PS5 (Land Acquisition and Involuntary Resettlement) is not triggered by the project because the SAF project is developed on land already owned and occupied by BTE. The Client owns 5.84 acres of land purchased for industrial use in 2014 on a willing buyer-willing seller basis. The SAF project will be developed on 3.18 acres of vacant land adjacent to the existing BTE plant. PS6: Biodiversity and Natural Resource Management does not trigger because the project does not involve any primary production nor using any biomass for sourcing raw materials. The project will use used cooking oil and byproducts from the wastes in SAF production process. PS7: Indigenous Peoples and PS 8: Cultural Heritage are not expected.            

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability (2012). Based on the information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible and readily addressed through existing mitigation measures and good international industry practices (GIIP). Key E&S issues and risks include (i) the company's management and monitoring systems to assess and manage E&S risks and impacts from the BTE’s operations, including operations of port terminals, as well as those related to the construction and operation of the SAF facility funded under the project including contractor management; (ii) management of labor and working conditions and occupational health and safety (OHS) policies and practices; (iii) supply chain management related to oil feedstock; (iv) chemicals handling and storage; (v) monitoring and management of air emissions, waste, wastewater, and hazardous materials; (vi) process safety risks to adjacent land users; (vii) community safety including traffic safety risks; (viii)  management and monitoring of security personnel; and (ix) the company's stakeholder engagement activities related to E&S aspects.       

PS1: Assessment and Management of Environmental and Social Risks and Impacts

Identification of E&S Risks and Impacts:

The company has conducted an ESIA study for the SAF facility to assess the E&S aspects and impacts of the construction and operations phases, oil feedstock collection supply chain, and product transportation to the off-take point. The ESIA study outlines an Environmental and Social Management Plan (ESMP) for the construction and operational phases. The ESIA process included consultations with the project’s stakeholders. The Client has prepared a provisional Stakeholder Engagement Plan.

The ESDD assessed the contents of the ESIA for alignment with the PSs and applicable WBG EHS Guidelines. The ESIA is being augmented to address the process safety risks explicitly through a preliminary Hazard Identification (HAZID) process and a preliminary Quantitative Risk Assessment (QRA) study of the existing BTE facility and upcoming SAF facility; undertake additional stakeholder consultation and information disclosure activities; assess the risks associated with the road transport of processed product and its storage at a terminal at the Karachi seaport for off-taking; perform quantitative air and noise modelling, and; evaluate the supply chain risks associated with child/forced labour. As per ESAP #1, BTE will augment the ESIA study including a cumulative impact assessment of the SAF project and the existing BTE plant to meet the requirements of IFC PSs, WBG General EHS Guidelines (2007) and WBG EHS Guidelines for Petroleum Refining (2016) and address all risks and issues identified in the ESDD report.

BTE has an established Environmental and Social Management System (ESMS), which includes a procedure for assessing and managing E&S risks and impacts of its current operations. BTE also has a procedure for annual risk assessment and hazard identification for the BTE plant and maintains a site-specific Hazard and Risk Register. As described in ESAP #2(iii), as part of ESMS manual BTE will update the procedure for the assessment of E&S risks in accordance with the requirements of IFC’s PS1 to cover the existing BTE operations and the SAF facility, feedstock supply chain, and road transportation of the products to the off taking point at Karachi.

BTE has conducted a HAZOP Study for their existing operations to verify their management of process safety risks and emergency response preparedness. Compliance with HAZOP recommendations was tracked using an Implementation Plan. The HAZOP study for the SAF plant will be conducted in the EPC phase after the completes of a detailed engineering design by AXENS as part of the Process Design Package (PDP). AXENS follows GIIP concerning the management of process safety risks. BTE will ensure the impartiality of the process safety studies. As per ESAP #1(i), the ESIA study of the SAF project will be updated addressing the process safety risks explicitly through a preliminary Hazard Identification (HAZID) process (based on the initial design of SAF project) and a preliminary Quantitative Risk Assessment (QRA) study of existing BTE facility and upcoming SAF facility. As per ESAP #4, BTE will ensure that a detailed HAZOP (Hazard and Operability) and updated QRA studies are conducted for the existing BTE facility in operation and the new SAF facility at the completion of the Process Design Package (PDP) phase of the SAF facility. The updated QRA study will also cover a fire and explosion risk analysis (FERA) and toxic gas dispersion study. HAZOP and QRA studies will be conducted by PTIK and AXENS and engaging a third-party consultant to monitor the process.

Policy and Management Systems:

BTE has an Environmental Policy, Occupational Health and Safety Policy, ESG Policy, and a Child Labor Policy that focuses on compliance with national law and addresses supply chain management, pollution prevention, energy efficiency and waste reduction, PPE procedures, workplace safety, emergency response, etc. As per ESAP #2(i), BTE will develop an overarching, consolidated, and standalone EHS and Social Policy consistent with the principles of IFC PSs, defining the environmental and social objectives and principles that guide the project to achieve sound environmental and social performance.

