No new land will be required for the projects and all the new SRUs will be constructed within the footprint of the existing refineries, which are all within industrial zones. Therefore, PS5: Land Acquisition and Involuntary Resettlement, PS6: Conservation and Sustainable Management of Living Resources, PS: 7 Indigenous Peoples, and PS8: Cultural Heritage are not considered to be applicable to the project

 The proposed SRUs will be built inside the existing refineries which are operational for the past 30 years. Tupras refineries are located in industrial zones, and its emissions and liquid effluents generally comply with Turkish Regulations. The proposed project will increase the efficiency. Since there is no production increase, the additional E&S impacts will be very limited; rather the project, upon implementation, will result in net environmental improvements. 

The key E&S issues and risks and issues associated with this project include; i) assessment of the project's (largely positive) impacts on the ambient air quality, ii) improvement of the corporate occupational health/safety management to prevent serious accidents during construction, maintenance and normal operations; iii) effective management of all contractors during SRU constructions; and iv) enhancement of hazardous material management and prevention of any major accidents during operations.  

Mitigation measures for the potential E&S impacts have been identified and are incorporated into an Environmental and Social Action Plan (ESAP). The potential adverse E&S impacts of this project are considered few in number, of limited significance and readily mitigated through the company’s existing robust systems and procedures. This is therefore a Category B project according to IFC’s Policy on Environmental and Social Sustainability.

       Environmental and Social Assessment and Management System

Tupras hires external experts to conduct E&S assessments for various new projects according to Turkish laws/regulations and its own technical standards. The company also has an established and robust corporate E&S management system that applies to all operations. All four refineries are certified to management systems of ISO 9001 (quality), ISO 14001 (environment), ISO 50001 (energy), ISO 17025 (laboratories), and OHSAS 18001 (occupational health/safety) standards. There are detailed environmental, occupational health/safety (OHS), and process safety requirements in Tupras EHS management programs. Once such E&S assessment reports are finalized, the company will disclose those locally as well as on its website as part of its ongoing stakeholder engagement. 

Policy

Tupras’ E&S policy reflects its commitments for the sustainable development and the corporate social responsibility. Its environmental policy requires reducing the probable negative environmental effects of its business operations through Best Available Techniques based on cost-effective solutions (https://www.tupras.com.tr/environmental-manegement-system). The policy promotes process safety management to prevent major accidents and ensure a health and safe working environment for all workers, contractors, and visitors. Tupras’ E&S policy is implemented though its environmental, OHS, and process safety procedures, which include well-designed key performance indicators (KPI) to evaluate and improve E&S performances.

Identification of Risks and Impacts

EHS risks for any new projects are initially identified and mitigated during preparation phases through Tupras’ internal procedures of Environmental Impact Identification/Assessment and Health Risk Assessment. During operational phases, EHS risks are identified through formalized auditing programs and informally frequent inspections. All these audits and inspections are summarized with corrective actions to mitigate the EHS impacts. Tupras has a process hazard analysis (PHA) standard in place to manage production safety. Under the PHA standards, Tupras conducts hazard and operability study (HAZOP), fault tree/ event tree analysis (FTA), facility siting, and job hazard analysis to identify production safety risk and develop mitigations. For the proposed project, Tupras will follow Turkish regulatory requirement to prepare the impact assessment, Project Description File, which will quantify and document the environmental improvements achieved through SO _X  emission reduction by the new SRUs and the resultant effect on the airshed (ESAP #1), as described in details under PS3 section of this ESRS. 

Management Programs  

EHS management teams at each refinery are responsible for educating, training and motivating employees to understand and comply with EHS performance procedures and the EHS management systems have been set up to monitor and support the works throughout the organization. Tupras’ EHS management system is well developed and includes detailed technical standards, standard operating procedures (SOPs) and work instructions, internal codes for EHS performance, and an extensive inspection/audit program. Systematic monitoring of environmental performance and process safety measures is in place for air emissions/liquid effluent controls, waste management, occupational health/safety tracking, and process safety management. Non-conformities to the technical standards are monitored and extensively followed up by the management. 

Organizational Capacity and Competency

At corporate level, Tupras has environmental and OHS/process safety management teams, respectively. The environmental team reports to Tupras’ Assistant General Manager (Technical). The OHS/process safety management team is assigned to OHS Directorate and reports directly to the General Manager. Additionally the refineries’ EHS managers report to the OHS Directorate at the Tupras headquarters. Environmental and safety teams are responsible for ensuring compliance with the corporate EHS/safety policy and management program implementation. The corporate environmental database is also managed by the corporate environmental team, which enables corporate management to quickly access the environmental performances at each refinery directly. As part of this project, Tupras will enhance the OHS/process safety management capacity with additional qualified staffs. As indicated in the ESAP #2, Tupras will establish an OHS/process safety database similar to the corporate environmental database, to further improve OHS/safety management. 

