EnvironmentalAssessmentf/AnalysisReports ______

Report E0051

Ghana .

*Thermal. Power'EA Category-A-:..

.....::Environmental Assessmn3of4August 1993,

This report has been prepared by the Borrower or its Consultant

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Pub

lic D

iscl

osur

e A

utho

rized

Republic of GhanaVolta River Authority

Takoradi Thermal Plant

Addendum I

Revisions toEnvironmental Impact Assessment

Final Draft

September 1993

Acres International Uimited

Addendum 1

Revisions to EnvironmentalImpact Assessement Final Draft

In response to prellminary review comments received from the World Bank and the AfricanDevelopment Bank, this addendum is provided to clarify the following points.

1 Cooling water discharge temperature with one steam turbine generator (300 MW) and twosteam turbine generators (600 MW), and predicted extent of hydrodynamic mixing zone andthermal plume under each of those operational conditions.

2 Maximum ground level NOx concentrations under open cycle (bypass mode) operation priorto availability of water for either combined cycle operation. NOx control or desalination plantoperation.

Pages incorporating the revised text are attached. Please attach this addendum to your copiesof the above noted report. These changes have been included in the 'EA Summary' publishedSeptember 1993.

Revised Pages

Executive Summary

This report has been prepared to review and evaluate the environmentalimpact of a proposed 300-MW, with the potential to upgrade to 600 MW,combined-cycle thermal generating plant to be located 15 km northeast ofSekondi-Takoradi. near the village of Aboadze. This environmentalassessment addresses the requirements of the African Development Bank andalso those of the World Bank as a Category 'A' project.

The analysis involved a 1-wk visit to the area by an environmental specialistand the provisions of socioeconomic and other data by VRA staff, both ofwhich supplemented site visits by engineering staff. Some monitoring datais presented, while further information is being collected, and will be included,as an addendum to this report at a later date.

The plant will inifially use light crude oil, or distillate oil with the possibility oflater conversion to natural gas should a supply become available. The plantrequires a 3.0 m conduit for once through cooling water, drawing 5.7 m3/sfrom the sea.

Current estimates indicate a construcfion work force of approximately 400including 75 expatriates and an operating work force of up to 125. Plansinclude a townsite for construction and operations staff, likely including a first-aid clinic. A permanent townsite will be developed for operating staff, and aschool will be provided if existing community services are insufficient.

There will be a self- contained sanitary sewage treatment system and adesalination plant to provide an adequate long-term, water supply foroperational and domestic requirements. In addifion, the plant will beconnected to the municipal water supply.

In general the analysis indicates that the plant will have modest, butmitigatable, environmental impacts. The key potential issues include:

- the eftect of the cooling water on marine life and the consequent effectson the thriving fishing industry of Aboadze and neighboring villages

- the effects that the loss of site land (some 35 - 40 ha) will have on nearbyfamilies who currently practice predominantly subsistence level agricultureon that site

- air quality impacts

- potential spillage and/or leakage of oil.

Cooling Water and Marine UfeNormal ambient sea water temperatures are 26 to 270C, however, watertemperatures occasionally rise to 30 to 310C. Draft guidelines proposedby the Environmental Protection Council of the Ghanaian Ministry ofEnvironment suggest that the maximum ambient water temperature at thebeaches should not exceed 330C and not raise temperatures by more than6°C. The State of Florida uses 36°C maximum for open waters and at theedge of a mixng zone. The proposed 300 MW plant would operate witha 9°C AT, while the potential 600 MW plant would operate with a 12°C AT.Thus the 300 MW plant's discharge would periodically exceed 36°C, whilethe 600 MW plant would routinely exceed 36DC.

The use of a discharge nozzle which creates an exit velocity greater than2 nVs, would ensure that discharge temperatures above the 36C level areconfined to a small, localized midng zone (less than 20 m from dischargepoint for the 300 MW plant and less than 200 m for the 600 MW plant).Modeling results have indicated that the temperature rise will be no morethan 0.50C beyond 200 m from the discharge, even under two unit(600 MW) operation. In addition, the discharge will be directed offshoreand located beyond the 6 m depth contour. This will ensure that theabove noted crteria are met. No measurable damage is expected to thefishery.

Reied Septebe r10. 1. ii

It is recommended that baseline monitoring be undertaken to assist inselecting the optimum intake and outfall locations and to ensure thatpredictions of impacts are verified and applicable standards are met.

