While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

All the Bulmarket owned fuel storage terminals are either new or upgraded recently according to current Bulgarian regulations. All liquid fuel storage tanks in both terminals and filling stations have secondary containment. Bulmarket assesses the potential for soil/groundwater contamination prior to acquisition to ensure there is no soil/groundwater contamination. Bulmarket has established environmental, health and safety (EHS) procedures for operations, which aims to meet European Union (EU) requirements, and the transportation business follows the EU requirements. The mitigation measures for the potential E&S impacts and risks have been identified and are incorporated into the project Environmental and Social Action Plan (ESAP).

The potential adverse E&S impacts of this project are few in number, limited to project sites and may be readily mitigated. This is therefore an E&S Category B project.



The key E&S risks and issues include the following:

- Occupational health and safety
- Operational hazards, fire prevention, and emergency response
- Road transportation and community safety

Where expansions occur, these are generally within existing properties and if land is acquired, Bulmarket only purchases existing industry assets. No natural protected areas or protected species are identified at, or near, the Project sites and thus Performance Standard (PS) 5: Land Acquisition and Involuntary Resettlement and PS 6: Biodiversity Conservation and Sustainable Management of Living Resources are not applicable. Indigenous Peoples were not identified in areas associated with the Project, or other company operations, and no issues related to cultural heritage were equally identified in the project area; thus PS7: Indigenous Peoples and PS8: Cultural Heritage are not applicable.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Corporate Environmental and Social Policy: Bulmarket is developing its corporate environmental and social (E&S) policy thereby aligning with the general corporate social responsibility trend in EU countries and so as to demonstrate its commitment to environmental and social management and support sustainable development. As required in the ESAP, Bulmarket will develop an E&S policy to improve its corporate E&S management. The new corporate E&S policy will also be covered during the new employee orientation and induction program. The existing five terminals at Bulmarket are certified by both ISO 14001 and OHSAS 18001, environmental and occupational health and safety management systems respectively.



Identification of Risks and Impacts: In accordance with the company E&S procedure, Bulmarket screens the environmental and social risks for industry sites of terminals and fuel filling stations. For sites that may be contaminated, Bulmarket conducts a site investigation prior to purchase. If soil/groundwater contamination is identified, Bulmarket undertakes more detailed analysis to confirm if the contamination can be remediated or not. In the event of the latter, the company does not purchase the site.



For all the new developments including construction of new LPG/LNG terminals or renovation of existing LPG terminals, the company undertakes a detailed E&S Impact Assessment (ESIA) following EU standards and the assessment is registered according to Bulgarian Law as part of the Environmental Impact Assessment procedures. The company also undergoes annual inspections by local regulatory agencies for operation safety and environmental controls. Bulmarket’s operations meet all the regulatory requirements of these authorities. In accordance with ESAP, Bulmarket will also contract external experts to conduct annual EHS audits with the focus on operational safety.



Corporate Environmental and Social Management and Organization: Bulmarket has a corporate environmental and occupational health and safety (EHS) unit under the HR manager. The EHS head reports to both the HR manager and General Manager. Each of the fuel terminals has an EHS engineer in charge of environmental and OHS issues who reports directly to terminal manager and corporate EHS unit head. Bulmarket has well established environmental and OHS management programs and operational procedures which are aligned with ISO 14001 and OHSAS 18001 for terminal and filling station operations. The implementation of these programs/procedures are supervised and enforced by the EHS unit. There are intensive EHS trainings at Bulmarket, which include induction training and annual refreshers. The annual refresher training consists of 12 hour classes provided by both internal and external trainers. As indicated in the ESAP, Bulmarket will set up an independent EHS department with qualified EHS engineers and reporting line directly to the General Manager.



