Performance Audit Report 2011

CARD Environmental Performance Report July 2009- December 2010

I. Introduction

1.1 Background

The Philippine Environmental Partnership Program (PEPP) is a program between the

government, industry and civil society to promote improved environmental management and

performance of industry. Since the beginning of the participation of the Center for Alcohol

Research and Development Foundation (CARD) to the PEPP, participating distilleries have

continuously implemented significant pollution control programs and demonstrated self-

regulation geared towards full compliance to environmental regulations.

The purpose of the Environmental Performance Audit is to verify through a review the system's

EMP implementation and effectiveness; to collect; and to evaluate objective evidence/s related

to the EMP or EMS. This audit determines whether individual company’s EMP is functioning as

intended to produce desired outcomes; that documented practices and/or procedures are

conducted; to identify those EMS elements that warrant efforts for continuous improvement;

and to map a performance improvement pathway for the future.

Results of this and future audits will provide added value to our EMP system that will be viewed

as an overall opportunity for enhancement. Since the audit is a snapshot in time, it cannot

identify each and every area for improvement. However, the results of each of our audits do

provide for an additional incremental step in the overall improvement of our EMPs.

1.2 Facilities Description

As of December, 2010 there is still a total of 11 participating distilleries in the Environmental

Consent Agreement (ECONA) which was signed in December, 2003. These include the

following:

Page 1


Absolut Distillers, Inc. (ADI)

ADI is a medium size

alcohol distillery plant

established in October,

1990. It is ADI distillery

complex occupies a

total lot area of

approximately nine

hectares, sixty percent

of which is dedicated

to its wastewater treatment facility. Its major product is Ethyl Alcohol and liquefied

Carbon Dioxide as a fermentation by-product. ADI has pioneered the Clean

Development Mechanism (CDM) Project of the private manufacturing sector duly

registered on October 2006 under the United Nations Framework Convention on

Climate Change (UNFCC).

Alko Distillers, Inc. (ADI)

ADI was established in 1997 at Brgy. Baritao, Manaoag, Pangasinan in an estimated 1.2

hectare complex. The 10-year lease agreement with Hind Alcohol Company (HAC)

expired last July 2010 and the management opted not to renew its contract.

Note: Not included in the audit scope.

Page 2


Asian Alcohol Corporation (AAC)

AAC plant was

established in 1973

and is located at

Barangay Canjusa,

Pulupandan, Negros

Occidental, covering

an area of

approximately fifteen

(15) hectares. The plant

generates its own power and produces mainly hydrous ethyl alcohol with liquefied

carbon dioxide as its by-product.

Not operating and was not included in the audit scope

Balayan Distillery, Inc (BDI)

BDI was established in 2001 and is located at Barangay Talisay, Calaca, Batangas

covering an area of approximately

seven and a half (7.5)

hectares. The plant

generates its own power

and produces mainly

hydrous ethyl alcohol with

liquefied carbon dioxide

as its by-product. The

plant features a small

Page 3


mooring facility at the shoreline along its private property for unloading of the

materials.

Central Azucarera de

Tarlac (CAT) Distillery

The CAT Distillery is part

of an` integrated

manufacturing plant of

the Jose Cojuangco &

Sons Organization

located in a fifty (50)

hectare property inside

the Luisita Agro-Industrial

Complex in San Miguel, Tarlac City. Established in 1929, the integrated facility produces

both raw and refined sugar, and hydrous ethyl alcohol. Liquefied carbon dioxide and

dried yeast are by-products of the Distillery.

Consolidated Distillers of the Far

East, Inc. (CONDIS)

CONDIS started operations in

1990 and is located at

Barangay Lumbangan,

Nasugbu, Batangas covering

an area of approximately ten

(10.0) hectares. The plant

Page 4


generates its own power and produces mainly hydrous ethyl alcohol with liquefied

carbon dioxide as its by-product.

Distilleria Bago, Inc. (DBI)

DBI was established in 1992

and is located at Km. 13.5,

Brgy. Taloc, Bago City, Negros

Occidental with an area of

approximately 115 hectares.

It then undertook a major

expansion program that

doubled its production

capacity making it the largest

of all the participating distilleries. The plant is an ISO 9001-2008 certified and produces hydrous

ethyl alcohol and liquefied carbon dioxide.