Farm Land LossIt is estimated that some 35 - 40 ha of the site are farmed - generally bywomen, as income and food supplements for their families. In somecases, quite valuable crops (e.g., coconut palm, tigemuts) are grown. Thelands are farmed by tenants. Commercial farmers pay for the use of theland with a share of their crops grown, while subsistence farmers make anominal contribubon to the land owner. The concern is that anycompensation will be paid to the land owners and not to the tenant whomay find it difficult to find an alternate farm site. It is important that thisissue be addressed in the compensation structure and it may beappropriate to provide assistance to tenants in locating other lands. Thedevelopment plan for the project includes preservation 2 of the beachridge coconut palm plantings.

Air QualityThe major air quality concern of the project is related to NOx emissions.Source emission standards are measured in nanograms per joule and theWorld Bank guideline for NOx is 130. The plant could generateapproximately three times that level without control mechanisms. Waterinjection technology used to lower NOx emissions will be installed on thecombustion turbine bumers, however, due to limited fresh water availabilityon site, may be delayed by up to 12 months from the start-up of the firstCTG. To provide, a sufficient and reliable source of water for this control,a desalination plant is provided in the plant design. Assuming no delaysin contract award or schedule, the water supply from the desalination plantwill be available shortly after the start-up of the second CTG. therebyensuring that emission levels are below applicable standards for operabonsbeyond this point.

iii

It is suggested that an environment/social development officer be appointedto the project. The task of this officer will be to oversee the various monitoringprograms that will be taking place and to ensure that impacts, both naturaland socioeconomic are dealt with and minimized. A comprehensiveenvironmental training programme should be provided to supervisory staff.

A detailed monitoring and baseline/data gathering programme is outlined.This will supplement the existing information, provide the data required forsiting the marine structures and determine if emissions are in compliance withthe guidelines. As this will be the first large scale thermal power plant inGhana, detailed effects monitoring will aid in developing future mitigationrequirements and help determine if the predictions and mitigations given hereare correct.

As the local community of Aboadze will be changed by the presence of theplant, it is recommended that the population should obtain some benefits fromthe project to offset these changes. VRA should consider assisting thecommunity in some of their development projects.

iv

5-31

concentration (100 ug/m3). however, ground level concentrations during shorterperiods of time (0.5 and 1 h averages) generally exceed this value, especially atstack helghts of less than 60 - 75 m. The preferred stack height (due to cost,aesthetic and other considerations) was 40 e5 m. At that height. predicledground level concentrations from an uncontrolled plant, at C stability condilions(the worst case) are as lollows

- annual mean 58 pg/m3- 0.5hpeak l9Bgpgm3

- 1 h average 163 pg/M3

- 24 h average 67 pg/m3

Considerable concern was expressed by ADB project appraisal staff with respectto these emissions and projected ground level concentrations. Considering thepotential for a future development of a similar size, and the need to maintainprovision for contributions from other sources, it was recommended that thestation contribution not exceed 1/3 of the total, and preferably be less than

10 pg/m3. Under the worst case scenario, a 1/3 contribution ( =S30pg/m3) would

require a stack height of 80 rn. It was therefore decided to investigate otheroptions as well.

High NO, levels are produced from combustion at extremely high temperatures.To control NO, emissions both dry and wel techniques have been used. Boththese technologies were investigated to ascertain their feasibility for use in thisplant.

While reviewing available technology, it became apparent that dry 'LO NOX'burners have been developed, and are in widespread use for gas firedinstallations, achieving emission rates of as low as 5% of those now predicted forthe oil fired equipment. Although dry 'LO NOX burners for oil riring-are in somestage of development and most manufacturers indicate that prototype units arebeing investigated, there is no manufacturer at this time prepared to indicate adefinite schedule for the availability of these new burners, nor identify theobtainable emission values. Published data from research papers do howeverindicate potential reductions to approximately 213 of the present emission levels.Further reduction can be achieved by injecting steam or water into thecombustion zone, which satisfactorily modifies the NO, generation and inconjunction with sophisticated computerized cDntrol, achieves a level of emissionwell below the allowable emission criteria. However, the present level of control

5-32

achieved by dry 'LO NOx' burners Is marginal, as reflected in the valuespresented in Table 5.4.

Considering that dry 'LO NOx' burners Aill become available at a later date It wasInvestigated whether a temporary load reduction would achieve an emission ratewithin the established criteria. While theoretically a load reduction does producea lower heat release, today's high efficiency units use multi burner arrangementswhich maintains the flame temperature and hence little or no variation of NO, canbe achieved. Increasing the stack height results in a reduction of the groundlev6e concentration but does not produce a reduction of the emission. Toincrease the stack height incurs an extra cost especially as the plant is fitted witha total of four (4) stacks.

