Environmental & Social Impact Assessment

Sonker Bunkering Company S.A.E. was founded in 2003 as a petroleum storage, handling, and bunker supply company operating at Basin 3, Sokhna Port free zone, Red Sea near Suez city in Egypt. It is an example of a successful private public partnership as it is jointly owned by the Amiral Holdings Group and companies associated with Egyptian Governmental entities, see pie chart.

The Sonker terminal has been operational since 2009, when it started handling Egypt basic industries corporation’s ammonia exports. EBIC has two ammonia storage tanks of 110,000 m³ in total within the Sonker terminal area. Sonker also operated a contract with EGAS to berth LNG floating storage and regasification units at the Sonker jetty between Q2 2015

Q3 2018. In the period 2015-2020 Sonker built a world class bulk liquids tank farm (the SBLT-project) consisting of storage tanks for Gasoil (100,000 m³) and Liquefied Petroleum Gas (LPG, 150,000 m³).

Sonker has signed and is operating a long-term supply point agreement with Egyptian General Petroleum Corporation – EGPC. This agreement is for the use of the Sonker bulk liquids terminal and includes the delivery of Gasoil and LPG by vessels at the Sonker jetty, the handling, storage and the redelivery into the EGPC underground national network.

The Sonker bulk liquids terminal (SBLT) is located in Basin 3 at Sokhna Port near Suez city in Egypt and spans an area of 400,000 m2 inside which the EBIC facility has been realized on an area of 50,000 m2.

The SBLT project, further described as phase 1, involves the following main components:

• 1. Construction and operation of 3 refrigerated tanks, each of 50,000 m3 capacity for a total storage of 150,000 m3 of liquified petroleum gas (at normal atmospheric pressure), including related equipment.
• 2. Construction and operation of 2 tanks of 40,000 m3 and 1 tank of 20,000 m3 capacity for a total storage of 100,000 m3 of Gasoil.
• 3. Construction and operation of underground pipelines connecting the SBLT tanks to the national networks for both gasoil and LPG.
• 4. The infrastructure for above, including an operations building;
• 5. Seawater intake from and discharge in the port basin for raising the temperature of the LPG and to serve as firefighting water intake.
• 6. Additional piping and (un)loading arms at the existing Jetty.

Phase 1 of the SBLT development is to be followed by other phases, reaching a total storage capacity of 1-1.2 million m3 at the end situation.

National Requirements

In accordance with law 4/1994, law of the environment, and its executive regulations (ERs), Sonker has prepared and submitted an Environmental Impact Assessment (EIA) with the application for the license of new projects and/or extension of existing facilities. Accordingly, environmental requirements are integrated into the existing licensing system.

Sections Pertaining to the Project:

• 1. Air quality
• 2. Solid wastes
• 3. Noise
• 4. Hazardous substances and waste
• 5. Protection of water resources
• 6. Work environment
• 7. Protection of biodiversity
• 8. Environmental register

In addition to law No. 4/1994, work environment and labour protection, are governed by the following laws:

• General public cleaning law No. 38/1967.
• Labour law, No. 12/2003.
• Social insurance law No. 79/1975

2-IFC & EBRD Performance Requirements

The environmental impact assessment study satisfies the requirements and guidelines for projects as financed by both the International Finance Corporation (IFC) and the European Bank for Reconstruction and Development (EBRD). Both IFC & EBRD require the project to abide by its performance standards and guidelines to ensure that the project is environmentally sound and sustainable. Performance standards are applied to manage social and environmental risks and impacts.

IFC & EBRD Performance Standards
Performance Standard 1: Social and Environmental Assessment and Management System

A scoping exercise was carried out during the commencement of the study to include the neighboring activities as well as the Bedouin community south of the project location, which is the only settlement in the area. At a later stage, a public disclosure meeting was held to discuss the study findings. Feedback from different stakeholders during both stages are summarized and incorporated in the report.

Performance Standard 2: Labour and Working Conditions

The report addresses the employment aspects during the different project phases. SONKER adheres to the Egyptian labour law (which was updated to reflect the ILO requirements), including work conditions and child protection laws.

