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SMC Consolidated Power CorporationLimay Coal-Fired Power Plant Project
Volume I: ESIA Non-technical Summary
FEBRUARY 2016
GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155 | i
Table of contents 1. Introduction..................................................................................................................................... 1
2. The Project ..................................................................................................................................... 2
2.1 Project components ............................................................................................................. 4
2.2 Project phases ..................................................................................................................... 5
3. Summary of environmental and social baseline conditions, impacts and mitigating
measures........................................................................................................................................ 6
3.1 The Project and land resources ........................................................................................... 6
3.2 The Project and ecology ...................................................................................................... 7
3.3 The Project and water resources ......................................................................................... 9
3.4 The Project and air ............................................................................................................. 10
3.5 The Project and the people ................................................................................................ 11
4. Environmental and social management and monitoring .............................................................. 13
Table index Table 1 Main features of the Project ................................................................................................. 2
Figure index
Figure 2-1 Project location .................................................................................................................... 3
GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155 | 1
1. Introduction SMC Consolidated Power Corporation (SMC CPC) is undertaking the development of the Limay
Coal-Fired Power Plant Project utilising the Circulating Fluidised Bed (CFB) Boiler technology in
Barangays Lamao and Alangan in the Municipality of Limay, Province of Bataan. The Project is
expected to have a total installed capacity of 600 MW, to be developed in two phases, each
having a generation capacity of 2 x 150 MW. The Project includes the development of an ash
storage facility to manage the wastes that will be generated by the power plant once operation
starts.
The Project was issued an Environmental Compliance Certificate (ECC), presented in Appendix
A, by the Environmental Management Bureau of the Department of Environment and Natural
Resources (DENR‒EMB) in 2014 following the submission of an Environmental Impact
Statement (EIS) prepared by LCI Envi Corporation (LCI), which satisfactorily complied with the
requirements of the DENR‒EMB under Presidential Decree 1586 (Establishing Philippine EIS
System). Construction of Phase 1 of the power plant commenced in 2013 and full commercial
operation of Phase 1 (i.e. both units) is scheduled in January 2017.
SMC CPC has decided to seek funding for Phase 1 of the Project from international lending
institutions, consisting of a project finance facility to be provided by Mizuho Bank, Ltd and
Standard Chartered Bank, and SMC CPC’s equity. SMC CPC is required to prepare and submit
an Environmental and Social Impact Assessment (ESIA), in accordance with applicable
environmental and social performance standards such as Equator Principles (EP), International
Finance Corporation (IFC) Performance Standards and World Bank (WB) Environment, Health,
Safety (EHS) Guidelines, in order to meet the requirements of international lenders.
SMC CPC has commissioned GHD Pty Ltd to undertake the additional studies required for the
ESIA, and to develop the Environmental and Social Management System (ESMS),
Environmental and Social Management Plan (ESMP) and Environmental and Social Action Plan
(ESAP) of the Project in compliance with Philippine regulations and international finance
requirements.
The purpose of this ESIA is to identify and assess potential environmental and social impacts of
the Project and ensure that the Project complies with relevant national and international
standards, specifically the Equator Principles, IFC Performance Standards, and WB EHS
general and industry-specific guidelines.
This ESIA was prepared at the time when SMC CPC was roughly 19 months into project
development. The report is a compilation of the documentation prepared by LCI to secure the
Project’s ECC, project updates and development stages from the time the ECC was issued until
December 2015 (i.e. preparation of this report), validation of findings onsite by GHD from March
to November 2015, and additional studies to determine the cumulative impacts of the Project.
Through these activities, the ESIA specifically aims to:
Determine the current status of compliance of SMC CPC with applicable guidelines and
standards to serve as a basis for establishing the acceptable incremental impacts from
project-related activities
Validate and assess baseline information against the environmental status during the
construction and operation phases of the Project
Identify environmental and social impacts and assess their significance
Establish mitigation measures, as well as a monitoring program to address residual
impacts after mitigation measures have been implemented
2 | GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155
Inform the community about the Project
2. The Project SMC CPC is currently developing a 600 MW coal-fired power plant utilising the CFB boiler
technology. The Project is located in Barangay Lamao in the Municipality of Limay, Province of
Bataan (Figure 1). It has a total land area of 47 hectares, 37 hectares of which is apportioned to
Phase 1 and 10 hectares of which is apportioned to Phase 2. The ash storage facility has a total
land area of 27.6 hectares. It is located two kilometres away from the power plant facility.
