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Environmental and Social<br />

Due Diligence:<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

<strong>Expansion</strong>, <strong>Colombia</strong>


Environmental and Social<br />

Due Diligence:<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

<strong>Expansion</strong>, Columbia<br />

Prepared by<br />

Exponent<br />

15375 SE 30th Place, Suite 250<br />

Bellevue, WA 98007<br />

June 2011<br />

� Exponent, Inc.<br />

Doc. no. 1101335.000 04F1 0611 MJ21


Contents<br />

1101335.000 04F1 0611 MJ21<br />

ii<br />

June 21, 2011<br />

List of Tables v<br />

List of Figures vi<br />

1 Introduction 1<br />

2 Project Description 4<br />

Page<br />

2.1 Existing Operations 6<br />

2.2 <strong>Refinery</strong> <strong>Expansion</strong> 10<br />

2.3 Schedule and Costs 12<br />

2.4 Project Workforce 13<br />

3 Institutional and Legal Framework 14<br />

3.1 Institutional Framework 14<br />

3.2 Legal Framework 14<br />

3.3 Other Requirements 17<br />

3.4 Status 18<br />

4 Environmental and Social Conditions 22<br />

4.1 Environmental Conditions 23<br />

4.2 Social Conditions 28<br />

4.2.1 District of <strong>Cartagena</strong> 28<br />

4.2.2 Urban Government Community Unit #11 32<br />

4.2.3 Mamonal Industrial Area 32<br />

4.2.4 Local Communities 33<br />

4.2.5 Cultural Heritage 35<br />

5 Environmental and Social Impacts 36<br />

5.1 Construction 36<br />

5.1.1 Site Clearing 36<br />

5.1.2 Air Quality 37<br />

5.1.3 Construction Workers 37


1101335.000 04F1 0611 MJ21<br />

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June 21, 2011<br />

5.2 Operation and Maintenance 38<br />

5.2.1 Air Quality 38<br />

5.2.2 Water and Wastewater 42<br />

5.2.3 Waste Generation 45<br />

5.2.4 Risks 46<br />

5.3 Liabilities 47<br />

5.3.1 Phase 1 ESA for the Existing <strong>Refinery</strong> 47<br />

5.3.2 Phase 2 ESA for the Existing <strong>Refinery</strong> 49<br />

5.3.3 Health and Safety 51<br />

5.4 Positive Impacts 51<br />

5.4.1 Craft Training, Jobs, and Increased Tax Revenue 52<br />

5.4.2 Corporate Social Responsibility 53<br />

6 Environmental, Social, and Health and Safety Management 55<br />

6.1 Project EIA Environmental and Social Management Plan 55<br />

6.2 Project Construction EHS Management 60<br />

6.2.1 Craft Training Programs 62<br />

6.2.2 Construction Worker Hiring Plan 62<br />

6.2.3 Construction Worker Housing Plan 63<br />

6.3 Existing <strong>Refinery</strong> EHS Management 63<br />

6.3.1 EHS Management System 63<br />

6.3.2 Environmental 64<br />

6.3.3 Health and Safety 65<br />

6.3.4 Emergency Preparedness and Response 67<br />

6.3.5 Contingency Plan 68<br />

7 Information Disclosure and Public Consultation 70<br />

8 Conclusions and Recommendations 73<br />

8.1 Conclusions 73<br />

8.1.1 Impacts 73<br />

8.1.2 Compliance 75<br />

8.1.3 Environmental Liabilities 76<br />

8.1.4 Risks 77<br />

8.2 Current Status of Recommendations Included in the 2009 ESDD Report 79<br />

8.3 Additional Recommendation from 2011 94


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June 21, 2011<br />

8.4 Assessment of Compliance with International Guidelines 95<br />

8.4.1 The Equator Principles 95<br />

8.4.2 IFC Performance Standards 96<br />

8.4.3 IFC EHS Guidelines 99<br />

8.5 Recommended Lender Action Plan 100<br />

8.5.1 Prior to Financial Close 100<br />

8.5.2 Prior to Initial Disbursement 101<br />

8.5.3 Prior to Commencement of the Operations Phase 103<br />

Appendix A Photograph Log


List of Tables<br />

1101335.000 04F1 0611 MJ21<br />

v<br />

June 21, 2011<br />

Table 1a. Data/information reviewed associated with 2011 environmental and social due<br />

diligence for the updated ESDD report<br />

Table 1b. Data/information reviewed associated with 2009 environmental and social due<br />

diligence for the initial ESDD report<br />

Table 2. Project-related air emission standards<br />

Table 3. Project-related ambient air quality limits<br />

Table 4. Project-related wastewater discharge limits<br />

Table 5. Project-only air quality modeling predicted maximum concentrations resulting from<br />

existing and proposed <strong>Cartagena</strong> refinery operations<br />

Table 6. Cumulative air quality modeling predicted maximum concentrations resulting from<br />

existing and proposed <strong>Cartagena</strong> refinery operations plus other sources in Mamonal<br />

area<br />

Table 7. Conclusions and recommendations related to Project air quality impact/ modeling<br />

analysis<br />

Table 8. Siemens proposal Table 3.4a<br />

Table 9. Estimated waste generation during refinery expansion operations (from Project<br />

EIA)<br />

Table 10. Social programs<br />

Table 11. 2009 Recommendations related to the Project EIA ESMP and current status of all<br />

programs under the Revised ESMP<br />

Table 12. Action Plan based on the Phase I and Phase 2 Environmental, Health and Safety<br />

Assessments—<strong>Cartagena</strong> <strong>Refinery</strong> Facility, Environmental Health and Safety<br />

Action Plan Existing <strong>Refinery</strong>–Due Diligence<br />

Table 13. Project-related total energy consumption versus IFC Guidelines<br />

Table 14. Project-related total power consumption versus IFC Guidelines<br />

Table 15. Comments and recommendations related to environmental liabilities at existing<br />

refinery<br />

Table 16. Total greenhouse gas estimates<br />

Table 17. Conformance review: EHS General Guidelines<br />

Table 18. Conformance review: EHS Guidelines for Petroleum Refining<br />

Tables are presented at the end of the main text.


List of Figures<br />

Figure 1. <strong>Cartagena</strong> <strong>Refinery</strong> location<br />

Figure 2. <strong>Cartagena</strong> <strong>Refinery</strong><br />

Figure 3. Current configuration of the <strong>Cartagena</strong> <strong>Refinery</strong><br />

Figure 4. Future configuration of the <strong>Cartagena</strong> <strong>Refinery</strong><br />

Figure 5. Proposed wastewater treatment plant configuration<br />

Figure 6. Health, Safety, Security, and Environmental Management System model<br />

Figure 7. Engineering, Procurement, and Construction Contract–Health, Safety and<br />

Environment Organization during construction<br />

Figures are presented at the end of the main text.<br />

1101335.000 04F1 0611 MJ21<br />

vi<br />

June 21, 2011


1 Introduction<br />

1101335.000 04F1 0611 MJ21<br />

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June 21, 2011<br />

The <strong>Cartagena</strong> <strong>Refinery</strong> is owned by Refinería de <strong>Cartagena</strong> S.A. (“<strong>Reficar</strong>”), a <strong>Colombia</strong>n<br />

special-purpose company owned by Andean Chemicals (50.9%), Ecopetrol S.A. (48.9%), and<br />

minority shareholders (0.2%). The refinery is located on the northern coast of <strong>Colombia</strong>, just<br />

south of the city of <strong>Cartagena</strong>. <strong>Reficar</strong> intends to modernize the refinery and expand its refining<br />

capacity from 80,000 to 165,000 bpd (the “Project”). The modernization of the refinery will<br />

include an increase in the facility’s complexity, which will enable it to process a less expensive<br />

mix of crude (heavier, more acid) while producing low-sulfur gasoline and ultra-low-sulfur<br />

diesel that will meet new domestic and international clean-fuel requirements (e.g., sulfur content<br />

for the domestic market: not higher than 300 ppm for gasoline and 50 ppm for diesel, and for<br />

the export market: < 30 ppm for gasoline and < 8 ppm for diesel). The new configuration,<br />

including hydrocracking, hydrotreating, catalytic reforming, and coking capacity, will enable<br />

the refinery to handle up to 90,000 bpd of acidic crudes. This will provide a competitive<br />

advantage because most refineries can process only small quantities of such corrosive crude<br />

oils, and will allow <strong>Colombia</strong> to better use its domestic oil reserves. The new products will<br />

include low-sulfur gasoline, jet fuel, and ultra-low sulfur diesel.<br />

The investment plan has an estimated capital cost of US$4.7 billion. The debt financing<br />

structure considered for the upgrade program includes a Direct Loan and/or Loan Guarantee<br />

structure provided by three export credit agencies (US Ex-Im Bank, <strong>EKN</strong>, and SACE, the<br />

“Senior Lenders”) up to US$2.95 billion (Tranche 1), and up to US$300 million (Tranche 2),<br />

which is expected to be provided by domestic and/or international commercial banks.<br />

Exponent was contracted to act as the Independent Environmental and Social Consultant for the<br />

Senior Lenders to the Project. This work was initially reported in Exponent’s Environmental<br />

and Social Due Diligence report (Exponent April 2009). The scope of work for this updated<br />

Environmental and Social Due Diligence report consisted of four tasks:


� Task 1—Presentation to the Senior Lenders. Exponent provided a<br />

presentation on its 2009 due diligence to representatives of US Ex-Im Bank,<br />

<strong>EKN</strong>, and SACE, and their advisors in Washington, DC, on January 26,<br />

2011.<br />

� Task 2—Information Review. Exponent provided an initial list of<br />

information and data required, and proposed ideas for the site visit.<br />

Subsequently, additional information was requested based on the site<br />

reconnaissance (Task 3). The work involved review of the documentation<br />

provided related to the Project (Tables 1a and 1b provide a summary list of<br />

documents reviewed).<br />

� Task 3—Site Reconnaissance. Exponent staff conducted a site visit from<br />

February 28 to March 5, 2011. The visit included presentations and<br />

discussions with various <strong>Reficar</strong>, CBI <strong>Colombia</strong>na S.A., Foster Wheeler<br />

PCIB, and Mecor company personnel; reconnaissance of the existing<br />

refinery, the area for refinery expansion, and some surrounding areas;<br />

meetings with representatives of three <strong>Cartagena</strong> local governmental<br />

authorities and two civil society groups; and public consultation meetings in<br />

three local communities, Arroz Barato, Pasacaballos, and Membrillal.<br />

� Task 4—Report Preparation. This task consisted of preparing a<br />

Preliminary Report of Findings (submitted on March 11, 2011) and this<br />

updated Environmental and Social Due Diligence report.<br />

1101335.000 04F1 0611 MJ21<br />

2<br />

June 21, 2011<br />

This report presents the results of our environmental and social due diligence and consists of the<br />

following sections:<br />

� Section 2, Project Description<br />

� Section 3, Institutional and Legal Framework<br />

� Section 4, Environmental and Social Conditions


� Section 5, Environmental and Social Impacts<br />

� Section 6, Environmental, Social, and Health and Safety Management<br />

� Section 7, Information Disclosure and Public Consultation<br />

� Section 8, Conclusions and Recommendations, including assessment of<br />

1101335.000 04F1 0611 MJ21<br />

compliance with the following:<br />

� Equator Principles<br />

� IFC Performance Standards<br />

� IFC EHS Petroleum Refining Sector Guidelines<br />

� IFC EHS General Guidelines.<br />

� Appendix A Photograph Log<br />

3<br />

June 21, 2011


2 Project Description<br />

The <strong>Cartagena</strong> <strong>Refinery</strong> is owned by Refinería de <strong>Cartagena</strong> S.A. (<strong>Reficar</strong>), a <strong>Colombia</strong>n<br />

1101335.000 04F1 0611 MJ21<br />

4<br />

June 21, 2011<br />

special-purpose company owned by Andean Chemicals (50.9%), Ecopetrol S.A. (48.9%), and<br />

minority shareholders (0.2%). <strong>Reficar</strong> and CBI Americas Limited (CBIA) entered into an<br />

engineering, procurement, and construction contract (the Early Works EPC) dated November 6,<br />

2007, for the expansion of the <strong>Cartagena</strong> refinery. The Early Works EPC was amended on<br />

August 26, 2009, and pursuant to that amendment, CBI <strong>Colombia</strong>na S.A. (CBIC) acceded to the<br />

Early Works EPC. CBIA and CBIC (together CB&I) are severally and jointly liable for the<br />

performance of the specific works established in the aforementioned amendment. Notwith-<br />

standing the signing, or coming into effect, of the new EPC (as defined below), all those<br />

activities, services, and works that are currently being performed under the Early Works EPC<br />

shall continue to be performed, and shall be subject to the terms and conditions of the Early<br />

Works EPC. Under the Early Works EPC, CB&I renders services on a reimbursable basis. The<br />

Early Works EPC is scheduled to be in force and valid until November 30, 2011. In addition,<br />

on June 5, 2010, CB&I signed the new EPC, which will replace the old one when the Early<br />

Works are finished. Foster Wheeler PCIB was awarded the project management contract<br />

(PMC) for <strong>Reficar</strong> on December 15, 2009. Ecopetrol S.A., a mixed equity company with<br />

majority state ownership, is an integrated oil company, established in 1951, that engages in oil<br />

and gas exploration, production, and transportation, and crude-oil refining. Ecopetrol is the<br />

largest company and the principal petroleum company in <strong>Colombia</strong>.<br />

The <strong>Cartagena</strong> <strong>Refinery</strong> is located in the Mamonal Industrial Area on <strong>Cartagena</strong> Bay,<br />

30 minutes to the south of the city of <strong>Cartagena</strong> on the northern coast of <strong>Colombia</strong> (see<br />

Figure 1). Mamonal is a highly developed industrial zone, hosting more than 170 1 different<br />

industries that range from oil and petrochemicals to shipyards and cement manufacturing.<br />

Under a use-of-port agreement, Ecopetrol provides <strong>Reficar</strong> the use of port facilities on<br />

<strong>Cartagena</strong> Bay owned by Ecopetrol, and an option to use tanks on an adjacent tankfarm, also the<br />

property of Ecopetrol. The refinery location represents a strategic advantage, because it has<br />

1 As of May 2010, according to the Logistical and Business Center of <strong>Cartagena</strong>.


access to the Gulf Coast and Caribbean markets via the Atlantic Ocean, as well as to the<br />

1101335.000 04F1 0611 MJ21<br />

5<br />

June 21, 2011<br />

national <strong>Colombia</strong>n market by river through the “Canal del Dique” and via existing pipelines.<br />

The refinery was inaugurated in 1957 by the International Petroleum Company and was<br />

acquired by Ecopetrol in 1974. It has undergone some previous expansions to grow from its<br />

initial capacity of 26,000 bpd, including expansions in 1962 (33,200 bpd), 1964 (42,000 bpd),<br />

and some after the Ecopetrol acquisition (up to the present approximately 80,000 bpd). The<br />

current refinery uses a mix of 85% <strong>Colombia</strong>n and 15% imported crude, while exporting about<br />

47% of its product mix. The average product yield of the existing refinery (during the year<br />

ending March 2008) included: gasoline (33%), diesel (27%), fuel oil (24%), jet/kerosene (8%),<br />

light ends (4%), and slurry (2%).<br />

<strong>Reficar</strong> intends to modernize the refinery and expand its refining capacity from 80,000 to<br />

165,000 bpd; products will be distributed to the <strong>Colombia</strong>n domestic market and to international<br />

markets. The modernization of the refinery will include an increase in the facility’s complexity,<br />

which will enable it to process a less expensive mix of crude (heavier, more acid) while<br />

producing low-sulfur gasoline and ultra-low sulfur diesel, jet fuel, and fuel oil that will meet<br />

new domestic and international clean-fuel requirements (e.g., sulfur content for the domestic<br />

market: not higher than 300 ppm for gasoline and 50 ppm for diesel, and for the export market:<br />

< 30 ppm for gasoline and < 8 ppm for diesel). The new configuration, including<br />

hydrocracking, hydrotreating, catalytic reforming, and coking capacity, will enable the refinery<br />

to handle up to 90,000 bpd of acidic crudes. This will provide a competitive advantage, because<br />

most refineries can process only small quantities of such corrosive crude oils, and will allow<br />

<strong>Colombia</strong> to better use its domestic oil reserves. The new products will include ultra-low-sulfur<br />

gasoline, jet fuel, and diesel.<br />

<strong>Reficar</strong> has entered into a contract with Technip for the basic design and engineering of the<br />

upgrade and expansion, and into an EPC Contract with CB&I. During the expansion, Ecopetrol<br />

will continue to operate the existing refinery under a mandate agreement, with the economic<br />

benefit of such operation belonging directly to <strong>Reficar</strong>. After the expansion is complete, <strong>Reficar</strong><br />

will take over full management and operation of the entire refinery.


<strong>Reficar</strong> is requesting financing for the refinery expansion (“Project”). The Project has an<br />

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June 21, 2011<br />

estimated capital cost ofUS$4.7 billion. The debt financing structure considered for the upgrade<br />

program includes a Direct Loan and/or Loan Guarantee structure provided by three export credit<br />

agencies (US Ex-Im Bank, <strong>EKN</strong>, and SACE, the “Senior Lenders”) up to US$2.95 billion<br />

(Tranche 1), and up to US$300 million (Tranche 2), which is expected to be provided by<br />

domestic and/or international commercial banks.<br />

2.1 Existing Operations<br />

The <strong>Cartagena</strong> <strong>Refinery</strong> is located in the Mamonal Industrial Area, KM 10, approximately<br />

15 km south of the City of <strong>Cartagena</strong> in the Bolivar Department, <strong>Colombia</strong> (see Figures 1<br />

and 2). A total of approximately 170 industries are located within the Mamonal Industrial Area,<br />

resulting in a flow of more than 40,000 people daily, including employees, vendors, and<br />

contractors. The approximate size of the Mamonal Industrial Area is 3,100 hectares, of which<br />

most has been developed. The industries include ammonia and fertilizer manufacturing, gas<br />

storage, fuel storage, and petrochemical and herbicide manufacturing.<br />

The refinery was constructed in 1956 by INTERCOL and consisted primarily of a crude<br />

distillation unit for the production of refined fuels. A catalytic cracking unit was installed in<br />

1957 and subsequently expanded in 1964 along with the expansion of the distillation unit. The<br />

original production was approximately 26,000 bpd. By 1964, the refinery had expanded<br />

production to 47,000 bpd. An ammonia plant known as the Abocol plant was part of the<br />

INTERCOL operations up to 1972, at which time this business was sold and formally separated<br />

from the refinery. Ecopetrol acquired the refinery from INTERCOL in 1974 and increased<br />

production to 70,700 bpd with a further expansion of the distillation unit and construction of the<br />

Visbreaker plant. Production was increased to 75,000 bpd with repair of the preheater. The<br />

Visbreaker plant was expanded in 1981, along with the port installations, to accommodate the<br />

increased production. Ecopetrol reportedly acquired neighboring land in this same period from<br />

Andean National Land, constituting some of the areas to the south and east of the refinery<br />

property, where the proposed refinery expansion is planned. Landfarming activities commenced<br />

around 1986 in portions of the newly acquired land. The sulfur plant was added in 1990. LPG


1101335.000 04F1 0611 MJ21<br />

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June 21, 2011<br />

and butane production and storage tanks were installed in 1992. Following in 1994 was an<br />

expansion of storage, including three gasoline tanks, one crude tank, two jet fuel tanks, and one<br />

aromatic tar tank. The asphalt plant commenced operations at the site in 1993 and ceased<br />

operations in 2003. The asphalt plant building is currently abandoned.<br />

The current refinery utilizes a mix of 85% <strong>Colombia</strong>n and 15% imported crude while exporting<br />

about 47% of its product mix. The existing refinery has a current capacity to process<br />

80,000 bpd of crude oil, visbreaking 25,000 bpd, and fluid cracking 29,000 bpd. The current<br />

operations consist of the following (see Figure 3):<br />

� One atmospheric crude unit (primary distillation unit) that processes the<br />

crude feedstock into naphtha, gasoline, diesel, fuel oil, etc.<br />

� One vacuum unit used to separate the atmospheric column residuum into<br />

lighter fractions (light gas oil, heavy gas oil, vacuum residuum)<br />

� One visbreaker unit for cracking the vacuum residuum into lighter fractions<br />

� One fluid catalytic cracking unit (FCCU) used for cracking the gas oils<br />

generated by the vacuum unit<br />

� One polymerization unit that uses olefins produced in the FCCU to produce<br />

propane, butane, and polymer gasoline<br />

� One sulfur plant that produces sweet gas for electricity generation and<br />

sulfuric acid for sale.<br />

The current principal refining products are LPG, high-sulfur gasoline, Jet A, diesel, marine<br />

diesel, arotar (aromatic tar), No. 6 fuel oil, propylene, and sulfur.<br />

Support facilities include:<br />

� Five turbo-generators, 31 turbines, and 8 compressors, fuel oil and<br />

natural/refinery gas fired (22.5 MW)


� Five steam boilers for ovens<br />

� Five water treatment plants for fresh and salt water, cooling water, and<br />

1101335.000 04F1 0611 MJ21<br />

wastewater treatment<br />

� Piping and valves (1,500 km crude and product piping inside the refinery)<br />

� Approximately 20,000 valves<br />

� API oil/water separator<br />

� Crude and product tanks (134 tanks, with total storage capacity of more than<br />

6.4 MM bbls)<br />

� Maintenance workshop<br />

� Marine terminal for loading/offloading of raw materials and products (two<br />

marine terminals of 85 KDWT, one LPG and butane terminal, and three<br />

fluvial docks)<br />

� Spill response equipment and spill containment control (including pilot boats<br />

for support of barge and bunkering operations, environmental boats, spill<br />

response boats)<br />

� Administrative buildings.<br />

8<br />

June 21, 2011<br />

The refinery operations include the use of two marine terminals (the refinery terminal itself and<br />

the Nestor Pineda Terminal [TNP]) and two fluvial piers which are connected directly to the<br />

refinery marine terminal. The refinery terminal is located immediately west of the refinery, and<br />

TNP is north of the refinery. The marine terminal consists of a metal finger pier or bridge<br />

approximately 300 m long, connecting the main tanker loading and unloading platform to the<br />

land. This pier consists of tubular support sections, carrying a main central narrow walking<br />

bridge and supporting the product pipelines conveying loaded and unloaded product which are<br />

on both sides. The loading and unloading platform allows the operation of tanker ships with a<br />

maximum draft of 12 m (Panamax standard). The platform is equipped with transfer hoses,<br />

manifold piping, loading arms and valves, and firefighting equipment. The land end of the


1101335.000 04F1 0611 MJ21<br />

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June 21, 2011<br />

marine terminal is equipped with an emergency electricity generator, piping, and a warehouse to<br />

store towropes, firefighting equipment, and spill control and response equipment. Smaller boats<br />

and tugboats, used to transport tankers in and out of the main platform, use the fluvial piers<br />

located to the south at the land end of the terminal. Halfway along the pier to the south is the<br />

main LPG and diesel loading and unloading platform. This platform, a medium-draft pier, is<br />

designed for ships with a maximum draft of 7 m, whereas the fluvial or low-draft piers allow<br />

vessels with a maximum draft of 4 m.<br />

The site operates in four 8-hour shifts, which considers three working shifts and one resting.<br />

Maintenance areas operate in two work shifts and one administration shift, Monday through<br />

Friday. All other shifts are seven days per week.<br />

The site generates its own electricity at the onsite generation plant. For backup supply, the site<br />

is connected to the electrical grid. The onsite generation is steam generated by 70% natural gas<br />

and 30% refinery gas or sweet gas. Compressed air is generated internally at a compressor<br />

plant. The site receives natural gas from the Ecopetrol facility, which is transported by<br />

PROMIGAS to the site. The generation system is set up with dual burners, so either fuel oil or<br />

natural gas can be burned in the boilers.<br />

Water is supplied by Agua de <strong>Cartagena</strong> (ACUACAR), and usage is approximately<br />

2,300 gal/min (0.146 m 3 /sec). The intake for this supply is the Magdalena River through Canal<br />

del Dique. Drinking water for onsite operations is supplied by a third-party company. Water is<br />

stored in tanks and is treated by various processes according to its final use. Water to be used<br />

for the fire extinguishing network is stored in tanks untreated and also in ponds on the southern<br />

part of the property. Industrial and sanitary water is clarified with addition of flocculants and<br />

chlorine. Cooling water is further treated through a demineralization process to remove<br />

hardness. This process includes the following phases: clarification, filtration with sand and<br />

activated carbon, demineralization, and aeration. The water supply is supplemented by an<br />

intake from the ocean amounting to approximately 20,000 gal/minute (1.21 m 3 /sec) of cooling<br />

water, which is subsequently chlorinated and discharged back to the sea. This water is also used<br />

to dilute the skim-pond effluents. Wastewater from the office areas is discharged to the septictank<br />

system, consisting of approximately 35 septic tanks. The remaining wastewater from the


industrial areas is discharged to the onsite wastewater treatment plant and is subsequently<br />

discharged to the Bay through an open canal.<br />

1101335.000 04F1 0611 MJ21<br />

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June 21, 2011<br />

The natural gas consumption in refinery operations is approximately 14 MMSCFD. The energy<br />

consumption by the refinery is approximately 8 MMBTU/h.<br />

2.2 <strong>Refinery</strong> <strong>Expansion</strong><br />

Ecopetrol established certain minimum requirements for the upgrade of the refinery, including:<br />

configuration to at least comply with national fuels (gasoline and diesel) quality and with<br />

environmental regulations that went into effect in March 2006, and sulfur content for the<br />

domestic market: not higher than 300 ppm for gasoline and 50 ppm for diesel, and for the<br />

export market: < 30 ppm for gasoline and < 8 ppm for diesel; achieve a production capacity for<br />

medium distillates of 70,000 bpd minimum (diesel, heating oil, jet fuel of any grade) and<br />

gasoline (any motor gasoline and blendstocks); minimum input for local and/or international<br />

petrochemical industry of 40,000 bpd; and refinery-grade propylene at minimum of 60,000 tpy.<br />

The refinery expansion is significant in that it will double the crude capacity, involve<br />

installation of a large coker and hydrocracker, and double the existing FCCU capacity. The<br />

expansion will create a throughput of 165,000 bpd and handle feed quality of 22 API gravity,<br />

0.6%–1.8%* sulfur, and high acid content. The processing capacities will be as follows (see<br />

Figure 4):<br />

� Atmospheric crude distillation unit: 165,000 bpd<br />

� Vacuum distillation unit (VDU): 100,000 bpd<br />

� Coker: 43,000 bpd<br />

� Hydrocracker: 35,000 bpd<br />

� FCCU revamp: 35,000 bpd<br />

� ULSD diesel (2 units): 70,000 bpd (total)


� Butamer: 1,500 bpd<br />

� Kero Merichem: 20,000 pbd<br />

� HF alkalation: 9,000 bpd<br />

� H2 plant: 100 MMScf/D<br />

� PSA plant: 20 MMScf/D<br />

� Sulfur plants: 270 tpd.<br />

The principal products will be low-sulfur gasoline, jet fuel, and ultra-low-sulfur diesel.<br />

1101335.000 04F1 0611 MJ21<br />

11<br />

June 21, 2011<br />

Associated support facilities will include sulfur handling, transport, and storage (patio with<br />

concrete slab and storm water collection); coke handling, transport, and storage (configuration<br />

to be determined); product transport and storage (13 new tanks to increase capacity by 2.4 MM<br />

bbls, 9 new spheres/pressurized storage); torch system; electrical energy (75 MW new capacity);<br />

steam production; water supply and treatment (approximately 6,000 gal/min or 0.36 m 3 /sec<br />

required); water cooling towers.<br />

The entire expansion and upgrade process will be carried out within the existing refinery’s<br />

boundaries. The expansion will be located on about 135 ha of land east of the existing<br />

operations.<br />

The main construction works involving vegetation clearing and grading of approximately<br />

135 ha (estimated movement of 500,000 m 3 of organic soil material); building and operation of<br />

construction offices, work areas, and maintenance areas; and fill and compaction of base for<br />

facilities have been completed. The main activities that remain to be completed include:<br />

casting of reinforced concrete structures; foundation construction; assembly of equipment, civil<br />

works and hydrostatic testing; laying of pipelines for raw materials and product transport;<br />

installation of storage tanks; refinery commissioning, start-up, and testing; and site cleanup.<br />

The Project is considering three options for raw material delivery:


� Nestor Pineda Terminal. The existing facility will undergo modification to<br />

1101335.000 04F1 0611 MJ21<br />

handle the import of crude oil at the Ecopetrol facility. This includes<br />

installation of a 24-in. underwater pipeline from the terminal, two new crude<br />

oil storage tanks (550,000 bbls), and pumps for transfer of crude oil to<br />

<strong>Reficar</strong> by pipeline. Ecopetrol facility modifications for export of ultra-lowsulfur<br />

diesel from <strong>Reficar</strong> include the installation of a new pipeline, transfer,<br />

and storage tanks (5). The port facilities were added to the license in March<br />

2010 under Resolution 511.<br />

� Coveñas Option. This would involve building a new 24-in. crude pipeline<br />

(approximately 190 kbpd) from Coveñas to the refinery (approximately<br />

130 km), and building tanks (by Ecopetrol) at the existing Ecopetrol Coveñas<br />

crude storage facility.<br />

� New Coke Jetty and Storage Option. The 2009 option was to include the<br />

augmentation of the coke jetty to handle ultra-low-sulfur diesel, domestic<br />

diesel/kerosene, and sulfur by a T-shaped configuration. Crude will now<br />

come from Coveñas using the existing pipeline and terminal. This facility is<br />

under consideration by <strong>Reficar</strong>’s Board of Directors at this time. While<br />

<strong>Reficar</strong> had an EIA for the new port facilities prepared in 2010, its Board of<br />

Directors has recommended that <strong>Reficar</strong> evaluate the alternative of not<br />

building the marine terminal and instead constructing only stand-alone truck<br />

facilities for the export of the coke, which may be shipped by truck to two<br />

existing ports nearby. <strong>Reficar</strong> plans to complete its evaluation of the two<br />

shipping options as soon as possible. Therefore, no further environmental<br />

studies, permits, or authorizations may be required for the port facility.<br />

2.3 Schedule and Costs<br />

12<br />

June 21, 2011<br />

Project construction is ongoing and Guaranteed Mechanical Completion is scheduled for<br />

February 2013. As of the site visit (February 28 to March 5, 2011), the main construction works<br />

involving vegetation clearing and grading of approximately 135 ha (estimated 500,000 m 3 of


waste organic material); building and operation of construction offices, work areas, and<br />

maintenance areas; and fill and compaction of base for facilities have been completed.<br />

The Project capital cost for the investment plan is an estimated US$4.7 billion.<br />

2.4 Project Workforce<br />

1101335.000 04F1 0611 MJ21<br />

13<br />

June 21, 2011<br />

The estimated peak construction workforce for the Project, according to CB&I, is approximately<br />

7,000 personnel, with a distribution of supervisor-senior staff, operators, and contractors. Total<br />

workers are projected to be approximately 10,780, and with turnover, could go as high as 15,000<br />

at CB&I. This does not include subcontractor workers or miscellaneous labor.<br />

The existing refinery has approximately 420 Ecopetrol staff. Additional contractual personnel<br />

provide various services, especially maintenance-related work. In addition, there are<br />

approximately 900 people currently working at the project site. The current total Project<br />

workforce is approximately 1,425, and is made up of 118 direct workers, including small teams<br />

in Bogotá and Houston, plus 1,307 indirect workers.<br />

The present estimated number of staff for the refinery operations after expansion is 500.


3 Institutional and Legal Framework<br />

3.1 Institutional Framework<br />

1101335.000 04F1 0611 MJ21<br />

14<br />

June 21, 2011<br />

The principal relevant governmental environmental, and health and safety entities related to the<br />

Project are as follows:<br />

� Ministry of Environment, Housing and Territorial Development (Ministerio<br />

de Ambiente, Vivienda y Desarrollo Territorial—MAVDT), which is<br />

responsible for issuing environmental licenses for projects and for setting<br />

environmental standards and regulations<br />

� Corporación Autónoma Regional del Canal del Dique (CARDIQUE), which<br />

is the regional entity responsible for environmental protection and<br />

management<br />

� Establecimiento Publico Ambiental de <strong>Cartagena</strong> (EPA, <strong>Cartagena</strong> Public<br />

Establishment for the Environment), which is the city level entity responsible<br />

for environmental protection.<br />

3.2 Legal Framework<br />

The following lists the principal legislation relevant to this Project (in terms of environmental,<br />

social, and health and safety aspects):<br />

� Environmental Organization/Responsibilities: Law 99 (1993), which<br />

established the national system of environment.<br />

� Air Quality: Decree 948 (1995) related to air pollution and establishes<br />

ambient air quality standards at a national level. Resolution 601 (2006)<br />

designates national emission air quality standards for total suspended<br />

particulates (annual and 24-hour period), PM10, SO2, NO2, O3, and CO.


