PS1 – Social and Environmental Assessment and Management Systems
Environmental and Social Assessment
IFC has reviewed the EIA reports of Trakya Yenişehir Plant prepared in 2005 and 2006 by a certified company for the first (TR5) and second (TR6) float lines, respectively. Trakya was granted a positive decision on the EIA by the Ministry of Environment for these projects in 2005 and 2006. When designing/commissioning the new furnaces for TR5 & 6 two successive air quality modeling studies have been carried out for the determination of the impact of the furnace projects in terms of emissions. The first set of results considers the contribution of emissions generated from TR 5 while the second set of results looked at TR6 including TR5 and one container furnace in the neighboring plant. The conclusion reached is that dispersion of air emissions from furnaces of Trakya Cam Yenişehir San. A.Ş. would not have significant adverse affect on the air quality in the surrounding residential areas. Ambient air monitoring study to reveal the real status is currently going-on and IFC will be provided with the copy of the overall report along with the comparison with the projections of the modeling study.
The EIA for the second float line (TR4) and figured glass line in Mersin has also been reviewed by IFC. The Turkish authorities do not require an EIA for the new solar glass line at the Mersin Plant. There is positive decision on the EIAs for the two existing float glass lines (TR3 & 4) and figured glass line. An air modeling study was performed by a certified company in year 2007 to determine NOx emission contribution of sources (TR 3, TR 4 and figured glass furnace) at the plant. This study showed that the lines’ contribution to ambient NOx levels would be just 16% of regulated values, and monitoring has shown ambient NOx levels well within Turkish standards.
There is positive decision on EIA of existing float and tableware lines in Bulgaria Plant, and a permit was granted before the construction work of the plant was started. The EIA was revised for the proposed second float line and a positive decision was guaranteed. Permit conditions will be tightened upon renewal in 2011, and Trakya has investments planned to meet the new permit as described below.
IFC receives annually the Annual Monitoring Reports (AMR) for Trakya Cam San. A.Ş. Mersin and Lüleburgaz Plants and Trakya Glass Bulgaria EAD, as well as for other operations of Şişecam in Turkey and Russia. These AMRs include information about point source air emissions, the status of ISO/OHSAS certifications, as well as information on HSE management.
Environmental, Health, Safety and Social Management
Trakya Cam established the Lüleburgaz, Mersin and Yenişehir plants respectively in 1981, 1996 and 2007. The Trakya and Paşabahçe plants in Bulgaria were commissioned in late 2006.
Environmental and social management is currently undertaken essentially to meet local regulatory requirements. Furthermore, Trakya Cam like all Sisecam companies is committed to continuous improvement and performance beyond regulatory compliance wherever applicable through establishment of certified environmental, health and safety management systems according to international standards. The strategy of Sisecam is to have ISO 14001 and OHSAS 18001 certifications at all plants by the end of 2009.
Trakya Cam plants in Turkey (Lüleburgaz and Mersin) each have a dedicated Environmental Management System (EMS) certified under ISO 14001 and an Occupational Health and Safety (OHS) Management System certified under OHSAS 18001. The Bulgaria Plant of Trakya Cam (in Targovishte) has an OHS Management System certified under OHSAS 18001 and has implemented an EMS which will be certified to ISO 14001 in 2009. The certification process for both standards is going-on at Yenisehir plant and expected to be achieved in June 2009. Trakya Cam companies maintain an independently certified Quality Management System as well in line with the ISO 9001.
Sisecam is organized along four main product lines: the float glass division (Trakya Cam San. A.Ş.), the container glass division (Anadolu Cam San. A.Ş.), the glassware division (Pasabahce Cam San. A.Ş.) and the chemicals division (Soda San. A.Ş. and other Business Units). Health, Safety, Environmental and Social (HSEC) Management at Sisecam corporate level are under the responsibility of two departments: Industrial Relations Department (under Human Resources Vice Presidency) and Research & Engineering Department (under Research and Technology Vice Presidency) covering Environment.
Corporate environmental management organization at Sisecam is under Research and Technology Vice Presidency and includes a team of 1senior staff, 3 environmental engineers and one technician. The team is responsible for tracking environmental regulations, international standards and best practices in the glass industry, participating in several local and international institutions’ environmental working committees, supporting plants in development of pilot projects to improve environmental performance, monitoring performance at site and corporate level, making benchmarking and sharing information with Sisecam plants as well as with global sector leaders. The corporate team organizes three times a year a meeting with all plant environmental engineers and/or production engineers looking at environmental issues. Sisecam owns an accredited mobile Air Quality and Emission Monitoring facilities including a measurement vehicle to monitor emissions at plant level and to calibrate on-site monitoring devices.