The Project is situated within an industrial area owned by Petron and its subsidiaries, with the
land area of the Project under the ownership of New Ventures Realty Corporation (NVRC) and
the foreshore area of the Project currently leased to Grand Planters International Incorporated
(GPII). The Project area is bounded on the north by Petron Bataan Refinery, on the east by
Manila Bay, on the south by the fishing community of Barangay Lamao, and on the west by the
Bataan Provincial Highway.
The project will be developed in two phases, with Phase 1 and Phase 2 each having a
generation capacity of 2 x 150 MW. The construction of the Project has commenced in the last
quarter of 2013 and is roughly 19 months into project development at the time of the preparation
of this report.
The main features of the project are summarised in Table 1.
Table 1 Main features of the Project
Features Phase 1 Phase 2 Total
Generation capacity (MW)
2 x 150 MW 2 x 150 MW 4 x 150 MW
Technology 2 x CFB boiler 2 x CFB boiler 4 x CFB boiler
Area 37 hectares 10 hectares 47 hectares
Pier facilities 46 hectares (Foreshore Lease Agreement currently under application)
46 hectares
Coal consumption Approximately 178 tons of coal per hour
Approximately 178 tons of coal per hour
Approximately 356 tons of coal per hour
Freshwater requirement 1,600 m3/day 1,600 m3/day 3,200 m3/hour
Cooling water requirement (sea water)
72,000 m3/hour 72,000 m3/hour 144,000 m3/hour
Coal source Local and imported Local and imported Local and imported
Ash storage facility 27.6 hectares
11/F Alphaland Southgate Tower, 2258 Chino Roces Avenue corner EDSA, Makati City 1232 Philippines T 63 2 479 5600 F 63 2 479 5601 E [email protected] W www.ghd.com
AlanganKitang 2 & Luz
AlanganLamao
LamaoBatangas II
238,500
238,500
239,000
239,000
239,500
239,500
240,000
240,000
240,500
240,500
241,000
241,000
241,500
241,500
242,000
242,000
242,500
242,500
243,000
243,000
243,500
243,500
244,000
244,000
1,605,
500
1,605,
500
1,606,
000
1,606,
000
1,606,
500
1,606,
500
1,607,
000
1,607,
000
1,607,
500
1,607,
500
1,608,
000
1,608,
000
1,608,
500
1,608,
500
G:\71\12155\GIS\Maps\MXD\Rev0\7112155_2-1_ProposedProject_rev0.mxd© 2016. Whilst every care has been taken to prepare this map, GHD, NAMRIA, Google Earth and OSM make no representations or warranties about its accuracy, reliability, completeness or suitability for any particular purpose and cannot accept liability and responsibility of any kind (whether in contract, tort or otherwise) for any expenses, losses, damages and/or costs (including indirect or consequential damage) which are or may be incurred by any party as a result of the map being inaccurate, incomplete or unsuitable in any way and for any reason.
LEGEND0 250 500
MetresMap Projection: Transverse Mercator
Horizontal Datum: WGS 1984Grid: WGS 1984 UTM Zone 51N
SMC Consolidated Power CorporationLimay Coal-Fired Power Plant ProjectEnvironmental and Social Impact Assessment
Figure 1
Job NumberRevision 0
71-12155
19 Feb 2016
SMC Project Siteo Date
Data source: GHD/SMC - SMC Project Site and Ash Storage Facility. NAMRIA - Barangays. Google Earth - Satellite Imagery (Date captured: 2015-06-03). Created by:agciar
Paper Size A3SMC Project SiteAsh Storage FacilityBarangays
SMC Project Site
4 | GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155
2.1 Project components
The main components of the Limay 600 MW Coal-Fired Power Plant Project consist of the
power plant, coal handling system, pier facility, ash storage facility, and other auxiliary and
support facilities.
