The design of the proposed project is based on established state-of-art and worldwide applied technologies whose performances are both predictable and well proven in operation, so that no significant variations are expected to be found between predicted and actual performance in the field. The use of state of the art technology will also help the project making optimal use of energy and water. In addition, the project has been designed to comply with the most stringent of Argentinian Standards and applicable WBG EHS guidelines. Resource Conservation, Energy Efficiency As part of its EHS management, Axion has an Energy Management System in place to track and optimize energy usage. It conducts periodic monitoring of conditions and efficiency of the boilers, and assesses combustions controls, among others. For the current operation, Axion’s energy efficiency performance and water consumption can be considered satisfactory when compared with those parameters included in the WBG’s Petroleum Refinery EHS guidelines. In addition, every two years, Axion participates in the Solomon refineries survey benchmarking, which includes 300 refineries worldwide. For the last eight years, Axion has been among the lowest energy and water refinery consumers among the 30 Latin American refineries part of this survey. IFC recommended the company to expand its benchmarking to refineries of other regions to compare its performance and further improve its energy and water consumption rates, if needed. The energy demand due to the expansion will be twice the current demand, it will expand from the current 25 MW installed capacity to 50 MW; and it will be sourced from the public grid as well as from the onsite steam turbines power generation. . Currently, the plant is connected to the main grid through an underground cable. As part of the expansion, the company is adding an additional 60 MVA capacity to the existing internal/external electrical power supply. This additional capacity will be supplied from external and independent sources from the national grid. The connecting 5.5. Km lines will be underground, thus overall minimizing negative impacts. However, as part of its energy optimization approach, Axion will identify the worst case energy consumption scenario and improve operations reliability, conduct energy improvements and optimize overall energy usage, it will conduct pinch analysis looking to improve the refinery’s Energy Intensity Index (EII) and optimize the use of the available fuel gas stream. Stack Air Emissions Main sources of air emissions during the operation phase include the catalytic cracking unit, nine furnaces and five boilers. Although the air emissions currently comply with the local Argentinian regulations, they do not comply with the IFC requirements. However, as part of the expansion project, it will install controls to recover sulfur emissions, and control gases emissions prior being released to the atmosphere thus operating in accordance with the applicable IFC requirements. The refinery’s clean fuel project, part of the expansion, is primarily aimed to produce low sulfur liquid fuels (gasoline and diesel) and treating the total gas streams processed at the refinery. With this project, it will install two new hydro treating units to remove sulfur from all gasoline and diesel streams and reduce their concentration from 500 ppm to less than 10 ppm in the final products. The crude sulfur will be converted to hydrogen sulfide, removed from the gas stream, and sent to the sulfur recovery unit where it will be converted to elemental sulfur. In addition to the low sulfur content in the fuel gases, all heaters will be specified as low NOx burners and the additional power needed will come from the national grid. All point source emissions from the refinery will continue to meet Argentinian regulations and the IFC applicable requirements. The existing flare will be replaced by a new flare system to handle the additional loads from the new units. In addition to the main flare, Axion will also install an acid flare to collect the discharges from the fuel gas system. The flare system will be relocated to prevent any negative impacts to the neighboring industries surrounding the refinery. There will be no-routine steady-state flaring at the refinery. The flare will be used for maintenance and emergency flaring only. Axion currently has controls in place to reduce the release of fugitive of dust and particulate matter emissions to the atmosphere. The coke produced is handled and stored in an open storage area from which it is loaded into trucks or ships through an enclosed conveyor. The coke stockpile is surrounded with a high mesh and it is periodically sprinkled with water, and it is taken via enclosed conveyors to the ships. The LPG loading station has a fluid and gas recovery arms with a protection system to prevent the possibility of unexpected gas leaks. Axion also has portable gas emission detection meters to support their “Leak Detection and Repair Program” which aims to reduce fugitive emissions at the facility. It also has an storage tanks fugitive losses control program (e.g., floating roofs) based on the American Petroleum Institute (API) and the US Environmental Protection Agency (EPA) to prevent release of fugitive volatile organic compounds (VOCs) to the atmosphere. Ambient Air Quality Impacts Axion has an ambient air quality monitoring program in place to routinely measure air quality in proximity to the refining operations. In addition, to assess the air quality and to confirm compliance with air quality requirements, the company periodically models its emissions (particulate matter, nitrogen dioxide and sulfur dioxide and carbon monoxide) using the USEPA AIRMOD air dispersion model. The most recent model run was conducted in 03/2015. None of the modeled concentrations exceeded the correspondent Argentinian guidelines for ambient quality. After the project, the Argentinean as well as the IFC ambient air quality requirements will be satisfied. Once operational the proposed project will bring positive cumulative effects to the local air quality. After the expansion, the refinery will not only recover the emitted stack sulfur but it will also produce liquid fuels, for local consumption, with much lower sulfur concentrations. As a whole it is expected it