1101335.000 04F1 0611 MJ21<br />

Decree 979 (2006) established areas of pollution levels. Resolution 909<br />

(2008) establishes emission limits for fixed-source refinery operations.<br />

� Noise: Resolution 601 (2007) related to control of noise pollution and<br />

standards for maximum possible noise levels. Decree 948 (1995) regulates<br />

the prevention and control of air pollution and the protection of air quality.<br />

Resolution 627 (2006) develops regulations on control of noise pollution and<br />

sets standards for maximum permissible emission levels.<br />

� Water: Decree 475 (1998) outlines the requirements for potable water.<br />

Decree 1594 (1984) establishes wastewater discharge limits depending on the<br />

type of facility that is discharging (i.e., industrial or domestic) and the<br />

receiving location for the discharge (surface water, groundwater, marine, and<br />

estuarine water).<br />

� Materials Management: Decree 948 (1994) outlines the requirements for<br />

storage conditions and loading and unloading operations (specifically in port<br />

areas) with regard to fugitive emissions, including particulates, dust, and<br />

gases and volatile substances. Resolution 2400 (1979) outlines the<br />

requirements for materials compatibility storage conditions and the use of fire<br />

extinguishing equipment in these areas. Decree 321 (1999) outlines the<br />

national plan for hydrocarbon spill prevention and response. Resolution<br />

805050 (1997) outlines the requirements for tank storage for LPG. Decree<br />

318 (2003) outlines requirements for diesel storage in tanks, with regard to<br />

minimum distance and other safety requirements.<br />

� Solid and Hazardous Waste: Law 430 (1998) and Decree 4741 (2005) that<br />

establishes responsibilities of solid waste and hazardous waste generators,<br />

transporters, and disposal facilities/sites. Resolution 541 (1994) regulates the<br />

loading, unloading, transportation, storage, and disposal of debris, materials,<br />

components, concrete, and aggregates loss in construction, demolition, and<br />

excavation.<br />

15<br />

June 21, 2011


� Health and Safety: Resolution 2400 (1979) establishes main health and<br />

1101335.000 04F1 0611 MJ21<br />

safety requirements. Decree 1295 (1994) addresses management and<br />

administrative guidelines, requires a formal Occupational Health Plan for<br />

every industrial site, accident statistics records and reporting requirements,<br />

organization of safety committees and communication of hazards to<br />

employees. Resolution 1570 (2005) establishes standards for accident<br />

records and statistics calculation. Law 378 (1997) establishes responsibilities<br />

in occupational health, employees’ right of safety information, and periodic<br />

reporting requirements. Resolution 2013 (1986) regulates the organization<br />

and functioning of safety committees. Resolution 6398 (1991) defines the<br />

types of medical exams to be conducted (admission, return to work, exit, and<br />

periodical) and establishes the confidentiality of employees’ medical records.<br />

Resolution 1792/1980 complements Resolution 2400/79 establishing noise<br />

exposure limits (85 dB A for an 8-hour period).<br />

� Polychlorinated Biphenyls: Law 18-1028/2005 (and Decree 4741/2005 and<br />

Resolution 18-1-34/2004) regarding polychlorinated biphenyls (PCBs) and<br />

asbestos.<br />

The following are potentially relevant international environmental conventions related to<br />

the Project:<br />

� Convention for the Protection and Development of the Marine Environment<br />

in the Wider Caribbean Region was adopted in <strong>Cartagena</strong>, <strong>Colombia</strong>, on<br />

24 March 1983 and promulgated on 11 October 1986. The Convention is<br />

supplemented by three Protocols: Protocol Concerning Co-operation in<br />

Combating Oil Spills in the Wider Caribbean Region, which was also<br />

adopted in 1983 and entered into force on 11 October 1986; Protocol<br />

Concerning Specially Protected Areas and Wildlife (SPAW) in the Wider<br />

Caribbean Region Committee, which was adopted on 18 January 1990 and<br />

entered into force on 18 June 2000; and the Protocol Concerning Pollution<br />

from Land-Based Sources and Activities which was adopted on 6 October<br />

16<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

1999 but is not yet in force. The Land-Based Sources protocol, which is part<br />

of the <strong>Cartagena</strong> Convention, establishes limits for discharge of domestic<br />

wastewater into Class I and II waters. Class I waters are classified by various<br />

characteristics. Limits have been established for each class of water for:<br />

total suspended solids; biological oxygen demand; pH; fats, oil, and grease;<br />

fecal coliform; and floating solids.<br />

� International Convention on Oil Pollution, Preparedness Response and<br />

Cooperation (OPRC), 1990.<br />

� MARPOL 73/78.<br />

� International Convention on Civil Liability for Oil Pollution Damage.<br />

� Civil Liability Convention Fund.<br />

� Convention on Biological Diversity.<br />

� Montreal Protocol on Substances that Deplete the Ozone Layer.<br />

� Basel Convention (trans-border movement and disposal of hazardous waste).<br />

3.3 Other Requirements<br />

17<br />

June 21, 2011<br />

In relation to the potential lenders involved, the following are environmental, social, health and<br />

safety, and labor-related requirements that are applicable to this project and upon which this<br />

report is based:<br />

� Equator Principles (2006)<br />

� IFC Performance Standards (2007), and in particular, Performance Standards<br />

1, 2, 3, 4, 6 and 8<br />

� IFC Environmental, Health and Safety Guidelines for Petroleum Refining<br />

(2007)


� IFC Environmental, Health and Safety General Guidelines (2007).<br />

1101335.000 04F1 0611 MJ21<br />

18<br />

June 21, 2011<br />

Tables 2 and 3 present the applicable Project air emission limits and relevant ambient air quality<br />

limits, respectively. Table 4 presents the applicable Project wastewater discharge limits.<br />

Ambient noise limits per <strong>Colombia</strong>n regulations are 75 dBA at plant boundary from 0700 to<br />

2100 and 70 dBA from 2100 to 0700. Noise limits from IFC EHS General Guidelines are<br />

70 dBA for all times.<br />

It is our understanding that US Ex-Im Bank, <strong>EKN</strong>, and SACE have classified the Project as a<br />

Category A as per the OECD Common Approaches, and, in the event there is a Tranche 2,<br />

classification of the Project as per the Equator Principles will take place once the commercial<br />

lenders have been identified.<br />

3.4 Status<br />

In 1996, Ecopetrol contracted MW Kellogg to design the Master Plan of Development (PMD)<br />

for the refinery to increase the refinement capacity to a maximum of 140,000 bpd. This<br />

assessment was later updated in 2000 by Shell Global Solutions International. In 2002 and<br />

2003, Ecopetrol contracted for development of basic design for the PMD. From December<br />

2005 to February 2006, Ecopetrol carried out a pre-qualification process to assess possible<br />

investors. Four companies prequalified to participate in a bidding process: Marubeni<br />

Corporation, Glencore International AG, BP, and Petrobras. Ecopetrol entered into an<br />

arrangement with Glencore in 2007 to establish <strong>Reficar</strong> S.A., in which Glencore owned 51%<br />

and had the obligation to lead the process of upgrading and expanding the refinery (including<br />

financing), and to contribute cash corresponding to its share of the equity. Ecopetrol owned the<br />

remaining 49% and contributed the existing <strong>Cartagena</strong> <strong>Refinery</strong> as equity. Andean Chemicals,<br />

an offshore company wholly owned by Ecopetrol, acquired Glencore’s share of <strong>Reficar</strong> in 2010,<br />

and Ecopetrol continues to own 49%. Currently, the existing refinery is being managed,<br />

operated, and maintained by Ecopetrol under a Mandate Agreement. After completion of the<br />

refinery expansion, <strong>Reficar</strong> will take over the full management and operation of the upgraded<br />

refinery.


Ecopetrol started the environmental licensing process for the PMD in 1995. In 1996, the<br />

1101335.000 04F1 0611 MJ21<br />

19<br />

June 21, 2011<br />

Ministry of Environment issued the terms of reference for the environmental impact assessment<br />

(EIA) and stated that no alternative analysis was required, because the proposed project<br />

consisted only of an expansion of capacity of an existing operation. Ecopetrol submitted an EIA<br />

and environmental management plan in March 1998. MAVDT granted an environmental<br />

license to Ecopetrol for the construction and operation project of the proposed new plants for the<br />

refinery in November 2000 (Resolution 1157). The resolution identified 27 requirements.<br />

However, the present proposed Project expansion is not the same as presented, and thus, this<br />

resolution is not fully valid for the proposed refinery expansion.<br />

In January 2007, Ecopetrol and <strong>Reficar</strong> requested MAVDT to grant partial concession to<br />

<strong>Reficar</strong> of the environmental license (Resolution 1157 of 2000) granted to Ecopetrol, and<br />

MAVDT granted the partial concession (Resolution 349 of February 2007). CARIDQUE issued<br />

a similar transfer to <strong>Reficar</strong> of the responsibilities and obligations in Resolutions 433 (2002) and<br />

911 (2005).<br />

In August 2008, <strong>Reficar</strong> requested a modification to the originally proposed refinery expansion<br />

as authorized by Resolution 1157 of 2000. This modification included submittal of the Project<br />

EIA. The principal requested modifications were: one additional primary distillation unit, one<br />

additional vacuum distillation unit, one new FCCU, one new coke unit, one new alkalation unit,<br />

one additional sulfur cathodic oxidation unit, one new gas saturation unit, increase tank storage<br />

of product by 2,000,000 barrels, additional solid storage for coke and sulfur, and four new<br />

turbo-generators of 52 MW. MAVDT issued the modification authorization for the Project<br />

(presently proposed refinery expansion) in November 2008 (Resolution 2102). The<br />

authorization states that the existing authorizations/resolutions related to the existing refinery<br />

operations shall maintain in effect until initiation of the refinery expansion operations.<br />

CARDIQUE authorized the land clearing for the proposed refinery expansion in 2008<br />

(Resolutions 1045, 1063, which allowed for the clearing of 56 ha and required the planting of<br />

36,000 trees as compensation for the loss of the 5,143 trees during site clearing (1 to 7<br />

compensation ratio).


1101335.000 04F1 0611 MJ21<br />

20<br />

June 21, 2011<br />

The EIA for the port development associated with the Project (Port EIA) was submitted to<br />

MAVDT for review on July 9, 2009, and was approved and added to the license in March 2010<br />

(Resolution 511, March 2010). Subsequent to the Port EIA, <strong>Reficar</strong> submitted a request for a<br />

port concession to construct and operate the port facilities; this concession was awarded in<br />

November 2010.<br />

MAVDT has monitored compliance with the existing refinery (e.g., Acts 338 of February 16,<br />

2007; 890 of April 11, 2007; 1389 of April 28, 2008; Act 984 of March 31, 2008).<br />

With regard to the existing refinery (and not the new Project), CARDIQUE has issued the<br />

following resolutions:<br />

� In August 2002, CARDIQUE issued Resolution 433 regarding hazardous<br />

waste generation, treatment, and disposal. This resolution was issued prior to<br />

the promulgation of Decree 4741/2005, which requires a hazardous waste<br />

management program. The requirements included actions associated with the<br />

landfarming operations. This resolution indicates that Ecopetrol is<br />

responsible for any type of contamination caused by their wastes that may<br />

affect human health and the environment.<br />

� In December 2002, CARIDQUE requested that the refinery develop and<br />

implement a plan to resolve the issue with excessive phenol wastewater<br />

discharges. A plan was presented in May 2003.<br />

� In November 2005, CARDIQUE issued Resolution 911, which established<br />

various requirements related to wastewater discharges, air emissions, and<br />

waste management. It authorized refinery operation under the present<br />

refinery conditions until November 2010, which has been extended to<br />

August 14, 2011.<br />

� CARDIQUE issued Resolution 187 (2005) based on a November 2005 site<br />

visit. The observations indicated that hydrocarbons appeared to be spilling<br />

over the barrier into the Bay at the wastewater discharge point. CARDIQUE


1101335.000 04F1 0611 MJ21<br />

required the sludge on the ocean floor to be characterized at nine locations to<br />

determine the TPH levels and removal of a barge that was sunk in this area.<br />

� CARDIQUE issued Resolution 647 (2006) that stipulated air monitoring<br />

requirements, including an annual emission monitoring program for PM,<br />

NOx, and SO2.<br />

21<br />

June 21, 2011<br />

Regarding waste generation, and per regulatory requirements, the existing refinery presents<br />

waste generation reports to MAVDT.<br />

In December 2007, Ecopetrol presented a plan to CARDIQUE to allow the existing refinery to<br />

meet the 0.2-mg/L phenol wastewater discharge limit.<br />

In order to meet the air emissions limits established in Resolution 909 (2008), we understand<br />

that <strong>Reficar</strong> has requested a waiver from CARDIQUE to delay compliance with the standards<br />

that are effective July 2010 until the new refinery expansion is completed. While <strong>Reficar</strong> has<br />

not yet received the waiver from CARDIQUE, they believe it is likely to be granted.<br />

CARDIQUE granted the extension of Resolution 911 until August 14, 2011, permitting the<br />

continuance of refinery operations under the present refinery conditions. <strong>Reficar</strong> has applied for<br />

a subsequent extension and expects this to occur prior to August 14, 2011.


4 Environmental and Social Conditions<br />

1101335.000 04F1 0611 MJ21<br />

22<br />

June 21, 2011<br />

The site is located in the industrial sector of <strong>Cartagena</strong> known as the Mamonal Industrial Area.<br />

This area is approximately 15 km south of the city of <strong>Cartagena</strong>, along the coast (see Figures 1<br />

and 2). The Mamonal area consists of approximately 3,100 hectares. North of the industrial<br />

zone is <strong>Cartagena</strong> City (Santa Clara, Campestre, and Bellavista neighborhoods), to the south is<br />

the Corregimiento Pasacaballos town, to the west is the <strong>Cartagena</strong> Bay, and to the east is<br />

Membrillal, which is a small rural community.<br />

The neighboring properties (and land uses) to the refinery are as follows:<br />

� North: A narrow strip of undeveloped land; further north are LPG and AGA<br />

plants that produce and store gas (including both petroleum and chemical<br />

gases); and a propylene plant further north. Northwest of the site are Exxon-<br />

Mobil, Texaco, and Terpel fuel loading/unloading terminals. Several<br />

kilometers north is the Terminal Nestor Pineda, which is part of Ecopetrol,<br />

and is a product storage and transfer facility, with a storage capacity of<br />

approximately 1.0 million bbls.<br />

� South: Undeveloped land in some areas, the Abocol ammonia<br />

manufacturing plant, and then a polystyrene plant. Further southwest is an<br />

herbicide plant and a salt-processing facility.<br />

� East: Undeveloped land in some areas as part of the duty-free zone. The<br />

community of Membrillal is in this direction, 2.9 km from the refinery. This<br />

was the only community identified within 3 km of the site.<br />

� West: Mamonal Highway, <strong>Cartagena</strong> Bay, and the Ecopetrol refinery<br />

terminal.


4.1 Environmental Conditions<br />

1101335.000 04F1 0611 MJ21<br />

23<br />

June 21, 2011<br />

The Project site is part of the coastal plain and is relatively flat with some small undulations<br />

about 6 m high. In the Project area, there are low-altitude ridges and hills (approximately 100 to<br />

200 m above sea level east of the site. The refinery site elevation is slightly above sea level.<br />

The <strong>Cartagena</strong> Bay and surrounding islands are formed by Middle to Upper Miocene<br />

(approximately 11.2 million years old) and Pleistocene (1.6 million years old) geologic<br />

formations, both of sedimentary marine and shoreline (litoral) origin. In the coastal area, the<br />

latter lie above the former. Overlying both of these units, recent Quaternary alluvial and marine<br />

sediments constitute the upper layer.<br />

Based on site boring logs at the Project site, the subsurface conditions underlying the site to<br />

approximately 15 m depth (50 ft) consist of fill materials, including clay varying to sandy and<br />

silty loam and other fine-grained hydraulic fill material of low permeability, with intercalations<br />

of sporadic calcareous gravel and sandy clay lenses. Based on site monitoring wells, there is an<br />

upper clay layer, mixed with organic compounds, with an average thickness between 1 and 6 m,<br />

which covers the majority of the existing refinery area. A second layer, with an average<br />

thickness of 15 m, constitutes the phreatic aquifer in the area. This aquifer consists of finegrained<br />

clayey sands, intermixed with calcareous and micaceous gravels. Below this aquifer,<br />

ICP reports the presence of a thick (> 20 m) clay layer. The region is reported as a zone of low<br />

seismic threat.<br />

The Project area is classified as having a dry tropical climate. The Project is located in an area<br />

traversed by the Intertropical Convergence Zone (ITCZ), a belt of low pressure and atmospheric<br />

instability that circles the Earth near the equator. As the ITCZ crosses the Project site, the<br />

climate shifts from dry to wet and back. Total annual average rainfall in the area is<br />

approximately 1,044 mm per year. The dry season typically lasts from late December until<br />

early April, with average monthly rainfall of 5.3 mm. February is, climatologically, the driest<br />

month, with an average of only 0.3 mm. The rainy season occurs during the remaining months,<br />

with substantial rainfall (188.2 mm/month) between early April and late June. The monthly<br />

average rainfall rate dips in July, but climbs back to 104.2 mm/month from the beginning of<br />

August until the end of December. On an annual basis, the average monthly temperature is


1101335.000 04F1 0611 MJ21<br />

24<br />

June 21, 2011<br />

25.6°C and is fairly uniform throughout the year. The average monthly temperatures vary from<br />

24.5°C in February (during the dry season) to 26.3°C in July (between the two wet-season<br />

peaks). The area has a low probability for impact by hurricanes.<br />

There is a clear annual cycle to the prevailing winds, another reflection of the latitudinal<br />

movement of the ITCZ. During the dry period, from late December until early April, when the<br />

ITCZ is south of <strong>Cartagena</strong>, the trade winds blow steadily from the north to northeast at an<br />

average speed of 4 m/s. During the first rainy season, the winds shift a little to blow more from<br />

the north, with average wind speeds decreasing to 2.8 m/s. During the second rainy season, the<br />

winds are more evenly distributed around the compass, again with an average speed of 2.8 m/s.<br />

Because showers during this second period may be intense, however, localized winds may be<br />

quite high. Superimposed on the annual cycle of winds can be a large diurnal variation of the<br />

wind associated with land-sea breezes. While <strong>Cartagena</strong> is too close to the equator to feel the<br />

direct impact of hurricanes, those that pass to the north can have an indirect impact, causing<br />

stronger winds in the Project area.<br />

Limited air quality sampling was conducted as part of the Project EIA baseline. Sampling was<br />

conducted during one 10-day period between May 10 and June 6, 2008, during the first rainy<br />

season. Sampling was performed at six sampling sites, roughly encircling the Project site.<br />

Samples were analyzed for total suspended particulate matter (TSP), particulate matter<br />

composed of particles 10 μm or less in diameter (PM10), sulfur dioxide (SO2), nitrogen oxides<br />

(measured as nitrogen dioxide, NO2), carbon monoxide (CO), ozone (O3), total hydrocarbons<br />

(THC), volatile organic compounds (VOCs), hydrogen sulfide (H2S), ammonia (NH3), and the<br />

heavy metals nickel (Ni) and vanadium (V). Monitoring sites were selected based on a variety<br />

of considerations, but not, apparently, on estimations of maximum modeled impacts. Winds<br />

were light (≤ 2.1 m/s), and there was little rain (totaling ~ 0.8 mm) during the 10-day period.<br />

Maximum daily concentrations (reported as the highest value recorded among all of the six sites<br />

during the entire 10-day sampling period) were as follows:


� TSP: 72.8 μg/m 3<br />

� PM10: 54.3 μg/m 3<br />

� SO2: 34.1 μg/m 3<br />

� NO2: 37.5 μg/m 3<br />

� CO: 3,030.6 μg/m 3<br />

� O3: 74.8 μg/m 3<br />

1101335.000 04F1 0611 MJ21<br />

25<br />

� THC: 152.6 μg/m 3<br />

� VOC: Not reported on daily basis<br />

� H2S: Not reported on daily basis<br />

� NH3: Not reported on daily basis<br />

� Ni: Not reported on daily basis<br />

� V: Not reported on daily basis.<br />

June 21, 2011<br />

Data for each pollutant for each site were also apparently averaged over the 10 samples<br />

collected at that site, and the averages were compared to applicable annual standards. This<br />

comparison is considered to be of limited value given the limited duration of the sampling. For<br />

completeness, these average values are reported as follows:<br />

� TSP: 56.5 μg/m 3<br />

� PM10: 31.7 μg/m 3<br />

� SO2: 12.4 μg/m 3<br />

� NO2: 20.2 μg/m 3<br />

� CO: 1,732.2 μg/m 3<br />

� O3: 46.7 μg/m 3<br />

� THC: 91.2 μg/m 3<br />

� VOC: < 0.17 μg/m 3<br />

� H2S: < 500 μg/m 3<br />

� NH3: 514.5 μg/m 3<br />

� Ni: < 0.02 μg/m 3<br />

� V: < 0.01 μg/m 3 .<br />

Although some of the values listed above are relatively high, all but one of the values are below<br />

maximum allowable annual or daily levels. Ammonia was found at levels above the national<br />

standard, defined as an odor threshold. Monitored ammonia values from four of the six sites<br />

were below the U.S. Environmental Protection Agency (U.S. EPA) standard of 100 μg/m 3 .


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Noise measurements were collected as part of the EIA (seven stations, 5-second intervals over<br />

2 days—a working day and a holiday) during May–June 2008. The results showed the highest<br />

noise levels near the Crude Plant, where the daytime <strong>Colombia</strong>n standard (75 dBA) was<br />

exceeded by 9.89 dBA, and at night, the level was exceeded by 15.78 dBA (standard of<br />

70 dBA). All other stations varied from 53 to 74 dBA and were less than the <strong>Colombia</strong>n<br />

standard.<br />

The regional drainage system is controlled by the Canal del Dique, a neighboring swamp area,<br />

and other minor surface channels flowing directly to the sea (<strong>Cartagena</strong> Bay). Canal del Dique<br />

is a navigation channel excavated by the Spanish in the eighteenth century (1760) with the<br />

objective of connecting the main Magdalena River with the <strong>Cartagena</strong> Bay. Because of the<br />

sediment flow of the diverted waters, Canal del Dique has drastically modified the Bay and<br />

shoreline bottom landscape.<br />

Local drainage of the refinery site and surrounding industrial facilities is through the surface<br />

creek called Arroyo Grande. This creek flowed in a southeast-to-northwest direction, traversing<br />

the refinery site. It has been relocated and now flows north along the eastern boundary of the<br />

site then west where it reconnects to the original creek flowing to the northwest directly into the<br />

<strong>Cartagena</strong> Bay (Figure 2). In winter, the flow can reach 25 m 3 /s. However, in extreme rain<br />

cases (i.e., 100-year flood conditions), it could record flows of up to 120 m 3 /s. Flood events<br />

have been recorded in the past (e.g., 1992, 1994, 2005).<br />

The hydrodynamic conditions of the waters in <strong>Cartagena</strong> Bay are seasonal based on climate<br />

(winds) and currents. During the dry period, when the trade winds are intensified in a<br />

predominantly northeast direction and the Canal del Dique contribution decreases, a superficial<br />

flow to the south is observed, resulting in more fresh water at the South Bay and a deep current<br />

of compensation of mass from south to north. During the rainy season, the Canal del Dique<br />

flow reaches its peak, generating a surface stream to the north. The tide is semi-daily and<br />

micro-tidal, registering a magnitude of less than 0.5 m, and thus, its effect on hydrodynamic<br />

conditions of the Bay is less pronounced than those of the seasonal wind variations and the flow<br />

of the Canal del Dique. The waves within the interior of the Bay are a function of the wind


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pattern and are limited to the short distance available for its production, with heights between<br />

10 and 50 cm at the threshold of wind from 6 to 7 m/s.<br />

The main source of sediments in the <strong>Cartagena</strong> Bay is the Canal del Dique, with a seasonal flow<br />

estimated between 55 and 300 m 3 /s, with a sediment load of approximately 3,500,000 m 3 /year,<br />

and is mainly silt and clay with a small percentage of sand. The water quality of the <strong>Cartagena</strong><br />

Bay is affected by a number of natural and anthropogenic factors and other industrial sources,<br />

including sewage discharges from <strong>Cartagena</strong>; inputs of sediments, nutrients, and other<br />

contaminants by the Canal del Dique; discharges from Mamonal industries; operation of ships<br />

and port terminals; and several stream and direct runoffs into the Bay. The most recent<br />

significant tanker spill was in 2005, when the SAETTA ship spilled approximately 33 tons of<br />

fuel oil into the Bay.<br />

Bay water quality is generally considered poor because of elevated levels of fecal coliforms,<br />

biological oxygen demand (BOD), chemical oxygen demand (COD), ammonia nitrogen, and<br />

low dissolved oxygen. The water quality monitoring results suggest that the Bay is stratified<br />

into two layers. The upper layer is characterized by higher temperatures, pH, and dissolved<br />

oxygen content, and lower values of conductivity and salinity. The underlying water layer<br />

formed by the middle and deep stratum is characterized by higher salinity and lower<br />

temperature (higher density), pH, and oxygen content. Significant differences in water quality<br />

occur between the rainy and the dry season (e.g., decrease in surface temperature and a slight<br />

increase in pH; greater contribution of organic matter to the Bay; and resultant increases in<br />

BOD, COD, ammonia nitrogen, nitrate, and greases and oils; and a significant decline in<br />

dissolved oxygen and oxygen saturation). Historically, contaminated sediments have been<br />

found in the <strong>Cartagena</strong> Bay (e.g., concentrations of mercury, 0.05−0.77 µg/g; cadmium,<br />

0.15−1.44 µg/g; copper, 0.18−19.3 µg/g; iron, 160−1,444 μg/g; and aromatic hydrocarbons,<br />

0.58−400 µg/g). Because of water quality issues, fishing in the <strong>Cartagena</strong> Bay is restricted.<br />

However, there are some individual fishermen who fish mainly on the sides of Tierra Bomba<br />

and Baru (south and southwest quadrants of the <strong>Cartagena</strong> Bay).


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The aquifer in the area of the <strong>Cartagena</strong> refinery is reported as poor and influenced by saltwater<br />

intrusion. Thus, salinity in groundwater is high, which precludes the use of this groundwater for<br />

human consumption. Groundwater salinity levels in onsite monitoring wells have varied from<br />

9.21 to 0.76 masl (meters above sea level), and approximately between 4.8 and 0.66 m bgs<br />

(below ground surface; referred levels are not related to the same monitoring wells).<br />

Reportedly, the prevalent local groundwater flow direction is east to west, toward the Bay, with<br />

an estimated local maximum flow velocity of 0.227 m/day. The aquifer characteristics have an<br />

estimated capacity for usage of 4 L/sec, with a specific capacity of 0.15 L/sec/m.<br />

In terms of flora and fauna, the area being developed for the Project is within the existing<br />

refinery property. The specific vegetation present is mixed, with grass and trees growing in<br />

isolation or in groups of various sizes. Many of the species defoliate during intense drought<br />

periods as a mechanism of avoiding excessive water loss. As a result, the soils are almost bare<br />

and are exposed to the action of erosion. The vegetation develops rapidly during the rainy<br />

season (May–June and September–November). The vegetation consists of grasses (Panicum<br />

purpurascens), shrubs and trees (e.g., Guazuma ulmifolia species, Albizzia caribaea species,<br />

Hobo [Spondias Bombina], Uvita mocosa [Cordia dentata], Olla de mico [Lecythis minor],<br />

Mora [Chlorophora tinctoria], and Leucaena [Leucaena leucocephala]). The EIA estimates that<br />

approximately 464 m 3 of wood will need to be extracted for the Project. In the <strong>Cartagena</strong> Bay,<br />

there are some limited areas of mangroves but they have been affected significantly over time.<br />

A small area of mangroves is located on the portion of the Project site adjoining the Bay. The<br />

main fauna present are birds, which possess greater capacity and ease of movement and equally<br />

possess abundant food, and build shelter and nesting sites in trees. Additionally, small<br />

mammals and reptiles (snakes mainly) are present.<br />

4.2 Social Conditions<br />

4.2.1 District of <strong>Cartagena</strong><br />

The District of <strong>Cartagena</strong>, situated in northern <strong>Colombia</strong> on the Caribbean Sea, is the capital of<br />

the Bolivar Department and encompasses an area of approximately 6,091 km 2 .


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The 2005 census reports the population of <strong>Cartagena</strong> to be 895,400 inhabitants, with 845,801<br />

located in the municipal capital and 49,599 in rural areas. The age composition includes 35.7%<br />

of people younger than 17 years of age. From 1997 to 2003, the city of <strong>Cartagena</strong> was one of<br />

the main receivers of displaced population resulting from violence within <strong>Colombia</strong>. The<br />

location of these groups of displaced people, particularly in the Nelson Mandela community<br />

(located 9.5 km away from the Project), generates pressure on the urban structure of the city and<br />

the supply of public utilities. The majority of the population own the houses where they live, at<br />

both urban and rural levels (149,813 urban versus 88,359 rural). According to 2005 census data,<br />

the District of <strong>Cartagena</strong> has approximately 183,255 houses in urban areas and about 14,000<br />

houses in rural areas. There is apparently relatively high unemployment and under-employment<br />

in the <strong>Cartagena</strong> area.<br />

In general, the health infrastructure for the <strong>Cartagena</strong> area is deficient, both in prevention of and<br />

providing adequate attention to diseases. From 2001 to 2005, there was a marked increase in<br />

the number of reported cases of dengue fever in the District of <strong>Cartagena</strong> (from 4.3 to 25.33<br />

cases per 100,000 inhabitants). As a result of the efforts of the local government, the number of<br />

cases reported has been reduced to 3 to 6 per year 2 . <strong>Cartagena</strong> has a relatively extensive road<br />

network, and the main roads are paved. Many secondary roads are in poor condition and<br />

hamper access and public transportation.<br />

The District of <strong>Cartagena</strong> is divided both politically and administratively into three localities:<br />

� Locality 1, Histórica y del Caribe Norte (Historical and North Caribbean)<br />

� Locality 2, De la Virgen y Turística (De la Virgen and Tourist)<br />

� Locality 3, Industrial de la Bahia (Industrial by the Bay).<br />

These localities are divided into 15 Urban Government Community Units and 12 Rural<br />

Government Community Units.<br />

2 As per <strong>Reficar</strong> April 2011.


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The <strong>Refinery</strong> is located in Locality 3, the Industrial de la Bahía, and in Urban Government<br />

Community Unit #11.<br />

Locality 3, the Industrial de la Bahia, is located in the center of <strong>Cartagena</strong>’s Territory. It is an<br />

area of 8,933. 38 hectares and has a perimeter of 86.22 km. The Urban Government<br />

Community Units are #s 11, 12, 13, 14, and 15, and the Rural Government Community Units<br />

are Pasacaballos and Membrillal.<br />

Locality 3 has 64 neighborhoods, with a total population of approximately 346,883 and 55,865<br />

houses. Of these, 329,854 people and 53,102 houses are urban and 17,029 people and 2,763<br />

houses are rural.<br />

The majority of the habitants of Locality 3 are subsidized people with a total of 214,069<br />

(111,074 women and 102,995 men) classified by the <strong>Colombia</strong>n System of Selecting<br />

Beneficiaries for Social Programs (SISBEN) as Level 1 and Level 2 (people living in poverty).<br />

There are a total of 134 schools within this locality, 85 private and 49 public. There are also<br />

21 hospitals, 10 attending Level 1 cases and 11 attending Level 2 cases. There are 25 churches,<br />

4 universities, 57 sport fields, 1 fire station, and 5 police stations.


