Environmental and social due diligence Saturn

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Environmental and social due diligence Saturn
Environmental and social due diligence
of the
Saturn Management,
Mondi Świecie CHP Biomass Project
Poland
Prepared for:
Polish Energy Partners S.A.
Prepared by:
ENVIRON Poland Sp. z o. o.
Date:
June 2009
Project number:
PL0586
Report status:
Final
ENVIRON POLAND SP. Z O.O.
ul. Bytomska 5A, 01-612 Warszawa
NIP: 525-22-90-477 REGON: 015637332
Kapitał zakładowy: PLN 517,000
KRS: 0000193459, Sąd Rejonowy dla m. st. Warszawy,
XIX Wydział Gospodarczy Krajowego Rejestru Sądowego
Tel: ( 0 ) 2 2 8 3 3 0 9 3 6 , 8 3 3 8 2 9 6 , 8 3 2 3 4 4 6 Fax: (0) 2 2 8 3 3 1 0 8 7
e-mail: [email protected]
Project No:
PL00586
Report status and issue:
Final Issue
Project Manager:
(signature)
Maciej Rozkrut
Project Director:
(signature)
Magdalena Trybuch
Authors:
Maciej Rozkrut, Leszek Andrzejewski,
Radosław Piechal
Date:
June 2009
This report has been prepared by ENVIRON with all reasonable skill, care
and diligence, and taking account of the Services and the Terms agreed
between ENVIRON and the Client. This report is confidential to the client,
and ENVIRON accepts no responsibility whatsoever to third parties to
whom this report, or any part thereof, is made known, unless formally
agreed by ENVIRON beforehand. Any such party relies upon the report at
their own risk.
ENVIRON disclaims any responsibility to the Client and others in respect of
any matters outside the agreed scope of the Services.
Polish Energy Partners S.A.
Environmental and Social Due Diligence
Poland
Contents
Page
Executive Summary
1
1
Introduction
4
2
2.1
2.2
Nature of the Project to be Supported
General Description and Context of the Proposed Project
Potential Environmental and Social Benefits of the Project
5
5
7
3
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
3.11.1
3.11.2
3.12
3.13
3.14
3.15
3.16
Environmental And Social Review of the Existing Facilities
Site setting
Geology and Hydrogeology
Site history
Site operations
Air emissions
Water sources and consumption
Wastewater management
Waste management
Noise
Storage of chemicals
Deleterious materials
Asbestos containing materials
PCB
Soil, Surface and Groundwater Contamination
Key Health and Safety Issues
Control of Major Accident Hazards
Current Health and Safety Monitoring Practice
Summary of Regulatory Compliance Status
9
9
9
10
10
11
13
14
16
17
17
17
17
18
18
19
20
20
21
4
4.1
4.2
4.3
4.4
4.5
4.6
Corporate Environmental, Health and Safety Management
EHS Policies and Practice
Organization of EHS Management
Environmental Permits
Contingency Planning and Emergency Procedures
Staff Training and Supervision
Internal and External Stakeholder Dialogue
21
21
22
22
23
23
23
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5
Compliance with National Regulations and EU standards
24
6
Potential for resource, energy and raw material savings
25
7
Biomass supply principles
25
8
Compliance with EBTD’s Performance Requirements
29
9
Environmental and Social Action Plan
31
10
10.1
10.2
10.3
10.4
Conclusions and Recommendations
Summary of Regulatory Compliance Status
Key Risks and Liabilities
Process Efficiency and Environmental Opportunities
Environmental Action Plan
31
31
32
32
32
Annex A: Site Maps/Plans
Annex B: Photo Log
Annex C: Environmental and Social Action Plan (separate volume)
Annex D: Stakeholders Engagement Plan (separate volume)
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Executive Summary
ENVIRON has completed an environmental and social due diligence (ESDD) audit of the
Saturn Management, Mondi Świecie CHP biomass project in connection with a proposed
EBRD financial provision for the project. Following the Bank’s request, the audit did not
comprise the full scope of ESDD and was limited to the top level review of the company to
ascertain the environmental and social standing of the company’s operations and their
impact, as well as the company’s ability to implement the EBRD Performance
Requirements. Moreover, the biomass supply chain was assessed and Environmental and
Social Action Plan (ESAP) as well as Stakeholders Engagement Plan (SEP) were
elaborated within the scope of this project. The work was completed by Mr. Maciej Rozkrut,
Leszek Andrzejewski and Radosław Piechal. The site was visited on 3rd and 4th June 2009.
The project to be supported by the bank consists of conversion of the coal fired steam boiler
into a modern, fluidized bed, biomass fired one, and auxiliary boiler’s installations. The
project aims at increasing CHP capacity in order to provide heat (in steam) and electricity to
a new production line of Mondi Świecie S.A. (Mondi). The decision on biofuel fired boiler
was taken due to economical reasons as well as on-site availability of the biomass,
however, the environmental issues were also taken into consideration while project
planning.
The CHP plant and the land occupied by the main and auxiliary installations is owned by
Saturn Management, however it is leased to Mondi. Mondi as a tenant bears full
responsibility for environmental permitting and reporting. Thus, the CHP plant and related
emissions (including waste generation), monitoring obligations and other environmental
aspects of CHP operations are regulated by an integrated permit common for the entire
Mondi facility. Besides, Mondi holds valid concessions for heat and electricity generations
and permit for participation in the ETS for CO2. No non-compliances were identified during
the audit with respect to possessed permits and operational practice of the CHP. The facility
appears to operate in line with the national and EU legal requirements and best practice.
Based on the evaluation of the available documents and observations taken during the onsite inspection tour as well as on information provided by the site representatives, ENVIRON
found no environmental, health, safety, and social concerns related to present and future
(after implementation of the project) operations of the facility. However, as predicted by the
environmental impact assessment and based on theoretical assumptions, the new boiler
may not meet recommendations for unit emissions of SO2 and NO2 from auxiliary boilers
given by the BREF for paper and pulp industry. All other BREF recommendations as well as
emission standards (that follow LCP directive) will be met. Moreover, the actual parameters
of biofuel used at the site (low sulphur content) and data from the same type boiler operated
in CHP in Białystok suggest that the BREF recommendations in actual conditions can be
met. Taking into account environmental benefits of the project (e.g. significantly less
emission of SO2 – by approx. 1000 tons/year, CO2 by approx. 117,700 tons/year and dust by
approx. 600 ton/year comparing to existing, coal fire boiler) implementation of additional
measures to reduce unit emissions of these pollutants is assessed as economically
unjustifiable and the BAT requirements seems to be fulfilled.
According to the cited above EIA report, completion of the project will not result in excessive
environmental impact of the facility (especially with respect to air emission and solid waste
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generation) that could cause breaches of the environmental standards. New integrated
permit will have to be obtained by Mondi in order to reflect the technical changes at the site.
Based on the actual emissions from the existing boilers and the predicted ones from the
new boiler it appears that the new permit will define permissible emissions in line with the
Polish implementation of LCP directive. Irrespective of an “emission source” definition (in
Poland it is understood as a “boiler” wherein in EU as a “stack” ), the CHP plant appears to
meet the LCP criteria.
The project, according to ENVIRON assessment will not create direct social benefits.
However, since heat and electricity supply to the new paper production line is crucial for its
operations, indirect social benefit is related to increase of the employment at the Mondi
facility and reduction of the unemployment in the area.
No issues of concern were identified with respect to environmental and social management
at the site. The company implemented a certified integrated management system according
to ISO 14001, PN-N 18001/OHSAS 18001 and ISO 17025 standards. Mondi also
implemented a certified management system based on ISO 14001, ISO 9001, PN-N
18001/OHSAS 18001 standards.
No issues of concern were identified with respect to air emission, water and wastewater
management, chemicals management and on-site deleterious materials.
The OHS management at the site is adequate. No issues of concern were identified.
The wood supply to Mondi and biomass (waste wood and other green waste) to Saturn
Management are assessed as adequate and in line with the EBRD requirements. Both
companies use the Forest Stewardship Council (FSC) or Program for the Endorsement of
Forest Certification (PEFC) chain of custody certification schemes to track raw material
supplies. Non-certified wood supplies are subject to company check against lawfulness of
trees felling and its place of origin. Any wood acquisition originating from protected areas or
acquired via an illegal felling, with violation of traditional and human rights is prohibited. In
both companies the wood procurement is regulated by procedures of the integrated
management system.
The operations of Saturn Management are in general in compliance with applicable EBRD’s
PRs, however a room for improvement was identified. The company should develop a
special procedure to verify its contractors and suppliers versus the requirements of PR2 –
Working and Labor Conditions. This issue was addressed in the ESAP attached to the
report. Also the project performance monitoring and review requirement which need to be
implemented at the facility are addressed in the ESAP.
The SEP was elaborated and attached to the report. As the project is in the stage of
advanced implementation, no further disclosure of information to the public is required. The
SEP defines the communication rules with other stakeholders. Communication with the
community is foreseen in response to complaints or other enquires. Special SEPs will be
elaborated in order to address the issues related to biomass procurement and transportation
related issues.