will recover around 30 Tons/day of elemental sulfur. Axion will complete the installation of the VOC control measures systems for all the existing storage tanks and as indicated in the ESAP, it will provide IFC with a copy of an evidence document. Expected air emissions from the construction phases include mainly particulate matter, noise, and combustion gases from vehicles and machinery. Key control measures to be implemented during this phase includes dust suppression though covered transport of excavated earth; water spraying during the dry season, especially during strong wind conditions; regulated vehicles speed; regular road maintenance; grading and compacting road surfaces, as needed, to prevent uneven running surfaces thus preventing both noise and dust impacts. In addition, mandatory preventive vehicles and equipment maintenance to reduce generation of combustions gases will be also implemented. Water Usage and Liquid Effluents The raw water to satisfy the refinery water, which include cooling water, process injection water, and water for the boilers steam generation is obtained from the Parana River. The refinery recycles water as part of its process, for which it uses a closed cooling water system including a cooling water tower and four circulation pumps. As part of the expansion project, Axion will incorporate new air fin coolers that will not only reduce the specific consumption of cooling water, as well as of total energy since there will not be a need to pump additional quantities of water. The refinery liquid effluents include cooling waters, process wastewaters, sewage waters, and storm waters. Each one receives appropriate treatment and are monitored prior to being release to the Parana River. Since the cooling water have no contact with process flows, there are discharged to the river without any prior treatment. As the process wastewater comes from different sectors of the refinery, they are segregated and treated separately. Once monitored, the treated wastewaters are released into the Parana River through a 150 meters long underground channel. Axion’s liquid effluents comply with the Argentinian requirements. Potential additional wastewater treatment requirements from the expansion project will be assessed and as needed additional control treatment will be installed. Once identified, the final design wastewater treatment control specifications for the operation of the expansion project will be submitted to IFC as indicated in the ESAP. This system will be designed based on achieving compliance with Argentinian standards and the WBG EHS Guidelines. The project implementation which will require water for sanitary needs, dust suppression, and hydro testing of equipment and tanks will also source the water from the Parana River which it is expected it will not negatively affect this water source. The principal wastewater generated during this phase will be sanitary waters. The treatment option selected will be in accordance with effluent standards and a monitoring program will be developed to monitor compliance. Once decided Axion will inform IFC as indicated in the ESAP. As part of its commitments with OPDS, Axion has been conducting soil and groundwater monitoring to determine potential impacts and remediation measures. The monitoring results indicate that there are no exceedances of hydrocarbons and chemicals in soil or groundwater, as well as any presence of hydrocarbon in groundwater is confined within the site boundaries. Waste Management The refinery generates industrial hazardous (i.e., industrial, medical), non-hazardous wastes, and domestic wastes.  Axion has in place a waste management plan to manage, store, and dispose all wastes generated.  The plan procedures include a tracking system for the collection, transportation, treatment and disposal of all hazardous waste streams leaving the site.  Only government approved facilities are used for waste treatment and disposal and Chain-of-Custody and Duty of Care procedures are in place for all waste streams leaving the refinery.  The residues sent for incineration and those send for disposal in a secure landfill are collected, treated, and disposed by OPDS certified companies.    Axion has built a dedicated roofed well ventilated hazardous waste management area in the downstream wind direction, meeting all relevant fire code requirements, with impervious sloped floor, drainage channel, and sump and pump system. The materials are segregated by chemical characteristics and the area has restricted entrance/exit. For the project implementation phase, Axion is requiring the contractor to establish a waste management system.  The waste generated during this phase will be segregated and stored in roll-off containers at waste yards managed by the EPCm contractors.  Domestic solid waste will be stored in waste skips and disposed of in an authorized landfill. Hazardous wastes generated at construction such as used lubricating oil, batteries, empty drums of paint/solvent/additives, floor sweepings from material storage yard, oily sludge, contaminated soils from spills, off-specification materials, electrical and mechanical components, etc. will be stored in drums and containers at the waste yard established by the EPCm contractors, and then transferred to licensed waste treatment contractors.  Axion currently has 5 remaining transformers with PBC levels below 10 ppm and 3,100 liters of oil with a PCB concentration of 14.8 ppm, securely stored in drums.  Axion is currently in the process of selecting the firm that will conduct the final treatment. Details of this process will be submitted to IFC as indicated in the ESAP.  