Site Assessment of a Russian Metal Fabrication Enterprise
This report was submitted by Ed Shoener, ECOLOGIA EMS technical consultant, summarizing a walk-through audit and preliminary EMS consultation with a Russian copper tubing manufacturer. The name and precise location of the company are deleted at the request of the factory managers.
The facility is part of a larger holding company, which owns a number of diverse facilities, from timber to mining to metal works. The manufacturing facility has been in operation since the 1970's. It produces metal products of various shapes and sizes. Currently the facility employs about 2000 people.
ISO 9002 Certification
The facility obtained ISO 9002 certification from an international certifying body in 1995 and was re-certified in 2000. The company decided to obtain ISO 9002 certification primarily for marketing reasons. Foreign competition was hurting the company and it was loosing market share even in Russia. Competition from foreign enterprises, primarily Italian, was putting the company in serious financial difficulty.
ISO 9002 certification stabilized the economic situation of the company. It now can produce a product of consistent and predictable quality and is successfully competing in the Russian market. Its improved quality, along with lower production and transportation costs, has allowed it to regain market share in Russia.
Company management believes that ISO 9002 certification has helped increase efficiency. It has improved its process of internal monitoring and documentation. The process has affected all employees, and the company now has contests and rewards for improved efficiency and quality.
The company has established a separate QA/QC staff that is responsible for ISO 9002. This staff maintains all of the 9002 documentation. The QA/QC staff director reports directly to the General Director of the facility.
The holding company has a person who is in charge of environmental management for all of the holding companies facilities. Her duties appear to be mainly compliance management. On the staff of the Technical Director for the facility are 3 people who are responsible for environmental monitoring and compliance at the facility.
The current management system is clearly focused on "end-of-pipe" compliance. Although we did not talk with any local regulatory authorities, it appears that the facility is in substantial compliance. A wastewater treatment system with a sand filter and a membrane filter for finishing was installed in the early 1990's. Company data shows that it has been effective in maintaining reduced pollution levels. Air emissions levels are monitored about twice per year. The air emission levels were calculated using an air dispersion model. Company representatives stated that they are in compliance, although we did not see any air pollution control equipment.
The holding company does have a general written environmental policy, and an environmental administration plan is periodically developed and signed off on by the General Director and Chief Engineer. An emergency response document has been developed which focuses on response to fires and explosions.
We were given a brief tour of the production building, the smelting building and the wastewater treatment facility.
Metal Products Production - The building and production equipment is over 20 years old. Due to the ISO 9002 requirements, a great deal of attention is paid to controlling off-spec production. As a result, over 50% of the production is rejected at some point in the production process. This rejected material is recycled.
Probably due to the age of the equipment, there were numerous oil and lubricant leaks. These leaks were being "sopped" up with sawdust and collected for off-site disposal.
There appeared to be very little, if any, off-site environmental pollution directly caused by this unit (i.e. waste water or air emissions). However, the production facility is old and creates a number of indirect environmental problems. For example, the high rate of product rejection results in increased energy consumption and smelter use (and associated air emissions). The leaking equipment results in the generation of large amounts of waste material that has to be disposed of in an off-site landfill.
Smelting Building - Air emissions from the smelting operation are collected and vented directly to the atmosphere. There does not appear to be any air pollution control equipment. However, the company claims to have used an air dispersion model to demonstrate that the emissions do not exceed the local environmental standards.
Cooling water is sent to the wastewater treatment system. Company representatives state that organic greases are difficult to handle due to their insolubility and that a switch to inorganic greases is being considered.
Waste Water Treatment - This building appeared to have the most modern equipment and was the cleanest and best maintained facility. A series of pressure sand filters and membranes filters are used. An automated control room was used to monitor and control the treatment system. Sludge from the treatment facility contains up to 18% pure copper and can be sold to metal recyclers for further processing.
We met with the Assistant Energy Director. The facility does not produce its own energy but purchases energy from other producers. The energy department views its main mission as managing energy use and costs at the facility. It does this by negotiating energy contracts and calculating paybacks for various investments to reduce energy consumption.
Meters have been installed on all the main energy consuming devices, and this has led to lower energy consumption (you manage what you measure). Additionally, water reuse and the installation of more efficient nitrogen lighting has led to a reduction in energy consumption of about 30% in the last two years.
Walk-Through Audit: Comments and Recommendations
The facility has many of the elements necessary to put together an ISO 14001 type EMS. There is an environmental policy, an operations plan, an emergency response plan, and the ISO 9002 system has introduced the concept of documenting procedures and monitoring to the facility.
The area that needs to be focused on first, however, is the need to identify all the environmental aspects and impacts of the facility. At this facility many of the aspects will be somewhat indirect. For example, while energy is not directly produced at the facility, it is a large consumer of energy and this consumption has environmental aspects. Similarly, the facility does not have its own landfill, but the waste generated in the production building goes off-site to a landfill.
The largest number of environmental aspects and impacts relate to the general inefficiency of the facility -- the large amount of material that has to be returned for reprocessing results in larger energy consumption, more waste water production and more waste generation. For company management this may be the best reason to implement an EMS: it will force the company to examine the efficiency of its operations. By increasing efficiency, waste production will be reduced and energy consumption will be lessened. This should increase the profitability of the entire enterprise while at the same time reducing the facility's environmental impacts.
Once the aspects and impacts are identified, the company can develop an EMS to mange the major impacts. The EMS should be integrated into the overall company operations, not set off to the side as a separate activity. Although one person needs to be designated as the EMS coordinator, the EMS should be designed into all aspects of the facility operation. It cannot be viewed as simply an "end-of-pipe" activity. It needs to be considered in terms of production process and efficiency. The EMS should not be viewed as a "cost center". The EMS should be viewed as a "profit center" that will reduce costs and improve efficiency so that company profits are increased.