Role Play

Case Study: Environmental Management
Aspects of the Combined-Cycle Power Plant
Project in Country X
Discussion Material
For the Moldova Safeguards Training Workshop
October 28-31, 2008
By Victor B. Loksha
ECA Safeguards Team
Europe and Central Asia Region
The World Bank
Country X would like to improve its energy supply
•The country’s Ministry of Energy is the official counterpart
•The country’s National Power Company (NPC) is in charge of implementing
the project
•Main physical component is to build a combined-cycle thermal power plant
and connect it to the power grid
Project preparation milestones
I. Consulting firm TQE is tasked with:
1) Selecting the best site, technology, and fuel
2) Conducting a study of technical, economic, and
environmental feasibility at the selected site
3) Implementing EIA and developing EMP
II. Engineering, Procurement and Construction
contractor (EPC contractor) will:
1) Implement detailed design
2) Implement construction works, supply and install
Site selection
Seven possible locations were considered based
on the following criteria:
Environmental conditions on site
Air quality concerns
Cost of electricity generation
Socio-economic concerns
Proximity to available transmission lines
Transmission system considerations
Fuel availability
Water and sewer needs
Property availability
Sea coast of town Z chosen to be the site of the power plant[email protected]/2069577002/
The wildlife of coastal zone of Town Z is not unique
but has value
Liquid fuel (distillate oil) is chosen as the primary fuel for the plant
Fuel for the plant will be delivered by sea from an offshore terminal
•The terminal is 20 km away from the plant site
•About 30 deliveries will be made per year by a barge with minimum
capacity of 3,000 m3
Environmental Impact Assessment includes modeling air
pollution induced by the project
•Country X has adopted the standards of the European Union for air quality
•To demonstrate compliance with these standards, the TQE consultants
have utilized the latest US EPA air pollution simulation model (ISCST3)
•A sewage treatment facility will be provided at the plant
•Discharge of treated effluent will be combined with the cooling
water discharge
Sea water will be used for cooling
• The power plant needs cool water for converting
the plant’s exhaust steam back into water
• The TQE team chooses the once-through
cooling (OTC) system utilizing sea water for
• OTC technology is acceptable practice in
Country X
• The alternative closed-system technology would
add $10 million (or 9%) to the cost of the plant
Once-through cooling technology
•Cooling water will be
treated with sodium
hypochlorite to eliminate
biological fouling
•Residual chlorine in the
effluent will meet World
Bank guidelines (0.2
Screening devices at the intake of the cooling circuit
Bar screen for initial screening
Traveling screen for final screening
Return pipe of the cooling circuit ends with an outfall returning water to sea
Environmental Management Plan
A. Mitigation: Operation and Maintenance Phase
Proposed Mitigation Measures
Liquid Fuel
Air emissions of
NOx, SO2, CO,
particulate matter,
and volatile
•Low-NOx burners and water
injection to control NOx;
•Firing only low-sulfur (<0.1% by
wt.) distillate fuel oil to control SO2;
•Good combustion control to control
CO, PM and VOCs;
•Stack height at least 45 m to
facilitate dispersion.
•Power plant
operator (NPC)
•Power plant
supply and
Noise from
Acoustic enclosures for the
combustion turbines to ensure that
noise does not exceed 85 dB(A) at
1 m and 70dB(A) off-site
•Power plant
•S&I contractor
Entrainment of
fish, shellfish, and
other marine
•Bar screens and traveling water
screens for final screening at
cooling water pump suctions
•Inlet velocity less than 1 m/s to
minimize entrainment
•S&I contractor
Water Intake
Example: Environmental Management Plan
B. Monitoring: Operation and Maintenance Phase
Project Activity
Proposed Monitoring Measures
Liquid Fuel
•Fuel sulfur content will be monitored no to exceed 0.1% by
weight. Sampling and analysis will be performed on each
delivery received.
•An initial performance test will be performed to confirm the
emissions from the plant do not exceed the amounts in the
EIA report. The stack will include continuous monitoring of
NOx and opacity emissions.
•Baseline noise monitoring will be conducted prior to
operation of the plant, both at the plant and at predefined
receptor locations. Then, off-site, far field noise monitoring
will be performed at those locations once during operation
of the facility to confirm the 70 dB(A) limit.
•Workers close to the turbines or other noise emitting
equipment will wear hearing protection.
Cooling Water
•Documentation will be maintained on-site concerning the
final design of the water intake including the inlet velocity.
EMP requirements are incorporated in the
legally binding documents
• The Project Agreement with NPC includes a
provision on the need to implement the EMP
• EMP requirements are incorporated in the
bidding/contract documents
• These requirements are binding for the EPC
• Relevant provisions of EMP are also included
into contracts for fuel supply
Additional impact-specific plans and
studies envisaged:
Plans and Manuals:
Oil spill response, recovery, and mitigation plan
Emergency response plan
Site drainage and grading plan
Community impact action plan
Health and safety plan
Noise and vibration plan including baseline
• Waste management plan
• Employee health and safety manual
Additional impact-specific plans and
studies envisaged (cont’d)
• Environmental assessment of the final
transmission line
• Ambient air monitoring including meteorological
• Cooling water intake and discharge structure
location study including:
– fish studies, seabed flora and fauna, sea
temperature monitoring, sediment sampling
and analysis
Proposed power plant on sea coast of town Z
Public consultation and disclosure
 EIA report documents adequate public
 Public announcements were thorough, transparent,
and well distributed
 National Agency for Energy and Environment
coordinated the process
 The meetings were well attended and publicized
 The public provided inputs which were reflected in the
final EIA and EMP
 Final EA report was published in the World
Bank’s InfoShop
Coast of Town Z before and after the Power Plant is built
Attention Seminar participant!
