling water intake structure and pumphouse is at (5), 220 kV substation is at (6),and transmission lines are at (7). RADIAN- INTER NATIONALm Figure5. Eastside of JLPP Lookingnortheast from a point southeast ofJLPP (same location as in Figure 3). The 220 kV transmission lines(1 ) leadeast up the bluff. The nearest residence (2)is a four family compound that is outside the fencelineand will not be directly affected by the JLPP expansion. The nearest off-site residence is beyond thecrest of the bluff. Point (3) is where nearest-residential areanoise survey monitoring was conducted. RADIAN INTERNATIONAL Figure6. CenterPart of JLPP. Lookingwest acrossarea south of thecoal storage area and north of Units1 and2. Railspur connecting port with rail networkabove the bluff is at (1). Securityfence is at (2).Space reserved for futurefuel oil tank is at (3). Conveyorbringing coal from storagepile is at (4). Fueloil unloadingarea (5) for trans- ferringoil fromtrain cars to tanks.The Atlantic Ocean is in the background. RADIANI INTERNATIONAL 1 - -- I'i-I* * ##E -; Figure7. NorthPart of JLPP. Lookingnorth from escarpment above JLPP. One of two fuel oil tanks is at (1).Coal ship being unloaded at the port is at (2).Existing (3) and future (4) coal storageareas. Main breakwater jetty at the port is at (5).The berm protecting the coal yard from the Atlantic Ocean is at (6).The 12-month baseline ambient airquality monitoring station is alsolocated at this point (6). RADIAN- iNTER NAT 10 N AL -,l-: Figure8. CoalStorage Area at FarNorth End of JLPP. Coalstacking and storage operations atthe far north end of JLPP.Port is to theright (north) of photo. RAPIANf INTE-RN AT ION A-L - - ,>4__., - .,W .n~~~~~~~~~~~~~~~~~~~~~~:" Figure9. Rockyshoreline north of JLPP and north of the port. Wave action (1) with cliffs of Jorf Lasfar (2) in backgroundillustrates high energy shDreline. RADIANU I NTER NAT IONA L E Figure10 Figure11 Figures10 through 12. Marine Biology and Water QualityStudy Marinebiology and water quality study. Wildco benthic grabsampler inFigure 10. Niskin water sampler in Figure 11.Fish catch displayed inFigure 12. Figure12 RADIANU INTERNATIONAL -- ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ .4 -S -!- S~~~~~~~' ~~~~~~~~~~~~~~~ - : '- lx- - >~~~~~~~~~~~~~~ F-gure 14. Eas g e *- r-4 ! Y _~ - ~~~~- s 2 1' Figure 13. FarSouth Endof JUgPP Site .~ ~ ~~Fgr Figure-;. 14 Eas 13_sar 14 Edgof Quarry^ .X Figreook 3suthonthec ree-Flged14.hne EathEdecoofn wuatrry shre()tm oaybto asuiseoa ara2 usedbecause disposalsite. oceanash disposal lineshad become clogged, OCPdischarqe (3). 17 E-R-NAT IO0NA L Figure16. OCPSulfur Storage Tanks Figures15 and 16. Figure15 looks west from the crest of the bluff across part of the port area. Coal is beingunloaded atthe pierto theleft (1). Sulfur is being unloaded at the pier to thenght (2), where it is meltedat the port and transportedbysteam-jacketed linesto storagetanks in Figure 16. INTERN ATION AL w f . - :~~~~~~~~., .gW,EsjW:f._r,;'-.;>a 3.' * --- - J Figure17. Sidi Al 'Abed ; -! - _. . . Figure18. SceneSouth of JLPP Figures 17 and 18. Figure17 looks north along the coastalhighway about 6km southof JLPP.The villageof SidiAl 'Abedis typicalof traditionalscenes around JLPP where the societyappears to beunaffected by nearbyindustrial development.Figure 18 shows a hoteland restaurant a fewkm southof JLPPwhere rocky beach begins to giveway to sandybeaches. RADIAN- I NTERNATIONAL3 I I I Appendix F Air Emissions Calculations 4 INTERNATIONALM Stac'- Emission Calculations Methodology Methodof calculationsfor estimatedstack particulatematter (PM) emissionsfrom Units I or 2: (1.) Usingthe coal ultimateanalysis, heating value, and the boiler originalequipment manufacturer's(OEM's) predictedoperating characteristics (i.e., heat rate and excess 02)7 combustioncalculations