NEPCon Evaluation of Enermontijo S.A. Compliance with the SBP Framework: Public Summary Report

Transcription

1 NEPCon Evaluation of Enermontijo S.A. Compliance with the SBP Framework: Public Summary Report First Surveillance Audit

2 Completed in accordance with the CB Public Summary Report Template Version 1.0 For further information on the SBP Framework and to view the full set of documentation see Document history Version 1.0: published 26 March 2015 Copyright The Sustainable Biomass Partnership Limited 2015 NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page ii

3 Contents 1 Overview Scope of the evaluation and SBP certificate Specific objective SBP Standards utilised SBP Standards utilised SBP-endorsed Regional Risk Assessment Description of Biomass Producer, Supply Base and Forest Management Description of Biomass Producer Description of Biomass Producer s Supply Base Detailed description of Supply Base Chain of Custody system Evaluation process Timing of evaluation activities Description of evaluation activities Process for consultation with stakeholders Results Main strengths and weaknesses Rigour of Supply Base Evaluation Compilation of data on Greenhouse Gas emissions Competency of involved personnel Stakeholder feedback Preconditions Review of Biomass Producer s Risk Assessments Review of Biomass Producer s mitigation measures Non-conformities and observations Certification decision Surveillance updates Evaluation details Significant changes Follow-up on outstanding non-conformities NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page iii

4 12.4 New non-conformities Stakeholder feedback Conditions for continuing certification Certification recommendation Evaluation details NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page iv

5 1 Overview CB Name and contact: NEPCon, Primary contact for SBP: Report completion date: Report authors: Certificate Holder: Producer contact for SBP: Certified Supply Base: SBP Certificate Code: Date of certificate issue: Date of certificate expiry: Ondrej Tarabus, 17/Jul/2017 Rui Simões Enermontijo, Cruzamento de Pegões R. Josué Gordicho Pegões Joana Carvalho, NA SBP /Nov/ /Nov/2021 Main (Initial) Audit Indicate where the current audit fits within the certification cycle First Surveillance Audit Second Surveillance Audit Third Surveillance Audit Fourth Surveillance Audit T NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 1

6 2 Scope of the evaluation and SBP certificate Production of wood pellets, for use in energy production, in Pegões and transportation to Setúbal harbour in Portugal. Description of the scope: The certificate scope covers production of wood pellets, for use in energy production, at Enermontijo and transportation to Setubal harbour. The scope of the certificate does not include Supply Base Evaluation. Scope Item Check all that apply to the Certificate Scope Change in Scope Approved Standards: Primary Activity: SBP Standard #2 V1.0 SBP Standard #4 V1.0 SBP Standard #5 V1.0 Pellet producer (N/A for Assessments) Input Material Categories: SBP-Compliant Primary Feedstock SBP-Compliant Secondary Feedstock Controlled Feedstock SBP non-compliant Feedstock SBP-Compliant Tertiary biomass Post-consumer Tertiary Feedstock SBP-approved Recycled Claim Post-consumer Tertiary Feedstock Chain of custody system implemented: FSC PEFC SFI GGL Transfer Percentage Credit Points of sales Harbour (including own handling of material) T Harbour (e.g. FOB incoterms) legal owner is not responsible for handling of material at the harbor Other point of sale (e.g. gate of the BP, boarder, railway station etc.) NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 2

7 Provide name of all points of sales Use of SBP claim: - -Setúbal Yes No SBE Verification Program: Low risk sources only Sources with unspecified/ specified risk New districts approved for SBP-Compliant inputs: Sub-scopes Specify SBP Product Groups added or removed: NA Comments: PEFC evaluation of Chain of Custody was already performed, but audit was conducted according to FSC Chain of Custody as Organization is FSC certified since last year. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 3

8 3 Specific objective The specific objective of this evaluation was to confirm that the Biomass Producer s management system is capable of ensuring that all requirements of specified SBP Standards are implemented across the entire scope of certification. The scope of the evaluation covered: - Review of the BP s management procedures;; - Review of the production processes, production site visit;; - Review of FSC system control points, analysis of the existing FSC CoC system;; - Interviews with responsible staff;; - Review of the records, calculations and conversion coefficients;; and - SAR and profiling data collection analysis. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 4

9 4 SBP Standards utilised 4.1 SBP Standards utilised Verification of SBP-compliant Feedstock, SBP Standard 2, Version 1.0, March 2015 Chain of Custody, SBP Standard 4, Version 1.0, March 2015 Collection and Communication of Data, SBP Standard 5, Version 1.0, March 2015 Instruction documents 5A: Collection and Communication of Data, 5B Energy and GHG Data and 5C Static Biomass Profiling data version 1.1, October SBP-endorsed Regional Risk Assessment Not applicable. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 5

