January 2011Complex Ecological Examination of Naftna Industrija Srbije (NIS) Production Facilities

D’Appolonia S.p.A.AN ISO 9001 AND ISO 14001 CERTIFIED COMPANY

www.dappolonia.it

Content and Scope of Services• Scope of the services has been to conduct an environmental

examination of several NIS manufacturing facilities

• The study has targeted 12 facilities (total area: about 400 ha):

Pančevo Refinery (about 200 ha)Novi Sad Refinery (150 ha)Smederevo and Čucarika Tank Farms (20 ha)2 Petrol Stations in Novi Sad and BelgradeGas Refinery ElemirKikinda and Mokrin Compression StationsTNG Regional Centre Novi Sad2 facilities of Service Companies (Zrenjanin)

Specific Scope of Services

• The Study has been divided in four phases corresponding to four general goals:

Phase 1: Ecological Assessment of Environmental Status (water, soil, air) within the NIS Economic Activity Zone

Phase 2: Assessment of Potential Environmental Risks

Phase 3: Assessment of Facility Ecological Management System

Phase 4: Development of Instructions for Improvement of Ecological Status and Reduction of Ecological and Economic Risks

Phase 1: Ecological Assessment of Environmental Status (Water, Soil, Air)

• The main objectives of Phase 1 have been to obtain information on the current environmental status within each of the 12 facilities

• Phase 1 has been divided in the following Work Packages (WP):

WP 1: Acquisition of existing data

WP 2: Site Surveys at each facilities

WP 3: Data Gap Analysis

WP 4: Site Investigations (Soil and Groundwater)

WP 5: Evaluation of the present Environmental Status for each Facility

Phase 2: Assessment of Potential Environmental Risks• Phase 2 has relied on the results of Phase 1 and has

evaluated, for each facility, the risks associated with:impacts on subsoil and groundwater quality due to the presence of chemical substancespossible exceedances of the legislation limits for wastewaterpossible obligations related to remediation and/or clean-up needspossible law breaching on environmental protection due to the activity of the facilities and the need of paying fees and fines

• Recommended corrective actions, based on local legislation and best international practice, have been outlined in the final reports

Phase 3: Assessment of Facility Ecological Management System

• Phase 3 has evaluated the compliance between the law requirements and the present ecological and environmental management system

• This project Phase has been based on:data on facilities and current environmental management systems provided by the ClientSerbian Environmental Legislationoutcomes of the field survey (Phase 1)

• This project Phase has delivered:An overview of local and international legislative requirements for soil, groundwater, wastewater, etc; An evaluation of the Ecological Management System in place for each facility with respect to the above regulations

Phase 4: Development of Instructions for Improvement of Ecological Status and Reduction of Environmental Liabilities• Phase 4 has developed general corrective actions to:

improve the ecological and environmental status at each facility Reduce the potential environmental liabilities identified in Phases 3 and 4

• This Phase has delivered:a list of site-specific priority corrective actions to be implemented in the short/medium/long term period to reduce the environmental risks

Results: Overview

• The project has targeted the following four components for each facility

Soil and GroundwaterWastewaterAirEnvironmental Management

• For each component the following activities have been developed:

Analysis of the environmental statusIdentification of the potential risksIdentification of existing or potential law breakings Proposed corrective actions

Soil and Groundwater

International Approach

CSOIL/GW > CLIM

Calculation of Site-specific

Target Levels (SSTL)

through Human

Health Risk Assessment

CSOIL/GW > SSTLRemediation / Mitigation

Action

The approach followed for the evaluation of the current state of soil and groundwater considered both the International regulations/best practices and the new Serbian law for soil and groundwater quality monitoring, risk assessment and preparation of remediation programs (Official Gazette RS No. 88/2010)

(DIV and

Italian

Standards)

Soil and GroundwaterThe approach followed for the evaluation of the current state of soil and groundwater considered both the International regulations/best practices and the new Serbian law for soil and groundwater quality monitoring, risk assessment and preparation of remediation programs (Official Gazette RS No. 88/2010)

