NPC has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements and regulations of Egypt and the IFC Performance Standards on Social and Environment Sustainability and relevant IFC/World Bank environmental, health and safety guidelines. The information about how these potential impacts will be addressed is summarized in the paragraphs that follow. Actions are summarized in the attached Environmental and Social Action Plan (ESAP).
Social and Environmental Assessment and Management Systems:
Under the requirements of the 1994 Egyptian Environmental Law (Law 4/1994), sponsors of new or expansion projects are required to conduct an Environmental Impact Assessment (EIA) or complete Screening Forms (A/B), and to submit the required document to the Competent Administrative Authority and Egyptian Environmental Affairs Agency (EEAA) for clearance. Because both the El Baddar and one of the El Shorouk plants in Obour were constructed prior to passage of law 4/1994, no environmental clearances were required. NPC has provided copies of the environmental clearance for its expansion facility in Obour and Windsor plants. In compliance with national requirements, an EIA will be prepared for the new duplex board plant in Sadat city. The EIA will be carried out by a qualified consultant team against the requirements of both host country regulations as well as IFC’s PSs. NPC has committed to implementing the EIA recommendations in full. Copies of subsequent EEAA clearance and permits will be provided to IFC, as outlined in the attached Environmental and Social Action Plan (ESAP). The El Shorouk and El Baddar Plants, as per national legal requirements, currently maintain Environmental Registers with laboratory analysis reports of air emissions, water effluent quality, working environment and noise levels. NPC will continue to maintain Environmental Registers for all of its current operations and for the expansion project.
EL Shorouk Printing is ISO 9001 (Quality) certified. El Shorouk has a food packaging line under its Windsor subsidiary company that is Hazard Analysis and Critical Control Point (HACCP) certified. The El Baddar facility is in the process of developing a quality system with the advisory assistance of Egypt’s Industrial Modernisation Centre (IMC). El Shorouk has an environmental and safety policy. At the corporate level, there is currently no integrated environmental social, and health, safety (ESHS) management system. NPC has agreed to develop an ESHS management system to cover all of its operations and ensure compliance with environmental, social and health and safety requirements of host country regulations and IFC’s PSs. In accordance with the timeline specified in the attached ESAP, NCP has agreed to obtain ISO 14001 certification for its ESHS management system.
EL Baddar has an emergency response plan and the other facilities have emergency evacuation plans. As part of the integrated ESHS management system, NPC will incorporate a comprehensive corporate crisis management plan, including plans for crisis management, life and fire safety, emergency response, and staff health and safety. As noted above, El Baddar and El Shorouk have separate safety policies; however, organizational capacity to implement the policies is not integrated on the corporate level. NPC has agreed to appoint a corporate ESHS manager that will ensure implementation of the integrated ESHS management system in all its operations. In addition, NPC will designate ESHS coordinators at each of its operating plants, within an agreed timeframe.
Labor and Working Conditions:
At present, NPC’s full time employees number approximately 1600, working on two 12 hours shifts for 6 days a week. Third parties provide cleaning staff and security guards, and seasonal staff amount to approximately 70 workers. NPC has confirmed that it complies with all host country labor laws. El Shorouk has in place an HR system that conforms with host country laws, while El Baddar has initiated a Human Resources (HR) study, undertaken by an external consultant, to develop a comprehensive HR system. NPC has agreed to establish a comprehensive corporate Human Resources (HR) policy, approved by the Board of Directors, that covers all of its operations in all subsidiaries within a timeframe agreed with IFC. NPC will prepare an HR Manual, review policies and procedures, including a formalized employee grievance mechanism that conforms fully to PS2 requirements.
Currently, all newly-hired employees undergo a probation period of three months. Employee benefits include governmental social insurance for all staff. Current HR policies require induction training for all employees.
As noted, NPC’s SHSE manual will cover all aspects of workplace health and safety at all operations. NPC agreed that, for the construction of the new project in Sadat City, all contractor contracts will include the requirements IFC EHS guidelines. NPC will monitor construction regularly to ensure that all construction contractors and subcontractors adhere to these guidelines; failure to do so will be grounds for contract termination.
Raw materials (bulk paper and cardboard rolls) of 30,000 tons are sourced primarily from Europe, the Americas and Indonesia. As noted, approximately 25-30% of raw materials for the greenfield Uniboard plant will come from recycled paper sourced from local vendors. In Egypt, waste collection and segregation is handled primarily by informal sector garbage collectors (zabaleen), many of whom employ their children to help in what is largely a family-based means of livelihood generation. NPC intends to establish its own supply chain, working with collectives and non-governmental organizations (NGOs) to establish a monitoring mechanism to ensure that any child labor involved in the supply chain is not harmful. Moreover, in situations where education for zabaleen children is not available, NPC will engage with NGOs and other partners to provide a schooling alternative for these children. IFC is in discussions with NPC about providing Advisory Services support to assist in this program, which would have an important demonstration effect in Egypt.
