Social and Environmental Assessment and Management Systems:
- Land and natural environment:
None of the current or anticipated Nitol operations are located in either protected areas or in designated national parks. The industrial site is located in a dedicated industrial area.
- Environmental and Social (E&S) Assessment:
Nitol has programs in place to prevent and reduce air emissions, liquid effluents, soil contamination, and solid waste. The company also has rigorous preventive maintenance programs for process and transport operations and it has a continuous improvement approach to enhance its E&S systems and ensure all established procedures and requirements are duly followed. As needed, the company commissions environmental audits and environmental impact assessments when engaging either in new projects or upgrades that pose material changes. Specifically, Nitol commissioned an environmental audit for its chemical operations in October 2007. The capacity increase of its TCS operations required an environmental impact assessment which was submitted to the local authorities and is the base for the environmental permits being requested for the execution of this project. For the polysilicon project, the solar division is preparing an additional EIA which will be ready in July 2008. A copy of this report, which it is anticipated, will demonstrate compliance of the project with all applicable IFC PSs and guidelines will be submitted to IFC prior the first disbursement.
For the chemical division, the company has agreed on an action plan with the local environmental authorities to reach compliance with local requirements.
- Environmental, Health, and Safety (EHS) Management and Organization:
Nitol is working towards obtaining the ISO 14001 and the Occupation Health and Safety OHSAS 18001 certifications for both the chemical and solar operations and anticipates obtaining them within 2008.
The Group has personnel dedicated to handle the EHS aspects of its operations. The corporate EHS coordinator, who oversees the EHS activities of Nitol''s entire operations, reports directly to the Group''s General Manager. In addition, each site has specialized dedicated personnel to ensure the operations comply with:
- the local EHS requirements,
- Nitol''s corporate EHS initiatives, and now,
- IFC requirements.
At Usoliekhimprom, the environmental division is a subdivision of the Industrial Safety Department which in turn reports to the Technical Director. The industrial department has approximately 240 dedicated employees. The Usoliye-Sibirskiy Silicon complex has a department of environmental protection, a department of industrial safety and a department of occupational health.
Nitol also manage the EHS performance of it contractors with practices such as conducting induction training about Nitol EHS practices and associated job risks, establishing contractual requirements, and conducting audits.
- Training:
Nitol has its own training facilities where periodically conducts EHS training for its own employees, as well as contractors. Both, Nitol''s chemical and solar divisions conduct induction for new employees, targeted training for managers and specialists, specific job risks training, quarterly EHS refresher courses, testing of training effectiveness, etc.
- Community Engagement:
Nitol makes a practice of maintaining the community informed about its EHS performance by periodically publishing updates in local and regional communication media (i.e., newspapers, radio.) In addition, Nitol has established a grievance mechanism through which the community can place complaints and in turn Nitol resolves, follows-up, registers, and monitors these complaints.
As part of the EIS assessment approval process for the TCS capacity increase project, Nitol conducted public hearings where representatives of the local community, schools, public organizations and state authorities convened. The minutes of these meetings are part of the approval process by the local authorities. In general, the community supported the project on the basis that it will bring additional revenues to the town and will generate additional jobs. As part of the PCS EIA process, Nitol also conducted public hearings and will submit the results to IFC, to demonstrate that it has addressed as appropriate community concerns.
- Monitoring:
The company has monitoring programs in place to asses its EHS performance which are conducted by the chemical division for both chemical and solar divisions. Nitol monitors air emissions, water consumption, liquid effluents, noise, groundwater and soil contamination as well as workplace conditions and number of work-related accidents/incidents. In addition, it also monitors the air quality at the boundary of the sanitary protective zone (SPZ) with continuous chlorine and hydrogen chloride monitoring systems.
The monitoring results of the various parameters measured from the company operations reflect a constant reduction of the environmental pollution (tons of air emissions released, air mercury concentrations, mercury amounts, volume of wastewater discharged, etc.) and particularly an improvement in the air releases to the atmosphere during the last few years.