At each refinery, there are also environmental and OHS/process safety teams to manage the daily EHS operations according to corporate policies, programs, and procedures. Both teams report to refinery general manager with dotted reporting lines to corporate environmental and OHS/process safety teams, respectively. 

Emergency Preparedness and Response

Turkey is in the earthquake-prone zone. All four refineries are designed and constructed according to California Seismic Design Criteria, which are more stringent than the local regulatory requirements. There are sufficient firefighting equipment and firefighting water/foams onsite, which are all properly maintained. Toxic gas sensors and automatic fire detectors are installed at all critical locations with connection to central operation room. Automatic sprinkler systems are installed for all fuel storage tanks. Each refinery has its own dedicated fighting team with fire trucks and other necessary equipment. 

Each refinery has well documented emergency response (ER) plans as required by corporate safety procedures. At each refinery, there are monthly ER drills and annual disaster response drills. For the annual disaster response drills, local municipal fire brigade and nearby hospitals are invited to participate. Local government agencies also inform the nearby community of the proposed drills. The marine ER services at Izmit and Izmir refineries are contracted to a qualified third party, which joins the annual disaster response drill and has the capacity to seal the bays with floating booms in 30 minutes in case of major marine oil spills.

Each refinery has a crisis response center to coordinate the major ER action. The center has access to all the managers / ER teams and the get real time views of all critical locations through closed-circuit televisions (CCTV). The corporate crisis response center located at headquarter office in Izmit also has access to all the information available to each refinery crisis response center. 

Heavy  residuals are transported from Kirikkale refinery to Izmit refinery though railroad tankers. Railroad transportation follows the EU safety standards for transporting fuels. In addition, Tupras marks catch basins along the entire 400 km railway to prevent oil runoff in case of a railway accident. Four ER teams are also permanently stationed along the railroad to quickly act in case of spills or fires. For road transportation, Tupras only contracts transportation companies that have defensive driving programs, acceptable safe driving records, and sufficient emergency response methods. 

Monitoring and Review

Tupras has instituted comprehensive environmental and OHS/process safety monitoring programs. The environmental monitoring includes point source emissions, fugitive emissions, effluents, fence line air quality, ambient air quality, noise levels, waste handlings/disposals. OHS/Process safety has key performance indicators (KPIs) to monitor the performances (e.g. total recordable incidents, work permit review, etc.).

Both the refinery and headquarter teams continuously review 15 KPIs for OHS. Additionally, 15 process safety KPIs (according to API 754) are reviewed and analyzed on a continuous basis. KPIs cover both leading and lagging indicators. KPIs and performance/trends analyses are presented in detail at monthly safety meetings chaired by the Tupras’ General Manager.

OHS and process safety audits are carried out by refinery and headquarters’ teams regularly. All projects are subject to Tupras management of change (MOC), PHA, permit to work (PtW), and incident investigation standards. 

The monitoring is carried out at 3 different levels. Firstly, refinery environmental teams conduct monthly environmental inspections. The corporate environmental teams coordinate annual corporate-wide intra-refinery environmental audits. Lastly, Koc Holding, Tupras’ holding company, also conducts its EHS audits for Tupras’ EHS management and performances at each refinery. Corrective actions are proposed at all inspection/audit with implementation timelines. Implementation of the corrective actions is evaluated at the following inspection/audits. As part of the Project, Tupras is expected to enhance its stack emissions and ambient air quality monitoring as described under PS3 .

   Tupras currently has a total of 4,981 direct employees and 15,791 contractor employees in four refineries and headquarters by the end of 2016. Third party workers are employed in main business operations as well as other supporting activities including warehouse, cleaning, canteens, etc. As part of this project, an undetermined number of construction workers will be hired by contractors for SRU construction and commissioning. Most of the construction workers will come from the local areas. 

Human Resources Policies and Procedures

Human resources (HR) policy, programs, and procedures are developed by corporate HR department and applied to all four refineries. Tupras’ corporate HR policy provides HR frameworks/guidelines and are consistent with Turkish Labor Code and IFC PS2. Tupras’ corporate HR policy defines general principles of freedom of association, privacy and equal employment opportunities. HR policy and procedure trainings are incorporated in the new employee induction and are provided in Turkish. The corporate HR department coordinates with HR teams at each refinery to ensure consistency. Annual or more frequent HR audits are conducted by Koc Holding to confirm compliances with the Group HR requirements.

