The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific measures agreed, comply with applicable host country laws and regulations and World Bank/IFC requirements. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. (Further information is provided in the attached documentation.)
1. Environmental Policy. Conaprole has an existing Environmental Management Policy stating Conaprole''s mission with respect to the environment. It obligates Conaprole to respect the environment and to carry out all its activities with due concern, protection and improvement in a continuous improvement process. Conaprole will obtain senior management public endorsement of the policy, modify employee job descriptions to incorporate environmental responsibilities, and undertake an education campaign to communicate the objectives and requirements of the program to all employees and to members of the supplier network.
2. Environmental management. Environmental management at Conaprole is evolving. An environmental management committee, with the participation of human resources, operates under the aegis of Industrial Management. It is responsible for implementation of a management system, planning and construction of wastewater treatment plants, and liaison with national agencies such as the Dirección Nacional de Medio Ambiente (DINAMA). Not all satellite plants have an environmental coordinator but several coordinators have been nominated and taken professional courses dictated by the Uruguayan Standards Institute''s (UNIT) program for Environmental Management Specialists to fill this role in the most important plants (1, 7 and 9). As part of this investment, Conaprole will establish a standalone Environmental Management Department, complete placement of environmental managers at each of the plants, and undertake activities required to implement the Conaprole environmental policy at all levels of operations.
3. Emissions to the environment (e.g. air and water emissions to the environment, hazardous materials handling, solid wastes) in existing operations and plants. Conaprole''s principal industrial operations are situated throughout the country. Several of these principal operations have up to four (4) satellite operations. The principals include: Montevideo (Plant 1 and 2) to be replaced by a significantly upgraded and modernized operation at Plant No. 2; ; Florida (plant 7); Villa Rodriguez, San Jose (plant 8); San Ramon, Canelones (plant 9); San Carlos, Maldonado (plant 10); Rincon del Pino, San Jose (plant 11); Rivera (plant 14); and Mercedes, Soriano (plant 16).
4. Air Emissions. Conaprole''s industrial plant air emissions emanate from the production of steam and heat needed for industrial operations. Data submitted for all operations demonstrates compliance with World Bank Group guideline limits for SO2 and for NO2. Data on particulate emissions were not incorporated into the assessment report. These data will be collected on a regular basis and incorporated into monitoring reports for all installations.
5. Wastewater management. Plants 1 and 2 in Montevideo, which will be replaced by the upgraded, modernized facility at Plant No. 2''s existing location currently discharge untreated wastewater to city sewerage. The faculty of engineering of the Universidad de La República will assist Conaprole to ensure design of wastewater pre-treatment facilities for Plant No. 2 that will comply with Uruguayan Standards and with the City of Montevideo''s discharge regulations and avoid nuisances in the adjacent neighborhoods. Operations at Plant No. 1 and current discharges of untreated wastewater will be eliminated with the completion of Plant No. 2 modifications. A new wastewater treatment plant at Plant 7 is in the start-up phase and should be in stable operation within several months; effluent will be used for land treatment or surface water discharge if the quality is adequate for such purposes. Similarly, construction of a new wastewater treatment works at Plant 9 is nearly complete. Treated effluents from plants 8
and 10 are used for land treatment. Although treated, wastewater from plant 14 exceeds WBG guideline limits for surface water discharge. Conaprole will undertake required corrective actions to improve effluent quality at all plants including, as needed, effluent disinfection systems for all discharges to surface water to ensure compliance with Uruguayan and WBG guideline limits.
6. Environmental conditions of existing facilities including asbestos in existing structures. Conaprole will commission an asbestos survey of existing structures and facilities in Plants No. 1 and 2 to identify any asbestos containing materials. Based upon the results of these studies, Conaprole will develop, if needed, remedial action plans for safe removal and disposal of such materials. Conaprole will implement any needed remedial measures with the assistance of a specialized, licensed contractor prior to or in conjunction with modernization of Plant No. 2 and decommissioning/demolition of existing structures at Plant No. 1
7. Quality and hazardous materials management. The mission of Conaprole''s quality management unit is to participate in design, provide technical support for and to audit all raw materials utilization, instruments and procedures that are employed in the cooperative to assure the quality of products, processes and services. Quality documentation (Quality Control Manual, procedures and instructions) is based upon HACCP and ISO standards. Conaprole''s goal is to obtain ISO 9000-2000 certification for the majority of industrial operations.
8. Solid waste management. Uruguay does not have pervasive national-level regulations governing the management of solid waste. However, Conaprole has several ongoing management programs. Conaprole recycles 60% of polyethylene waste, Kraft paper, various plastics, and paper and nylon bags in each of its plants. Whey is converted to powder for sale, used as an animal food supplement or disposed on land. Other solids such as chocolate and sugar bags, small cans with cleaning products, 200 liter concentrated juice drums (>5000/year), and broken wooden pallets are segregated from solid waste containers and sold as by products. At the new, modernized Plant No. 2, Conaprole will establish a Waste Management Unit in production, storage and transport to classify, dismantle and recover salable by-products, and reduce the volume and cost for items destined for landfill disposal.
9. Potable water supply. Conaprole''s Montevideo plants (1 and 2) use water from the public utility, OSE. The rural plants use well water exclusively. Chemical and microbiological data evaluated for appraisal demonstrate that the microbiological quality of raw water supplies at selected installations, which is subsequently disinfected, exceeds IFC guidelines and World Health Organization (WHO) limits. Microbiological data were not submitted for all plants. Engineering improvements are required. Supplemental data for all plants and modifications to raw water supply systems will be carried out on an urgent basis in accordance with the attached corrective action plan (CAP).