Power plant
The power plant comprises mainly of CFB boilers with steam turbines. The boiler serves as the
coal combustion chamber, wherein heat from the combustion of coal boils water to produce
steam at high pressure and temperature. The high pressure steam then impinges and expands
across a number of blades in the turbine, thereby rotating the turbine to produce energy.
A total of four boilers, each having a capacity of 150 MW will be constructed for the Project. Two
boilers will be initially constructed for Phase 1, while the other two boilers will be constructed for
Phase 2 of the Project.
Each boiler is of subcritical pressure, with single drum, natural circulation, radiant and water-
cooled furnace, steam cooling wall back path, reheat, balanced draft, and outdoor, basic detail
design. In order to ensure compliance with relevant environmental standards, the boilers are
designed with low temperature combustion to limit NOx formation; limestone injection into the
furnace for desulfurisation; and electrostatic precipitator for dust collection.
Coal handling system
The coal handling system will haul coal supply from the unloader, transfer coal into the storage
and into coal crushers, then into the coal silos, and finally into the boiler. The coal conveying
system will be totally enclosed to prevent coal dusting during transport.
Pier facility
A new pier has been constructed for the plant, which has an unloading facility that includes the
port and jetty, ship unloaders, and the coal conveying system. Coal will be supplied from a local
coal blending facility or from an imported coal supplier, and delivered via Panamax vessels or
mid-sized cargo ships.
Ash handling and storage
Fly ash and bottom ash collected from the electrostatic precipitator will be initially stored in
individual silos prior to hauling and disposal. All fly ash and bottom ash will be hauled to the ash
storage facility located approximately two kilometres from the power plant site. Both fly ash and
bottom ash will be hauled daily by 20-ton dump trucks with tarpaulin covers to prevent dust and
fugitive emissions during transportation. SMC CPC will deploy 10 bulk carrier trucks and 10
dump trucks per day for the hauling of ash to the ash storage facility. An additional 5 bulk carrier
trucks and 5 dump trucks will be on standby in case of emergencies. At present, SMC CPC is
negotiating with several cement manufacturing companies to sell all fly ash.
GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155 | 5
2.2 Project phases
2.2.1 Pre-construction
The pre-construction phase of the Project entailed land acquisition and transfer of ownership,
and initial site preparation and development activities such as sourcing of suppliers, contractors
and other service providers, preliminary engineering studies, acquisition of necessary permits
and licenses, fuel supply and power offtake arrangements, and enhancement of road networks
for increased accessibility and transport of materials.
2.2.2 Construction
The construction phase of the Project consists of civil, mechanical and electrical works. This
involves the activities such as hiring of workers, site development ‒ land clearing and
earthmoving works, foundation development, and construction and installation of the power
plant components, its auxiliary facilities, and the pier facility.
Measures to ensure minimal impact on surrounding areas from dust emissions and noise are
implemented during the construction phase.
2.2.3 Operation
The Project will initially operate with a capacity of 300 MW for Phase 1, until its full operation of
600 MW. Construction of the Project commenced in the last quarter of 2013 and commercial
operation of Units 1 and 2 are expected in August 2016 and January 2017, respectively.
Construction for Phase 2 of the Project will coincide with Phase 1 construction until its expected
commercial operation for Units 3 and 4 in the last quarter of 2017. The construction of the ash
storage and support facilities will start by second quarter of 2016. It will be ready to accept ash
by August 2016.
The main activities during the operation phase include 24/7 operation of the power plant and its
auxiliaries, sourcing and delivery of coal supply, and unloading of coal at the pier, coal handling
and combustion for electricity generation. Maintenance of the plant facilities, including the coal
yard, and environmental pollution control and monitoring will also be part of the operational
activities. Environmental management measures will be implemented during this phase.
The core activity of the ash storage facility is limited only to the transportation of ash from the
plant to the storage of fly ash and bottom ash. The facility will be monitored for any
contaminations or leachates, and preventive measures will be implemented to avoid any
harmful impacts to the environment.
2.2.4 Abandonment
The power plant is projected to have an operating life of over 25 years. A more detailed
decommissioning or abandonment plan will be developed until such time or five years prior to
the end of the project operating life.
