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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 EBRD’s Environmental Policy and Public Information Policy. The
modernisation of the existing cement plant focussing mainly on rehabilitating
an old line is associated with a number of environmental issues, which can be
readily identified, assessed and mitigated as part of an Environmental
Analysis. The Environmental Audit and Analysis has been undertaken by an
independent consultant.
Key environmental issues and mitigation
The key environmental
issues are associated with dust emissions from point and fugitive sources.
Due to lack of funds for maintenance and repairs, and overall lowering of
demand for cement in the early 1990s, the dry lines where mothballed and not
used. The plant has relied on the less efficient and more polluting wet lines
for production purposes. The performance of the existing environmental
abatement equipment has gradually declined and dust emissions are a problem at
the plant. This affects both the local ambient air quality as well as
employee health and safety. A considerable amount of product is also lost as
a result of the poor condition of dust arrestment equipment, which also has
economic implications.
The planned modernization will focus on re-commissioning one of dry cement
process lines with key process elements being newly constructed incorporating
relevant environmental abatement equipment. The modernized line will be
designed in line with EU IPPC requirements inclusive of dust, SO2 and NOx
controls. As part of the investment programme an environmental management
system will be incorporated into day-to-day operations at the plant. A
continuous monitoring system will be installed on the rehabilitated dry line.
Additional investments will be made at the wet lines focusing on air abatement
equipment aimed at significantly reducing dust emissions and improving worker
health and safety. The wet lines may remain in operation depending on market
conditions and additional investments may be required in the future to ensure
compliance with international best practice.
Water consumption and wastewater discharges are an issue at the plant as the
wet process lines result in higher water use. Although there are no reported
problems with the current systems in place, and the water and wastewater
management meets local requirements, the plant has committed to reassess the
water management practices in due course once the dry line is operational.
Waste has been an issue at the plant, mainly associated with waste product and
dust deposited on structures. Construction debris and redundant equipment is
also an issue. The environmental action plan includes measures for addressing
these issues to reduce environmental and human risk.
Asbestos is used at the plant, and the modernization programme will include
the development of an asbestos management plan to address this issue. Overall,
the health and safety culture at the plant has been unsatisfactory and will be
upgraded as part of developing an environmental, health and safety management
system.
Environmental opportunities
The proposed project is expected to
bring significant environmental benefits as the re-commissioned dry plant will
be operated to modern internal environmental standards and have a higher
overall efficiency. Investments at the existing wet lines will also allow for
substantial improvements to be made to the environmental management and
operation of the plant. The increased efficiency of the dry line is likely to
lead to reduction of dust and lower energy use per ton of cement produced.
This will yield possible carbon reduction opportunities. The ERBD is
progressing this issue and some additional investments may take place once
Kazakhstan ratifies the Kyoto protocol.
Summary of Environmental Action Plan
The Company will be
required to adhere to Kazak environmental, health and safety regulations and
EU environmental standards. All relevant permits will need to be obtained
during the modernization process.
An Environmental Action Plan (EAP) has been developed following the due
diligence and has been agreed. The EAP addresses inter alia air emission
control, need for continuous air monitoring systems, asbestos management,
house keeping, and the overall management of the environment, health and
safety issues at cement plant and associated auxiliary operations. An updated
environmental assessment, focused on benchmarking with best international
cement manufacturing standards (including EU IPPC) is to be undertaken by 2008.
Monitoring and reporting
The Company will monitor the
environmental impact of its operations in accordance with national law and
regulations. The EBRD 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 EBRD’s representatives will also conduct periodic site
supervision visits when deemed appropriate.
An update environmental assessment is to be undertaken by an independent
consultant in 2008.
If required, the EBRD will carry out monitoring visits to the plant.
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