The other technology for NOx control and the one being currently used at a fewoil fired plants throughout the world, involves injection of fresh water into thebumers. Considerable quantities of water are required (i.e., water is added in theratio of .5 to 1.8 kg per kg of fuel burned). Based on a fuel consumption of25 000 to 30 000 kg/h per turbine this would require a water supply of 25 000 to108 000 kgthour.

Additional model runs were undertaken utilizing emission characteristics(Table 5.4) of those CTGs employing NOx control with either dry low NOx burnersor with water injection. The predicted emission rates and ground level NOxconcentrations for similar operating conditions and stack heights are presentedin Table 5.5. Model runs for intervening stack heights and bypass mode ofoperation are presented in Appendix E (tables and figures E2.1).

Emission rates for the dry NOx control system are estimated at 297 ng/J. Thesestill exceed the World Bank guidelines by a factor of over two. To achieve therecommended ambient GLCs the stack height would still have to considerablyexceed 40 m (Appendix E).

For water injection, the emission rate of 77.9 ng/J falls considerably under theguidelines. Ambient GLCs with a 40 m stack are considerably less than witheither the uncontrolled or dry Nox control condifion, and are as follows

- annual mean 10.0 ,g/m 3

- 0.5 peak 34.4 Pg/m3- 1 h average 2f.3 pg/m3

- 24haverage 11.6pg/m3

5.33

However the selection or this option would require that a constant, reliable sourceof water for injection be located. The availability of a fresh water supply at theproposed site was investigated.

The site was selected for Its proxlmity to the ocean to provide access to coolingwater for the condensers of the steam turbine. However, the fresh water supplyis at present limited to a single source, that is a supply from the Ghana Waterand Sewerage Corporation (GWSC) at Inchaban in the amount of 100 000 g/d(378.5 m3/d). GWSC.provides about 300 000 gtd of municipal water to thevillages of Aboadze and Aboesi, of which. 100 000 g/d could potentially beassigned to the new plant. No additional water is at this time available from thissource, which is known to be erratic during dry periods. Hydrologic data is notadequate to allow confirmation of the overall reliability oF this supply.

Altemate water sources are the River Pra, about 20 km each of the site, or salinewater from the ocean.

Water from the Pra is now piped to Takoradi for their muni';ipal water supply.This supply is also very dependent on the river flow which varies considerablywith the season. To create a second water supply frorn the Pra would likelyaffect the reliability of the Takoradi supply and would necessitate a new dam orweir to be built on the River Pra. Minimally, this would require an intake for apumping station, and a 20 km pipeline to the plant. Its dependability could notbe assured without creation of an adequate storage reservoir.

A desalination plant using sea water would meet the requirements (a high gradeof purity) of water for injection. A nominal plant of 300 000 g/d. would berequired, equivalent to approximately 47 500 kg/h. which would represent a waterinjection rate of 1 kgtkg at a fuel flow of approximately 28 000 kg/h per unit. Itwould also require other system components consisting of seawater pumps,additional pumphouse space, reverse osmosis units (complete with their feedsystems comprising pumps, filters, piping systems, etc.) and an increase to theproposed demineralizers to handle the arger water flow.

From the above discussion it is then recommended that NO, control be installedat the proposed Takoradi Thermal Plant. The technology to be used is the waterinjection system. To ensure a constant and adequate water supply a desalinationplant wil be builL

5-34

In order to satisfy the requirements of the lenders (financiers) for the project, four

separate packages have been developed, related to combustion turbines, steamturbine, transmisslon and housing. This has resulted In assljnmeni of thedesalination plant to the STG package, as both require a sea water supply. Theend result of this Is a scheduling problem in that the first combustion turbine wIlloperate for 3 - 6 months without NOx emission control (potentially 6 - 12 monthsor more If delays occur In the awarding of the STG contract). Given that only oneunit will be operational and wIll be in bypass (simple cycle) mode, ground levelconcentrations will be reduced from that with two units, and would be 50% of thatshown in Appendix E2.1(b)-1 (i.e., 4.6 pg/M3 vs 92 j,g/m3 for uncontrolled twoCTG operation, bypass mode). It is felt that approval for temporary operationshould be granted, to allow the plant to operate before the long-term watersupply is available.