Far East Alcohol Corporation

(FEACO) FEACO was

incorporated in 1987 and is

located in an approximately two

(2) hectare property at Barrio

Alauli, Apalit, Pampanga. The

plant is ISO 9001-2000 certified

and produces mainly hydrous

ethyl alcohol.

Page 5


International Pharmaceuticals, Inc. (IPI) Distillery

IPI Distillery was established in 1993 and is located at Barangay Purisima, Manapla,

Negros Occidental. The plant produces mainly hydrous ethyl alcohol. It ceased

operation in August 2009.

Kooll Company, Inc. (KCI)

KCI started operation in

1969 and is located at

Barangay Bubog, Talisay

City, Negros Occidental

covering an area of

approximately four (4)

hectares. The plant

produces mainly

hydrous ethyl alcohol with

dried yeast as its by-product.

Leyte Agri Corporation (LAC)

In 2001, LAC bought the

existing plant from AA Aqua

Agri Corporation located at

Barrio Ipil, Ormoc, Leyte

covering an area of

approximately seven (7)

hectares. The plant

Page 6


produces mainly hydrous and anhydrous ethyl alcohol with liquefied carbon dioxide as

its by-product. It is the first bio-ethanol plant in the Philippines which started its

operation in April 2008.

All these distilleries are active members of CARD Foundation from the beginning of the ECONA

to the present. The updated contact details of the distilleries are shown in Table 1.

Table 1. Participating Members

Company Contact Person Contact Details

Absolut Distillers, Inc (ADI)

Barangay Malaruhatan

Lian, Batangas

Gerardo T. Tee

Jaime Giovanni H. Tan

043-215-2439

[email protected]

[email protected] .ph

Alko Distillers, Inc. (ADI)

Bo. Baritao, Manaoag, Pangasinan

Engr. Philip T. Baligod 075-529-011

[email protected]

NOTE: No operations

Asian Alcohol Corporation (AAC)

11 Alijis Road, Bacolod City

Henry L. Tan

Susan C. Benitez

034-434-7001

[email protected]

[email protected]

NOTE: No operations

Balayan Distillery Inc. (BDI)

Km. 118 Barangay Talisay

Calaca, Batangas

Redmond L. Lee

Abigail S. Macalalad

02-635-9888

043-223-7426

[email protected]

[email protected]

Central Azucarera de Tarlac (CAT)

Barangay Central, Tarlac City

Fernando C. Cojuangco

Fernando B. Urbanozo

Romeo B. Ecraela

045-491-1086

[email protected]

Page 7

http://[email protected]

mailto:[email protected]








Consolidated Distillers of the Far

East Inc. (CONDIS)

Lumbangan, Nasugbu, Batangas

Felizardo T. Sapno

Luzviminda A. Angeles

02-867-8873 to 75

043-931-3827

[email protected]

Distileria Bago, Inc. (DBI)

Km. 13.5 Brgy. Taloc, Bago City,

Negros Occidental

Cesar B. Gimena

Alfredo P. Aquino

Kerwin L. Lopez

034-444-2965

[email protected]

Company Contact Person Contact Details

Far East Alcohol Corp. (FEACO)

Brgy. Alauli, San Vicente, Apalit,

Pampanga

Antonio S. Co

Rodolfo B. Calagui

Juanito C. Manalang

045-302-5904

[email protected]

[email protected]

Kooll Company Inc. (KOOLL)

Brgy. Bubog, Talisay City ,

Negros Occidental

Juanito Y. Gamboa

Benjamin A. Masiglat

034-495-2718

034-495-1994

[email protected]

Leyte Agri Corp. (LAC)

Brgy. Ipil, Ormoc City, Leyte

Ruben A. Villanueva

Maria Perpetua T. Honrado

02-848-0224

[email protected]

[email protected]

2.0 AUDIT OBJECTIVES

The 2010 CARD Foundation Performance Audit focused on site inspection and table validation.

The objective of the internal audit was to assess implementation and compliance of set

Environmental Management Plans (EMPs) based on Environmental Management System (EMS).

2.1 AUDIT SCOPE AND METHODOLOGY

Page 8









2.1.1 Audit Scope

The scope of this Performance Audit encompassed the entire wastewater value chain

(pre-treatment, collection and treatment, storage and transportation and end use /

disposition), as it applies to each company’s individual operations, with special attention to

practices and management activities that directly support wastewater treatment-related

operations, processes and activities.

