Current operations at SSL Bosnia
The plant currently produces light soda, dense soda ash and refined sodium bicarbonate using the Solvay process. The current production capacity is 280,000 soda ash tpa.
The Company has presented information demonstrating it is aware of EHS issues associated with its current operation. In its production facility SSL will increase its focus on efficient use of raw materials, energy and water. SSL has presented plans to ensure that the implementation of Environmental Social Action Plan (ESAP), which had been agreed with the company for the first project, will be completed and that the new proposed project will, upon implementation of the few specific agreed measures identified during the appraisal, as specified in the attached Environmental Social Action Plan (ESAP), comply with host country’s environmental and social requirements, as well as IFC’s Environmental and Social Performance Standards and industry guidelines. The information about how these potential impacts are being/will be addressed by the project is summarized in the paragraphs that follow and in the enclosed ESAP.
PS1: Social and Environmental Assessment and Management Systems
Social and Environmental Assessment: The Environmental, Health and Safety (EHS) Assessment completed for the first investment identified several potentially negative EHS aspects, based on which a corrective action plan was developed (ESAP). During the last two years IFC has regularly supervised operations in SSL, implementation of the agreed ESAP and made suggestions for improvements. The Company has gradually improved its EHS performance as observed during the supervision visits and from the Company’s reporting. SSL has renewed its water permits and obtained new environmental permit for the period of 2 and 5 years, respectively. These permits outline what are the specific actions that SSL will have to implement in a given period(s) in order to satisfy requirements of the permits. SSL Bosnia is also subject to regular supplier audits covering EHS issues by its multinational clients with certified EHS management systems.
Social and Environmental Management System: The company started to implement an occupational health and safety management system in June 2009 and expects to obtain OHSAS 18001 certification of the system by the end of March, 2011. The current environmental management system (EMS) is defined as set of measures that SSL is required to implement which were outlined in SSL’s environmental permit.
Plans for developing a formal ISO 14001 certified EMS are yet to be developed. However, extensive lists of environmental monitoring and improvement actions are included in water permit and environmental permits provided by local regulators to SSL. These are currently forming an effective environmental management framework.
The refined sodium bicarbonate production has received Halal and Kosher certification while SSL is currently preparing procedures and expects to obtain HACCP-based food hygiene processes for the same production line in 2011.
Management Programs, Organization and Training: SSL has upgraded its EHS management structure which now counts 5 professionals in charge of different QEMS functions including Fire Safety unit.
Stakeholder Engagement, Monitoring and Reporting: SSL has recently activated its web site via which it reports on all major EHS development and social development activities including report on its production activities, ongoing investments in improving operational efficiency, and compliances with EHS legal requirements. Regular inspections, required as per Bosnian laws will ensure continued implementation of the EHS actions as defined in the permits.
PS2: Labor and Working Conditions
Human Resources Policy and Procedures: SSL’s Human Resources (HR) policy, procedures and manuals are based on the Bosnian Labor law, which is largely consistent with the requirements of IFC Performance Standard 2. The company HR policies define the rights and responsibilities of the employee and employer, including terms of employment and working conditions, grievance mechanisms, and promotion of non-discrimination and equal opportunity.
Working Conditions, Terms of Employment and Workers’ Organization: The current employment is 607 persons. SSL provides written contracts to staff and management interacts regularly with Union and staff on workplace issues. Around 460 workers in SSL are unionized and their working conditions and terms of employment are defined by internal regulations and agreement signed between the Union and the SSL management, which is based on a collective agreement that the National Chemical and Non-Metallic Industry Union has signed with Bosnian government. SSL provides salaries for blue colors workers which are within the industry average but below national average salary. The minimum age for employment by SSL workforce is 18 years.
Non-Discriminatory and Equal Opportunity: HR policy of SSL endorses principles of non-discrimination in hiring and uses well developed performance evaluation system as a feedback to management on workforce performance. In hiring new employees SSL uses transparent and competitive procedures through public announcements, newspaper and the internet, and interviews with the potential candidates. For high level position the hiring is conducted and facilitated by Sisecam management.