10. Use of refrigerants. Conaprole''s long-standing policy is to eliminate purchase of CFCs. Ammonia is the predominant material used for refrigeration although several small plants continue to use CFC-12 for cold storage rooms (plant 13 and 14). The cold storage room at plant 13 will be closed and purchases of CFCs refrigeration at plant 14 will be terminated. Selected ammonia installations will be reviewed and modified to ensure protection from heat and ignition sources. As part of Conaprole''s occupational safety and health program each plant has emergency response plans for ammonia, and appropriate protective equipment and respirators. Operation and maintenance of ammonia refrigeration systems are under the exclusive control of technical staff.
11. Energy management. Conaprole is active in energy conservation. AF-Energikonsult AB provided energy conservation training and conducted an energy audit; and several Conaprole engineers attended an Energy Conservation Seminar in the USA in 1998. Accumulated knowledge is applied actively to the design and installation of plant equipment (e.g. heat recovery). Conaprole commissioned energy reduction studies for equipment, services and lights, and continuously monitors other potential heat and energy losses (e.g. pipe insulation and steam traps). Exhaust temperatures, CO2 and CO percentages are carefully monitored to ensure maximum boiler efficiencies. Industrial water treatment is oriented to the avoidance of scaling and corrosion. A recent energy review performed with the assistance of McKinsey established a goal of 20% reduction and several programs are underway to achieve the goal. As an extension of existing monitoring programs, and to promote energy awareness, use reduction and reduce production cost
s, each plant will prepare and implement an energy plan to define the energy policy for the facility. The degree of detail in each energy plan and the approach to be taken will depend on the size of the facility, its energy use and the pre-existing systems in place. The energy plan will facilitate employee participation and demonstrate each facility''s commitment to continuous improvement in use of energy to meet the targets set by and for the facility.
12. Industrial hygiene, general occupational safety and health, corporate environmental management and life and fire safety. Conaprole''s corporate safety policy is oriented to achievement of zero accidents. The occupational health department employs an Occupational Health Physician, an Industrial Hygienist, an Accident Prevention Technician and a safety coordinator in each plant. Accident frequencies and severities are monitored closely and training is adjusted to reflect the findings of collected statistics and to thereby strengthen education and accident prevention programs.
13. Land acquisition, cultural property and sensitive natural habitats. Conaprole developed its rural facilities over the past twenty years in response to expansion needs. The property for these operations was purchased from owners in a willing buyer-willing-seller relationship. A seventy-five hectare property slated for future expansion was similarly acquired in 1990. A Pre Feasibility Property Assessment consistent with the requirements of the City of Montevideo''s regulations will be prepared for the proposed modifications and new construction at Plant No. 2 and submitted to the municipal government of Montevideo for review and approval. A comprehensive mitigation and monitoring program for development of Plant No. 2 will be prepared and submitted to the City for approval. Upon approval of the plan, Conaprole will implement and manage the required mitigation programs before, during and after the construction phase.
14. Community development. Conaprole supports schools, families and other educational institutions to promote Campana de Reciclaje de la Bolsa de Leche in which post consumer polyethylene milk containers are collected. Conaprole converts the containers into bags for solid waste collection and distributes them to schools and towns. At the national level in conjunction with the National Primary Education Administration, Conaprole supports an arts and creativity program for children aged 5-12. It supports a variety of foundations such as the Fundación Niños con Alas that supports needy children by paying all required school costs during primary education. And, periodically, Conaprole supports public school systems with donations of powdered milk and other products. For cooperative employees there are education and training grants for staff and children, housing support for relocated families and a variety of contributions to recreational and cultural activities.
15. Technical support for milk producers. Conaprole lends financial and technical support to some 2400 milk producers. Technical advice includes animal health, reproduction management, feed, milking equipment, farm management, veterinary clinics, and artificial insemination to name a few. Conaprole''s tambOletín (Dairymen''s Bulletin) contains timely technical information and is distributed to all producers. Conaprole and the Uruguayan government are proactively implementing dairy waste treatment programs throughout the country. Additionally, a variety of training programs is available to producers including: various thematic courses (e.g. animal feed, milk quality, dairy management) and the Young Producers Program. Conaprole established agreements with several financial institutions to lend money to cooperative members thus allowing them to opportunity to purchase new technology and to repay with cash flow from milk production. Several national programs in cooperation with Conaprole provide technical support, assistance with civil works (e.g. well construction and waste management) and financial services for the small producers not reached by other programs. Conaprole is promoting a Safe Dairies Program that incorporates food quality goals required to ensure the safety of milk from the dairies to the industrial plants. Conaprole intends to have all producing dairies become signatories to the program. The program clearly defines the standards to which each dairy should organize its resources and materials and to systematize its distinct activities to consistently assure a product that is innocuous, healthy and safe. Tuberculosis was eliminated in Uruguay some time ago. Brucellosis is well controlled and a program of eradication certification is well underway. Although eliminated some time ago, small pockets of hoof and mouth disease were identified last year but were quickly controlled with vaccinations and the country is once again free of the disease.
16. Labor retrenchment. In past industrial plant adjustments Conaprole addressed the needs of its supernumerary employees through a panoply of adjustments including arranging for transport to different operations, retraining for new positions elsewhere, early retirement, and other forms of compensation. During the past four years Conaprole has made significant staff reductions with specific agreements and without conflict. Upgrading and modernization at Plant No. 2 will necessitate retrenchment of approximately 200 employees. Conaprole''s adjustment program for these and other affected employees will be audited quarterly to ensure that compensation payments are made according to plan.