- Reporting:
Nitol prepares annual monitoring reports for the local environmental authorities. It also prepares and publishes an annual report, which includes basic EHS aspects. The company regularly publishes materials referring to the environmental situation of the production facility and its effort aimed at improving this situation on its corporate site www.nitolsolar.com. As indicated above, Nitol periodically publishes its EHS performance in the local media. Just in 2007, it made 21 environmentally related newspaper publications at local and regional level as well as radio announcements and reports.
Labor and Working Conditions:
- Human Resources (HR) Policy and Management:
Nitol has an HR manager in charge of implementing the company''s HR policy and systems for all its operations including staffing, staff development, organization and development of positive reinforcement systems, and corporative culture organization and development, amongst others.
- Non-Discrimination and Equal Opportunity:
The company is an equal opportunity employer. All hiring and promotions are merit-based.
- Retrenchment:
The chemical division had a personnel reduction in the last three years, 2005 (42), 2006 (172) and 2007 (240). The solar division has not had any personnel reductions. All the reductions were conducted in accordance with the local labor requirements. The company (both: chemical division and solar division) does not have any pending legal actions as a result of retrenchment. If during the life of the project with IFC, Nitol has reduction of personnel; the company will inform IFC prior it takes place and will prepare, as needed, a retrenchment plan. Additionally, during the construction phase, at the solar division, it will create approximately 500 additional temporary jobs. And by the end of 2009 when the polysilicone project is completed, 1000 new permanent jobs will be created. Nitol will submit copy of the retrenchment plan for the personnel reduction occurred in 2005, 2006 and 2007 as indicated in the ESAP.
- Protecting the Workforce:
There is no child or forced labor at any of its operations. The company also ensures that the contract laborers are at least 18 years old. In addition to the compliance with in-country labor laws, the company provides additional benefits to its employees (i.e., extended health insurance to employees'' families, educational support, loan programs for employees, programs of sport support, etc.) The local authorities conduct periodic labor audits. The most recent labor audit to Nitol operations was conducted in 2006. No irregularities were found. Nitol will confirm that details of it will be provided.
- Workers Organizations:
Nitol employs approximately 5259 employees of which 5100 are direct employees and 159 are contract employees. Specifically the chemical division has 4,503 employees; the solar division has 259 employees, Khimstroymontage, the construction and repair support unit, has 198 employees and the remaining are employed in other parts of the group including sales and administration. Nitol employees based in Russia have the right of association as per the Russian labor laws. Currently the number of unionized Nitol employees is 2597 people.
- Occupational Health and Safety (H&S):
Nitol has an H&S management system in place to coordinate all relevant E&H aspects of its operations. Key H&S programs include assessing employees'' general and occupational health, evaluating work-related risks and preventing occupational impacts, workplace monitoring, maintaining records of accidents and incidents, and implementing corrective measures to reduce negative EHS impacts. It has appropriate medical services at all its operations and conducts regular medical check-ups including those for employees working in dangerous and hazardous areas. It provides personnel protective equipment (i.e., uniforms, respiratory protective devices, boots, etc.) which are required to be used at all times. The company has response equipment and trained personnel, available at all times, to handle fire/emergency response actions.
It is anticipated that for the solar division, as part of the new project, the company will install automated ventilation systems and automated alarms at the work place areas to ensure early detection and response for exceedance of HCl, chlorosilane, and other vapors.
Nitol continues strengthening its H&S systems to reduce the likelihood of lethal accidents. This situation will be significantly improved with the development of the procedures needed to obtain the OSHAS 18001 certification, with the implementation of the E&H action plan Nitol has already developed, and with the work place risk assessment currently on-going. Nitol has established workers grievance mechanisms by which employees can go directly to the supervisor or contacts its union leaders. In turn, Nitol follows, resolves, and documents those grievances.
- Pollution Prevention and Abatement:
Nitol conducts all operations in ways that minimize environmental impacts by reducing the possibility of leaks and accidental spills and puts strong emphasis in conducting predictive, preventive, and corrective maintenance.
The chemical division produces:
- chloro-organics including liquid chlorine, trichloroethylene (TCE), polyvinyl chloride (PVC), epichlorohydrin, and hydrochloric acid (HCl); and
- inorganics including calcium carbide, calcium chloride, calcium hypochlorite, caustic soda, epoxy resin, hydrogen peroxide, metallic potassium, gases (i.e., nitrogen, argon, oxygen), liquid nitrogen, and liquid oxygen.