The company has an established Environmental and Social Management System (ESMS) for the existing BTE plant that is broadly aligned with the requirements of IFC PSs and commensurate with, its operations' scale and E&S impacts. The ESMS is certified per ISO 9001:2015, ISO 14001:2015, and ISO45001:2018. As part of managing the change process, the company will augment its ESMS procedures to address changes the SAF Project will generate (in the operational phase) and document a single, centralized ESMS for implementation by a single EHS Team. The ESMS includes an Environmental Management Plan (EMP), an Occupational Health and Safety (OHS) Manual, and procedures to manage environmental risks in its existing operations. Topics covered include air emissions monitoring, wastewater management, solid waste management, spill response procedures, safety rules, water conservation, and OHS management review and reporting procedures. The company has acquired International Sustainability & Carbon Certification (ISCC) EU certification verifying compliance with the European Union's (EU) Renewable Energy Directive (RED II) sustainability criteria in the production of biodiesel at BTE plant using three waste oil feedstocks (used cooking oil, poultry feather acid oil, and soap stock acid oil). Following ISCC, BTE provides evidence of sustainability for every shipment of biodiesel to Europe. BTE has obtained a license from the Punjab Food Authority to collect oil feedstocks for processing into biodiesel at BTE plant. The company obtained approval from the provincial Environmental Protection Agency (EPA) for the existing operations in 2019 and for the construction of the SAF facility in April 2024. As per ESAP #2(ii), BTE will augment site-specific EHS&S management plans and procedures (ESMS Manual) for BTE and the new SAF facility, as an integrated and a consolidated document, ensuring alignment with the ESIA and the requirements of IFC PSs and WBG General EHS Guidelines, WBG EHS guidelines for Oleochemicals Manufacturing (2007) and WBG EHS Guidelines for Petroleum Refining (2016). The ESMS Manual will also include Service Providers Management Framework, Supply Chain Management System (SCMS) including a Responsible Collection Policy (RCP), product Transport Safety Management Plan, Risk Assessment and Management of Change, Environmental Monitoring Plan, Occupational Health and Safety Management Plan, Air Emissions Management and Monitoring Plan, Spill Management Plan, Hazardous Materials Management Plan, Waste Management Plan, Wastewater Management Plan, Safe Operation and Resource Conservations Plan, Community Grievance Mechanism, Security Management Plan, EHS Trainings, Performance Review and Internal Auditing and Reporting Procedures, Accommodation Management Plan, Emergency Preparedness and Response Plan, and a site-specific Stakeholder Engagement Plan.

For the 20-months construction phase of the SAF plant, the company has developed, as part of the ESIA a site-specific Contractor’s ESMP. As per ESAP #3, BTE will augment the Construction Environmental, Occupational Health, Safety, and Social Management Plan (CESMP) for the SAF plant, consolidating the Contractor’s ESMP, in line with the requirements of IFC PSs, WBG General EHS Guidelines (2007) and WBG EHS Guidelines for Petroleum Refining (2016) and to reflect the updated ESIA. The Company will ensure that the EPC contractor develops and implements its own project specific ESMP that aligns with the CESMP.

BTE has a procedure for the contractors to collect and handle raw materials and inspect contractors’ vehicles. As part of the updated ESMS Manual, BTE will have oversight on the E&S performance of their contractors through the Service Providers Management Framework and the Supply Chain Management System. Individual contractors’ E&S performance will be reviewed monthly in accordance with a Performance Review and Reporting Procedure. BTE has prepared a Contractor Management Plan that includes the interface between the SAF Project’s construction contractor and the Client’s OHS management system to manage interface risks. This Plan will form part of the Construction broader ESMS.

To ensure the mechanical integrity of the SAF plant for the process safety management system, the company will have a supervisory O&M contract with the EPC contractor and a technical assistance and enhanced training contract with AXENS. During the operational phase of the SAF plant, maintenance will be organized through an in-house team supervised by the EPC contractor, PTIK, under an O&M contract for three years.

Organization Capacity and Competency: BTE has established an EHS organizational structure, which includes an EHS Oversight Committee, headed by the Chief Operating Officer (COO) and comprising of senior management, to oversee the company’s E&S performance quarterly. BTE has an established ESG unit overseen directly by the company’s Chief Executive Officer (CEO). The head of the ESG unit leads the environment, safety, GHG compliance, and supply chain teams and has been designated to implement ESMS.  The HSE Manager ensures HSE compliance, monitoring, and reporting at the plant level with a staff of 4 safety officers and 2 safety technicians. The company has developed an E&S staffing plan to enhance the ESG unit's capacity commensurate to the SAF plant's operational phase. The staffing plan includes hiring an environmental engineer, a GHG compliance officer, a supply chain compliance head and 6 compliance officers, a social specialist, 2 additional safety officers, and 6 additional safety technicians. As per ESAP #2(iv), BTE will update and formalize its organizational EHS structure, aligning roles and responsibilities for the existing operations as well as for oversight of the project’s construction phase and for implementation of the ESMS for both the biodiesel plant and SAF plant during the operational phase. 