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4.2.2 Urban Government Community Unit #11<br />

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The population of Unit #11 is 33,043 with a total of 5,139 houses. There are 12 neighborhoods,<br />

10 schools, 3 churches, no universities, and 2 hospitals (Level 1). There are only 3 sports fields.<br />

Ninety-two percent of the people are on stratification Level 1 and the rest are on Level 2.<br />

The neighborhoods of Policarpa, Albornoz, Arroz Barato, Puerta de Hierro, El Libertador, Villa<br />

Barraza, Veinte de Julio Sur, and Antonio Jose de Sucre share the same social economic issues:<br />

78% of their population live in extreme poverty, there is no water and sewage, the roads are in<br />

very bad condition, their average income is less than one-third the minimum wage, which is<br />

equivalent to COP$190,000 (USD$105). The children have access to school but only 22% of<br />

them have the opportunity to go to a technical school or university. These communities have a<br />

high level of insecurity and homicide. 3<br />

4.2.3 Mamonal Industrial Area<br />

The Project is located in the Mamonal Industrial Area, which is considered one of the most<br />

important industrial areas in the country. According to the Logistical and Business Center of<br />

<strong>Cartagena</strong>, the number of companies in the Mamonal Industrial Area has increased by 50.4% in<br />

the last 4 years, growing from 113 to 170 companies in that time period. Mamonal’s enterprises<br />

(industrial, trade, and port services) are reported to generate about 5% of the country’s industrial<br />

GDP, over 15% of manufacturing exports of the country, and more than 40% of the GDP of<br />

<strong>Cartagena</strong>. They generate a total of approximately 34,000 direct formal jobs 4 . The key<br />

industrial sectors for the economy of <strong>Cartagena</strong> City are metalworking, petrochemicals and<br />

derivatives, food and beverages, tourism, engineering and civil, and electrical works.<br />

Specifically, oil refining represents 38.2%, and the petro-chemical cluster represents 42% of the<br />

total industrial production. For the rural sectors, the economy is based on agro-industrial and<br />

fishery developments. The port activities are a major economic sector for <strong>Cartagena</strong>.<br />

3 Supplemental information on local social conditions provided by <strong>Reficar</strong>.<br />

4 Update provided by <strong>Reficar</strong> April 2011.


There is 100% coverage of public service utilities in the Mamonal Industrial Area. The<br />

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aqueduct service is provided by the company Acuacar SA. The electrical energy service is<br />

supplied by Termocartagena and Proeléctrica, which provide the service to the municipality in<br />

general. The sanitary sewer service is also provided by Acuacar SA. Fixed telephone service is<br />

provided by Telecartagena–<strong>Colombia</strong>tel for local service and Telecom–Telefonica for long<br />

distance service. Cellular phone service is provided by three private companies.<br />

Principal issues identified by CARDIQUE that are related to the Mamonal Industrial Area<br />

include improper handling of industrial waste; restoration and maintenance of the wells and/or<br />

groundwater monitoring network in Mamonal’s area of influence; sewer infrastructure; work<br />

protection for areas prone to flooding; and inter-institutional actions to protect mangroves along<br />

the <strong>Cartagena</strong> Bay.<br />

4.2.4 Local Communities<br />

There are no communities within 2 km of the Project site, inside the Mamonal Industrial Area,<br />

(the Project’s Direct Area of Influence), and 26 communities identified within the Project’s<br />

Indirect Area of Influence (all but a few are in Urban Government Community Unit #11).<br />

Inhabitants in this area are estimated to number from 70,000 to 100,000 and include the islands<br />

located west of the industrial area, known as the Baru and Tierra Bomba islands.<br />

The area near the refinery includes some communities with high levels of poverty,<br />

unemployment, and a general lack of education. There are limited public services in these<br />

areas, in particular regarding health infrastructure, wastewater collection, road maintenance, and<br />

other services.<br />

While the 2009 EIA provided information on the socio-economic conditions for the District of<br />

<strong>Cartagena</strong>, it provided minimal information on these conditions in the local communities.<br />

<strong>Reficar</strong> provided Exponent with the following brief summary of the socio-economic conditions<br />

in the nine communities located closest to the Project and a map showing their locations:


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There are nine neighborhoods closest to the <strong>Refinery</strong> that belong to the Urban Government<br />

Community Unit #11 (Albornoz, Antonio José de Sucre, Arroz Barato, Bellavista, El<br />

Libertador, Policarpa, Puerta de Hierro, Veinte de Julio and Villa Barraza); and two rural<br />

communities (Membrillal and Pasacaballos).<br />

Neighborhood Name UCG LOC Population Total Housing<br />

Distance<br />

from Project<br />

(km)<br />

Albornoz 11 LI 1,220 233 5.1<br />

Antonio Jose de Sucre 11 LI 2,498 502 5.7<br />

Arroz Barato 11 LI 1,956 427 4.7<br />

Bellavista 11 LI 1,537 333 6.8<br />

El Libertador 11 LI 1,987 384 6.2<br />

Membrillal R LI 226 49 2.9<br />

Pasacaballos R LI 10,195 2,345 4.1<br />

Policarpa 11 LI 3,578 759 3.6<br />

Puerta de Hierro 11 LI 429 90 4.3<br />

Veinte de Julio Sur 11 LI 5,034 997 6.6<br />

Villa Barraza 11 LI 350 77 5.8


4.2.5 Cultural Heritage<br />

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<strong>Cartagena</strong> City is considered to be a historical and cultural heritage site. As part of the EIA,<br />

archaeological surveys were conducted in 123 areas, 11 of which showed archaeological<br />

evidence. Most of the evidence was located in a hilly area in the vicinity of Arroyo Grande. In<br />

general, evidence was found on the surface and without context. According to the results of<br />

field visits, two areas of archaeological potential can be defined: areas of high archaeological<br />

potential that correspond to hilly areas near the Arroyo Grande, and areas of low archeological<br />

potential.<br />

The archaeological team communicated with the residents of the area to establish the probability<br />

of archaeological findings; and held discussions with the local authorities to establish the<br />

municipality’s capacity of natural resources management.<br />

Laboratory work included the analysis and classification of archaeological material found in the<br />

field. First the collected material was subjected to a cleaning process. Later it was classified<br />

and included in an inventory to facilitate analysis. The ceramic material collected is composed<br />

of 66 fragments and 2 scraps of clay. It was found in the areas of soil borings 14, 16, 21, 22, 31,<br />

46, 47 48, 54, 75, and 79. Two surface colors were identified: red (47 pieces) and brown<br />

(19 pieces) (see figures and photos included in Section 3.4.5 of the EIA).


5 Environmental and Social Impacts<br />

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The Project EIA evaluation process considered the impacts generated during the construction<br />

and operation phases, and covered different environmental and social components within the<br />

Project’s area of influence. The EIA defines the area of direct environmental influence as the<br />

Project site property boundary and a 2-km radius. The area of indirect influence includes the<br />

Mamonal Industrial Area and the city of <strong>Cartagena</strong>. The potential negative environmental and<br />

social impacts due to Project construction and operation are presented in Sections 5.1 and 5.2,<br />

respectively. The associated mitigation measures and monitoring programs to address these<br />

impacts and risks are described in Section 6. Section 5.3 presents a summary of the principal<br />

environmental liabilities at the existing refinery. Section 5.4 highlights some of the Project’s<br />

main positive benefits.<br />

5.1 Construction<br />

The principal potential significant negative impacts during construction include vegetation<br />

clearing; decreased air quality due to dust generation and vehicle traffic; increased noise and<br />

vehicle traffic; and construction worker impacts (both on workers and nearby communities).<br />

Other potential impacts include liquid- and solid-waste management, displacement of fauna, soil<br />

and water contamination due to spills, and worker health and safety. With the exception of loss<br />

of vegetation, the impacts should be relatively localized, temporary, and reversible, and should<br />

be reasonably prevented or mitigated with standard/good practices. No significant impacts are<br />

anticipated related to natural habitats, indigenous populations, endangered or economically<br />

important flora or fauna, or cultural or archeological sites. The implementation of the Project<br />

will not require change in land use, nor will it require any resettlement.<br />

5.1.1 Site Clearing<br />

The construction involved the removal of the vegetation on approximately 58 hectares of land<br />

on the refinery site that was approved by the authorities (see Section 6). The vegetation present


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is mixed, with grass and trees growing in isolation or in groups of various sizes. It is estimated<br />

that approximately 500,000 m 3 of soil will be needed for site fill material, which is<br />

approximately the amount of material to be excavated during construction.<br />

The Arroyo Grande creek has been modified by creating a new stabilized channel that runs<br />

along the eastern and northern side of the refinery expansion area. The design was developed<br />

based on analysis of 48 years of rainfall data from the Rafael Nunez airport, <strong>Cartagena</strong> City.<br />

A maximum flow rate of 170 m 3 /s was determined for an extreme winter event with a return<br />

period of 100 years. The channel is trapezoidal in shape, with a base width of 20 m. Vegetation<br />

and trees will be planted along 20-m swaths on each side of the channel.<br />

5.1.2 Air Quality<br />

Potential adverse impacts to air quality could occur due to fugitive dust emissions resulting from<br />

earth moving, material handling, and other operations. <strong>Reficar</strong> is using water with a<br />

biodegradable additive to control these emissions. Fugitive dust emissions are expected to<br />

consist primarily of large particles that will fall out of the atmosphere within a relatively short<br />

distance of their point of emission. Fugitive dust emissions will be somewhat higher during the<br />

dry season. There will also be minor air pollutant emissions from mobile sources operating both<br />

onsite (e.g., bulldozers and other earth-moving equipment) and offsite (e.g., transporting<br />

materials and workers to the site). These emissions will consist of the products of combustion<br />

of diesel and gasoline fuels in earth-moving equipment, trucks, and cars. Air quality impacts<br />

will also occur during the initial testing/trial phase of new refinery units, which should be<br />

similar to those generated during the operation stage.<br />

5.1.3 Construction Workers<br />

An estimated 7,000 construction workers are needed (peak workforce) for the project. While<br />

the training and hiring of persons local to <strong>Cartagena</strong> is a top priority for both <strong>Reficar</strong> and CB&I,<br />

workers from outside the <strong>Cartagena</strong> area will be needed for Project construction. There are<br />

potential impacts on nearby residents and other workers in the Mamonal Industrial Area because


of increased traffic resulting from Project-related vehicle movement and transport of<br />

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construction workers, service providers, and refinery equipment. This could produce traffic<br />

congestion, accidents, and impacts on air quality and noise.<br />

There are also potential impacts due to a partially non-local construction workforce, specifically<br />

in terms of worker housing (e.g., adequate housing provided to workers, potential impacts of<br />

increased demand on local housing), social conflicts with local population, and increased<br />

demand on local social infrastructure. No worker camp will be constructed; all workers will be<br />

housed in <strong>Cartagena</strong>. At present, the plan regarding worker housing in the city has not been<br />

finalized. While plans are in place for the housing of Expat workers and workers from other<br />

<strong>Colombia</strong>n cities, the plan for housing workers from other countries in Latin America (the Other<br />

Country Nationalities or OCNs) is pending (for more details, see Section 6.2.2).<br />

5.2 Operation and Maintenance<br />

The principal potential significant negative impacts during operation include air emissions and<br />

resultant impacts on ambient air quality; wastewater discharges and resultant impacts on<br />

receiving-water quality; increased petroleum-based wastes and hazardous wastes; and potential<br />

risks due to spills and fires/explosions (see below for more details). Other but less significant<br />

impacts include increased noise due to operations, and increased non-hazardous waste<br />

generation. No significant impacts are anticipated related to critical natural habitats or cultural<br />

sites, indigenous populations, or endangered or economically important flora or fauna.<br />

5.2.1 Air Quality<br />

The primary air pollutant emissions from the refinery’s expanded operations will include coarse<br />

particulate matter (PM10), fine particulate matter (PM2.5), sulfur dioxide (SO2), nitrogen dioxide<br />

(NOx), carbon dioxide (CO2), heavy metals (e.g., vanadium [V], nickel [Ni], and others), and<br />

volatile organic compounds (VOCs). The Project is designed to meet the applicable emissions<br />

limits specified in the provisions of Resolution 909 of 2008.


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Air pollutant emissions will be subjected to various emissions controls. Emissions of PM10<br />

from the coker operations (cutting, transport, and storage) will be reduced by confining the<br />

coker unit within a perimeter wall. Transfer towers within the coke conveying system will be<br />

totally enclosed to the coke load-out area for storage. As mentioned previously, the final<br />

configuration of this facility is under consideration by <strong>Reficar</strong>’s Board of Directors. The final<br />

design will include coke handling procedures and equipment that meet the IFC EHS Guidelines<br />

for Petroleum Refining and the EHS General Guidelines. Emissions of PM10 from sulfur<br />

pelletization and storage operations will be reduced by the use of dust suppression equipment<br />

such as covered conveyors and spray systems.<br />

At the catalyst regeneration unit, particulate matter from coal combustion will be controlled<br />

through the use of a high-efficiency cyclone system that will reduce emissions by approximately<br />

76%.<br />

The refinery expansion will allow for the refining of higher sulfur crudes than are currently<br />

being processed at the refinery. To meet worldwide environmental limitations on the amount of<br />

sulfur that is allowed in modern fuels, the sulfur content must be reduced from certain fuel<br />

products. This will result in the production of more hydrogen sulfide gas (H2S). All H2S, as<br />

well as ammonia, will be sent to a new Claus unit, followed by a tail-gas treatment unit. Off<br />

gases (e.g., light fractions that could be emitted directly to the atmosphere) will be collected and<br />

used as fuel gas in the refinery. The use of fuel gas is expected to result in a decrease in<br />

emissions to the atmosphere, because it will replace the fuel oil currently used in the refinery.<br />

Low-NOx burners will be used on all burners.<br />

As part of the EIA, air quality dispersion modeling was performed using the Industrial Source<br />

Complex Short-Term (ISCST3) model, Version 3, with 2 years of meteorological data. The<br />

ISCST3 was approved by U.S. EPA as a “preferred model” until 2005. In late 2005, the newer,<br />

more sophisticated AERMOD model was designated as U.S. EPA’s “preferred model.” The<br />

ISCST3 was re-designated as an “alternative model” for use in certain situations, with agency<br />

approval. Air quality modeling was conducted both for the Project-only scenario (emissions<br />

from current and future scenario) and for a cumulative impact scenario (emissions from the<br />

existing sources in the Mamonal Industrial Area and for emissions from the <strong>Cartagena</strong> refinery).


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Three pollutants were modeled: PM10, SO2, and NO2. The results of the air quality modeling<br />

are summarized below; however there are various issues with the air quality modeling (see<br />

Section 8.1 for details) and thus the results should be interpreted in this context. The results of<br />

the Project-only modeling are presented in Table 5. These results show that the operational<br />

ambient air quality impacts due to emissions from the <strong>Cartagena</strong> refinery (as proposed) will<br />

decrease by approximately 75% for PM10, stay approximately the same for SO2, and increase by<br />

200% or more for NO2, when compared to the impacts of the current <strong>Cartagena</strong> <strong>Refinery</strong>.<br />

While there is a substantial increase in ambient NO2 impacts, the modeling results show that the<br />

<strong>Reficar</strong> Project will not, by itself, cause any exceedance of the permissible limits under<br />

Resolution 601. Even if the ambient baseline values monitored in the vicinity of the refinery<br />

were to be added to the predicted concentrations shown below, there would be no exceedances<br />

of permissible limits.<br />

All of the maximum predicted impacts due to emissions from the refinery alone (as proposed)<br />

occur to the south of the refinery, within 2 km. For the existing situation, the maximum ambient<br />

NO2 impacts occur at 2.4 and 3.5 km for the 24-hour and annual periods, respectively. All other<br />

impacts for the existing situation are within 2 km of the refinery. PM10 is measured as part of<br />

the monitoring that is required by the operation of the existing refinery.<br />

Emissions from current and future non-refinery operations in the Mamonal Industrial Area were<br />

also modeled to predict maximum ambient PM10, SO2, and NO2 impacts. These impacts do not<br />

change between current and future scenarios, because there is no change in emissions assumed<br />

for these non-refinery sources, with the exception of annual NOx values (see Table 6). It must<br />

be noted that, these modeled conditions show the Mamonal Industrial Area to be in a degraded<br />

state. The new <strong>Reficar</strong> refinery will have improved air quality control equipment and will lower<br />

or maintain air emission concentrations (excluding NO2 ) causing no estimated negative impacts<br />

on the air quality of the Mamonal Industrial Area (Table 6).<br />

The maximum estimated impacts associated with non-refinery emissions sources are not<br />

coincident with the maximum impacts from the <strong>Cartagena</strong> refinery emissions. With the<br />

exception of the SO2 annual standard, all of these predictions are substantially above the<br />

associated standard, and are also substantially above the ambient values monitored in the


vicinity of the existing refinery. It is impossible to reconcile these discrepancies without<br />

1101335.000 04F1 0611 MJ21<br />

41<br />

June 21, 2011<br />

additional information concerning the basis for emissions calculations for the Mamonal sources.<br />

It is also impossible to confirm whether the cumulative predicted impacts from the refinery and<br />

other sources in the Mamonal Industrial Area together would exceed applicable permissible<br />

standards without having modeled all sources together.<br />

There is no assessment of the impact of existing or proposed scenarios on ambient air pollutant<br />

concentrations for pollutants other than PM10, SO2, and NO2. Thus, it is impossible to<br />

determine whether or not the Project will create an issue with ozone, CO, heavy metals, or other<br />

pollutants (e.g., VOCs). The EIA also does not address the effect of the Project on greenhouse<br />

gas (GHG) emissions or global climate; however, an IDB study apparently estimated GHG<br />

emissions of approximately 100,000 tons/year. The modeling also does not address potential<br />

fugitive emissions of PM10 (e.g., coke and sulfur transfer) or VOCs (e.g., vents, floating roof<br />

storage tanks, pressure relief valves, and loading and unloading of raw materials [crude] or<br />

product).<br />

Air dispersion modeling for the Site will be performed to predict the maximum ground level<br />

concentration (GLCmax) of nitrogen oxides (NOX), sulfur dioxide (SO2), carbon monoxide (CO),<br />

and particulate matter (PM10) from the expanded refinery within and around the refinery fence<br />

line. The baseline emissions from current refinery operations plus the surrounding industrial<br />

facilities will be established by conducting real-time ambient air sampling with the refinery<br />

fence line, as well as at critical receptor locations (such as Membrillal, a restaurant,<br />

Pasacaballos) around the refinery fence line.<br />

New plant modifications will result in a reduction of air emissions from the new refinery and no<br />

net impact to the Mamonal Industrial Area airshed. NO2 total load will increase but the<br />

permissible limits will be met (Resolution 601, 2006, Tables 5 and 6). Confirmational air<br />

sampling and dispersion modeling will be performed at the Site to establish a baseline. This<br />

modeling program is designed to meet the issues listed in Table 7, using the following<br />

protocols:


� Selection of the appropriate modeling tool<br />

� Establishing baseline with actual sampling<br />

� Developing a receptor grid from the fence line to 2 km at 100 m spacing and<br />

1101335.000 04F1 0611 MJ21<br />

from 2 km to 5 km at 500 m spacing<br />

� Developing a modeling protocol for approval<br />

� Building appropriate model input files for NOX, SO2, and PM10<br />

� Developing a model output in a graphical and report presentation.<br />

42<br />

June 21, 2011<br />

<strong>Reficar</strong> has prepared the <strong>Cartagena</strong> <strong>Refinery</strong> <strong>Expansion</strong> Project, Air Dispersion Modeling Scope<br />

of Work. This request for proposal provides the guidelines for a consultant to provide this air<br />

quality impact consulting, and the contractor will be selected once the lenders accept the<br />

proposed methodology for air sampling. The detailed engineering has begun and it is scheduled<br />

to be completed by year-end. The modeling program may begin once the detailed engineering<br />

is completed, and the program will be completed prior to commencement of the operations<br />

period. Exponent received a copy of the proposal and confirms that it is in compliance with the<br />

recommendations included in Table 7.<br />

5.2.2 Water and Wastewater<br />

The estimated water consumption for the Project will be 28,200 m 3 /day, with approximately<br />

142 m 3 /day used by workers.<br />

The current refinery wastewater treatment system will be replaced by an entirely new treatment<br />

plant, for industrial and domestic wastewater. There is some potential for keeping portions of<br />

the existing system for use in emergencies such as spills, excessive rains, or maintenance. The<br />

following is a description of the proposed wastewater treatment system as presented in the<br />

Project EIA; however, the Project design has been re-evaluated, to reduce the quantity of water<br />

usage and also to ensure compliance with all applicable requirements (in particular, phenol<br />

limits):


� Primary treatment, including oil removal (e.g., API separators) and storage,<br />

1101335.000 04F1 0611 MJ21<br />

equalization, neutralization, coagulation, flocculation, and fluidized aeration<br />

(DAF)<br />

� Secondary treatment, including denitrification, oxidation-reduction, final<br />

clarification<br />

� Tertiary treatment, including disinfection, filtration (sand and carbon)<br />

� Sludge treatment.<br />

43<br />

June 21, 2011<br />

The system described in the EIA is being replaced by a Siemens designed system. Siemens’s<br />

technical proposal to supply raw water and wastewater treatment equipment and services, which<br />

includes two process performance guarantees to meet IFC guidelines for effluent criteria, and<br />

covers all above-mentioned wastewater impacts, was accepted by <strong>Reficar</strong> under their Purchase<br />

Order No. 42166001-PO-1311154001 dated March 23, 2011 (the Purchase Order). Siemens<br />

will provide the basic engineering and the major equipment, and construction will be performed<br />

by CB&I.<br />

The process performance guarantees are in the form of make good warranties up to a limit of<br />

1) US$10.0 million for impaired performance of the wastewater treatment system and<br />

2) US$2.295 million for impaired performance of the raw water treatment system, for failure of<br />

the systems to achieve the guarantees in accordance with the terms and conditions of the<br />

guarantees as set forth in the Purchase Order. The process performance guarantees may be<br />

drawn once the plant is constructed and confirmatory sampling has taken place (see Table 8).<br />

In addition to the process performance guarantees, Siemens will provide an Irrevocable Standby<br />

Letter of Credit (Standby L/C) in favor of <strong>Reficar</strong> in an amount equal to 15% of the Purchase<br />

Order price (US$35.31 million). Such Standby L/C shall be opened as condition precedent to<br />

the first milestone payment and shall remain in full force and effect until full delivery of the<br />

goods under the Purchase Order to <strong>Reficar</strong>, at which time such Standby L/C shall be reduced to<br />

an amount equal to 5% of the Purchase Order price. The reduced Standby L/C shall remain in<br />

full force and effect until the expiry of the Base Warranty Period.


1101335.000 04F1 0611 MJ21<br />

44<br />

June 21, 2011<br />

The new Siemens wastewater treament plant design flow is 2,150 gpm or 488 m 3 /h (maximum<br />

flow of 4,500 gpm or 1,022 m 3 /h). The EIA estimated total wastewater to be treated is<br />

approximately 440 m 3 /h (dry season) and 660 m 3 /h (wet season), and the resultant wastewater<br />

discharge is 436.2 m 3 /h (dry season) and 652 m 3 /h (wet season). There is an estimated 0.7 to<br />

1.4 m 3 /h of oily and biological sludge produced (dry and wet season). The EIA stated that<br />

concentrations in the discharges are 5 mg/L suspended solids, 5 mg/L oil and grease, 115 mg/L<br />

COD, 25 mg/L BOD, 10 mg/L total nitrogen, and 0.2 mg/L phenol. These conditions<br />

approximate the new wastewater treatment system criteria (see Table 8); see Section 6.1 for<br />

further details on the new Siemens system (the major components of the system are shown on<br />

Figure 5).<br />

The EIA conducted mathematical modeling of refinery discharges using the model “CODEGO,”<br />

which is based on a Lagrangian-eulereana methodology and was developed specifically for<br />

<strong>Cartagena</strong> Bay. The EIA states the model has been used for other studies, including EIAs,<br />

associated with the Bay. The modeling included the following inputs: discharge 436.2 m 3 /h,<br />

phenol 0.2 mg/L, sulfate 1 mg/L, total nitrogen 10 mg/L, and oil and grease 10 mg/L. Oil and<br />

grease and nitrogen were modeled as non-conservative elements (i.e., degrading), and phenol<br />

and sulfate as conservative elements (i.e., non-degrading). The model used a 60-m grid across<br />

the Bay and considered the following: movement caused by wind; freshwater input from the<br />

Canal de Dique channel and subsequent stratification (due to density differences); thermal<br />

stratification in the water column from the Bay; tide fluctuations and the exchange of water with<br />

the open sea; bottom relief; and thermohaline pattern in the adjacent waters of the sea. Eight<br />

modeling scenarios were used to simulate the conditions in the Bay throughout the year.<br />

On the basis of the modeling the EIA concluded that discharges showed a common pattern, with<br />

a flow direction along the coast, north or south of the Bay, and the areas with concentrations<br />

comparable to the source. The direction of the wind was a significant factor—with NNE or N<br />

winds (more frequent situation), the substances are dispersed to the south and across the Bay,<br />

while all other scenarios had the concentration plume move north along the Bay coastline. The<br />

ranges of simulated concentrations were: oil and grease 0.036−0.46 mg/L, phenol 0.00075−<br />

0.0085 mg/L, sulfate 0.0036−0.044 mg/L, and nitrogen 0.032−0.4 mg/L.


5.2.3 Waste Generation<br />

Table 9 presents a summary of the principal wastes to be generated during the refinery<br />

1101335.000 04F1 0611 MJ21<br />

45<br />

June 21, 2011<br />

expansion operation, and associated estimated quantities and proposed waste treatment/disposal.<br />

A temporary onsite waste-drum storage area exists at the present refinery.<br />

The main hazardous waste stream generated by the refinery will consist of:<br />

� Oily sludge and sediments from storage tanks, sludge from the plant, material<br />

from the filter beds of the treatment units of finished products, and spills<br />

sludge<br />

� Used oil and grease<br />

� Oil-impregnated materials, such as gloves, rags, containers, insulation, and<br />

scrap metal.<br />

The main non-hazardous waste to be generated by the plants will be:<br />

� Catalyst extracted from the internal regeneration unit (free of hydrocarbons),<br />

other than the alkylation unit, according to the classification of the Basel<br />

Convention, adopted by <strong>Colombia</strong> under Act 253 of 1996 (B1120 – spent<br />

catalysts with transition metals, B1130 – clean spent catalyst containing<br />

precious metals, and B2060 – activated carbon free of hazardous substances)<br />

� Recyclable material not contaminated by hazardous substances<br />

� Food residue from the cafeteria<br />

� Sludge from the wastewater treatment plant—sludge from the API separator,<br />

the unity of aeration (DAF), and the biological treatment.


5.2.4 Risks<br />

As part of the EIA, a risk analysis was performed to identify the potential risk events and<br />

1101335.000 04F1 0611 MJ21<br />

46<br />

June 21, 2011<br />

estimate the magnitude of their associated effects. The risk analysis considered the following<br />

principal factors: internal or controllable factors (staff training, etc.), external or non-<br />

controllable factors (e.g., weather, etc.), operations types, and hazard and compatibility of<br />

chemical substances. The results identified the following as principal risks:<br />

� Leaks of liquid hydrocarbons from joints or cracks in pipelines and tanks<br />

� Leaks of gas hydrocarbons, hydrogen sulfide, ammonia, or hydrogen from<br />

joints or cracks in pipelines and tanks<br />

� Fracture of equipment due to failure in the process instrumentation<br />

(temperature control, pressure, chemical dosage).<br />

� Excessive noise generation<br />

� Chemical spill<br />

� Accidental chlorine or ammonia emissions or fires from neighboring plants<br />

� Natural phenomena<br />

� Fire in non-confined spaces<br />

� Fire in a roof tank<br />

� Fire in a tank with light/white products<br />

� Spill of heavy product in a pipeline<br />

� Spill of light product in a pipeline<br />

� Spill of heavy product in sea water<br />

� Spill of light product in sea water


� Spill of heavy and light product on soil<br />

� Leak/release of LPG in tanks or cisterns.<br />

1101335.000 04F1 0611 MJ21<br />

47<br />

June 21, 2011<br />

The risk analysis performed mathematical modeling to assess the potential impact of a liquid<br />

spill/release into <strong>Cartagena</strong> Bay. The results indicated that the substances do not accumulate in<br />

the area because of the hydrodynamic factors of transport and dispersion, and that oil spills in<br />

the vicinity of the <strong>Cartagena</strong> <strong>Refinery</strong> show a tendency to move in line with the direction and<br />

intensity of the winds.<br />

5.3 Liabilities<br />

Potential environmental liabilities associated with the existing refinery were assessed by a<br />

Phase 1 and 2 environmental site assessment (ESA).<br />

5.3.1 Phase 1 ESA for the Existing <strong>Refinery</strong><br />

A Phase 1 ESA of the existing refinery was performed by URS in March 2007. The objective<br />

was to establish a baseline of the existing liabilities at the <strong>Cartagena</strong> <strong>Refinery</strong>, and included<br />

compliance with applicable local EHS regulations, corporate directives, international guidelines,<br />

accepted protocols, best management practices, and permitting requirements, as well as<br />

identifying potential areas of concern and developing order-of-magnitude cost estimates for<br />

recommended corrective actions. The assessment was performed in general accordance with<br />

ASTM E1527 (Standard Practice for Environmental Site Assessments).<br />

The principal liabilities identified included:<br />

� Environmental: Wastewater discharges into the <strong>Cartagena</strong> Bay from the<br />

WWTP exceed the <strong>Colombia</strong>n environmental standard for phenol;<br />

groundwater at the site is affected by free product and dissolved product,<br />

especially in the areas near the 3040, 3050, 3060, and 3500 series tanks, and


1101335.000 04F1 0611 MJ21<br />

around the polymerization and cracking units; and additional impacts are<br />

likely to be occurring from other, unidentified sources.<br />

� Operations and Maintenance: Lack of proper secondary containment for<br />

tanks, and substandard piping integrity.<br />

� Health and Safety: Lack of a structured process safety management<br />

program, training deficiencies, incomplete accident investigations (root<br />

causes of accidents not addressed), poor knowledge of chemical hazards and<br />

deficient hazard communication, unreliable fire alarm system with potential<br />

delayed response to an emergency, inadequate worker medical surveillance,<br />

missing or degraded warning signs and visual aids.<br />

(See Section 8.1.3 for the current status of the above-mentioned principal liabilities).<br />

48<br />

June 21, 2011<br />

The reported estimated probable liability/remedial costs, which will be paid by Ecopetrol, were:<br />

environmental–US$19.277 million, operation and maintenance–US$21.350 million, and health<br />

and safety–US$0.185 million.<br />

The Phase 1 assessment reported the following significant sources of air emissions: Steam<br />

Generation Plant (Area 24, five boilers); Crude Processing Plant (Area 23.1/23.2, four<br />

furnaces); Catalytic Cracking Unit (one stack); Visbreaker Unit (one heater); Sulfur Recovery<br />

Unit (SRU) (one stack); two process flares (one in the southwest portion of the refinery near the<br />

wastewater treatment system [WWTS]) and one in the south portion of the refinery near the<br />

tankfarm area 3000); and fugitive hydrocarbon sources, including storage tanks, valves, flanges,<br />

pump/compressor seals, and the WWTS area. These sources were reported to produce air<br />

emissions of criteria pollutants, which include SO2, NO2, CO, PM, and VOCs. In addition,<br />

toxic air contaminants such as benzene are also emitted by some of these sources. The heaters,<br />

boilers, and furnaces utilize either natural gas and/or refinery fuel gas and are major emitters of<br />

SO2, NO2, CO, PM, and VOCs. The Catalytic Cracking Unit is a process source of SO2, NO2,<br />

PM, CO, and VOCs. The SRU is a significant source of SO2 emissions. The flares are<br />

significant sources of SO2, NO2, and PM. The storage tanks, valves, flanges, pump/compressor<br />

seals, and the WWTS are significant sources of VOCs and toxic air contaminant emissions.


5.3.2 Phase 2 ESA for the Existing <strong>Refinery</strong><br />

A Phase 2 ESA was performed by URS during the period between November 12 and<br />

1101335.000 04F1 0611 MJ21<br />

49<br />

June 21, 2011<br />

December 5, 2007. The objective of the Phase 2 investigation was to carry out an evaluation of<br />

the general baseline conditions at the site, with regard to the quality of effluents, groundwater,<br />

soils, air, and emissions. The study focused on identifying significant environmental impacts<br />

potentially present at the site, defined as those environmental impacts that could involve<br />

liabilities with a potential economic impact equal to or greater than $US1.0 million.<br />

Some key results included:<br />

� Concentrations of total recoverable phenols fluctuated in the period between<br />

November 21 and 26, 2007, between 1,030 and 693 μg/L at the point of<br />

discharge into the Bay.<br />

� Three wells (PM10, PM11, and PM26) had observed free product. This freeproduct<br />

contamination has apparently been detected since approximately<br />

1998. The thickness has apparently varied over time, between 0.12 and more<br />

than 2.0 m. The free-product thicknesses measured in November 2007 in<br />

these wells were 0.23, 0.62, and 0.13 m, respectively.<br />

� The salinity of the groundwater, as defined by electrical conductivity,<br />

definitively excludes the use of this water for human consumption, unless salt<br />

removal technologies are applied.<br />

� Groundwater contamination in the sampled monitoring well network showed<br />

relatively minimal presence of TPH, oil and grease, SVOCs, and VOCs, with<br />

the exception of some presence in wells PM35, PMSN, PM13, PM5, and<br />

PM12. The presence of mercury at a concentration slightly above the<br />

<strong>Colombia</strong>n standard was noted in well PM8.<br />

� In terms of soil contamination, none of the samples had measured levels of<br />

TPH, VOCs, SVOCs, or heavy metals that exceeded the Dutch Intervention<br />

Levels.