Operation of both CTGs in combined cycle mode, without water injection, willexceed emission criteria, and may result in ground level concentrations up to themaximum allowed (annual average <100 pg/M3. 24-h average <200 pg/m3). Asambient wind speeds in the project area (Appendix A) are quite low. two modelruns were undertaken. representing one and two unit incontrolled combinedcycle CTG operation, to provide preliminary information concerning the potenlialpoint of impingement of the plume under light wind conditions. The results ofthose runs are presented graphically in Appendix E, Figures E2.1 (a2) andE2.1(a3). As shown, plume impingement is expected to be a considerabledistance downwind (beyond 10 kIn) under those conditions. Maximum ambientGLC under two unit operation is predicted to be approximately 70 pg/M3, whichis below the 100 ,,gtm3 annual average criteria. One unit operation would more

closely approximate the GLC goals previously described (30 - 35 Pgim3).

However predicted maximum ground level concentrations in bypass mode arewell below recommended limits, and ambient conditions will be monitored.Should testing reveal GLCs in excess of the maximum allowed, then it would berecommended that the second CTG not be allowed to operate until the watersupply from the desalination plant is available to provide NOX control for bothunits. In no case should both units operate in combined cycle mode withoutwater injection operational and in use.

Thus the desalination plant should be placed on the critical path within the

STG contract, such that it is available and capable of providing water forcombined cycle operations. Groundwater from a series of boreholes may be able

Revised September 10. 1993.

5.53

the season, and total temperature of the effluent Is not to exceed 33.3DCor 32XC, depending on season. In open waters (beyond the 5.7-mcontour), the temperature at the point of discharge must not exceed9.4°C above ambient, and surface waters of the receiving environmentshall not exceed 36.1aC. Also, the discharge should be placed farenough off shore to ensure that water criteria In the coastal zone are notexceeded.

Florida regulations also provide for thermal mbdng zones inside whichtemperatures may exceed the above criteria, provided two conditions aremet. First, the mixing zone must provide for the protection andpropagation of a balanced, indigenous population of shellfish, fish, andwildlife In, and on the body of water Into which the discharge is to bemade. Second, that the temperature criteria must be mel at the edge ofthe mixng zone (State of Florida. 1993).

Hydrodynamic modelling was cDnducted to provide a preliminaryassessment of the impact of the thermal discharge on the receivingwaters. The modelling Included both single port and multiple portoutfalls. For the single port outfalls, four scenarios were modelled inwhich the thermal discharge rate and temperature, and ambient currentvelocities were varied. The results of this modelling are presented inAppendix F.

Figures 5.3 and 5.4 portray the thermal plumes resulting from a singleport outfall under two of the scenarios modelled, referred to as Case 1and Case 4. In Case 1, the thermal discharge was 6.4 m3/s with a 9°Crise above ambient temperature and an ambient current velocity of025 rm/s. This case was selected to model normal one STG unitoperation, however, the plant would be designed to operate with a 12°Ctemperature rise if expanded to 600 MW. Under Case 4, the thermaldischarge was 11.3 m3/s with a 120C rise above ambient temperatureand an ambient current velocity of 0.10 mf/s. This approximates 2 STGunit operation, with low ambient current flow (worst case scenario).

The results of the modelling (discussed in Appendix F) indicate that theimpacts of the thermal plume will be limited. Under Case 1, thetemperature of the plume was predicted to be 4.5DC above ambient watertemperatures at a 10 m distance from the ouffall, and less than 1°C at15 m from the outfall. Under Case 4. the temperature was 60C over

Revised September 10. 1993.

5.54

ambient at a distance of 16 m, while the mixing zone boundaries werepredicted to extend approximately 200 m from the outfall. As suggestedby Figures 5.3 and 5.4, In both cases the thermal plume was predictedto be less than 1"C above amblent water temperatures at the edge of themixing zone, while at a distance of 2000 m the tempsrature of the plumewas prolected to be 0.5C (or less) above the ambient temperatures. Theother scenarios modelled provided similar results (see Appendix F),suggesting that the thermal Impacts will be limited.

The temperature of the final effluent of the proposed Takoradi plant willpotentially exceed the ambient sea temperature by 90C for 300 MWoperation and by 12°C at full (600 MW plant operation. For thepresently proposed development (300 MW), this Increase will result indischarge temperatures ranging from 330C during upwelling events to390C lo 40rC during much of the remainder of the year. On rareoccasions, discharge temperatures could potentially exceed 400C.