The solar division produces various grades of (TCS) and silicon tetrachloride. Key operations include crushing (silicon), compression (HCl and nitrogen) and synthesis and purification (TCS and silicon tetrachloride.)
- Raw Materials and Resource Consumption:
Process and drinking water for both divisions is supplied by the municipal authorities. The power and steam for both divisions is obtained from a nearby coal fired power plant.
Main raw materials associated with the chemical division include salt, propylene, acetylene, coke, limestone, sulfuric acid, and potassium hydroxide; they are all bought from third parties. The main raw materials associated with the solar division include silicon and gaseous HCl which is provided by the chemical division. To satisfy the additional demand of raw materials from the solar division for the new project, the chemical division will increase production of Chlorine and has upgraded the current operations.
Nitol aims to develop programs to optimize its operations and reduce consumption of raw materials. Specifically, it is evaluating an ecologically friendlier new technology for epichlorohydrin production (glycerin based) and all organic-chlorinated wastes are used for HCl production, among others. For the solar division, Nitol will install a closed water system which will be in operation for 2009 and will upgrade as appropriate the equipment to ensure better energy consumption, etc.
- Ambient Conditions, Air Emissions, Liquid Effluents:
Nitol conduct periodic ambient monitoring within its premises and also at the boundary of the SPZ. These results demonstrate that the company is within the limits of the local authorities and IFC.
The chemical division has controls in place to reduce the emissions from most of its processes which include approximately 480 stationary emission sources and 30 fugitive sources. However, it has identified additional actions to further reduce the emission levels. Specifically, at the chemical division, it has a plan to curb chlorine, vinyl chloride, epichlorohydrin, and PVC emissions. In addition, it will also enhance its controls to reduce particulate emissions from some of its sources which have concentrations above the IFC requirements. The specific actions are listed in the ESAP. Upon implementing those actions, the chemical division air emissions will be in compliance with the local authorities and IFC requirements.
The air emissions at the solar division include silicon dust, nitrogen and hydrogen which are released to the atmosphere after passing through air pollution control devices. It is anticipated the new project will have an ammonia vapor recovery system, processing facility for gaseous wastes, two-stage off-gases scrubbing systems in the synthesis department, scrubbers in the sludge collection area, and overall improvement of leak detection system for the equipment. As part of this project, the hydrogen will be captured and reused in the polycrystalline silicon production process. Concentrations of air releases in the solar division are in compliance.
The chemical division treats the liquid effluents generated by the chemicals and solar divisions as well as those generated by the nearby power plant, a nearby pharmaceutical manufacturer and a few other small industries.
The liquid effluents generated at the chemical division include organic effluents, acid/caustic effluents, storm water, cooling water, and sewage. The acid/caustic stream is sent to a neutralization station, via an underground pipe network which will be upgraded as indicated in the ESAP. The supernatant from the neutralization station is discharged into the river via a bulk chamber and the sludge in pumped to the sludge lagoons handled by Nitol. The storm and cooling waters are sent directly to the Angara River located at approximately 3.5 km from the site, and the sewage and untreated organic effluents are sent to the municipal system which biologically treats all effluents prior discharging them into the Angara River. Since the chlorine and mercury levels and those from other parameters are currently above the local and IFC requirements, Nitol will rebuild its neutralization station and implement other actions as indicated in the ESAP. After implementation of these actions, Nitol''s treated liquid effluents will be in compliance with IFC and local requirements.
The liquid effluents generated from the solar division include process water (i.e., from off-gas scrubbers, equipment cooling, etc.) and domestic wastes. It is anticipated that between 70 to75% of the process wastewater will be reused. There will be no need to increase the capacity of the wastewater treatment facilities to accommodate the effluents from the new project.