were made for full load to determinethe flue gas flow and moisturecontent at the electrostaticprecipitator (ESP) inlet. (2.) The heat rate and fuel analysiswere used to determinethe total ash being generated during full load operation.The flyashwas assumedto be 80% of the total ash being generated. This enabledthe dust loadingat the ESP inletto be estimated. (3.) The ESP OEM (Walther)provided a series of correctioncurves to correctthe predicted ESP collectionefficiency based on deviationsfrom designof: coal sulfur,'fluegas temperatum,inlet dust loading,unburned carbon, flue gas moisture,and flue gas flow. Flue gas temperatureand unburnedcarbon were assumed to be unchangedfor all cases since there was no meansto assess the impactof variouscoals on these parameters. (4.) Onceeach correctionfactor was determined,ESP efficiencywas calculatedusing the followingformula nEP= 1 - ek and: k= K,*C,*C2*C3*C,*CS where:K, = -5.21673738 C1 , C2 , C3 , C4, C5 = correction factors EIA F-I August 1, 1996 (5.) The stack particulate emissions were calculated by: m PM Emissions ( ) (Rated Power Output of Units(MW)) * (CapacityFactor) * (Specific Heat Rate Kcal * _____ I______* ( kg - Ash) (0.80) * ( 1000kW' LowerHeat Value Ka )J kg- coal \ MW)I l 1 ~~~~kg- coal)) W 1z11 (O~ fl18~mgTtESp)) (I -kg Dry GasFlow (6.) The PM emissions per day were calculated by: Stack PM (Tonne/day) = Stack PM (mg/Nm') * Gas Flow m'/hr * 24 hr/day * I Tonne/10' mg '. '0 SO, Emissions m Emissionsof SO2 are calculatedbased on the conversionof all coal sulfurto sulfurdioxide (SO 2) and an averageanticipated future z composition.In the futureit is anticipatedthat coal will come fromthe UnitedStates, Colombia, and South Africa. Usingthe -; m averageultimate analyses of each of these coals, a compositeultimate coal analysiswas computed and is presentedin Table F-I. o r;bZ Table F.I. UltimateAnalysis of CompositeCoal Parameter tii % By Weight -Sulfur 1.25 -Ash 10.75 -Moisture 9.21 -Volatiles 30.89 -Carbon 66.67 -Hydrogen 4.50 -Nitrogen 1.29 -Oxygen 6.48 -Chlorine 0.10 HigherHeating Value (Kcal/kg) 6,574 Lower Heating Value (KcaVkg) 6,302 (tonne f~c~ ae Kcal 124.!rsl [.(kg sufu (2k S- 2 SO2Emissions ( SpeciricHeat Rate kw hr)|- * |Coal Sulfur Content kg - sulfur g day-MW) kw - hr~j day j ~ I kg - coal )j 1~kg - sulfur) onneA , (1000 kW) t 1000 kgJ l\ MWJ Lower Heating Valve Kcal ,kg- Coal) Scenario #1 - "Base Coal" For Units I & 2 Firing "Base Coal" 2 kg - 02) , ,I tonneA 1000kW) S02 Emissions ( tonne = (2,065 Kcal , (24 hr) , 0.0125 kg - sulfur kg - sulfur 100 kg/) MW )2 2 day-MW) Kwh J day kg - coal ) 6,302 kgc-l r- 0.20 tonne- SO, day - MW For Units 3 & 4 Firing "Base Coal" 2 kg - S02\ 1 tonne I1000 kW ) ( tonne - 2,080Kcal' * 24 hr) , 0.0125kg - sulfur) * 2kg - sulfurO 1000 kg, ( kW S0-2 Emissions ( i ____ y .0125 kg -ulu) 00k) . W 'TI 1, day-MWJ Kwh J dayJ kg - coal ) (6302 Kcal kg - coal) 0.20 tonne - SO2 day - MW Scenario #2 "Ultra-Low" Sulfur Coal For Units 1 & 2 Firing "Ultra-Low" Sulfur Coal ( 2 kg - SO28 tonne ' { 1000kW S°2 Emissions [ toinne 2 065 Kcal) * 24 hr) * 0.0020 kg - sulfur) 2 kg- sulfur02 t1000 kg) MW ) ;> t day-MW Kwh day kg - coal J 6,835 Kcal 12 S~~~~~~~~~~.2 tonneda-M - S02Okg kg - coal) ce = ~~~~~ ~ ~~~~~0.029 _ ~~~~~~~~~~~day- MW ko For Units 3 & 4 Firing "Ultra-Low" Sulfur Coal __ (2 kg - SO2 , tonne ) * (1000 kW M tonne___ 2,080 Kcal' __4_- sulfur' 1000kg MW day-MW Kwh day kg - coal Kcal 2 SO2 Emissions( tonne * 24 hr * 0.0020kg- * kg - sulfur~ 6,835kg -coal)r tonne- SO2 = 0.029 day - MW '71 I- '0 I I NTERNATIONAL! Appendix G Thermal Discharge Compliance of the Jorf Lasfar Power Plant I INTERNATIONALM THERMALDISCHARGE COMPLIANCE OF THE JORF LASFARPOWER PLANT G1.0 INTRODUCTION The objectiveof this activityis to evaluatethe impactsof the JorfLasfarPower Plant (JLPP)thermal