� No remains of contaminated-waste burial sites were found at the sites<br />

1101335.000 04F1 0611 MJ21<br />

investigated.<br />

� The results of limited air emission monitoring showed:<br />

� Elevated SO2 emissions from the sulfur plant (average value above<br />

11,400 mg/m 3 )<br />

� Elevated CO emissions from the sulfur recovery plant (over<br />

4,500 mg/m 3 )<br />

� SO2 emissions from the Visbreaker and Crude Plants below<br />

500 mg/m 3<br />

� Emissions of NOx found at the monitored stacks, between 7.7 and<br />

74.3 mg/m 3<br />

� Crude-oil refining plant emissions of CO of 648 mg/m 3 .<br />

� Based on a mass balance calculation, a total of approximately 0.6 metric tons<br />

of sulfur is burned every day, resulting in an emission of 1.2 tons of H2S per<br />

day, or 50 kg/hour, from the flare.<br />

� Ambient air quality sampling at 10 sites within the refinery property showed<br />

no elevated levels of TSP, PM10, NOx, SO2, CO, V, or volatile hydrocarbons.<br />

None of the detected concentrations of aromatic compounds were above<br />

values considered critical, based on the maximum permitted workplace<br />

exposure limits (PELs) during an 8-hour day.<br />

� None of the containment areas for tanks is paved, and they only have clay<br />

and clayey sand floors. Many dike crests showed evidence of wear and<br />

material loss.<br />

� Other potential issues include integrity problems with the industrial<br />

wastewater pipe system and also the raw material and product pipelines.<br />

50<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

51<br />

June 21, 2011<br />

The following are the Phase 2 ESA “probable” estimated costs to resolve identified liabilities:<br />

� US$17.875 million to comply with the phenol limit (0.2 mg/L) in the WWTP<br />

wastewater discharge<br />

� US$1,583 million to address free product and groundwater contamination<br />

� US$0.5 million to address soil contamination<br />

� US$1.563 million to address air emission issues<br />

� US$8.975 million to address secondary tank containment issues<br />

� US$0.7 million to address wastewater pipeline integrity issues<br />

� US$12.500 million to address raw material and product pipeline integrity<br />

issues.<br />

5.3.3 Health and Safety<br />

In January 2011, the Project reached 5.5 million man hours (MMH) worked with no lost time.<br />

The existing refinery operation had measured lost-time frequency rates of around 2 to 2.5<br />

accidents per MMH worked for 2006 to 2008. This is lower than the rates measured during<br />

2002 to 2004 (i.e., 7 to 9.5). The accident frequency rate has decreased similarly, from<br />

approximately 12.5 accidents per MMH in 2004 to 1 accident per MMH in 2008.<br />

5.4 Positive Impacts<br />

With this Project complete, <strong>Colombia</strong> will be able to meet the current demand for diversified<br />

derivate products and that will be in demand in the future. The refining capacity in<br />

Barrancabermeja, <strong>Cartagena</strong>, and the small refineries in the interior of the country is<br />

approximately 312,000 bpd, and the crude oil transformation is 305,000 bpd. The <strong>Cartagena</strong><br />

refinery represents 23% of the capacity and currently consumes 80,000 bpd, and the expansion


1101335.000 04F1 0611 MJ21<br />

52<br />

June 21, 2011<br />

Project will bring 165,000 bpd. Therefore, the refinery growth will be 106% and will produce a<br />

42% participation in the national total, and will help improve <strong>Colombia</strong>’s energy security.<br />

The refinery expansion will result in the production of cleaner fuels (gasoline and diesel) that<br />

will comply with local and international standards, and thus assist in reducing air pollution<br />

resulting from vehicles.<br />

5.4.1 Craft Training, Jobs, and Increased Tax Revenue<br />

The Project will generate approximately 10,781 direct construction jobs (plus additional indirect<br />

jobs) and will contribute increased taxes to the city of <strong>Cartagena</strong>.<br />

The projected positive impacts on workers and the city of <strong>Cartagena</strong> are as follows:<br />

� Craft Training<br />

� All potential workers are given assessment tests and most go through<br />

one of the craft training programs before being hired for the Project;<br />

1,654 people have been trained (as of January 2011)<br />

� Through its two craft training programs, <strong>Reficar</strong> will increase at least<br />

3,900 people’s skill sets by the end of the construction phase of the<br />

project.<br />

� Employment<br />

� <strong>Reficar</strong> and CB&I have policies to maximize local hiring during the<br />

construction phase; 87% of non-skilled workers are from <strong>Cartagena</strong><br />

(as of January 2011)<br />

� <strong>Reficar</strong> estimates that at least 70% of the people who go through their<br />

craft training programs will be hired by the project, approximately<br />

2,700 people<br />

� Another 4,200 skilled and non-skilled people will be hired (craft,<br />

supervisors, helpers) in addition to the trained new hires


1101335.000 04F1 0611 MJ21<br />

� The people hired will be earning an average salary of US$1, 200 per<br />

month<br />

� Each person hired impacts at least 5 more, since the average family in<br />

<strong>Cartagena</strong> is 5.6 persons. 5<br />

� Service Contracts<br />

� <strong>Reficar</strong> has a plan to contract members of the local communities to<br />

sew workers’ uniforms and to provide some food services. The small<br />

local communities will not be able to supply the large quantities of<br />

uniforms and food needed by the Project to support over 5,000<br />

workers during the construction phase on a sustainable basis. <strong>Reficar</strong><br />

will start with some small contracts and increase them as the<br />

communities demonstrate their ability to perform.<br />

Below, is a brief summary of worker-related positive impacts:<br />

Impact People Amount<br />

Improving skill level of people 3,900<br />

Approximate total people hired 6,900<br />

Monthly income per person US$1,200<br />

Total people impacted 34,500<br />

Total population 980,000 approx.<br />

Impact on total population 3.52%<br />

Total local purchases (direct) US$658 million<br />

Industry and commerce tax<br />

contribution to the city that will be<br />

reinvested<br />

5.4.2 Corporate Social Responsibility<br />

53<br />

US$4.61 million<br />

June 21, 2011<br />

<strong>Reficar</strong> has developed a Corporate Social Responsibility Program that includes government-<br />

related actions (e.g., institution strengthening, strategic alliances, participation in decision-<br />

5 As per <strong>Reficar</strong> April 2011


1101335.000 04F1 0611 MJ21<br />

54<br />

June 21, 2011<br />

making process), direct actions, associated actions with local foundations (Fundacíon Mamonal<br />

and Corporacíon Acción por Bolivar (ACTUAR) (e.g., health, education, housing, economic<br />

opportunities, sports, culture), and communication (see Table 10). Amount spent to date on<br />

Social Programs is US$6.5 million.<br />

Projected amount to be spent on social investment/responsibility<br />

Year USD (million) Year USD (million)<br />

2011 2.06 2021 1.07<br />

2012 2.16 2022 1.12<br />

2013 0.72 2023 1.18<br />

2014 0.76 2024 1.24<br />

2015 0.80 2025 1.30<br />

2016 0.84 2026 1.36<br />

2017 0.88 2027 1.43<br />

2018 0.92 2028 1.50<br />

2019 0.97 2029 1.58<br />

2020 1.02 2030 1.66


6 Environmental, Social, and Health and Safety<br />

Management<br />

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55<br />

June 21, 2011<br />

The environmental, social, and health and safety management for the Project is based on three<br />

main components:<br />

� Environmental and social mitigation and monitoring plans for the Project<br />

(refinery expansion) construction and operation, as specified in the Project<br />

EIA (see Section 6.1)<br />

� Environmental, and health and safety mitigation and monitoring measures for<br />

the Project construction, per the EPC contractor (CB&I) systems developed<br />

for this Project (see Section 6.2)<br />

� Environmental, and health and safety systems and related plans for the<br />

existing refinery operations (see Section 6.3).<br />

6.1 Project EIA Environmental and Social Management Plan<br />

The Project EIA includes an Environmental and Social Management Plan (ESMP) that<br />

combines individual measures and actions designed for prevention, control, and mitigation of<br />

identified impacts. The ESMP is based on the following basic concepts:<br />

� Compliance with existing legislation<br />

� Integration of environmental, safety, and industrial hygiene management<br />

� Prevention as the first means of EHS management<br />

� Minimization of waste generation at the source<br />

� Saving energy and resources<br />

� Development of operational procedures for managing environmental, safety,<br />

and industrial hygiene


� Monitoring and recording of incidents and accidents involving<br />

1101335.000 04F1 0611 MJ21<br />

environmental, safety, and industrial hygiene<br />

� Education and training at all levels of the organization regarding EHS<br />

management.<br />

The framework for the ESMP includes:<br />

� Environmental impact assessments<br />

� Risk analysis<br />

� Environmental management plans<br />

� Social management plans<br />

� Contingency plans<br />

� Technical operating regulations<br />

� Industrial safety and health procedures<br />

� EHS audits.<br />

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June 21, 2011<br />

The Project EIA ESMP was revised by <strong>Reficar</strong> in April 2010 (the Revised ESMP) and now<br />

includes individual plans and programs, including 21 for Project construction mitigation, 17 for<br />

Project operation mitigation, and 12 for Project monitoring and supervision. Each of these<br />

includes: overall objective, specific objective, Project stage, impacts to respond to, type of<br />

measure to implement, applicability location, benefited population, activities to conduct,<br />

management and performance indicators, responsible for execution, responsible for control,<br />

schedule of activities, and cost of execution.<br />

Some of the key measures to mitigate environmental impacts during operations include:<br />

� An ambient air quality monitoring program is included in <strong>Reficar</strong>’s ESMP.<br />

Air dispersion modeling for the Site will be performed to predict the


1101335.000 04F1 0611 MJ21<br />

maximum ground level concentration (GLCmax) of nitrogen oxides (NOX),<br />

sulfur dioxide (SO2), carbon monoxide (CO), and particulate matter (PM10)<br />

from the expanded refinery within and around the refinery fence line. The<br />

baseline emissions from current refinery operations plus the surrounding<br />

industrial facilities will be established by conducting real-time ambient air<br />

sampling within the refinery fence line, as well as at critical receptor<br />

locations (such as Membrillal, a restaurant, and/or Pasacaballos) around the<br />

refinery fence line (see Section 5.2.1).<br />

� High efficiency cyclone equipment will be installed at the output of the<br />

Cracking unit combustion gases from the regenerator stack to reduce the<br />

concentration of fine particles of the catalyst.<br />

� The final design of the new coke storage and loading facility is under<br />

consideration by <strong>Reficar</strong>’s Board of Directors at this time. While <strong>Reficar</strong> had<br />

the Port EIA prepared in 2010 and the permit to construct and operate Port<br />

facilities were added to the license (Res. 511–Mar 2010), its Board of<br />

Directors has recommended that <strong>Reficar</strong> evaluate the alternative of not<br />

building the marine terminal and instead constructing only stand-alone truck<br />

facilities for the export of the coke, which may be shipped by truck to two<br />

existing ports nearby. <strong>Reficar</strong> plans to complete its evaluation of the two<br />

shipping options as soon as possible.<br />

� Hydrogen sulfide that did not react in the process will be sent to a tail gas<br />

treatment system (one system for each sulfur plant), along with ammonia<br />

from the sour water striping units. The storage tank of liquid sulfur will have<br />

a venting system for gases (mainly H2S and SO2).<br />

� Process gas of the refining units, with significant concentration of hydrogen<br />

and lighter fractions, will be used as domestic fuel gas in the refinery. The<br />

acid gas containing hydrogen sulfide is mainly produced in the FCC unit,<br />

coking, naphtha hydrodesulphurization (USLD1/2), hydrocracking (HDC),<br />

naphtha hydrotreatment (CDTech ® ), and hydrogen purification (PSA). The<br />

57<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

acid gas phase will be purified by adsorption in a monoethanolamine (MEA)<br />

or diethanolamine (DEA) solution in the amine plant which will separate the<br />

sulfide from the hydrogen (acid gas). The purified acid gas will be sent to<br />

sulfur plants where it will be oxided by catalization according to the Clauss<br />

process. This process will obtain liquid sulfur (and solid if necessary) which<br />

is one of the finished sub-products of the <strong>Cartagena</strong> <strong>Refinery</strong>. The sulfur<br />

plants will also receive the acid gas from the stripping bitter waters units.<br />

� Part of the nitrogen content in crude oil will be removed in the refining<br />

process. Ammonia will be removed by stripping the bitter waters and will be<br />

sent to sulfur plants. It will be incinerated in the gas tail treatment system<br />

each plant, along with the hydrogen sulfide that did not react.<br />

� The hydrogen fluoride gas will be used as a catalyst for the alkylation<br />

reaction. It will be regenerated and recycled in two stages, which will<br />

prevent its release into the atmosphere.<br />

� The FCC catalyst regeneration unit will carry out the controlled thermal<br />

oxidation of coke formed in the catalyst. As part of the modernization, it will<br />

be equipped with an additional high-efficiency cyclone system.<br />

� If required, air compressors and boiler silencers will have concrete walls to<br />

minimize the potential noise.<br />

� All effluent from the refinery will be treated in a wastewater treatment<br />

system, which will replace the existing wastewater treatment plant. The new<br />

system (as described in the Siemens proposed wastewater treatment plant<br />

proposal) consists of:<br />

� Process Water Diversion Chamber: Nitrogen blanked system that<br />

collects the existing desalter brine, oily water from the existing oily<br />

water sewer, storm water from the existing storm water pond, oily<br />

water from the tanker truck, excess oily water from the excess oily<br />

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June 21, 2011


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water storage system, cooling tower blowdown, and new process<br />

sewer<br />

� API Separator System: Primary treatment, oily water storage,<br />

removal of oil to American Petroleum Institute standards (API<br />

Publication 421)<br />

� Dissolved Nitrogen Flotation (DNF) System: Designed to enhance<br />

the separation and removal of smaller oil droplets and solids.<br />

� Equalization Basin: Equalizes the contaminant load discharged to<br />

the downstream biological system<br />

� Process Wastewater Treatment Plant, Sequencing Batch Reactor<br />

(SBR): An activated sludge process that completes all unit process<br />

steps within the same reactor<br />

� Sludge Treatment System (thickener and centrifuge): Centrifuge<br />

dewater system<br />

� Hydro-clear ® Gravity Sand Filter: Used in final polishing of water.<br />

� Used oils and greases will be sent to a specialized supplier authorized for its<br />

use as industrial fuel, regeneration of lubricant bases, or for the manufacture<br />

of plasticizers, temple fluids, and timber immunization. In the case of clearly<br />

recoverable liquid hydrocarbons, they may be reprocessed in one of the<br />

process units, through the Slope system of the refinery. Materials<br />

contaminated with oil will be delivered to authorized suppliers for its use,<br />

treatment, or final disposal in accordance with the provisions of Decree 4741<br />

of 2005 from MAVDT.<br />

� The spent catalyst from the catalytic cracking unit will be removed daily<br />

from the regeneration unit. It will be stored in a spent catalyst hopper located<br />

in the catalytic cracking unit. From the hopper they will make periodic<br />

deliveries of spent catalyst to cement firms who use it as part of their cement<br />

59<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

manufacturing process. The spent catalyst used in the sulfur plants will be<br />

treated in the area of land-farming, under the recommendations of ARPEL<br />

(Oil Reciprocal Assistance on Latin American business) (see handling<br />

INDEX OP–11). The catalyst from the hydrogen generation plant will be<br />

disposed in land-farming.<br />

6.2 Project Construction EHS Management<br />

60<br />

June 21, 2011<br />

A Health, Safety, Security, and Environmental Management System (HSSE-MS) Manual has<br />

been developed by CB&I and <strong>Reficar</strong> to document the management and implementation of an<br />

HSSE-MS for the <strong>Cartagena</strong> <strong>Refinery</strong> <strong>Expansion</strong> Project. The system addresses health, safety,<br />

crisis, and environmental topics and includes the following sections (see Figure 6):<br />

� Responsibilities<br />

� HSSE policy<br />

� Requirements<br />

� Planning<br />

� Legal and other requirements<br />

� Procedures<br />

� Management program<br />

� Implementation and operation<br />

� Training, awareness, and competence<br />

� Documentation<br />

� Crisis management, emergency preparedness, and response issues<br />

� Accidents, incidents, and non-conformance actions<br />

� Roles, responsibilities, authorities, and accountabilities


� Records and records management<br />

� Audit.<br />

Some key aspects of the manual include:<br />

� Health Aspect Management Documentation, including Medical Surveillance,<br />

1101335.000 04F1 0611 MJ21<br />

Care for injured and ill employees, and Worker’s Compensation<br />

� Safety Aspect Management Documentation, including Safe Work Practices,<br />

Safety in Design, and Program Management<br />

� Security Aspect Management Documentation, including Security<br />

Management and Emergency Management<br />

� Environmental Aspect Management Documentation, including an<br />

Environmental Control Plan<br />

� Specific operational control procedures to manage health, safety, security,<br />

and environmental risks<br />

� Emergency Response—Crisis Management and Emergency Response<br />

Requirements<br />

� Performance Measurement and Monitoring (monthly report)<br />

� Audits will be conducted daily, weekly, monthly, semi-monthly, quarterly,<br />

and annually<br />

� A training needs assessment has been conducted to define and implement an<br />

approved and supported training plan; the needs assessment is based on the<br />

hazard identification, risk assessment, and legal and other requirements<br />

� The Project will use the following methods to communicate HSSE-related<br />

risks and mitigation measures to employees and interested parties: training;<br />

health, safety, security, and environmental bulletins; newsletter/postings; and<br />

communication records.<br />

61<br />

June 21, 2011


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62<br />

June 21, 2011<br />

<strong>Reficar</strong> will perform planned and focused assessments at least quarterly, to determine<br />

compliance and the effectiveness of implementation of HSSE processes in key areas of concern.<br />

6.2.1 Craft Training Programs<br />

The ESMP includes the Training for Project Workers Program (Ficha OP R1-1 in Table 11).<br />

The program’s objective is to raise awareness and improve the skills of the project workers<br />

(skilled and unskilled labor, local and foreign), to ensure the proper implementation of the<br />

ESMP.<br />

Training is provided under partnership agreements with SENA (the primary provider of craft<br />

skills training to the industrial sector in <strong>Colombia</strong>) and the INEM High School. <strong>Reficar</strong> has<br />

invested COP5.05 million in the program (2008−2010). As of January 2011, 1,654 people have<br />

been trained, and the training plan calls for 1,900 people to be trained as of year-end 2011.<br />

Total training plan is 3,900 people.<br />

6.2.2 Construction Worker Hiring Plan<br />

The ESMP includes programs for the recruitment and prioritization of hiring a local workforce<br />

(see Ficha OP R1-3 in Table 11). The two objectives of the programs are (i) to give priority in<br />

the recruitment of the skilled and unskilled workforces to the <strong>Cartagena</strong> city population, and<br />

(ii) to give preference to the recruitment of qualified personnel from the rest of <strong>Colombia</strong>, and<br />

that complies with the technical and experience requirements established by the project.<br />

The program includes specific actions related to residents living in the immediate vicinity of the<br />

refinery, and includes training and assistance to these people to enhance their opportunity to<br />

receive Project benefits (e.g., job training, service provision, etc.).


6.2.3 Construction Worker Housing Plan<br />

1101335.000 04F1 0611 MJ21<br />

63<br />

June 21, 2011<br />

No worker camp will be constructed on the Project site; all workers will be housed in <strong>Cartagena</strong>.<br />

At present, the plan regarding worker housing in the city has not been finalized. While plans are<br />

in place under CB&I’s EPC contract for the housing of Expatriate workers and workers from<br />

other cities in <strong>Colombia</strong>, the plan for housing workers from other countries in Latin America<br />

(the Other Country Nationalities or OCNs) is pending.<br />

The housing needs of Expatriate workers and workers coming from other cities in <strong>Colombia</strong><br />

will be satisfied through the local real estate market, which is sufficient to meet their needs.<br />

Housing for the OCNs is under <strong>Reficar</strong>’s responsibility since it was left out of CB&I’s contract.<br />

<strong>Reficar</strong> is studying the possibility of providing housing to these OCNs through the nearby<br />

hotels/motels. A study was done and there are sufficient rooms at these local hotels/motels to<br />

accommodate all the OCNs. Nevertheless, <strong>Reficar</strong> is studying the possibility of constructing a<br />

social housing project, under an agreement with the local government, to house these workers<br />

throughout the construction period, and then <strong>Reficar</strong> would donate the housing facility to the<br />

local government once the construction of the project is complete.<br />

6.3 Existing <strong>Refinery</strong> EHS Management<br />

6.3.1 EHS Management System<br />

The <strong>Cartagena</strong> <strong>Refinery</strong> has an EHS Management System Manual based on ISO 14001 and<br />

OHSAS 18001. The manual details the policy, organization, responsibilities, document control,<br />

communication systems, process for managing hazards and their effects, planning and<br />

procedures, implementation and monitoring, auditing, updating, and documentation.<br />

The system is developed in conjunction with the following: Regional Occupational Health and<br />

Safety Plan, HSE Plan for plant shutdown, Integrated Operational Plan, Annual Maintenance<br />

Plan, and Simulation Plan. Some of the key procedures include worker personnel protection,<br />

preventive medicine, work permits, management and control of plant changes, contractor


management/control, waste management, emergency preparation and response, HSE<br />

monitoring, and auditing/inspections.<br />

6.3.2 Environmental<br />

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64<br />

June 21, 2011<br />

The following is a summary of some key environmental management aspects associated with<br />

the existing refinery operations.<br />

Wastewater Management: Use of cooling water since 1982 instead of salt water, except for<br />

TG, deviation of salt cooling water from TG directly to the Bay instead of the Skim Pond,<br />

segregation of rainwater and oily water sewers, and wastewater treatment system.<br />

Solid Waste Management: Landfarming area (oily sludge treatment from tanks and from the<br />

WWTP); FCC catalyst sent directly to Holcim Cement Plant (Nobsa, Boyacá); clay, sand, and<br />

other catalyst packaged in drums also sent to Holcim; coke from VR T/A to incineration at a<br />

cement plant; construction residues sent to authorized disposal facilities outside the refinery and<br />

special wastes warehouse (temporary storage of used chemicals, catalysts, and/or any special<br />

solid wastes).<br />

Landfarming: Onsite landfarming will continue at the existing refinery facility. Landfarming<br />

will treat the following: oily sludge generated from maintenance activities, including sludge<br />

plant, oil-impregnated material (filter treatment material of finished products), and spills<br />

management; sludge from wastewater treatment plant (including oily sludge from the API<br />

separators and the flotation system, and biological sludge from secondary treatment); and solid<br />

catalysts spent in the refining units, except for platinum catalyst of the catalytic cracking unit.<br />

The landfarming includes receipt and storage of sludge into two ponds, discharge of oily water<br />

into two ponds, sludge treatment in three sectors of 5 ha each, storage of inputs to the process<br />

(NPK fertilizer 15-15-15, calcium hydroxide, and biological stump), preparation of bacterial<br />

broth in five pools, and machinery and equipment. The landfarming ponds contain base<br />

material composed of clay and stabilized by geotextile membrane (30-mm geo-membrane on


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65<br />

June 21, 2011<br />

15 cm of fine sand and covered with thick sand and zahorra gravel free layers). The collected<br />

leachate is sent to the WWTP. The area has four piezometers to monitor groundwater quality.<br />

Air Emissions: Only fuel gas to boilers and furnaces (no liquid fuels or fuel oil). Fuel gas is<br />

sweetened by using a new amine unit, NH3/H2S gases from SWS sent to flare, FCC regenerator<br />

has complete combustion since 1982, installation of low-NOx burners in four of five boilers,<br />

and optimization of the oxygen-sulfur gases ratio in the Sulfur Plant.<br />

Operations: Reportedly, Ecopetrol prepares annual and 5-year tank maintenance plans. These<br />

plans are based on risk-based inspections (RBIs). Both plans (annual and 5-year) are adjusted<br />

according to information and findings gathered during each shutdown, and to operation results<br />

between maintenance activities. Ecopetrol has implemented a Lines (Piping) Maintenance<br />

Program similar to the one used for the tanks. This program considers both annual and 5-year<br />

plans. Additionally, Ecopetrol is applying a specific Line Integrity Management Program, which<br />

is based on a more structured and scientific application of the concept of risk-based evaluation.<br />

Ecopetrol cleans the marine terminal piers every 2.5 years. Each cleaning involves the removal<br />

of an average volume of approximately 100,000 m 3 of sediment. The cleaning involves<br />

removing (dredging) the deposited sediments in an area of approximately 300�300 m 2 around<br />

each pier, down to a depth sufficient to guarantee the minimum draft required in each pier.<br />

6.3.3 Health and Safety<br />

The Health and Safety Program (Programa Regional de Salud Ocupacional) is divided into five<br />

areas: Strategic Steering, Industrial Safety, Occupational Health, Industrial Hygiene, and<br />

Ergonomics. A risk assessment is conducted for all tasks and activities on the site, which<br />

involves the use of a risk assessment matrix (RAM) in which the probability of an accident in<br />

any given activity and the potential severity of its effects are estimated. A formal safety<br />

analysis has been developed for all activities that rank medium or higher in the RAM<br />

classification, identifying the hazards and risks and defining appropriate safety procedures.


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June 21, 2011<br />

Other programs include Contractor Safety, Work Permit System, SAS (Sistema de Aislamiento<br />

Seguro) Lockout/Tagout, Accident Investigation, Employees’ Health Monitoring, and Industrial<br />

Hygiene. Safety statistic records are maintained per regulatory requirements set forth in Laws<br />

76/1988 and 1295/1994 and Resolution 1570/05. Monthly and quarterly reports are issued<br />

covering employees and contractors, and both on- and off-the-job accidents. Frequency and<br />

severity rates are tracked per the ANSI Z 16 Standard. The trends for both frequency and<br />

severity have improved in recent years (see Section 5.3 for details).<br />

Health and Safety training programs are established in an annual program and include Task<br />

Safety Analysis, RAM risk assessment methodology, and Accident Investigation. A health and<br />

safety inspection program is carried out regularly and includes medical and IH inspections,<br />

multidisciplinary inspections, and industrial safety inspections. All inspections are formal and<br />

supported by a checklist/report form. In addition to the inspections program, there are specific<br />

audits for programs such as work permits, lockout and tag, work at heights, etc. Work permits<br />

are issued for hot works, cold works, and electricity works. Included in each of these permits is<br />

a series of additional standard checklists (called “Certificados de apoyo”), such as confined<br />

spaces, work at heights, lockout and tag, hot-tap, excavations, etc. Employees are regularly<br />

trained in the completion of permit forms.<br />

Industrial Hygiene is managed by the use of a health risk assessment (HRA) tool derived from<br />

Shell Oil programs. The HRA is a systematic method of assessing potential health hazards in<br />

any job or task on the site, measuring the actual exposure level, and defining control measures<br />

to address the hazards. The hazards addressed in the HRA program are BTX, particulates,<br />

noise, sulfur compounds (H2S, SO2), and gasoline vapors.<br />

In terms of fire safety, the site is provided with a hydrant system covering all production,<br />

storage, and administrative facilities. As of May 2006, mobile equipment consists of three fire<br />

trucks each with a 2,750-gal capacity, three tank trucks each with 2,000-gal capacity, and one<br />

1,000-gal foaming agent tank truck. The site is assisted by a 12-member emergency brigade per<br />

shift. Weekly training sessions are conducted, and a fire brigade training facility located in the<br />

southern portion of the site is used for live fire training. Fire drills are conducted approximately


1101335.000 04F1 0611 MJ21<br />

67<br />

June 21, 2011<br />

every 6 weeks. In addition to the brigade members, more than 100 employees have received<br />

emergency and fire protection training.<br />

Contractors’ safety policies include standard HSE clauses in contracts, specific field audits,<br />

specific health and safety plans for large jobs, HSE training at Ecopetrol, contactors’ own H&S<br />

professionals, and insurance. Since January 2007, it has been Ecopetrol’s policy to prefer<br />

contractors certified by the <strong>Colombia</strong>n Safety Council, or who are certified to OHSAS 18001 by<br />

an accredited institution. Depending on the RAM risk classification of the jobs they will<br />

perform, contractors may be required to have a safety inspector or supervisor (or both) in place<br />

and to prepare a Health and Safety Plan for the job. Contractors are subject to weekly<br />

inspections by Ecopetrol personnel and are required to present weekly safety performance<br />

reports. Penalties are prescribed for safety breaches by contractors while performing the<br />

contracted jobs.<br />

6.3.4 Emergency Preparedness and Response<br />

Three primary emergency situations are addressed in the site’s emergency preparedness and<br />

response (EPR) plan: fire, environmental emergencies (spills), and gas releases. Emergencies<br />

are ranked from Minor to Major to National/Catastrophe, according to their potential magnitude,<br />

duration, and expected consequences, and to the expected resource level required to meet them.<br />

Response plans address the resources required, command organization/ hierarchy, access<br />

control, and communications. The emergency organization includes an emergency control<br />

brigade, comprising trained members for each shift, mainly from the operational area; support<br />

brigade with maintenance and technical personnel; evacuation leaders for each department or<br />

area in the plant; and emergency response equipment. Periodic drills are conducted. In addition<br />

to these, Ecopetrol participates in the APELL group, which involves other industries and public<br />

organizations in the greater <strong>Cartagena</strong> area. Specific scenarios have been developed for many<br />

possible emergency situations, and the response plans for each are outlined in Ecopetrol’s EPR<br />

manual. Various emergency drills are conducted every year, as well as one large-scale APELL<br />

exercise. Response equipment includes (in addition to the fire-fighting equipment described<br />

above) two vacuum trucks for spilled material collection, suction pumps with skimmer (“manta


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68<br />

June 21, 2011<br />

ray”) suction heads, and spill containment floaters. Detection systems are based mainly on<br />

permanent inspection rounds conducted in the refinery area watching for fires and signs of<br />

spillage at the 33 spill detection points located throughout the refinery.<br />

6.3.5 Contingency Plan<br />

The <strong>Cartagena</strong> <strong>Refinery</strong> has developed an Integral Contingency Plan based on the guidelines for<br />

Decree 321 (1999). Through this Decree, the National Government adopted the Contingencies<br />

National Plan for hydrocarbons, derivatives, and toxic chemical spills. The main components of<br />

the plan include:<br />

� Strategic Plan, which includes basic concepts, regulatory framework, maps<br />

identifying sensitive areas and areas of influence, analysis of risks, strategy<br />

for risk response, coordination with external entities, basic signalization,<br />

training and auditing programs, information dissemination, and plan updating<br />

� Operation Plan, which includes general considerations, operation procedures,<br />

operation response, control and evaluation of operations, termination of<br />

operations, and post-emergencies<br />

� Information Technology Plan, which includes maps, equipment inventories,<br />

and contact directories.<br />

<strong>Reficar</strong> has an in-place emergency and contingency plan that is tied to the National Contingency<br />

plan for disasters (Decreto 321). These plans integrate the following emergency levels for<br />

National to onsite consideration:<br />

� National Emergency—Level 3 National/International for disaster prevention<br />

activation (SNPAD)<br />

� Major Emergency (regional area of influence)—Level 2 Regional Committee<br />

for disaster prevention activation (CREPAD)


� Medium Emergency (local area of influence)—Level 1 Local Committee for<br />

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disaster prevention activation (CLOPAD)<br />

� Minor emergency (onsite area of influence).<br />

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June 21, 2011<br />

This ensures that the proper authorities and personnel are activated at the appropriate level for<br />

any potential emergency resulting from onsite activities.