RS Law for Soil and GW (2010) Approach

CSOIL > Limit ValueRemediation

Program

CSOIL/GW > Remediation Value

Volume > 25 m3 (soil) / 100 m3

(GW)

Remediation Project

Soil and GroundwaterSoil and GW Sampling - General Strategy

Soil (surficial and subsoil)• Boreholes were performed at each identified potential pollution

source • Boreholes were drilled up to GW level• One soil sample was collected at the bottom of each boring• Surficial soil samples were collected at the waste storage areas• Collected soil samples were analyzed for 8 metals, TPH, Aliphatic

Aromatic Split, BTEX, Chlorinated Hydrocarbons, PAH, MTBE, cyanide, fluoride and other anions

• Analytical results compared with local and international limit values

Ground Water• Where not available, GW monitoring wells were installed• GW samples were collected at each facility • Collected GW samples were analyzed for 8 metals, TPH, Aliphatic

Aromatic Split, BTEX, Chlorinated Hydrocarbons, PAH, MTBE, cyanide, fluoride, nitrite, sulphates

• Analytical results compared with local and international limit values

Soil and GroundwaterSoil and GW Sampling Activities

Fac. No.

Facility Name Borings Monitoring

Wells Subsoil Samples

Surficial Soil

GW Samples

1 Pancevo Refinery 22 - 22 2 5

2 Novi Sad Refinery 17 - 17 21 5

3 Smederevo Tank Farm 5 - 5 - 4

4 Belgrade Tank Farm 4 1 4 - 3

5 Belgrade Petrol Station “Zmaj 1”

2 - 2 -

-

6 Novi Sad Petrol Station “Novi Sad 1”

2 - 2 -

-

7 Elemir Gas Refinery 2 1 2 1 3

8 Kikinda Dispatch Station 3 1 3 - 3

9 Mokrin Dispatch Station 2 1 2 1 3

10 TNG Novi Sad Regional 3 3 3 - 3

11 Zrenjanin Service Complex 4 1 4 2 3

12 Zrenjanin Maintenance Complex

3 1 3 1

3

TOTAL 69 9 69 28 35

Soil and GroundwaterCurrent state of soil and groundwater (International

Standards)

• SoilDiffuse exceedances of heavy metals (Hg at Pancevo Refinery, Pb at all minor Facilities), cyanides (especially at minor Facilities) and organics (Total Petroleum Hydrocarbons [TPH] and benzene, especially at the two refineries)

• Surficial SoilDiffuse exceedances of Pb (all Facilities) and benzene (two refineries)

• GroundwaterDiffuse heavy metals contamination (Pb, Zn, As)Some exceedances for organics (TPH, BTEX, and benzene)

Soil and GroundwaterHHRA Results (Potential Risks – International Approach)

• Heavy metals (both in surface and subsurface soil) resulted in no risk for on-site workers / off-site residential receptors

• Risk for on-site inhalation was calculated only for benzene and light TPH fractions in soil at the two refineries and for Hg at Pancevo refinery

• The estimation of the volume of contaminated soil was possible only at a preliminary (very conservative) level

• Risk for potential groundwater receptors was calculated considering the soil-leaching-to-groundwater pathway for benzene and light TPH fractions

• Groundwater contamination exceeded target levels for down gradient receptor protection at almost all Facilities

Soil and GroundwaterMitigation Actions (International Approach)

• With the exception of the two refineries, “cutting” the groundwater exposure pathway would allow excluding the remediation need at any Facility (no need for remediation intervention on soil)

• With reference to organic contamination at the two refineries, several techniques can be proposed, ranging from in situ bioremediation/bioventing or on-site/in situ thermal desorption for organics to on-site stabilization/solidification for mercury

• Further detailed site characterization (i.e. Remediation Program) is needed to:

better defining the extension and depth of the contamination sources for each contaminant identified and develop a detailed HHRAdevelop a detailed remediation design

