The Sponsor has presented plans to ensure that the proposed project will, upon implementation of the specific agreed measures, comply with host country environmental and social requirements, as well as IFC’s Environmental and Social Performance Standards and industry specific guidelines. The information about how these potential impacts are being/will be addressed by the project is summarized in the paragraphs that follow.
The environmental and social risks associated with the proposed project, as described in the following sections, mainly relate to the assurance of appropriate implementation of already proven systems and technologies. The mitigation measures agreed with the Sponsor are therefore focused on four aspects: 1) continued strong implementation of Titan Group''s corporate Environmental & Social, Health & Safety, and Corporate Social Responsibility commitments at the facilities, 2) upgrade of specific units in need of improved performance to achieve full compliance with WBG EHS guidelines, 3) continued implementation of initiatives that will reduce specific CO2 emissions, and 4) implementation of corrective measures to counter improper, legacy related (pre-Titan Group ownership) quarry utilization hereby ensuring full utilization of raw materials while creating appropriate benching of the quarries to allow for appropriate rehabilitation. The compliance related mitigation measures are included in the Environmental and Social Action Plan (ESAP).
PS1: Social and Environmental Assessment and Management System
Titan Group is a cement producer operating in 9 countries and is highly committed to sustainable operations. Therefore it is a member of, or actively participates in, the following sustainability forums; the World Business Council for Sustainable Development (WBCSD), the Cement Sustainability Initiative (CSI), United Nations Global Compact, Global Reporting Initiative (GRI), CSR Europe (the European business network for Corporate Social Responsibility), and a number of sector specific organizations for the application of best available technologies (BAT) for production procedures and distribution methods. At Titan Group headquarter in Greece, the company has set up an organization that provides both technical and organizational support and training for its regional operations. Based on this central support the Serbian, Kosovo and FYROM operations of Titan Group have locally developed management teams with individuals having specific responsibility for each of these aspects. As a result the Serbian and FYROM operations are both ISO 14,001 and OHSAS 18,001 certified, and are publishing monthly environmental performance results as well as the local CSR reports on their local web-portals, while the Kosovo facility (Titan ownership since 2011) is in the process of achieving the same certifications with the ISO 14,001 process started in 2012 and all certifications and CSR reporting are to be active within 36 months of IFC participation.
General portals:
Usje:
http://www.usje.com.mkSharr:
http://www.sharrcem.com/Kosjeric:
http://www.titan.rsEnvironmental reports:
Usje:
http://www.usje.com.mk/opstestvena_odgovornost_1_en.html?mid=68&Lan=ENKosjeric:
http://www.titan.rs/home/page/28/EnvironmentHealth and safety reports:
Usje:
http://www.usje.com.mk/opstestvena_odgovornost_4_en.html?mid=87&Lan=ENKosjeric:
http://www.titan.rs/home/page/13/Occupational-Health-and-SafetyCSR reports:
Usje:
http://www.usje.com.mk/Default5f9d.html?mid=76&Lan=ENKosjeric::
http://www.titan.rs/public/fck_files/file/TCK%20CSR&S%20Report%202010%20eng.pdfThe management systems implemented under the above initiatives were evaluated during the appraisals of the individual facilities, and it was found that the information flow and principles applied ensured full compliance with the IFC Performance Standards not least with respect to the quality of data collected, assurance of management information and the management teams’ commitments to transparency. The current operations are in compliance with local requirements, and the proposed upgrades are to further improve the plants performance with respect to lowering of emissions (to meet expected future requirements), compliance with IFC guidelines and energy savings to improve competitiveness. None of the process upgrades will reach outside the current facilities and will undergo normal documentation requirements and approvals related to internal industrial upgrades. Any further developments of the quarry operations that require additional land take will require public authority approval, and public consultations according to local planning requirements and the Titan Group is preparing these documents for public submission and approval as the project proposals develop. The Usje and Kosjeric plants were among the first industrial operators in their respectively countries to apply for and obtain operating permits according to the IPPC license systems, as well as the first to issue CSR report (Kosjeric is the only industrial facility in Serbia which has been granted IPPC license so far).
With respect to stakeholder engagement Titan Danube is actively pursuing local engagement, and over the past year this has included the following specific activities: At Kosjeric in Serbia two multi-stakeholder meetings were held in 2011 (February and October), as well as a "thematic" stakeholder meeting in June on the potential use of alternative fuels. As an outcome of the October meeting a local stakeholder Advisory Panel and Board was formulated to create a formalized way of stakeholder communication and rising of issues of concerns. The Usje plant had its first multi-stakeholder meeting in December 2010, where written suggestions were encouraged. The Usje management is now looking into the recent (2 months experience at the time of the IFC appraisal) Advisory Panel experience in Kosjeric and is evaluating how to create a similar system for Usje adjusted for the location differences (capital versus village). The Sharr operation only recently came under Titan Group operational control and has since then carried out the first open stakeholders meeting, has become the local founder of the Kosovo Corporate Social Responsibility Network, and has undertaken initiatives similar to those in Usje and Kosjeric. Besides this all operations have suggestion boxes where named or anonymously issues can be raised, with a promise to react / answer as appropriate.