Working Conditions, Term of Employment, and Worker’s Organizations

Tupras has a collective bargaining agreement with the Petrol-Is Worker Union. All blue collar workers in Tupras are members of the union. The collective bargaining agreement is renewed biannually. At the time of the appraisal, the renewal of the agreement was under negotiation between Petrol- Is and Tupras. Each refinery has union representatives and an office is allocated to union representatives at the Tupras headquarters. The employment terms are defined in signed contracts in accordance with The Turkish Labor Code and collective agreement, which cover working conditions, worker and employer rights, salary, annual leave, minimum wages, discipline procedures, overtime management, health benefits (insurance), religious holidays etc. Employees work in three 8-hours shifts and in total 40 hours/ per week and overtime work is paid in line with collective agreement. 

Tupras has also social facilities in every refinery that offers restaurant, gym, music room and is open to all employees and their dependents. Transportation services are offered to employees living in nearby cities. 

Non-discrimination and Equal Opportunity

Tupras has a business ethics policy, promoting equal opportunities, negating all forms of discrimination, respecting privacy of employees, and opposing any discriminations based on race, sexual, political orientation, religion etc. The HR policy includes requirements related to non-discrimination and equal opportunity. No procedures and/or practices have been identified as discriminatory. All hiring and promotion are merit-based. 

Tupras management is encouraging more and more women employees in its workforce who currently make up about 8.3% of total workforce. The company has started to modify working areas to accommodate female employees. Tupras is also committed to a campaign initiated by UN Women called “He for She” ( http://www.heforshe.org/en  ). The aim of the campaign is to support gender equality in every platform including workplace. 

Retrenchment

While the project does not require significant new recruitment of new employees, no retrenchment is also expected at any of the company’s refineries in the foreseeable future.

Grievance Mechanism

The company strives to maintain a good working environment by encouraging open and direct communication between employees and their supervisors. Grievances can be received through the worker union representatives or suggestion/complaints boxes accessible in the refineries. Any worker with concerns or feeling for unfair treatment are encouraged to report to the management or HR. This is also applicable for all contracted workers in all four refineries and corporate office. All the grievances are formally recorded and Tupras is committed to handling every grievance on a fair and equitable basis. Tupras has business ethics policies and procedures. In cases of violation of business ethics, employees can inform their supervisor. These submissions are handled by the Ethics Committee. The employees are informed of this procedure during induction. This formal grievance mechanism is also applicable to contractor employees in all four refineries. 

Protecting the Work Force

Tupras has corporate policies against hiring of workers below the age of 18 years and forced labor. HR teams check birth and school certificates during the hiring process. These requirements also apply to all the temporary workers hired by third party contractors. 

Occupational Health and Safety

All Tupras refineries are certified by OHSAS 18001. There are routine OHS training, including new employee training and annual refreshers. Job hazard analysis (JHA) is conducted and updated for each operation position. Based on JHA, OHS operation procedures are developed and proper personal protection equipment (PPE) is provided. The OHS procedures (e.g. PPE usage) are enforced strictly. The OHS management is also implemented through a set of safety tools and methods, including systematic inspections, walk through/observation, peer-to-peer behavior check, etc. Tupras sets up challenging key performance indicators targets (e.g., total recordable incidents, work permit review, etc.) for OHS performance. Contractors working at Tupras refineries are subjected to the same company OHS rules. The total recordable incident rates (TRI) for employees and contractors are among the industry averages. 

Tupras has a comprehensive set of workplace air quality and noise level monitoring, which include dust, important volatile organic contaminants (VOCs), hydrogen sulfide, etc. for all important operation positions. The monitoring data shows that the company is compliant with local regulatory requirements and good international industry practices. 

All four refinery sites are crowded and OHS management is difficult for renovation construction and maintenance. As indicated in the ESAP #3, Tupras will develop an enhanced contractor OHS management plan to prevent serious OHS accidents during the constructions of the sulfur recovery units. The plan should include major components of construction OHS management, including, but not limited to, reasonability, prevention, monitoring, reporting, mitigation, medical services, ER etc. 

Workers Engaged by Third Parties

Tupras has an internal ranking system to evaluate potential construction or other major contractors. The evaluation includes suitable HR policy/procedures and OHS records/management capacity. Only qualified contractors are allowed to submit biddings. Once contracted, all contractors are subjected to the same OHS management procedures as Tupras employees, and the contractor employees also have access to Tupras HR grievance mechanism.