- Soil and Groundwater:
Nitol''s current chloro-alkali production is based on the diaphragm technology. However, prior to 1998, when the assets were under state ownership, mercury cells were used for electrolysis on a site not owned by Nitol, whereby the mercury containing slag was disposed into underground pits. The mercury contaminated areas of the plant were not included when Nitol purchased the other assets in 2003 and hence it does not own the land subject to the mercury contamination. Despite the fact that it has no legal obligation,, the company is keen to facilitate the clean-up and it is contributing with a study commissioned to provide a base line assessment (i.e., levels of soil and groundwater mercury contamination, actions to be taken to dismantle the contaminated buildings where this process and supporting activities used to take place) and definition of the eventual remedial actions to the mercury contamination for which the local environmental authorities will take the lead. The study is expected to be ready by April 2008. A copy of this report will be submitted to IFC. The Irkutsk environmental authorities have approached the World Bank for support on the mercury soil and groundwater decontamination. The process is on going; however, no specific outcomes have been yet established.
For the solar division and as part of the new project, the existing storage tanks as well as those new to be installed will be upgraded to have double containment, impermeabilized flooring as well as alarm systems to detect potential leaks.
- Solid and Hazardous Wastes:
The hazardous and non-hazardous wastes are segregated and properly disposed following local requirements. For the chemical division, the sludge from the neutralization station is sent to a sludge lagoon, the wastes from the organic chlorine operations are reused in the production of HCl, the calcium carbide dust is sent to the company''s landfill which is properly lined and has monitoring systems to control leaks. Other wastes generated (i.e., mercury from lamps, used oil) are collected and sold to authorized third parties for reuse. The domestic wastes are sent to the municipal landfill.
The main wastes from the solar division include:
- distillation residues from wet and dry scrubbers, spent silicon from the reactor, and silicon dust from crushing and purification of the TCS products disposed in the chemical division industrial landfill.
- sand, which is used for on-site road construction and repairs; the remaining is sold for reuse, and
- used oil is reused onsite and spent fiberglass from air filters is sold to a third party for reuse.
The chemical division has made efforts to reduce the generation of solid wastes. Specifically in 2005 it began reducing the total amount of solid waste materials by 12% per year. In addition, as a result of the project, the company will replace compressors with none-greased compressors at the solar division.
The company has established procedures to manage the transport and disposal of waste generated ad it is committed to reduce the amount of wastes generated to comply with local environmental requirements and to optimize the use of its raw materials.
- Hazardous Materials:
The chemicals division has numerous above ground storage tanks (ASTs) to store materials such as brine, TCE, epychlorohydrin, acetylene, oxygen gas, etc. As part of its environmental upgrades, the chemical division has a program to install, as needed, double containment for the raw materials and products storage tanks as indicated in the ESAP. It will also ensure impermeable flooring in the areas where the tanks are sited. There are no underground storage tanks (USTs) in use. This division uses asbestos in some of its processes (i.e., diagraph cells for its chloro-alkali production, metallic potassium production) and in equipment ancillary. It is also present in existing building as construction material. The chemical division uses radioactive materials in measurement equipment. The company has detailed procedures for handling, storage and disposal of these types of wastes.
The solar division stores its hazardous materials in ASTs and does not have USTs. Asbestos is evident in building materials. Radioactive materials are not used in the production process. Radioactive sources are used in measurement and observation.
There are no PCB transformers at either the chemical or solar divisions.
- Operational Safety:
Nitol has periodic rigorous maintenance programs for both its chemical and solar divisions operations. It is in the process of completing the first steps in the completion of the HAZOP for the chemical division. It anticipates having it completed by December 2008.
For the new operations at the solar division, it will upgrade its operational safety procedures including its HAZOP and commits to have them ready prior to commissioning of the new operations. The operations have gas detectors (nitrogen, ammonia, HCI, oxygen) throughout the work areas.
- Emergency Preparedness and Response:
Nitol has established procedures to ensure the safety of its operations. For each operation site Nitol has developed emergency response and contingency plans which contain detailed procedures to respond to accidents. Key elements of these plans include procedures for internal/external communications, response organizations/contacts, neighboring plants involved in the Mutual Aid plan. The company requirements are included into the individual agreements made with the parties contributing to the emergency responses. Currently, Nitol is evaluating these plans to ensure they consistently correspond to their specific risks and will, as needed, upgrade these plans as a result of the upgrade of its operations.