Retrenchment and Social Program:
In 2009 SSL retrenched 79 employees of which 25 had limited physical ability. The company reported that the retrenchment process was designed to meet the requirements of the Bosnian Labor Law Article 98, following criteria including age, qualification and health condition of selected workers, and investigating an opportunity for alternative employment with another employer. The retrenched workers received severance payments as required by the Bosnian Labor Law. The manner of the retrenchment and conditions and deadlines for payment of severance pay were established by a written agreement between Union and SSL in accordance with Article 100 item 4. of the Labor Law. In spite of that agreement a number of retrenched workers have filed claims seeking compensation or right for reemployment with SSL. The resolution for approximately 40 such court cases is pending.
In order to maintain compliance with country-specific regulations and to meet IFC labor requirements, SSL will prepare a written company Retrenchment Policy, compliant with Bosnian Labor Law and Performance Standard 2, and will develop Retrenchment Plans if significant retrenchment (i.e. of more than above 10 employees) is foreseen. Each Retrenchment Plan will provide details on, amongst other matters: a description of the anticipated magnitude of and justification for retrenchment, retrenchment method and procedures, including management arrangements at all levels to ensure open and timely communication to the employees, provision of grievance mechanisms, the legal framework including reference to IFC Performance Standard 2 and country labor regulations, anticipated social impacts involving both retrenched workers and their communities (including any remedial measures proposed), compensation and assistance to be offered to retrenched workers, the criteria for selecting those to be retrenched (e.g. qualifications and experience, health, years of service, number of dependents and work quality) and monitoring of the process. These plans will be based on the principle of non-discrimination and will reflect the Group’s prior consultation with employees, their Union and the relevant Government agencies, in a timely manner. The plans will also demonstrate in advance of further retrenchment that sufficient funds have been set aside to cater for the full costs involved.
Grievance Mechanism: SSL has disciplinary and grievance procedures as part of their HR framework, incorporating both verbal and written procedures. Complaints submitted by workers and Union are submitted to the HR unit. Complaints and corrective actions are discussed and settled within a reasonable timeframe. If the employees are not satisfied with decision they may initiate formal grievance proceedings through the Union and file a law suit in local court.
Occupational Health and Safety:
SSL has improved its OHSAS performance compared with that seen during an IFC visit in May 2009 and further improvements are expected to be achieved through on-going investments. The caustic soda plant where most frequent OHS incidents were reported has been closed, and this contributed to the overall improvements in OHS performance. As part of OHSAS certification process SSL has drafted OHS rule book, preformed an OHS assessment of each workplace and drafted OHS report for 2009, which includes an Emergency Preparedness and Response plan. OHS report which has been prepared by an authorized agency of Tuzla Canton has specified specific workplaces in the production process with different levels of risks. According to the report a higher risk workplaces have more stringent operational procedures to be followed and are to be paid more. SSL is requested to make the report available to all interested staff and to ensure that the recommendations from the report are implemented.
An authorized state agency has performed measurements on workforce exposures to different chemical pollution sources, including monitoring of heat, dust, noise and illumination/light intensity and testing of and providing certificates for different equipments, machines, vessels. A contract with Health Institute was signed for providing regular medical checkups at the first aid facility located on site and funds provided for treatment. During 2009 several SSL employees went for an on-site training in Sisecam soda ash factory in Mersin, Turkey. General housekeeping at the site has improved from the last visit, so did workers’ safety aspects mostly as a result of development of policies and procedures for formal OHSAS certification. Building structures are currently being consolidated. Until further engineering controls such as process dust containment are available to minimize workplace risks, the use of relevant personal protective equipment, including appropriate masks, goggles and gloves, will be enforced. SSL will install gas leakage detectors and alarm systems where hazardous gases (e.g. ammonia) are handled.