Emergency Preparedness and Response: BTE has an Emergency Response Plan (ERP) that includes a firefighting plan, emergency fire action plan, evacuation plan, and a fire extinguisher inspection checklist. The ERP identifies the roles and responsibilities of emergency coordinators and employees responsible for evacuation, rescue, and firefighting. The firefighting plan includes potential fire hazards, fire prevention plan and the emergency contact details of the responders.

As per ESAP #13, BTE will update its Emergency Preparedness and Response Plan (EPRP) in line with the requirements of IFC PS and GIIP, consolidating discrete procedures in a single integrated document that covers both the existing biodiesel plant and the SAF plant. The EPRP will encompass on-site and off-site specific emergency scenarios such as the failure of hazardous liquid storage tanks, the failure of pipes under pressure, spillage during feedstock collection activities, and transportation emergencies that could occur from road transport operations. The EPRP will include contact details of the local emergency responders and describe the drill and training needs for security personnel, supply chain vendors, and transport contractors, and be used for the basis of a consultation with adjacent land users and government departments who have responsibility for providing emergency response resources.

HSE Training: BTE develops annual EHS training plans for its employees. Training sessions are conducted internally and documented. The EHS training plan is aligned with the risk assessment matrix. Near-misses records are analyzed and integrated into the training plan. The company provides training to contracted workers undertaking feedstock collection activities on spill management and the use of PPE.

As part of the ESMS Manual, BTE will update the HSE training plan and develop an induction training module, including training related to process safety hazards, handling and storage of hazardous materials, waste management, industrial hygiene, transportation safety, and awareness of IFC PSs and WBG EHS guidelines. BTE will also develop an OHS training module for the feedstock collection contractors and transportation contractors and will contractually require and monitor its contractors to train contracted employees for awareness and compliance with BTE’s OHS procedures (ESAP #5).

Monitoring and Reporting: BTE submits quarterly environmental compliance reports to the provincial EPA compliant to the approval conditions and monthly reports to Punjab Food Authority on the collection and consumption of the oil feedstocks and biodiesel production. For reporting under ISCC, GHG monitoring is carried out by engaging an external auditor. The staffing plan includes hiring an internal GHG auditor before the operations of the SAF plant. A third-party laboratory monitors the effluent quality, stack emissions, and noise levels at the BTE plant for reporting to the EPA. Annual audits are conducted in line with ISO requirements.

The company's safety performance is monitored through daily inspections by the safety officers and unsafe practices or violations of the safety procedures are recorded and summarized in the monthly safety reports. The EHS Oversight Committee includes the senior plant management. It is responsible for monitoring the company’s E&S performance and ESMS implementation and the compliance status of the company operations with the applicable national standards and E&S regulatory permits and requirements.

The company documents the E&S performance in the Annual Safety Reports highlighting the safe working manhours, incidents records, emergency drills and training, environmental Key Performance Indicator (KPIs), Corporate Social Responsibility (CSR) initiatives and HSE action plan for the subsequent year. As part of the updated ESMS Manual, BTE will update its performance review and internal auditing process including the feedstock supply chain, and road transportation contractors, and will enhance its internal monitoring and reporting procedures, ensuring monthly EHS&S performance review (ESAP #2(v)).

PS2: Labor and Working Conditions

As of May 2024, BTE employed 273 direct workers, comprising 240 permanent workers undertaking 8-hour/day shifts at the processing site, 8 permanent workers attending collection points, and 25 permanent workers based in the head office in Lahore. All workers are male. Following the completion of the construction stage and commissioning of the SAF plant, the direct, permanent workforce is expected to reach a maximum of 300 workers when peak production is reached, with the total workforce being approximately 573.

BTE currently uses three service providers: two for the collection and transportation of feedstock and biodiesel and one for the provision of security personnel based at the site. During the SAF Project, it is planned that these service providers will continue to be used.

Human Resources (HR) Policies and Procedures: BTE has an HR Policy that complies with national law and most PS2 requirements and includes a commitment to respect human rights and a Code of Ethics. All the direct workforce receives training on the HR Policy and Code of Ethics during their initial induction and repeat induction training is provided every quarter.  BTE’s Code of Ethics applies to the contracted workforce through legally binding agreements with the service providers. As per ESAP #6(i), BTE will update its HR procedures to specify that all workers engaged must be provided with copies of their employment contracts and access to all supporting human resources policies; including details of monitoring actions undertaken by BTE to check their internal implementation, and state that that there is no restriction on a worker’s rights to join and form trade unions or other associations, as well as the right to collective bargaining.