6 | GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155
3. Summary of environmental and social baseline conditions, impacts and mitigating measures 3.1 The Project and land resources
3.1.1 Land use
The municipality of Limay is characterized half of its land area is agricultural and the other half is
comprised of forests, open areas and shrub lands, residential and commercial establishments.
The project area is categorised as ‘Alienable and Disposable Land (A&D). The section where
the Project is located is classified as an industrial zone for the land, and a shipping and
navigation zone for the coastal land and sea portions.
The Project area is located near water bodies and is flood prone especially those along the
coastal waters.
The Project is considered an environmentally-critical area due to its proximity to a water body,
namely Manila Bay, where the Project intends to place their marine facilities. Despite its general
classification as suitable for recreational activity and fisheries, the location of the Project’s
facilities will be in an area of the bay that can be used and is classified for shipping and
industrial purposes.
There are no foreseen conflicts or impacts due to inconsistency with current land use since the
project area is privately-owned within an industrial zone and do not contain other areas declared
under other classifications such as forest lands or agricultural lands.
Since the Project site is both flood-prone and near water bodies, it must maintain and develop a
proper drainage system as well as an emergency response plan in order to reduce flooding. It
must also include steps to control their pollution and waste and comply with the set standards
for water quality.
3.1.2 Geology and geological hazards
Mt. Mariveles is a potentially active stratovolcano located in the southern end of the Bataan
Peninsula characterized by rocks ranging from basaltic to andesitic. Specifically for Barangay
Lamao, rocks originated from Mt. Mariveles and are quarternary pyroclastics in nature and also
the dominant rock type beneath the project site. The coast and stream cuts have quarternary
alluvium deposits, which are mostly sandy and gravelly deposits in nature.
The Project area is flat in nature and located along the coast. The geomorphology of Limay and
vicinity is dominated by the natural drainage pattern cutting through the volcanic apron of Mt.
Mariveles as evidenced by the dendritic like pattern of channels radially arranged from the
summit of Mt. Mariveles.
The Project site has a low chance of flooding except for the areas near the river, where there is
a possibility of flash floods during heavy rainfall. It is also predicted that rainfall will increase in
the coming years.
Mt. Mariveles poses a risk to the Project since it is classified as a potentially active volcano with
activity that can range from very quiet to violent eruptions. Should an eruption occur, the Project
site is at risk of pyroclastic flows, ash fall, and lahar. Nearby volcanoes can also affect the site,
but only by ash fall that depends on the direction of the wind.
GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155 | 7
The Project site may experience seismic activity due to its proximity to a volcano (Mt. Mariveles)
and its location within the western flank of Luzon, which has history of seismic activity. As a
result, the Project site is also exposed to seismic related hazards especially ground shaking.
Based on analysis of the project area, ground rupture, liquefaction, mass movement and
tsunamis will not affect t the project and have low possibilities to occur due to its flat topography,
location, stability and absence of faults.
Potential impacts may arise during project phases. During construction stage, the site was
flattened with the top soil removed and cut and fill strategy implemented which poses risk of
surface erosion and localized flooding. Mitigation will need installation of proper drainages, but
otherwise, no additional impacts are perceived during plant operations. Inducement of localized
flooding may occur during the site preparation and construction stage of the project. No
landslides are expected except where cuts will be made inducing temporary unstable slopes. As
mitigation, good engineering practices will be implemented but otherwise, no additional impacts
are perceived during plant operations.
3.1.3 Pedology
Based on the soil map of Bataan, the soils found in the upper slopes of Mt. Mariveles are
categorized as Undifferentiated Antipolo Soils, while soils from the lower slopes and coastal
portions between Lamao and Ayam, is of Antipolo Clay.
Concentrations of most metals in the soil except for arsenic, cadmium, and copper conformed to
the levels set by the Dutch and US EPA. The soils roughly have the same composition due to
the small differences in concentrations between samples. Despite the differences in
concentrations, these metals may be naturally inherent to the site, which is volcanic in origin.
Based on soil analyses, impacts of the project to soil quality will be minimal to negligible during
the operation and decommissioning phases of the Project. Soil contamination may occur due to
accidental leaks and spills onto the surface of the soil. Should this occur, the chemicals may
permeate into the soil and result to soil and groundwater contamination. As mitigation,
secondary containment measures such as concrete lining, bund walls, clay base in the ash
storage area, and/or spill containing equipment to prevent such potential impacts from arising
will be implemented. Groundwater monitoring will be undertaken as well.