PS 3: Pollution Prevention and Abatement:
All of NPC’s existing printing plants are located in industrial urban or peri-urban areas where basic infrastructure and utilities (electricity, water supply, sewerage systems, and solid waste collection) are supplied by relevant municipalities. El Shorouk’s power consumption of approximately 4MW is sourced primarily from the grid, in addition to a steam boiler with capacity of 12 tons/hr and an oil boiler of 350 KW. A 100KW standby diesel generator is available onsite. El Shorouk uses split units for air conditioning with total capacity of 591 kW. The average energy consumption per ton of product for Shorouk is 320 kWH/ton. El Baddar’s power consumption is 1.5MW, and the plant is equipped with 3 boilers, with a total capacity of 8 ton/hr. Annual diesel consumption is approximately 240 tons, heavy fuel oil 2400 tons, and water is 36000 m3. The El Baddar plant initiated an energy audit in January 2009 in collaboration with Egyptian IMC to identify potential power saving opportunities. The study identified several opportunities for saving power consumption and reducing total GHG emissions by approximately 500 tons of CO2 equivalent annually. NPC has agreed to initiate a process to implement the recommendations of the study and conduct similar energy audits in the other facilities. IFC has initiated discussions with NPC about supporting these audits across the entire group through the IFC Cleaner Production program.
Water is provided to all of NPC’s pants by the relevant municipalities. Annual water consumption at the El Shorouk plants is approximately 34,000 m3. Water is stored in 300 m3 underground storage tanks. As El Shorouk is only a printing operation, the municipality has given NPS approval to discharge untreated waste water directly to the municipal sewerage system. An examination of El Shorouk’s environmental register indicates compliance with national standards.
The environmental register for El Baddar indicated that wastewater does not presently meet national effluent standards for a few parameters, including Biochemical Oxygen Demand (BOD), Chemical Oxygen Demand (COD), and some heavy metals. NPC is in the process of obtaining design specifications and bids for a wastewater treatment plant. The Company will ensure that the new plant is designed to ensure compliance with IFC’s EHS guidelines, as well as national standards, and is commissioned in accordance with a timeframe agreed with IFC.
Air emissions from boilers are monitored regularly, and data provided in the environmental register indicates compliance with national requirements. The working environment in El Shorouk was also tested for ambient heat, particulates and volatile organic compounds (VOCs). All workplace air quality data for El Shorouk was found to be in compliance with national requirements.
For the El Baddar plant, testing and analysis of workplace air quality indicate levels of particulates and acid in some areas of the plant that exceed national requirements. In addition, noise levels in some parts of the plant exceeded national standards, and lighting intensity did not meet good industry practice. As part of the environmental audit noted above, an audit of the working environment will be undertaken by a qualified consultant and corrective actions implemented accordingly, within a timeframe indicated in the ESAP. To address this situation, NPC has agreed to (1) conduct an environmental audit to identify potential sources of non-compliance to effluent parameters and develop an action plan for non compliant parameters in air emissions and wastewater discharge to be acceptable to IFC to ensure compliance with EHS guidelines; (2) implement the audit recommendations for remedial actions within a time frame agreed with IFC; and (3) monitor and annually report on air emissions and wastewater discharge at each facility to ensure that these comply with local requirements and IFC EHS Guidelines.
El Shorouk commissioned Pöyry Industry, a well-known Finnish company with considerable experience in the pulp and paper sector, to prepare a pre-engineering study for the new Uniboard plant. The design indicates power consumption of 0.5-0.6 MWh/ton of product and heat or steam consumption of around 7.5 GJ/ton. These figures are consistent with good industry practice for specific energy use. Average water consumption is expected to be approximately 10 m3/ton, including process and cooling waters. These volumes are consistent with good industry practice, as well as with the Integrated Pollution Prevention and Control (IPPC) Reference Document on Best Available Techniques in the Pulp and Paper Industry. The design of Uniboard plant indicates that it will be equipped with a wastewater treatment facility that will meet European Union effluent standards, which are consistent with both host country and IFC EHS guidelines.
NPC’s printing operations use relatively few hazardous materials, including cleaning fluids and diesel fuel. The company confirmed that relevant Material Safety Data Sheets (MSDSs) are made available to employees working with and in proximity to toxic and/or flammable materials. As part of its ESHS system, NPC has agreed to consolidate MSDSs into a Standard Operating Procedures (SOPs) manual that addresses employee occupational health and Safety (OHS) procedures and safeguards. Appropriate Personal Protection Equipment (PPE) will be distributed accordingly, and the use of PPE will be strictly enforced.
The plants raw material include about 2-3000 tpa of imported paper, 15,000 tpa corrugated heavy cartons, 10,000 tpa brown carton, 2500 tpa quality paper and 2-3000 tpa treated polyethylene bags. Waste fraction of all of these materials averages 2.5-3% and is currently sold.
Community Health, Safety and Security:
As noted above, NPC has agreed to put in place a disaster response plan for earthquakes, fires and other large scale emergency situations. Details of these plans will be communicated to any communities located in close proximity to the plants.