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June 21, 2011<br />

7 Information Disclosure and Public Consultation<br />

During the initial licensing process for the PMD expansion (i.e., leading to issuance of<br />

Resolution 1157 in 2000), Ecopetrol implemented a program called Open Door, in which it is<br />

reported that more than 4,200 people from 24 communities participated. Additionally, meetings<br />

with the relevant entities (e.g., ANDI-Mamonal Foundation, ACOPI, Chamber of Commerce,<br />

FENALCO, ASIEN, and the local universities) were held. The PMD for the refinery and the<br />

Environmental and Social Management Plans were presented by Ecopetrol.<br />

The Project EIA and the Port EIA were made available to the public in August 2008 and July<br />

2009, respectively. The Project EIA and the Port EIA were each presented to the public in four<br />

sessions, and included local communities, local and regional authorities, universities, industry,<br />

and non-governmental organizations. The public may view the Project EIA and the Port EIA at<br />

the offices of the environmental authorities: CARDIQUE, EPA <strong>Cartagena</strong>, and MAVDT.<br />

During the Project EIA process and the request to the MAVDT for a modified Environmental<br />

License, a social/participation process was implemented. The objective of this process was to<br />

inform the community of new technologies to be used in the refinery and the environmental<br />

benefits that will arise with this modernization. This included presentations to various<br />

stakeholders as follows:<br />

� Local: Including the mayor and <strong>Cartagena</strong> city officials of health, mobility,<br />

planning, education, competitiveness, environment, and Office of the<br />

Ombudsman<br />

� Regional: Including CARDIQUE, Governor’s office (environmental and<br />

economic development), DIMAR, and CIOH<br />

� Industry and Academics: Including ANDI, FUNDACION Mamonal,<br />

Chamber of Commerce of <strong>Cartagena</strong>, ACOPI, ACIEM sectional Bolivar, and<br />

various universities (e.g., Technological University of <strong>Cartagena</strong>, University


1101335.000 04F1 0611 MJ21<br />

Jorge Tadeo Lozano, University of Bolivar, SENA, CIFEM, Monitoring of<br />

<strong>Cartagena</strong>, and Monitoring of the Caribbean)<br />

� Communities: Including those elected leaders, delegates, representatives,<br />

and community leaders.<br />

71<br />

June 21, 2011<br />

The results of this process confirmed that the refinery operations and the proposed expansion<br />

were relatively well known, although the technical details were not necessarily known. It was<br />

reported that the Project information was well received, including the environmental<br />

management plan, the social management plan, and information on the social responsibility<br />

policies of <strong>Reficar</strong>.<br />

The results also identified a strong expectation of local residents regarding generation of<br />

employment for them (both direct and indirect). Similarly, there are great expectations on the<br />

improvement of the local economy and the effect of resources to be invested in the Project.<br />

The Project’s Revised ESMP includes a Community Communication and Participation Program<br />

(see Ficha OP R1-2 in Table 11). The objective of the program is to communicate to the<br />

municipal, regional, and environmental authorities, as well as to the communities and unions, in<br />

general about the modernization project. The program includes actions in terms of ongoing<br />

consultation and information disclosure, consistent with IFC Performance Standards.<br />

<strong>Reficar</strong>’s public consultation and disclosure program was implemented in 2008, and made<br />

public when their website was established in 2009. The plan was not formally presented to the<br />

community or to other stakeholders, but it has been discussed during <strong>Reficar</strong>’s public<br />

consultation meetings with the communities and suppliers.<br />

Since early 2010, <strong>Reficar</strong> has significantly expanded its public consultation and disclosure<br />

activities; they conducted many meetings with the local communities in 2010 (more than 1,000<br />

people attended), and at least 50 more meetings are planned for 2011 (12 meetings were<br />

conducted from January to March 2011).


1101335.000 04F1 0611 MJ21<br />

Projections for future public consultations<br />

Type of Public Consultations 2011 2012 2013 a<br />

Community leaders 6 6 3<br />

Nearby communities 48 50 20<br />

Nearby companies 3 3 1<br />

Chamber of Commerce 3 3 1<br />

Other 5 5 1<br />

a The operation starts July 2013.<br />

Total 65 66 26<br />

72<br />

June 21, 2011<br />

The Project’s Revised ESMP also includes a Community Grievance Mechanism (see Ficha<br />

OP R1-6 in Table 11). The program’s objective is to address, record, resolve, and answer all<br />

concerns, suggestions, expectations, and complaints expressed by officials of the municipal<br />

administration or any other private or public entity and the community in general; and to obtain<br />

feedback about the Project from the community in order to foster good working relationships,<br />

minimizing the occurrence of conflicts affecting the normal development of the project. The<br />

program includes grievance mechanisms actions, consistent with IFC Performance Standards.<br />

<strong>Reficar</strong> has good Grievance Mechanism procedures in place for the local communities and other<br />

interested parties, and can receive inquiries through their website, by email, telephone, or letter.<br />

<strong>Reficar</strong> uses the SUGAR software application to register, monitor, and respond to inquiries.<br />

The system also generates reports. There were 1,308 inquiries in 2010 and 258 as of<br />

January 31, 2011. Almost 90% of the inquiries concern job opportunities and the rest are<br />

inquiries on how to become a supplier to the Project. To date, <strong>Reficar</strong> has responded to 100%<br />

of the inquiries within 72 hours.


8 Conclusions and Recommendations<br />

The following conclusions (Section 8.1) and recommendations (Section 8.2) are based on<br />

1101335.000 04F1 0611 MJ21<br />

73<br />

June 21, 2011<br />

Exponent’s environmental and social due-diligence of the Project. Sections 2 through 7 of this<br />

report present a summary of the environmental and social aspects of the Project based on the<br />

information provided. The conclusions and recommendations presented herein are based on the<br />

work performed as described in this report. Exponent reserves the right to revise these<br />

conclusions and recommendations if and when additional information becomes available.<br />

Exponent investigated specific issues relevant to the objectives of this Project. Therefore, the<br />

scope of services performed during this work may not adequately address the needs of other<br />

users, and any reuse of this report or the findings, conclusions, or recommendations presented<br />

herein is at the sole risk of the user. Exponent offers no warranty regarding this report beyond<br />

that specifically stated in the Consultant Services Agreement for this work. We have made<br />

every effort to accurately and completely present all areas of concern identified during our<br />

investigation. If there are perceived omissions or misstatements in this report regarding any<br />

aspect of our work, we ask that they be brought to our attention as soon as possible, so we have<br />

the opportunity to address them.<br />

8.1 Conclusions<br />

8.1.1 Impacts<br />

The principal potential significant negative impacts during Project construction include<br />

vegetation clearing (approximately 58 ha within existing refinery property), air quality impacts<br />

due to dust generation and vehicle traffic, increased noise and vehicle traffic, and construction<br />

worker (approximately 10,780) related impacts (both on the workers and on nearby<br />

communities). Other potential impacts include liquid- and solid-waste management,<br />

displacement of fauna, soil and water contamination due to spills, and worker and community<br />

health and safety. With the exception of loss of vegetation due to clearing, the impacts should<br />

be relatively localized, temporary, and reversible; and reasonably prevented or mitigated with


1101335.000 04F1 0611 MJ21<br />

74<br />

June 21, 2011<br />

standard/good practices. However, the extent of worker-related housing impacts is still unclear,<br />

because worker housing plans have not been finalized. Loss of vegetation is being mitigated by<br />

planting of 36,000 trees (i.e., 7 new trees for every 1 tree lost) under an agreement with<br />

CARDIQUE. No significant impacts are anticipated related to natural habitats, indigenous<br />

populations, endangered or economically important flora or fauna, or cultural or archeological<br />

sites. The implementation of the Project will not require change in land use or any resettlement.<br />

The principal potential significant negative impacts during Project operation include air<br />

emissions and resultant impacts on ambient air quality, wastewater discharges and resultant<br />

impacts on receiving-water quality, increased petroleum-based wastes and hazardous wastes,<br />

and potential risks due to spills and fires/explosions. The extent of the potential impacts on<br />

ambient air quality is still not fully defined due to an incomplete Project air quality impact/<br />

modeling analysis (see Table 7 for details). Emissions of PM10 and SO2 are estimated to<br />

decrease as a result of the refinery expansions, while emissions of NO2 are estimated to<br />

increase. There is the potential for fugitive emissions and greenhouse gas emissions, but these<br />

were not modeled or analyzed. No actual ambient air quality data are available from locations<br />

of likely maximum impact from the Project; data are available only from locations within the<br />

plant boundary and have limited representativeness in terms of assessing Project impacts. Thus,<br />

there is a degree of uncertainty related to the Project impact (i.e., Project emissions plus existing<br />

baseline ambient air quality).<br />

The EIA Project modeling of cumulative impacts (Project plus other sources in the area) showed<br />

significant exceedances of applicable air quality criteria, but there are concerns about the quality<br />

and accuracy of this modeling. The new WWTP designed by Siemens ensures a 0.2-mg/L<br />

phenol discharge will be constructed by CB&I, and Siemens will provide two process<br />

performance guarantees.<br />

Other but less significant impacts include increased noise due to operations, and increased nonhazardous<br />

waste generation. No significant impacts are anticipated related to critical natural<br />

habitats, cultural sites, indigenous populations, or endangered or economically important flora<br />

or fauna.


8.1.2 Compliance<br />

1101335.000 04F1 0611 MJ21<br />

75<br />

June 21, 2011<br />

In terms of compliance with <strong>Colombia</strong>n-related environmental requirements, the MAVDT has<br />

issued an environmental license for the Project (Resolution 2102, November 2008) based on a<br />

Project EIA, which actually represents a modification to an original authorization issued in 2000<br />

(Resolution 1157). MAVDT and CARDIQUE granted <strong>Reficar</strong> was the relevant responsibilities<br />

and obligations associated with existing environmental authorizations associated with the<br />

existing refinery. CARDIQUE authorized the land clearing for the proposed refinery expansion.<br />

The Port EIA was approved by MAVDT and added to the license in March 2010 (Res. 511,<br />

March 2010). Subsequent to approval of the Port EIA, a concession to construct and operate the<br />

Port Facilities was awarded to <strong>Reficar</strong> in November 2010. The only possible pending key<br />

environment-related Project regulatory requirement is the submittal to MAVDT of an EIA for a<br />

new 130-km pipeline from Coveñas to the refinery for review and approval, to the extent that<br />

this is applicable (i.e., if this option is selected); this will be Ecopetrol’s responsibility. The<br />

previously noted significant regulatory non-compliance which related to exceedance of the<br />

0.2-mg/L phenol limit in the wastewater discharge has been corrected with the new WWTP<br />

design; this is no longer an issue.<br />

In order to meet the air emissions limits established in Resolution 909 (2008), we understand<br />

that <strong>Reficar</strong> has requested a waiver from CARDIQUE to delay compliance with the air emission<br />

standards that were effective July 2010 until the new refinery expansion is completed. While<br />

<strong>Reficar</strong> has not yet received the waiver from CARDIQUE, they believe it is likely to be granted,<br />

considering CARDIQUE granted the extension of Resolution 911until August 14, 2011,<br />

permitting the continuance of refinery operations under the present refinery conditions. (See<br />

Section 8.4 for the assessment of compliance with International Guidelines [the Equator<br />

Principles, IFC Performance Standards, IFC EHS Guidelines for Petroleum Refining and EHS<br />

General Guidelines]).


8.1.3 Environmental Liabilities<br />

1101335.000 04F1 0611 MJ21<br />

76<br />

June 21, 2011<br />

Various environmental liabilities existed at the existing refinery, based on the results of the<br />

Phase 1 and 2 ESAs, as discussed in the 2009 ESDD Report. Several of these issues have been<br />

addressed by plant design modifications and upgrades, and they include:<br />

� Wastewater Treatment: 2010 results for phenol were below the <strong>Colombia</strong>n<br />

national limit; and groundwater at the site, affected by free product and<br />

dissolved product, is being addressed and paid for by Ecopetrol. The new<br />

WWTP will meet the phenol limit that the existing WWTP cannot. As<br />

mentioned previously, Siemens will provide two process performance<br />

guarantees to meet IFC guidelines for effluent criteria (see Table 8).<br />

Therefore, this is no longer an issue.<br />

� Health and Safety: The existing refinery has received ISO 14000 and<br />

OSHAS 18000 accreditation, and CB&I has established a significant and<br />

world class health, safety, and environmental management system. The<br />

specific details are outlined in the Project’s Health, Safety, and<br />

Environmental Management System Environmental Management Plan.<br />

� Air Emissions: New plant modifications result in a reduction of air<br />

emissions from the new refinery and no net impact to the Mamonal Industrial<br />

Area airshed. NO2 total load will increase but the permissible limits will still<br />

be met (Resolution 601, 2006, Tables 5 and 6). Confirmational air sampling<br />

and dispersion modeling will be performed at the Site to establish a baseline.<br />

The scope of work for this effort has been established and the contractor will<br />

be selected once the lenders accept the proposed methodology for air<br />

sampling.<br />

� Operation and Maintenance: The new and existing facilities are<br />

undergoing extensive rebuild. Operation and maintenance procedures are<br />

defined under the Environmental Management Plan; these functions are


8.1.4 Risks<br />

1101335.000 04F1 0611 MJ21<br />

currently being executed by Ecopetrol, and paid for by <strong>Reficar</strong> as part of the<br />

normal operation of the existing refinery.<br />

77<br />

June 21, 2011<br />

The Project does carry some environmental and social risks in the context of lender financing.<br />

The most significant of these are as follows (see Section 8.2 for proposed measures to address<br />

these risks):<br />

� Lender Policy Risks: The most significant of these are (see Section 8.1.2<br />

for details): The Project design documents confirm that the Project will meet<br />

IFC and <strong>Colombia</strong>n National guidelines for air emissions. However, due to<br />

an incomplete air quality impact/modeling assessment, it is unclear whether<br />

the Project will meet applicable ambient air quality standards. Current plans<br />

call for air dispersion modeling with additional sampling which will be<br />

undertaken to confirm that air quality is met at the Site. Some programs<br />

under the Revised ESMP need to be further modified to correct some<br />

remaining deficiencies (see Table 11 for recommendations).<br />

� Environmental Liability Risks: Various environmental liabilities exist at<br />

the existing refinery (see Section 8.1.3 for summary). <strong>Reficar</strong> has submitted<br />

the EHS Action Plan 2011 to fully and properly correct these liabilities (see<br />

Table 12). The resolution of these liabilities has a significant cost, with<br />

existing estimates ranging from US$30 to US$60 million. Ecopetrol is<br />

responsible for cleanup and remediation activities and <strong>Reficar</strong> will be<br />

overseeing these activities to ensure compliance.<br />

� Construction Risk: There are significant local expectations regarding the<br />

Project expansion providing economic opportunities to the local population<br />

during construction. Thus, if the Project construction does not provide<br />

substantial employment or service contracts (e.g., food services, cleaning<br />

services, etc.) to the nearby communities, there could be some strong local<br />

negative sentiment against the company and/or Project. This could result in


1101335.000 04F1 0611 MJ21<br />

protests (e.g., stopping traffic, etc.), labor issues, increased regulatory<br />

enforcement, or even governmental political intervention. While <strong>Reficar</strong> and<br />

CB&I have specific policies and programs in place to train and hire a large<br />

number of people from the local communities, to utilize the services they<br />

provide, and to communicate these programs to the local communities, the<br />

communities’ expectations may exceed what the Project is able to provide, so<br />

<strong>Reficar</strong> should continue to manage these expectations.<br />

78<br />

June 21, 2011<br />

Other, but less significant, potential Project environmental and social risks include the following<br />

(see Section 8.2 for proposed measures to address these risks):<br />

� Regulatory Risk: <strong>Reficar</strong> has secured environmental regulatory approval for<br />

the refinery expansion and has all the regulatory approvals for the Project.<br />

The key relevant pending permits from the site review in 2009 included the<br />

permit for the port/terminal expansion works and operations. This permit has<br />

been acquired (Res. 511, March 2010). To the extent applicable, any<br />

permitting for the new pipeline and terminal facilities in Coveñas will be the<br />

responsibility of Ecopetrol who will own and operate these logistic facilities.<br />

� Construction Timing Risk: CB&I has fully developed and documented the<br />

construction-phase Occupational Health and Safety Management System and<br />

Environmental Management System. These systems and associated plans<br />

and procedures are in place and are currently being implemented by CB&I.<br />

This risk was mitigated subsequent to the status reported previously in the<br />

2009 ESDD Report.<br />

� Operation Risk: There is a risk due to the potential significance of lowprobability<br />

major events (e.g., accidental releases, spills, explosions, etc.)<br />

during operations. While the track record of the existing refinery does not<br />

appear to be poor, adverse events have occurred, and there are existing<br />

environmental liabilities due to past practices. The new refinery expansion<br />

will substantially increase, in some aspects, the potential consequence


1101335.000 04F1 0611 MJ21<br />

severity if a major event does occur. The potential for major events would<br />

include Project-related facilities such as the Nestor Pineda Terminal. In our<br />

opinion, these risks can be properly identified, quantified, and mitigated. The<br />

site Health, Safety, Security, and Environmental Management System for the<br />

<strong>Cartagena</strong> <strong>Refinery</strong> <strong>Expansion</strong> Project (CB&I Contract No. 166000) provides<br />

procedures, guidelines, and requirements for such occurrences during<br />

construction activities.<br />

79<br />

June 21, 2011<br />

8.2 Current Status of Recommendations Included in the 2009<br />

ESDD Report<br />

The following specific technical, environmental, and social measures were recommended for the<br />

Project in order to satisfy the applicable lender environmental and social requirements and to<br />

adequately mitigate the Project’s environmental and social risks:<br />

1. <strong>Reficar</strong> should present supplemental Project environmental and social impact<br />

analysis/information on:<br />

(a) Project-specific and cumulative air quality impacts (see Table 7 for<br />

specific recommendations).<br />

Status: The ambient air quality monitoring program is included in <strong>Reficar</strong>’s<br />

ESMP. Air dispersion modeling for the Site will be performed to predict the<br />

maximum ground level concentration (GLCmax) of nitrogen oxides (NOX),<br />

sulfur dioxide (SO2), carbon monoxide (CO), and particulate matter (PM10)<br />

from the expanded refinery within and around the refinery fence line. The<br />

baseline emissions from current refinery operations plus the surrounding<br />

industrial facilities will be established by conducting real-time ambient air<br />

sampling with the refinery fence line, as well as at critical receptor locations<br />

(such as Membrillal, a restaurant, Pasacaballos) around the refinery fence<br />

line.


1101335.000 04F1 0611 MJ21<br />

<strong>Reficar</strong> has prepared the <strong>Cartagena</strong> <strong>Refinery</strong> <strong>Expansion</strong> Project, Air<br />

Dispersion Modeling Scope of Work. This request for proposal provides the<br />

guidelines for a consultant to provide this air quality impact consulting, and<br />

the contractor will be selected once the lenders accept the proposed<br />

methodology for air sampling. Exponent received a copy of the proposal and<br />

confirms that it is in compliance with the recommendations included in<br />

Table 7 of our ESDD Report (see Section 5.2.1).<br />

� The detailed engineering has begun and it is scheduled to be<br />

completed by year-end. The modeling program may begin once<br />

the detailed engineering is completed, and the program will be<br />

completed prior to commencement of the operations period.<br />

� <strong>Reficar</strong>’s commitment that air modeling will take place for the<br />

refinery operation, along with the environmental management<br />

plans included in the Revised ESMP, and contractor process<br />

guarantees ensure that the Project will be in compliance with IFC<br />

PS 3 (Pollution Prevention and Abatement).<br />

(b) construction worker–related impacts (i.e., influx management, housing,<br />

transportation, impacts to immediate nearby communities, etc.),<br />

Status: During the recent site visit, <strong>Reficar</strong> and CB&I gave presentations to<br />

Exponent on their programs to manage construction worker-related impacts,<br />

including workers’ housing, worker transportation (by bus daily to the project<br />

site), and potential impacts to Membrillal (the only immediately nearby<br />

community, which is located about 3 km from the project site, along the back<br />

road).<br />

Complete information has not yet been made available to Exponent on i) the<br />

history of the Project’s Community, Health, Safety and Security program<br />

(FICHA OP R1-5); and ii) the Project’s Construction Worker Housing Plan<br />

(for details see i) and ii) below). Exponent recommends this information be<br />

submitted to the Senior Lenders for their approval prior to Financial Close.<br />

80<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

i) the Project’s Community Health, Safety and Security programs;<br />

Status: The EMP Contingency Plan included in the HSE Management<br />

System includes procedures for Community Health, Safety and Security,<br />

and the ESMP includes a program for informing, training, and educating<br />

surrounding communities about the environment and emergency<br />

preparedness (see Section 6.4 and Ficha OP R1-5). The history of<br />

activities under the ESMP program, including practice emergency drills<br />

conducted with the local communities, has not yet been presented to<br />

Exponent.<br />

ii) CB&I’s Construction Worker Housing Plan,<br />

Status: The Project plan regarding worker housing in the city has not<br />

been finalized. While plans are in place under CB&I’s EPC contract for<br />

the housing of Expatriate workers and workers from other cities in<br />

<strong>Colombia</strong>, the <strong>Reficar</strong> plan is pending for housing workers from other<br />

countries in Latin America (the Other Country Nationalities or OCNs).<br />

While there are sufficient rooms at local hotels/motels to accommodate<br />

all the OCNs, <strong>Reficar</strong> is studying the possibility of constructing a social<br />

housing project, under an agreement with the local government, to house<br />

these workers throughout the construction period, and then <strong>Reficar</strong> would<br />

donate the housing facility to the local government once the construction<br />

of the project is complete (see Section 6.2.3).<br />

iii) CB&I’s Workers’ Transportation Plan.<br />

Status: CB&I’s Workers’ Transportation Plan is included in the<br />

Project’s Traffic Management Plan, which includes bus transportation for<br />

the project workers, to and from the Project site, and the transportation of<br />

cargo to the Project site. Personnel transportation will be subcontracted<br />

by CB&I to a specialized firm or group of firms. The estimated demand<br />

at peak will be around 250 buses per day, with an average capacity of<br />

30 passengers each. Staggered entrance to and exit from the jobsite will<br />

81<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

be organized in order to prevent congestion and traffic jams at the<br />

surrounding roads of the jobsite (see Section 6.2.4).<br />

(iv) Influx Management<br />

Status: As Exponent was informed, <strong>Reficar</strong> does not have a plan to<br />

address an unexpected influx of people looking for jobs at the refinery.<br />

<strong>Reficar</strong>’s and CB&I’s programs to provide craft training and hire a peak<br />

workforce of approx. 7000 for the construction will minimize this risk.<br />

Exponent recommends that <strong>Reficar</strong> work with local authorities to develop<br />

a contingency influx management plan.<br />

(c) decommissioning of existing wastewater treatment plants (WWTPs),<br />

Status: Decommissioning of the current WWTP is integrated with the<br />

development of the new WWTP. Some tanks and storage facilities will be<br />

maintained and used with the new system (see status of the new Siemensdesigned<br />

system in sub-section 4 below, and further details of the new system<br />

in Sections 5.2.2 and 6.1).<br />

(d) transport of hydrofluoric acid during operations,<br />

Status: A plan has been developed to import hydrofluoric (HF) acid using<br />

ISO containers (20 or 40 ft) following established <strong>Colombia</strong>n standards that<br />

are based on UN guidelines for hazardous materials transportation (1995).<br />

The hydrofluoric acid, along with other hazardous materials, will be<br />

transported by truck to the Project site. The handling, storage, and<br />

transferring of hazardous materials is covered under the existing EMP, and<br />

the Project ESMP has contingencies and fichas for handling hazardous<br />

materials (see Fichas CO R1-3 and CO R1-15).<br />

(e) estimated total energy consumption during operation (expressed as MJ per<br />

metric ton of processed crude oil) and estimated electric power consumption<br />

during operations (expressed as KWh per metric ton of processed crude oil).<br />

Status: This information has been provided to Exponent (refer to Tables 13<br />

and 14).<br />

82<br />

June 21, 2011


2. <strong>Reficar</strong> should present specific information confirming how the Project will<br />

comply with the SOx emission limit in the IFC Environmental Health and<br />

Safety Guideline for Petroleum Refining when operating with over a 1%<br />

sulfur feedstock and up to the maximum likely sulfur content feedstock. This<br />

should include the design and operation aspects (including any applicable<br />

EPC or equipment guarantee emissions limits) and the associated costs. It<br />

should also include how this design and operation would comply with that<br />

stated in Resolution 2102 (November 2008) on atmospheric emissions<br />

(“permiso de emisiones atomosfericas”, Hoja No. 26 and 27).<br />

1101335.000 04F1 0611 MJ21<br />

Status: The Project redesign includes a FCCU that is designed to meet the<br />

SOx emission limit in the IFC Environmental Health and Safety Guideline<br />

for Petroleum Refining, and will include modeling of baseline and<br />

operational conditions; baseline will be obtained by using actual sampling at<br />

critical receptors.<br />

3. <strong>Reficar</strong> should prepare and present a revised ESMP (from Project EIA) to<br />

fully address (a) the requirements established in Resolution 2102 (November<br />

2008) and (b) the recommendations listed in Table 11.<br />

Status: The Revised ESMP was prepared in April 2010, and was provided to<br />

Exponent during the recent site visit (see Table 11 for listing of the fichas of<br />

the plans and programs).<br />

4. <strong>Reficar</strong> should present the final design of the wastewater collection and<br />

treatment system for the refinery expansion. This should include a guarantee<br />

of phenol discharge of less than 0.2 mg/L, program/design for water use<br />

minimization, guarantee limits for all wastewater discharge parameters, and<br />

specific operational procedure for stormwater testing (i.e., in terms of<br />

deciding whether stormwater will be treated or not).<br />

Status: The wastewater collection and treatment system described in the<br />

EIA is being replaced by a Siemens designed system. Siemens’s technical<br />

proposal to supply raw water (Proposal No. 703725) and wastewater<br />

83<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

treatment equipment and services (Proposal No. 7040008), which included<br />

two process performance guarantees to meet IFC guidelines for effluent<br />

criteria and covered all above-mentioned wastewater impacts, was accepted<br />

by <strong>Reficar</strong> under their purchase order no. 42166001-PO-1311154001 (the<br />

Purchase Order), dated March 23, 2011, for US$35.31 million. Siemens will<br />

provide the basic engineering and major equipment. Construction will be<br />

performed by CB&I. The Siemens technical proposal includes Table 3.4a<br />

that outlines meeting the IFC EHS Guideline for phenol of less than<br />

0.2 mg/kg (see Table 8). The major components of the system are shown on<br />

Figure 5.<br />

The process performance guarantees are in the form of make good warranties<br />

up to a limit of (i) US$10.0 million for impaired performance of the<br />

wastewater treatment system and (ii) US$2.295 million for impaired<br />

performance of the raw water treatment system, for failure of the systems to<br />

achieve the guarantees in accordance with the terms and conditions of the<br />

guarantees as set forth in the purchase order. The guarantees may be drawn<br />

once the plant is constructed and confirmatory sampling has taken place.<br />

In addition to the process performance guarantees, Siemens will provide an<br />

Irrevocable Standby Letter of Credit (Standby L/C) in favor of <strong>Reficar</strong> in an<br />

amount equal to 15% of the Purchase Order price. Such Standby L/C shall be<br />

opened as condition precedent to the first milestone payment and shall remain<br />

in full force and effect until full delivery of the goods under the Purchase<br />

Order to <strong>Reficar</strong>, at which time such Standby L/C shall be reduced to an<br />

amount equal to 5% of the Purchase Order price. The reduced Standby L/C<br />

shall remain in full force and effect until the expiry of the Base Warranty<br />

Period. (See Sections 5.2.2 and 6.1 for further details on the new wastewater<br />

treatment systems.)<br />

5. <strong>Reficar</strong> should present a complete Corrective Action Plan to address (a) all<br />

the environmental liabilities at the existing refinery identified in the Phase 1<br />

and 2 ESAs, including those identified but necessarily with material financial<br />

84<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

costs and (b) the issues listed in Table 15. The plan should include the<br />

associated costs, responsibilities for implementation, and proposed time<br />

schedule.<br />

Status: A complete Corrective Action Plan to address all the environmental<br />

liabilities identified in the Phase 1 and Phase 2 ESAs has been completed and<br />

submitted to Exponent (the EHS Action Plan 2011, see Table 12). As<br />

outlined in this Action Plan, <strong>Reficar</strong> completed assessments during 2010 and<br />

will continue to monitor and complete remedial actions and systems between<br />

2011 and 2013. Ecopetrol is responsible for cleanup and remediation<br />

activities and <strong>Reficar</strong> will be overseeing these activities to ensure<br />

compliance.<br />

6. <strong>Reficar</strong> should present specific information on how the potential material<br />

Project-related environmental costs will be paid for, including specifically<br />

those for:<br />

(a) compliance with SOx emission limit in the IFC EHS Guidelines for<br />

Petroleum Refining,<br />

Status: The Environmental Management Plan, EIAs, and the proposed air<br />

emissions modeling work will address this issue. The focus will be on<br />

evaluation, management, monitoring, and contingency planning. The scope<br />

basis and engineering design set the plant air emissions to meet IFC<br />

guidelines, but <strong>Reficar</strong> will still need to sample, model, and confirm the<br />

emissions. The monitoring is included in the approved EMP for the future<br />

operation, and is included in the operational costs (as it is today for the<br />

existing refinery).<br />

(b) resolution of environmental liabilities at the existing refinery,<br />

Status: The current refinery operation falls under the current Environmental<br />

Management Plan. Several of these issues have been addressed by plant<br />

design modifications and upgrades. The phenol will be resolved with the<br />

85<br />

June 21, 2011


1101335.000 04F1 0611 MJ21<br />

new WWTP, and the free product plume will continue to be addressed by<br />

Ecopetrol (see Section 5.3.1, and sub-section 5 above).<br />

(c) compliance with the 0.2-mg/L phenol limit in wastewater discharge for<br />

refinery expansion.<br />

Status: Siemens will provide process performance guarantees to cover the<br />

phenol limit in wastewater discharge (see sub-section 4 above and Siemens<br />

Table 3.4a [Table 8]).<br />

7. <strong>Reficar</strong> should prepare and present a plan to provide economic opportunities<br />

to the local population during Project construction, especially for those<br />

populations in the immediate vicinity of the refinery. The plan should<br />

consider employment or service contracts (e.g., food services, cleaning<br />

services, etc.) to the nearby communities, and specific training and assistance<br />

for the immediately local residents and community associations.<br />

Status: Providing economic opportunities to the local population and other<br />

means of improving their livelihoods is a top priority for both <strong>Reficar</strong> and<br />

CB&I. While <strong>Reficar</strong> does not have an overall plan to provide economic<br />

opportunities, there are individual plans and social programs covering local<br />

hiring, use of local services, craft training, and corporate social responsibility<br />

(see Section 5.4.1 and Fichas OP R1-1—Training of Project Workers and<br />

OP R1-3—Recruitment Programs and Prioritization of Local Workforce).<br />

<strong>Reficar</strong> has a plan to contract members of the local communities to sew<br />

workers’ uniforms and to provide some food services, and has recently<br />

placed purchase orders with three small local businesses.<br />

8. <strong>Reficar</strong> should present the executed EPC contract, and such contract should<br />

have specific EHS requirements established, including those required by<br />

lenders, air emission guarantees to meet <strong>Colombia</strong>n and lender requirements,<br />

wastewater discharge guarantees to meet <strong>Colombia</strong>n and lender requirements,<br />

implementation of the CB&I/<strong>Reficar</strong> EHS system (see next item), and<br />

specific management and performance EHS indicators.<br />

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1101335.000 04F1 0611 MJ21<br />

Status: A copy of the executed EPC contract between <strong>Reficar</strong> and CB&I<br />

was presented to Exponent during the recent visit.<br />

� EPC Contract includes:<br />

a) air emission guarantees to meet <strong>Colombia</strong>n and lender requirements;<br />

b) wastewater discharge guarantees to meet <strong>Colombia</strong>n and lender<br />

requirements;<br />

c) implementation of the CB&I/<strong>Reficar</strong> EHS system (see next item), and<br />

d) specific management and performance EHS indicators.<br />

9. The CB&I/<strong>Reficar</strong> Health, Safety, Security, and Environmental Management<br />

System for Project construction should be updated to reflect all lenders’<br />

requirements.<br />

Status: <strong>Reficar</strong> and CB&I gave presentations to Exponent on their Health,<br />

Safety, Security, and Environmental Management System policies and<br />

procedures. These systems are firmly emplaced in the day-to-day<br />

performance at the Site. Details are presented in the Health, Safety, and<br />

Environmental Management System for the <strong>Cartagena</strong> <strong>Refinery</strong> <strong>Expansion</strong><br />

Project, CB&I Contract No. 166000 document.<br />

Exponent was informed that as of January 31, 2011, the Project had reached<br />

5.5 million man-hours with no lost time.<br />

10. <strong>Reficar</strong> should require CB&I to establish and implement a labor policy and<br />

associated procedures for the Project construction that complies with IFC<br />

Performance Standard 2 on Labor and Work Conditions.<br />

Status: CB&I gave a presentation to Exponent on their labor policies and<br />

procedures. While CB&I’s policies and procedures comply with most<br />

requirements of Performance Standard 2, they did not have a written projectspecific<br />

Workers’ Grievance Mechanism at that time. This plan is currently<br />

in process and expected to be complete by the end of July 2011. Also, a<br />

written summary of workers’ health insurance information and the<br />

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1101335.000 04F1 0611 MJ21<br />

<strong>Colombia</strong>n health programs that workers contribute to was provided to<br />

Exponent.<br />

11. <strong>Reficar</strong> should work with CB&I to develop and implement a Construction<br />

Worker Housing Plan and a Construction Traffic Management Plan.<br />

Status:<br />

a.) For the status of the Construction Worker Housing Plan, refer to<br />

Section 1.(b) above; and<br />

b.) <strong>Reficar</strong> and CB&I have implemented a Construction Traffic Management<br />

Plan for the construction phase of the project (see Section 6.2.4). For the<br />

Operations Phase, <strong>Reficar</strong> will need to update the plan to include<br />

procedures for the truck transportation of pet-coke from the plant;<br />

Exponent recommends that this plan be presented to the Senior Lenders<br />

for their approval prior to commencement of Operations.<br />

12. An EHS Management System for the <strong>Refinery</strong> <strong>Expansion</strong> should be<br />

developed and implemented, by expanding and updating the existing<br />

<strong>Cartagena</strong> <strong>Refinery</strong> EHS management system, in order to be fully consistent<br />

with ISO 14001 and OSHAS 18001.<br />

Status: Refer to Section 9 above for information on the Construction Phase<br />

EHS Management System. Exponent recommends that <strong>Reficar</strong>’s EHS<br />