Soil and GroundwaterProposed Mitigation Actions for

Groundwater

• Hydraulic Barrier (Pump & Treat System)

• Steel Sheet Piling (in case of river/canal presence) + Drainage Trench

Considering that the contamination levels detected during the last sampling campaign do not show evidence of high/diffused contamination, the barrier/trench should be installed within the short-term period and tested on a regular basis, but it could be operated only when the contamination plume will reach the barrier/trench line

Soil and GroundwaterCurrent state of soil and groundwater (Serbian

Standards)

Soil• Diffuse exceedances of heavy metals (Hg and Ni at Pancevo

Refinery, Pb at minor Facilities), cyanides (especially at minor Facilities) and benzene, (at the two refineries and TNG)

Surface Soil• Diffuse exceedances of Pb (all Facilities) and benzene (two

refineries)

Groundwater• Diffuse Zn contamination at all Facilities

Some exceedances for Pb (Smederevo and Belgrade TF), BTEX (Pancevo) and TPH (Zrenjanin SC Maintenance)

Soil and GroundwaterMitigation Actions (RS Law Approach)

Soil• Several exceedances of the Limit Values • Some exceedances of the Remediation Values potentially involving

volumes higher than 25 m3 of soil • Further detailed site characterization (i.e. Remediation Program

development and implementation) is needed to: • better defining the volume of the contamination• developing a detailed remediation design (if needed)

Groundwater• Some exceedances of the Limit Values and few exceedances of the

Remediation Values (however potentially involving volumes higher than 100 m3 of aquifer)

• Further detailed site characterization is needed to better define the groundwater contamination presence, where confirmed, to define the plume dimensions

WastewaterWW and SW Management Approach

• Identification of WW issues

• Identification of potential environmental risks

• Identification of the most time-cost-benefit solution to be implemented

• Cost of the proposed corrective actions

• Prioritization of the identified solutions

WastewaterMain Regulatory Drivers

• Law on Environmental Protection (Official Gazette RS No. 135/04)

• Limits values for discharge of wastewater into surficial water bodies are based on prescribed quality indicators for a recipient category

• All water streams in Serbia are categorized in classes according to the level of their pollution (Decree on Water Classification, Official Gazette No. 6/78)

• The Decree specifies for each class, parameters and relevant limit values

• Limit values for the discharge into sewage system are defined by local Authorities in appropriate regulatory document

WastewaterCurrent Status of the Sites and Potential Risks

• WW and SW Drainage Systems not present or found in poor condition; potential leakages can infiltrate and contaminate the soil

• Waste Storage Areas: several outdoor storage areas with no containment; potential cross-contamination of SW runoff

• Storage Tank Areas unpaved and not provided with any drainage system to collect SW and possible spills; SW infiltrates the soil and potential oil spills or leakages can contaminate the ground

• WW Discharge: Absence of treatment devices upstream the WW discharge point; possible exceedances of the legislation limits for wastewater discharge can lead to the payment of fines ranging from 150,000 to 3,000,000 dinars, according to the Law on Environmental Protection (Official Gazette RS No. 135/2004, Art. 116)

WastewaterProposed Corrective Actions

WW and SW Drainage Systems

• Installation of new pipeline network

• Replacement of existing pipe network

• Segregation of SW runoff according to source and quality

Waste Storage Areas • Installation of roof to cover the storage area to limit/prevent runoff

• Installation of a containment (concrete curbs on the sides)

• Paving the roofed area

WastewaterProposed Corrective Actions

Storage Tank Areas• Paving the storage tank area• Installation of drainage system• Installation of safety valve• Installation of oil water separator

WastewaterProposed Corrective Actions

WW Discharge• On site infiltration through Low Impact Development (LID)

Systems (Foundation Planters, Bioretention Areas)

• Off-site discharge to external ditch or municipal sewage system (permitting and discharge quality monitoring)

WastewaterPrioritization of the Identified SolutionsThe ranking was based on:

• Engineering evaluations of constructability, operation and management (O&M) requirements

• Land use and site accessibility

• Technical Criteria

• Regulatory

• Costs

• Sustainability of proposed solutions

Air - What was checked?