Specifically, the scope of this audit included:

Validation of compliance with the regulated aspects (all applicable requirements).

Review of documentation or proof of compliance showing that EMPs have been

properly implemented and maintained.

Audit of performance of the wastewater treatment plant. The audits were performed

onsite at the plant facilities.

Verification of pertinent transactions to assess functionality of set EMPs.

Examination of outcomes being achieved by the company through the use of their set

EMPs.

2.1.2 Audit Methodology

The audit was performed by assessing key processes or activities related to the company’s

program for conformance with the regulated and unregulated aspects of the set EMPs. Using

sampling techniques, the auditors interviewed key persons, observed practices in place and

reviewed pertinent documents and records. Plant representatives were interviewed to validate

set programs.

Note: No audit was conducted for 2010.

Audit Schedule for 2011

Date : Time: Location: Activity/Agenda:

Page 9


February 9 9:00 AM-5PM Federal Consolidation of 2010 PEPP report.

Preparation of Audit Plan

March 8 6:20-7:20 AM

7:20AM-11:00AM

12:00NN-5:30PM

BCD to MNL

MNL to Batangas

BDI Batangas

PCOs from Bacolod to Manila

All PCOs from Manila to Batangas

Plant Audit

March 9 8:00AM-12:00NN

1:00PM-5:00PM

5:00PM-11:00PM

ADI Batangas

CONDIS Batangas

BTGS to Tarlac

Plant Audit

Plant Audit

All PCOs from Batangas to Tarlac City

March 10 8:00AM-11AM

1:00PM-5:00PM

5:00PM-6:00PM

CAT Tarlac

FEACO Apalit

Apalit to Tarlac

Plant Audit

Plant Audit

Overnight at Tarlac

March 11 8:00AM-4:00 PM

4:00PM-8PM

CAT Conference room

CAT to Manila

Consolidation of Luzon Audit results.

PCOs from Tarlac to Manila

March 12 8:40 AM PCOs from Manila to Bacolod

April 25 9:00 AM-10:25AM

7:00 AM –8:00AM

10:00AM-12:00NN

1:00PM-5:00PM

BAC to CBU

MNL to CBU

CBU to Ormoc

LAC Ormoc

PCOs from Bacolod to Cebu

PCOs from MNL to Cebu

PCOs from Cebu to Ormoc Via Ferry

Plant Audit

April 26

8:30AM-10:30AM

1:00PM-5:00PM

6:00PM-7:00PM

Ormoc to CBU

Consolidation of

reports

CBU to BCD

PCO from Ormoc to Cebu Via Ferry

PCO from Cebu to Bacolod

April 27 8:00 AM-11:00NN

2:00PM-5:00PM

DBI Bago City

Kooll Talisay City

Plant Audit

Plant Audit

April 28 8:00AM-4:00PM AAC office Consolidation of Visayas Audit results.

April 29 10:40 AM PCOs from Bacolod to Manila

2.2 AUDIT TEAM

The Center for Alcohol Research and Development Foundation selected the individuals

listed in Table 2 to serve as members of the Environmental Performance Audit Team. All team

Page 10


members have received internal EMS auditor training, and were deemed competent to have

the level of expertise necessary to conduct the audit. These individuals were chosen based on

their knowledge of the organization and/or their ability to gather objective evidence.

Page 11


Table 2. Composition of the Audit Team

3.0 ENVIRONMENTAL PERFORMANCE

3.1 Regulated Aspects

3.1.1 Environmental Impact System (PD 1586)

All distilleries have existing Environmental Compliance Certificates (ECCs)

covering the different areas of operation of their plants. A number of distilleries were in

operation before the enactment and effectivity of this Presidential Decree e.g. CAT and

KOOL but all succeeding projects and expansions have secured ECCs. Examples of these

projects are capacity expansions, storage facilities, fertilization program and system

upgrading.

Some plants have not implemented any expansion programs since the start of their

operation.