Emergency Preparedness and Response: Bulm
arket has a fire prevention and emergency response (ER) plan which applies to all facilities. There is firefighting equipment, including fire water storage tanks, water cooling and the water/foam fire extinguishing systems at all Bulmarket terminals. The fire trucks from local fire departments can reach the respective Bulmarket sites within 10 to 20 minutes. There are internal fire safety trainings followed by emergency response (ER) drills each quarter at all terminals. Besides, Bulmarket holds annual joint fire prevention and ER drills with local fire brigades, hospitals, and polices. All terminals are equipped with heat detector and automatic fire alarm systems for early emergency detection, which are maintained monthly. In addition, key terminals are equipped with video surveillance systems for monitoring.



Monitoring and Review: Each operation unit head gives daily EHS briefings before work. The operation unit heads also report daily to the corporate EHS head before the end of a work shift. The EHS head has weekly meeting with the general manager to brief them on EHS issues. The corporate EHS unit conducts quarterly EHS inspections for all operations with written reports to the General Manager. For non-compliances or any other EHS issues identified during quarterly inspection, a corrective action is proposed and recorded and the implementation is reviewed in the future inspection. As part of this project, annual external EHS audits will also be implemented. The EHS unit also coordinates the environmental monitoring for workplace air quality/noise levels and wastewater discharge qualities

Corporate Human Resources Policy and Management: Bulmarket has a corporate human resources (HR) policy that specifies the terms of employment and working conditions. These include procedures related to recruitment, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and firing, vacation, other leave, and retirement. The company has HR policy training that is part of the new employee induction, and all employees have access to this policy through the corporate intranet. Bulmarket is committed to compliances with IFC Performance Standard 2 (PS2) for labor requirements and will also require any construction contractors to comply with IFC PS2.



Working Conditions: All workers are on Bulmarket’s payroll as term employees and there is no temporary labor. Under the employment terms that strictly follow the national labor law, workers are employed on fixed term contracts which are renewable subject to satisfactory performance and availability of work. Overtime work is uncommon and is usually only associated with emergencies. Staff receives time-off or cash compensation in lieu of any overtime work at rates regulated by the national labor authority. Overtime work during weekends and holidays is compensated on the basis of 1.5 to 2 times of base salary. The average salary at Bulmarket is the same or slightly higher than the average salary of similar industries in the regions. All employees have access to the insurance and pension funds as required by labor law.



Workers’ Organization: There is no independent labor union at Bulmarket. The management has no restriction on labor union and allows collective bargaining. There is a labor condition committee at Bulmarket, which consists of 10 elected members from the employee assembly and 10 appointed members by management. The committee reviews work conditions, compensation and benefits periodically and reports to management for suggestions.



Non-Discrimination and Equal Opportunity: The HR policy specifies non-discrimination and equal opportunity. No procedures and/or practices have been identified as discriminatory. All hiring and promotions are merit-based. When candidates have equal qualifications, preferences of hiring are given to local residents. Currently approximately only 10% of employees are female. As indicated in the ESAP, Bulmarket will draft a promotion program to hire more female employees in the Project.



Retrenchment: There is no retrenchment planned for this project. Currently there are approximately 450 employees at Bulmarket. The company will hire approximately 55 new employees for the expansion project. An undetermined number of employees will be hired for construction through contractors.



Grievance Mechanism: The grievance mechanism is introduced during the new employee induction. The employees can report their grievances to either HR manager or the labor condition committee. All the grievances and the mitigations ar
e recorded. The HR manager/labor condition committee shall report to the senior management if they could not solve the grievance. HR email address and suggestion box are available for anonymous grievances.



Protecting the Work Force Bulmarket complies with national law and does not hire workers below the age of 18 years. HR checks birth and school certificates during the hiring process. No forced labor practices are used by Bulmarket.