A change in soil quality is unlikely but may result from excavation of soil materials due to
subsurface disturbance affecting surrounding environment structures through the exposure of
contaminated materials and mobilisation of runoff or groundwater. As mitigation, spoils or
excavated materials will be properly contained to avoid surface runoff to nearby water bodies.
3.2 The Project and ecology
3.2.1 Flora
The project site is located along in an industrial area indicating a highly disturbed environment
characterized primarily by few trees, palms, shrubs, herbs and a grassland ecosystem. More
than 50% of the recorded plants in then power plant site can only be found in the Philippines
while the rest are either native or introduced. There are no threatened plants recorded on the
power plant site but two threatened plants were recorded outside the power plant site. Eight
invasive plants were recorded in the power plant site.
In terms of ecosystem services, some plants recorded have potential for medicinal, ornamental,
field and fodder and lumber purposes but the existing condition of the project site has a minimal
provision for regulating services. Supporting and cultural ecosystem services were also very
minimal or almost nil due to existing conditions.
8 | GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155
Potential impacts of the project will include removal of vegetation, dust generation, proliferation
of invasive species and loss of provisioning services. As mitigation, the proponent will minimize
clearings, comply with tree cutting permit regulatins, implement buffer zones, reduce dust
sources, and implement plans such as conservation corridor plans and pest and weed
management plan.
3.2.2 Fauna
Given that the project area is highly disturbed, most the recorded animal species are common,
widespread and are adapted to disturbed habitats. Most of the animals recorded are birds and
few amphibians, reptiles and mammals. Only a few endemic and threatened animal species
were recorded. Five animal species recorded along the project site were known to be invasive
species.
Vegetation removal and loss of habitat, threat to existence of important species, threat to
abundance of animal species, invasive species proliferation and habitat fragmentation are the
potential impacts of the project to animals. As part of the proponent’s mitigation for such
impacts, revegetation, restoration and enhancement of the existing condition will be
implemented. A species action plan and pest management plan for important species and
invasive species will be implemented respectively.
3.2.3 Freshwater ecology
The freshwater communities along Ayam River are composed mostly of plankton communities
followed by macroinvertebrates and by other freshwater organisms. Most of the species
recorded are common and widespread and can be encountered along related and comparable
freshwater ecosystems along the country. None of the recorded species are either threatened or
of conservation importance. The presence of certain macroinvertebrates (stoneflies, caddisflies
and mayflies) but in low proportions indicates a declining water quality. It is also an indication of
the impacts of the observed dumping of domestic wastes by residents along the river. The
upstream portion of the river is being utilized by locals for fishing, domestic purposes and for
agricultural use.
Potential impacts likely to affect freshwater community include increased surface water run-off,
oil spills, coal spill and pollution by wastes (i.e. domestic, sewage). Corresponding mitigating
measures such as management and control measures for surface run-off, appropriate bunding
of fuel storages, waste water treatment facilities, and waste management plans will be
implemented. Avoidance measures such as fuel and coal storages to be built far from water
bodies will be applied, response protocols and standard maritime procedures will be followed
and engineering controls (e.g. sediment fences, siltation ponds, drainages) will also be built.
3.2.4 Marine ecology
The marine ecology along the Manila adjacent the proposed project site is a plankton-based
ecosystem. There were no seagrass and coral communities recorded along the area. Most of
the fish captured by fishermen are plankton consumers and their corresponding predators,
mostly pelagic. Though there was mangrove communities recorded, these are along indirect
impact areas which will have insignificant impacts from the project.
Potential impacts of the project are mainly due to activities related to coal handling, storage and
processing (i.e. intake of cooling water, thermal plume, construction of pier and associated
facilities, ship operation, coal unloading, transport, etc). Since a large seawater intake and
thermal plume is expected, mitigation measures will be implemented in order not to disrupt the
plankton-based ecosystem of the area. For the pier and associated facilities, these will be
constructed in the form of pillars/piles to prevent disruption of coastal hydrodynamics. With
GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155 | 9
increased shipping activities, specific and appropriate measures and standards will be strictly
followed to prevent spills and other impacts to the coastal waters.