Page 12

Role Name (Firm)

Lead Auditor Kerwin L. Lopez, DBI

Auditor Abigail S. Macalalad, BDI

Auditor Romeo B. Ecraela, CAT

Auditor Jaime Giovanni H. Tan, ADI

Auditor Rodolfo B. Calagui, FEACO

Auditor Luzviminda A. Angeles, CONDIS

Auditor Melinda E. Bartolome, TDI

Adviser Susan C. Benitez, AAC

Adviser Ma. Perpetua T. Honrado, LAC


The ECCs of each distillery is shown in Table 4

Table 4. List of Environmental Compliance Certificates Issued to Distilleries

Company Environmental Compliance Certificate # (ECC)

Project

ADI 8703-003-114 Alcohol Distillery

AAC 0601-0326-084-120

0697-1118-567-120A

0605-0411-185-120

0607-1227-442-120

Barrel Farm

Expansion Project

Molasses Storage Tanks

Storage Terminal Expansion Project

BDI ECC 0005-161-114 Alcohol Distillery

CAT Not Covered

Condis ECC-263-BA-120-94

ECC 4A-2002-041-120

ECC 4A-2004-0194-3529

ECC-4A-2005-0458-3131

ECC-4A-2007-0189-3131

Distillery Expansion

Re-distillation Plant

Fertilization Program

Modernization/ Upgrading of Distillery Columns

Modification and upgrading of the redistillation plant

Page 13


Company Environmental Compliance Certificate # (ECC)

Project

DBI ECC 1 9204-026-114CD

ECC 2 0697-1111-497-120

ECC 3 0601-0716-200-120

ECC 4 0602-0923-317-120

ECC 5 0603-0707-251-120

Alcohol Distillery

Expansion Project

Molasses Tanks and Submarine Pipeline

Cassava Composting Plant

69 KV Transmission Line

Feaco ECC 03-PA 1007-220043-120A Fertilization Program

Kooll 0600-0621-127-120

0698-1012-210-120A

CO2 Recovery Plant

Molasses Tank

LAC 08-070604-0044 Alcohol Distillery

3.1.2 Clean Air Act (RA 8749)

Distilleries operate boilers to generate its needed steam and power in processing,

hence, each distillery has one or more smokestacks and is considered a point source.

Facilities for air pollution control include water scrubbers, flares, gas recovery systems

dust/particulate collectors and all the distilleries so far are adequately equipped as

manifested by their valid permits to operate from the DENR-EMB. Details of which are

shown in Table 5.

Page 14


Table 5. List of Permit to Operate (Air) Issued to the Distilleries

Company Permit to Operate (POA) Validity

ADI 2010-POA-0410-002 August 26, 2011

BDI 2010-POA-0410-504 August 13, 2010

CAT

Condis 2010-POA-0410-005 August 22, 2010

DBI 10-POA-G-0645-123 September 15, 2011

Feaco TPOA-90J-03PA-047 October 30, 2010

Kooll 09-POA-H-0645-038 August 15, 2010

LAC 09-POA-E-0837-0261 February 28, 2010

3.1.3 Clean Water Act (RA 9275)

Distilleries discharging wastewater either to a receiving body or to farmlands as fertilizer

must secure a Discharge Permit.

Herewith is the breakdown of how the 10 distilleries discharge their effluent.

BDI and KOOLL through barging to the dumping site designated by the Coast

Guard.

CAT holds a permit to discharge its effluent to Class D (OEI) RBW, Bojo Creek.

Page 15


DBI was given permit to discharge through the Guimaras Strait via submarine

outfall.

ADI, CONDIS, FEACO and LAC were permitted to discharge their waste to

farmlands as fertilizer – by the fertilizer and pesticide authority.

Most of the plants have undergone various enhancement projects for the wastewater

treatment plant and have been continuously implementing programs geared towards

the reduction of pollution load. Among these are the continuous enzyme treatment to

reduce TSS concentration and application of inoculants for further slops digestion.

For this period under review, AAC was under TLO issued by the Pollution Adjudication

Board. All other distilleries have no notice of violation for non-compliance to water

standards. All measures for pollution prevention were religiously carried out as

manifested in the EMP report.

Table 6 shows the details of the permits to discharge of the distilleries while Table 6

shows the FPA permits of the four distilleries.

Table 6. List of Discharge Permits

Company Discharge Permit (DP) Validity

ADI 2010-DP-BA-0398 August 31, 2011

BDI 2010-DP-BA03-064 September 11, 2011

CAT DP-10L-03TA-1056 December 30, 2011

Condis 2010-DP-BA-03-096

DBI 10-DPW-G-0645-123 July 15, 2011

Feaco DP-09J-03PA-031 October 13, 2010

Kooll 09-DPW-H-0645-038 August 15, 2010

Page 16


LAC 10-DP-C-0837-0206 February 28, 2011

3.1.4 Hazardous Wastes Management (RA 6969)

Disposal of any hazardous wastes in any form are regulated under the Republic Act No.