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No material issues of concern with respect to improvement of environmental or social
performance of the company or to achieve full compliance with the legal requirements were
identified within the course of this assessment.
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1
Introduction
ENVIRON has been requested by Polish Energy Partners S.A. (“the Client”, “PEP”) to
conduct an Environmental and Social Due Diligence Assessment (ESDD) of a Saturn
Management (company), Mondi Świecie CHP Biomass project (the “Project”). The project is
considered by the European Bank for Reconstruction and Development (“the Bank”, EBRD)
for provision of financing. Execution of the ESDD was required by the Bank as a part of a
Project qualification procedure, thus the scope of this ESDD followed the Bank’s
requirements and comprised:
•
Review of existing environmental and social documentation of the CHP and Mondi
Świecie that addresses environmental and social standing of existing operations and
facilities and the Company’s management systems.
•
Top level environmental and social review of Saturn Management operations and
planned investment program to ensure it is structured to meet the Bank’s PR’s. The
assessment focused on corporate management, investments plans and review of the
material EHS risks and liabilities associated with the Company's assets which need to
be resolved prior to the Bank committing to financing the project;
•
Assessment of current and future operations at Saturn Management CHP to ensure
the project is structured to meet current and future Polish and EU environmental
standards.
•
Review the fuel supply cycle for the biomass plant. This included a review of
sustainable wood procurement policies of Mondi Świecie, and assessment whether the
future supply of biomass to the Saturn Management CHP is/will be in line with EBRD’s
Environmental and Social Policy requirements (presented as an Annex 3 to the ToR as
EBRD wood procurement requirements) and international best practice for wood and
biomass supply.
•
Development of a consolidated ESAP based on existing documents and the ESDD.
•
Assessment of EHS and social benefits and opportunities that may occur from the
company’s proposed CAPEX for the project;
•
Development of a Non Technical Summary (NTS) of the proposed investment project
based on an existing EIA and the site visit to enable appropriate public consultation on
the project.
•
Development of a Stakeholder Engagement Plan (SEP) for the Company in line with
PR 10.
Following the Bank’s requirements, the ESDD was limited to the top level review of the
company to ascertain the environmental and social standing of the company’s operations
and their impact, as well as the company’s ability to implement the Bank’s Performance
Requirements (PR).
As part of the ESDD, a site inspection tour on 3rd and 4th June 2009 was conducted at the
company site in Świecie (the site, the facility) by ENVIRON consultants: Mr. Maciej Rozkrut,
Leszek Andrzejewski and Radosław Piechal.
The following sections present the project findings.
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2
2.1
Nature of the Project to be Supported
General Description and Context of the Proposed Project
Saturn Management (the company) operates a CHP plant located in Świecie, within the
borders of the Mondi Świecie S.A. (Mondi) production facility. The CHP plant as well as the
land of a total approximate area of 7.16 ha is owned by the company, however, it is leased
to Mondi. Moreover, based on a service contract of 29.04.2002, the company acts as a CHP
plant operator. Mondi bears all legal obligations related to CHP operations, including
concession for electricity production as well as environmental permitting and reporting.
Mondi is one of the biggest paper producers in Europe, specializing in manufacturing
corrugated case materials and sack paper. Annually the facility produces approximately
800,000 ton of paper. Sustainable development, with taking care of the environment and
safety and harmonious co-operation with local communities is the main philosophy of the
Mondi group. The facility operates under requirements of Pollution Prevention and Control
(IPPC) Permit. To properly manage its environmental impacts, the facility operates its own
slag and ash storage landfill (which is currently used only incidentally), surface water intake
on Wda river with water purification installations; wastewater streams generated during the
production process is treated on Mondi’s mechanical and biological wastewater treatment
station. Recently the facility has obtained an anaerobic wastewater treatment installation for
generation of methane. Methane as bio-fuel is planned to be combusted in the Saturn
Management boilers. Currently, the facility constructs a new paper machine with production
capacity of 470 000 ton per year, producing light weight recycled containerboard. Based on
review of the recent reports on audits conducted by State Environment Inspectorate, the
Mondi facility operates in line with the permit.
The project considered by EBRD for financing provision consists of conversion of the former
coal-fired steam boiler (K1, type OP-140) into a new, biomass-fired, fluidized bed (type BFB)
steam boiler as well as construction of new or remodeling of existing auxiliary installations.
The investment is directly justified by future increased demand for steam due to construction
of a new paper production line (No. 7) by Mondi. Although the decision on construction of
the biomass fuelled boiler was justified primarily by the economical factors, the
environmental benefits of such solution and on-site availability of fuel was also taken into
consideration while project planning.
The new boiler to some extent utilizes existing structures of the old boiler. However, the new
major parts (the chamber, pressurized part, automatics, flue gas ducts, electrostatic
precipitator, etc.) are constructed. The planned capacity of the new boiler is 100 ton/h of
o
steam with pressure 96 bar and temperature 510 C. For boiler ignition furnace oils will be
used, during the normal operation only biomass will be used. According to the performance
guarantee of the major parts of boiler producer (Metso Power), the maximum concentrations
of pollutants at the boiler outlet will not exceed:
3
•
300 mg/m for NO2;
•
200 mg/m3 for SO2;
•
400 mg/m3 for CO;
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and as guaranteed by the electrostatic precipitator supplier PM in flue gases will not
exceed 30 mg/m3.
•
The noise level at a height of 1.5 m and in a distance of 1 m from the equipment shall not
exceed 85 dB. The maximum auxiliary power consumption is 980 kW. Expected biomass
3
consumption is 34.6 ton/h and cooling water utilization 36 m /h. The total power capacity of
the CHP will increase by approximately 82MW th after project completion.
The legal procedure preceding the construction process (Environmental Impact
Assessment, obtaining of a building permit) was already completed at the day of site
inspection and the construction works have started. Prior to the day of site inspection the
following took place in relation to the boiler development:
•
on 30th June, 2008 the company applied for an administrative decision on the
environmental conditions for project acceptance (decision on environmental
conditions), attaching report on EIA required by the environmental law;
•
the administrative procedure related to issue of the decision on environmental
conditions was commenced on July 1, 2008;
•
on August 18, 2008 the company provided the authorities with an updated version of
the EIA;
•
on August 19, 2008 the company notified Starostwo Powiatowe (County Office) in
Świecie on commencement of the old coal fired boiler KW1 dismantling;
•
on August 21, 2008 the company applied to the authorities for the immediate
execution clause for the decision on environmental conditions;
•
on September 2, 2008, Burmistrz (Mayor) of Świecie issued a decision No. ROSiGK
7625/15/4/2008 on environmental conditions;
•
on September 9, 2008 the company applied for a change of the decision on
environmental conditions in order to correct wrong land plots numbering, the same
day the decision was respectively changed by the decision of Burmistrz of Świecie
No. ROŚiGK 7625/15/6/2008;
•
on September 24, 2008, Starostwo Powiatowe in Świecie commenced administrative
procedure related to issuing of a building permit;
•
on October 7, 2008 the building permit for construction of the new boiler and
auxiliary infrastructure was issued by the Starostwo Powiatowe in Świecie with the
decision No. 704/2008, which came into force on October 27, 2008;
•
in the 4th quarter of 2008 disassembly works of the boiler KW1 were completed
(insulation, brick walls, pressurized part of the boiler, instrumentation, electrostatic
precipitator, flu gas ducts, and auxiliary devices were disassembled);
•
in November 2008 construction of the bio-fuel supply installation was commenced;
•
by the end of 2008 the boiler supporting structures were renovated;
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•
in the beginning of 2009 the supply of the boiler parts and construction works
started;
•
since the beginning of 2009:
•
all foundation (civil) works are completed
•
the underground part of the external bio-fuel installation was completed;
•
equipment of the external bio-fuel installation (receiving hoppers and screening
station) was installed
•
short conveyor of the external bio-fuel installation between screening station and
existing conveyor from CFB boiler was installed
•
long conveyor of the external bio-fuel installation between screening station and
bio-fuel silo of BFB boiler is almost ready (actually status - 80%)
•
the boiler supporting construction was remodeled;
•
Bio-fuel silo and rest of internal bioline equipment are during assembly works
(actually status - 90%)
•
pressurized part of the boiler had been installed and accepted after hydro test by
the Urząd Dozoru Technicznego (Technical Supervision Office);
•
Boiler equipment (ducts, funs and another) are in the process of assembly works
(actually status – 50%)
•
New LUVO (rotary air preheater) is in the process of assembly works (actually
status – 75%)
•
new electrostatic precipitator was installed and commissioned (cold test).
For technical specification of the constructed boiler refer to the section 2.2.
In accordance with EBRD Environmental Policy (2003), the project has been assigned as a
category B requiring an environmental analysis of the planned investment, and an
environmental audit of the existing plant.