The corporate Occupational Health and Safety organization is within the Human Resources Unit reporting to the Industrial Relations Department. Within the corporate management of Sisecam Group, there are three OHS auditors certified by the European Organization for Quality. This organization is mainly responsible to set OHS key performance indicators, to do statistics and to track performance at site and corporate level.
At each production site, an engineer is in charge of permitting and ensuring compliance with local environmental regulations and the requirements of the established management system standard. He or she reports periodically key performance indicators to the corporate office of Sisecam. An engineer has been appointed with responsibility for Occupational Health & Safety, industrial safety and in certain cases is overseeing environmental management. The Environmental and OHS Engineers report in most of the cases to the Technical Manager and/or to Quality Operations Manager along who in turn report to the Factory Director who has overall responsibility for the Plant and its operations. Staff is currently provided with environmental, health and safety training as required by local regulatory requirements as well as by ISO 14001 and OHSAS 18001 management system standards.
Each site has periodic monitoring and reporting of emissions to air and water, ambient air conditions, workplace air quality, waste generation and resource consumption. As previously mentioned, accident and incident statistics are also reported and tracked in order to reduce accident rates through corrective and preventive actions.
Sisecam top management is in the process of developing robust communication and cooperation between corporate Social, Environmental and OHS organizations and will ensure that key performance indicators are established for all significant parameters on social, environmental, health and safety issues and all sites are included in the performance tracking system by the corporate management.
Supply Chain of Raw Materials
Major suppliers of sand, soda ash and limestone to each float glass plant area and the information about the origin of the supplier have been reviewed. The majority comes for sources controlled by Sisecam or subsidiaries (most of them with established environmental, health and safety management systems with exceptions in Egypt for sand and in Bulgaria for sand and limestone)
PS2 - Labor and Working Conditions
Human Resources Policy and Training
Sisecam Group holds a policy to attach highest importance to its human resources to ensure a working environment where staff are provided with development opportunities through modern and sustainable methods and where competence, performance and satisfaction are commonly nurtured. The training process, which begins from the recruitment stage and continues with a variety of training and self-development opportunities constitutes one of the most significant elements of the Group’s investments. Training projects are held within the framework of annual training plans prepared in compliance with individual and organizational needs.
Working Relationship, Working Conditions and Terms of Employment
The working conditions, terms of employment, wages and benefits of the white-collar employees are formed by ‘individual labor agreements’. As reported by the Sisecam Group, there are also detailed procedures and regulations of the company regarding benefits, working hours, overtime work, annual leave, performance evaluation, etc. All employees are able to reach these procedures and regulations through Sisecam Group’s Intranet system.
Sisecam has reported that working conditions and terms of employment at a minimum comply with national Labor Act Code No:4857, but at most of the areas such as paid annual leave, marriage allowance, birth allowance, death allowance, educational allowance, meal allowance, period of notice and compensation, marriage leave, birth leave, death leave etc. are beyond law. The minimum age for employment is 18 in Sisecam Group. All enterprises have been reported to be in full compliance with national and local laws restricting child and forced labor in accordance with ILO standards. The Industrial Relations Department updates the relevant legislation related with labor relations, give information and rule the Human Resources Departments of the enterprises including Trakya Cam facilities.
Industrial Relations, Freedom of Association, Grievance Mechanism
On behalf of the Sisecam Group, the Industrial Relations Department deals with the relations between the management of the enterprises and its blue-collar employees. Employees have freedom of association can be member of a union and unions are active at Sisecam Group Companies including Trakya Cam. Collective bargaining, relations with trade unions, employer associations and the other official foundations, advising, training and performance tracking on occupational health and safety are the major functions of the Industrial Relations Department.
Sisecam Group is bargaining with seven different trades unions in four different branch of industry, namely glass, metal, chemistry and paper. Trakya float glass operations deal with Kristal-Is Union in Turkey and with Podkrepa in Bulgaria. The agreements are usually enacted for two years. Not only enacting the collective labor agreements but also supervising the application of the agreements at the plant level is an important mission of the Industrial Relations Department of Sisecam Group. The Industrial Relations Department organizes training programs for the human resources functions at site level and for the site managers about the application of labor act and collective labor agreement.