6969. Alcohol plants do not generate hazardous wastes but they are required to obtain

hazardous wastes generator’s IDs because some of the facilities used such as

transformers, generators and trucks generate hazardous wastes such as PCB and used

oil respectively.

However, the operations make use of sulfuric acid, which is a regulated substance and

so there is a need for all distilleries to secure permit from PDEA to make use of the

substance.

Table 7. Fertilizer and Pesticides Authority Permits

Company FPA Control #

ADI Manufacturing - # 129

Warehousing – W-126

Product Registration – 1 1LF-1103 “Abono”

Condis Manufacturing - # 252

Warehousing - W-249

Product Registration – 1 1LF-2000

Feaco Manufacturing - # 096

Warehousing – W-047 (L3)

Page 17




License-121 Control No :01-04L-2009

License-125 Control No :01-04L-2010

Product Registrations – 1 1LF-1148



LAC Experimental Use Permit – F-337

Older distilleries have facilities that still contain Polychlorinated bi-phenyls (PCB) such as

AAC and LAC. These companies likewise registered their PCB containing facilities in the

same manner as the asbestos under the Chemical Control Order Registry.

Refer to Table 8 for the list of Hazardous Wastes Generator’s IDs of the distilleries.

Table 8. Hazardous Wastes Generator’s IDs of the Distilleries

Company Hazardous Wastes Generator’s ID #

ADI 04-10-0130

AAC 06-45-0020

BDI 04-10-0134

CAT 03-69-0001

Condis 04-10-0017

DBI 06-45-0029

Page 18


Feaco 03-54-0087

Kooll 06-45-0054

LAC 08-37-0008

Table 9. PDEA License of the Distilleries

Company PDEA License No.

ADI P3-01447001-R011

P6-01447001-R014

BDI P3-129R258-042309-050710

P6-350R107-042309-050710

CAT P3-1224R020-011409-011910

P6-229R008-011409-011910

Condis P3-934R260-042409-042510

P6-388R108-042409-042510

DBI P3-913R238-041609-033110

Feaco P3-995R770-60707-61410

P6-221R771-60607-61410

Kooll P3-1590-080709-080710

LAC P3-204R257-042309-042610

P6-235R106-042309-042610

3.1.5 Department Administrative Order 26

Page 19


Directly ensuring their compliance to environmental regulations are the Pollution

Control Officers (PCOs) of the distilleries.

The list of updated PCOs together with their accreditation numbers is shown in

Table 10.

Table 10. List of Pollution Control Officers

Company PCO Accreditation #

ACIGerry Tee

Jaime Giovanni H. Tan

Accredited, 1988

2006-205

ALKO Engr. Philip Baligod Accredited, 1998

AACSusan Benitez (PCO III)

Joerey B. Ison

2000-3131-0645-278

04-0645-3131-407

BDI Abigail Macalalad 2004-1051

CAT Romeo B. Ecraela 01J-03TA-018-2001

Condis Luzviminda A. Angeles 2007-2170

DBI Kerwin L. Lopez 05-0645-3131-508

Feaco Rodolfo S. Calagui 02C-03PA-056

IPI Wilma Dignos 99-3131-0645-262

KoollBenjamin Masiglat

Andres Aquino II

05-0645-3134-498

05-0645-3134-499

LAC Yolanda Juanillo

Nofe M. Cabintoy

Cynthia G. Leonidas

Dalla D. Atok

06-067

06-068

06-069

06-070

3.2 Unregulated Aspects and Implementation of OTPs

4.2.1 Reduction in Slops Generation

Page 20


The production of alcohol entails the production of slops and other liquid wastes.

Distilleries produce huge volume of slops which has a strong pollution load. Most of the

slops produced is being confined in temporary, lagoons or digesters as a means of

avoiding water pollution. Reduction in slops generation has been one of the major

waste minimization activities being continuously implemented, monitored and

evaluated in distilleries.

The programs being implemented in line with slops reduction include process

upgrading and modernization and the use of better yeasts. Some plants have been

utilizing enzyme to increase the efficiency of sugar conversion to ethanol. Others have

recently deployed enhanced batch culture and continuous fermentation with Yeast

Recycling System.