To moderate these high temperatures the final design of the dischargeportal will include either an off-shore diffuser or a nozzle. If a singleorifice is employed, it should provide an exit velocity of not less than2 rm'sec. Both types will provide rapid mixing of the effluent, in a smallarea where the discharge-induced currents exceed the ambientalongshore currents. As the discharge currents approach the velocity ofthe ambient currents, the thermal effluent will rise to the surlace (due totemperature-related density differences). At Ihe surface, furthertemperature reductions will take place at a slower rate, and will occur

both due to atmospheric cooling and further mixing. Additional modellingwill be required by the successful contractor to undertake the final designof the exit portal, to assure adequate mixing and cooling and meetdesign criteria.

The increase in temperature of the discharge (above ambient) at full600 MW operation will not meet the Florida criteria for open waterdischarges, however, the diffuser will act to rapidly mix the discharge withambient water, resulting in attainment of the Florida and Texas criteria atthe edge of the mixing zone.

Rsgd Septmber 10. 1993.

5-59

The exact location of the diffuser cannot be identified at this point. Thediffuser should, however, be located off shore beyond the most distant6 m contour in an area away from any Important shellfish beds and fishconcentraton areas. It should also be pointed offshore, and maintainan exit velocity of not less than 2 m/sec. Preconstruction Investigationswill be required to select the appropriate locallon. This design will ensurethat temperatures at the edge of the mixing zone are less than 90C aboveambient and below 360C total temperature.

When the plant becomes operational, modelling and/or drogue studiesof the behaviour of the thermal plume should be conducted to Identifywhere and at what temperature the plume will enter the coastal zone (i.e.,Inside the 6-m contour). The final design and siting of the dischargeshould ensure that the temperature (of the plume) at the edge of themixing zone does not exceed 2C above ambient, or 330 C maximumtemperature at the point where the plume enters the coastal zone.Adherence to these criteria will also meet the EPC's requirements.

Chronic or Acute Discharges of ToxicSubstances In Cooling WaterThe main substance that could be present in the cooling water dischargeat toxic levels is chlorine. A chlorination system is to be included in thecirculating water system to chlorinate the water, as well as to preventbiofouling of the heat exchangers and piping. The chlorine will beproduced using an electrolytic chlorinator (sea water will be electrolyzedto produce a hypochlorite solution). Chlorination will be an intermittentactivity, but levels will be high during activation.

Excessive chlorine can kill or damage aquatic life. The residual chlorineat the discharge point will be considerably diluted. It should at no timeexceed 0.2 mglL

The cooling water circuit will be the final receptor for all others effluentstreams on Site. Prior to its installation, these streams will have beendischarged to a feeder stream of the Anankwari River. All liquid effluentstreams will be joined together on Site, and discharged as one commonwaste stream. This combined stream will be monitored and will meet thecriteria specified in the following section and in the tender documents forliquid effluent.

Revised September 10. 1993.

5-60

The other discharge to the cooling water circuit will be from thedesalination plant. This could amount to up to 750 m3 /d (<0.01 m3/s),which Is a small amount, compared to predicted cooling water discharge.

This discharge will be of elevated salinity, but Is not expected to havesignificant impacts, due to Its limited volume.

(c) Discharge of Weastewater

* Discharge of effluents can have detrimental effects on the water quality of the

receiving water body. For example, excessive amounts of organic matter candeplete the oxygen available for the existing organisms. High phosphate

levels can produce rapid growth of algae, etc. in the receiving water.

Wastewater will come mainly from sewage and preoperational cleaning

requirements. Sewage from the proposed plant and the housing complex will

all be treated at one central facility, consisting of an activated sludgeextended aeration treatment system. The system will be designed to meeta BOD5 of 25 mglL and suspended solids of 200 mg/L

Wastewater will also be derived from preoperational cleaning of the HRSGsand other operational chemical cleaning. It is proposed that these wastes

-ilI be stored in a suitably lined lagoon or tank (i.e.. one which will not reactwith the chemical cleaning solutions). The wastes will be neutralized by the

addition of lime and dissolved metals, such as iron, will be precipitated outof solution. A polymer may be added to help coagulate and settle the solids.

Once the solids have settled, the clear water will be pumped out to thedischarge outfall. As the lagoon fills, the solids will be cleaned out and taken

to the sold waste landfill area.