Hazardous Materials Axion ensures proper handling of hazardous materials (i.e., additives, resins, catalysts, etc.) The refinery has a dedicated roofed storage area without walls to allow ventilation, with cement floor and gutter edge to avoid potential soil contamination in the event of a spill. Storage tanks have double containment, there is a database accessible to all employees with the Material Safety Data Sheets (MSDS) for all hazardous materials; all hazardous liquids are segregated and securely stored with appropriate secondary containment. In case of spillage incidents, Axion has the appropriate prevention measures to absorb or contain liquids so that they do not enter drains, ditches or waterways compliant with the required safety measures. Any additional storage as regards of the expansion project will be to the same standard as above described. Noise Noise generation is mainly associated with equipment such as compressors, turbines, pumps, electric and motors as well as flow of gases and vapors through ducts and during emergency de-pressurizations. Axion has measures (noise barrier/insulation, periodic maintenance plans) to limit noise disturbance outside the site boundary. In addition, Axion has a noise monitoring program at the facility boundaries to ascertain the project’s compliance with Argentinian standards. Noise monitoring will also be routinely carried out during the facility construction program and measures will be taken to minimize noise disturbance where necessary. Axion will install, as needed, additional controls to ensure that after the expansion project, the noise levels will be in compliance with both the Argentinian as well as the IFC noise requirements. Operational Safety Axion’s design philosophy is to provide sufficient process safeguards to protect personnel, equipment and the surrounding communities. These include, but are not limited to, smokeless elevated flares; installation of emergency isolation valves, as per design codes; de-pressurization facilities; hazardous emission detectors; protective instrumentation and controls with sufficient redundancy; emergency shutdown instrumentation; emergency alarms; installation of fire protection systems, etc. Axion has an operation integrity system that combines standard operations with reliability management systems including risk analysis, mechanical integrity, work permits program, incidents investigation, and daily inspections among others. Its inspection programs are risk based focused on risky and vulnerable areas, it has an inspection data management system for pressure vessels, heaters and boilers, heat exchangers, tanks and atmospheric vessels, and piping circuits. The maintenance program is risk based and conducted by dedicated team such as mechanical integrity, tank repair, process safety to resolve HAZOP identified issues, etc. As part of this project, Axion will establish additional upgrades to the existing operation control system, impacting on the refinery reliability with a more stable operation, and indirectly driving to a reduction in unplanned emergency releases to the environment. Additionally, Axion has doubled the number of shift supervisors starting in the second semester of 2014 from 10 to 20, it will continued with the signed agreement it has with Exxon Mobil to support as needed in technical aspects as well as operational safety, and it will continue adopting the U.S. Occupational Health and Safety Administration (OSHA) and API 75 requirements for operation safety and API 653 requirements for tanks handling. As previously indicated Axion will complete the hazard and operability (HAZOP) and layers of protection analysis (LOPA) studies for the expansion project and submit them to IFC. In addition, it will also conduct coarse and detailed quantitative risk assessment (QRA) of potential hazards and consequences of accidental impact sources to assess the risk associated with catastrophic incidents (explosion, fire, toxic release etc.) The initial results will lead as appropriate to implement design changes such as relocation of the flare, etc. Once the detailed engineering is concluded, the company will conduct a refined qualitative risk assessment to ascertain that final operational data will not pose negative risks to communities or environment as indicated in the ESAP. Axion will complete the installation of the VOC control systems for all existing storage tanks and as indicated in the ESAP it will provide IFC with a copy of an evidence document. The VOC control measures consist of installing membranes where absent, or replacing where damaged, in the vertical tanks of the tank farm as a part of Axion’s ongoing tanks safety program. For the construction phase the EPCm contractors will be required to develop and implement an Emergency Response Plan and have qualified personnel and equipment response to potential emergencies. For the operation phase, Axion will develop an Emergency Response Plan and Oil Spill Contingency and Prevention Plan. This plan will identify likely emergency scenarios, appropriate response equipment, calibration and maintenance of the equipment, emergency training and drill frequencies, identification of appropriate supporting parties, etc. Qualified personnel to respond to any emergency will be available at all times. Axion will submit a copy of this plan prior to operations to IFC as indicated in the ESAP. Axion will also become active participant of the already established Emergency Response Mutual Aid Organization established by the industries in the area. Greenhouse Gas Emissions Greenhouse gas contributions from the facility will be routinely monitored and recorded during operations.  The commitment to install best available technologies in relation to the expansion will provide higher energy efficiency which will reduce the CO2 emissions generated from 3.17 to 3.14 Kg CO2 Equivalent.   The CO2 currently generated by the hydrogen manufacturing unit, which is operated by Air Liquide and uses natural gas as a raw material, is all recovered and sold for use in the nearby industries, for medical purposes and soda manufacturing. The additional CO2 will be recovered as well. At preliminary design stage, the company identified several energy optimization measures and conducted a site wide energy assessment to identify areas of energy optimization such as the installation of high efficiency combustion system with low NOx burners; application of pinch technology to determine external heat inputs and heat sinks, and installation of high efficient heat exchangers (high flux tubes). At detailed engineering design stage Axion will confirm these measures and seek additional energy optimization measures as appropriate. The company will develop and submit to IFC as indicated in the ESAP, (a) an energy balance assessment including the energy consumption of each key process unit, and (b) benchmarking energy and water use of these key process against good international comparable industry practice in the sector.