The following potential impacts/issues of the Project were analyzed:
- Environmental and social assessment;
- Social and environmental management system and structure;
- Waste management;
- Treated wastewater quality;
- Community health and safety including the potential resettlement from a buffer zone;
- Labor and working conditions including occupational health and safety.
Mitigation measures for the key environmental and social issues are summarized in the paragraphs that follow and have been agreed between IFC and UVK. When implemented, these measures will ensure the Project’s compliance with the environmental and social requirements: the host country’s laws and regulations and IFC’s environment and social Performance Standards.
PS1: Social and Environmental Assessment and Management Systems
- Social and Environmental Assessment:
Under Russian legislation, each new development or upgrading of existing operations is required to be evaluated through social and environmental assessment (S&E) studies. This comprises the evaluation of the potential S&E impacts associated with a project and development of measures to avoid, mitigate, or compensate for adverse impacts. The studies were undertaken during the design preparation. The State Expert Review Committee and the State Environmental Expert Review Committee have reviewed the design documentation, including environmental protection measures for its compliance with Russian laws and regulations. Environmental risks and impacts upon implementation of mitigation measures were recognized as general in character and site-specific.
Social impact associated with the physical displacement of a limited number of people living in the current buffer zone since the sixties is a historical problem of Ufa. Actions undertaken by the Company and authorities to address this historical issue are summarized in the relevant paragraphs below.
Upon completion of the construction of the third block, the Company has also agreed to conduct in-situ measurements to evaluate actual impact on health of people living near the WWTP facilities. Further actions consistent with IFC’s Performance Standards are included in the attached Environmental and Social Action Plan (ESAP) containing specific tasks that the Company will undertake to mitigate risks and impacts from the planned upgrading.
- Environmental and Social (E&S) Management System:
The management system is currently relying on the adherence to regulatory requirements and focusing on their observance, availability of appropriate permits and licenses as well as systematic reporting and recording of EHS performance parameters.
- Management program - The Company established and continuously upgrades a management program to ensure the appropriate quality of potable water delivered to the population and the continuous improvement of treated wastewater quality. From 2001 through 2008 UVK has implemented more than 450 improvement measures and actions contributing to E&S performance improvement.
- Organizational structure - The Company has established and maintains an organizational structure that ensures the sufficient management of the company E&S performance. Environmental responsibilities are communicated to the Chief Process Engineer and are reported to the Director and the Technical Director. Environmental monitoring of the Company’s compliance with environmental legal requirements and development of appropriate environmental and social documents is outsourced to a local consulting company.
- Training - Regular professional training is maintained; annual training programs are established for workers, engineers, specialists and managers. Training, apart from professional, includes teaching specific categories of workers a second occupation skill. To ensure future proper operation of the third block the company arranged training of specialists and workers in various educational centers.
- Monitoring - Operational environmental monitoring includes control of waste collection and disposal, efficiency of air emission abatement equipment, treated wastewater and the recipient river water quality monitoring. Monitoring reports are prepared monthly. Environmental performance of the company departments is monitored through internal quarterly inspections; corrective actions are reviewed by the Company management.
Selection of the construction contractor was carried out in accordance with IBRD procedures within a program for rehabilitation of existing wastewater networks and treatment facilities launched in 2006 and supported by IBDR and EBRD over 2006-2007. The contractors’ EHS performance is controlled and monitored through regular inspections undertaken by the company’s specialists of technical, labor and occupational health and safety services and departments.
PS2: Labor and Working Conditions
The Project will create limited number of new jobs in the local area for operation of the third block for biological treatment in the WWTP. The company intends to hire about 23 new employees with appropriate skills.
- Working Conditions and Terms of Employment - Protection of the work force in Russia is provided through federal legislation, in particular the Labor Code. The Labor Code provides extensive protection for workers and ensures that a large set of social benefits must be provided. Republican labor laws specify and supplement rights and responsibilities of an employer and employees, guarantees employees’ rights for labor protection, and are consistent with the International Labor Organization’s core labor standards and IFC’s Performance Standard 2.
- Human Resources Policy, working relationship and workers’ organization - The Company is 100% owned by the Ufa municipal authority and strictly adheres to the national labor laws. The company ensures availability of personnel with appropriate professionalism and skills by maintaining of a procedure for multilevel selection and hiring of candidates. The hiring is conducted in accordance with the Russian Labor Code with a strict policy against discrimination based on gender, race, age, ethnic association or nationality, hereby fulfilling IFC’s Performance Standards. More than 97% of the employees are members of a trade union. The company maintains a collective agreement that sets up mutual rights and responsibilities of the company management and employees, moreover a suitable social package is offered to employees including onetime payment in special cases; financial aid and social benefits.
The Company will amend current internal labor documents and procedure to adopt a grievance mechanism consistent with PS2.