The Group has established grievance mechanisms for white and blue collars. The Grievance Mechanism for white-collar employees is outlined in a document named “Human Resources Systems Regulation of Şişecam” which is available on the company’s intranet. Disciplinary Boards are also formed for white-collar employees in case of a grievance expressed by another employee. To comply in Turkey with the national Labor Act code no: 4857- article 18, white-collar employees also have right to ask for judicial or administrative arbitration. For blue collars it is described it in the collective agreement document and in the Human Resources Systems Regulation of Sisecam. Apart from internal conflict resolution mechanisms, the employees have right to ask for judicial or administrative remedies.
Non-Discrimination and Equal Opportunity
Sisecam has reported that all of the employment decisions are based on job requirements. National labor law prohibiting discrimination, the company respects and obeys the rules. The number of women employees is 242 out of 2818 (8.6%) for Trakya Group and 67 of the employees are disabled employees. A significant number of women employees hold managerial position. Including the Flat Glass Group President, there are 40 women who are in a managerial position in Trakya Cam.
Retrenchment
Sisecam reported that the retrenchment is considered as the last option when restructuring of the work is required and in such cases, there is a model to mitigate adverse impacts of the retrenchment. When retrenchment is unavoidable within an enterprise, transfers between enterprises part of the Sisecam Group are considered at first to a possible extent. Otherwise, the dismissals are proceeded along with the payments of extra compensations beyond that is required by law. There is an agreement with the trade union which requires negotiation prior to any decision for retrenchment.
The current marketing conditions due to global financial crisis and reduced production has not caused any retrenchment so far. The working structure has not changed in float glass processing operations, however in automotive glass processing, working hours have been reduced. Sisecam Group has made a general announcement to its employees that there is no planned retrenchment within the Group, including in Bulgaria. However, the possibility of a retrenchment given the market conditions cannot totally be excluded. If such conditions occur, Sisecam will provide IFC with the relevant studies and plans in relation with unavoidable retrenchment prior to proceed.
As reported by the Group, the total number of employees in Trakya Cam is 2818. Besides, there are 845 contractor employees of 30 different contractor companies providing transportation, cleaning, catering and security services.
Sisecam has in place mechanisms to strictly control contractor operations to be in line with the national Labor Act.
Occupational Health and Safety (OHS)
OHS management structures are in place in Trakya Cam as defined by Turkish and Bulgarian regulatory requirements. Trakya Cam has implemented in Turkey and Bulgaria an OHS Management System per OHSAS18001 international standard. Mersin, Targovishte and Luleburgaz have been certified since 2006, 2007 and 2008 respectively. Yenisehir is under the process for certification which is expected for June 2009. All plants have reported that periodic workplace monitoring is undertaken as defined by Turkish and Bulgarian regulatory requirements. Plants have nearby medical staff and hospital facilities. Training is provided to all staff on quality management, OHSAS, production quality improvements, labor safety and subsequent EHS regulations applicable at each plant.
For Trakya Cam Turkey, Lost Time Incidents (LTI) Frequency Rate (number of LTIs per 1,000,000 worked hours) which was 21 in 2007, reduced to 16 in 2008, representing 24% reduction. On the other hand, Severity Rate (number of lost days per 1,000,000 worked hours) has been constantly increased over the three years period and reached 433 in 2008. In Bulgaria, for float glass operations, no LTI was reported for 2008 while the LTI frequency rate was 4.1 and severity rate was 104. The LTI Frequency Rate for overall operations at Sisecam’s Bulgaria site was reported as 7 in 2007 and reduced to 2.6 in 2008. Reduction has been recorded in Severity Rate as well in Bulgaria operations.
Sisecam Group has defined a number of measures to reduce accident rate particularly in Turkey where LTI frequency and severity rates are considerably higher than in other countries operations. Reduction of accident rate has been set as an important performance criterion. The Group will also develop networking between the plants located in different countries and ensure sharing best practices, learning experiences and consistent reporting. It will also be ensured that workplace monitoring and risk assessments are extended as necessary cover a number of risks as indicated in the attached action plan. Risk mitigation measures will focus on the implementation of engineering controls wherever applicable.
