Reficar Cartagena Refinery Expansion, Colombia - EKN
Reficar Cartagena Refinery Expansion, Colombia - EKN
Reficar Cartagena Refinery Expansion, Colombia - EKN
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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 />
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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
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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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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 />
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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 />
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1 Introduction<br />
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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 />
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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 />
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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 />
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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 />
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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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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
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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 />
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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 />
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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
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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 />
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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 />
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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 />
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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 />
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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.
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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 />
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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 />
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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 />
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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).
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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 />
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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 />
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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
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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 />
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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 />
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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 />
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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.
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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 />
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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 />
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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 />
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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
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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 />
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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 />
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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 />
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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
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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
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� 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 />
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US$4.61 million<br />
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<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
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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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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 />
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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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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
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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 />
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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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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 />
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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 />
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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 />
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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 />
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<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 />
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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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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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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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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
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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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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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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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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
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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 />
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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).
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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 />
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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 />
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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
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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 />
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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 />
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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 />
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currently being executed by Ecopetrol, and paid for by <strong>Reficar</strong> as part of the<br />
normal operation of the existing refinery.<br />
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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 />
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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 />
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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.
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<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 />
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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 />
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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 />
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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 />
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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 />
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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 />
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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 />
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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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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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<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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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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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 />
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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
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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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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 />
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� Prior to first disbursement:<br />
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� 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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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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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 />
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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 />
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(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 />
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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.
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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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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 />
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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 />
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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 />
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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 />
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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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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 />
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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 />
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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 />
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<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.
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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 .
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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.
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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
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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 />
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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 />
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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 />
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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 />
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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 />
A-17
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 />
A-18
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 />
A-19
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 />
A-20
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 />
A-21
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 />
A-22
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 />
A-23
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 />
A-24
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 />
A-25
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 />
A-26
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 />
A-27
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 />
A-28
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 />
A-29
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 />
A-30