PS1: Social and Environmental Assessment and Management Systems
Prior to the privatization, SEDAS did not have any formal EHS management system. The SEDAS new management appointed an Environmental Officer, and retained an international environmental consulting firm to carry out a comprehensive EHS audit. Based on the audit conducted in July 2009, detailed Environmental Action Plan (EAP) and Health and Safety Action Plan (HSAP), or collectively “EHS Action Plan”, was prepared to correct the areas of potential concern.
The areas of potential concern identified in the EAP that would be evaluated, corrected, and/or monitored include:
Confirmation from the relevant authorities (Municipality / Provincial Department of Ministry of Health) about the requirements of operating permit;
Temporary hazardous waste storage permit;
Management of air emissions from SEDAS vehicles;
Greenhouse Gas (GHG) inventory and management system for tracking and reducing GHGs;
Wastewater and stormwater management;
Hazardous, non-hazardous and waste and materials (including chemicals and medical waste) management (inventory, minimization opportunities, proper storage areas, 3-year waste management plan, etc.)
Waste oil management (source identification, minimization opportunities, proper storage, proper handling and management procedures);
Potential PCBs (Polychlorinated Biphenyls) contamination of transformer oils (inventory, analysis, proper storage and treatment as required depending on the concentration and volume – 500ppm / 50ppm / 5 liter);
Land / soil / groundwater contamination including assessment of and correction at waste oil and transformer storage sites;
Environmental management system including risk management, energy efficiency management, and training to employee and subcontractors on environmental issues.
The areas of potential concern identified in the HSAP that would be evaluated, corrected and/or monitored include:
Implementation of the requirements provided by the Ministry of Labor and Social Security audit (e.g. assignment of technical personnel responsible for the occupation health and safety, H&S risk assessment, appointment of a medical doctor, personnel protective equipment);
Health and safety management system (e.g. health and safety policy, procedures, safety meetings prior to activities involving power lines);
Working at height (e.g. provision of safety harness and vest, fall protection program and written guidelines);
Emergency response plans and drills;
Occupational health and safety employee training;
Public safety (e.g. secured prevention of access by general public to electric hazardous areas);
Traffic safety program;
Fire protection program (e.g. inventory of fire extinguishers, routine maintenance and monitoring of fire extinguishers, fire emergency exits); and
Risk assessment.
Implementation of the actions proposed in the EHS Action Plan in 2009 and 2010 helped to improve the SEDAS EHS performance significantly compared with the pre-privatization status. In June to August 2010, implementation status of the EHS Action Plan was further reviewed by SEDAS, IFC and EBRD (other co-lender), and updated Environmental and Social Action Plan (ESAP) dated September 13, 2010 was agreed. This updated ESAP includes actions related to: development and implementation of EHS management systems; obtaining missing permits; air emissions; waste and wastewater management; soil and groundwater contamination; handling and storage of hazardous materials; occupational health and safety; environmental and social appraisal of the investment program; and development and implementation of a Stakeholder Engagement Plan. Implementation of the updated ESAP will help further improve SEDAS’s performance to good international industry practice and in full compliance with IFC Performance Standards. The updated ESAP also includes development of land acquisition and compensation process, cultural heritage “chance find” procedures, as preventive measures to meet IFC Performance Standards.
SEDAS’s HSE Unit will monitor the progress of the ESAP of September 13, 2010, evaluate regulatory compliance status, manage reporting procedures and arrange provision of appropriate EHS training programs to employees.
PS2: Labor and Working Conditions
As a recently privatized electricity distribution company, SEDAS is in the process of improving its Human Resources (HR) management. The ESAP of Sep 2010 includes an action to develop an updated HR policy and system that will meet IFC Performance Standards for human resources management, worker organizations, wages, benefits and condition of work, non-employee workers, workers organizations, retrenchment, non-discrimination, and defined worker grievance process. This action will address HR benefits of both employees and workers.