For selected construction contractors, the OHS requirements are included in the standard contract clauses. Adequate insurance is also required in the contacts to cover potential construction accidents, including fatalities. According to the OHS management procedure, Tupras OHS team also takes the lead to manage the OHS performances of construction / EPC contractors. 

Supply Chain

The raw materials are mainly from other large oil and chemical companies. Child labor or forced labor are unlikely. 

     Resource Efficiency and Efficiency Projects

In 2016, four refineries in Tupras processed a total 28.3 million tons of crude oil and consumed approximately 17.5 million tons of raw water. The main energy sources are mainly from various fuels generated from refining process, including natural gas, refinery gas, fuel oil, refinery coke, etc. Besides, electricity is also purchased to supplement internal power generations as needed. 

In recent years, Tupras has focused on energy efficiency as one of the main means to reduce operational costs and promote sustainable development. For this, Tupras invested in various energy efficiency related projects during the past five years (e.g. gas-based co-generation). As a result, energy consumption was reduced by about 22% from 3,367 to 2,760 MJ/ton of processed crude oil, which is consistent with the benchmark values in WBG EHS Guidelines. More energy efficiency projects are also planned in next five years for a further reduction in energy consumption. 

Water and Water Efficiency

In the past, Tupras sourced the water for production mainly from the surface water sources, which posed competition with other industrial or municipal usages. Tupras, therefore, implemented a grey water recycling project in 2015, which utilized treated municipal wastewater from the nearby Korfez Municipality as raw water for Izmit refinery. Approximately 10 million tons of municipal wastewater is now recycled per year as raw water for Izmir refinery. 

Tupras has launched a wastewater recycling project at Izmir refinery in 2016, where up to 30% of the treated wastewater generated from Izmir refinery will be recycled as raw water after tertiary treatment, including reverse osmosis. 

GHG Emissions 

The greenhouse gas generation at Tupras is mainly from consumption of various refining fuels for power, steam, heating, etc. Tupras monitors the GHG emission through recording of refining fuel consumptions.  Since this investment is mainly to fund new sulfur recovery units, additional GHG emissions due to this investment are considered limited.

Point and Fugitive Emissions

The main air emissions from refinery operations are SO _X , NO _X , H ₂ S, particulate matters (PM), heavy metals, benzene, and other volatile organic compounds (VOCs). Majority of the fuels are purchased natural gas or refinery gas, and the monitored emission parameters are compliant with local regulatory requirements. With the new SRUs, conversion will be higher than existing SRUs. High conversion will result in decreased emissions, and hence will contribute to the environmental improvements.  

As part the project, the company will install SRUs in Izmit, Izmir and Kirikkale Refineries with a capacity of 240 tons/day, 240 tons/day and 135 tons/day solid sulfur capacity, respectively. The main objective of SRUs is to have minimum 99.5% sulfur recovery efficiency in acid gas feed that should be recovered as sulphur product in EuroClaus© process  by Comprimo® Sulfur Solutions & Petrochemical Technologies. The specific details of stack emission, SOx reduction and ambient air quality improvement will be known once the company complete the assessment as indicated in ESAP #1.

Tupras will use its reasonable endeavors to (i) comply with the emission limits in the WBG EHS Guidelines for Petroleum Refining one year after the final acceptance of each new SRU to be constructed in Izmit, Izmir and Kirikkale refineries to the extent that such compliance would not require any additional investment or substantial change in the scope of the investment plan of Tupras or result in substantial costs to be incurred by Tupras  and,  (ii) use  technically and financially feasible methods to ensure Tupras’ contributions of  SOX, NOX and PM at main communities nearby  Izmit, Izmir and Kirikkale refineries  are = 25% of Turkish regulatory standards for the ambient air quality  (ESAP #4) .  In addition, Tupras will monitor and report its contributions of SOx, NOx and PM at main communities nearby Izmit, Izmir and Kirikkale refineries every two years (ESAP#5). 

In line with the ESAP #6, Tupras will monitor and report SOx, NOx and PM emissions for those point emission sources equal and higher than 50 MWth capacity and the new SRUs four times a year and for those less than 50 MWth capacity once in every two years at Izmit, Izmir and Kirikkale refineries.

Tupras reduces fugitive VOC emissions through equipment VOC emission checkup, frequent maintenance, double sealing, nitrogen blanket, etc. Floating roofs are also installed for all gasoline and other volatile product storage tanks. The fence line benzene levels meet WBG EHS Guideline limit. 

Wastewater

All the wastewater is treated at the onsite wastewater treatment plants through physical /chemical and biological treatment and reverse osmosis (RO) for recycles. The treated wastewater and RO rejection are discharged to surface water by sea. The monitored parameters for the discharged wastewater are compliant with Turkish regulatory requirements. Groundwater qualities at each refinery site is also regularly monitored, which shows no groundwater contamination at any site covered under the project. 