Management System for the Operations Phase be submitted to the Senior<br />

Lenders for their approval prior to the commencement of the Operations<br />

Phase.<br />

13. <strong>Reficar</strong> needs to complete the pending environmental studies and obtain the<br />

necessary governmental permits and authorizations for the Project port<br />

facility and the selected raw material delivery option (Coveñas Option or<br />

New Coke Jetty and Storage Option).<br />

Status:<br />

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1101335.000 04F1 0611 MJ21<br />

Coveñas Option: To the extent applicable, any permitting for the new<br />

pipeline and terminal facilities in Coveñas will be the responsibility of<br />

Ecopetrol who will own and operate these logistic facilities.<br />

New Coke Jetty and Storage Option: While <strong>Reficar</strong> had the Port EIA<br />

prepared in 2009, and an environmental license was granted (Resolution 511,<br />

March 2010), its Board of Directors has recommended that <strong>Reficar</strong> evaluate<br />

the alternative of not building the marine terminal and instead constructing<br />

only stand-alone truck facilities for the export of the coke, which may be<br />

shipped by truck to two existing ports nearby. <strong>Reficar</strong> plans to complete its<br />

evaluation of the two shipping options as soon as possible. Therefore, no<br />

further environmental studies, permits, or authorizations should be required<br />

for the port facility.<br />

With or without the port facility, the possibility of using both covered and<br />

open storage for the coke is being evaluated. Each option will take into<br />

consideration stormwater contact, dust, water treatment, wetting, and other<br />

handling and environmental factors that are outlined by the IFC EHS<br />

Guidelines for Petroleum Refining. IFC has confirmed that while covered<br />

storage is a good practice mitigation measure, it is not required.<br />

14. <strong>Reficar</strong> needs to present a plan to properly perform the dredging operations<br />

associated with the port/dock work, including assessment of sediment<br />

confirmation and specific method and location for disposal of dredge spoils.<br />

If the final design for the port/dock construction requires the loss of any<br />

mangroves, then <strong>Reficar</strong> should present a plan to reestablish an appropriate<br />

number of lost trees.<br />

Status: The dredging plan was included in the Port EIA. The dredging plan<br />

has been reviewed and all permits have been approved. Compensation plans<br />

for tree and mangrove removals have been prepared and submitted; EPA<br />

<strong>Cartagena</strong> and the MoE have awarded the permit for removal of mangroves.<br />

As discussed under Section 13 above, <strong>Reficar</strong> is evaluating the alternative of<br />

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1101335.000 04F1 0611 MJ21<br />

not building the marine terminal and instead constructing only stand-alone<br />

truck facilities for the export of the pet-coke, so further dredging may not be<br />

required (<strong>Reficar</strong> will make its decision by the end of May 2011). The<br />

dredge spoils (approximately 20,000 cubic meters) for the Ro-Ro dock<br />

dredging are located in the area to the west of the WWTP.<br />

Final details on the compensation plan are pending recommendation by the<br />

City of <strong>Cartagena</strong>. The coke and sulfur facility is pending review by the<br />

Board. If the Board proceeds with construction of the coke and sulfur dock<br />

facility, the compensation plan for proposed mangrove cut in this area<br />

(approximately 2,500 m 2 ) will need to be approved by the City of <strong>Cartagena</strong>.<br />

15. <strong>Reficar</strong> should explore with other major industries in the Mamonal industrial<br />

Area and CARDIQUE the development and implementation of an ambient<br />

air quality monitoring program.<br />

Status: Now that <strong>Reficar</strong> has established its own Project site-specific<br />

ambient air quality monitoring program, it would be beneficial for <strong>Reficar</strong> to<br />

explore with other major industries in the Mamonal Industrial Area and<br />

CARDIQUE the possibility of developing and implementing a cumulative<br />

ambient air quality monitoring program for the area.<br />

90<br />

June 21, 2011<br />

In the 2009 ESDD Report the following recommendations were made, and are associated with<br />

the timing of Project financing:<br />

� Prior to consideration of internal lender final/credit approvals:<br />

� Supplemental information on air quality modeling in form and<br />

substance acceptable to lenders demonstrating that the Project will<br />

comply with applicable <strong>Colombia</strong>n requirements, IFC EHS General<br />

Guideline and IFC EHS Petroleum Refining Guideline.<br />

Status: The detailed engineering has begun and it is scheduled to be<br />

completed by year-end. The modeling program may begin once the<br />

detailed engineering is completed, and the program will be completed


1101335.000 04F1 0611 MJ21<br />

prior to commencement of the operations period. Exponent received a<br />

copy of the proposal and confirms that it is in compliance with the<br />

recommendations included in Table 7 (see Sections 5.2.1 and 8.2.1 (a)).<br />

� Information in form and substance acceptable to lenders<br />

demonstrating how the Project will comply with the following:<br />

(a) SOx emission limit in IFC EHS Guideline for Petroleum Refining<br />

Status: Satisfied.<br />

and<br />

(b) the 0.2 mg/L limit for phenol in the wastewater discharge<br />

Status: Satisfied.<br />

� Information on how material Project-related environmental costs will<br />

be paid.<br />

Status: Satisfied.<br />

� Prior to financial closing:<br />

� Corrective Action Plan in form and substance satisfactory to lenders<br />

to address environmental liabilities.<br />

Status: Satisfied.<br />

� Revised ESMP including a construction worker housing plan and a<br />

construction traffic management plan.<br />

Status: Worker Housing Plan is still in process.<br />

� Plan to provide economic opportunities to the local population during<br />

Project construction, especially for those populations in the immediate<br />

vicinity of the refinery.<br />

Status: Satisfied.<br />

� If necessary, an Action Plan to comply with lender environmental and<br />

social requirements (e.g., Equator Principles, etc.) to the extent that<br />

(a) the associated requirements are not established in Project<br />

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1101335.000 04F1 0611 MJ21<br />

financing documentation (e.g., loan agreement) or (b) there are<br />

pending actions to comply with the associated requirements.<br />

Status: See Section 8.5 for recommended Lender Action Plan.<br />

� Include as part of the financing documentation (a) a list of the Project-<br />

specific air, wastewater, and noise standards or limits required by the<br />

lenders; and (b) the proposed minimum elements (i.e., parameters,<br />

frequency, locations) of the Project environmental monitoring<br />

program during construction and operation for air emissions, ambient<br />

air and water, wastewater discharges, groundwater, and noise.<br />

Status: This is the Lenders’ responsibility.<br />

� Implement some form of public consultation with the local population<br />

regarding the final results of the EIA and supplemental information<br />

regarding air quality impacts, construction traffic, and constructionworker<br />

housing.<br />

Status: Satisfied. An active public consultation and disclosure<br />

program has been in place since 2008, and was expanded in 2010<br />

after the hiring of the Director of Corporate Affairs.<br />

� Plan for a greenhouse-gas management program that is acceptable to<br />

the lenders, and should include estimated GHG emissions during<br />

operations, measures to minimize GHG emissions, and measures to<br />

offset Project-related GHG emissions.<br />

Status: <strong>Reficar</strong> has an inventory of GHG future emissions, and also<br />

is applying for Carbon Credits for some parts of the Project (measures<br />

to minimize GHG emissions) (see for Table 16). No plan for<br />

offsetting 100% GHG emissions is contemplated, and <strong>Reficar</strong><br />

requests that the Senior Lenders advise to what extent GHG offsetting<br />

is required. Air modeling and monitoring reporting will provide<br />

further discussion of GHGs.<br />

92<br />

June 21, 2011


� Prior to first disbursement:<br />

1101335.000 04F1 0611 MJ21<br />

� Detailed construction ESMP and an HSP that provide a complete set<br />

of all Project-related requirements, including at a minimum those in:<br />

(a) the government-approved Project EIA and ESMP; (b) the update<br />

of the ESMP to reflect recommendations including those presented<br />

herein; (c) the requirements for Project environmental authorization<br />

by MAVDT; (d) any other applicable regulatory requirements; and (e)<br />

applicable requirements in the EPC contract.<br />

Status: Satisfied. The Revised ESMP has been received by<br />

Exponent.<br />

� Designate Project-related EHS staff for <strong>Reficar</strong> and CB&I, and<br />

specify their responsibilities.<br />

Status: Satisfied. EHS management for both <strong>Reficar</strong> and CB&I<br />

were introduced to Exponent during our site visit and we received<br />

presentations on their job responsibilities, along with an EPC-EHS<br />

organization chart for construction (see Figure 7).<br />

� Applicable governmental environmental regulatory approvals for<br />

(a) the port/terminal expansion works and operations, and (b) to the<br />

extent applicable, for the new pipeline and terminal facilities in<br />

Coveñas.<br />

Status: (a) All approvals have been received for the new port<br />

facilities, and (b) any permitting required for the new pipeline and<br />

terminal facilities in Coveñas will be the responsibility of Ecopetrol<br />

who will own and operate these logistic facilities.<br />

� Prior to initiation of refinery expansion operations:<br />

� <strong>Reficar</strong> should develop, in form and substance acceptable to lenders,<br />

and implement: (a) an Environmental and Social Management Plan<br />

and an Environmental Management System that is consistent with<br />

ISO 14001; (b) a Waste Management Plan that integrates all non-<br />

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1101335.000 04F1 0611 MJ21<br />

hazardous and hazardous waste generation, storage, treatment and<br />

disposal procedures and is consistent with IFC EHS General<br />

Guidelines (section 1.6 on waste management); (c) a Health and<br />

Safety Plan and a Health and Safety Management System that is<br />

consistent with OSHAS 18001; and (d) a Contingency/Emergency<br />

Plan and Spill Prevention and Response Plan that are based upon the<br />

results of Project-specific risk analysis (e.g., HAZOP, HRA, etc.) of<br />

the refinery expansion.<br />

Status: Satisfied (see Table 11 [the fichas under the ESMP that<br />

pertain to environmental programs] and the Health, Safety and<br />

Environmental Management System).<br />

� <strong>Reficar</strong> should develop a labor management plan for staffing the new<br />

refinery operations, including specifically the treatment of existing<br />

Ecopetrol personnel whom are working at the existing refinery.<br />

Status: Satisfied.<br />

In terms of Lender reporting and supervision, we recommend:<br />

� <strong>Reficar</strong> submit quarterly environmental and social compliance reports until<br />

1 year after Project technical completion, and annually thereafter for the life<br />

of the loan.<br />

� Lender independent quarterly site reviews during construction and first year<br />

of operation, semi-annually during second year of operation, and annually<br />

thereafter for the life of the loan.<br />

8.3 Additional Recommendation from 2011<br />

� Provide an update on the Archeology Prevention Program, and the Chance<br />

Find Procedures that will be in place during the Project’s Construction Phase.<br />

Status: The archeologist last visited the Project site in December 2010, and<br />

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1101335.000 04F1 0611 MJ21<br />

is preparing the final report, which will be submitted to <strong>Reficar</strong> by April 30,<br />

2011. Exponent recommends that this report be presented to the Senior<br />

Lenders for their approval prior to Financial Close.<br />

95<br />

June 21, 2011<br />

8.4 Assessment of Compliance with International Guidelines<br />

8.4.1 The Equator Principles<br />

� It is our understanding that, in the event the project financing includes a<br />

Tranche B, the lead commercial bank who will participate in the financing<br />

will determine the Project’s Category prior to financial close (Principle 1).<br />

� As stated above, <strong>Reficar</strong> has prepared a Project EIA and a Port EIA<br />

(Principle 2); however, there are some impacts that were not adequately<br />

assessed in the Project EIA (see “Environmental and Social Impact<br />

Assessment” below for details).<br />

� The applicable social and environmental standards have been identified and<br />

include the IFC Performance Standards, IFC Environmental Health and<br />

Safety Guideline for Petroleum Refining, and IFC Environmental Health and<br />

Safety General Guidelines (Principle 3).<br />

� While no one formal Project Action Plan has been established per se, there<br />

are various environmental, social, and health and safety mitigation and<br />

monitoring systems, and plans and procedures for the Project construction<br />

and operation (Principle 4). However, there are some identified<br />

recommendations related to these systems, plans, and procedures (for details<br />

see “Environmental and Social Management Plan” below and Table 11).<br />

� An ongoing Public Consultation and Disclosure program is in place (see<br />

Section 7 for summary, and also Table 11, FICHA OP R1-2 in the Revised<br />

ESMP) (Principle 5).


� A grievance mechanism was established as part of the Project EIA ESMP<br />

1101335.000 04F1 0611 MJ21<br />

(see Section 7, and also Table 11, FICHA OP R1-6 in the Revised ESMP)<br />

(Principle 6).<br />

� This environmental and social due-diligence report reflects an independent<br />

review (Principle 7).<br />

� The Lenders will need to establish applicable covenants for the Project<br />

(Principle 8), based in part on this environmental and social due diligence.<br />

� We recommend (see Section 8.2 for details) independent monitoring and<br />

review (Principle 9) and borrower/Project reporting to the lenders<br />

(Principle 10).<br />

8.4.2 IFC Performance Standards<br />

96<br />

June 21, 2011<br />

The review indicates that the following Performance Standards are applicable to this project:<br />

� PS1–Social and Environmental Assessment and Management Systems<br />

� PS2–Labor and Working Conditions<br />

� PS3–Pollution Prevention and Abatement<br />

� PS4–Community Health and Safety<br />

� PS6–Biodiversity Conservation and Sustainable Natural Resource<br />

Management<br />

� PS8–Cultural Heritage.<br />

The Project does not trigger PS5–Land Acquisition and Involuntary Resettlement.<br />

Implementation of the Project will not require change in land use or any resettlement, because<br />

Ecopetrol already owned the land on which the Project is being developed.


1101335.000 04F1 0611 MJ21<br />

97<br />

June 21, 2011<br />

PS7–Indigenous Peoples, was also not triggered, because, according to the EIA, there are no<br />

indigenous people living in the Project’s Indirect Area of Influence.<br />

No significant impacts are anticipated related to natural habitats, endangered or economically<br />

important flora or fauna (PS6), or cultural or archeological sites (PS8).<br />

It is our understanding that the US Ex-Im Bank, <strong>EKN</strong>, and SACE have classified the Project as<br />

a Category A, per the OECD Common Approaches; and Exponent confirms the Category A<br />

categorization per the OECD Common Approaches.<br />

In terms of the IFC Performance Standards, and EHS Petroleum Refining sector and General<br />

Guidelines, no material non-compliance issues were identified, with the exception of the<br />

following (see Section 8.2 for recommendations to address these deficiencies):<br />

� PS1—Social and Environmental Assessment and Management Systems<br />

� Environmental and Social Impact Assessment. Supplemental Project<br />

environmental and social impact analysis/information is needed on:<br />

(a) Project-specific and cumulative air quality impacts (see Table 7<br />

for issues with existing air quality modeling); and (b) influx<br />

management. Once the new impact modeling is performed, it will be<br />

disclosed as requested by the lenders.<br />

� Environmental and Social Management Plan. The Revised ESMP<br />

needs to be further modified to correct some remaining deficiencies<br />

(see Table 11 for recommendations). Eventually, <strong>Reficar</strong> will need to<br />

update the construction phase mitigation and monitoring plans and<br />

procedures (the operations fichas in the Revised ESMP) for the<br />

Project’s operation phase.<br />

� <strong>Reficar</strong> does not have a plan to address an unexpected influx of<br />

people looking for jobs at the refinery. <strong>Reficar</strong> and CB&I plans to<br />

provide craft training and hire a peak workforce of approximately


1101335.000 04F1 0611 MJ21<br />

7,000 for the construction, which will include training and hiring of<br />

people from other areas in <strong>Colombia</strong>, which should minimize this<br />

risk.<br />

� PS2—Labor and Working Conditions<br />

� CB&I’s policies and procedures comply with most requirements of<br />

Performance Standard 2, but they do not have a written projectspecific<br />

Workers’ Grievance Mechanism in place at the refinery<br />

where workers can locally express grievances. CB&I does have a<br />

Workers’ Grievance Mechanism at the Company’s headquarters in<br />

Houston, with Internet access and a toll free number that workers may<br />

call.<br />

� Under CB&I’s EPC Contract there is a Construction Worker Housing<br />

Plan that includes procedures to obtain housing for Expatriate workers<br />

and workers from other parts of <strong>Colombia</strong>, but the plan does not<br />

include housing for workers from other countries in Latin America<br />

(OCNs). <strong>Reficar</strong> is studying the possibility of providing housing to<br />

these OCNs through nearby hotels/motels. <strong>Reficar</strong> is also considering<br />

constructing a social housing project, under an agreement with the<br />

local government, to house these workers throughout the construction<br />

period; <strong>Reficar</strong> would donate the housing facility to the local<br />

government once the construction of the project is complete.<br />

� PS3—Pollution Prevention and Abatement<br />

� The Project design documents confirm that the Project will meet IFC<br />

and <strong>Colombia</strong>n National guidelines for air emissions. However, due<br />

to the incomplete air quality impact/modeling assessment, it is unclear<br />

at present whether the Project will meet applicable ambient air quality<br />

standards. Current plans call for air dispersion modeling with<br />

additional sampling which will be undertaken to confirm that air<br />

quality in compliance with PS3 is met at the Site. The detailed<br />

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June 21, 2011


1101335.000 04F1 0611 MJ21<br />

engineering has begun for the Air Dispersion Modeling Program and<br />

it is scheduled to be completed by year-end. The modeling program<br />

may begin once the detailed engineering is completed.<br />

� There is no plan for GHG management. <strong>Reficar</strong> has an inventory of<br />

GHG future emissions, and is also applying for Carbon Credits for<br />

some parts of the Project (measures to minimize GHG emissions).<br />

No plan for offsetting 100% GHG emissions is contemplated, and<br />

<strong>Reficar</strong> requests that the Senior Lenders advise to what extent GHG<br />

offsetting is required.<br />

� <strong>Reficar</strong>’s commitment that air modeling will take place for the<br />

refinery operation, along with the environmental management plans<br />

included in the Revised ESMP, and contractor process guarantees<br />

ensure that the Project will be in compliance with IFC PS3 (Pollution<br />

Prevention and Abatement).<br />

� PS4—Community Health, Safety, and Security<br />

� <strong>Reficar</strong> has a Community, Health, Safety, and Security program (see<br />

FICHA OP R1-5), but Exponent has not received any information on<br />

the history of the program, or emergency drills that may have taken<br />

place.<br />

8.4.3 IFC EHS Guidelines<br />

99<br />

June 21, 2011<br />

The Project via the EIA and ESMP is also compared against the IFC EHS Guidelines. Most of<br />

these issues are already addressed in the sections above related to Performance Standards 1−4,<br />

while others can only be properly assessed through site visits during the construction phase and<br />

monitoring after commencement of operations.<br />

The two applicable IFC Guidelines are the IFC EHS General Guidelines and the EHS<br />

Guidelines for Petroleum Refining.


8.4.3.1 IFC EHS General Guidelines<br />

The EHS General Guidelines provide specific technical guidance to assist in achieving<br />

1101335.000 04F1 0611 MJ21<br />

100<br />

June 21, 2011<br />

conformance with Good International Industry Practice in four main areas: i) the environment,<br />

ii) worker Health and Safety (H&S), iii) community H&S, and iv) construction and<br />

decommissioning.<br />

Table 17 provides an assessment of the content and scope of the EIA with reference to the IFC’s<br />

EHS General Guidelines. The “Recommended Follow-Up” column is provided to ensure that<br />

these requirements are taken into account in the planning process in anticipation of the<br />

operational phase.<br />

8.4.3.2 IFC EHS Guidelines for Petroleum Refining<br />

Table 18 provides an assessment of the content and scope of the EIA with reference to IFC’s<br />

EHS Guidelines for Petroleum Refining. A number of these requirements are more relevant to<br />

the construction and operational phases of the Project and can only be properly assessed through<br />

field visits. The “Recommended Follow-Up” column is provided to ensure that these<br />

requirements are taken into account in the planning process in anticipation of the operational<br />

phase.<br />

8.5 Recommended Lender Action Plan<br />

8.5.1 Prior to Financial Close<br />

Air Emission Standards Waiver from CARDIQUE<br />

Waiver from CARDIQUE to delay compliance with the air emission standards for the existing<br />

refinery that are effective July 2010 until the new refinery expansion is completed to be<br />

presented to the Senior Lenders for their approval prior to Financial Close, or when available<br />

from CARDIQUE.


New Coke Jetty and Storage Option<br />

1101335.000 04F1 0611 MJ21<br />

101<br />

June 21, 2011<br />

The <strong>Reficar</strong> Board of Director’s decision, after evaluating the two shipping options for coke, to<br />

be presented to the Senior Lenders prior to Financial Close.<br />

<strong>Reficar</strong>’s decision, after evaluating the possibility of using both covered and open storage for<br />

the coke, in accordance with the recommended pollution prevention and minimization measures<br />

included in the EHS Guidelines for Petroleum Refining, Section 1.1 Environmental, sub-section<br />

Air Emissions: Particulate Matter, to be presented to the Senior Lenders prior to Financial<br />

Close.<br />

CB&I Workers’ Grievance Mechanism<br />

A written Project-specific Workers’ Grievance Mechanism with procedures for construction<br />

workers to register grievances at the refinery, time limits to respond to inquiries and grievances,<br />

and record keeping, to be presented to the Senior Lenders for their approval prior to Financial<br />

Close.<br />

Community Health, Safety, and Security<br />

Details on the history of the Project’s Community, Health, Safety, and Security program<br />

(FICHA OP R1-5), including emergency drills, to be presented to the Senior Lenders prior to<br />

Financial Close.<br />

A Crisis Manual is in development currently, to be presented to the Senior Lenders prior to<br />

Financial Close.<br />

8.5.2 Prior to Initial Disbursement<br />

Environmental and Social Management Plan<br />

Revised ESMP programs, correcting the remaining deficiencies (see Table 11 for recommendations),<br />

to be presented to the Senior Lenders for their approval prior to Initial Disbursement.


Compensation Plan for Mangrove Removals<br />

1101335.000 04F1 0611 MJ21<br />

102<br />

June 21, 2011<br />

If <strong>Reficar</strong>’s Board of Directors elects to proceed with construction of the coke and sulfur dock<br />

facility, the compensation plan for proposed mangrove cut in this area (approximately 2,500 m 2 )<br />

will need to be approved by the City of <strong>Cartagena</strong>. This process can take up to 6 months. If the<br />

plan is required, it will be presented to the Senior Lenders for their approval, and the Senior<br />

Lenders will revise the Action Plan to include the deadline for submission.<br />

Construction Worker Housing Plan<br />

Final Worker Housing Plan, including procedures for housing workers from other countries in<br />

Latin America, to be presented to the Senior Lenders for their approval prior to Initial<br />

Disbursement.<br />

Influx Management Plan<br />

A contingency plan to manage any unexpected influx of people to the area looking for jobs, to<br />

be developed in collaboration with local government authorities, to be presented to the Senior<br />

Lenders for their approval prior to Initial Disbursement.<br />

Greenhouse Gas Management<br />

Greenhouse gas management plan, which includes estimated GHG emissions during operations,<br />

measures to minimize GHG emissions, and measures to offset Project-related GHG emissions,<br />

to be presented to the Senior Lenders for their approval prior to Initial Disbursement.<br />

Archeology Preventive Program<br />

The archeologist’s final report, to be presented to the Senior Lenders for their approval prior to<br />

Initial Disbursement.


8.5.3 Prior to Commencement of the Operations Phase<br />

Environmental and Social Management Plan<br />

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103<br />

June 21, 2011<br />

The Construction Phase plans and procedures that will be applicable to the Operations Phase<br />

(the OP fichas in the Revised ESMP), to be updated if necessary and presented to the Senior<br />

Lenders for their approval prior to commencement of the Operations Phase.<br />

EHS Management System<br />

The EHS Management System for the Operations Phase, to be submitted to the Senior Lenders<br />

for their approval prior to the commencement of the Operations Phase.<br />

Air Dispersion Modeling Program<br />

Results of the Air Dispersion Modeling Program, demonstrating that the Project will comply<br />

with applicable <strong>Colombia</strong>n requirements for ambient air quality, IFC EHS General Guidelines,<br />

and EHS Guidelines for Petroleum Refining, to be presented to the Senior Lenders for their<br />

approval prior to the commencement of the Operations Phase.<br />

EHS Action Plan 2011 (Corrective Action Plan)<br />

An updated EHS Action Plan, providing the status of all environmental liabilities identified in<br />

the Phase 1 and Phase 2 ESAs, to be presented to the Senior Lenders for their approval prior to<br />

commencement of the Operations Phase.<br />

Traffic Management Plan<br />

Traffic Management Plan for the Operations Phase, which will include a plan for the truck<br />

transportation of coke, to be presented to the Senior Lenders for their approval prior to<br />

commencement of the Operations Phase.


Tables


Table 1a. Data/information reviewed associated with 2011 environmental and social due<br />

diligence for the updated ESDD report<br />

Key Project Documents<br />

� Environmental Licenses and Permits<br />

� Environmental License–Year 2000<br />

� Resolution 349-280207 Partial Transfer of the Environmental License<br />

� Resolution 2102-281108 Modification License<br />

� Resolution 0511-1-2010 MAVDT–Modification License to include new port facilities<br />

� Port EIA<br />

� EPC Contract<br />

� Revised Environmental Social Management Plan<br />

Environmental<br />

� Environmental Aspects of the Project Presentation to Exponent<br />

� Corrective Action Plan–EHS Action Plan 2011<br />

� CB&I Construction Environment Management Plan<br />

� Compensation Plans<br />

� Mangroves: Anexo D- VO-002-11 Carta al EPA <strong>Cartagena</strong><br />

� Trees: Resolución 260 de 2009–Aclaracion compensacion forestal <strong>Reficar</strong><br />

� Air Quality<br />

� Air Emissions–Dispersion Modeling Scope of Work<br />

� Waste Water Discharge Sampling/Monitoring Data 2008-2011<br />

� Effluent Results: Vertimientos GRC–Quarters 1 to 4, 2010<br />

� Waste Water Treatment<br />

� Siemens Technical Proposal to Supply Raw Water and Wastewater Treatment<br />

Equipment and Services<br />

� Updated Waste Generation and Disposal Documentation<br />

� Generación RSI–Data on industrial sold waste generated at <strong>Reficar</strong> (2008-2010)<br />

� GRC-CRP-M-0004.Capitulo 2 Manual for the Handling of Domestic Waste at <strong>Reficar</strong><br />

� GRC-CRP-M-0004.Capitulo 3 PGIRHS Manual for the Handling and Disposal of<br />

Industrial Solid Waste at <strong>Reficar</strong><br />

� GRC-CRP-M-0004–Integrated Waste Management Manual<br />

� Energy Consumption<br />

� Estimated Total Energy and Electric Power Consumption during Operation<br />

Labor and Working Conditions<br />

� CB&I Construction Operation Support Presentation to Exponent<br />

� <strong>Reficar</strong> and CB&I Craft Training Program Presentation to Exponent<br />

� Work Regulations of CB&I <strong>Colombia</strong>na<br />

� <strong>Reficar</strong> Employment Contracts<br />

� Form of individual employment contract with indefinite term and Integral Salary for<br />

positions in management, operations, and trust<br />

� Form of individual employment contract with indefinite term and Ordinary (regular) Salary<br />

for positions in management, operations, and trust<br />

� CB&I Employment Contracts<br />

� Form of indefinite term employment contract with Integral Salary for Expat management<br />

and trust personnel<br />

1101335.000 04F1 0611 MJ21


Table 1a. (cont.)<br />

� Form of indefinite term employment contract with Integral Salary for management and<br />

trust personnel<br />

� Form of indefinite term employment contract with Ordinary (regular) Salary for<br />

management and trust personnel<br />

� Form of term employment contract with Ordinary Salary for identified work or activity by<br />

regular staff<br />

� <strong>Reficar</strong> Health and Life Insurance Programs for Workers<br />

� CB&I Workers’ Health Insurance and Grievance Mechanism<br />

Health, Safety, and Security<br />

� <strong>Reficar</strong> HSE Safety Training Presentation to Exponent<br />

� <strong>Reficar</strong> HSE Management System Presentation to Exponent<br />

� <strong>Reficar</strong> HSE Policy<br />

� <strong>Reficar</strong> and CB&I HSE Project Management System<br />

� <strong>Reficar</strong> and CB&I Traffic Management Plan<br />

Socio-Economic Conditions<br />

� Table of Communities in the Project’s Area of Influence<br />

� Socio-economic conditions in the nine closest communities<br />

� Map showing location of the nine communities<br />

Community Engagement<br />

� Public Consultation and Disclosure<br />

� History of meetings with the communities in 2010<br />

� Projections: Public Consultations (2011−2013)<br />

� <strong>Reficar</strong> Grievance Program Presentation to Exponent<br />

� <strong>Reficar</strong> Grievance Mechanism<br />

� Corporate Social Responsibility/Community Investment<br />

� Corporate Social Responsibility Program Presentation to Exponent<br />

� Description of current social programs<br />

� Projections: Positive Impacts on Workers and the City of <strong>Cartagena</strong><br />

� Projections: Social Investment/Corporate Responsibility (2011−2030)<br />

Archeology/Cultural Heritage<br />

� Archeological Report<br />

� Final Archeology Report (June 2008) by Judith Hernández Bacca<br />

� Archeology Monitoring License no. 1382 (December 2009) from ICANH<br />

� Anexo 1–Approval Application to ICANH (December 2010)<br />

1101335.000 04F1 0611 MJ21


Table 1b. Data/information reviewed associated with 2009 environmental and social due<br />

diligence for the initial ESDD report<br />

� Project EIA<br />

� Health, Safety, Security, and Environmental Management System for the <strong>Cartagena</strong> <strong>Refinery</strong> <strong>Expansion</strong> Project<br />

� HSSE Assessments for the <strong>Cartagena</strong> <strong>Refinery</strong> <strong>Expansion</strong> Project<br />

� <strong>Cartagena</strong> <strong>Refinery</strong> HSE Management System Manual<br />

� <strong>Cartagena</strong> <strong>Refinery</strong> Contingency Plan<br />

� Phase 1 ESA of <strong>Cartagena</strong> <strong>Refinery</strong><br />

� Phase 2 ESA of <strong>Cartagena</strong> <strong>Refinery</strong><br />

� Waste generation and disposal documentation<br />

� Computer files for air quality modeling: model inputs (including emissions data and stack parameters) and<br />

model outputs, meteorological data<br />

� Site visit presentations<br />

� List of environmental and worker safety accidents (2004−2008)<br />

� Breakdown on CAPEX for 2002–2009, for the $47.9 million for HSE and $3.7 million for environment<br />

� HSE Action Plan for 2008–2011<br />

� List of plants and animals found during site clearing (for new expansion Project)<br />

� Various EHS governmental resolutions for existing refinery<br />

� Agreement between Ecopetrol and Glencore<br />

� Contract for use of port<br />

� Socio-economic and environmental viability study for Zona Franca with <strong>Cartagena</strong> <strong>Refinery</strong><br />

� Example contract for existing refinery workers<br />

� Wastewater discharge sampling/monitoring data<br />

� Estudio de disponibilidad de mano de obra<br />

� Matiz de gestión de peligros y aspectos significativos<br />

� Energy Efficiency Study<br />

� Procedure for existing landfarming<br />

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Table 2. Project-related air emission standards<br />

Parameter<br />

1101335.000 04F1 0611 MJ21<br />

<strong>Colombia</strong>n Resolution 909 (2008)<br />

Combustion Equipment<br />

Associated with Petroleum<br />

Refining Process Equipment<br />

Existing<br />

Installations<br />

New<br />

Installations<br />

Solid Gas<br />

Particulate material 170 --<br />

Existing<br />

Installations<br />

Sulfur<br />

Plant Other<br />

New<br />

Installations<br />

Gas Turbines with<br />

Capacity Equal or<br />

Greater Than<br />

20 MW<br />

Existing and New<br />

Installations<br />

Sulfur<br />

Plant Others Gas<br />

6% Oxygen 3% Oxygen 11% Oxygen 15% Oxygen<br />

0.5 kg/h: 50 --<br />

SO2 2,800 -- 1,600 550 900 500 --<br />

NOx 760 300 550 500 120<br />

HF -- 8 --<br />

HCL -- 40 --<br />

Total hydrocarbons -- 50 --<br />

Dioxins and furans -- 0,5 ng-EQT/m 3 --<br />

Acid rain of SO3<br />

(expressed as<br />

H2SO4)<br />

-- 150 --<br />

Pb -- 1 --<br />

Cd -- 1 --<br />

Cu -- 8 --<br />

COV, CO, Hg, NH3,<br />

H2S y mercaptans,<br />

COT<br />

-- Monitor --<br />

IFC EHS Guideline for<br />

Petroleum Refining (2007)<br />

Pollutant Air Emission Standard a<br />

150 mg/Nm<br />

Sox<br />

3 for sulfur<br />

recovery units<br />

500 for other units<br />

NOx 450 mg/Nm 3<br />

PM 50 mg/Nm 3<br />

Vanadium 5 mg/Nm 3<br />

Nickel 1 mg/Nm 3<br />

H2S 10 mg/Nm 3<br />

a<br />

Emission levels are expressed at dry gas at<br />

3 percent O2.