All plants have prevention/response programs in place (i.e., trained fire/emergency response brigades available at all times, periodic emergency response drills, fire prevention/response equipment such as alarms, sprinklers, signals, hydrants, dedicated fire water tank, and extinguishers throughout the operations site.) There are a number of dedicated fire and rescue stations which are equipped with a fleet of fourteen fire and rescue trucks. Nitol also keeps an incident log to register the emergency situations and the mitigation actions.
At Nitol Solar, the company has developed emergency preparedness response programs. (“The liquidation of emergency situations consequences plan” in each shop) The existing emergency preparedness and response plans for the solar division will be upgrade as a result of the new project and will be ready before the project is commissioned.
- Green House Gases (GHGs):
Major sources of green house emissions (carbon monoxide, and nitrous oxide,) at the chemical division, include process and fugitive emissions from the operations and equipment. Nitol makes an effort to optimize its operations to reduce CO2 emissions. Specifically in 2006, it collected approximately 1,100metric tons of CO2 and reuse these in the production of sodium carbonate. In 2006, the chemical division released 45 metric tons of CO2 and 340 metric tons of nitrogen oxides to the atmosphere. The solar division does not contribute process GHG emissions because there is not GHG generation during the production activity.
Currently the overall energy consumption for the entire company is approximately 2 billion of kw-h/yr. All the requested electric energy is obtained from the Regional Power Station 11. It is anticipated that by 2009 when the polysilicone project is completed, the amount of energy will increase proportionally.
- Community Health, Safety and Security:
Nitol operations are built to reduce negative risks to the nearby communities. The sanitary protective zone (SPZ) extends 1.5 km from the operational site and there are no residents located within this radius. There are residential properties approximately 600 meters from the salt extraction fields. The company has established monitoring programs to assess potential impacts to the community. The monitoring results indicate that there are no negative impacts affecting the community. In addition, the company has an aggressive on-going forestation program within the SPZ.
- Transportation:
The chemical division raw materials are brought by railroad to the storage areas Owned by the company. All main raw materials as well as the products are dispatched by railroad. The solid products in wagons (calcium carbide, calcium hypochlorite and PVC), and the liquid products in tank containers (epichlorohydrin) and in cisterns (caustic soda, TCE, liquid chlorine.) Some of the cisterns are owned by Nitol. In case of accidents, the responsibility relies on the contractor for tank containers, on the railroad authorities for all others once it has accepted the shipment. Nonetheless, Nitol has emergency response procedures in place in case of any transport accident.
The wastes sent to the company''s landfill are transported in Nitol’s own trucks.
The solar division uses contracted trucks to receive the silicon, the HCl is sent via pipeline from the chemical division. The TCS is transported by tank container via railroad. The railroad system is operated by OAO “RZhD”, Russian government owned transportation company.
- Product Stewardship:
Nitol is committed to produce safe products, disclose the inherent risks in the use and handling of its products, and share the good environmental and safety practices it applies in its industrial sites. Nitol produces a newsletter that it distributes among employees, clients, and communities. It brings environmental themes and environmental awareness campaigns.
- Land Acquisition:
Nitol will not need to acquire additional land as part of the project.
- Protection of Cultural Property:
None of the company operations or proposed project is located in areas where cultural resources, such as sites of archaeological value, are likely to be found.
Nitol policy is to keep close and open communications with local communities and authorities. The company generates local employment and is committed to fill all unskilled employment positions with local persons and to use local suppliers of goods and services whenever possible. The company supports projects to improve the quality of life in communities located within the area of influence of its operations. It focuses mainly on environmental protection training for students, greening/embellishment of the town, and social support.
- Monitoring:
IFC will evaluate the project''s compliance with the applicable environmental and social requirements during the lifetime of the project through the following methods:
- Review of the annual monitoring reports (AMRs) prepared for the project;
- The status of implementation of any measures contained in the ESAP;
- Ongoing performance of project-specific environmental, health, safety, and social activities;
- Periodic site supervision visits will also be conducted, if necessary.
- Conclusion:
Accordingly, IFC concludes that the proposed project will meet the applicable World Bank/IFC environment and social policies and the environmental, health and safety guidelines upon successful implementation of the agreed mitigation measures listed in the ESAP.