4.2.2 Renewable Energy from Wastewater Treatment

In abeyance to the government’s stringent regulations on the qualities of

industrial effluents, distilleries have developed and enhanced their wastewater

treatment plant facilities using the best available technology.

Most of the distilleries have been using anaerobic digester technology to turn

wastewater into energy. Anaerobic Digestion improves wastewater treatment efficiency

while providing value added by products such as energy in the process. These

companies have invested more than Php 150 million over the past years to implement

this process, which combines the treatment of wastewater with the generation of

energy to minimize the plant's reliance on fossil fuels. The heart of the treatment facility

is an anaerobic digester, where micro-organisms naturally degrade waste materials,

producing biogas (methane) in the process. Biogas is then collected and stored before

being utilized as boiler fuel to produce steam, which is used in the distillery for alcohol

production. This wastewater treatment process has produced significant quantities of

renewable energy. Plants have derived more than 40% of its energy requirements from

naturally created biogas. The distilleries have put in a lot of money for their co-

Page 21


generation facility, producing electricity from biogas, enhancing the site's energy

efficiency and its reduced reliance on fossil fuels.

4.2.3 Utilization of Treated Slops/ Sludge as Fertilizer

Slops is usually considered as wastes but it has all the essential elements

required for the growth of plants, therefore it has an agronomic value. The use of slops

for agricultural purposes is continuously being practiced by the distilleries since it

ensures a sustainable environment by improving the soil pH, increasing the soil’s

nutrient content and improving the soil’s physical properties.

A study carried out by the distilleries has proven the use of slops as fertilizer on

sugar cane and other crops. Researchers have also studied its application for other

crops such as corn, papaya, vegetables, mango and ornamentals.

At present, there are four distilleries with on-going fertilization programs,

namely, ADI, CONDIS, FEACO, and LAC. After passing slops thru a series of treatment,

digested slops is subsequently withdrawn and delivered thru tank trucks and sprayed as

soil conditioner and fertilizer. Its utilization for agricultural purposes is an economical

and feasible alternative.

Distilleries undertaking agricultural application of slops have secured the

corresponding permits from FPA and ensure that their product is safely transported and

uniformly applied in the field. Regular monitoring of groundwater, surface water and

soil is being conducted in the areas applied with distillery effluent. The records of soil

and groundwater quality data are properly maintained and copies of the collected data

are submitted to EMB as part of their compliance requirements. Site evaluation of the

area prior to fertilization is likewise conducted.

100 percent utilization of slops for fertilization results in the absence of

wastewater discharges such as in the case of ADI, CONDIS and FEACO.

Page 22


4.2.4 Reduction of Washings

The distilleries’ resource conservation program have significantly reduced the

used of fresh water in the washing activities within the plant. Volume reduction ranged

from 2 to 50 percent.

These reductions were achieved through the following measures:

the 50 percent reduction was achieved by simply using the wash water

twice;

decreasing the frequency of washing from 10 times to 6 times;

substituting washing with dry cleaning where possible; and

use of spent CO2 scrubber water instead of fresh water.

use of RC bottoms product in cleaning fermentation vessels instead of

fresh water

collection of reject water from the reverse osmosis for re-use

recover water from the CO2 and air blower for re-use

re-used of yeast separator flushing water to other processes

The decreased fresh water consumption further led to energy conservation since

there was a significant decrease in the operation of water pumps.

4.2.5 Reduction/ Recycling of Solid Wastes

The most common solid wastes from the distilleries are used containers that

come in the form of plastic and metal drums, carbouys, and sacks. All these are

recyclable and as such are collected and either sold to scrap buyers or donated to the

Page 23


local community as part of their outreach programs. Some companies are implementing

a supplier return policy to eliminate accumulation of carbouys in the plant.

Sludge from the wastewater treatment process are stored and disposed of as

follows:

Dried, collected and stored in 25 K bags;

Dewatered and disposed of through the landfill;

Used as organic fertilizer for fruit trees (mangoes); and

Used as part of feeds for aqua cultures.

4.2.6 Prevention of Accidental Releases

There were no accidental releases, both in the transport of treated slops for

fertilization and in the barging of slops to designated discharge points during the period

in review. Distilleries having fertilization and barging activities have continuously

implemented protocols drafted for conducting these activities and trained personnel

directly involved in the transport and barging of treated slops.

Page 24

Documents

Performance Audit Report 2011