2.2
Potential Environmental and Social Benefits of the Project
The project is implemented as a measure to provide steam to the newly constructed paper
production line of Mondi. As estimated by Mondi, a new paper production line will increase
demand for steam and electricity by 50% in comparison to the current consumption. As
reported by the site representatives, theoretically increased demand for energy could be
covered by the existing boilers OP-140 working continuously under full load. Such work
regime, however, is technically unfeasible. Thus expansion of the CHP plant is crucial for
development of the Mondi company.
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In order to fulfill Mondi’s production requirements and minimize the environmental impact of
the future boiler operation, it was decided that the biomass fuelled boiler is to be installed.
Such decision was justified by the economical factors, however, environmental benefits and
compliance with Polish and EU policy on increase of renewable energy production was also
taken into account. An important factor was the on-site availability of biomass (waste
generated by Mondi) and company experience with this type of boilers gained during a few
years long exploitation of the CFB biomass or coal fired boiler.
Although operation of a new boiler will generate additional environmental impacts, mainly
related to air emission and ash generation, the overall impact of the plant as evaluated in
the EIA report prepared by Politechnika Łódzka in 2008, will not cause breaches of the
environmental standards and its impact will be generally limited to the area of the Mondi
facility.
The major environmental benefits of the Project, i.e. biomass fuelled boiler installations in
comparison with coal fired boiler installation are presented in the table below:
1)
2)
Parameter
Reference value
Expected value
emission of SO2
1258 ton/year
193 ton/year
reduction by approximately 1000 ton/year
dust generation
5243 ton/year
4625
reduction by approximately 600 ton/year
emission of CO2
347,700 ton/year
230,0003) ton/year
reduction by approximately 117,700 ton/year
Benefit
1) estimated for the coal fired boiler
2) estimated for the BFB boiler, based on ENVIRON calculations or provided by the company.
3) neutral for the environment since it will be generated by biomass incineration (it is widely agreed, that the amount of
emitted CO2 during incineration is equal to CO2 amount consumed by “living” biomass).
EIA assessment was mainly focused on organized emissions resulting from the new boiler
operation; the issue of biomass transportation, particularly by cars, was not widely
discussed/assessed within the EIA. As a part of EIA procedure public consultations were
conducted and no negative reactions were identified; the process of public consultations is
not addressed in the EIA report.
No direct social benefits of the project were identified, except for the creation of the working
places in the companies involved in equipment supply and construction of the boiler and
auxiliary installations. Indirectly the Project, as a crucial investment for the new paper
production line, will create the working places thus will positively influence the local
employment market.
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3
3.1
Environmental And Social Review of the Existing
Facilities
Site setting
The subject site occupies land plots owned by the State Treasury based on the perpetual
usufruct rights. The land and structures present therein are leased to the Mondi company.
The site occupies an area of approximately 7.16 ha situated centrally inside the industrial
properties of the paper producer – Mondi . The site occupies a regular, “L”-shape area
located roughly along the NW-SE geographical orientation. Most of the site area is occupied
by buildings, storage yards and auxiliary infrastructure (electrostatic precipitators, ash silo,
small slag storage, chimneys, biomass and coal storages etc.) of the boilers. The site is not
fenced but is entirely surrounded by the industrial facilities of Mondi .
The Mondi facilities are located in a distance of approximately 5 km to the west of the
Świecie town center, in a predominantly industrial area. The nearest sensitive areas
identified in the vicinity of the site are:
•
birds preserve area and Nature 2000 protection zone “Dolina Dolnej Wisły” –
approximately 3 km from the site
•
complex of landscape protection parks (Chełmiński and Nadwislański Parks) –
approximately 5 km from the site
•
forests protection complex (Leśny Kompleks Promocyjny) - approximately 7 km from
the site
•
hospitals, schools and water intakes – in a radius of 7 km from the site.
The nearest residential buildings are situated in a distance between 60 and 170 m from the
borders of the Mondi site.
3.2
Geology and Hydrogeology
The geological characterization of the site was prepared based on publicly available sources
(hydrogeological Map of Poland, scale 1:200 000), geotechnical report prepared for the
needs of the BFB boiler development (prepared by GEOTECH company in July 2008),
geotechnical report prepared prior to the installation of an above ground tank (prepared by
GEOTECH company in November 2005) and information from the EIA.
The site is located at the upper terrace of Vistula river built of Pleistocene fluvial deposits
represented primarily by various grained sands and gravels. Layers of Pleistocene clays and
silts with low permeability are of localized and discontinuous character in the region of the
site (with thickness of several meters). The average thickness of the Quaternary deposits
are of approximately 50 m in the region of the site. Below, there are Miocene deposits
developed in the form of sands.
The geotechnical drilling revealed presence of man-made fills as the superficial layer at the
site. The fill materials comprised sands and top soil mixed with construction debris as well
as hardstanding concrete layers. The thickness varied from 0.7 to 2.0 m. Below, sediments
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of natural origin were encountered. These were represented to the maximal depths of the
borings (15 m bgl) primarily by fine and medium grained sands with localized addition of
gravel fractions. In two of the completed boreholes a 1 m thick layer of sandy clay was
encountered.
Hydrogeologically, the site belongs to the region of Vistula Lower Valley unit with abstracted
aquifer formed within Quaternary and Miocene deposits. The Quaternary aquifer is
developed within sands and gravels at depths generally between 20 and 60 m bgl. Lower
lying Miocene water resources are abstracted from depth at top 90 m bgl.
According to the on-site geotechnical drillings performed in 2008, groundwater was
encountered at the site at depth varying from 2,8 to 8.5 m bgl. It was a continuous and in
general unconfined water stratum. It considered that the encounter water layer may be in
hydraulic contact with the abstracted Quaternary aquifer.
Due to the geological sequence the potential for migration of surface contaminants to the
uppermost groundwater layer is assessed as medium to high due to the lack of
impermeable layers.
3.3
Site history
Based on available information, the paper production facility and the subject CHP was
developed on an undeveloped land in 1960’s. In 2002 the CHP was purchased by Saturn
Management. The same year the site was leased to Mondi.
3.4
Site operations
The CHP plant operated by Saturn Management currently comprises:
•
two, pulverized coal-fired steam boilers, type OP-140, steam production 140 ton/h,
capacity 98 MW each;
•
one fluidized bed steam boiler, fired with bio-mass, hard coal or composition of biomass and coal, type CFB, steam production 234 ton/h and capacity 164 MW (100%
coal) or 180 ton/h and 126.2 MW (100% bio-mass);
•
four turbo-generators.
Additionally, steam generated by a recovery boiler operated by Mondi is used for electricity
production.
Steam generated by the CHP is used for technological needs of Mondi and for electricity
production. Produced electricity is entirely consumed by Mondi.
The coal for the OP-140 boilers is stored on a yard located to the north-west of the
buildings. The yard is hardened and drained to a common rainwater sewer via a coal
sedimentation tank. Coal is supplied to the boilers via conveyor belts. Part of the coal supply
installation (providing coal to the CFB boiler) is ventilated via a bag filter of efficiency of
99%.
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The biomass that comprises bark, wooden chips and shavings are stored on a yard to the
west of the main building. The yard is hardened and drained to the common rainwater
sewer. The biomass is supplied to the boiler via a conveyor belt, on which an electromagnet
is installed to separate metal intrusions.
The boilers are equipped with individual electrostatic precipitators of efficiency of 99.5%.
The precipitated dust is collected in the aboveground silos and then transferred off the site
by trucks. Fugitive emission during the truck loading is reduced by use of textile sleeves.
The coal fired boilers discharge flue gases to a common stack, 130 m tall, outlet diameter
3 m. The CFB boiler discharges flue gases to an individual stack, 100 m tall, outlet diameter
2.5 m.
The site is supplied with water from the Mondi mains. Technological water (for steam
production and cooling purposes) is used in a closed circuit system. Cooling water is cooled
in a ventilator cooling tower situated out of the CHP plant, however, still at the premises of
Mondi.
The annual production and fuel consumption is presented in the following table:
Coal
Biomass
Heavy oil
Electricity
produced
Recovery boiler
Heat provided
to Mondi
Year
1000
ton
GJ
1000
ton
GJ
ton
GJ
2006
130.3
3 030 284
481. 1
4 033 612
383,8
15735,8
367 626
4 893 173
175 504,87
7 651 611,02
2007
131.9
3 092 059
499.0
4 155 699
185,0
7586,64
384 797
4 926 779
219 970,84
7 696 230,71
2008
122.1
2 820 094
414.7
3 556 282
366,6
15030,6
291 994
4 948 949
219 666,36
7 571 088,40
MWh
GJ
MWh
GJ
Note: the yellow background indicate fuel consumption, the green one – heat (in GJ) and electricity (MWh) production
As explained by the company management, in 2008 one of the turbo-generators had
undergone a major repair, thus the total annual electricity production was reduced in
comparison to the previous years.
3.5
Air emissions
The major sources of air emission at the site constitute the steam boilers of the CHP plant:
•
two coal fired boilers, type OP-140
•
one biomass or coal fired fluidized bed boiler, type CFB.