PS2: Labor and Working Conditions
Usje, Sharr and Kosjeric employ about 325, 460 and 324 people respectively.
All Titan Group operations have their own HR managers who ensure the application of HR Policies compliant with Titan Group corporate principles and local legislation. Both Titan’s corporate HR principles and the local legislations are individually consistent with IFC''s PS2. Therefore the Usje, Sharr and Kosjeric HR Policies, in a manner consistent with the IFC PS2, define 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.
When Titan took over the Usje and Kosjeric plants the health & safety performances of the two plants were far from ideal, with Lost Day Accidents / Million Man Hour (LDA/MMH) of above 10. Immediately after the takeover, Titan Group improved the physical conditions at the plants. An example of the improvements is that all bagging of cement is carried out by automatic rotor-packers equipped with automatic bag feeders and feeding directly to automatic palletizers. These initiatives combined with organizational changes improved the general safety at the plant and the LDA/MMH fell with approximately 50%. The Sharr facility was taken over in the middle of this process, and had already been improved by the previous operator to levels similar to the Usje and Kosjeric health & safety performance. Thereafter, Titan Group hired DuPont to help improve the safety culture and organization at both plants. As a result the Usje and Kosjeric plants now have OHSAS 18,001 certified management systems and the accident frequencies for all three plants have for the last 2 years been reduced to the range of 1-3 LDA/ MMH which is a level consistent with good practice in the sector.
PS3: Pollution Prevention and Abatement
Overview
The Usje and Kosjeric plants are both Polysius designed dry process plants with 4 stage pre-heaters, but without pre-calciners, while the Sharr plant differs with the pre-heater system consisting of hybrid preheater shaft and cyclone, 2-stages, 2-strings. This means that the plants have relatively good energy efficiencies, although not able to reach the levels of a modern plant with 5 stage pre-heater and pre-calciner. The quarry operations are carried out with a mix of blasting and ripping operations, depending on hardness of materials to be extracted. This is followed by crushing and subsequent transport to enclosed stacker and re-claimer storage areas. Raw material/fuels and cement mills are based on ball and vertical mill technology and are equipped with bag filters for control of emissions.
Emissions to Air
The Usje and Kosjeric cement kilns themselves are also equipped with a combination of Electro Static Precipitators (ESP) and bag filters and operate with very low (typically below 5 mg/Nm3) particulate emissions, while the WBG EHS guideline value is 30 mg/Nm3, and the local limit is 50 mg/Nm3. The Sharr facility is in the process of upgrade to similar technology and performance during 2012. Cement handling after final milling is either by automatic bagging and stacking in modern units with good control for particulate emissions or by bulk transport to end users. SO2 emissions are also low (Usje and Sharr around 100-200 mg/Nm3 and Kosjeric below 1 mg/Nm3), with both WBG EHS guidelines and local limits being 400 mg/Nm3.
Both plants rely on optimization of combustion conditions for NOx emissions control, and neither has any secondary NOx controls. The WBG EHS guideline value for cement industry NOx emissions is 600 mg/Nm3, while local requirements are 1300 mg/Nm3. For the Usje plant the typical emissions have been in order of 800-1100 mg NOx/Nm3, and this means that the plant needs to be equipped with SNCR reduction for NOx. For the Kosjeric plant the NOx emissions have been in the range of 400-900 mg/Nm3 during 2011, with 14 out of 19 monitoring periods being below 600 mg/Nm3, accordingly it should be possible to stabilize the Kosjeric operations within the WBG guideline limits.
The Sharr plant has for the last years operated with NOx emissions of 500-600 mg/Nm3, and these are now subject to confirmation by new continuous monitoring equipment to be installed during 2012.
The Titan Group is closely monitoring all trace elements including mercury (Hg), as per EU Directive, to ensure acceptable air emissions. This takes place at all operations including those outside the EU, which do not have these legislative requirements. In addition the Titan Group has initiated a survey in all quarries starting from Serbia and FYROM for mapping of Hg to allow for source control and potentially phasing out at source. Spot stack monitoring data from Usje has for 2008-2011 all been below 0.01 mg/Nm3, while Kosjeric has had emissions varying in the range of 0.02-0.09 mg/Nm3 with the pyrite additive being the main Hg source at the Kosjeric plant.. The WBG EHS guideline value is 0.05 mg Hg/Nm3 and this additive will therefore need to be tightly controlled or replaced to maintain full compliance with the guidelines. Surveys of Sharr quarries are in progress.