Occupational Health and Safety (OHS): Bulmarket has routine OHS training, including new employee training and annual refreshers. All employees have to pass exams at inductions and annual refreshers to be able to work at the plants. There have been no fatal or serious accidents in the past ten years. As indicated in the ESAP, Bulmarket will record all accidents and manage the OHS risks by statistical incidences. Job hazard analysis (JHA) is used to evaluate all critical positions, and the JHA results are used to improve OHS management. There is sufficient personal protective equipment (PPE) at each position and employees all wear proper PPE. Workplace air quality and noise levels at major terminals meet both local regulatory requirements and good international industry practices (GIIP). As part of the Project, workplace air quality and noise levels will be monitored at all existing and new terminals. The company has comprehensive OHS procedures including PPE rules and that related to hazardous material handling, height protection, confined spaces, etc. As part of the Project, OHS procedures for LNG will also be developed and implemented. As required in the ESAP, Bulmarket will also record all accidents and manage the OHS risks by statistical incidences. Bulmarket will also require its construction contractors to follow applicable OHS requirements stated in IFC PS2.

Raw Material and Resource Efficiency: The company activities focus on LPG/LNG storage and wholesale of such. There are no manufacturing processes and thus resource consumption is limited. The main resource consumption is related to water (3,200 t/y) primarily for sanitary use and electricity (12,515 MWh/y) for LNG refrigeration, CNG compression, pumping, heating, air conditioning, and lighting, and diesel fuel (1,300 t/y) for fuel/cargo transportation. Water at sites is supplied by onsite wells or municipal supply. Electricity is supplied from the national grid. The energy efficiency for the planned LNG transportation meets the benchmark of World Bank Group (WBG) EHS Guidelines.



Effluent and Emission Compliances: For most of the terminal and fuel filling stations, there are septic tanks into which all sewerage is discharged and there is no vehicle washing at any filling stations. The potentially contaminated water from the paved/covered areas is collected for offsite disposal. There is an onsite wastewater treatment plant (WWTP) for the Bulmarket port and main site. The effluents meet both local regulatory requirements and WBG EHS Guideline limits, with the exception of COD and total nitrogen, which slightly exceed WBG EHS Guideline limits. As part of the expansion project, Bulmarket will improve the WWTP efficiency to ensure compliance with WBG EHS Guideline limits. There is no point source emission at any terminal. The fugitive emissions are not significant and the workplace/ambient air quality meet GIIP and local requirements.



Fuel Management: All above-ground tanks for LPG and diesel fuel have secondary containment, which were renovated in the past few years to meet current Bulgarian standards. All the underground tanks and pipes are constructed according to EU standards with double steel layers and a leak detection system. All the storage tanks are inspected daily by employees. All the valves, connections, and electric groundings are checked annually by external experts. The tank integrity is also checked by external experts: LPG/CNG tanks every three year and diesel tanks every five years. The heavy hydrocarbons accumulated at the LPG tank bottoms are taken out during the integrity check, and sent to licensed hazardous waste companies for disposal. All the loading and unloading are automatically controlled. The vaporized LPG during loading and unloading processes is compressed/liquefied and piped back to the tanks. The vaporized LNG during loading/unloading from the future main storage terminal at the Ruse Port will be transferred to the boiler onsite as fuel; the vaporized LNG from other terminals will be transferred to the onsite natural gas system to be compressed as CNG. These fuel management practices meet the WBG EHS Guidelines in general.



As required in the ESAP, Bulmarket will contract external experts to conduct a qualitative risk assessment (QRA) for the LNG storage tank at the proposed terminals. If high valued objec
ts are located within the exclusive zone calculated from QRA modelling, Bulmarket will build blast-proof walls to ensure the safety of the high valued objects.



Wastes and Historical Contamination: Bulmarket has internal policies/procedures to manage solid and hazardous wastes. The municipal contractors collect the sanitary solid wastes generated from terminals and filling stations periodically for disposal at licensed facilities. Bulmarket investigates and identifies soil and groundwater contamination before purchasing any industry lands. Bulmarket only purchases the industry land without soil/ground water contaminations or with contaminations that can be easily remediated.



Greenhouse gases (GHG): Bulmarket will generate approximately 11,500 ton CO2 equivalent per year after the Project is implemented, mainly from electricity consumption and diesel for transportation.