The boilers discharge the flue gases via the tall stacks, a common one for the OP140
boilers and an individual one for the CFB boiler (for details see section 3.4). Prior discharge,
the flue gases are purified in the individual electrostatic precipitators of efficiency 99.5%.
Emission of SO2 is generally controlled by use of a low-sulphur coal ( below 0.6% of
sulphur), additionally from the CFB boiler such emission can be reduced by use of a dry
desulphurization method (addition of a limestone to the combustion chamber).
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The fuel incineration process is controlled automatically and the composition of the flue
gases is continuously monitored (CEM). The actual emission of pollutants can be reduced
by the operators by appropriate adjustment of the incineration process and composition of
the fuel.
Moreover, the following emission sources are present at the site:
•
two air vents of a limestone powder storage tank;
•
an air vent of a storage tank for sand used for fluidized bed;
•
the air vents of two bark storage tanks;
•
the air vents of two conveyor belts for coal transport to CFB boiler;
•
an air vent of a storage tank for ash storage;
•
the air vents of two coal storage tanks.
The emission from the plant sources is regulated by the integrated permit held by Mondi
(see section 4.3). The last change of the integrated permit (dated January 28, 2009) defines
different periods for which the emission limits are set up, however, such distinction is used
to reflect organizational and technical changes expected at the time for application of the
permit. The emission limits for the boilers reflect the emission standards adopted from the
LCP directive and implemented into the Polish legal framework. The permissible emission
limits are presented in the table:
Emission source
NO2
One or two boilers OP-140, stack
600 mg/m
3
1500 mg/m
CFB boiler, 100% coal
200 mg/m
3
200 mg/m
3
30 mg/m
3
CFB boiler, 100% biomass
300 mg/m
3
200 mg/m
3
30 mg/m
3
each of the other sources
-
SO2
PM
3
-
100 mg/m
3
0.0148 kg/h
As reported by the site representatives, no breaches of the permitted emission levels
occurred in the recent years. The average concentrations of controlled pollutants observed
in the period January-June 2009 are presented in the following table:
Emission source
3
3
3
NO2 [mg/m ]
SO2 [mg/m ]
PM [mg/m ]
OP-140 (K4)
458
1143
14.9
OP-140 (K5)
253
1121
24.6
CFB (K6)
138
11
8.5
The actual emissions are far below the permitted values, particularly in case of the CFB
(biomass fired) boiler.
Polish implementation of the LCP directive implemented definition of an “emission source”
as equivalent to boiler, wherein the EU interpretation commonly defines stack as such. Thus
it cannot be excluded, that in a future Poland will have to change the definition appropriately.
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For many Polish facilities change of the “emission source” definition will result in a need for
implementation of more strict emission standards than it is now (in general, the standards
are more restrictive following increase of the source capacity). This, however, will not affect
the subject plant since the emission standards remain the same both for one and two coal
boilers operating at the time.
The air emission register is maintained by Mondi. Mondi also calculates and pays the fees
related to air emission.
The CHP plant as well as the entire Mondi plant is allowed (by the decision No. ŚG.I.jw.7602-206/08/09, issued by Marszałek Województwa Kujawsko-Pomorskiego (KujawskoPomorskie Province Marshall) on February 27, 2009, valid until December 31, 2017) to
participate in the ETS for carbon dioxide. On average 318,335 allocation units per year was
assigned for the entire Mondi plant (including CHP) for the years 2008-2012. In 2008, Mondi
reported to emit 292,817 ton of CO2.
Conclusions
No issues of concern were identified with respect to air emission from the existing plant
3.6
Water sources and consumption
Water is supplied to the facility from the network of Mondi, based on the contract for
services provision of 2002.
The contract specifies the quality and quantity of water. Based on the civil contract, the
quantity of water supplied to the CHP is as follows:
3
Type
Quantity [m /day]
Drinking water
max. 35
Process water
max. 17 000
Demineralized water
Av. 3 000
max. 7 000
Treated water
In case of emergency max. 2 400
Raw water
max. 70 000
Fire fighting water
max. 1 000
Based on the obtained information these quantities where not breached by CHP.
Water mains located on the area of CHP are operated and managed by Mondi. Saturn
Management operates only these water mains which are located inside buildings operated
by Saturn Management.
Based on the obtained information CHP in 2007 used 8.000 m3 and in 2008 used 10.000 m3
for sanitary purposes. Flow, pressure and temperature of water are measured online by
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Mondi. Quantity of sanitary water is controlled in Mondi accredited laboratory and four times
a year by an external laboratory (SANEPID). Sanitary water is used predominantly in sinks
and toilets and as drinking water.
There are three main loops of technological water in CHP:
•
Process/cooling water used for cooling purposes of devices in CHP. After cooling,
water is directed to the cooling tower of Mondi. In emergency cases, when water
cannot be supplied to the cooling installation, post process water is discharged to
storm water discharge network (approximately 4% of process water per year). Saturn
Management controls temperature of cooling water online and content of oil once a
day.
•
Demineralized water – used for refilling a water-steam circuit because of the loses,
supplied from the purification station after deionization.
•
Cooling water – used for cooling of condenser of turbine no. 2.
Raw water for technological purposes is collected from Wda river, from water an intake
located in Kozłowo village, approximately 2,5 km north from the Mondi facility. Water is
pumped and directed via water mains into three reservoirs, of 4000 m3 of capacity each,
located at the area of Mondi. After treatment processes in “akcelator” tank (chemical
coagulation and sedimentation) and gravel filters water is pumped to the demineralization
station on cationic and anionic exchangers. Quality of water is monitored constantly and is
adequately regulated in the water purification station.
According to the Mondi representatives, the quality and quantity of supplied industrial water
is satisfactory and is not an issue of concern. During summer months (June – July)
occasionally the monitored parameters elevates, this relates to periodical algal bloom in
Wda river. Breaches do not last longer than 2 – 3 weeks.
Additionally, there is a chemical correction station working online installed in the CHP for
removal of oxygen and pH correction. Flow, pressure and temperature are measured online
in CHP. Quality of water is additionally controlled in Mondi Świecie laboratory.
Detailed conditions regarding water consumption are specified in the integrated permit.
Based on the information obtained from the representatives of Saturn Management, in 2007
CHP used on average 2924 m3 of demineralized water a day and 7608 m3 of process water,
and in 2008 on average CHP used 3009 m3 of demineralized water a day and 8055 m3 of
process water.
Conclusions
No issues of concern were identified with respect to water management.
3.7
Wastewater management
There are three types of wastewater generated on-site:
•
storm water;
•
sanitary wastewater;
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•
process/cooling wastewater.
All the wastewater streams generated at the site are discharged to Mondi sewage systems.
Storm water is discharged into the storm water system and prior to the discharge to Vistula
pretreated in a sand chamber and oil separating unit. Storm water from coal storage area is
directed to the storm water network via sedimentation tank. In 2004 Saturn Management
improved a drainage system at the areas of coal and bio-fuels storage.
Sanitary wastewater is generated mainly in toilets and other social facilities. Sanitary
wastewater is collected by sanitary wastewater system owned and operated by Mondi and
discharged to the biological waste water treatment plant. Treated wastewater goes to the
collector and then is discharged to the Vistula river.
Process wastewater is generated during cooling and used in a closed loop. Process
wastewater is cooled in two cooling towers (one owned by Saturn Management, other
owned by Mondi) and is redirected to the three raw water reservoirs or is used again in the
cooling process. Small quantity of process wastewater is discharged to the storm water
system.
Based on a lease contract Mondi is obliged to keep all permits necessary for operation of
the CHP. The tenant holds a valid Integrated Permit for groundwater abstraction and
wastewater discharge. Quality of wastewater (cooling water, sanitary wastewater and storm
water) is controlled by Mondi in their accredited laboratory.
Quality of wastewater prior discharge is controlled by Mondi. Detailed conditions regarding
wastewater discharge are specified in the attachment to the Integrated Permit hold by
Mondi.
Based on the civil contract, the quantity of wastewater discharge from the CHP is as follows:
3
Type
Quantity [m /day]
Discharge of sanitary wastewater
Max. 35
Discharge of process wastewater (post cooling water)
Max. 17 000
Discharge of storm and technological wastewater from the area of
CHP and coal storage area
Max. 1 260
Discharge of wastewater from biomass storage area
Max. 235
Conclusions
No issues of concern were identified with respect to wastewater management. According to
Mondi representatives, wastewater discharged by the CHP plant is of low volume in
comparison to the whole outflow from the paper plant.
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3.8
Waste management
The major waste streams generated by the CHP plant are the ashes and slag created by
coal and biomass combustion processes. The ashes collected in the electrostatic
precipitators and slag are collected in the storage tanks, from which they are transferred
directly off the site by certified contractors. The amount of generated ash and slag is
monitored by weighting trucks that transport ash for final disposal. In the extraordinary
situations (e.g. due to a temporary lack of a certified waste disposal company) ash can be
stored on a landfill owned and operated by Mondi. As reported, such situation happens very
rarely. The total amounts of ashes and slag generated by the CHP were 49,333 tons and
49,163 tons for the years 2008 and 2007 respectively and were below the limits set up by
the integrated permit.