discharges onto the AtlanticOcean. The analysisfocuses on the unpact of the thermaldischarges while all four unitsare m operationand at fill load. The analysisresults are evaluatedto assess compliancewith the WorldBank (WB), UnitedStates Overseas Private InvestmentCorporation (OPIC) and the Export ImportBank of the UnitedStates (Ex-Im) Guidelines. The waste thermalenergy of fossilfuel power plants range from50% to 67% of the total fuel energyinput. Approximately10% of the wastethermal releases are emittedthrough the stack. The remainderis typicallyreleased through condenser cooling. The preferablecondenser designand the coolingmedium depend largely on the particularfuel of choice,the sitegeographic locationand proximityto water sources,estuaries, or sea water. The proper condenserdesign is particularlyimportant to optimizepower plantoperation and minimizeenvironmental impacts. The United StatesElectric Power Research Institute has identifiedthe condensercooling design and performanceas the singlelargest source impactingthe performanceefficiency of the power plant. The increases to the ambientwater temperaturecaused by condensercooling water may adverselyimpact the localmarine biology. Releasesof chemicalsemployed to treat the cooling water may also impactthe biologicalenvironment. Thus, proper operationof the condenser coolingsystem is criticalto powerplant efficiencyas well as environmal protecton. Proper operationof the condenserconsists of efficientheat transferto the coolingwater and targeted use of chemicalwater treatment. The fo}lowingare generalguidelines required to ensure optimumcondenser performance and mmmum environmentalimpact of the thermaldischarges and the coolingwater chemical treatment: EIA G-1 August 1,1996 INTERNATIONALM3 >- Use of targetedchlorination in the treatmentof cooling water; Continuousmonitoring of condensertube foulingrate; periodiccondenser maintenance prga;and Coolingwater temperatureincrease not exceeding10 degrees Celsius( 0C) across the condenser. Theseguidelines have been demonstrated to optimizethe powerplant performanceand to minimizethe environmentalimpacts of the coolingwater releases. EIA G-2 August1, 1996 RADUAN- INTERNATIONAL1n G2.0 PROJECTDESCRIPTION The JLPPUnits 1 through4 use sea water to cool the plant condensers.Units I and 2 generate348 MW each at flll load.Units 3 and 4 are designedto generate350 MW each at full load. Each of the condensersis a singleshell, single pass condenserwith multiple tube bundles. The tubes are made of titanium. The tube sheets are made of carbonsteel withtitanium cladding. Each tube bundleis equippedwith a set of air coolersfor deaerationand ventingof incondensbile gases. Each condenseris providedwith 2 inlet and 2 outlet waterboxes. The condenserdesign rejectedheat load is 363,470kJ/s for Units I and 2. At this load, the predictedcondenser pressureis 0.049bar at a coolingwater inlettemperature of 20°Cand a coolingwater volume flow of 11.4m 3/s. At this flow rate, the designcooling water pressuredrop betweencooling water inletand oudet nozzlesis 0.37 bar. Each condensercooling water is dischargedinto a commonopen channelconstructed from concrete. Its width is about 12 meters(m) at the condenserdischarge point and increasesto 26 m at the dischargepoint into the AtlanticOcean. The channellength is approximately1.5 ln. A serratedcascade weir is constructedat about the midpointalong the channellength. The JLPP coolingwater drop height at the weir canbe up to 4 m in elevation. The channelwater temperatureprofile (with two units operatig at fuilload) was measuredin September1995 and laterduring April 1996. Temperaturedata for the receiving waters was taken in April 1996. The September,1995 data was reportedin the Phase II report. The Aprildata for the channeland the receivingwaters is shownin Table