PS3 – Pollution Prevention and Abatement
Point Source Emissions to Air:
The most significant point source emissions to air arise from glass furnaces. All are fired by natural gas, which limits emissions of particulate matter and sulphur oxides. Particulate emissions range from around 50 to 140 mg/Nm3, generally meeting local requirements, although three furnaces do not yet meet IFC’s guideline value of 100 mg/Nm3. SOx emissions from these gas-fired furnaces are not of concern. NOx emissions from existing furnaces range from around 1,300 to 2,300 mg/Nm3, again generally compliant with local regulations but not with IFC’s guidelines.
Primary Systems for Air Emissions:
In a general program covering all its glass manufacturing operations, Sisecam is participating in an ongoing project on primary NOx abatement techniques, lead by TNO (Netherlands Organization for Applied Scientific Research) in which Sisecam is involved. The Project namely “Low NOx with primary measures” aims to study reduction possibilities of NOx emissions by controlling the furnace combustion conditions. Some short-term trial running studies have reduced NOx by 30-45 % through combustion control; however these results have yet to be replicated in long-term running, and the effect on glass quality is yet to be determined. Longer-term studies are planned to be started in May 2009. Benchmarking and modeling studies also continue in order to figure out which furnace design and which operating conditions can provide the lowest NOx emissions. Based on the primary techniques, Sisecam planned to implement a step by step reduction program for air emissions (NOx and particulate matter in priority) from existing plants. The initial target is to control NOx to less than 1,400 mg/Nm3 and particulate matter to less than 100 mg/Nm3 before the end of 2010 unless more stringent requirements are imposed by regulatory authorities earlier and/or the receiving capacity has decreased.
Secondary Systems for Air Emissions:
While the Bulgarian furnaces meet current air emissions requirements, the regulations that will apply from 2011 will be more stringent. It is also anticipated that Turkish Air Quality standards will become more stringent within the next few years. For these reasons, and to comply with IFC glass sector guidelines, the project includes secondary controls of particulate and NOx emissions to air, to be installed on a pilot basis to the Trakya and Pasabahce furnaces in Bulgaria and to the new Solar Glass line at Mersin. These secondary control projects will be the first of their kind within Sisecam and if successful will be replicated within the Group, though these further applications are outside the scope of this Project. The pollution control technology to be adopted is Selective Catalytic Reduction (SCR) of NOx, although treatment systems will include electrostatic precipitators and acid scrubbing ahead of the NOx destruction stage. Design emissions values to be obtained per the design of the secondary systems are 20mg/Nm³ and 500mg/Nm³ respectively for dust and NOx, which are representative of Best Practice performance.
In 1996 Sisecam experienced a disappointing outcome when trying to install secondary systems for particulate and SOx abatement in one of their plant, and has since adopted a pragmatic approach to new technology implementation. Therefore the first SCR system will be installed first in Bulgaria and be tested over a period of 6 month to monitor actual performance.
Ambient Considerations
As described above in the PS1 section, air dispersion has predicted that Sisecam’s operations will not cause ambient air quality to deteriorate to an unacceptable level, and ongoing studies has confirmed that ambient air quality remains well within local requirements. The Group plans to review the ambient air monitoring program including number and locations of monitoring points and sampling durations for each site and will provide IFC detailed information about this study.
Emissions to Water:
Wastewater from the various sites comprises, glass and cullet cooling water and sanitary wastewater. Most sites have installed a wastewater treatment plant to remove main pollutants and treat sanitary wastewater. Treated waste water is then discharged to a natural receiving body. Trakya aims to recycle effluents for use as process water to the maximum extent possible. No significant emissions of contaminated water are reported.
In Bulgaria Plant, domestic wastewater (from whole plant) and process wastewaters (generated from tableware production, mirror and processing lines) are treated in different specialized treatment plants and treated wastewaters are discharged into the receiving body near the Plant. Qualities of treated water streams satisfy the local discharge limits and IFC standards, except a recent inconsistency on COD and TSS parameters of treated process wastewater of tableware production line. Studies for advanced treatment are planned to be completed at the end of 2009.
As indicated in the attached plan, the wastewater monitoring program will be extended in all plants to cover all parameters within the IFC guidelines in addition to local requirements. It will be ensured that good practices (e.g. In Mersin, tertiary treatment of biological wastewater to control coliforms) are consistently implemented at all sites where treated effluent is discharge into the surface waters.
Solid Waste Management:
Sisecam strides for waste minimization i.e. to reduce the generation of waste at the source itself. After assessing reduction opportunities at the source, projects are undertaken to recycle solid waste generated by various processes within or outside the company.