3.3 The Project and water resources
3.3.1 Hydrogeology (water use)
Three wells were installed onsite, within the project site to serve as water supply wells for the
planned power plant. Given the ground recharge in the area and the estimated water usage of
SMC at 133 cu.m. for both Phase 1 and Phase 2, projected water balance is at 1244 cu.m.
Barangay Lamao, the residential area nearest to the project, sources its water from the Lamao
Water System (LWS) operated by the government. Residents not supplied by the LWS rely on
shallow wells and springs. SMC will be tapping the deeper aquifer hence the possibility of
affecting the local wells is low.
The only well used by the community is around 0.5 km away from the proposed wells of the
Project and is unlikely to be affected by any drawdown.
While water use competition with the nearest community is unlikely, the conditions stipulated by
the water permit issued by the NWRB must be strictly followed to prevent over usage of the well
that may potentially impact its quality or availability.
3.3.2 Water quality
Surface water quality in the area is within the DAO 90-34 with the exception of three parameters
– total coliform, lead and mercury. The high coliform in the sampled stations may be linked to
the poor sanitation in the area and discharge of domestic wastes from residential communities.
Only Alangan station was slightly above the allowable DAO 90-34 lead limit of 0.05 mg/L. The
water samples in the vicinity of the ash storage site had mercury concentrations slightly above
the DAO 90-34 guideline. Water samples from Ayam River exhibited minor discoloration, which
according to nearby residents attribute this to a gun powder and ammunitions factory that is
located upstream.
The coal yard is an enclosed building thus stormwater will not get in contact with the stored
coal. Thereby surface run-off from coal storage facilities will not discharge to Ayam River. Waste
generation and poor waste management may also affect the nearby Ayam River. To prevent
these potential impacts, SMC will implement a solid waste management and monitoring
program including the installation of sanitation systems, where it will be required.
Groundwater samples were within the Philippine National Standard for Drinking Water
(PNSDW), apart from a few parameters. Similar to the surface water samples, total coliform and
lead exceeded the limit set by PNSDW.
During operation, the potential impacts arising from the utilization of the groundwater wells are
the possible introduction of contaminants into the groundwater, siltation of the deep well and
water depletion. To prevent these incidents from occurring, secondary containment measures
will be considered. A potential impact of the ash storage operation is leaching of contaminants.
Perimeter and under drainage systems will be utilized to collect any seepage or runoff from the
ash storage facility. A clay base for the ash storage area and leachate collection pond will be
provided to limit seepage of water into the environment. Groundwater monitoring bores will also
be established within and in the vicinity of the ash storage facility to monitor background and
downstream groundwater levels and quality.
Samples collected from the coastal waters showed that stations were within their respective
limits with the exception of total coliform, cadmium, lead and copper concentrations, which
exceeded the DAO 90-34 standards.
10 | GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155
Impacts to the marine water quality during the operation and construction phases of the project
will be localized and minimal only. Based on the ecological survey, neither live hard corals nor
reef-fish species were recorded in the area; therefore, the potential impact to the aquatic
environment is marginal.
3.3.3 Oceanography (thermal plume)
SMC thermal plume modelling reveals that the largest section of the plume will have a
temperature ranging from 0 to 0.25 to 0.25 to 0.5 °C. Model runs also show that in general,
lower velocities achieved compliance at areas that are further downstream of the discharge
point and yielded wider plumes, owing to less mixing in the near field. Also, deeper outfalls had
smaller plumes at the surface; as the buoyant discharge travels a vertical distance, this allows
heat to dissipate prior to reaching the surface.
Model results show that the discharge plumes of the nearby oil refinery plant are much larger at
the surface compared to the SMC plumes, primarily due to larger temperature excess of the
Petron discharge effluent compared to ambient, and to the shallow discharge depth.
Due to the large size of the discharge plume of the nearby refinery, SMC discharges directly into
its mixing zone during tidal ebb, whence current flows southward, although this is not the case
during flood period (northwest current direction). As the site experiences tidal reversal, this
means that the interaction of the SMC discharges with the oil refinery is temporary.