G-1. The condenser coolingwater net temperatureincrease is measuredto be less than 90C. The aggegate impactsof the JLPP Units3 and 4 are determinedvia modelingtechniques in the followingsections. EIA G-3 August 1, 1996 RADIMAKE INTERNATIONALIM Table G-1. Measured Thermal Conditions with two units at full load in April, 1996 ADprtChannel Condenserexit Immediatelyafter dischargefrom the boiler 26 condensers Nd oint Halfwaydown the 1.5 km concretechannel 26 Channelexit At channelexit intothe concretepool 26 Concretepool Immediatelyprior to enteringthe receiving 25.8 waters ...... stace:L'rom -:;::A:W te th .ea t t Ave..ge 60 4 18.7 18.2 17.6 18.2 _0 5.3 18.7 18.2 17.5 18.1 140 6 18.6 17.8 17.5 18.0 240 8 18.6 17.6 17.2 17.8 440 12 18.6 17.6 17.2 17.8 The coolingwater is chlorinatedto controlmussels and mollusks.The JLPP personnel continuouslymonitor the chlorinelevels at the condenserdischarge and at the AtlanticOcean dischargepoints. The JLPP recordsindicate that the chlorinecontent at both locations does not exceed 0.23 mg/l. Thisfree chlorinelevel is well belowthe WB Guidelines. In summary,the condensercooling water systemdata indicatesthat the systemis within the generalguidelines required for good performanceand adequateprotection of the enviromnent. The followingsections provide analysis of the net themal impactof the coolingwater on the receivingocean. The objectiveof the analysisis to determinethe net ocean water temperature increaseat 100 m awayfrom shore,with all 4 boilersoperating at fill load. EIA G4 August 1, 1996 RADfAN- INTERNATIONALO G3.0 TECHNICALAPPROACH G3.1 Fundamentals A basic, but extremely important factor in the consideration of thermal discharges is that the discharge plume disperses in the receiving ocean waters in a nonlinear manner. The plume dispersion field is normally divided into three regions. Near Field (A Zone): The A zone is in the vicinity of the discharge point. The dispersion rate is minimalin this zone and is dominated by the plume (or jet) discharge momentum. The length of the A zone ranges from 2 channel diameters to several hundred meters, depending on the geometry of the plume and the receiving water. Intermediate field (B Zone): The B zone domain extends from the edge of the A zone into the receiving water. The B zone mDiDxgrate is controlled by the plume geometry, momentum and thermal energy, as well as the receiving water currents, thermal stratification, and depth- The length of the B zone can be determined for deep bodies of water via scaling techniques (Jirka and Doneker, 1991). However, if the receiving water depth is not uniform as well as in the presence of land jetties and rocky obstructions, the analytic techniques yield large errors. Advanced computational techniques are required *forsuccessful analysis. The B zone can be very short or up to several kilometers long depending upon the flow characteristics. Far Field (C zone): The C zone region extends from the edge of the B zone. The plume in this zone is filly dispersed. The residual plume thermal energy dissipation rate is dommiatedby the receiving water temperatures and currents. G3.2 Application to JLPP The thermal discharge analysis for JLPP consists of an integrated field testing and mathematical modeling of the thennal discharges. The implementingtasks included gathering of data desciibing the ocean bottom, ocean currents, and the water and air temperatures. The model simulations cover reasonable thermal discharge scenarios. The simulation results are then examined in light of the WB and the Ex-Im Guidelines-specifically,the temperature of the EIA G-5 August 1, 1996 INTERNATIONAL1U3 rece7vingwater at the edge of the maixngzone is determined. The WB definesthe edge of the mixingzone for open bodies of water to be 100m away from shore. The WB definitionis