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Screening categories and rationale for classification
An
Initial Environmental Examination conducted by the Bank’s environmental
specialist showed that the mill location and operations are not associated
with sensitive environmental, health and safety issues and that the
environmental impacts of the project can be readily identified, assessed and
mitigated. The introduction of BAT will reduce the emissions and discharges to
the environment from the present level despite the planned production
increase. The operation involves existing facilities and operations, which may
be associated with significant EHS issues. For the above mentioned reasons,
the EBRD has classified the project B/1, requiring an Environmental Analysis
and an Environmental Audit.
Information reviewed during the environmental appraisal
The
environmental appraisal has been based on the review of the Environmental
Analysis and Audit undertaken by international environmental consultant in
accordance with the EBRD's requirements in May 2005. The investigations
included an environmental site assessment, a field survey of the project area
and its surroundings, a BAT assessment and an assessment of the environmental
impacts of the project. The EBRD environmental specialist visited the site
and reviewed also other supportive technical and environmental documentation.
Key environmental issues and mitigation
Following the
transposition of EU Integrated Pollution Prevention and Control (IPPC)
Directive into Bulgarian law, Svilosa has been issued an IPPC permit requiring
it to meet environmental standards achievable with the use of Best Available
Techniques (BAT) for Pulp and Paper Manufacturing by October 2007. The project
is largely oriented at financing the investments required for meeting the EU
BAT environmental standards. The investigations showed that although the
production will be approximately doubled, the introduction of BAT will reduce
the emissions and discharges to the environment from the present levels. Air
emissions of sulphur dust and malodorous gases will be reduced by upgrading of
the evaporation plant, installing electrostatic precipitators for the recovery
boiler and the lime kiln, and installing a collection and recovery system for
high concentration malodorous gases from the pulp line. The process
modernisations and upgrades will improve resource and energy efficiency as
well as reduce water consumption and wastewater discharges. Also external
environmental protection measures will be implemented, including a mechanical
wastewater treatment plant and measures to improve waste management.
The key indirect environmental impact of the plant will arise from the
consumption of a considerable amount, up to 460,000 m3/a, of round wood. The
Company uses mainly small diameter hardwood (oak, beech and acacia), which has
little or no other use in Bulgaria. In addition, saw dust and sawmill residues
can be used to substitute some of the round wood. To mitigate the adverse
impact of the wood procurement and to ensure the wood is of legal origin, the
Company will adopt and implement wood procurement procedures that are based on
principles of sustainable forestry, ensuring that:
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the wood does not originate from statutory protected forests, forest areas
included in nature conservation programmes or sites which have been notified
by the authorities to be excluded from felling;
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the origin of the wood is monitored;
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suppliers operate according to the principles of sustainable development, in
compliance with the legislation currently in force and under the supervision
of state authorities; and
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the biodiversity and the functions of the forest ecosystem are maintained in
accordance with internationally and nationally approved principles.
Summary of Environmental Action Plan
An Environmental Action
Plan has been developed as part of the environmental due diligence to ensure
the mill will reach full BAT-level environmental performance within acceptable
timeframe. The EAP includes measures for further improving the wastewater
treatment (biological treatment), malodorous gas collection (low
concentration) and dust emission control as well as for improving waste
management. The EAP also includes a programme for setting up a wood
procurement control system ensuring sustainable use of forest resources.
Disclosure of information and consultation
In accordance with
the Bulgarian environmental permitting procedure information of the project
and the present activities of the mill has been disclosed to public on the
local level for the purpose of getting possible comments from the potentially
affected individuals and groups. Local newspapers have reported on the mill’s
activities. In the context of EBRD’s potential participation in the project, a
summary describing the relevant environmental issues associated with the
project and the mitigation measures has been disclosed locally.
Monitoring
The Company will systematically monitor and report
its environmental and health and safety impacts in accordance with BAT
guidelines to ensure it complies with Bulgarian/EU environmental standards.
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 by the Company, describing
ongoing of project-specific environmental, health and safety performance, and
by conducting periodic monitoring visits.
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