No. Facility I nternal

regulation

Management system

documents specific for

site

Previous studies on

emission/ air quality1

Emission in the air/ air quality

measurements2

Report on air

monitoring realization

NIS a.d. yes 2009

Naftagas yes yes 2009

Petrol_ yes no

Facility No. 1

Pancevo Refinery, RNP (H2)3 yes yes 2007 - 2010

Facility No. 2

Novi Sad Refinery, RNS (H3)

no yes 2007 - 2009

2007 - 2009

Facility No. 3

Tank Farm Smederevo, TF SD (H4)

no yes 2010

2010

Facility No. 4

Tank Farm Beograd, TF BG (H5)

no yes no

no

Facility No. 5

Petrol station "Zmaj 1, PS Zmaj 1

no no no no

Facility No. 6

Petrol station "Novi Sad 1", PS NS1

no no 2007, 2008,

2010 2007, 2008,

2010

• Review of the local and international legislation framework• Site-specific analyses have been conducted

Air – Overall Outcomes

• Annual monitoring plan incomplete and inadequatepurpose of the measurementslocations of sampling schedule of sampling (production/process state, meteorological conditions, season) results interpretation

• Legal obligation to implement regular air emission monitoring not met in some cases

• Air emissions of some parameters above limit values

Air - Outcomes

SITE SPECIFIC: Pančevo Refinery

 

Year Storage

area Stacks

API and clarifier

Auto filling

station

Railroad filling

station Port

Continual measurement

2007 + + + +

2008 + + + + +

2009 + + + +

2010 + + + + + + + +

Air - OutcomesCURRENT SITUATION – SITE SPECIFIC: Pančevo RefineryStorage area in 2010

 

Legend Layer Air Status RNP 2010 - Storage area, TAH hydrocarbons:

Emission limit value for total aromatic hydrocarbons (TPH), Regulation (Official Gazette RS No. 30/97 and 35/97)

Measured values above emission limit values

Measured values above emission limit values

Layer Air Status RNP 2010 - Storage area, TPH:

Emission limit value for total petroleum hydrocarbon, Regulation (Official Gazette RS No. 30/97 and 35/97)

Measured values under emission limit values

Measured values above emission limit values

Air - Outcomes

CURRENT SITUATION – SITE SPECIFIC: Pančevo RefinerySome of the results of stack measurements

Legend Layer Air Status RNP: Stacks 2007

Emission limit value, Regulation (Official Gazette RS No. 30/97 and 35/97)

Measured values above emission limit values

Layer Air Status RNP: Stacks 2008

Emission limit value, Regulation (Official Gazette RS No. 30/97 and 35/97)

Measured values above emission limit values Layer Air Status RNP: Stacks 2009

Emission limit value, Regulation (Official Gazette RS No. 30/97 and 35/97)

Measured values above emission limit values

Air - Outcomes

SITE SPECIFIC: Service complex Zrenjanin – Maintenance sectionno monitoring plan for air emissiontwo stacks foreseen for measurement after construction is doneair quality measurement done in 2010

 

Air - Risks and mitigation options 1. Set up a new site-specific monitoring plan/program to allow

monitoring of:air emission in normal operationair emission in process deviation, incident situation and possible accidentscompliance with the new regulation

2. Set up a new site-specific monitoring plan/program that will, as self standing, public document, define:

the purpose of the measurements (legal compliance has not to be the key purpose)precise locations of sampling (by measurement points not only by type of emitter)Schedule of sampling (production/process state)meteorological conditions, season analytical method approach to results interpretation

Air - Risks and mitigation options 3. Set up Integrated System for Environmental and System

Risks Monitoring to avoidwrong priorities in environmental monitoringOverlooking of new trends and critical monitored/measured values

GIS supported system of environmental hazard monitoring including:

Database of stored hazardous substances(according to REACH and GHS)Influence/impact zones Environmental measurement/monitoringIntegrated data managementIntegrated documents managementAnalysis management

Air - Risks and mitigation options 4. Conduct detail analysis and select solutions for actual

emission in the air exceeding limit valuesPancevo Refinery, Novi Sad Refinery

5. Conduct measurements as required by actual regulation and in accordance to the monitoring plan, existing

tank farms (Smederevo, Belgrade)petrol stations (Zmaj 1, Novi Sad 1, Elemir Refinery)

6. Review identification of emission sources in the air and amend monitoring plans

Env. Management - Corporate & Branch EMS: EXISTING SITUATION

• NIS and NIS Petrol are not ISO14000 certified

• NIS has a general EHS policy and a wide number of procedures, but lacks a general Environmental Management System (EMS)

• NIS Petrol has not a company-wide integrated EMS

• NIS Petrol has a series of documents and procedures that regulate the facility operations but these are not formally structured

Env. Management - Corporate & Branch EMS: EXISTING SITUATION

• NAFTAGAS, has implemented a fully developed integrated EMS in accordance with ISO 14000

• The EMS includes all the major components, from the company policy and the main EHS general procedures to site-specific standard operation procedures

• Evidences of implementation of NAFTAGAS policies and procedures are found at the facilities

• Little personnel is responsible to oversee and coordinate E-management at a huge number of facilities

Env. Management - Waste Management Waste Management: EXISTING SITUATION

• NAFTAGAS facilities produce few waste streams, especially oily waste, and have developed WMPs that are adequately implemented

• A couple of small facilities produce very little waste and do not require any WMP (Pump Stations)

• Some facilities, like Tank Farms and TNG-NS, produce few waste streams, mainly oily waste. At these facilities, no relevant issues are present, although a structured WMP is missing and Waste management is based on a number of policies and procedure yet to be properly structured

Env. Management - Waste Management Waste Management: EXISTING SITUATION

• Major facilities, like PAR and NSR, produce several waste streams, handle waste on the basis of different procedures, and have not yet a WMP

• These facilities store huge amounts of undifferentiated and differentiate waste (including historical waste)

• A general issue common to all the sites, is the lack of a proper solution for disposal of oil sludge or contaminated soil in Serbia. Huge amounts of this waste are stored at some sites (OS Kikinda, PAR, NSR)

Env. Management – General Env. Issues General Environmental Issues

• Many Waste or Hazardous Material Storage areas are not roofed/paved or do not have secondary containment

• Several Aboveground Storage Tanks have earthy secondary containment and the base is not paved

• Oil sludge, oil waste and HW in general stored in earthy pits, or concrete pits with potential cracks

• Underground Storage Tanks for fuel or waste oil are old, single-walled, do not have leakage detection systems

• Reportedly buried flowlines might have licks or cracks since seldom or never checked, especially in facilities bombed in 1999

• Some facilities, especially Service Complexes, use to store, staple or park contaminated equipment and spares on the soil or on cracked concrete pavements

E Management at the Facilities Suggested Corrective Actions include:

• Establish an EMS at corporate, branch and facility level

• Supplement the EMS with site-specific WMPs, where missing. Main issues to be covered are:

Waste labeling Identification of adequate storage areas Waste amountsWaste classification Waste segregation optionsReporting schemesManagement of special waste flows (batteries, PCB, Oil sludge, etc)

• Increase the number of personnel to oversee E-management

• Certify corporate, branch and facilities

E Management at the Facilities Suggested Corrective Actions include:

• Find adequate end solutions for special waste flows (Es Kikinda) and historical waste (PAR, NSR)

• Improve hazardous material storage areas (roof, berm, pavement)

• Check integrity of buried flow lines (video inspection, pigging, pressure tests, etc)

• Check integrity/revamp of UST, discontinue when heavily damaged, install monitoring wells

• Ensure proper secondary containment for AST

• Discontinue storing contaminated material on soil or unpaved surfaces

THANKS FOR YOUR ATTENTION