1101335.000 04F1 0611 MJ21<br />

Table 3. Project-related ambient air quality limits<br />

Pollutant<br />

Averaging<br />

Period<br />

<strong>Colombia</strong>n<br />

Resolution<br />

601 (2006)<br />

SO2 3 hour 750<br />

24 hours 250<br />

Annual 80<br />

NO2 1 hour NA<br />

24 hours 150<br />

Annual 100<br />

Ozone (O3) 1 hour 120<br />

8 hours 80<br />

Total suspended particulates 24 hours 300<br />

Annual 100<br />

Particulates (PM10) 24 hours 150<br />

Annual 70<br />

Particulates (PM2.5) 24 hours NA<br />

Annual NA<br />

Carbon monoxide 1 hour 40,000<br />

8 hours 10,000<br />

Ammonia 8 hours 14.5<br />

Hydrogen sulfide 8 hours 7<br />

Benzene Annual 5<br />

Total hydrocarbons (as methane) 4 months 1.5<br />

Toluene Weekly 260<br />

Vanadium 24 hours 1<br />

Methyl mercaptan 0.7<br />

Ethyl mercaptan 0.06<br />

Note: All concentrations in this table are expressed in µg/m 3 .


1101335.000 04F1 0611 MJ21<br />

Table 4. Project-related wastewater discharge limits<br />

Parameter<br />

CARDIQUE 1594<br />

(1994)<br />

IFC EHS<br />

Guideline for<br />

Petroleum<br />

Refining (2007)<br />

IFC EHS<br />

General<br />

Guideline (2007)<br />

pH 5–9 6−9 6−9<br />

Temperature < 40°C < 3°C increase<br />

BOD5 80 percent removal 30 mg/L<br />

Chemical oxygen demand 150 mg/L<br />

Total suspended solids 80 percent removal 30 mg/L<br />

30 mg/L<br />

125 mg/L<br />

50 mg/L<br />

Oil and grease 80 percent removal 10 mg/L 10 mg/L<br />

Chromium (total) 0.5 mg/L<br />

Chromium (hexavalent) 0.5 mg/L 0.05 mg/L<br />

Copper 0.5 mg/L<br />

Iron 3 mg/L<br />

Cyanide (total) 1 mg/L 1 mg/L<br />

Cyanide (free) 0.1 mg/L<br />

Lead 0.5 mg/L 0.1 mg/L<br />

Nickel 1 mg/L 0.5 mg/L<br />

Mercury 0.02 mg/L 0.02 mg/L<br />

Vanadium 1 mg/L<br />

Phenol 0.2 mg/L 0.2 mg/L<br />

Benzene 0.05 mg/L<br />

Benzo[a]pyrene 0.05 mg/L<br />

Sulfides 1 mg/L<br />

Total nitrogen 10 mg/L a 10 mg/L<br />

Total phosphorus 2 mg/L 2 mg/L<br />

Arsenic 0.5 mg/L<br />

Total coliform bacteria 400 MPN<br />

a Maybe up to 40 mg/L if process includes hydrogenation.


1101335.000 04F1 0611 MJ21<br />

Table 5. Project-only air quality modeling predicted maximum<br />

concentrations resulting from existing and proposed<br />

<strong>Cartagena</strong> refinery operations<br />

Parameter<br />

PM10<br />

SO2<br />

NO2<br />

Averaging<br />

Period<br />

Note: Units are in µg/m 3 .<br />

Current <strong>Refinery</strong><br />

Operations<br />

Proposed<br />

<strong>Refinery</strong><br />

<strong>Expansion</strong><br />

Operations<br />

Permissible<br />

Limit<br />

(Resolution<br />

601, 2006)<br />

24-hour 27 7 150<br />

Annual 8 2 70<br />

3-hour 37 37 750<br />

24-hour 13 15 250<br />

Annual 4 4 80<br />

1-hour 37 124 200<br />

24-hour 14 46 150<br />

Annual 4 12 100


1101335.000 04F1 0611 MJ21<br />

Table 6. Cumulative air quality modeling predicted maximum<br />

concentrations resulting from existing and proposed<br />

<strong>Cartagena</strong> refinery operations plus other sources in<br />

Mamonal area<br />

Parameter<br />

PM10<br />

SO2<br />

NO2<br />

Averaging<br />

Period<br />

Note: Units are in µg/m 3 .<br />

Current<br />

Mamonal<br />

Operations<br />

Future<br />

Mamonal<br />

Operations<br />

Permissible<br />

Limit<br />

(Resolution<br />

601, 2006)<br />

24-hour 876 876 150<br />

Annual 201 200 70<br />

3-hour 834 834 750<br />

24-hour 322 322 250<br />

Annual 75 76 80<br />

1-hour 3,005 3,005 200<br />

24-hour 1,068 1,068 150<br />

Annual 251 252 100


Table 7. Conclusions and recommendations related to Project air quality impact/<br />

modeling analysis<br />

Conclusions<br />

The extent and magnitude of Project impacts on ambient air quality (due both to the Project itself and to the<br />

cumulative impact of the Project and other air emission sources in the area) is not fully estimated due to limitations in<br />

the air quality modeling performed. Specific issues include:<br />

� The air quality model used was ISCST3. This model is no longer considered state-of-the-art and has been<br />

replaced with a newer model, AERMOD.<br />

� The basis for emission rates of PM10, SO2, and NOx are based on process guarantees to meet <strong>Colombia</strong>n<br />

and IFC standards but requires monitoring and modeling efforts as described previously. These are not<br />

clear in terms of being representative of the actual potential operation scenario for the refinery expansion,<br />

the EPC, and/or equipment guarantees, and the applicable <strong>Colombia</strong>n and IFC allowable emission rates.<br />

There are also discrepancies between information and the modeling (e.g., text mentions 27 new<br />

combustion sources and 12 new sources of particulate matter, but only 23 or 24 sources are listed in table;<br />

a total of 41 sources at the refinery are listed in the model outputs).<br />

� The initial modeling apparently used only 1 year of meteorological data which does not really provide a<br />

representative set of conditions.<br />

� The Project-only modeling results show a substantial increase in NO2 emissions from the refinery, with a<br />

corresponding increase in ambient NO2 impacts (by a factor of 3 or more). While predicted ambient NO2<br />

concentrations are within ambient limits, there is no consideration of whether or not the refinery expansion,<br />

which will consume more than half of the remaining NO2 increment, will constrain future growth in the area.<br />

CARDIQUE has mentioned that there are some projects under consideration, and IFC EHS guidelines have<br />

some potentially relevant limitations on the extent to which any single new or modified emissions source is<br />

allowed to consume the remaining air quality increment.<br />

� Due to the limited ambient air quality presented, there is a significant degree of uncertainty related to the<br />

actual existing baseline ambient air quality conditions in the Project area of influence, and hence, the<br />

overall Project impact (i.e., Project plus baseline existing conditions). For example, no actual ambient air<br />

quality data are reported in locations of likely maximum impact from the Project; data are available only<br />

from locations within the plant boundary and thus have limited representativeness in terms of assessing<br />

Project impacts.<br />

� No modeling was conducted for CO, heavy metals, PM2.5, or O3 precursor emissions quantification or<br />

modeling.<br />

� No modeling/analysis of fugitive emissions was performed.<br />

� The modeling of cumulative impacts (Project plus other sources) has several issues. The results showed<br />

significant exceedances of applicable air quality criteria. For example, the model-predicted PM10<br />

concentrations exceed applicable standards by a factor of 2 to 5, and the model-predicted NO2<br />

concentrations exceed applicable standards by a factor of 2 to 15. Also, the model-predicted<br />

concentrations are much higher than the limited monitoring data (by as much as a factor of 28 for 24-hour<br />

NOx values). There are no references or documentation for emissions from the other fixed sources in the<br />

Mamonal area that were modeled. The modeling outputs only identify these sources as “Industria<br />

Mamonal,” together with a generic identifier, “FTE” with a number. It is impossible to determine which<br />

sources are being modeled, or to assess the probable accuracy of the expected emission rates and<br />

parameters. There is no indication that growth, expansions, or anticipated modifications were included in<br />

the future-scenario modeling of other fixed sources in the Mamonal area.<br />

� The full degree of Project-only impact on the existing ambient air quality is not fully presented in the EIA<br />

(e.g., maximum estimated concentrations are only summarized). This will be evaluated in future modeling<br />

and monitoring efforts that will be presented in the future.<br />

1101335.000 04F1 0611 MJ21


Table 7. (cont.)<br />

Recommendations<br />

Based on our present understanding, additional air quality modeling will be required to more completely assess the<br />

potential Project air quality impacts. This effort is currently being evaluated by <strong>Reficar</strong> and will be performed by a<br />

consultant in the future. The future air modeling efforts should include or evaluate:<br />

� Modeling should be done with AERMOD, or at a minimum, adequate information (e.g., test-run<br />

comparisons) should be conducted to ensure that the modeling done with ISCST3 is consistent with<br />

AERMOD.<br />

� Modeling should be done with a more complete representative set of meteorological data or a statistical<br />

analysis performed that confirms the 1 year of data truly is representative.<br />

� Project-only modeling of all relevant fixed sources in the refinery expansion should be conducted using the<br />

appropriate emission limits (e.g., EPC or equipment manufacturer guaranteed emissions levels).<br />

� Project-only modeling of SOx emissions should be conducted for the full range of different feedstock<br />

scenarios for the Project (e.g., 1%, 1.5%, etc.).<br />

� Project-only modeling of NOx needs to include an evaluation of whether or not additional controls would be<br />

needed, such that the Project would not consume an unacceptable amount of the available airshed NOx<br />

ambient air quality limit.<br />

� Project-only modeling of fixed-source emissions should be performed for PM2.5, CO, and relevant heavy<br />

metals.<br />

� Project-only modeling of fugitive emissions and resultant air quality should be performed.<br />

� Cumulative modeling/analysis needs to be improved. This could include improved summary of existing<br />

baseline ambient air quality conditions by including data from CARDIQUE and collecting some samples in<br />

areas outside of the <strong>Refinery</strong> property (e.g., areas of predicted maximum impacts). This could also include<br />

improved documentation of emission rates and emission parameters for the additional sources modeled.<br />

1101335.000 04F1 0611 MJ21


1101335.000 04F1 0611 MJ21<br />

Table 8. Siemens proposal Table 3.4a


Table 9. Estimated waste generation during refinery expansion operations (from<br />

Project EIA)<br />

Waste Hazard Category<br />

1101335.000 04F1 0611 MJ21<br />

Estimated<br />

Quantity<br />

(per month) Handling<br />

FCC spent catalyst Non-hazardous 65 t Temporary storage and<br />

recycling by catalyst provider<br />

Spent catalyst (sulfur unit, etc.) Non-hazardous 50 t Landfarming onsite or recycling<br />

by catalyst provider<br />

Sludge of oil and soluble<br />

aromatics (Alkalation Plant)<br />

Potentially hazardous 158 t Re-use in refinery<br />

Oil sludge (maintenance, etc.) Potentially hazardous 580 m 3 Landfarming onsite<br />

Used oil and grease<br />

(maintenance)<br />

Hazardous 2.2 m 3 Recycling offsite waste service<br />

provider<br />

Materials contaminated with oils Potentially hazardous 1.5 t Offsite waste service provider<br />

Sludge (wastewater treatment<br />

plant)<br />

Recyclable materials (paper,<br />

wood, metal, etc.)<br />

Non-hazardous 575−1,007 m 3 Landfarming onsite or offsite<br />

waste service provider<br />

Non-hazardous 3.4 t Offsite recycling or waste<br />

disposal<br />

Food waste Non-hazardous 2.8 t Offsite disposal


Table 10. Social programs<br />

Health<br />

Urgency supplies and equipment of Arroz Barato´s hospital. Operator: Fundación Mamonal<br />

Construction of center for young poor women who get pregnant and need assistance.<br />

Operator: Fundación Mamonal<br />

Sexual education and birth control programs for young girls who do not have access to<br />

education. Operator: Actuar por Bolivar<br />

Integral domiciliary care for children in early childhood at marginalized sectors of <strong>Cartagena</strong>.<br />

Operator: ALUNA<br />

Education<br />

Community Leadership Training. Operator: Fundación Mamonal<br />

SENA Training Center<br />

INEM Training Center<br />

Training, education, and awareness on environment and emergency for the communities<br />

surrounding the Project. Operator: Fundación Mamonal<br />

School of Management for Public Schools Directors. Operator: Fundación Mamonal<br />

Media Training Technical Plastics Petrochemicals. CASD Manuela Beltran. Operator:<br />

Fundación Mamonal<br />

Training, Education and Environmental Awareness. Operator: Fundación Mamonal<br />

Housing<br />

Housing programs within poor communities. Operator: Actuar por Bolivar<br />

Loans for upgrading the housing of poor communities. Operator: Actuar por Bolivar<br />

Income and Work<br />

Education and improvement of small businesses within the nearby community. Operator:<br />

Actuar por Bolivar<br />

Inclusive business-urban agriculture and clothing. Operator: Fundación Mamonal<br />

Recovery of fishermen activity. Operator: Fundación Mamonal<br />

Productive patios. Operator: Fundación Granitos de Paz<br />

Sports<br />

Baseball training school for kids 9−18 years old of the nearby communities. Operator:<br />

Fundacion Mamonal<br />

Football training school for adolescence age 12−18 years old. Operator: Fundacion Mamonal<br />

Culture<br />

Musical group in Pasacaballos. Operator: Fundación Mamonal<br />

1101335.000 04F1 0611 MJ21


Table 11. 2009 Recommendations related to the Project EIA ESMP and current status of<br />

all programs under the Revised ESMP<br />

Ficha CO R1-1 (new)<br />

Installation, Operation/Maintenance, and Decommissioning of Temporary Construction Camp<br />

Objective: Minimize impacts from the installation, operation, and removal of the camp, workshop, and temporary<br />

storage sites for construction of the port.<br />

Ficha CO R1-2 (previously CO-1)<br />

Operation and Maintenance of Construction Vehicles, Machinery, and Equipment<br />

Objective: Establish, implement, and maintain the requirements and procedures for the proper management of<br />

selection and mobilization of vehicles, machinery, and equipment to be used in the expansion works and operation<br />

of <strong>Reficar</strong>.<br />

2009 Recommendation: More specific details (procedures, plan) are required regarding traffic management.<br />

Status: Satisfied.<br />

Ficha CO R1-3 (new)<br />

Management of Construction Materials, Fuels, and Chemicals<br />

Objective: Prevent poor management of building materials, fuels, and chemicals which might lead to negative<br />

effects on the environment and worker health.<br />

Ficha CO R1-4 (previously CO-5)<br />

Management of Solid Wastes<br />

Objective: Establish the requirements and procedures to manage solid waste from contractors to perform the<br />

expansion works at <strong>Reficar</strong> in compliance with technical and environmental standards.<br />

2009 Recommendation: Need to develop the Emergency Response Plan referenced (called for in the event of a<br />

spill).<br />

Status: Satisfied.<br />

Ficha CO R1-5 (previously CO-4)<br />

Management of Liquid Wastes<br />

Objective: Establish the requirements and procedures to handle the liquid waste from contractors to perform the<br />

expansion works at <strong>Reficar</strong>, complying with technical and environmental standards.<br />

2009 Recommendation: Need more specific details on stormwater control into Arroyo Grande in terms of erosion<br />

and sedimentation.<br />

Status: Satisfied (see CO R1-13).<br />

Ficha CO R1-6 (new)<br />

Control of Atmospheric Emissions (particulate matter, gasses, and noise)<br />

Objective: Control atmospheric emissions produced during construction.<br />

1101335.000 04F1 0611 MJ21


Table 11. (cont.)<br />

Ficha CO R1-7 (new)<br />

Pile Driving in the Sea<br />

Objective: Establish the requirements and procedures for the driving of piles during construction of port facilities<br />

that meet the technical and environmental standards established.<br />

Ficha CO R1-8 (previously CO-3)<br />

Management of Land Clearing, Excavations, and Earth Movements<br />

Objective: Establish the requirements and procedures for the management of geotechnical activities of clearing,<br />

earthwork, excavation, and fillings during the expansion of the refinery. Establish them in compliance with technical<br />

and environmental standards.<br />

Ficha CO R1-9 (previously CO-1 [two ficha were numbered CO-1])<br />

Mangrove Management<br />

Objective: To remove any mangrove forest according to the technical and environmental standards established by<br />

relevant authorities, and to compensate for the loss of mangrove by reforesting within the lot and/or any other area<br />

that is indicated by the environmental authorities.<br />

Ficha CO R1-10 (previously CO-2)<br />

Fauna Management<br />

Objective: To responsibly manage the wildlife present on the Project construction site, and to prevent and mitigate<br />

the impacts on the fauna caused by the removal of vegetation.<br />

Ficha CO R1-11 (new)<br />

Inspection of Soldering and Management of Radiation Sources<br />

Objective: To prevent exposure to radiation and reduce the generation of hazardous waste.<br />

Ficha CO R1-12 (new)<br />

Signage and Site Access Program<br />

Objective: Maintain adequate signage on the construction site and limit access to the Project site by unauthorized<br />

persons.<br />

New Recommendation: Develop an indicator to gauge the effectiveness of the site perimeter security other than<br />

the percent of the Project enclosed by the perimeter fence.<br />

Ficha CO R1-13 (new)<br />

Relocation of Canals and Pipelines<br />

Objective: Establish requirements and procedures for the relocation of stormwater channels and pipes that exist in<br />

the pet-coke and sulfur storage areas that meet the technical and environmental standards established.<br />

New Recommendation: Develop an indicator for the effectiveness of the relocation (e.g., number of spills during<br />

relocation).<br />

1101335.000 04F1 0611 MJ21


Table 11. (cont.)<br />

Ficha CO R1-14 (previously CO R1-7)<br />

Preventative Archeological Program<br />

Objective: Avoid any kind of damage to the archeological heritage during the civil works of the expansion of<br />

<strong>Reficar</strong>.<br />

2009 Recommendation: <strong>Reficar</strong> is responsible for overseeing the work through EHS Inspectors who can stop any<br />

work that they deem unsuitable. Need to develop and include a feedback mechanism to the contractor for continued<br />

improvement once the issue is resolved and work resumes.<br />

Status: Satisfied.<br />

Ficha CO R1-15 (previously CO R1-8)<br />

Activation of Contingency Plan<br />

Objective: Establish, implement, maintain, and improve the Emergency Response Plan, for events that may occur<br />

during the construction of <strong>Reficar</strong>.<br />

2009 Recommendation: Need to develop the Contingency Plan that is referred to in the Ficha.<br />

Status: Satisfied.<br />

Ficha OP R1-1 (previously OP-1)<br />

Training for Project Workers<br />

Objective: Raise awareness and improve the skills of the Project workers (skilled and unskilled labor, local and<br />

foreign), to ensure the proper implementation of ESMP.<br />

2009 Recommendation: Need to develop specific EHS training materials, both general for all workers and<br />

additional specific training given job category. Training needs to include potential worker–community issues and<br />

also worker core labor rights. Need to have ongoing training, not just initial training.<br />

Status: Partially satisfied, pending information on training programs for potential worker-community issues and<br />

worker core labor rights. As we understand, <strong>Reficar</strong> is to work with CB&I and subcontractors to assure their<br />

upcoming workers are aware of their core labor rights<br />

Ficha OP R1-2 (previously OP-2)<br />

Community Communication and Participation Program<br />

Objective: Communicate to the municipal, regional, and environmental authorities, as well as the communities and<br />

unions in general about the modernization project. Include the scope, progress, and implications and relevant<br />

features in the technical and environmental aspects.<br />

2009 Recommendation: Need more specific details. Need more actions in terms of ongoing consultation,<br />

information disclosure, and grievance mechanism consistent with IFC Performance Standards. Should include<br />

actions not only for immediately nearby communities to the refinery but also some information disclosure to the<br />

<strong>Cartagena</strong> area.<br />

Status: Satisfied.<br />

Ficha OP R1-3 (previously OP-3)<br />

Recruitment Programs and Prioritization of Local Workforce<br />

Objective: Give priority in the recruitment process of skilled and unskilled workforce to the <strong>Cartagena</strong> city<br />

population. In the second instance, give preference to the recruitment of the qualified personnel of the rest of the<br />

country that complies with the technical and experience requirements established by the Project.<br />

2009 Recommendation: Need more specific actions related to residents living in immediate area near the refinery.<br />

Should explore training and assistance to people living in immediate vicinity to enhance their opportunity to receive<br />

Project benefits (e.g., job training, service provision, etc.).<br />

1101335.000 04F1 0611 MJ21


Table 11. (cont.)<br />

Status: Satisfied.<br />

Ficha OP R1-4 (previously OP-5)<br />

Program to Support Institutional Management Capacity<br />

Objective: Support training for the leaders of communities near the Mamonal Industrial Area. Promote<br />

reinforcement of their management abilities and social projects before mayors and institutions in general, for the<br />

benefit of projects to improve the quality of life of the inhabitants of the region.<br />

2009 Recommendation: Include an indicator to measure the institutional capacity building.<br />

Status: Partially satisfied.<br />

Ficha OP R1-5 (previously OP-6)<br />

Program for Informing, Training, and Educating Surrounding Communities about the Environment and Emergency<br />

Preparedness<br />

Objective: Develop a program to support the community and local and regional governmental agencies on<br />

emergencies and disasters management, both natural and industrial. The program aims to educate the nearby<br />

communities on the importance of the environment and natural renewable and non-renewable resources. It will<br />

include topics such as deforestation and reforestation, environmental sanitation, inherent risks in ongoing<br />

operations, and the ability to protect themselves in case of incidents or accidents.<br />

New Recommendation: Need to specify which disasters or emergencies might be expected for which<br />

communities. Should develop a metric designed to measure the effectiveness of the training and practice<br />

emergency drills.<br />

Status: Awaiting information from <strong>Reficar</strong> on the history of the program.<br />

Ficha OP R1-6 (previously OP-4)<br />

Community Grievance Mechanism<br />

Objective: Address, record, resolve, and answer all concerns, suggestions, expectations, and complaints<br />

expressed by officials of the municipal administration or any other private or public entity and the community in<br />

general. Obtain feedback between the Project and the environment in order to harmonize relationships, minimizing<br />

the occurrence of conflicts affecting the normal development of the Project.<br />

2009 Recommendation: Consider development and implementation of community participatory monitoring<br />

program. Include procedure to deal with issues/claims that are repetitive in nature.<br />

Consider including an objective to enhance economic development specifically in Area No. 3 in Mamonal Industrial<br />

Area.<br />

Status: Satisfied.<br />

Ficha OP R1-7 (new)<br />

Social Compensation Program<br />

Objective: Contribute to the development of communities located around the Mamonal Industrial Area by<br />

implementing <strong>Reficar</strong>’s CSR policy and the programs outlined in the ESMP.<br />

Status: Satisfied.<br />

Ficha OP R1-8 (previously OP-7)<br />

Air Emissions and Environmental Noise Management<br />

Objective: Minimize the amount of air emissions generated by the production process and keep the environmental<br />

noise levels at permissible levels.<br />

1101335.000 04F1 0611 MJ21


Table 11. (cont.)<br />

2009 Recommendation: High-efficiency cyclone equipment should be installed at the catalyst regeneration unit<br />

(i.e., more than 76% as stated in the EIA ESMP). Enhanced measures are needed to control fugitive emissions from<br />

coke-handling operations (perimeter wall control is not adequate during high wind conditions). The regenerator unit<br />

is proposed to be equipped with only a cyclone, while a best-technology analysis might indicate that a bag filter<br />

system would be more appropriate.<br />

The only NOx controls considered appear to be low-NOx burners; should consider more controls rather than just<br />

burner technology. All new storage tanks should be designed to meet good international practices (e.g., double-seal<br />

floating roofs, proper secondary contaminant, etc.).<br />

The proposed ground flares need to have adequate exclusion zones.<br />

Status: Satisfied with modeling and monitoring.<br />

Ficha OP R1-9 (previously OP-8)<br />

Management of Domestic/Industrial Effluents and Stormwater<br />

Objective: Minimize and control the wastewater discharges to the Bay, discharges generated by the different<br />

processes, and operational support of the <strong>Cartagena</strong> <strong>Refinery</strong>.<br />

2009 Recommendation: Provide design criteria for stormwater retention calculations and containment capacities.<br />

Status: Satisfied.<br />

Ficha OP R1-10 (new)<br />

Management of Cargo Boat Bilge and Ballast Water<br />

Objective: Control bilge and ballast water discharges to the <strong>Cartagena</strong> Bay from cargo ships at the <strong>Reficar</strong> port<br />

terminal.<br />

Ficha OP R1-11 (previously OP-9)<br />

Hazardous Waste Management<br />

Objective: Dispose of hazardous waste in an environmentally safe manner.<br />

Ficha OP R1-12 (previously OP-10)<br />

Non-Hazardous Waste Management<br />

Objective: Dispose of non-hazardous waste according to <strong>Colombia</strong>n laws.<br />

2009 Recommendation: Spent catalyst delivery to cement firms must be documented—provide procedures.<br />

Status: Unresolved.<br />

Ficha OP R1-13 (new)<br />

Cleaning of the Port<br />

Objective: Establish requirements and procedures for the cleaning of loading docks and access routes during<br />

operation of the port facilities that meet the technical and environmental standards established.<br />

Ficha OP R1-14 (new)<br />

Adequacy of the “Roll On Roll Off” Pier<br />

Objective: Optimization of the docks for the roll-on roll-off pier, on which equipment for the <strong>Cartagena</strong> <strong>Refinery</strong><br />

modernization will be offloaded.<br />

1101335.000 04F1 0611 MJ21


Table 11. (cont.)<br />

Ficha OP R1-15 (previously OP-11)<br />

Soil and Groundwater Protection<br />

Objective: Prevent pollution of soil and the groundwater.<br />

2009 Recommendation: Containment areas should be required to be constructed to a minimum permeability using<br />

impermeable materials. Present plan for free-product remediation. Present soil and groundwater cleanup criteria.<br />

Status: Pending.<br />

Ficha OP R1-16 (previously OP-12)<br />

Hazardous Substances Storage<br />

Objective: Prevent potential environmental damage related to inappropriate storage of finished products and other<br />

hazardous substances used in the plant.<br />

2009 Recommendation: Need details for chemical storage warehouse design.<br />

Status: Satisfied.<br />

Ficha OP R1-17 (previously OP-13)<br />

Contingency Plan<br />

Objective: Establish criteria for early detection of abnormalities of the operation of the plant.<br />

2009 Recommendation: Need better definition of initiation of contingency plan required for leaks of gaseous<br />

hydrocarbons and leaks of acid gas, ammonia, or hydrogen fluoride. Need to confirm adequate distances between<br />

office buildings and process area (e.g., building study in accordance with API-752/753). Operation contingency plan<br />

must be developed based upon detailed risk analysis results (e.g., HAZOPs, HRA, etc.).<br />

Status: Satisfied.<br />

Ficha DR1 (new)<br />

Procedure for Information Disclosure by the <strong>Cartagena</strong> <strong>Refinery</strong> SA <strong>Reficar</strong> and the Construction Contractor<br />

Objective: Supply information on dredging progress to the maritime community in the <strong>Cartagena</strong> Bay in order to<br />

inform the users of the port and respond to inquiries. Address issues raised by the community directly or through<br />

citizen oversight committees, journalists, or any other party.<br />

Ficha DR2 (new)<br />

Environmental Education Plan for Workers, Crew, and Operators of the Equipment Used in Dredging Activities<br />

(Supplemental Environmental Management Plan Exclusively for Use During Dredging Activities)<br />

Objective: Provide environmental and industrial safety training to crews and operators involved in the dredging<br />

works so they can conduct their activities in a safe manner and prevent water pollution in the <strong>Cartagena</strong> Bay, the<br />

dump area on land and adjacent banks. Comply with HSE laws and standards, the requirements of environmental,<br />

maritime, and port authorities, and this ESMP.<br />

Ficha DR3 (new)<br />

Procedure for the Handling of Fuels and Lubricants by the Workers, Crew, and Operators of the Vessels Involved in<br />

Dredging<br />

Objective: Establish minimum requirements and procedures necessary to ensure proper handling of fuels and<br />

lubricants by the workers, crew, and operators of dredging vessels and equipment.<br />

1101335.000 04F1 0611 MJ21


Table 11. (cont.)<br />

Ficha DR4 (new)<br />

Procedure for Handling, Interim Storage, and Disposal of Solid Waste Generated by the Vessels Involved in Dredging<br />

Objective: Establish requirements and procedures for handling, storage, and disposal of solid waste generated on<br />

board the dredging vessels and auxiliary ships.<br />

Ficha DR5 (new)<br />

Procedure for Handling, Interim Storage, and Disposal of Liquid Waste Generated by the Vessels Involved in Dredging<br />

Objective: Establish requirements and procedures for handling, storage, and disposal of liquid waste generated on<br />

board the dredging vessels and auxiliary ships.<br />

Ficha DR6 (new)<br />

Procedure for the Control of Dredging Activities<br />

Objective: Control and manage dredging operations in an environmentally safe manner that complies with<br />

environmental, maritime, and port regulations.<br />

Ficha MS R1-1 (previously MS-1)<br />

Internal Operations Control of the <strong>Refinery</strong> and Port<br />

Objective: Record data related to operation internal controls and prevention of environmental impact to the natural<br />

resources.<br />

Ficha MS R1-2 (previously MS-2)<br />

Wastewater Quality<br />

Objective: Monitor the quality of wastewater at the <strong>Cartagena</strong> <strong>Refinery</strong>, before and during the discharge to<br />

<strong>Cartagena</strong> Bay.<br />

2009 Recommendation: Need to define the frequency of construction and operation water quality monitoring.<br />

Provide breakdown for cost estimate.<br />

Status: Satisfied.<br />

Ficha MS R1-3 (previously MS-3)<br />

Water and Sediment Quality of the Receptor Water Bodies<br />

Objective: Monitor the quality of water and sediments of <strong>Cartagena</strong> Bay and Arroyo Grande Creek.<br />

2009 Recommendation: Need to define the frequency of sampling in Arroyo Grande and in the Bay. Define<br />

rationale for Bay sampling location E10 (i.e., why not east of entrance?). Provide details of spill-event sampling.<br />

Status: Not satisfied.<br />

Ficha MS R1-4 (previously MS-4)<br />

Air Emissions Quality<br />

Objective: Perform air emissions quality monitoring of the stationary sources of the <strong>Cartagena</strong> <strong>Refinery</strong> in the<br />

construction and operation phases.<br />

2009 Recommendation: Need more complete emissions monitoring of all relevant sources and parameters. Need<br />

to establish more applicable monitoring frequency.<br />

Status: Satisfied with modeling and monitoring.<br />

1101335.000 04F1 0611 MJ21


Table 11. (cont.)<br />

Ficha MS R1-5 (previously MS-5)<br />

Air and Environmental Noise Quality<br />

Objective: Conduct air quality monitoring and environmental noise monitoring in the Project’s area of influence.<br />

2009 Recommendation: Increase noise monitoring from annually to monthly.<br />

Status: Satisfied with the proposed air modeling and monitoring efforts that will be undertaken.<br />

Ficha MS R1-6 (previously MS-6)<br />

Soil and Groundwater Quality<br />

Objective: Conduct soil and groundwater quality monitoring at <strong>Cartagena</strong> <strong>Refinery</strong>.<br />

2009 Recommendation: Need to define frequency of monitoring. Must include contingencies for uncovering<br />

contamination during construction period. Must include contingencies for installation of groundwater monitoring<br />

wells if soil contamination is encountered during construction activities.<br />

Status: Satisfied.<br />

Ficha MS R1-7 (previously MS-7)<br />

Characterization and Distribution of Hydrobiological Communities of the <strong>Cartagena</strong> Bay<br />

Objective: Monitor the condition and variation of the aquatic communities (benthos, zooplankton, and fish) in five<br />

stations located in <strong>Cartagena</strong> Bay. Their dynamics can be associated with discharges and operation of the<br />

<strong>Cartagena</strong> <strong>Refinery</strong> compared with the traditional behaviors of those communities in the estuary.<br />

2009 Recommendation: Must include a reference station in the Bay.<br />

Status: Not yet satisfied.<br />

Ficha MS R1-8 (previously MS-8)<br />

Social Impacts Management<br />

Objective: Periodically verify compliance with the objectives, targets, and indicators associated with the<br />

development of the designed programs to manage the social impacts to be created by the project.<br />