followedthroughout the EIA document. As can be deducedfrom the previoussection, the JLPP thermaldischarge analysis depends on the use of computationalfluid dynamics (CFD) techniques. Order of magnitudeanalysis of the JLPP dischargeshas indicatedthat the followingfactors dominatethe coolingwater dispersion rate: )P. Oceanbottom depth and gradient; >- Mean oceanwater currentsvelocity, Geometricshape of the dischargechannel; )0' Maximumdischarge plume mass flow rate; _P- Mean dischargeplume water temperature;and )' Mean ocean water temperature. The accuracyof the dischargewater themal analys dependson the levelof detail availableon the abovecontrolling parameters. Field activiies havebeen carriedout to quantify these parameters. Where fielddata was not avadable,conservative estmtes are made. These estimateswere chosento ensurethat the actualtemperature increase at the edge of the midng zone is smallerthan the predictedtemperature increase to ensure complancewith the WB Guidelines. The controllingparameters are smmarized in TableG-2. EIA G-6 August 1, 1996 INTERNATIONALI Table G-2. Controlling Parameters for Thermal Discharge Analysis 1. Ocean BoUom Depth Distance from 10 30 90 190 390 shore (m) Depth(m) 4 5.3 6 _ 12 2. Mean ocean wave motion and Tides Extne tides, de-uota and surquota included: meain ocean. CureS velocity maximum: +4.5 mtZ;Happroimate +2.3m/NGM minimum: 0 mJZH approximate -2.2 m/NGM Average tides, de-qua and sur-quot: maximnin: 3.7 mIZH approximate +1.5mtNGM mini_um : 0.7 m/I approximate -1.5 mINGM Currents at the The crmnets are facing south with velocites ranging from surf2ice 0.05 mis to 0.5 mIs. In the shallow water, curmrus could attain lm/s generated by reflection aganst the cliff ______Wave motion Hihy twbulent with strong wave motion. 3. Geometric shape of the The channel at the discharge point is a rectangular concrete open channel with a discharge channel width of 26 nL .''. ,. I~~~~~~~~~~ .I*' ... 3 3 4. Maximum discharge plume | 83,880 m /hr for units 1 and 2, and 171,360 mehr when all four units are in mas flow rate operation. 5. Mean discharge piume water 26°C 6. Mean ocean water t erature 17.80 C Other Background and Calibration Data The oceancurrent is from the Northto the South.The JorfLasfar Technical Specifications document have reported that the ocean current velocity ranges from 0.05 to 0.5 m/s. The minimumvelocity is typicallynear the oceanbottom. Thisclass of flow is fully ELA G-7 August 1, 1996 INTERNATIONALUB turbulent. The velocityprofile typically follows the logarithmiclaw at the wall (White, 1975). The meanvelocity is typically67% to 85% of the maximumvelocity. As a conservativeesiimate, and in light of the transientnature of this problem,the meanvelocity component along the shore was chosento be 0.5 m/s (or 50% of the maximumvelocity). The wind roses indicatethat regardlessof winddirection, the normalwind velocitycan be as high as 40 kph. The oceanbottom from the shorelineand up to 200 m awayfrom land is rocky. The ocean wavesare highlyturbulent, with strongwave motions. The region is not amenableto recreationalswimming and diving. The measuredwater temperatureprofile indicates that, with 2 units in operation,the coolingwater is fullymixed (C zone) within50 m from the shoreline. Thetemperature increase at 100 m away from shoreis about 0.3 'C. Thisdata is the cornerstoneof the model development and it is used to calibratethe model. The calibratedmodel is then used to predictthe impact of all 4 units in operation. G3.3 Model Development The dissipationof the thermaldischarges into the oceanare evaluatedusing a full capabilitycomputational fluid dynamics (CFD) simulation. The CFD code of choice is the PHOENICScode developedby Combustion,Heat and MassTransfer (CHAM based in London, UnitedKingdom. The PHOENICScode is a controlvolume