The second most important stream of wastes are the waste oils (turbine, gearbox and
lubricants). These are temporarily stored in an indoor storage and then transported to a
major waste storage place of Mondi.
Other wastes generated at the site comprise municipal-type waste, metal scraps, as well as
hazardous waste sorbets and oiled cleaning agents and fluorescent lamps. These are
temporarily stored on-site and periodically transported to the main waste storage of Mondi.
Separate waste collection is implemented at the site.
Mondi bears all formal and legal obligations related to waste monitoring, transferring off and
reporting, based on a lease contract of 2002. The types and amounts of generated wastes
are regulated for the Mondi facility by the integrated permit.
From the legal point of view, incineration of biomass generated by Mondi and purchased by
Saturn Management is classified as a waste treatment. Such is allowed by the integrated
permit. According to the last change of the integrated permit (dated January 28, 2009), the
CHP can incinerate up to:
•
180,000 ton of bark and cork generated by Mondi and 480,000 ton from other sources;
•
40,000 ton of wood chips, sawdust, chipboards generated by Mondi and 480,000 ton
from other sources;
•
10,000 ton of waste paper generated by Mondi;
•
20,000 ton of fibres and sludge generated by Mondi;
•
72,000 ton of other wastes generated by production or use of grease, soap,
detergents, disinfection agents or cosmetics, generated by Mondi
•
480,000 ton of waste wood from other than Mondi suppliers.
The total amount of different biomass provided by external suppliers cannot exceed 480,000
ton.
Conclusions
No issues of concern were identified with respect to waste management.
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3.9
Noise
The CHP plant generates a noise emission related to operation of ventilators and other
equipment. As reported by Mondi representatives, in the previous years the facility was
responsible for excessive noise levels on the protected areas. Mondi implemented noise
reduction measures that eliminated that excessive impact, however, no noise emission
measures were needed to be installed at the CHP plant.
Conclusions
No issues of concern were identified with respect to noise emission.
3.10
Storage of chemicals
According to the chemical substances register maintained by the company, there are 87
substances used at the site which annual consumption varies between a few hundred grams
and approximately 400 tons per year. Based on the observations taken during the site
inspection tour, the substances are stored either in the manufacturers packages or in
containers or above surface storage tanks. As reported by the site representatives and
observed during the site inspection, no underground storage tanks are present on-site.
In majority, the chemicals are stored on secondary containments.
The oils are stored in two storages. In the first one the oils are stored in drums and
intermediate bulk containers. Secondary containment is provided by sloping the storage
floor down towards a no-outlet well. In the second storage the oil is stored in AST of 400 l
capacity and in the IBC. No secondary containment was observed there.
The facility is not classified as a one of increased or large risk of industrial accident, thus no
special obligations apply.
Conclusions
In general storage of chemicals at the site was observed as adequate, however, as a good
management practice secondary containments should be provided for all stored chemicals,
especially in the oil storage room.
3.11
Deleterious materials
3.11.1 Asbestos containing materials
Asbestos containing materials are known to be present only as a sealants in the turbine No
3 and installations of feed water and steam in a turbine hall. Total amount of ACM is
estimated by the facility as of approximately 120 kg. Reportedly the facility plans to remove
the existing ACMs in 2010 or 2011.
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Conclusions
It is recommended to conduct regular surveys of the ACM technical status, as required by
the law in force. The AMCs should be eliminated until the end of 2032. Cost of asbestos
waste handling is estimated at approximately €100-150 per ton.
3.11.2 PCB
As reported by the site representatives, no PCB containing equipment is present at the CHP
plant. The devices that could potentially contain PCB were tested for PCB presence.
3.12
Soil, Surface and Groundwater Contamination
The interviewed site personnel reported that they are not aware of any areas of soil
contamination. Reportedly there were no significant spillage accidents/releases in the recent
years.
Investigation focused on potential soil contamination was conducted at the area of Saturn
Management in 2001 by ERM company. The scope of completed works included drilling of
seven deep soil borings and taking of soil and groundwater samples for chemical analyses.
Additional, chemical analyses were performed on groundwater samples collected from four
existing piezometers located in the vicinity of the site. The chemical analyses covered wide
spectrum of parameters including among others heavy metals, aromatic hydrocarbons,
chlorinated hydrocarbons, polycyclic aromatic hydrocarbons, total petroleum hydrocarbons,
pesticides. None of the collected samples showed elevated concentration of analyzed for
parameters which might have indicated contamination of the site.
Reportedly, no more investigations focused on potential groundmasses contamination were
conducted at the site.
It should be added that Mondi Swiecie conducts regular (twice a year) monitoring of
groundwater on a net of approximately 30 piezometers located across the entire paper plant
and its landfills. Six of the piezometers are located in the vicinity of the site (two upgradient
and four downgradient). The spectrum of analyses encompasses inorganic parameters
including heavy metals (chromium, zinc, cadmium, copper, nickel and lead) and analyses for
the presence of oil and grease (one piezometer in the vicinity of the site). The results
generally do not indicate presence of contamination in the analyzed areas, however
elevated concentrations of oils and grease have been indentified in a piezometer located
downgradient of the site (approximately 200 m of the site), and downgradient of Mondi filling
station (potential source of contamination).
A soil investigation (required to be completed by the IPPC decision conditions) was
conducted at the Mondi plant in 2008. The scope of work included drilling thirty boreholes
and subsequent collection of two soil samples from each borehole. Further, the samples
were analyzed for presence of eleven heavy metals, BTEX, PAHs and phenols. One of the
boreholes was located between the two properties of Saturn. The analyses of shallow
sample revealed elevated concentrations of lead, zinc and copper (in comparison with the
“C” (industrial areas) limit values as laid out in the Polish Standards for Soil 2002).
Concentrations of the parameters were significantly lower in the deeper sample.
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In terms of potential risk of contamination, the current operations can be assessed as of
medium level. The site tour did not reveal any areas with potential contamination signs, no
soil discoloration was noted. The current housekeeping can be summarized as appropriate.
Further taking into account the results of the above investigations it is considered that the
risk for the site contamination is not high.
3.13
Key Health and Safety Issues
Although for a company of this size a H&S issues could be managed by the outsourced
experts or companies, the facility has appointed an HS officer (Mr. Adam Głowacki), who
reports directly to the top management. The top management reportedly follows HS matters
closely. The facility is certified with the PN-N 18001 (OHSAS 18001 management systems
integrated with ISO 14001 (environmental management system), and ISO 17025 (laboratory
management system).
There are two trade unions within the facility, both integrated with trade unions structure of
Mondi company. Approximately, 30-40% of Saturn Management employees are the
members of the unions, most of them belongs to “Solidarność” union the rest (approximately
10-20%) to OPZZ union. Reportedly, the contact between the trade unions and the
management is good and regular.
Saturn Management prepares a register of work related accidents, accidents on the way to
and from work for employees of Saturn Management. According to the register there were
two accidents at the operating department in the last six years of operation of the facility,
including an eye burn (2003) and breaking of tendon (July 2007), both not classified as
serious. According to Mr. Głowacki no fatal accident has happed at the site.
Apart from the above several accidents happened in external companies (outsourcing and
servicing companies). Based on information provided by Mr Glowacki these included:
•
2003 - group accident, (steam burns during construction of the CFB boiler)
•
2004 – one accident, electric shock
•
2005 – one accident, electric shock
•
2006 – no accident
•
2007 – backbone bruise
•
2008 and 2009 no accidents
None of the above historical accidents was classified as serious.
According to the summary, no work related diseases were registered in the Saturn
Management. Reportedly, there was one case of suspicion of work related diseases
(damage of hearing), however, that case was not classified as a work related by the State
Labor Authorities (decision from August 2008).
All working stands have a recently prepared, valid working stand risk assessments. All
employees undergo OHS induction training (performed by the OHS officer) and initial
working stand training (performed by the area or shift chief). The working stand training is
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periodically repeated. Each employee has an individual HS registry sheet in which his OHS
performance is noted, especially breaking of OHS regulations.
The workers are provided with appropriate PPE wherever it is required (this includes
primarily protective clothing including safety boots, gloves, hardhats, as well as glasses,
acid-proof aprons, harness securing against falls from heights and where necessary hearing
protection devices) and are encouraged and controlled to apply the equipment as
necessary.
The fire fighting facility is provided with a firefighting instruction. This included
characterization of the site structures and its fire fighting conditions, description of applied
processes, identification of explosion zones and zones with the risk of fire, characterization
of fire fighting installations, emergency procedures etc. The nearest fire-fighting brigade is
located on the Mondi facility and the fire-fighting system of Saturn is integrated with the
system of Mondi.