Given the tidal reversing conditions at the site, the mixing zone is not stationary, but shifts
depending on the basis of the prevailing current direction. However, at any one time, this mixing
zone is not expected to be exceeded, and in most cases, the expectation of the surface plume
size is much smaller.
3.4 The Project and air
3.4.1 Air quality
Cumulative air dispersion modelling was carried out to determine the impacts of the Project, as
well as its contribution to cumulative impacts, on the ambient air quality.
The key finding of the study is that Project stack emissions have a high likelihood of complying
with Philippine ambient air quality standards. Insignificant air pollution hotspots assuming that
the design emission rates hold are also likely. There were pollutants, however, specifically the
1h SO2 and NO2, where the predicted GLCs have exceeded 50% of the standards. The EMB Air
Dispersion Modelling Guidelines specifies that a more refined modelling is required if this
happens. Since the AERMOD model is already considered by the guidelines as a “refined”
model, the next step for complying with the requirement is to simulate Project emissions using
actual onsite weather measurements for at least three years.
In addition, the EMB will require a Permit to Operate (PO) for the boilers and other air pollution
sources (back-up generators, among others) at the Project. One of the requirements of the PO
application for large sources is to demonstrate compliance to the CAA by doing air dispersion
modelling. The following measures will be done by SMC CPC for the air dispersion model
validation:
1. Inventory of other air pollution source installations at the Project;
2. Generation of actual emission rates by a) installation of a Continuous Emissions
Monitoring System (CEMS) for applicable pollutants, and b) regular source sampling tests
for sources and pollutants not covered by the CEMS; and
3. Installation of an automatic weather station to measure temperature, rainfall (to account
for wet deposition), wind speed, wind direction, and solar radiation (for deriving stability).
GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155 | 11
The identified air quality impacts during both construction and operation period are dust and
generation of air emissions such as SOx, NOx and particulate matter. To address dust
emissions, dust suppression measures, such as wetting of unpaved surfaces, equipment
washing facilities and tarpaulin covers on trucks loaded with dust-generating materials, are in
place. For the operation phase, SMC CPC will install a Continuous Emission Monitoring System
and conduct regular checking and maintenance of plant components, pollution control devices,
heavy machineries and vehicles to ensure that the Project will comply with regulatory standards.
3.4.2 Noise
Sensitive receptors in the vicinity of the Project were identified for the noise assessment. Site
investigation and noise monitoring indicated that the background noise environment of some of
the identified sensitive receptors located within the vicinity of the Project Site was dominated by
industrial noise from the existing Petron Bataan Refinery. Generally, ambient noise environment
at the identified sensitive receptors was influenced by local traffic noise and neighbourhood
activities.
Findings from the attended noise measurements indicate that the existing refinery noise was
audible during the daytime and night-time measurement period. Noise from on-site construction
and the Petron Bataan Refinery were inaudible during the attended measurement period at all
monitoring sites other than the above-mentioned periods.
Noise model results based on the adopted assumptions indicate operational noise emanating
from the Project Site is generally predicted to comply with both the NPCC as well as the IFC
noise criteria at the assessed sensitive receptors. The characterised existing industrial noise
levels from the Petron Bataan Refinery alone are above the NPCC night-time noise criteria, as
well as IFC criteria. Hence, the predicted change in noise level due to the operation of the
Project is not expected to be noticeable to the nearby assessed residential sensitive receptors.
Nevertheless, noise mitigation measures will be implemented to minimise potential noise impact
as far as practicable, in particular during the night-time period of operation. Measures include
proper siting of noise-generating equipment, scheduling of noise-generating activities and
selection of equipment/machine system that minimise noise emissions. All mechanical plant and
equipment will be checked regularly to avoid any unnecessary noise caused by lack of
maintenance. All site workers will be sensitised to the potential for noise and vibration impacts
on local residents and encouraged to take practical and reasonable measures to minimise the
impact during the course of their activities. Noise monitoring will also be undertaken to assess
and characterise any noise impact exceedance at the sensitive receptor, as a result of the
construction and operation of the Project.