The company did not retrench personnel during 2008, while a minor staff reduction was carried out in July 2009 in a manner consistent with the national labor laws and PS2 with an advanced notification of employees and relevant compensation. Further staff reduction is not planned as the new block will need additional man power when commissioned.
- Occupational health and safety (OHS): The Company’s OHS management system is established to address national legal and regulatory requirements. Responsible staff conducts regular workplace inspections; inspection records specify correction measures when needed. To ensure their implementation, follow-up reviews are also conducted.
Assessment of work conditions, carried out in accordance with national regulations, has defined that personnel in specific work areas are exposed to physical, chemical or biological hazards, a majority of which include “hard” manual labor, noise, contacts with pathogenic bacteria; chemical substances, and hazardous risks associated with emergency repair works (for instance, confined spaces and vehicle traffic). To reduce hazardous and risks the company assures ventilation systems in work areas potentially containing pathogenic bacteria; using of personal protective equipment and safe and advanced equipment and tools. A replacement of ventilation systems has been undertaking in different operational departments and workshops during the last years. The work safety is supported by regular work safety training relevant to specific job activities including chemical hazards (e.g., handling chlorine and repairing electrical equipment).
Safety data were analyzed and found within normal performance. The safety performance has zero accidents for 2006 and 2007 and the accident frequency was in 2008 increased slightly to 0.68 LDA/MMH (Lost-Day-Accidents per Million-Man-Hours), based on 3566 employees having a total of 5.9 million man-hours. Although it is an increase over the previous two years it is still a very good performance.
The company has implemented measures to improve work safety, including specific measures to exclude or reduce the need of staff being in hazardous work areas. Examples of implemented actions include installation of automated test equipment for operational control of water wells’ and second-lift pump stations at all water intakes; some of wastewater pump stations are remotely controlled.
- Emergency preparedness and response:
Emergency response plans are developed and implemented for chemical dangerous facilities, which, apart from response actions, include identification of predictable emergency cases, availability of proper response means, and communication with authorities, population and municipal rescue units/services. Personnel were trained and have necessary skills to response emergencies. Additionally, internal rescue teams were established in specific operation facilities; team members were given specific training in the specialized training centers.
PS3: Pollution Prevention and Abatement
- Overview of current operations and upgrading:
UVK currently operates two wastewater treatment blocks within the WWTP. The current wastewater treatment includes: primary or mechanical treatment consisting of large suspended and floating objects removal through comb filters (preliminary water screening) and settling of sand and small stones in grit chambers; and biological treatment that include aeration systems, activated sludge and sedimentation. Aeration and sedimentation tanks are combined structurally within each block. All these facilities are located on the right bank of the river Belaya. The waste biomass, settled solids and excess activated sludge are pumped through under-riverbed tubes to the facilities located on the opposite riverbank for dewatering by centrifuges and drying by special dryers and further stabilization at the sludge ponds. Since the first two blocks of biological treatment were commissioned, respectively in 1974 and 1987, their capacity is limited to handle the total volume of wastewater delivered to the WWTP at that time. Today a short retention time in the system does not provide sufficient quality of the treated water and minor volume of the wastewater is discharged to the river with only primary treatment. The project will help increase the total capacity of the WWTP by the construction of the third block for biological treatment with advanced design of aeration systems and sedimentation tank combining a nitri/denitrification processes with the removal of phosphor using aluminum sulfate precipitation.
- Pollution prevention, resource conservation and energy efficiency:
UVK has undertaken initiatives to improve the quality of effluent discharges from the WWTP, since its efficiency no longer provide compliance with national standards specified in permits issued by the relevant environmental authorities. Exceeding was registered on COD, BOD, total suspended solids, oil products, and other pollutants. Completion of the project will provide additional biological treatment capacity for the wastewater delivered to the WWTP and will reduce the amount of heavy metals, oil products and other pollutants currently discharged into the river with wastewater receiving mechanical treatment only. Additionally, the quality of treated wastewaters will be improved through the reduction of operation load on the existing blocks.
Going further the company is considering the option of completing the fourth block for biological treatment that is expected to result in full compliance of treated water with established standards on abovementioned parameters. However, such investment plan would need considerable review and justification and will be strictly constrained by the availability of resources, thus limiting the future borrowings and ensuring debt servicing.
The company has implemented actions for enhancement of operation and energy efficiency and resource conservation. Some of them include the following: A wireless dispatching system SCADA (Supervisory Control and Data Acquisition) and geographical information system were installed to manage effective water distribution; identify leak detection, account and record data on requests for repair works and identified faults; analyze the water network operation status all based on real-time data. Water and wastewater pump stations were equipped with advanced power efficient equipment to reduce energy consumption. Portable water distribution and wastewater return pipelines are gradually replaced with long-term service polyethylene or other polymer tubes or steel pipes with internal sand-cement insulation. To reduce environmental impacts during maintenance and repair works preference is given to trenchless pipelaying (controlled-angle drilling).