Based on provided information one fire was recorded in 2008 and one in 2007. The fire of
2008 was connected with sparkling on an installation during reloading/loading of straw, the
fire of 2007 was a self ignition on bio-fuel storage yard (occurred after 9 mounts of storage).
Following the fires and to minimize the risk of fire the site incorporated improvements in
operational practices i.e. straw is allowed to be stored in the vicinity of loading installation
only in amounts designated for an individual load; the bio-fuel stored in the piles is to be of
homogenous composition, without green fragments (source of volatile substances –
increasing the risk of self-ignition) and stored in a pile no longer than half a year. Currently,
the facility prepared a complex fire-fighting concept to minimize the risk of fire at the storage
yards and bio-fuels loading transporters.
3.14
Control of Major Accident Hazards
According to site personnel and reviewed documents (e.g. the recent EIA document) the
facility does not fall within the scope of working of the SEVESO II directive (control of major
accident hazard) implemented in the Poland within the frame of the Environmental
Protection Law. The facility is not provided with a safety report or a major accident
prevention policy.
The site has recognized zones where explosive atmospheres can be formed. These
included mainly internal zones within installations and tanks (installations for ash, coal, biofuels, transport/storage) and the room housing vehicles batteries loading installations.
Following the identification, the site has prepared an “Explosion Protection Document”
incorporating a risk assessment for all working stands under explosion hazard. The
explosive zones are marked.
The facility has prepared internal rescue-operations plan (last update February 2008 and
prepared procedure for reaction on accidents (last update March 2008).
3.15
Current Health and Safety Monitoring Practice
The facility follows an appropriate HS monitoring regime including periodical monitoring of
working stand conditions and employee health status. Internal audits are performed by the
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HS officer and Management System officer in order to fulfill regulatory and ISO 18001
requirements. In case that any breach of OHS rules is observed, a notice is made, followed
by an appropriate correcting actions.
Saturn Management is controlled regularly by Occupational Authority (PIP) and Hygienic
Authority (SANEPID). In the recent inspection report of SANEPID for May, 26 2009 three
inaccuracies were noted by the Authorities. These were about lack of accurate results on
hazardous factors measurements (tests of chemical compound in the laboratory, vibration
and tests on drills work stands) and two other minor issues related to the state of
social/sanitary equipment. According to the interview with Mr Głowacki all issues, when
recognized, are gradually corrected and/or updated.
The site conducts regular tests of working stands hygienic conditions (exposure), including
the following parameters measured: noise, coal dust, wood dust, hot microclimate,
vibrations, electromagnetic field and chemical compounds. The performed measurements
showed elevated noise levels in comparison with maximum permissible noise level in
several work places (mainly electrical and mechanical departments). Hot microclimate has
been also recognized at the facility. The levels of dust, vibrations, electromagnetic field and
chemicals did not exceed the maximum permissible limits.
Following the elevated levels of noise the facility prepares an action plan for improvement
work conditions, as part of the PN-N 18001 management system. The major planned
investments incorporated into the plan include development of casing constructions on two
turbo generators.
3.16
Summary of Regulatory Compliance Status
The audit has not revealed major incompliance issues at Saturn Management company.
Last control of SANEPID showed three inaccuracies including lack of accurate results on
hazardous factors measurements (tests of chemical compound in the laboratory, vibration
and tests on drills work stands).
Tests of working stands hygienic conditions (exposure) shows presence of hot microclimate
and elevated noise levels on several work places. In response, the facility prepares action
plan for improvement of work conditions to reduce the employees exposure to these factors.
4
4.1
Corporate Environmental, Health and Safety
Management
EHS Policies and Practice
Saturn Management has implemented the integrated management system based on
certified standards: ISO 14001:2004 (environmental management), PN-N 18001:2004
(Polish norm H&S management), OHSAS 18001:2004 (international H&S management) and
ISO 17025 (laboratory management system). The certificates confirm validity of the
certificates until August 2011, the laboratory management system is valid until February
2012.
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4.2
Organization of EHS Management
Environment management structure of Saturn Management is highly associated with
environment management system of Mondi. Environmental reporting, keeping the
environmental permits, contacting the environmental authorities in aspects where the
companies are associated (waste management, water supply, wastewater discharge,
groundwater monitoring, and air emissions) is the responsibility of Mondi. The site has
appointed a coordinator for ISO 14001 environment management system Ms Agnieszka
Cacałowska, who is responsible for monitoring environmental issues and providing input to
elaboration of the environmental part of the integrated management system. The
Environmental Coordinator reports directly to the operational director of the company.
The H&S Engineer (Inspektor ds. BHP), Mr. Edward Adam Głowacki, is in charge of H&S
matters within the company. His scope of responsibilities include: providing H&S training,
accidents handling and reporting as well as providing input to the H&S part of the integrated
management system – he is also appointed for coordination of PN-N 18001:2004 and
OHSAS 18001:2004 health and safety management systems. He reports directly to the
board of the company.
4.3
Environmental Permits
Mondi as the site’s tenant is responsible for all issues related with environmental permitting
and reporting. Mondi holds the integrated permit for the entire facility, including the CHP
plant. The integrated permit regulates all environmental impacts of the facility.
The integrated permit was originally issued for the Frantshacht Świecie S.A. by the
Wojewoda Kujawsko-Pomorski (Kujawsko-Pomorskie Province Head) with the decision No.
WSiR.III.6618/11/03 dated June 18,2004, valid until June 18, 2014. The permit was
changed by the following decisions:
•
of Wojewoda Kujawsko-Pomorski, No. WSiR-III-HF/6618/10/05 of May 23, 2005
(transfer of rights and obligations to Mondi Packaging Paper Świecie S.A.);
•
of Wojewoda Kujawsko-Pomorski, No. WSiR.III.HF/6618/64/06 of April 16, 2007;
•
of Wojewoda Kujawsko-Pomorski, No. WSiR.III.HF/6618/51/07 of September 26,
2007;
•
of Wojewoda Kujawsko-Pomorski, No. WSRiR.III.HF/6618/37/07 of December 14,
2007;
•
of Marszałek Województwa Kujawsko-Pomorskiego (Kujawsko-Pomorskie Province
Marshall), No. ŚG.I.hf.760-1/10/08 of June 27, 2008;
•
of Marszałek Województwa Kujawsko-Pomorskiego, No. ŚG.I.mc.760-1/50/08 of July
28, 2008 (transferring the right and obligations to Mondi Świecie S.A.)
•
of Marszałek Województwa Kujawsko-Pomorskiego, No. ŚG.I.mc.760-1/67/08 of
January 28, 2009.
All of the changes of the integrated permit reflected the technical and technological changes
that took place at the Mondi facility.
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Mondi also holds a valid permit for participation in the ETS for carbon dioxide. The permit is
given with the decision of the Marszałek Województwa Kujawsko-Pomorskiego, No.
SGiU.jw.760-2/206/08/09 of February 27, 2009 and is valid until December 31, 2017.
Mondi holds a permit for surface water intake, No. OS-II-6811/3/14/00 of November 7, 2007,
changed with the decision of January 3, 2001.
Electricity production by CHP is conducted based on the concession of Urząd Regulacji
Energetyki issued on July 10, 1998, valid until October 15, 2018 and heat production based
on concession of Urząd Regulacji Energetyki, issued on October 7, 1998, valid until October
15, 2018.
Based on the audit findings the CHP plant holds all necessary environmental permits.
4.4
Contingency Planning and Emergency Procedures
Based on findings of the audit it is concluded that the facility is not a major accident hazard
site and therefore it does not need a formally approved contingency plan.
The site has recognized zones where explosive atmospheres can be formed. The explosive
zones are marked and according to the ATEX regulations the site has prepared an
“Explosion Protection Document” as well as risk assessments for the area under explosion
hazard. In addition, the facility has a prepared internal rescue-operations plan for last update
February 2008 and procedure for reaction on accidents (last update March 2008).
The facility is provided with a firefighting instruction. This included characterization of the
site structures and its fire fighting conditions, description of applied processes, identification
of explosion zones and zones with the risk of fire, characterization of fire fighting
installations, emergency procedures etc. The fire-fighting system of Saturn is integrated with
the system of Mondi.
4.5
Staff Training and Supervision
Staff training is coordinated by the OHS Engineer. Comprehensive training programs are in
place for managers and production workers, with periodic refresher training. This training
includes key health and safety topics.
New employees receive initial basic health and safety, environmental protection and fire
protection training. The training is given by the H&S Engineer who also maintains a training
logbook that is individual for each of the employees. Following this initial briefing staff
receive work-stand specific H&S training, given by the superior in charge.
4.6
Internal and External Stakeholder Dialogue
As a limited liability company, Saturn is not obliged to publicly disclosure its environmental
or health and safety performance on a regular basis. However, external stakeholder
dialogue is conducted whenever it is required by the administrative procedures or law e.g.
during preparation of EIA when a public consultation is required and managed.
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As reported by the facility representatives, Saturn is also in touch with the local newspapers,
supports local organization “Przyjeciele Dolnej Wisły” and donates to local orphanage.
