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Environmental classification and rationale
The project was
screened B/1, requiring an Environmental Audit and Environmental Analysis in
line with the Bank’s Environmental Policy and Public Information Policy. The
modernisation and expansion of an existing beer coolers assembly plant to a
wider range of commercial refrigeration equipment is associated with a number
of environmental issues, which can be readily identified, assessed and
mitigated as part of an Environmental Analysis. An Environmental Audit of the
existing facilities was undertaken to determine environmental risks and
liabilities.
Key environmental issues and mitigation
Environmental issues
associated with the manufacture of commercial refrigeration equipment are
fairly specialized and consist of hand assembly of components, mainly
manufactured externally. Some light manufacturing is undertaken on site and
environmental issues are associated with mechanical tooling and assembly. This
is associated with small use of oils, lubricants, degreasers as well as paints
used for coating of products. The painting operations will fall under EU VOC
requirements, and use of low emissions paint pistols is planned. A component
of operations is the injection of the coolant itself (R-134a) and on site
testing. These emissions, although small, are being quantified and plans exist
to review current operations to reduce fugitive emissions. R134a is not a
banned substance and still in commercial use. Plant operations also include
the preparation of a polymer/foam and small quantities of hazardous chemicals
are used on site.
Plant operations are not associated with process effluents, nor with the
generation of significant quantities of waste. However, some hazardous and non
hazardous waste needs to be disposed in licensed landfills. At present this is
not well organized, and much of the waste ends up in the municipal landfills.
As part of the environmental action plan this will be addressed to reduce
environmental and human risk.
Contaminated land was not judged as a significant issue, although further
investigations are planned. The local chemical works have a significant impact
on the local environmental quality. This is a regional issue, beyond the scope
of this specific project.
Environmental opportunities
The project will allow for some
environmental improvements, and the management is tracking both domestic as
well as international environmental legislation to ensure that products meet
international standards. This includes the need to ensure RoSH and VOC
Directive requirements are met. The project will allow for further expansion
of the operations and incorporation of dedicated social amenities as well as
strengthening overall corporate environmental, health and safety management.
Summary of Environmental Action Plan
The company will be
required to adhere to Ukrainian and EU environmental, health and safety
regulations and standards. All relevant permits will need to be obtained
during the planned expansion period and prior to commissioning the new
production lines. An Environmental Action Plan has been agreed with the
Company, focusing on improving waste management operations, monitoring of
emissions as well as ensuring all appropriate permits are in place. An
environmental management system will be developed at the plant within the next
2 years.
Disclosure of information and consultation
In the context of
the EBRD’s participation in the project, the Company has released locally a
summary of relevant environmental issues associated with the project and
summarise mitigation measures, action plans and other initiatives agreed.
Monitoring and reporting
The company will monitor the
environmental impact of its operations in accordance with national law and
regulations. The Bank will evaluate the project's compliance with the
applicable environmental and social requirements during the lifetime of the
project by reviewing annual environmental reports prepared for the project
covering:
(i) ongoing performance of project-specific environmental, health and safety
activities as reflected in the results of periodic and quantitative sampling
and measuring programmes, and
(ii) the status of implementation of environmental mitigation and improvement
measures. The Bank’s representatives will also conduct periodic site
supervision visits when deemed appropriate.
If required, the Bank will carry out monitoring visits to the plant.
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