All direct workers are provided with a written employment contract, which includes information on wages, deductions, benefits, working hours, a reference to BTE’s Overtime Policy and Annual Leave Policy, and environmental and OSH requirements. Working hours (routine and overtime hours) are recorded using a biometric and a manual attendance system, and working hours are calculated each month and checked with workers to ensure their agreement before being paid. Working hours of the direct workforce are within the national legislative limit of 56 hours/week including overtime.

BTE has a Fair Employment Policy that commits to paying fair and equitable wages that reflect the cost of living, providing a workplace free from discrimination, and recognizing employees’ right to freedom of association and a safe and healthy working environment.

BTE uses a contractual template with their three service providers, which includes a clause to manage workers following national legislation and PS2 requirements. As per ESAP #7, BTE will develop a Service Providers Management Framework as part of its ESMS, including monitoring, auditing, reporting, and communication methodology. BTE will audit all service providers at their physical workplace and compile any gaps identified into a time-bound Action Plan with a specific focus on compliance with national working hour limits. Thereafter, BTE will conduct regular annual audits to check service providers’ compliance with the requirements of the Service Providers Management Framework.

Working Conditions and Terms of Employment:  BTE plans recruiting a Worker Welfare Officer from the start of SAF production to support the establishment of a professional workplace and to work with senior management to ensure that worker welfare facilities are adequate. The SAF Project includes constructing a workers’ canteen for the BTE facility.

During construction of the SAF facility no on-site accommodation would be required for the international workforce of the EPC Contractor as they will use an hotel or guesthouse. The workforce of national construction companies (a peak of 200 workers) subcontracted by the EPC Contractor may require the use of one, or more, accommodation facilities. During operations, BTE will not provide accommodation to the direct workforce.

BTE currently provides on-site accommodation to the contracted security personnel.  As per ESAP #8, BTE will develop a Workers’ Accommodation Plan to ensure that the quality of the on-site accommodation reflects the applicable content of IFC/EBRD Guidance Note on Workers’ Accommodation: Processes and Standards (2009).

Non-discrimination and Equal Opportunity: BTE’s HR Policy and Code of Ethics prohibit forced labour and child labour and include specific provisions on gender-based violence and harassment prevention. Workers are encouraged to report any incident of harassment, discrimination, violation of law, or misconduct to the HR Manager. BTE only employs persons according to legal age employment regulations, and age is verified using national ID cards. BTE’s Fair Employment Policy targets 20% female managerial employees and 20% female non-managerial staff by the end of 2027. 

Workers Organisation: BTE recognizes the lawful right of freedom of association and collective bargaining for all its employees. However, no collective bargaining agreements or formal worker organizations are currently in place, which will be discussed with the workforce as per ESAP #6(i). 

Grievance Mechanism: BTE established a written Grievance Policy in 2023. Grievances can be submitted to management in writing using forms or verbally, although there is currently no complaint boxes or anonymous reporting mechanism in place. All grievances are recorded in a central register and investigated sensitively and confidentially. BTE will ensure, as per ESAP #6(ii), that their Grievance Policy is updated to allow anonymous complaints to be submitted, complaint boxes are installed at various locations across the site, and the workforce is informed about their ability to submit a complaint anonymously, should they wish to do so.

Occupational Health and Safety: BTE has an OHS Policy, has performed process safety (HAZID and HAZOP) and OHS risk assessments and has established an OHS Management Plan for their current operations. BTE will ensure detailed HAZOP and updated QRA studies are conducted for the existing BTE facility in operation and the new SAF facility upon completion of the PDP phase. The OHS Management Plan includes 29 Standard Operating Procedures (SOPs), and these are aligned with a centralized Risk Register and reflect good international industry practice. BTE has established Plant Safety Rules which remind staff of basic safety precautions including the requirement to use personal protective equipment. A Permit-To-Work System is in place for critical activities with a fire/safety watch required.

Workers receive OHS training at the induction stage which lasts 2 weeks. Workers are subsequently kept under close supervision for one month thereafter, and a formal Training Plan is prepared that reflects hazards the worker is likely to be exposed to. Daily training is provided through tool-box talks and regular briefings by the Safety Manager.