Energy Efficiency and GHG emissions
The Titan Group has been actively and successfully pursuing the introduction of blended cement in the FYROM, Kosovo and Serbian markets and did in 2010 achieve a 0.702 clinker to cement ratio.
Based on the CSI calculation tools for CO2 emissions the three plants had a combined direct (part 1) and indirect (part 2 - caused by electricity consumption) CO2 emission of 1,280,865 tons in 2010. With a production of 1,905,092 tons of cement in the same period the average CO2 emission per tons of cement produced was 672 kg per ton according to the CSI calculation principles with electricity cause emission added.
Titan Group expects to be able to reduce the specific CO2 emission per ton of cement further by reducing the clinker to cement ratio to 0.66, and upgrading the plants with improved cooler, energy and heat recovery efficiency over the next years.
Wastewater:
All the cement manufacturing facilities are using the dry process, which means that the consumption of water is at low levels, while some equipment needs cooling water. The most important wastewater source is domestic wastewater arising from the employee needs. In Kosjeric plant this wastewater is receiving full mechanical and biological treatment before being discharged, while Usje and Sharr plants are directly connected to the municipal sewage network.
PS4: Community Health, Safety and Security
The Usje cement plant is located within the greater Skopje city area and is therefore surrounded by a number of residential areas. At the same time the main quarry operation is located within the site and no external transport is therefore needed for the raw materials, although the fuel is imported.
Impacts for the neighbors of the Usje plant relate to air emissions, for which the controls are described in the previous section, quarry extraction operations, and internal transport and processing (crushing) between the quarry and the cement plant. The neighboring communities have also had impacts on the Usje plant as some of residential areas in the past tended to drop garbage over the fence at the Usje site. By active intervention by Usje, the residential areas with garbage removal problems in the past are now having scheduled garbage collection and the problem of garbage dumping has been minimized. Usje has also changed operational practice at the quarry, where large scale excavators and dump trucks have been replaced with modern loaders and normal road trucks to bring noise levels down. Further an intensive greenery program has created significant wooded areas and border belts, which, together with road maintenance limit fugitive dust emissions in and from the quarry area. The crusher, which is located close to the perimeter has been equipped with noise walls, to limit the noise going towards a new high residential complex, and from there the raw materials are transported on covered and controlled conveyor systems. The main entrance of the plant, from where import of fuel and dispatching of cement takes place is located towards one on the city''s main roads and heavy vehicle traffic is therefore not entering through residential roads. With Usje not having large storage of oil or gas, and with operations being brought in compliance with European norms the plant does not carry any specific security risks for the surrounding communities.
The Sharr plant is located just north of the FYROM / Kosovo border on the main road from Skopje to Pristina. There is a minor village in the area, but due to the plant’s location directly on the main road the local interference is relatively low with respect to health, safety and security.
The Kosjeric plant is located in a valley in a remote area leading North-West out of the small village of Kosjeric towards Bosnia. The plant and its operations have, although close to Kosjeric, a separation from the village and therefore minimal interference with respect to health, safety and security.
PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
Based on the Usje, Sharr and Kosjeric quarry approval processes these plants are both located without sensitive and endangered flora and/or fauna species on or around their sites or quarry areas. Biodiversity conservation is therefore not of relevance for this project. The three plants on the other hand have several active and prospective quarry operations. These quarries were acquired as part of the general cement plant acquisition, and were during the pre-Titan Group ownership operated without appropriate quarry management plans to ensure full utilization of the raw materials, without appropriate benching at the quarrying limits and without appropriate rehabilitation planning and execution. Titan Group has since the takeover worked on correcting this situation and has for some of the quarries managed to establish new perimeters from where they work inwards while doing appropriate benching and rehabilitation with top soil application and planting. Currently the individual plants are revising all their quarry plans to ensure they have the needed long term reserves, and to ensure any extra land needs can be covered under satisfactory willing seller / willing buyer terms. Based on these principles the Kosjeric plant has recently applied for a new limestone quarry concession adjacent to the current reserves. This new concession is planned to be developed with new BAT techniques with a mobile crusher located at the active phase of the quarry and feeding through a shaft and tunnel in the mountain to a belt conveyor at end level. This principle will allow for appropriate operations and quick start of quarry rehabilitation. IFC and Titan have agreed that all quarries will undergo preventive planning (where not already carried out) to ensure appropriate reserves, the optimal utilization of these reserves, while ensuring the needed rehabilitation.