Solid and Hazardous Waste Management

The sanitary wastes are collected by municipal contractors for disposal. Platinum catalysts are sent back to manufacturers for regenerations. All other industry solid/hazardous wastes are disposed at waste disposal facilities, which are approved and licensed by Turkish Government. Tupras also keeps and reviews all the manifests and chain of custody to ensure proper disposal of hazardous wastes. Element sulfur from SRUs are sold as byproduct and there is no long-term storage of sulfur at any refinery site. 

Hazardous Materials and Operation Hazard

Refining industry’s raw materials, intermediate products, and products are mainly hazardous materials. The manufacturing, storage, handling, and transportation of these materials may pose high risks to employees and nearby communities alike. Tupras employs HEMP standard to manage production safety. HAZOP is updated whenever any process is modified. Even without any modification, HAZOP for critical processes are also updated every five years based on production experience or new technology. 

Fire detectors, leak detectors, and toxic gas sensors are installed in all key locations of refineries. All these detectors/sensors are connected to the central control rooms together with all other process data. Tupras does not have underground storage tanks. All tank farms have proper bottom and secondary containment structures with sufficient holding capacity in case of leak. Quantitative risk assessments (QRAs) are conducted for all important storage tanks. QRA models show the impact radius under the worst case scenarios are within Tupras properties. 

       Community Health and Safety

All four Tupras refineries are located in industrial areas. There are communities outside of the industry zones. The routine ambient air quality and fence line monitoring show the normal operations have limited impacts to the communities outside of the industry zones. QRAs for critical storage tanks show the impact ranges are within Tupras properties in case of an accident at the worst scenarios. Majority of raw materials and products are transported by sea, pipeline or railroad. 

Security Personnel

Tupras has its own security forces to protect the refineries. Tupras has security management plan with defined security risks and procedures. These security procedures and plans lay down operational protocols for security management of the refineries and marine terminals, which include emergency communication and response. Additionally, the port security at Izmit facility is verified by the Ministry of Transport, Maritime Affairs and Communication as it is in compliance with the provisions of SOLAS and International Code for the Security of Ships and of Port Facilities (ISPS Code). Tupras has also special security clearance from governor of the city.

Security personnel are recruited, trained and managed through corporate security management unit. Since the nearest communities are about 1 km away from the Tupras facilities, the interaction between armed security guards and the local communities is rather limited on a day-to-day basis.

Security personnel are examined regularly regarding to their physical, technical and psychological capabilities. Tupras security training program includes key procedures to avoid excessive use of force and to handle various situations with different stakeholders. Security forces are also responsible for conducting routine security checks at the gates and strategic points defined by the corporate security management unit. Background research and interviews did not indicate any issues with community regarding the security arrangement. As part of this project and indicated in the ESAP #7, Tupras will use its reasonable endeavors to run its operations in line with  the  Voluntary Principles on Security and Human Rights . In line with the ESAP #8, Tupras will also carry out a security risk assessment to identify gaps between existing security system and PS4 requirements and, if necessary, develop a detailed security management plan in line with the Voluntary Principles on Security and Human Rights.

 All four refineries are located in industrial areas with other industrial and commercial facilities. Izmit refinery is adjacent to a fertilizer production plant and a LPG production plant. The nearest residential area is located around 1 km from the project site. Tupras has a grievance mechanism where affected communities and interested parties can raise and register their concerns and complaints at Tupras web site ( https://www.tupras.com.tr/iletisim ). For the communities near its production sites and as a part of their environmental management system, all sites have formal procedures in place to address and resolve concerns or complaints raised by stakeholders, as well as emergency communication procedures to contact relevant stakeholders in a case of a potential accident. Complaints are monitored by the Communications departments of Tupras and delivered to the related departments at each refinery. Tupras also organizes public meetings with local stakeholders and interested parties to provide information and get feedbacks for its new projects.

Tupras recognizes corporate social responsibility (CSR) as an essential part of the company identity, and maps internal and external stakeholders for better communications.  Through various activities, Tupras engages and supports the key stakeholders. The main initiatives include breast cancer awareness, stage performances, sport activities, internship opportunities for nearby community youth, scholarship for children from disadvantaged families, etc. 

Tupras is a member of the United Nations Global Compact and publishes annual corporate social responsibility report since 2008. The CSR report consists of the social, economic and environmental results of its operations, available at:  https://www.tupras.com.tr/cr-report . This report is prepared in accordance with Global Reporting Initiative (GRI) G4 reporting standards.