Waste is reduced at source through: i) good housekeeping with periodic maintenance and inspection to decrease oil waste, ii) training of workers for awareness to reduce contaminated waste, iii) better glass making process control to reduce the rejected glass, iv) overall process development to increase plant efficiency and lower waste.
The reduction of solid waste is achieved mainly by the reuse of waste materials in the process (such cullet and dust collected from bag filters recycled in the glass melting). When this is not possible, waste is transferred to licensed companies for recycling or recovery. Waste oils are given to licensed companies for separation; and scrap materials or packaging wastes - paper, metal, plastic and wood - are sold for recycling. Finally end of life electronic equipment, batteries and accumulators are sold to licensed companies for reuse after proper separation.
Solid wastes which cannot be recycled, reused or recovered are stored temporarily on site for final disposal in accordance with local rules and regulations. Non-hazardous wastes are disposed off with local municipalities while hazardous wastes are transferred and disposed by licensed companies.
Dust recovered from the new ESP is targeted to be recycled to the batch. However, for reasons of insufficient consistency, glass furnace or batch conditions alternative disposal schemes may have to be used.
Hazardous Materials Management:
The raw materials used in float glass production process are mostly natural and non-hazardous. There are a few hazardous materials like diesel, lubricant oil and hydrogen gas used in some auxiliary processes. The common hazardous materials used in glass processing and auto glass production can be mentioned as printing paints, cutting liquids and lubricant oils. In addition to these materials, some solvents and chemicals are used in mirror production.
Regarding the hazardous materials management, there are procedures and instructions applied as a part of Environmental Management Systems at each plant. In that respect the basic principles to manage hazardous materials can be summarized as follows:
All materials including hazardous ones are supplied with MSDS. All necessary risk awareness signs and posters are available on respective containers.
Hazardous materials are stored in appropriate containers on pallets with a concrete slab and separate areas in the warehouse. They are handled and stored according to the handling and storage requirements mentioned in their MSDS.
Appropriate personal protection equipments like gloves, full face shield, goggles, and respirators are provided to the workers dealing with hazardous substances.
Local exhaust ventilation systems and isolated sections are used where volatile materials are used.
Sisecam reported that replacement of hazardous materials with less hazardous or non hazardous materials is always considered as an important issue where it is applicable within production process. Use of lead-free paints in printing is now a common practice. R&D studies under progress to producing copper and lead free mirror. Solvent free paints and chemicals are used wherever possible.
As indicated in the action plan, IFC will be provided with a detailed report of evaluation and feasibility studies for elimination or replacement of hazardous chemicals with non or less hazardous compounds and relevant working program at each site.
Resource efficiency / GHG Emissions:
Trakya Cam uses regenerative cross-fired furnaces. GHG emissions are minimized by the selection of natural gas as fuel, and by furnace design and control. Sisecam’s Furnace Development and Engineering Team continuously develops its furnace designs for energy efficiency and performance. New furnaces, and furnaces undergoing full cold repair, are amongst the most efficient in the industry according to intercompany and international benchmarks. IPPC BREF states that European float furnaces typically use 5.5 to 8 GJ/tonne of glass pulled in melting, and Trakya’s large float furnaces are operating towards the lower end of this range, although the smaller solar glass furnaces are less efficient due to the nature of highly oxidized glasses being melt. Cold repair will reduce the specific energy consumption of TR3 at Mersin by almost 20%.
Electricity consumption in the float glass lines is among the lowest seen by IFC in this industry. Sisecam’s extensive use of electronic variable speed drives for centrifugal fans and pumps contributes to this performance.
As is typical in this industry, all furnaces will melt internally generated cullet. In addition, the Lüleburgaz facility will use some external cullet arising from the auto glass manufacturing facility which is located in the same complex.
The Project includes for a waste heat recovery boiler to generate electricity through a steam turbine cycle, to be installed at Yenişehir factory. This initiative, which is expected to deliver some 4500 kW (net) is considered a pilot within Sisecam and will be replicated if successful.
At the conclusion of the project, annual GHG emissions are estimated at 1.2 million tonnes CO2 equivalent, for annual production of about 1.9 million tonnes of glass. This GHG estimate includes the effects of the cold repair and waste heat recovery projects.
In addition, at project conclusion, the two solar glass lines will support the manufacture of solar photovoltaic cells with rated capacity of around 1,200 MW. If this generation capacity is used in Northern Europe, annual CO2 emissions avoided through this 1200 MW of solar panels will be around 860,000 tonnes.