Performance Standard 3: Pollution Prevention and Abatement

The report investigates the environmental releases from different sources during construction and operation phases and their potential impacts. It also investigates relevant mitigation measures to minimize potentially significant impacts of pollutants.

Performance Standard 4: Community Health, Safety and Security

The study assesses the potential impact of the project on the surrounding activities as well as on the workforce during the different project phases. A Quantitative Risk Assessment (QRA) is prepared to quantify potential risks related to fire or explosion.

Performance Standard 5: Land Acquisition and Involuntary Resettlement

Land acquisition for the project components does not involve involuntary resettlement.

Performance Standard 6: Biodiversity Conservation and Sustainable Natural Resource Management

The biological baseline in the project area was investigated and relevant impacts assessed.

Performance Standard 7: Indigenous People

There are no indigenous people at the project location. Moreover, the tank farm exists within an operational port. However, the study presents the participation of the Bedouins in the consultation process of the project, and the actions taken to identify their needs.

Performance Standard 8: Cultural Heritage

Elements of potential cultural heritage value near the project location were identified and presented in the study.

3-International Conventions and Agreements

Egypt is a signatory to various conventions concerning environment protection, among which are: the environmental modification convention; the african convention on the conservation of nature and natural resources; the vienna convention for the protection of the ozone layer; the convention for the prevention of pollution from ships; the Barcelona convention for the protection of the mediterranean sea against pollution; the Brussels convention on civil liability for oil pollution damage and the Moscow treaty for nuclear weapon tests in the atmosphere.

1-Environmental Baseline

Issue	Baseline Condition
Climatic Factors	In general, the climate in Sokhna is characterized by a warm, dry weather most of the year. The dominant winds are from north and north-west direction with an occurrence of 84%. The wind direction with the highest occurrence is the northern wind. The area lies within an arid region. The maximum temperature in the Sokhna region ranges from 20 degrees in January till up to 37 degrees during the months of July and August. Rain is episodic and localized; often in the form of short, heavy downpours causing flash floods. Maximum rainfall occurs in February, followed by January, March and December. The weather is mostly dry during the rest of the year. The relative humidity has an annual mean of about 55% and reaches its peak in the period from October to January and its minimum in May and June
Air Quality	All results from monitoring at five different locations within and surrounding the Sokhna port were found well within the acceptable limits of Egyptian environmental law 4/94, including total VOC levels, which were well below the normal expected levels.
Noise	Noise levels measured at five different locations within and surrounding the Sokhna port were all found well within the permissible limits
Soil Quality	The soil quality poses no significant threat to humans, animals and plant life.
Ground Water Resources	Heavy metal, TPH, Glycol and Total VOC levels were not detected in the samples (lower than the detection limit).
Ecology	The project area is part of the coastal desert plain and includes some of its typical floral species. The area is roughly flat with a higher vegetative cover towards the north, reaching approximately 30% composed mainly of vegetation. However, the specific project area is almost devoid of any vegetation. The existence of fine-grained suspended sediment in water column and on the seafloor does not allow corals to grow. Also, during this study, poverty of the area in marine flora and fauna was noticed.
Archaeological Sites	There are no sites of archaeological importance within or nearby the project location.

2-Environmental Impacts and Mitigation Measures

Sonker to manage and mitigate the environmental impacts as below:

2.1-Construction Phase:

Issue	Baseline condition
Air Quality	Dust suppression Maintaining machinery and equipment Frequent inspection of all construction equipment
Noise Level	Using PPE Machinery maintenance Selection of construction equipment and techniques that minimize noise generation (ex. rotary pile driving rather than hammering)
Seawater and Groundwater Quality	Site management procedures and housekeeping measures, including measures for spill prevention. Oil booms will be available for containment of any oil leakage to the marine environment.
Biological Environment	Selection of equipment types and periodic maintenance. Measures to reduce emissions, noise and vibrations. Avoiding bird migration seasons, if possible. Avoiding night-time work and use of high energy lights, if possible Minimizing vegetative clearance and fencing hazard areas. Development and application of waste management plans. Selection of native vegetation for landscaping.
Workplace Health and Safety	Provision of PPEs to workers. Adopting spill prevention plans. Proper material storage, labelling and handling. Installing firefighting system. Proper waste management.

