E2666
V. 1
EXECUTIVE SUMMARY
Being a global leader in specialty chemicals, Rhodia produces adipic acid, in whose
manufacturing process N2O emissions are generated. During the production of
adipic acid, the main component of Nylon, emissions of a non-pollutant atmospheric
greenhouse gas (GHG), the N2O, occur.
The Kyoto Protocol has led Rhodia to reduce its N2O emissions through the so
called Angela Project. With the ratification of the Kyoto Protocol in 2005, Rhodia
decided to elaborate a project of N2O emissions abatement that is currently registered
with the Clean Development Mechanism Executive Board (CDM EB). In order to
become financially viable, the project depends on the sale of GHG emission reductions
through the destruction of N2O.
An auditing firm has been hired to assess the environmental and social compliance
of the Angela Project with World Bank Group safeguards standards. The auditing
firms E.Labore/Ambio performed an environmental and social compliance audit whose
scope was not only limited to the N2O project, but it also extended to all industrial units
in the existing industrial complex of Rhodia, including the industrial plants that do not
belong to the Rhodia Group located at the site. The compliance of both the Angela
Project and the Rhodia industrial complex were assessed according to the municipal,
state, and federal legislations. The IFC Environmental, Health and Safety (EHS)
Guidelines have also been considered in the safeguards assessment. Those guidelines
are applicable for new units and, as such, they have been used as parameters for quality
and assurance purposes.
Rhodia utilizes a state-of-art environmental management system and has been
granted ISO 14000 certification. The SIMSER+, an environmental system designed in
partnership with DNV, is periodically audited and defines Rhodia’s environmental
strategy. In addition to SIMSER+, Rhodia has a standing ISO 14000 certification, which
is periodically audited by Bureau Veritas.
The audit confirmed the compliance of the Angela Project with the requirements
established by the local environmental authorities. The process of environmental
licensing revision verified that the plant where the Angela Project (adipic acid) is
located complies with the necessary legal requirements. With respect to the industrial
complex where the Angela Project is located, environmental compliance has also been
confirmed with the local authorities. Regarding the licensing of the other units that are
part of the Rhodia complex concerns, only one comment on the renewal of industrial
licensing of an area for silica stockpiling was reported.
The atmospheric emissions and the hydric effluents comply with the applicable
local legislation. Still, deviations from IFC emissions parameters were registered
and actions regarding hydric effluent from plants in the complex shall be
undertaken. Rhodia conducted the exchange of fuels in oil boilers to natural gas,
eliminating the SOx emissions and reducing the total emissions of NOx. However, the
emissions from such equipments show some discrepancies when compared to the
parameters of IFC for new equipments. The hydric effluents of the ETE phase 1 related
to the Angela Project comply with the requirements of the local authorities and the IFC.
The effluents from the remaining plants in the complex need further assessment in so
far as the residual organic loads are concerned. Such issues are being assessed by
Rhodia and are part of the company’s priorities and action plan.
Rhodia has made long strides to improve atmospheric emissions and hydric
effluents. Such results are reinforced by the significant improvement in emission
reductions, despite the increase in production. At the same time, Rhodia has also
complied with the “Terms of Adjustment of Conduct” agreed with the environmental
authorities. Documents with references to environmental liabilities and remediation
areas were reviewed in detail, as well the four monitoring programs.
Rhodia employs an efficient system to interact with community and stakeholders.
Rhodia has two channels of communication with the community, both for questions,
requests, and complaints, and for the dissemination of the company’s initiatives, which
are part of the program known as the “Rhodia Way”. Besides, the Rhodia Institute
engages in social initiatives that are monitored and have displayed satisfactory results.
In parallel, the auditors conducted independent consultations to verify the efficacy of
the system of consultations and attention to the community and other stakeholders.
In sum, there were no significant technical or legal issues identified by the auditors that
could jeopardize the environmental, social or legal compliance of the Angela Project
according to the World Bank safeguards standards. Regarding the other facilities associated
with Rhodia’s Industrial Complext, the audit confirmed their compliance with the applicable
norms and legislations. The deviations from the parameters suggested in the IFC guidelines are
assessed and justified in the report considering the specific conditions of the plant and the
absorptive capacity of the local ecosystem. Therefore, it has been verified that Rhodia complies
with the requirements of the government authorities, always making use of the best available
technology, and deploying resources to improve the operational and environmental conditions
of the N2O abatement project and the entire Industrial Complex.