The sponsor has presented plans to address these issues and to demonstrate that the proposed project complies with applicable Turkish laws and regulations and World Bank requirements. The information provided about how these potential impacts are being addressed by Gunkol is summarized below:
Siting and Land Acquisition. The new production site is located in a recently established industrial zone, which was previously used for agriculture. Gunkol acquired the site through direct purchase from its previous private owner. There are no residences in the surrounding area, nor were any squatters occupying the site or subsequently moved to develop this project.
Site Contamination due to Past Practices. Gunkol began its manufacturing operations at its original Gorece site in 1980. There is no documented or physical evidence to suggest that past hazardous materials or waste management activities at the site over the last twenty years have resulted in any soil or groundwater contamination at this property. All potentially hazardous chemicals and fuels have been stored in areas provided with secondary containment, and there have been no spills reported. Overall, the site has been well maintained.
Air emissions. Most of Gunkol’s air emissions are generated by burning gaseous fuels used for heating and processing purposes, as well as from coating processes such as enameling and painting. Pollutants of concern include particulates, nitrogen oxides, sulfur oxides, and volatile organic compounds. Through the use of clean burning fuel (i.e., LPG) and paint booth exhaust filtering and recycling practices, Gunkol complies with applicable Turkish stack emission requirements and World Bank Group guideline emission limits. In addition, ambient air monitoring of the area surrounding both plants conducted by the government authorities indicates compliance with applicable requirements and guidelines.
Effluent discharges. Gunkol generates both employee sanitary and industrial process wastewaters. Sanitary wastewaters at each plant are treated in separate, secondary-level biological treatment systems, and the effluents meet Turkish and World Bank guidelines for all parameters. Because they contain organic (e.g., oils) and inorganic (e.g., ammonia, chromium, cyanide, lead) pollutants, the industrial process wastewaters are treated in separate physical-chemical treatment units. Here again, effluent parameters meet applicable Turkish requirements and World Bank guidelines. Currently, treated sanitary and industrial effluents from the Gorece plant are not directly discharged to the local surface water because of its use as a downstream water supply. Instead, they are collected in a tanker truck and transferred to the local municipal treatment plant for further treatment and eventual discharge. The Pancar facility treated effluents are discharged to an adjacent river, and are strictly monitored by the environmental authorities.
Solid and hazardous waste management. Gunkol generates a variety of solid and hazardous wastes, including, for example, packaging waste, waste oils, hazardous paint and coating process residues, wastewater treatment sludges, and domestic solid waste. These materials are appropriately segregated and managed through various approaches in accordance with relevant requirements and good industry practice. For example, steel and wood scrap, and waste paper, wood and plastics are all recycled. Waste oils are reused. Dewatered wastewater treatment sludges are trucked to and disposed at a licensed municipal landfill, as are domestic solid wastes.
Chemicals/fuels storage and handling. Fuels (LPG, propane, and diesel oil) are stored in above ground tanks provided with bermed secondary containment areas and proper signage. Hazardous chemicals (sulfuric and hydrochloric acids) are also stored in distinct, clearly labeled storage areas, and these areas are provided with sufficient secondary containment volume to prevent the spread of spills beyond the storage areas and subsequent contamination of the environment. Signage and security are up to international standards.
Emergency response planning and preparedness. Gunkol has developed and implemented emergency response and preparedness program for the facility. This includes emergency response plans, procedures for using inspecting, testing, and maintaining emergency response equipment, fire safety measures, alarms and equipment, and training for all employees in fire safety and emergency response procedures every three months. A 200 tonne on-site water tank provides the necessary fire protection needs for the new Pancar operation. As required under Turkish law, an earthquake crisis management system has been put in place, and the Pancar facility buildings have been designed and constructed to meet the latest standards in this regard.
Employee health and safety. Gunkol has implemented appropriate employee health and safety programs to protect the safety and health of all employees. Activities include control and monitoring of workplace air quality and noise, pre-employment and periodic medical examinations, provision of safety procedures and practices, the training of personnel in first aid, accident prevention, noise and hearing protection, handling of hazardous chemicals, proper control and maintenance of equipment, and safety procedures, and the maintenance of records of job-related accidents and injuries. A doctor or nurse is continuously available on-site; health clinics and hospitals are located nearby. Management meets every month to review injury incidents and other accidents, and develops and implements necessary programs to prevent these from reoccurring.