- Waste management:
The grit and other objects removed by the primary treatment are periodically collected and disposed to a municipal landfill. The main waste generated by the operation is the wastewater treatment plant sludge. A facility for sludge handling (dewatering and drying) was put into operation in June 2009. After processing the dried sludge is further delivered to special storage areas.
- Hazardous materials’ handling:
Liquid chlorine is used for disinfection of drinking and wastewaters. To prevent accidental release and ensure safe handling, the Company is using certified equipment. Facilities and workshops using and storing liquid chlorine are equipped with detection and alarm systems. Appropriate emergency prevention and control plans are in place, and include provision of appropriate response equipment and materials, and procedures to be followed to minimize the harm of any potential accident. Additionally, step-by-step modernization of disinfection systems is carried out to replace liquid chlorine by UV processing or sodium hypochlorite. UV-processing is implemented in 5 of 7 water intakes and design documentation has been developed for UV-disinfection of wastewater before discharging into the river.
To reduce asbestos-graphite packing, the company is implementing gradual replacement by face sealing.
The Company will ensure that staff will be trained properly to handle chemicals (aluminum sulfate) prior to operation of the third phase of the WWTP.
PS4: Community Health, Safety and Security
The company monitors ambient air quality at the edge of the current buffer zone. A set of indicators (ammonium, hydrogen sulfide and other substances) and a schedule were agreed with a relevant supervisory authority. Exceeding of regulatory standards has not been recorded during the last year.
As described above, due to the current limited capacity of the WWTP, certain amount of wastewater volume is currently discharged to the river without biological treatment. This results in potential adverse impact on the health of the population living downstream from discharge points, but does not affect directly on the water supply for the city of Ufa which is provided from the river Ufa, infiltration sources and underground water boreholes. This situation will be improved after completion of the project. The heavy metals, oil products and other pollutants currently discharged with wastewater currently only receiving mechanical treatment will be reduced. The company continuously monitors river water quality 500 m upstream and downstream from discharge points. In spite of the wastewater currently not meeting the established standards on a set of parameters the average monthly tests did not revealed a considerable difference of water quality at these two sampling points.
A complaint of odor from residents living in the buffer zone of the WWTP was registered in 2008. As a response the Company carried out special monitoring and confirmed that facilities worked in normal conditions.
As an effort to reduce repair time and improve operational efficiency, the Company also introduced advanced technologies, equipment and tools including vacuum wastewater pump installation, directional drilling and remote control devices for pipeline testing.
Residents have various options to resolve their concerns: e.g. visiting the Company and meet its responsible managers and specialists in ‘the reception hours’; sending a written request to the municipal authorities; calling “hot-line service”. The numbers for the hot-line service are listed on the official web-portal of Ufavodokanal
http://www.ufavodokanal.ru. Relevant contacts in Ufa city Administration are published at the official web-portal of the City of Ufa
http://www.ufacity.info/index.php.
PS 5: Land Acquisition and Involuntary Resettlement
The IFC Project does not involve acquisition of additional land for the construction of the third block for biological treatment; which is undertaken within current facility borders.
In compliance with the national regulatory requirements the Company has established a buffer zone and developed proper documents to address issues associated with people living in this zone. Within the current buffer zone there are a number of permanent residents; individual houses for seasonal (summer) living; people using land for individual agricultural needs and people living in this zone without formal legal rights to the land they have occupied since 1940-1950th. These users are currently legalizing their rights judicially and their claims are recognizable under the national laws since national legislation provides benefits for people occupying land for a long period.
To address the issue the Company has formally recorded permanent residents, seasonal houses and land plots and has handed over this list to the authorities. As per June 2009 the Company has recorded 149 permanent residents and 44 seasonal houses with land plots in the current buffer zone. An independent assessment of land plots and assets was carried out for identification of the needed compensation for loss of assets to be provided or an equal accommodation. In close cooperation with authorities the Company has developed a schedule of resettlement approved by the city authority and financed from the municipal budget.
The regulations require the final buffer zone size to be adjusted upon completion of the construction of the third block for biological treatment. To evaluate actual risks and impacts on the population’s health and safety the Company will arrange in-situ measurements within one year in accordance with national regulatory requirements. Based on these measurements, the size of the buffer zone will be revised accordingly and the final need for resettlement will be determined. If resettlement is needed, the physical displacement of people living in the final buffer zone and demolish old/abandoned individual houses as well as seasonal houses and land plots will be carried out in compliance with national legislation and the Performance Standard.
To ensure compliance with PS5 the Company will undertake agreed abovementioned actions included in the Action Plan which comprises the arrangement of in-situ measurements to evaluate the actual impacts on population health and safety. And if resettlement is needed, develop a Resettlement Plan in coordination with the IFC social specialist.