Community Health, Safety and Security: The fuel storage terminals are either located inside an industrial zone or in the rural areas with no community nearby. The filling stations are located along the rural highways. Operations of the terminals/filling stations have limited impacts on distant communities.



The fuel is transported to all storage terminals by rail or river. Bulmarket delivers fuels from terminals to customers and its fuel filling stations through railroad tankers, road tankers, and boat tankers. Besides fuel business, Bulmarket’s transportation divisions also deliver general cargo by railroads, roads, and rivers.



Bulmarket’s trucking fleet management strictly follows the requirements of European Agreement concerning the International Carriage of Dangerous Goods by Road (ADR); its railroad transportation management follows European Agreements Concerning the International Carriage of Dangerous Goods by Rail (RID); and its river transportation management follows European Agreement concerning the International Carriage of Dangerous Goods by Inland Waterways (ADN). Internal reviews and external checks are conducted periodically to ensure Bulmarket’s transportations be compliant with ADR/RID/ADN requirements.



All the truck drivers, locomotive engineers, and boat operators are required to have necessary trainings for their position and keep valid licenses, respectively. All are required to have annual medical checks. There are daily safety briefings for all drivers/engineers/operators, and they all use the necessary PPE.



Emergency Preparedness and Response: Bulmarket has emergency response (ER) plans for all transportation divisions as required by ADR/RID/AND and holds routine ER drills. For hazardous material transportations, required ER equipment is also installed at each truck/locomotive/boat.



Security Personnel: Bulmarket has its own security managers, who supervise contracted security personnel for its terminals. Some security personnel have fire arms at rural terminals, which are strictly used for self-defense purpose. Bulmarket has a security management plan in place. In addition, the facilities are equipped with video surveillance systems for monitoring. For serious security issues, Bulmarket reports directly to the local police stations.

Bulmarket engages the stakeholders actively and has routine meetings/contacts with nearby communities. All new/renovation projects are announced at local newspapers and all the ESIAs are published at local municipal offices. Bulmarket also holds public consultations for all the new/renovation projects. Contact information for community grievances are published at each facility and corporate website. Each grievance is recorded for follow-up.

Bulmarket has established programs with a specified budget for community engagement and development, which focus on the communities near its main port/terminal site in Ruse. Bulmarket is committed to supporting local sports teams including volley ball, soccer, and hand ball. Besides, Bulmarket also provides financial assistances for the senior community center near its main site.

Bulmarket will disclose this document in Bulgarian at local municipality offices, located at 6 Svoboda Square, 7000 Ruse, Bulgaria. For inquiries or concerns about the environmental and social impacts of this project please contact:

Mr. Dimitar Baev
Bulmarket, 100 Tutraken Blvd. POBox405, Ruse, 7000, Bulgaria
Phone: +35982 817 400
Fax: +359 82 844 862

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
1. Develop and implement corporate environmental and social (E&S) policy aligned with the requirements of Performance Standard 1 and ISO 14001.	06/30/2015
2. Contract external experts to conduct annual environmental, health, and safety (EHS) audits with the focus of operation safeties	12/30/2015
3. Set up an independent EHS department with qualified EHS engineers and a reporting line directly to the general manager.	06/30/2015
4. Draft a promotion program to hire more female employees in the expansion project.	03/30/2015
5. Record all accidents and manage the occupational health/safety (OHS) risks by statistical incidences.	06/30/2015
6. Update Human Resource policies and procedures to include requirement for contractors to comply with the requirements of PS 2, including that related to OHS. Such procedures are also to include a requirement for monitoring to ensure contractor compliance	06/30/2015
7. Contract external experts to conduct a qualitative risk assessment (QRA) for the LNG storage tank at the proposed terminals. If high valued objects are located within the exclusive zone calculated from QRA modelling, Bulmarket will build blast-proof walls to ensure the safety of the high valued objects	06/30/2015