SEDAS has been outsourcing several areas of operations over the last several years. Outsourced percentages are 99.6% for meter readings, 97.2% for repair works, 100% for cleaning and security, about 50% for electricity disconnection / reconnection. SEDAS now has about 700 employees and 1,500 outsourced workers. More than half of SEDAS’s employees are members of the trade union called TES-IS (Turkey Energy, Water, and Gas Workers’ Union). Selection of contractors is done using established procurement procedures (e.g. sending invitation to the potential contractors, review of technical and financial capability of companies who applied to the announcements). SEDAS monitors contractors’ health and safety codes and performance.
The sponsor of SEDAS is responsible to honor the past contracts signed between TEDAS and the unions. SEDAS has not faced with any major legal disputes related to employees or workers.
Following the EHS audit conducted in 2009, SEDAS has been implementing actions to improve its working conditions in according with the Health and Safety Action Plan of 2009. The updated ESAP of 2010 includes remaining actions such as full installment of machine guards, safe storage of flammables and explosives, improvement of odors in some of the prefabricated buildings, training of Electro Magnetic Field training, development of fall protection program, root-analysis training to personnel responsible for reporting and analyzing accidents, full provision of personnel protective equipment to all workers and contractors, etc. SEDAS had eight work related fatalities between 1999 and 2008. The implementation of the agreed ESAP will strengthen health and safety management including more systematic accident reporting and analysis and effective training and monitoring of both employees and contractors.
PS3: Pollution Prevention and Abatement
The EAP of 2009 by SEDAS included various pollution prevention measures to improve performance of air emissions, wastewater discharge, hazardous and non-hazardous waste management, PCBs, oil spill from transformers, and emergency planning. In preparing the updated ESAP of September 2010, implementation status of these pollution prevention activities were further reviewed, and updated implementation schedule was incorporated. Detailes can be found in the attached ESAP of September 2010. Key actions in the ESAP includes (i) development and implementation of stormwater management procedure for storage and warehouse facilities, (ii) separate collection and storage of hazardous waste and non-hazardous waste, (iii) inventory of transformers containing PCBs and development of monitoring plan of potential PCB leakage, if any, (iv) installment of adequate secondary containment for step-down transformer stations, implementation of more comprehensive soil contamination study, (v) proper maintenance and protection of the hazardous material and waste storage areas (transformers, hazardous wates, chemical containers), (vi) installment of adequate quantity of absorbents or spill kits available at all facilities to avoid spreading of spillages and leakages, (vii) conducting asbestos survey and development of procedure for asbestos handling and replacement.
The EHS audit identified that wood preservative chemicals were purchased in the past by SEDAS and unused chemical drums were stored within the premises of SEDAS. These drums were already disposed through certified treatment companies. Unused wooden poles are stored at SEDAS’s storage area at this moment. The EHS audit did not identify any major risks to the public because of the wooden poles in use mainly in rural areas. The updated ESAP has an action to improve hazardous waste handling and storage to minimize risks to communities, and this will address wooden poles in use and storage.
In accordance with the updated ESAP of 2010, the company plans to develop and implement a system to track GHG emissions from operation (e.g. vehicles, technical electricity distribution losses) and to find opportunities to reduce emissions. In 2009 SEDAS purchased 9,005 GWh of electricity from the national grid and sold 8,414 GWh, with 5.65% technical and commercial losses. This amount of loss (591 GWh/year) is equivalent to about 283,000 ton CO2/year, assuming the Turkish grid average CO2 emissions performance of 480 gCO2/kWh. SEDAS’s electricity distribution losses of 5.65% in 2009 are already in the reasonably good range, however, implementation of the capital expenditure program under SEDAS’s new management is expected to achieve further improvement to some extent.
PS4: Community Health, Safety and Security
SEDAS has a call center to receive customers’ complains / concerns. The EHS audit identified some areas for correction to ensure community health and safety are achieved (e.g. noise, access prevention to transformers). These have been corrected in 2009. According to global comparison, awareness to electricity safety by general public is high in the area, and high voltage electricity facilities are generally indicated with safety warning signage. Accidents recorded in the past by SEDAS are mainly by workers and not by the general public.