A daily housekeeping walkthrough is completed by the Safety Manager to identify areas of improvement. All OHS incidents (including near-misses) are recorded and investigated, and root-cause investigation is undertaken. In 2023, the company recorded 31 incidents of oil spills, 30 first aid cases, 14 near misses, no medical treatment incident, and no lost time injury. From the start of 2024, all OHS incidents (including near-misses) associated with the service providers involved in feedstock collection and biodiesel transport to the port have been incorporated into BTE’s central incident register. OHS statistics are centrally recorded and compiled into a monthly OHS report and annual OHS reports and are publicly disclosed. As part of the ESMS Manual under ESAP 2(vi), BTE will update the Occupational Health and Safety Management Plan (OHSMP), integrating and consolidating the discrete SOPs, ensuring alignment with IFC PSs and WBG General EHS Guidelines, WBG EHS guidelines for Oleochemicals Manufacturing (2007) and WBG EHS Guidelines for Petroleum Refining (2016). The OHSMP will include workplace monitoring including, but not limited to, occupational hygiene, workplace noise, vibration, dust, thermal comfort, and light intensity measurements.

Supply Chain: BTE’s existing network of feedstock collection (points of origin) ranges from multinational companies, national companies with several sites, and individual one-off businesses. BTE has numerous collection points and the details are compiled into a central register.  Before feedstock is collected, a representative from the collection point is required to sign a Waste Transfer Note, which includes a written self-declaration confirming the absence of forced labor and child labor and includes the quantity of feedstock, the date of transfer, and the name of the collection point. During SAF production, the number of points of origin will increase three to fourfold approximately when peak production is reached.  BTE’s existing supply chain of feedstock is certified to the International Supply Chain Certification European Union (ISCC EU) Scheme and reflects the ICC’s 6 sustainability requirements.

As per ESAP #9, as part of ESMS manual, BTE will prepare and implement a Supply Chain Management System (SCMS), including a Responsible Collection Policy (RCP) to achieve 100% traceability and risk screening across the entire feedstock collection network, and a Supplier Code of Conduct.  The Supplier Code of Conduct will require the prohibition of a child or forced labor to be present at the premises and the business to have adequate life and fire safety (L&FS) controls in accordance with PS1 and 2. BTE will prepare an audit methodology to assess the implementation of SCMS, including monitoring compliance using KPIs and a Remediation Plan for non-compliant businesses. 

Several large components required for the SAF plant from a range of international suppliers will be sourced through BTE’s EPC Contractor using an International Federation of Consulting Engineers (FIDIC) agreement. They will comply with AXENS’ (BTE’s technology and supervision consultant) Supplier Code of Conduct and Purchasing Policy. Consequently, the residual risks of child labor, forced labor, and life safety risks in the supply chain of international companies used for SAF processing infrastructure are very low.

 PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency:

The existing BTE operations consume 45 m3/day of water, including 24 m3/day of cooling water needs and 10 m3/day for sanitation facilities. Raw water is sourced from a 120 m deep groundwater well located within the plant premises. The SAF facility will require an additional 104 m3/day of raw water, which will be sourced from the existing well.

The annual water consumption per ton of product of the BTE plant in 2023 was 0.34 m3 against the resource consumption indicator benchmark figures of 1.6-2.0 m3/ton according to the WBG EHS Guidelines for oleochemicals manufacturing (2007). For the SAF plant, the annual water consumption per ton of feedstock input will be 0.19 m3, which is within the benchmark value of 0.07–0.66 m3/ton of processed material according to the WBG EHS Guidelines for Petroleum Refining (2016).

BTE has a Water Resource and Conservation Plan in place. Water consumption is monitored as a KPI, and the target is to achieve a 3% reduction in annual consumption over the next three years. Water conservation measures at BTE include maximizing line condensate recycling, boiler blowdown optimization, utilization of treated wastewater, a closed loop system for the vacuum pumps, and conducting regular maintenance of steam traps and cooling systems. The SAF plant will include a Sour Water Stripper to remove the contaminants such as ammonia and hydrogen sulphide from process wastewater, purifying it for recycling back into the plant's processes, reducing the need for freshwater intake.

The BTE plant’s energy demands (electrical and heat energy) are met by sourcing electricity from the national power grid and from the installed utilities, which include: two Heavy Fuel Oil (HFO)fired (2.45 MW combined capacity) generators as backup power source; two diesel-fired (1.76 MW combined capacity) for emergency use; two steam boilers (12 tons/hour combined capacity operating at 12.5 bars); and a thermal oil heater (750 cubic meters/hour capacity). A waste heat recovery boiler (1.5 tons/hr) is installed on the thermal heater exhaust to preheat the boiler’s intake water. The thermal heater and the two boilers are operated using bioheat oil and wood chips as fuel with an annual average consumption of 2,250 tons and 2,000 tons, respectively. Bioheat oil is generated internally in BTE biodiesel production from distillation of bottom sludge. The existing utility unit (power generation, boiler/steam, thermal heating) at BTE facility will be adequate to meet the additional energy demand of the SAF facility with an additional boiler (8 tons/hr) and a thermic oil heater. The utility interface point will be clearly defined for the SAF utility integration system as part of the AXENS-led engineering design.