based finitedifference algorithr. The code has been extensivelyvalidated in the applicationsof environmentalhydraulics. Specific environmentalflow applicationsinclude ocean thermal discharges (Markatos and Simitovic, 1983),waste water dischargesmto reservoirs(Rizk, 1992),and flow over aeratingweirs (Hadjeriouah,1993). PHOENICSsolves the fullcapability Navier Stokes equationsand generalizedtransport equationsin the solutionof fluidflow, heat and masstransfer. G3.4 Model Calibration A graphic summay of the modelcalibration parameters, computatonal grid,problem geometry,and input parametersfor the modelingruns are shownin Figure G-1. EIA G-8 August 1, 1996 RADUINE INTERNATIONALSB FigureG-1. ModelInput Parametersand Schematic d 280 m opencorretecharnI ------_------ N 20 446 m * Lrrwtdiret,on Poowate(fLikkd):23,300rn 3/Ir(u*isl&2) 24,300 nfP/h(urfts 3 & 4) ROMBWtiaUwe:26 0 C a * 1Atiu ttMwire17ZC Oanfklo0 gradiwt:1 446DO mmVref\ me = pt -II| x The ocean bottom gradient of 1:20 is based on the field data which Radian gathered. The coolig water is discharged into a pooI which is about 4 m deep bounded by concrete waUlsdiagramed in Figure G-1. The wave current velocities are a strong function of the prevailng winds, the tidal movemenits,and the proximityto the shoreline. This parameter is tuansientwith a wide range of varying values. The most conservtive assumption is a tme averaged forward (toward the shoreline) wave velocity. This velocity is used to calibratethe model to the field data at 80 m from the shore line. An optimal wave curent velocity was determned to be about 0.2 n/s toward the shoreline. EIA G-9 August 1, 1996 RADUANE INTERNATIONALa G3.5 Model Results Calibratedmodel rns simulatingfiull-load operation of all four unitsindicate that the impactof the condensercooling water is withinWB Guidelines.Figures G-2 and G-3 show the modelednet temperatureincrease along the centerlineof the plumeat increasingdistance from the shorefor 2-unitand 4-unitoperation, respectively. The net temperatureincreases modeled in Figure G-2 are confirmedby the actualwater temperaturetesting conducted during the EnvironmentalAssessment. Figure G-3 showsthat at 102 m fromthe shore,the modelednet tempeture increasefor 4-unitopemaion is about 2.2°C. Thisfalls well withineven the most stringentWB Guidelinesof 3°Cfor receivingwaters with ambienttemperatures greater than 28°C. Figures G4 and G-5 showthe modeledtemperature increases at variousdownstream locationsas a functionof distancefrom shorefor 2-unitand 4-unitoperation, respectively. EIA G-10 August 1, 1996 INTERNATIONALM Figure G-2. Net Temperature Increase at Plume Centerline for Z-Unit Operation T.peraw Pmfile st tbe Plume Ctaine 0.0 F&O ;Q"~~~~~~~~; 2z C VaanG-fAu awre (19) -~~~~~~~~~~~~~~~~~~~~~~~~~~22 EIA ~~~~~~~~G-11 August1, 1996 INTERNATIONAL Figure G-3. Net TemperatureIncrease at PlumeCenterline for 4-Unit Operation TSpaat ProJe& at &e Phme C.iine 2.0. .0 . 0.0 0 Eam EIA G-12 August 1, 1996 Nottemperalure Iner.abs 'CC I 0 4A c~~~~~~~~0 4 ...... : .... :z ...... CD 1~~~~~~~~~~~~~~~~~~~~~~IV 1~ 0 w_~~~~~~~~~~~~ 2; 0 1a g 0\ ~~~~~~~~~~~~~~~0* CD INTERNATIONALO Figure G-5. Net Temperature Increase as a Function of Downstream Distance and Off-Shore Distance (4-Unit Operation) Tempawbre Proie 5 . -. ._ 06 o A__Doo533 PodUnica m* fun)(&=*WePGot'=M) G3..6 Conclusions ThePhoemcs model was calibrated with field datato reflectthe field temperature data collectedfor 2-unit, ful-load operationat 80 m from theshore lie. Whenthe inpu parameters were adjustedfor 4-unitoperation, the modeledresults showedthat the maximumnet thermal incease from ambientconditions at I100m fromthe shorelinewas about 2.?*C. Thisfas vvithin the most stringentWB Guidelineof 30C for receivingwaters with ambientconditions of greater than 28.C. EIA G-14 August 1, 1996