SSL has started to upgrade chemical storage tanks, with primary attention to ammonia, sodium hydroxide and hydrochloric acid storage and will ensure that all emergency safety measures such as safety showers are available at the storage areas.
PS3: Pollution Prevention and Abatement
Pollution Prevention, Resource Conservation and Energy Efficiency: During 2009 SSL implemented a number of projects that aimed at the expansion of capacity and modernization of the processes, including installation of cooling tower system which has resulted in reduction of industrial water use for 60 %, thus significantly reducing effluent discharge to surface waters. In addition construction of a new lime kiln was completed in March 2009, which resulted in lower emission of dust and in increase of thermal energy utilization. New stationary tanks of liquefied ammonia decreased consumption of water in the process. As part of the modernization of the plant SSL : (i) installed 2 new concrete tanks used for brine storage and reactor for treatment of brine, (ii) distillation system, (iii) process automation has been upgraded to 90% , (iv) modernization of packaging system was completed and (v) automation works of boilers are 90 % completed. The investment in the process control automation has resulted in a reduction of raw material input per tonne of soda ash produced. These investments have improved production process stability and decreased operation and power consumption costs and brought SSL production within the BAT (Best Available Technique) for the consumption of raw material per unit of product. SSL has set an ambitious plan for 2010 including new lime kiln, new carbonation column, installation new hydrant network, replacement of old transformer unit, installation of new water treatment units, improvements in raw bicarbonate filtration process, purchase of new refined soda bicarbonate centrifuge and a new drier and conveyor system.
As per local requirement SSL has commissioned a certified institution to conduct regular monitoring of effluents (Pa, Ma, pH, suspended solids, Cl-, Ca2+, Na+ , NH4+), ambient air conditions and air emission from boilers and to report to National regulatory agency. In addition, an independent authorized agency performs daily monitoring of surface water quality (Pa, Ma, pH, suspended solids, Cl- , NH4, hardness, oil) upstream (rivers Spreca and Lukavcic) and downstream (Spreca) from the effluent discharge points of SSL. However additional measures are necessary to bring SSL EHS performance in compliance with the Bosnian requirements that relate to effluent and emission levels and with the best industry practice as discussed below:
Air Emissions: Monitoring shows some non-compliances in respect of particulate emissions, particularly from limestone and coal unloading. Also point source emissions of particulate from boiler #7 currently exceed the allowable limits. Ongoing investment in modernization of ESPs on boilers 6 and 7 and the project for refined soda bicarbonate production and product and by-product conveyor transport systems are expected to resolve these issues. New bag filters have been installed at the plant for transport of soda ash, storage silos, dense soda and packaging plant, so that emission from these operations has been largely reduced. At the lime kilns and in the refined soda bicarbonate plant new wet scrubbers for washing of the exhaust gases have been installed so that the system now is a closed one. SSL reports emissions to IFC through annual environmental reporting.
Waste Management: SSL discharges untreated effluents (process waste water, cooling water, facilities sewage, plant run off, overflow from black and white sea) to the river Spreca. Neither pH nor suspended solids currently meet Bosnian or IFC requirements. SSL has obtained water permit and environmental permit for the ongoing operations and is required to develop an action plan that SSL will have to implement by the end of 2012 in order to be in compliance with the permit requirements.
As required by the water permit, all waste water streams will be separated i.e. run-off water will be collected and after being treated in oil/sand traps discharged off in Spreca river. As a priority, a separate treatment plant will be installed for sanitary waste water. All process waste water will be collected and ducted to a sump point at the location of “White Sea” where the plant for neutralization and settling pond for solid removal will be built. The pH value at the discharge point should be between 6 and 9. In order to achieve this value, a neutralization process with CO2 will be designed at the discharge of the waste water. CO2 gas obtained from the lime kilns, which is already in excess, will be used for neutralization. The gas will be fed to the neutralization column via the existing compressor. Approximately 2500 Nm3/h gas will be used in the process instead of emitting to the atmosphere. After the treatment system is put into operations it is believed that pH value and suspended solids in the waste water will be in accordance with the environmental norms. As a final result of absorption and neutralization process CaCO3 particles will be collected in the settling pond, and waste water discharged off to Spreca river will have TSS value below local max allowable limits. The Black Sea overflow which currently is collected in a separate basin will in future be collected in a pit and pumped into the White Sea. SSL regularly performs effluent quality analysis and posts the result on its web site.