The annual electricity and heat consumption per ton of product in the BTE plant in 2023 was 17 kWh and 1.09 Gcal respectively against the resource consumption indicators of 40 kWh and 0.44 Gcal according to the WBG EHS Guidelines for Oleochemicals Manufacturing (2007). The energy demand for SAF facility will be about 64 kWh/ton of product. High heat consumption in BTE plant is due biodiesel process requirement of full vacuum distillation for the 100% waste-based feedstock to meet the EU specifications. The BTE energy consumption per ton of product will reduce significantly with future SAF plant because the off-gases from the SAF production will be used to fuel the utility operations (boilers and thermal oil heaters). The use of off gases will also replace the use of bioheat oil and wood chips. The SAF process is a closed-loop operation without the need for process gas or a flare stack. Energy generated through off gases will be 25 – 12 G cal/hr for high and low cases depending on the free fatty acid (FFA) content of feedstock (higher FFA leads to more off gas).

Liquid Effluents: BTE plant generates 24 m3/day of process wastewater from the boiler blowdown and wet scrubbers, which is treated through an oil skimming process and a wastewater treatment plant (WWTP), an activated sludge process of 60 m3/day treatment capacity. The skimmed oil is reused in the process. Domestic wastewater is collected separately and treated in a septic tank. The treated wastewater from WWTP and the septic tank is disposed of into the area's agricultural drainage system. BTE has acquired permission from the Irrigation Department to dispose of the treated wastewater into the Ghazi Drain at a sanctioned discharge flow rate of 1.0 cubic meters per second (cusec). The wastewater-related KPI for the BTE plant, 0.172 m3/ton product, is below the industry benchmark of 0.9 - 1.3 m3/ton for biodiesel production according to the WBG EHS Guidelines for Oleochemicals Manufacturing (2007).

The SAF plant will generate about 4 m3/hr of process wastewater (sour water) which will be initially processed through a Sour Water Stripper followed by treatment in a wastewater treatment plant (WWTP) constructed under the SAF project. The WWTP will include a Reverse Osmosis (RO) system recycling 66% of the treated effluent back into the process, as a water conservation measure, and utilizing the RO reject in washing by the housekeeping.

BTE has a wastewater management plan in place and conducts wastewater quality monitoring quarterly through a third-party laboratory with reports submitted to the provincial EPA compliant to the local regulations. Treated effluent parameters monitored quarterly in 2024, 2023, and 2022 generally remained below the limit values set by the local standards, however, they sporadically exceeded the relevant WBG EHS Guidelines limits values for the BOD, COD and total suspended solids for disposal into the surface water body.

As per ESAP #10, BTE will ensure that the wastewater treatment plant (WWTP) for the SAF facility is designed, constructed and operated to comply with effluent levels defined by the national law and the WBG EHS Guidelines for Petroleum Refining (2016) effluent levels (Table 2). The WWTP of the SAF facility shall have adequate capacity to treat the effluent of the existing WWTP of the BTE facility. BTE will not discharge any effluent from the existing WWTP of the BTE facility into the area drainage system. BTE will undertake an integrity inspection testing of the existing WWTP (sumps) and associated pipework, develop and implement a plan to address any identified breaches in integrity, and improve the general safety conditions of the wastewater treatment plant. 

As part of the ESMS Manual, BTE will update its wastewater management and monitoring procedure, including the WWTP sludge disposal procedure, to align with the WBG EHS General Guidelines (2007) and the WBG EHS Guidelines for Petroleum Refining (2016).

Air Emissions: The existing utilities in the BTE include seven air emission stacks (4 for backup power generators, 2 for boiler, and one thermal oil heater stack). SAF project will add 2 stacks in the utility unit. (one for steam boiler and one for thermic heater). Stack emissions are monitored quarterly for environmental reporting as per the plant's environmental approval requirements. The air emission monitoring results performed for 2023 and 2022 for carbon monoxide (CO), nitrogen oxides (NO, NOx), sulfur dioxide (SO2), smoke, and Oxygen (O2) indicate compliance with the national law and WBG General EHS Guidelines (2007). BTE has installed air scrubbers on the boilers to mitigate air emissions. BTE operations have no process stack. The SAF plant will generate no process air emissions as the reactors will be operated under vacuum with all off gases utilized as fuel. As part of operational safety, a safety stack will be installed for acid gas flares in an emergency.

As per ESAP #11, as part of ESMS Manual, BTE will update the air emissions management and monitoring plan to align with the applicable requirements under WBG EHS Guidelines (General Guidelines and EHS Guidelines for Petroleum Refining and Oleochemicals Manufacturing) including the frequency of monitoring and the monitoring parameters, including particulate matter in the stack emissions and VOCs (mainly methanol) in the workplace/process emissions.