Internally, the company management conducts dialogue with the workers unions, conducts
regular every three months meetings with delegates of employees “Rada Pracowników”,
once a year prepares incentive meetings for all employees. Saturn Management was
honored in 2007 by the Labor Authorities as the best employer in the group of medium
companies.
The internal and external dialogue rules are drown up in respective procedures of integrated
management system implemented in Saturn Management.
5
Compliance with National Regulations and EU
standards
Based on the analysis of presented documents and discussion with the Saturn Management
and Mondi representatives the site appears to be in general in compliance with the national
regulations and EU standards.
The most relevant EU standards are implemented into the Polish legal framework by the
Environment Protection Act, Waste Act, Water Law Act, Greenhouse Gases Emission
Trading Act and others. The facility holds valid environmental permits (integrated permit,
water permit and permit for participation in ETS for carbon dioxide) that set up conditions of
company operation and emission in line with abovementioned Acts. During the audit no noncompliances with the permits’ requirements were identified.
The H&S and labor EU standards are implemented in Poland in the Labor Act. No noncompliances with that Act were identified during the audit.
According to the EIA report prepared by Politechnika Łódzka in June 2008, the new boiler
may not meet the BREF recommendations set for auxiliary boilers with respect to unit
emission of SO2 and NO2, however, the emission standards for these pollutants will be met.
As explained by the EIA report authors, the unit emissions of these pollutants were
calculated based on the theoretical assumptions and amounted:
•
for SO2 – assuming average sulphur content in biomass at a level of 0.03% the SO2
concentration in flue gases will amount 178.6 mg/m3 which equals to 35.3 mg/MJ, while
the BREF recommendation states the limit value of 15 mg/MJ or less;
•
for NO2 – for permissible emission (according to the emission standards) of
300 mg/m3, the unit emission will amount 118.6 mg/MJ, while BREF recommendation
state the limit values in the range 60-100 mg/MJ.
As estimated by the EIA report authors, the recommended BREF values can be kept for
biomass containing 0.013% of sulphur (unit SO2 emission factor will equal 14.1 mg/MJ) and
3
NO2 concentration in flue gas of 250 mg/m .
As observed at the site, the SO2 and NO2 concentrations in the flue gases from the
biomass-fired CFB boiler are much below the emission standards (refer to section 3.5), thus
it is likely that the actual unit emissions of these pollutants can meet the recommended
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BREF standards. According to the site representatives, the average content of sulphur in
the biomass oscillates around 0.01%. The emissions from BFB boiler operated in CHP in
Białystok (the same type, producer and capacity as being installed in Świecie) reveal
average concentrations of SO2 and NO2 in flue gases at 9.45 mg/m3 and 219 mg/m3
respectively.
Taking into account low environmental impact of the new boiler comparing to the coal one
as well as the fact that according to the EIA the facility after investment completion will not
cause environmental standards to be exceeded, and moreover, that available information
allows to predict that the BREF recommendations can be met, any additional measures for
reduction of SO2 and NO2 seems to be economically unjustified. The planned investment
appears to meet the BAT criteria.
To assure compliance with the legal regulations, prior to operational use of the new boiler
Mondi will have to apply for change of the integrated permit. Taking into account that the
original permit has been changed seven times already it is recommended to request the
authorities to issue the unified permit, that will incorporate all of the previous changes.
6
Potential for resource, energy and raw material savings
Based on the audit findings, the site management is aware of rational consumption of
resource, energy and raw materials, however, a room for improvement still exists. The
management of Saturn has accepted the modernization plan that includes in total 34 tasks,
which aim among others at maintenance and development of the production capacity as well
as increase of energy distribution and production efficiency and reduction of environmental
impacts. The plan was commenced in 2007 and is to be finalized in 2010. The plan includes
among others:
•
modernization of the water heating system in order to utilize waste heat;
•
construction of bark drying installation with use of waste heat.
According to the site management, no energy audit have been conducted at the site for the
last few years. Despite of the fact that the internal energy consumption is dominated by the
technological devices, a comprehensive energy audit can be recommended as a measure
for further energy consumption reduction.
7
Biomass supply principles
According to the Annual Forestry Report of 2007, there are 9,026 thousand ha of forests in
Poland, which is approximately 28.9% of the total area of the country. Among these 82.2%
are public forests and 78.2% are managed by Lasy Państwowe (National Forestry). The
forests are dominated by conifer sort (75.6%). Total gross volume of wood in the forests
was estimated as for January 1, 2006 to amount 1,909 mln m3. In 2006, 30,23 mln m3 of
wood was acquired, among which approximately 1 mln m3 from private forests.
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The forestry management in Poland is mainly regulated by the Act on Forests of September
28, 1991. The principal rule appointed by the Act is a sustainable development of the forest
resources, which is implemented by the national authorities and Lasy Państwowe and
applies both to the national and private forests. The sustainable development is introduced
among others by intensive forests area development and rational wood acquisition,
supported by long-term planning and monitoring.
Mondi consumes for technological purposes approximately 2,000,000 m3 of wood per year,
which in majority is provided from the in-country forest resources (managed by Lasy
Państwowe or private) and in some extent also from Belarus, Ukraine, Lithuania and other
countries. Wood is supplied to the facility by trucks (approximately 70% of the total wood
volume) and by railway.
Wood acquisition is regulated by strict procedure of the integrated management system.
Details regarding wood/biomass procurement are specified in a document “Zakup i kontrola
dostaw drewna” (“Procurement and control of wood supply”) . The main goal of this
document was to specify the procedures of wood and biomass procurement. Scope of the
document comprises procedures such as:
•
•
•
•
•
•
planning of supplies,
delivery performance,
supply inspection,
verification of biomass in regard to FSC,
vendor rating,
claim procedures.
The company use the Forest Stewardship Council (FSC) or Program for the Endorsement of
Forest Certification (PEFC) chain of custody certification schemes to track raw material
supplies. Both standards provide transparent and fully accountable processes for tracking
wood and fiber from the forest right through to use by consumer. The procedure also
accepts non-certificated wood supplies (e.g. if certified supplies are hardly available),
however, in such circumstance a detailed control is conducted by Mondi representatives (on
average every ½ of a year). The entire process of wood acquisition is documented.
Approximately 61% of the total supplies is certified, the remaining 49% is controlled. During
control a special attention is paid to lawfulness of trees felling and its place of origin. Any
wood acquisition originating from protected areas or acquired via an illegal felling, with
violation of traditional and human rights is prohibited by the procedure.
Mondi does not have any map of geographical location of wood catchment areas. A list of
suppliers is treated by Mondi as a trade secret and as such was not provided for review.
The project implementation will not change the process of wood procurement by Mondi,
since the new production line will utilize waste paper as a raw material. Increase of wood
consumption will depend on the technological needs of the existing lines, which currently
utilize also waste paper. According to the Mondi representative, it is estimated that after
start up of a new production line the wood consumption will increase by approximately
10,000 ton per year.
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The Saturn Management company utilizes as a bio-fuel waste biomass generated by Mondi
(approximately 200,000 ton/year) or acquired from external suppliers (approximately
300,000 ton a year). After project implementation the total biomass consumption is
estimated at approximately 600,000 ton/year. As reported by the site representative,
biomass acquisition by the company is regulated by a procedure of the integrated
management system. Just like Mondi, Saturn Management uses FSC or PEFC chain of
custody certification schemes to track raw material supplies, or, alternatively conducts
control of the suppliers if the waste wood supplier cannot provide appropriate certificate.
Approximately 59% of the suppliers is certified, the remaining 41 – controlled. The scope
and aim as well as selection criteria of such control are the same as in case of Mondi. The
biomass purchased by Saturn Management from the external supplies originates from
sawmills, wood processing plants, forests (forest residue only), road maintenance works,
agricultural green waste. etc. The biomass to the CHP is and will be (after project
completion) delivered via truck transport, directly from the suppliers. The biomass main
suppliers are listed in the table below and the supply geographical structure is presented in
the figure 1.
Supplier
Planned purchase volume of biomass for 2009
[natural cubic meters]
QUERCUS Sp. z o.o.
31 500
PPHU "DREWPOL" Sp. z o.o. JV
0
USŁ.ZAKŁAD TRANS. A. DĘBNY
44 000
P.H.U. "SJ - SOLO" JERZY SEKU」A
49 000
FIRMA - Ex Pro
50 500
COMPLEX
47 500
PPHU " TRANS DREW " S. BEDNAROWSKI
0
P.W. "ELDREW" S.C.
22 000
ŁĄCCY-KOŁCZYGŁOWY Sp. z o.o.
26 500
ANDREWEX sp z o.o.
24 000
P.W. " ELMIR " s.c.
32 000
DELTA GARTENHOLZ POLSKA
72 000
PPD POLTAREX Lębork
47 000
Z.O.D KOŁODZIEJCZYK ROMAN
25 000
ABWood Sp. z o o
12 000
SPIL - TRANS s.c. A.Spiliszewski
26 000
P.P.U.H . "PAULA" Witold Wicher
23 500
ZAKŁAD DRZEWNY K. Leśnicka
23 000
PPU " DREWAR " Jan Wardyn
10 000
Zakł. Prod.Usługowy DOLINA s.c.