To ensure that the wastewater is strictly controlled, the effluent from all

systems will be discharged through one common pipe. This effluent will bemonitored to ensure that the criteria below are met. These criteria should

ensure that the water quality of the receiving body is not negatively impacted.The effluent will initially be discharged into a feeder stream of the Anankwari

River but will be diverted to the once-through cooling water discharge systemwhen it becomes operational. Provision will continue to be retained to

monitor this effluent before mixing with the cooling water discharge.

7-9

supplies In the area. The desalination plant is expected to be operation within 6 mo after

start-up of the first unit. Thus water for NO, control could be provided, if an alternate

source of water (other than CW circuit) could be made available on a temporary basis

(potentially, groundwater from a series of on-site boreholes).

However, as planned, the first CTG will operate in an uncontrolled manner for a period

of time predicted not to exceed 6 mo, assuming the present schedule is maintained.During this period, Its NOx emissions will exceed applicable standards, but ground level

concentrations are predicted to be below maximum acceptable levels. The second CTG

unit must not come on line until the cooling water supply is available and desalinationplant operation, such that NOx control can be implemented, if the air quality monitoring

program associated with the project, indicates that maximum ground level concentrations

are- being exceeded. Preferably, the schedule for the intake and outfall construction

should be advanced, such that the water, and the desalination plant, are both available

and operational when the first unit is commissioned, and definitely before the second unitis operated. A desalination plant will be built on-site to provide the long-term fresh water

requirements. The cost of this mitigation measure has been estimated at approximately

US$ 5 million. If the present project schedule is followed.

7.2 Aquatic Conditions

Further marine investigations are required as outlined in Section 9 to select appropriatelocations for the intake and discharge portals, and the SPM. It is required that the

studies to select an appropriate location for the SPM be undertaken and completed prior

to contract award in order to provide input to the final site selection. Studies to select

appropriate intake and discharge locations Wil require a 12-mo period (in order to

evaluate seasonal differences) and will be completed prior to November, 1994. (See

construction schedule, Figure 3.1.) The major mitigation costs will be in the form of the

monitoring.

Location of IntakeThe intake must be located upstream of the Raoni and Sherbro banks and inside the

10-m contour. The intake will .,e fitted with a velocity cap, and raised off the sea

bed. Buoys shall be placed to indicate the location of the intake. Detailed

preconstruc6on marine investigations will be required to select an intake location that

does not inflict undue impacts. These studies will include physical and biological

components.

7-10

At this time, It is not considered that the environmental requirements will aflect thecost of the intake construction, which is estimated at $14.5 M.

Location of the Dlscharge OutletField studies will be required to determine the most suitable location for the dischargeoutlet. Generally, the outfall must be located off shore of the most distant 6-mcontour and away from Important shellish beds and fish concentration areas. It isexpected that only a nozzle will be required but the exit velocity of the water must notbe less than 2 W/s to ensure rapid mixing of the heated water, and be directedoffshore. The nozzle will meet a T., of 330C at the edge of the mixing zone, and<2rC above ambient temperature rise in the near-shore zone (beach).

The outfall shaH extend a minimum of 1500 m from shore. Cost of the outfallconstruction is approximately US $14.5 M, which includes provision of the nozzle.The field investigations required to select an appropriate discharge location will beundertaken at the same time as the intake site selection studies.

Location of the Single-Point Mooring (SPM)The SPM must be located downstream of Sherbro and Raoni banks in an area suchthat any oil spilled at the buoy would not be swept directly into Shama Bay by long-shore currents or local gyres. Hence, an oceanographic study will be required to

select an appropriate location. This study should be undertaken during the periodof the low flow in the Pra River; thus, would be undertaken prior to contract award

(January/February 1994).

Waaming lights shall be required on the SPM.

Oil Spill Response/Recovery Miigaton PlanCurrently, there are no dedicated oil spill response teams or oil recovery equipmentin Ghana and there is a probability that spillage or leakage may occur at the SPM.

Therefore, VRA should obtain and dedicate such equipment and develop an action

plan to provide an 'initial response' capability. The goal of the initial response wouldbe to stabilize the situations, and contain a spill or release to as small an area aspossible, preventing further dispersal along the shoreline or out tD sea. The oil spillresponse plan of the VRA should be integrated with the National Oil Spill

Contingency Plan (NOSCP). Such an integration would allow recovery/cleanupoperations to be then conducted under the auspices of the NOSCP lollowing initial

containment by VRA. This approach would limit and minimize VRA's liability for

environmental and other damages incurred by the oil spill. At the same time, this

RPaised Sepinbef 10. 1993.