Noise: According to local legislation, BTE conducts quarterly ambient noise monitoring. The latest monitoring results (2023) at the plant's boundary confirmed compliance with national standards and the WBG General EHS General Guidelines. 

Hazardous Materials and Wastes Management: Most of the solid waste generated at the BTE plant is non-hazardous municipal waste disposed of in the municipality landfill through a local certified vendor. In 2023, the company generated 13.5 tons of non-hazardous waste sent to recycling or landfills, including 10 tons of municipal waste. As per the ESIA, the new SAF plant will add about 5 tons of municipal waste annually and will produce no significant quantities of hazardous waste.

Solid Waste Management Procedures and part of the ESMS are in place. BTE has engaged government-authorized vendors to dispose of wastes off-site. BTE will develop a Construction ESMP for the SAF plant, which will include management of construction wastes in line with WBG General EHS Guidelines (ESAP #3).

The hazardous materials stored at BTE plant include HFO, diesel, sulfuric acid, caustic soda (each stored in aboveground storage tanks (AST)) and methanol (in underground storage tank (UST)). SAF project will include 3 UST for methanol. Procedures for managing hazardous materials and spill controls are developed and implemented at the BTE plant. BTE practices for handling and storage of hazardous material include the installation of a SCADA system on the acid tank for storage volume monitoring, alarms fitted for overfilling warnings, installation of secondary containment, dedicated cabinets for storage of laboratory chemicals, and Material Safety Data Sheet (MSDS) in place. The ES due diligence recommended segregation of hazardous and non-hazardous wastes, improvement of secondary containment, labelling of hazardous materials AST, disposal of historical waste kept onsite, improvement of bulk materials unloading practices for spill control, and non-bulk hazmats drums storage in dedicated area with spill containment, labelling and segregation.  As per ESAP #12, BTE will conduct an audit of its hazardous substances and waste management procedures and practices which will include, but not be limited to, a review of (a) spill management during feedstock collection at source of origin and its unloading and storage at-site, (b) wastes storage and disposal including coal ash and waste slag management, and (c) secondary containment of the hazardous bulk storage tanks and oil/chemical drums. BTE will develop a time-bound Corrective Action Plan to implement the corrective actions identified in the audit. As part of the ESMS Manual, BTE will update its spill prevention and control management plan, hazardous materials management plan and waste management plan to address the gaps identified in the audit. The plans will meet the requirements of IFC PS3 paragraphs 12 and 13 and WBG EHS General Guidelines, will incorporate the findings of additional studies undertaken (such as HAZOP, HAZID, etc.), and include the appropriate engineering and management controls (procedures, inspections, communication, training, and drills) to address the residual risks.

Greenhouse gases (GHG): BTE monitors, documents, and reports its GHG emissions compliant to ISCC certification requirements. For every shipment of biodiesel to Europe, BTE provides evidence of sustainability which includes reporting of GHG emissions.

After completion of the SAF plant the total estimated annual GHG emission for the BTE will be around 86,559 tCO2e (Scope 1: 81,535 tCO2e and Scope 2: 5,024 tCO2e). The production of biodiesel and SAF will avoid emissions of 679,380 tCO2e per year, compared to using conventional diesel and jet fuel.

The company aims to achieve about 85% GHG savings from the biodiesel and SAF production process through advanced monitoring and tracking of energy utilization and wastewater management. BTE will save about 868,200 tons/CO2 emissions at full capacity operations.

PS4: Community Health, Safety and Security

Community Health and Safety: The BTE site is mostly surrounded by agricultural fields with sporadic community settlements and occasional industrial units. Adjacent to the south is a factory producing concrete components such as girders and roof slabs. The entire BTE site will have a boundary fence during construction and operations to prevent unauthorized entry.

BTE’s updated Emergency Preparedness and Response Plan (EPRP) will include a procedure to engage with sensitive receptors that may be impacted by an emergency situation (ESAP #13) and cover the entire site once the SAF facility has been constructed.

Road Traffic Safety and Transportation Management:  BTE has engaged two service providers utilizing 16 trucks to collect feedstock from each point of origin. The expansion of feedstock network during the operation of the SAF Project would require engaging about 20 trucks per day initially and reaching a peak of 30/day. Using dedicated tankers, BTE has also engaged a contractor to transport the biodiesel from the BTE plant to the port terminal. As of May 2024, there have not been any traffic accidents involving BTE operation-related trucks/tankers.