SSL has improved the management of its solid waste (domestic refuse, hazardous and industrial waste, oil/grease, scrap and used equipment, PCB, asbestos tiles) and signed contracts with authorized agencies for final treatment and upgraded its waste storage area. A local environmental consultancy was hired to prepare “Waste Management Plan” in compliance with Environmental Protection Law and the "Solid Waste Inventory". Contract with licensed agency for management of hazardous waste was made according to which all such waste is collected and exported to an Austrian facility for final treatment.
White and Black (Sea) tailing ponds.
SSL is currently constructing additional berm on top of the existing White Sea pond so to have additional immediate capacity for approx 2 years of disposal. The Tuzla Geological Faculty is providing technical guidance in the construction of this dams expansion. One of the existing, already filled up, ponds of White sea will be emptied after a testing for use of the mud in road construction and mine areas recultivation are authorized. SSL has been negotiating with a cement factory to sell the flying ash and slag from the power plant operations. The size of unburnt coal particles in fly ash is the only unresolved issue which needs to be dealt with before the contract can be signed. SSL is working to improve the burning process and obtain marketable quality of fly ash, expected to be finalize by the end of this year.
Emergency Preparedness and Response: SSL will develop Emergency Response Plan, and implement system for Incident and Accident Reporting including personnel and responsibilities. SSL is committed to establishing and maintaining procedures to identify potential emergency situations, to respond to emergencies and to mitigate any resulting safety, health and environmental impacts. SSL has developed a Program on Fire Protection for the current 2010 year as requested by Bosnian Fire Code for this type of facility defining actions and responsibilities in case of fire outbreak, which historically have been happening on a limited scale in coal storage area. Fire risks, primarily at the storage and transfer areas will be further assessed and mitigation measures will be taken as necessary.
GHG Emissions: CO2 emission is produced from calcinations of limestone and is mainly used in soda ash production; part of produced CO2 is also used as an input material in production of refined sodium bicarbonate and the rest of CO2, in total in average of 0,2-0,3 tonnes of CO2 per tonne of soda ash, is vented in to the atmosphere.
According to this and as per annual production of 250,000 tones of soda CO2 emission from SSL operations is estimated at 65,000 tones of CO2.
Monitoring: Ambient air quality parameters measured are above maximum allowable IFC and Bosnian limits. SSL attributes this to the fact that in the vicinity there is cement plant and coke production plant, which contribute to the overall ambient air quality. SSL is requested to establish, in coordination with Tuzla Canton that is performing air quality measuring for the region, SSL’s contribution to the overall pollution, and accordingly to implement corrective actions. Also SSL will extend the existing air emissions monitoring program beyond just PM to include a wider range of environmental parameters such as SO2, NO2, CO, O3. In addition SSL will request its suppliers of raw material (coal/coke) to provide a certificate of the chemical analysis of the presence of heavy metals, particularly As.
PS4: Community Health, Safety and Security:
Faculty of Mining, Geology and Civil Engineering of Tuzla conducted a Study in January 2008 on tailing dams/ponds stability and concluded that the risk of the tailing dams collapse is minimal. The Study concluded that an addition of 17 meters on top of the existing dam is possible enabling disposal for the next 120 year without jeopardizing community’s safety. SSL will install monitoring wells to secure good settling efficiency through measuring piezometric water level, flowrates at the inlet and the outlet of the pond, remaining suspended solids of drained water.
Security personnel: Unarmed security personnel are employed through private security contractors. Security personnel are trained in the use of force for defensive purposes.