2009 Recommendation: Need to modify Ficha to reflect that compliance with governmental requirements is not the<br />

same as presence of social impacts (or indication thereof). Need a specific procedure to deal with potential social<br />

crisis/emergencies in terms of work stoppage, local community protests, etc. For construction, need a policy related<br />

to labor unions.<br />

Status: <strong>Reficar</strong> is constructing a Crisis Manual that addresses these types of contingencies..<br />

Ficha MS R1-9 (previously MS-9)<br />

Effectiveness of the Social Management Plan<br />

Objective: Verify the effectiveness of social management plan programs that have been committed to by the<br />

Project with the community and local authorities, including objectives, targets, and compliance indicators determining<br />

the level of satisfaction of the people involved.<br />

2009 Recommendation: Clarify the differences between Ficha MS-8 and MS-9. Objectives are acceptable, but the<br />

activities do not align. Include method to monitor effectiveness of social management actions/programs. Perform a<br />

social risk analysis of the potentially relevant stakeholders, and as necessary, develop specific mitigation and/or<br />

monitoring actions.<br />

Status: <strong>Reficar</strong> is currently measuring and refining this metric.<br />

1101335.000 04F1 0611 MJ21


Table 11. (cont.)<br />

Ficha MS R1-10 (previously MS-10)<br />

Community Grievance Mechanism<br />

Objective: Management to assess the given concerns, complaints, and claims from the communities and<br />

authorities. Also assess any conflicts related to the Project with the community.<br />

2009 Recommendation: Need a more specific procedure to monitor for the presence of potential social conflicts.<br />

Enhance grievance mechanism consistent with guidance provided in IFC Guidance Notes on Performance<br />

Standards on Social and Environmental Sustainability.<br />

Status: Satisfied.<br />

Ficha MS R1-11 (previously MS-11)<br />

Community Participation and Information Program<br />

Objective: Verify compliance with the objectives, targets, and indicators of the participation program and<br />

information provided to communities.<br />

2009 Recommendation: Include a procedure to conduct surveys regarding satisfaction of associated programs/<br />

strategies<br />

Status: Perception survey for all stakeholders has been prepared and is to be conducted each year.<br />

Ficha MS DR-1 (new)<br />

Monitoring of Dredging Activities for the Roll On-Roll Off Pier<br />

Objective: Establish, implement and maintain the Environmental Monitoring Plan to monitor impacts from dredging<br />

activities.<br />

Status: Satisfied.<br />

1101335.000 04F1 0611 MJ21


Table 12. Action Plan based on the Phase I and Phase 2 Environmental, Health and Safety Assessments—<strong>Cartagena</strong><br />

<strong>Refinery</strong> Facility, Environmental Health and Safety Action Plan Existing <strong>Refinery</strong>–Due Diligence<br />

Item Action to be Implemented Description Schedule Priority Status<br />

1 Environmental<br />

Management System<br />

2 Project Execution<br />

(construction of new<br />

plants) with its respective<br />

Environmental<br />

Management Plan<br />

implementation as per the<br />

EIA approved by the<br />

<strong>Colombia</strong>n Ministry of<br />

Environment.<br />

1101335.000 04F1 0611 MJ21<br />

Implement EHS Management System for<br />

best environmental practices and<br />

evaluations of performance, track EHS<br />

action items and compliance status, and<br />

conduct auditing and implement corrective<br />

action (when necessary) that is inclusive of<br />

relevant impacts, EHS-related processes,<br />

construction, operations and maintenance,<br />

and waste, effluents and materials<br />

management. Since <strong>Reficar</strong> has two main<br />

and very different operations, <strong>Reficar</strong> has<br />

to implement to different EHS management<br />

systems: (i) for the existing refinery and<br />

industrial operation, and (ii) for the Project<br />

execution and the construction phase.<br />

Implement the refinery Master Plan to<br />

design and modify / construct expanded<br />

refinery operations (including wastewater,<br />

process water, waste and stormwater<br />

handling systems, port facilities, stacks,<br />

etc.); model and implement air emissions<br />

controls as necessary; effect upgrades /<br />

repairs as required by regulatory<br />

resolutions; assess sustainability and social<br />

impacts of expanded refinery operations on<br />

environment and community in compliance<br />

with IFC and Equator principle guidelines;<br />

conduct periodic reviews of status of<br />

mitigation measures and performance<br />

monitoring. Implement phenol mitigation<br />

plan until the new WWTP begins operation.<br />

CB&I has to implement and maintain an<br />

EHS Management System for the project<br />

execution (construction). <strong>Reficar</strong> has to<br />

validate and review the implementation<br />

of the Construction EHS Management<br />

System. This begins with the EPC<br />

Contract to the refinery start up.<br />

Ecopetrol S.A. responsible for Operation<br />

and Maintenance, and administration of<br />

the existing refinery until the expansion<br />

project enters in operation (2013) -<br />

inclusive of the environmental monitoring<br />

and mitigation plans for the existing<br />

operation. Ecopetrol has in place a<br />

certified EHS Management System for<br />

the operation of the existing refinery,<br />

<strong>Reficar</strong> to support Ecopetrol Operations<br />

for compliance with <strong>Colombia</strong>n<br />

regulations in the operation of the<br />

existing refinery.<br />

<strong>Expansion</strong> designs are under design,<br />

construction by 2013. Existing facility<br />

WWTP and ancillary waste streams<br />

operation to 2013.<br />

Sustainability and social impacts<br />

addressed in EIA completed in 2008 and<br />

2010, and approved by the <strong>Colombia</strong>n<br />

Ministry of Environment.<br />

Monitoring requirements implemented<br />

accordingly, once the environmental<br />

license modification is approved and<br />

during the whole life cycle of the project.<br />

High Implemented<br />

High Implemented


Table 12. (cont.)<br />

Item Action to be Implemented Description Schedule Priority Status<br />

3 Phenol Mitigation Plan Implement Phenol Mitigation Plan - Sample<br />

and define individual source loads into the<br />

water treatment facility so sources of<br />

inflows are fully understood. Inspect and<br />

test existing facilities to identify leaks and<br />

reduce unplanned process loadings into<br />

waste water.<br />

Design new wastewater treatment system<br />

to address elevated discharges and needs<br />

for the expansion to bring it into compliance<br />

4 Groundwater and Soil<br />

impacts control, mitigation<br />

and remediation Plan<br />

5 Health and Safety<br />

Programs<br />

1101335.000 04F1 0611 MJ21<br />

Assess groundwater, soil, and surface<br />

water impacts. Complete soil, ground<br />

water and free product assessments at the<br />

facility and fully delineate the product<br />

plume. Based on overall site and<br />

prioritized work plan, begin control,<br />

mitigation and remediation activities.<br />

Develop and implement a Risk Based<br />

Strategy to control, mitigate and remediate<br />

the free product plume found in the existing<br />

refinery.<br />

Organize and Implement Structured Health<br />

and Safety Programs inclusive of employee<br />

safety and contractor safety, worker risk<br />

assessment, and medical surveillance;<br />

install and maintain reliable emergency and<br />

fire safety systems; provide training and<br />

track training status of employees and<br />

contractors and modify reporting to<br />

strengthen root cause analysis and<br />

corrective action tracking.<br />

Initiated December 2008 by Ecopetrol<br />

S.A. - 2010 effluent results meet the<br />

<strong>Colombia</strong>n Phenol Standard.<br />

Operation of upgraded WWTP by 2013<br />

(as per project schedule).<br />

Complete assessments during 2010;<br />

continue monitoring and complete<br />

remedial actions and systems between<br />

2011 and 2013. Ecopetrol is responsible<br />

for cleanup and remediation activities<br />

and <strong>Reficar</strong> will be overseeing these<br />

actives to assure compliance.<br />

Certified for existing facilities during<br />

2010. Develop and implement expanded<br />

systems for the Expanded <strong>Refinery</strong><br />

during 2013<br />

Moderate Implemented<br />

High Implemented<br />

Moderate To be implemented<br />

prior to startup of<br />

new units


Table 13. Project-related total energy consumption versus IFC Guidelines<br />

Unit Service Equipment #<br />

1101335.000 04F1 0611 MJ21<br />

Absorbed<br />

Duty<br />

(MMBtu/h)<br />

Fuel<br />

Efficiency<br />

(%)<br />

Released<br />

Duty<br />

(MMBtu/h)<br />

002–FCC Waste heat boiler 002-FC-D-2550 0.0 0% 0.0<br />

044–ALK Isostripper reboiler 105-ALK-F-001 86.7 89.4% 96.98<br />

100–CDU/<br />

VDU<br />

Charge heater 100-CDU-F-001 206.1 92% 223.97<br />

Charge heater 100-CDU-F-002 157.0 90.8% 172.87<br />

107–CNT CDHDS reboiler heater 107-CNT-F-201 29.4 81.7% 36.00<br />

108–DHT 1<br />

109–DHT 2<br />

110–HCU<br />

111–DCU<br />

Charge heater 108-DHA-F-001 21.0<br />

Stripper reboiler 108-DHA-F-002 38.0<br />

Charge heater 109-DHB-F-001 21.0<br />

Stripper reboiler 109-DHB-F-002 38.0<br />

Stage 1 charge heater 110-HCU-F-001 49.6<br />

Stage 2 charge heater 110-HCU-F-002 36.3<br />

Frac charge heater 110-HCU-F-101 167.0<br />

Coker charge heater 111-DCU-F-201 117.0<br />

Coker charge heater 111-DCU-F-202 117.0<br />

81.3% 72.51<br />

81.3% 72.51<br />

90.7% 278.80<br />

90.7% 258.08<br />

115–HPU1 Reformer 115-HPU-F-001 308.0 90% 342.26<br />

116–HPU2 Reformer 116-HPU-F-002 308.0 90% 342.26<br />

123–SRU 1<br />

Block<br />

TailGas Incinerator #1 123-TGA-F-301 12.1 90% 13.41<br />

124–SRU 2 TailGas Incinerator #2 124-TGB-F-301 12.1 90% 13.41<br />

130–PSG<br />

Existing<br />

Boilers<br />

GTG1+HRSG1 (Normal) 130-PSG-X-001 164.9 42.2% 391.1<br />

GTG2+HRSG2 (Normal) 130-PSG-X-002 164.9 42.2% 391.1<br />

GTG3+HRSG3 (Normal) 130-PSG-X-003 164.9 42.2% 391.1<br />

Existing Boiler 1 - 48.0 90% 53.3<br />

Existing Boiler 2 - 48.0 90% 53.3<br />

Total 2,314.8 3,203.0<br />

Crude Daily Throughput = 165,000 bbl/d<br />

Crude API = 18 °<br />

Crude Sp Gravity = 0.95<br />

Hourly Crude Throughput = 1,034.4 MT/hr<br />

Total Hourly Absorbed Energy = 2,314.8 MMBtu/hr<br />

Total Hourly Released Energy = 3,203.0 MMBtu/hr<br />

<strong>Reficar</strong>: Total Energy (ABSORBED) Consumption = 2,361 MJ/MT Crude processed<br />

<strong>Reficar</strong>: Total Energy (RELEASED) Consumption = 3,267 MJ/MT Crude processed<br />

IFC Standard: Total Energy Consumption = 2,100−2,900 MJ/MT Crude processed


Table 14. Project-related total power consumption versus IFC Guidelines<br />

1101335.000 04F1 0611 MJ21<br />

Normal Absorbed Power = 125.7 MW<br />

Distribution Losses = 1.9 MW<br />

Intermittent Loads = 4.3 MW<br />

External Power to Coke and Sulfur Handling = 5.6 MW<br />

Total Power Usage = 137.5 MW<br />

Crude Daily Throughput = 165,000 bbl/day<br />

Crude API = 18 °<br />

Crude Sp Gravity = 0.946<br />

Daily Mass Crude Throughput = 24,826 MT/day<br />

Daily Process ABSORBED Power Consumption = 3,016,800 kWh/day<br />

Daily Process TOTAL Power Consumption = 3,165,600 kWh/day<br />

Daily <strong>Refinery</strong> TOTAL Power Consumption = 3,300,000 kWh/day<br />

<strong>Reficar</strong>: Process (ABSORBED) Power Consumption = 122 kWh/MT Crude processed<br />

<strong>Reficar</strong>: Process (TOTAL) Power Consumption = 128 kWh/MT Crude processed<br />

<strong>Reficar</strong>: <strong>Refinery</strong> Wide (TOTAL) Power Consumption = 133 kWh/MT Crude processed<br />

IFC Standard: Power Consumption = 25−48 kWh/MT Crude processed<br />

Note: Power consumption in petroleum refining is dependent on the refining process employed, a more<br />

complex and integrated refinery has higher power needs as compared to a simple refinery. The<br />

ABSORBED and TOTAL power consumption for REFICAR refinery is higher than IFC Standards<br />

because the refinery is highly integrated and complex to produce various kinds of finished products.


Table 15. Comments and recommendations related to environmental liabilities at<br />

existing refinery<br />

Phase 1 ESA<br />

� Stormwater Retention Ponds Are Undersized: They are sized for a 20-minute rainfall event or 1-in. event.<br />

A good international standard would be a 25-year, 24-hour event. Numerous pond liners are in need of<br />

repair/upgrade.<br />

� Status: Satisfied, new wastewater treatment system accommodates this issue.<br />

� Oil Water/Sewer System: There is relatively little information on the actual conditions and leakage from this<br />

system. This may be a transport mechanism for near-surface contamination to be spread around the site.<br />

� Status: Satisfied, new wastewater treatment system accommodates this issue.<br />

� API Separator System: DAF unit may not be operating completely. Skimmer issues exist.<br />

� Status: Satisfied, new wastewater treatment system accommodates this issue.<br />

� Skim Ponds: Need to confirm that the new aeration system is working (it was not operating during ESDD<br />

site visit). Need to confirm operational conditions and confirm BOD, TPH, phenols, and oil and grease<br />

concentrations in the inlet and outlet samples.<br />

� Status: Satisfied, new wastewater treatment system accommodates this issue. Water sampling was<br />

completed in 2008−2010.<br />

� Discharge Channel: Need to confirm that the oil separation barriers are upgraded.<br />

� Status: Satisfied, new wastewater treatment system accommodates this issue. Water sampling was<br />

completed in 2008−2010 and barriers were installed.<br />

� Tankfarm Issues: In the 3000 Tank Farm Area, tanks were purged to the earthen basins (no lining; i.e.,<br />

Tank 3081 area), which likely caused groundwater issues. Many tank berms are in need of repair. Need to<br />

remove vegetation and trees from dikes and floor areas. There are miscellaneous piping and valve leaks.<br />

� Status: Planned as part of the existing refinery operations and maintenance improvements.<br />

� Waste Management: Sludge ponds, landfarm, and former hazardous storage area. Need to evaluate soil<br />

and groundwater contamination in this area. Sludge ponds may have been buried or removed. Sludgepond<br />

area needs subsurface evaluation to confirm groundwater conditions, impermeable soil, and cement<br />

pond liners.<br />

� Status: Pending.<br />

� Groundwater: Free product likely exists around Tanks 3040, 3050, 3060, and 3500 series. Free product<br />

likely exists around the polymerization and cracking units. Area around P-11 has free product from<br />

potential multiple sources.<br />

� Status: Partially satisfied. Ecopetrol is currently working on this task.<br />

Phase 2 ESA<br />

� Focused only on environmental liabilities greater than $1 million US.<br />

� Status: In progress.<br />

� Groundwater: There could be fewer wells because the fire ponds are immediately upgradient, and it could<br />

be assumed that this is the area of maximum groundwater gradient from east to west. Therefore, the focus<br />

could be on the western or downgradient side of the tank areas. This could possibly be accomplished<br />

using 5–10 wells with soil sampling.<br />

� Status: Pending.<br />

� Soil and Buried Wastes: The area where the existing hazardous waste facility is currently located is also<br />

the former waste area. Should sample in the vicinity adjacent to the facility to confirm that no hazardous<br />

materials remain in the soil or groundwater.<br />

� Status: Planned.<br />

1101335.000 04F1 0611 MJ21


Table 15. (cont.)<br />

� Wastewater Treatment: Should get the wastewater treatment system in proper running condition. The<br />

oil/water separator, skim ponds, DAF system, and aerator all contribute to the problem of phenol in the<br />

discharge channel. In addition, there was discussion during Phase 1 (see issues and concerns section)<br />

regarding the skimmers in the discharge channel. They need to be upgraded. The <strong>Cartagena</strong> convention<br />

is very protective of the marine environment. Little or no sediment sampling was performed near the outfall<br />

to the Bay.<br />

� Status: Satisfied, new wastewater treatment system accommodates this issue. A plan was developed<br />

by <strong>Reficar</strong> on December 28, 2007, and submitted to CARDIQUE. Subsequent water sampling was<br />

completed in 2008−2010.<br />

� Other Environmental Aspects: Phase 2 ESA noted additional items that would require upgrading, including<br />

secondary containment for tanks, integrity of the industrial sewage system, and line integrity. The following<br />

are two potential additions: a) Stormwater storage should be upgraded from its existing size, which is for a<br />

20-minute rainfall event or 1-in. event, to a 25-year, 24-hour event. This upgrade should also confirm that<br />

surface water runoff from the northern tank areas is included. Pond liners should be upgraded and<br />

maintained. b) The discharge channel likely has sediment contamination that should be removed during<br />

the upgrades to the wastewater treatment system. Prior to that occurring, these sediments and those near<br />

the mouth of the discharge should be sampled.<br />

� Status: Satisfied, new wastewater treatment system accommodates this issue. Water sampling was<br />

completed in 2008−2010.<br />

1101335.000 04F1 0611 MJ21


1101335.000 04F1 0611 MJ21<br />

Table 16. Total greenhouse gas estimates<br />

Process Unit<br />

CO2<br />

Emissions<br />

(MT CO2/yr)<br />

CH4<br />

Emissions<br />

(MT CH4/yr)<br />

N2O<br />

Emissions<br />

(MT N2O/yr)<br />

CO2 Global<br />

Warming<br />

Potential<br />

CH4 Global<br />

Warming<br />

Potential<br />

N2O Global<br />

Warming<br />

Potential<br />

Total CO2<br />

Equivalent<br />

Emissions<br />

(MT CO2 e/yr)<br />

002 - FCC 367,346 10.8 2.2 1 21 310 368,239<br />

044 - ALK 47,294 2.4 0.5 1 21 310 47,493<br />

100 - CDU/VDU 246,220 12.4 2.5 1 21 310 247,253<br />

102 - NHT Deferred -- -- 1 21 310 Deferred<br />

103 - CCR Deferred -- -- 1 21 310 Deferred<br />

107 - FCC NHT 28,698 1.5 0.3 1 21 310 28,818<br />

108 - DHT1 38,316 1.9 0.4 1 21 310 38,477<br />

109 - DHT2 38,316 1.9 0.4 1 21 310 38,477<br />

110 - HCU 136,679 6.9 1.4 1 21 310 137,253<br />

111 - DCU 135,275 14.0 1.4 1 21 310 135,993<br />

115 - HPU1 496,101 5.2 1.0 1 21 310 496,529<br />

116 - HPU2 496,101 5.2 1.0 1 21 310 496,529<br />

123 -SRU/TGTU 13,266 0.4 0.1 1 21 310 13,295<br />

124 -SRU/TGTU 13,266 0.4 0.1 1 21 310 13,295<br />

130 - PSG 529,719 10.5 1.2 1 21 310 530,326<br />

141 - Flare - -- -- 1 21 310 --<br />

146 - Storage tanks - 6.0 -- 1 21 310 126<br />

Equipment leak - 16.5 -- 1 21 310 347<br />

Total 2,586,597 95.9 12.4 2,592,448<br />

CO2 e emissions from Fuel Combustion = 1,531,644 MT CO2 e/yr<br />

CO2 e emissions from Hydrogen Plant Feed = 679,494 MT CO2 e/yr<br />

CO2 e emissions from FCC and CCR Catalyst Regen = 368,239 MT CO2 e/yr<br />

CO2 e emissions from Sour Gas Treatment = 12,598 MT CO2 e/yr<br />

CO2 e emissions from Flared Gas Combustion = -- MT CO2 e/yr<br />

CO2 e emissions from Storage Tanks and Process Leaks = 473 MT CO2 e/yr


Table 17. Conformance overview: EHS General Guidelines<br />

Theme Issue Situation Observed, including Gaps<br />

Environmental Air Emissions and<br />

Ambient Air Quality<br />

Occupational<br />

Health andSafety<br />

1101335.000 04F1 0611 MJ21<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Energy Conservation Power consumption in petroleum<br />

refining is dependent on the refining<br />

process employed, a more complex<br />

and integrated refinery has higher<br />

power needs as compared to a simple<br />

refinery. The ABSORBED and TOTAL<br />

power consumption for REFICAR<br />

refinery is higher than IFC Standards<br />

because the refinery is highly<br />

integrated and complex to produce<br />

various kinds of finished products.<br />

Wastewater and<br />

Ambient Water<br />

Quality<br />

Siemens construction guarantee and<br />

the Environmental Management Plan<br />

(April 2010).<br />

Water Conservation Provided in the Environmental<br />

Management Plan (April 2010).<br />

Hazardous Materials<br />

Management<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Waste Management Not a major concern. Revised ESMP<br />

contains a Waste Management Plan.<br />

Noise Management Some noise during construction and<br />

equipment during operation.<br />

Recommended<br />

Follow-Up<br />

Monitoring and<br />

modeling<br />

Continue to monitor<br />

and report<br />

Contaminated Land Presented in the EIA. Continue monitoring<br />

groundwater<br />

General Facility<br />

Design and<br />

Operation<br />

Communications and<br />

Training<br />

<strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

<strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

Physical Hazards Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Chemical Hazards Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Biological Hazards N/A<br />

Radiological Hazards N/A<br />

Personal Protective<br />

Equipment<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).


Table 17. (cont.)<br />

Theme Issue Situation Observed, including Gaps<br />

Community Health<br />

and Safety<br />

Construction and<br />

Decommissioning<br />

1101335.000 04F1 0611 MJ21<br />

Special Hazard<br />

Environments<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Monitoring Provided in the Program and Project<br />

Monitoring (July 2009).<br />

Water Quality and<br />

Availability<br />

Structural Safety of<br />

Project Infrastructure<br />

N/A<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Life and Fire Safety Incorporated into the Contingency<br />

Plan.<br />

Traffic Safety Traffic safety is the responsibility of<br />

both <strong>Reficar</strong> and CB&I, and there is an<br />

integrated Traffic Management Plan.<br />

Transport of<br />

Hazardous Materials<br />

Hazardous materials will be<br />

transported by truck in 20’ and 40’ ft.<br />

containers, in accordance with IFC<br />

guidelines.<br />

Disease Prevention No construction camp or induced<br />

migration is expected.<br />

Emergency<br />

Preparedness and<br />

Response<br />

Environment,<br />

Occupational and<br />

Community H&S<br />

Incorporated in the Emergency<br />

Response Plan.<br />

Incorporated into the Contingency<br />

Plan.<br />

Recommended<br />

Follow-Up


Table 18. Conformance overview: EHS Guidelines for Petroleum Refining<br />

Theme Issue Situation Observed, including Gaps<br />

Environmental Air Emissions<br />

1101335.000 04F1 0611 MJ21<br />

Exhaust Gases<br />

Air Emissions<br />

Venting & Flaring<br />

Air Emissions<br />

Fugitive Emissions<br />

Air Emissions<br />

Sulfur Oxides<br />

Air Emissions<br />

Particulate Matter<br />

PM10 measurements taken in some<br />

areas were in excess of the IFC<br />

standard, indicating pre-existing,<br />

elevated background levels. Air<br />

emissions from mobile point sources<br />

during construction are not likely to be<br />

significant.<br />

<strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

<strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

<strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

<strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

Greenhouse Gases <strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

Recommended<br />

Follow-Up<br />

Determine the cause of<br />

the elevated background<br />

levels of PM10 and<br />

continue monitoring in<br />

these areas.<br />

There is the potential for<br />

fugitive emissions and<br />

greenhouse gas<br />

emissions, but these<br />

were not modeled or<br />

analyzed. Monitoring,<br />

measurement, and<br />

modeling during<br />

operation is planned.<br />

There is the potential for<br />

fugitive emissions and<br />

greenhouse gas<br />

emissions, but these<br />

were not modeled or<br />

analyzed. Monitoring,<br />

measurement, and<br />

modeling during<br />

operation is planned.<br />

There is the potential for<br />

fugitive emissions and<br />

greenhouse gas<br />

emissions, but these<br />

were not modeled or<br />

analyzed. Monitoring,<br />

measurement, and<br />

modeling during<br />

operation is planned.<br />

There is the potential for<br />

fugitive emissions and<br />

greenhouse gas<br />

emissions, but these<br />

were not modeled or<br />

analyzed. Monitoring,<br />

measurement, and<br />

modeling during<br />

operation is planned.<br />

There is the potential for<br />

fugitive emissions and<br />

greenhouse gas<br />

emissions, but these<br />

were not modeled or<br />

analyzed. Monitoring,<br />

measurement, and<br />

modeling during<br />

operation is planned.


Table 18. (cont.)<br />

Theme Issue Situation Observed, including Gaps<br />

Occupational<br />

Health &Safety<br />

1101335.000 04F1 0611 MJ21<br />

Wastewater<br />

Industrial Process<br />

Wastewater<br />

Wastewater<br />

Process Wastewater<br />

Treatment<br />

Wastewater<br />

Other Wastewater<br />

Streams & Water<br />

Consumption<br />

Siemens construction guarantee and<br />

the Environmental Management Plan<br />

(April 2010).<br />

<strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

<strong>Reficar</strong> and CB&I construction<br />

documentation and provided in the<br />

Emergency Response Plan and the<br />

Environmental Management Plan<br />

(April 2010).<br />

Hazardous Materials Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Wastes<br />

Hazardous Wastes:<br />

Spent Catalysts<br />

Wastes<br />

Other Hazardous<br />

Wastes<br />

Wastes<br />

Non-Hazardous<br />

Wastes<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010).<br />

Noise Some noise during construction and<br />

from equipment during operation.<br />

Modelling showed acceptable impact<br />

to offsite receptors.<br />

Process Safety Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010)<br />

Oxygen-Deficient<br />

Atmosphere<br />

Chemical Hazards<br />

Hydrofluoric Acid<br />

Provided in the Emergency Response<br />

Plan and the Environmental<br />

Management Plan (April 2010)<br />

Hazardous materials will be<br />

transported by truck in 20 ft and 40 ft<br />

containers, in accordance with IFC<br />

guidelines.<br />

Fire & Explosions Provided in the Environmental<br />

Management Plan (April 2010) and<br />

Emergency Response and<br />

Contingency Plans.<br />

Recommended<br />

Follow-Up<br />

Monitor and measure<br />

during operation.<br />

Monitor and measure as<br />

required in plans.<br />

Additional monitoring<br />

near receptors advisable<br />

once the expanded<br />

refinery is operating.<br />

Conduct drilling as<br />

required in plans.<br />

Conduct drilling as<br />

required in plans.


Table 18. (cont.)<br />

Theme Issue Situation Observed, including Gaps<br />

Community Health<br />

andSafety<br />

1101335.000 04F1 0611 MJ21<br />

Hazards<br />

Major Accidents<br />

related to Fires &<br />

Explosions<br />

Hazards<br />

Accidental releases of<br />

raw materials or<br />

finished products<br />

during transportation<br />

outside of the<br />

processing facility.<br />

Provided in the Emergency Response<br />

Plan and Contingency Plan.<br />

Provided in the Emergency Response<br />

and Contingency Plans.<br />

Recommended<br />

Follow-Up<br />

Conduct drilling as<br />

required in plans.<br />

Conduct drilling as<br />

required in plans.


Figures


Figure 1. <strong>Cartagena</strong> <strong>Refinery</strong> location<br />

1101335.000 04F1 0611 MJ21


Figure 2. <strong>Cartagena</strong> <strong>Refinery</strong><br />

1101335.000 04F1 0611 MJ21


Figure 3. Current configuration of the <strong>Cartagena</strong> <strong>Refinery</strong><br />

1101335.000 04F1 0611 MJ21


Figure 4. Future configuration of the <strong>Cartagena</strong> <strong>Refinery</strong><br />

1101335.000 04F1 0611 MJ21


Figure 5. Proposed wastewater treatment plant configuration<br />

1101335.000 04F1 0611 MJ21


1101335.000 04F1 0611 MJ21<br />

Figure 6. Health, Safety, Security, and Environmental Management System model


1101335.000 04F1 0611 MJ21


Figure 7. Engineering, Procurement, and Construction Contract–Health, Safety and Environment Organization during construction<br />

1101335.000 04F1 0611 MJ21


Appendix A<br />

Photograph Log


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 1. Project Site: worker safety and security signs at entrance<br />

to project site<br />

Photograph 2. Project Site: emergency evacuation route sign at entrance<br />

to project site<br />

A-1


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 3. Project Site: cleared site with all vegetation removed and<br />

ready for construction<br />

Photograph 4. Project Site: another cleared site with all vegetation<br />

removed and ready for construction<br />

A-2


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 5. Project Site: the entrance to Ro-Ro Dock area<br />

Photograph 6. Project Site: the Ro-Ro Dock<br />

A-3


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 7. Mangroves to the north of the Ro-Ro Dock<br />

Photograph 8. Mangroves between the Ro-Ro Dock and planned site of<br />

the new coke jetty<br />

A-4


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 9. Project Site: planned site for the new coke jetty<br />

Photograph 10. Project Site: workers’ safety sign inside the CB&I offices<br />

A-5


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 11. Project Site: no smoking sign inside the CB&I offices<br />

Photograph 12. Project Site: CB&I offices at back of project site<br />

A-6


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 13. Project Site: project construction along back road<br />

Photograph 14. Project Site: workers’ tented rest area with drinking water<br />

A-7


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 15. Project Site: guarded entrance to the project site along<br />

back road<br />

Photograph 16. Project Site: project construction along back road<br />

A-8


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 17. Project Site: project construction along back road<br />

Photograph 18. Project Site: workers’ meeting area, covered for sun<br />

protection<br />

A-9


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 19. Project Site: re-directed section of the Arroyo Grande<br />

Creek<br />

Photograph 20. Project Site: construction of CB&I storage facilities<br />

A-10


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 21. Entrance to INEM Training Center<br />

Photograph 22. Safety and security signs outside the<br />

entrance to the INEM Training Center<br />

A-11


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 23. INEM: students engaged in a craft training<br />

Photograph 24. INEM: students engaged in another craft training<br />

A-12


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 25. INEM: work yard with tented rest area<br />

Photograph 26. INEM: safety and security signs within the training grounds<br />

A-13


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 27. Entrance to the SENA Training Center<br />

Photograph 28. SENA: student engaged in craft training<br />

A-14


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 29. SENA: welding training area<br />

Photograph 30. SENA: students being trained to weld<br />

A-15


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 31. SENA: a student welder<br />

A-16


Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 32. SENA: a student welder who is wearing all<br />

required safety equipment<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 33. Arroz Barrato: main road to the community<br />

Photograph 34. Arroz Barrato: houses on main road<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 35. Arroz Barrato: small business on main road<br />

Photograph 36. Arroz Barrato: hospital expansion project supported by<br />

<strong>Reficar</strong> through contributions to the Fundacion Mamonal<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 37. Arroz Barrato: banner announcing public consultation<br />

meeting on school grounds<br />

Photograph 38. Arroz Barrato: public consultation meeting on March 5, 2011<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 39. Pasacaballos: main road in the community<br />

Photograph 40. Pasacaballos: small business on the main road<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 41. Pasacaballos: side road in the community<br />

Photograph 42. Pasacaballos: small Telecom business across the<br />

road from the school<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 43. Pasacaballos: school where public consultation<br />

meeting was held<br />

Photograph 44. Pasacaballos: public consultation meeting on May 5, 2011<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 45. Membrillal: the main road into the community<br />

Photograph 46. Membrillal: houses along north side of main road<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 47. Membrillal: roadside stand along main road<br />

Photograph 48. Membrillal: house along south side of main road<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 49. Membrillal: school where public consultation meeting<br />

was held<br />

Photograph 50. Membrillal: public consultation meeting on March 5, 2011<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 51. ACTUAR: headquarters of the foundation<br />

Photograph 52. ACTUAR: inspirational poster at the day care center:<br />

Reading is sound, it is to believe that anything is possible,<br />

your dreams will come true.<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 53. ACTUAR: day care class in session<br />

Photograph 54. ACTUAR: day care students<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 55. ACTUAR: preschool class in session<br />

Photograph 56. ACTUAR: preschool students<br />

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Photograph Log<br />

Site Visit February 24−March 4, 2011<br />

<strong>Reficar</strong> <strong>Cartagena</strong> <strong>Refinery</strong><br />

Photograph 57. ACTUAR: computer training course for high school students<br />

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