14 000
Total I group of suppliers
579 500
Other suppliers II group)
179 500
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Fig. 1. Geographical structure of a biomass supply to Saturn
Both Saturn Management and Mondi do not use their own truck fleet for biomass
transportation, such service is provided by external companies. No wood/biomass depots
are managed by Mondi or Saturn management. The biomass is transported directly from the
place of origin to the facility.
The truck transport of the wood/biomass to the facility is conducted between Monday and
Saturday (2 p.m.), 24 hours a day. As reported, currently approximately 150 trucks per day
deliver wood to Mondi and another 90 trucks per day deliver biomass to Saturn
Management. After the Project implementation it is estimated, that the number of deliveries
will increase respectively to 165 and 130 (160-180 maximum) trucks per day. The road
transport does not affect the citizens of Świecie since a town bypass road provides access
to the site without entering the residential part of the town. The maximum intensity of the
average truck traffic will increase due to the Project implementation from approx. 10 trucks/h
to 12 trucks/h (maximally 15/h). Neither Mondi nor Saturn Management have special traffic
management system at the moment and do not plan to develop any after the completion of
the project. The traffic is regulated by general road traffic code.
ENVIRON evaluates the biomass supply scheme of Saturn Management as adequate and
in line with the Bank’s requirements. As expansion of the existing procedures it is
recommended to develop a biomass supply chain auditing program to gain a full control on
the biomass origin.
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8
Compliance with EBTD’s Performance Requirements
Assessment of the Saturn Management operations and planned investment program versus
the Bank’s Performance Requirements (PRs) is presented in the table below.
PR
1. Environmental
and Social
Appraisal and
Management
Status
Compliance assessment
The company implemented a certified integrated management
system based on ISO 1400, PN-N-18001 (OHSAS 18001)
and ISO 17025 standards. The system provides systematic
approach tailored to the nature of conducted activities to
managing environmental and social risks.
The company is compliant
with the PR1 as for this
stage of the procedure.
ENVIRON assesses, that
the requirements set out in
PR1 that refer to later
stage of the project (e.g.
performance monitoring
and review requirement)
can be fully met by the
company management.
The company is aware of environmental and social
consequences of the project. The EIA of the project was
conducted. The expected impact of the project is limited to the
industrial area of the CHP plant and Mondi.
The company conducts annual internal due diligences on
compliance with appropriate legal, environmental and H&S
requirements.
For ESAP please refer to Annex C.
The company will assign people responsible for
implementation of the ESAP.
The contractors involved in the project execution must present
environmental impacts related to their on-site activities, are
selected based on their experience and ability to conduct their
work in line with environmental and H&S standards and
regulations. The contractors are supervised by the company’s
people of adequate responsibility.
The company monitors execution of the project.
The company management proved their willingness to follow
the Bank’s PRs
2. Labor and
working
conditions
The company operates following the human resource policy
which is adopted to the size of the company and fully reflects
the Polish labor regulations. The OHS issues are regulated by
integrated management system (part of the system related to
PN-N 18001/OHSAS 18001).
The terms of employment and working conditions are known to
the employees and appropriately documented.
The company follows the national regulations and Bank’s
requirements with respect to child labor.
No forced labor takes place at the site.
No-discrimination and equal-opportunity standards are
implemented in the company.
There are two workers unions operating at the site.
Wages, benefits and conditions of work are comparable to
these operating similar facilities in the area.
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The company is compliant
with PR2 except for
contactors and supply
chain verification against
PR2 requirements.
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No non-compliances with respect to OH&S were identified.
The requirements listed under article 13 of PR2 are met.
The company does not provide accommodation to workers.
The company does not plan to anticipate collective dismissals.
The grievance mechanism for workers is provided by a
respective procedure of the integrated management system.
The non-employee workers (employees of the contractors) are
provided with appropriate training on H&S rules in force at the
site. The compliance of the contactors with the requirements
set up by the PR2 is not verified prior to assignment.
The supply chain is not verified against the requirements of the
articles 20 and 21 of PR2
3. Pollution
prevention
and
abatement
The project was verified by the EIA to be compliant with
applicable national and EU requirements for the pollution
prevention and control. The only deviation of this requirement
is that according to the EIA, the BREF recommendations for
unit emission of SO2 and NO2 may not be met, however, the
emission standards of these pollutants are guaranteed. Based
on the company experience with biofuel incineration and on
emission data from the same type of boiler it is likely, that the
BREF recommendations can be entirely met.
The project implements state-of-the-art technology that
minimizes environmental impacts. According to the EIA, no
breaches of the environmental standards will occur due to the
boiler operations and the emissions (including generated
wastes) will be as far as possible limited.
The project implementation will not significantly increase use
of hazardous substances at the site. The company’s
hazardous substances was assessed as adequate, however,
some room for improvement exists (e.g. application on
secondary containments to all chemicals used on-site).
The company is compliant
with PR3. A compliance
with the BREF
recommendations for unit
emissions of SO2 and NO2
should be verified after
project implementations.
Potential non-compliance
with these BREF
recommendations is
considered as of
secondary importance,
since all other
environmental factors of
the constructed boiler are
in line with the law in force
and implementation of any
additional emission
prevention measures
would be economically
unjustifiable.
Emergency preparedness and response at the site is
assessed as adequate. The Project implementation will not
require significant changes to the existing procedures.
The company already conducts continuous monitoring of air
emissions, monitoring and recording of other environmental
impacts is conducted by Mondi.
Based on the data provided by the company, implementation
of the project will cause generation of 230,000 ton of CO2
annually. Due to incineration of biomass this emission, will be
neutral for the environment. As estimated by Mondi, 348,520
ton of CO2 would be generated if coal fired boiler (existing one)
would be used for steam production instead of the biomass
fired one.
4. Community
health, safety
As assessed by the EIA, the project implementation will not
environmentally affect the community. Some negative impact
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Not applicable.
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and security
can be related to transport of biomass, however, it is estimated
by ENVIRON as of low importance. Based on the data
provided by Mondi and Saturn Management, after project
implementation the traffic load will increase from
approximately 10 to 12 (maximally 15) trucks per hour. The
trucks do not pass the town of Świecie on their way to the
facility.
5. Land
Acquisition,
Involuntary
Resettlement
and Economic
Displacement
Not applicable
Not applicable
6. Biodiversity
Conservation
and
Sustainable
Management
of Living
Natural
Resources
This PR is applicable exclusively with respect to the biomass
supply chain.
Not applicable
The company purchase a biomass following the procedure
defined by the integrated management system. Purchase from
the certified (FCS or PEFC) suppliers are proffered. In case of
non-certified suppliers, the verification and control of the
supplier is conducted in order to eliminate a risk of biomass
purchase of illegal origin.
7. Indigenous
Peoples
Not applicable
Not applicable
8. Cultural
Heritage
Not applicable
Not applicable
9. Financial
Intermediaries
Not applicable
Not applicable
10. Information
Disclosure
and
Stakeholder
Engagement
For Stakeholder Engagement Plan please refer to Annex D.
9
Environmental and Social Action Plan
For the environmental and social action plan please refer to annex C.
10 Conclusions and Recommendations
10.1
Summary of Regulatory Compliance Status
No regulatory non-compliance issues were identified in this audit. Recommendations related
to future needs in order to keep compliance status are presented in the Environmental
Action Plan.
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10.2
Key Risks and Liabilities
No significant environmental risks or liabilities were identified.
10.3
Process Efficiency and Environmental Opportunities
The process appears to be efficiently operated. Project implementation will result with low
environmental impacts comparing to existing coal fired boiler.
10.4
Environmental Action Plan
An Environmental Action Plan (EAP) derived from the findings of this audit is presented in
Annex C of this report.
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Annex A:Site Maps/Plans
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Figure 1. Site location
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Figure 2. Site layout
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Annex B: Photo Log
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Photo 1: Power transforming station located near the northern border of the site.
Photo 2: Aboveground tanks for temporary storage of ashes from combustion process.
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Photo 3: Coal storage area with sedimentation basins in the east of the site.
Photo 4:
In the foreground, biomass transporting line (the blue one) and offices of SM.
In the background heaps of biomass on the biomass storage area.
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Photo 5:
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Construction of biomass transporting line, located in the south of the site.
Picture taken towards north.
Photo 6: In the foreground – coal storage area. In the background – CFB boiler.
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Photo 7: Ash storage area in the center of the site.
Photo 8: Installation of new BFB boiler.
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Photo 9: Power generating hall with turbine set.
Photo 10:
Properly marked information on asbestos located as a sealants in the turbine
set No. 3
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Photo 11:
Oil storage area - secondary containment provided by sloping the storage
floor down towards a no-outlet well.
Photo 12:
Turbine oil storage area. Oil stored in AST’s on a concrete floor, without
secondary containment.
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