3.4.3 GHG
At the worst-case, the estimated annual GHG emission of the Project is 4,594,163 MT with a
normalized GHG emission of 966g/kWh. SMC CPC will enhance energy efficiency of plant
operations (i.e. energy consumption) and promote sustainable forms of forestry (i.e.
reforestation programs) through its Corporate Social Responsibility (CSR)/Social Development
Program (SDP).
3.5 The Project and the people
3.5.1 Socio-economic
Labourers and unskilled workers make up the largest section of residents from Barangay Lamao
and Barangay Alangan. Farmers, forestry workers and fishermen consist of 9% of the
workforce.
12 | GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155
During the operation phase, delivery of coal is the main activity identified by fishermen to impact
their fishing activities. Concerns raised by the community include potential restriction of fishing
activities near the jetty, security issues, and the possibility of intimidation of small fishermen by
the security officers of industrial plants in the coastal areas of Barangays Lamao and Alangan.
Non-consultation of communities prior to construction of SMC CPC power plant and its
associated facilities as well as establishment of other industries in the area was also
communicated by the community.
SMC CPC prioritizes community safety, thus an exclusion zone will be established in the jetty
area especially during coal delivery. The marine resource within the jetty area is poor and not a
viable fishing ground for the nearby fishing community. Nonetheless, SMC CPC will implement
a Livelihood Restoration Plan as part of its corporate social responsibility and to address the
potential income loss due to lost fishing ground. As part of SMC’s commitment to its host
community, SMC CPC will prioritize locals on employment opportunities as well as provide
alternative livelihood. The Stakeholder Engagement Plan to be implemented by SMC CPC will
include measures to address the concern of the community on the possible intimidation of
security guards from SMC CPC. The Stakeholder Engagement Plan will include setting up of
regular engagement activities where affected residents may air their concerns. SMC CPC will
implement a grievance mechanism to ensure that concerns and valid complaints are addressed.
3.5.2 Cultural (cultural heritage)
The Province of Bataan, despite its extensive industrialisation, is also home to a group of
indigenous peoples (IPs) known as the Aetas or as Negritos (translated as “small blacks” in
Spanish). Aeta groups can be found in central (Aeta, Ita), eastern (Dumagat) and southern
Luzon (Agta) and several islands in the Visayas (Ati). Due to successive waves of immigration,
the Aetas of Luzon now primarily exist in the Provinces of Bataan, Zambales, Pampanga, Tarlac
and other distributed areas.
The Aeta of Bataan Peninsula, particularly in the municipalities of Morong, Mariveles and Limay,
are known as the Aeta Magbukún. They live a nomadic existence in the edge of a remaining
forest cover and watershed area of Mariveles Mountain and Bataan Natural Park, approximately
10 km and 35 km from the Project site (straight line distance).
Some groups of Aeta Magbukún were recorded in the Municipality of Limay. However, there is
no known Aeta Magbukún or IP group/tribe in Barangay Lamao, where the SMC Limay 600 MW
Coal-Fired Power Plant will be developed.
There are 11 cultural/ historical landmarks identified within Bataan, all of which are located
outside of the municipality of Limay, where the Project site is located.
With no known IP group residing and no known cultural properties within the project area prior
to the development, it is deemed that the Project area has no impact of cultural significance. In
case of any chance finds, a chance or accidental finds procedure has been prepared by SMC
CPC.
GHD | Report for SMC Consolidated Power Corporation - Limay Coal-Fired Power Plant, 71/12155 | 13
4. Environmental and social management and monitoring The Environmental and Social Management Plan outlines the measures for managing and
monitoring environmental and social impacts during construction, operation, and
decommissioning of the Project.
For each environmental and social aspect of the Project, corresponding mitigating measures
were identified, as well as the responsibilities (e.g. project proponent or contractor) and
timescales (e.g. construction, operation and decommissioning phases) for the implementation.
Relevant monitoring or key performance indicators (KPI) and the associated plans for
implementation were also included.
The monitoring will form an integral part of the implementation and operation of the Project. This
will also be in accordance with the Department of Environment and Natural Resource (DENR)
Administrative Order No. 2003–30 or the Implementing Rules and Regulations for the Philippine
Environmental Impact Statement (EIS) System, wherein an Environmental Management
Plan/Program (EMP) is required to prevent, mitigate, compensate, and monitor the impacts and
risks of the Project.
GHD
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