2.2-Operation Phase:

Issue	Measure
Air quality	Recovery of fugitive emissions from LPG tanks and loading/unloading operations. Controlled burning (flaring) of evaporated gases during abnormal conditions.
Noise Level	Machinery and equipment design according to standard specifications. Use of acoustic enclosures for noise generating equipment. Periodic equipment maintenance. Provide workers with PPEs.
Seawater and Ground Water Quality	Use of dry break couplings for all loading/unloading arms and hoses. Provision of leak collection facilities at liquid handling locations. Rainwater collection within curbed/bunded areas. Site management and appropriate housekeeping activities
Soil and Groundwater	Use of bunded areas for collection of potential leaks/spills in all areas of concern Adopting spill prevention plans Provision of containment and emergency response procedures and equipment
Biological Environment	Implementation of measures to minimize emissions, noise and vibration Noting bird migration/breeding seasons Avoiding night lighting as possible Developing and implementing waste management plans Selection of native vegetation for landscaping
Workplace Health and Safety	Abiding by all national occupational health and safety regulations as well as IFC EHS guidelines Planning for preventive maintenance programs Provision of suitable PPE Conducting periodic medical check-ups Preparation and adoption of emergency plans Preparation of quantitative risk assessment covering potential hazard situations.

1-Social Environment

The surrounding activities are limited to industrial and tourism sectors. An industrial area to the west of the port includes a worker’s camp, over 9 km east of the project location. A Bedouin settlement also exists over 6 km to the southwest of the project location. The closest tourism resort is approximately 3 km north of the project location.

Mining and manufacturing are among the basic economic sectors in the Governorate. Petroleum extraction and refinement, chemical and cement industries, and food industries, are the backbone of the industrial base in Suez.

Traditional activities are centered on fishing and livestock. Cultivation is strained by the poor quality of the soil, and the limited amount of fresh water to grow vegetables and fruits.

2-Social Impacts and Mitigation Measures

Sonker to manage and mitigate the environmental impacts as below:

Issue	Measure
Land Taken for the Project	Land used for the project lies within an operational port, which has been allocated as a tank farm since the master planning phase of the port. This project does not include any components outside the port fences.
Air and Noise Emissions during Construction and Operation	the study shows that noise and air quality impacts would not be significant outside project boundaries.
Road Transportation Activities	Trucking activities are limited to the construction phase, which is both of low magnitude and duration. Accordingly, the project operation will have no interference with road networks, except for transportation of the working staff.
Utilities (Water and Electricity)	The project does not involve industrial activity since it provides temporary storage, loading and unloading of LPG and Gas Oil. The electricity and potable water demands are acceptable.
Cultural Environment	The presence of foreign labour, with a cultural background that is different from that of the locals may cause some cultural tensions. However, the locals are used to the presence of foreigners in the port area. Any foreign workers will be instructed to respect the local prevailing culture.
Employment	During construction phase, the contractor will be instructed to use local labour as much as possible. During operation phase, most of these positions will be filled by Egyptian nationals and applications by local inhabitants will be encouraged, particularly from Suez Governorate
Influx of Construction Crew	it is not expected that there will be any significant activities resulting from catering for the influx of workers or due do misconduct of the workforce.
Community Health	In view of the project insignificant atmospheric and noise emissions, it is not expected to pose any community health impacts.
Impacts Related to Security Personnel	The project is located within the premises of an operational port. There is no interaction between the guards with any locals outside the port fence.

The gaps identified by the Independent Environmental and Social Consultant (IESC) during its due diligence process have been addressed in an Environmental and Social Action Plan (ESAP). The ESAP summarizes mitigation and improvement measures that have been implemented by Sonker to ensure that operations shall be carried out in compliance with relevant local laws and regulations, as well as with the Lenders Environmental and Social (ES) Policy and other requirements and standards applicable to the project.

During the implementation of this project, Sonker should meet the requirements set down by relevant national, IFC and EBRD environmental, social, health and safety legislation and standards, as defined in the Environmental and Social Action Plan (ESAP) to be fully implemented by Sonker. The most stringent regulations and/or requirements will be applied, in order to ensure environmental protection and community health and safety.