• You are the PIU Director at the NPC
• You are asked to prepare for a meeting with Dr.
Ruffle, a senior representative from an
international environmental NGO
• You believe that the recently finalized EMP (to
be distributed separately) can help you answer
Dr. Ruffle’s questions
• What kind of issues do you think you
need to be especially prepared to
Role Play: Dr. Ruffle’s Questions
Siting of the Plant
Air pollution from the Plant
Fuel supply (risk of oil spill)
Choice of cooling technology (why OTC)
Wastewater disposal
Practical implementation (enforcement) of
7. Scope of specialized (impact-specific) EMPs
Siting of the Plant
• Ruffle: In environmental management, like in many other fields,
avoidance of damage is considered a better option than mitigation.
The World Bank, among others, certainly subscribes to this view in
its guidance on Environmental Management Plans[1]. Some of the
impacts this project will have on the environment might have been
completely avoided had a different site been chosen for the project.
This particular coastal area of Country X is particularly
valuable/vulnerable and only 3 km away from a National Park. How
did your experts choose the coastal area of town Z as the site for the
project? What kind of criteria did you use to eliminate all the other
possible locations?
[1] Environmental Management Plans. Environmental Sourcebook
Update/ No. 25. January 1999.
Air pollution control
• Ruffle: How will you manage the air
quality concerns at the site you have
selected – especially the pollution resulting
from fuel oil combustion?
Fuel supply: risk of oil spill
• Ruffle: Choosing offshore oil as primary
fuel is a big environmental risk to take.
How many tanker trips per year do you
anticipate, and how will you manage the
risk of oil spills?
The choice of cooling technology:
“I am outraged!”
Ruffle: I am outraged that, after so much analysis of environmental
impacts, your experts would choose the once-through cooling (OTC)
technology to cool the power plant. Why didn’t you choose a closed-cycle
cooling system instead? The OTC technology uses the living and breathing
sea water as the radiator fluid to run through the plant. Furthermore, the
quantities of water involved in this process are enormous. Do you know how
much water these systems use? There are estimates[1] that the water
demand for a once-through cooling system is 30 to 50 times that of a
closed-cycle system. Not only are fish and other marine organisms
destroyed by being sucked into the plant at the point of intake, but the
thermal and chemical pollution of the sea by the return water coming from
the outfall is also very harmful for the aquatic ecology. Would you like to
have a few copies of this poster?
Once-through cooling technology
schematic emphasizing damage to aquatic environment
Wastewater disposal
• Ruffle: How will you manage the
wastewater coming from the pant?
Practical implementation
(enforcement) of EMP
• Ruffle: I have seen your EMP and I appreciate
the fact that it was on the table when the
consultation meetings were held with the local
public. I have to admit that it is probably one of
the best documents of this sort that I have seen
for similar projects. But I have some concerns
about its practical implementation. How exactly
can you make sure that the mitigation and
monitoring measures included in the EMP will be
actually enforced?
Discussion and Analysis:
EMP Strengths and Weaknesses
• The air pollution control measures are designed to
comply with the stricter of the potentially applicable
standards (EU, WB)
• Cost estimates are available for most items in the EMP
and included in the Procurement Plan
• EMP requirements are incorporated in the
bidding/contract documents (binding for EPC contractor)
and into the contracts of suppliers of fuel during
operating phase
• The EMP has been adequately disclosed, and the local
community was actively involved
Discussion and Analysis:
EMP Strengths and Weaknesses
• The mitigation options in the EMP are limited by
the earlier commitments to pursue particular
technological solutions (e.g., the once-through
cooling system)
• Both the technology and the site have been
chosen mostly on the basis of narrowly defined
(financial) cost minimization and plant efficiency,
giving a lower priority to environmental
• No siting or technology choices should be
eliminated until completion of the detailed EIA
Lessons Learned
• EMP is not an isolated tool but should be part of the overall good
environmental management and decision making
• Environmental mitigation is an integral part of decision making and
must be considered simultaneously with the analysis of alternative
technological and siting choices
• The project team may prepare a state of the art EMP, but may still
be in a vulnerable position if the upstream decision making is
perceived to be flawed
• In making choices about the technology, it is more prudent to err on
the conservative side and require the technology consistent with the
higher degree of environmental protection
• The absence of local environmental restrictions on certain
technology in Country X is a weak excuse if the environmental
credentials of the technology are known to be questioned.
• Economic (incl. environmental) rather than just financial
costs/benefits need to be part of the analysis of alternatives
Thank You!