BTE is responsible for transporting the SAF products from their plant to the Karachi (a distance of about 1,200 km) seaport for off-take. The port has a dedicated area where several (liquid cargo) storage terminals are operating privately as existing service providers for the export and import of bulk liquid cargo. These terminals receive and store product and load it onto vessels through pipelines once the vessel is at the berth. The terminal operators comply with the regulatory procedures of the port and other government agencies (including EPA), which requires all service providers to have an implemented OHS management system that includes an emergency response plan.

BTE conducts at its facility a checklist-based safety inspection of each tanker before loading the product. The truck is also subjected to a safety inspection by the terminal operator before entry into the terminal is allowed to off-load the product.

During SAF production, the product transportation for off-taking would require about five tankers (40-50 tons capacity each) per day in initially and reaching max of 8 tankers/day at peak SAF production. BTE will identify, with the consent of the off-taker, the port terminal for the shipment and the contractor for road transportation of SAF at least 6 months prior to the start of SAF production. As per ESAP #1(iii), the updated ESIA will include assessing the risks associated with the road transport of processed products and their storage at a port terminal at the Karachi seaport for off-taking.

As part of the construction ESMP, a Construction Road Safety Plan covering transportation to and from the plant will be developed that describes the way in which road transport operations will be managed to reduce risks to community health and safety (ESAP#3). As per ESAP #14, as part of the ESMS Manual, BTE will establish and implement a Transport Safety Management Plan, which includes the assessment of a transport operator’s ability to manage E&S risks in accordance with national legislation and the PSs, and address the following as a minimum including the risk assessment and management; safety practices relating to vehicle, driver, journey, and transport of hazardous materials and; a questionnaire/checklist assessment for road transport monitoring. BTE will ensure that clauses in the agreements made with the third-party transport service providers adhere to the requirements of this Plan.

Security Personnel: BTE’s factory security is provided by a government-registered contractor company and includes 15 security personnel working two shifts. Additional security guards will be engaged for the security of the SAF plant. The hiring process includes internal screening by the security firm and a police verification report from the applicant's residence area. All security personnel are armed with weapons, have government-issued licenses, and are trained in handling the weapons. A Security Manager, a retired army personnel, oversees the security affairs of the company. A Security Risk Assessment Procedure and Security Management Plan are in place. To date, there have not been any incidents involving the security personnel. All security personnel have already signed BTE’s Code of Ethics. The Security Management Plan requires a bi-annual audit on the security provider to check their ongoing compliance. 

Life and Fire Safety (L&FS)  management: BTE's existing units, processes, and facilities are equipped with passive and active L&FS systems designed as per NFPA standards and include pumps, fire hydrants, hose reels, handheld and trolleys mounted large (Dry Chemical Powder, Carbon Dioxide, and Aqueous film farming foam (AFFF) type) extinguishers, and a central fire detection and alarm system comprising of smoke, and heat detectors and manual call points at different locations in the plant. Evacuation route maps, assembly point signs, and hose reels have been placed at appropriate locations. A dedicated underground concrete tank stores 67,000 gallons of water for 90 minutes of backup.

A Permit-To-Work System is in place for critical and spark potential activities. Electrical safety is ensured through preventive maintenance.  Procedures are in place for the safe handling and storage of flammable liquids. The company has a contract with a 3rd party firm to inspect and refile fire extinguishers. The Civil Defence Department annually inspects the company’s firefighting system. The inspection certificate for 2023 noted the installed firefighting equipment was in satisfactory working condition. The company conducts monthly internal fire drills and organizes annual firefighting trainings through the Civil Defence trainers.

As per ESAP #4, the updated QRA undertaken at the completion of the PDP phase of the SAF facility will cover a fire and explosion risk analysis and verify the adequacy of the L&FS system.  

 The ESIA process included BTE’s engagement with various stakeholders including the government departments, businesses providing feedstock, company workers, adjacent land users, and local communities within 5km radius of the site. Engagement with nearby communities included meetings with local community leaders, local residents (including women) and educational facilities. The process of the stakeholders’ consultation and its outcome are documented in the ESIA study. A standalone framework for a Stakeholder Engagement Plan (SEP) has been annexed with the ESIA study, which includes a detailed list of the stakeholders and outlines a programme of information disclosure activities and stakeholder engagement strategy. CSR activities are disclosed in the Annual Safety Reports of the company. As per ESAP #15 (i), as part of ESMS Manual, BTE will expand the framework for the SEP to establish a site-specific SEP commensurate with its business operations and in line with the requirements of IFC’s’ PS1.

BTE will update its community and external stakeholders’ grievance mechanism to include a process for submitting anonymous complaints (ESAP #15 (ii)). The company has hired two community liaison officers (CLOs) from the local community and under the staffing plan will hire one social expert at commencement of SAF project.

Company: SAFCO Venture Holdings Limited

 Point of Contact: Mr. Ali Shaikh

Title: Chief Executive Officer

Telephone Number:  +923344499712

Email: alishaikh@btechenergy.com