10 5 Description of Biomass Producer, Supply Base and Forest Management 5.1 Description of Biomass Producer Enermontijo is the wood pellets plant of the Enerpar Group, operating since 2008 and located in the southern region of Portugal, Pegões. All Enermontijo primary feedstock is originated in Portugal, mainly from pines (Pinus pinaster & Pinus pinea), but also from eucalyptus, acacia and poplar. Primary feedstock includes roundwood, branchwood, mainly from thinning of pine forests (Pinus pinea and Pinus pinaster). Also eucalyptus wood is used, mostly low quality wood (tree tops, thinner diameters not accepted by pulp industries). Secondary feedstock is material as chips and sawdust forms from pines and also eucalyptus. Eucalyptus secondary material is coming from Portugal, Spain, Brazil and Uruguay. During 2016 year FSC certified wood was not available in Portugal for BP, but all the Eucalyptus secondary material from Portugal, Spain, Brazil and Uruguay was bought with FSC Controlled Wood claim. More than 97% of production is exported to central and northern Europe (Benelux, Denmark...). From Enermontijo, pellets are transported by truck and is sold at Setubal harbour where transport responsibility is hold by the customer under incoterms conditions FOB 5.2 Description of Biomass Producer s Supply Base Primary wood comes from forested areas of Portugal, mainly from the districts of Setúbal, Beja, Évora, Lisbon, Portalegre, Santarém, Castelo Branco, Faro, Leiria and Coimbra. The primary material (logs, harvesting waste and other forest waste mainly branches from pruning of umbrella pine) is supplied by approximately 10 small and medium companies which are made aware of and controlled in order to obtain the necessary information about the origin of the management unit, with a compromise stated to that effect. Secondary pine feedstock represented 6% of supplies on 2016, coming from 2 Portuguese sawmills. Secondary eucalyptus feedstock weighted about 16,5% of 2016 supplies, was coming from 2 pulp mills majority from Iberian forests but also there is a risk that 2,3% of it was coming from South American countries (Brazil, Uruguay). All this eucalyptus secondary feedstock was FSC Controlled Wood. Portugal According to preliminary data from the latest National Forest Inventory, 2013 (IFN6 - Areas of land use and forest species in mainland Portugal in 1995, 2005 and 2010), the forest land use is the dominant use of the mainland. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 6

11 The Portuguese forest occupies 3.2 million hectares, which corresponds to 35.4% of the country, one of the largest proportions of forested areas of Europe. From the total forest land the main forest correspond with Eucalyptus forest (26%) followed by cork (23%). The pine forest is distributed throughout the with Maritime Pine occupying 23% of the forest area of the mainland, mostly located in small areas and Umbrella Pine occupying 6% of the total forest area of continental Portugal, with its main distribution in the south of the country. Maritime Pine (Pinus pinaster) forests are usually managed in stands of trees, generally of seed or seedling origin, that usually develop a high closed canopy, and can be managed using natural regeneration or by sowing or planting. In Umbrella Pine (Pinus pinea) silviculture, management is oriented to cone production, the trees should grow in favourable light and ventilation, in order to develop large canopies that favour the production of pine cones. Over the period the forest areas exhibited a decrease of 4.6%, corresponding to a net loss rate of 0.3% / year (10 mil ha / year). The net decrease of forest areas (-150,611 ha) is mainly due to conversion to the land use class "brush and pastures." In addition to this conversion, significant amount of forested land was converted to urban use between 1995 and 2010 ( ha). Additional information about this evolution, risk and facts connected with the supply base are detailed in the SBR. Spain Spain has 18.4 million hectares of forest area, representing 36.3% of the national territory, being the third largest of European countries. Currently, 68.6% of national forest area is private and 31.4% is public, mainly from local authorities. Between 1970 and 2010 the forest area in Spain increased by about 6.48 million ha. Between 1990 and 2010 the growth was 31%: 4.4 million ha, with an average rate of 210,000 ha / year. It is the European country with the highest growth. There is a huge diversity of species as the variety of forests being more than 80% of forest areas are composed of two or more species. An average of 45% of the production comes from softwoods, 35% from hardwoods and 20% are mixtures of various species. The wood volume with bark, according to the 3rd Inventory National Forest, is 927, 76 million m3. The average annual production of timber and firewood, according to available data ( ) was million m3 with bark. The main timber producing species are Eucalyptus, Maritime Pine, Radiata Pine Radiata, Scotch Pine and Poplars, all with annual productions of more than 500,000 m3. Brazil In Brazil, according to the report 2015 (IBA-Brazilian Industry Association of Trees), the area of planted forests for industrial purposes totalled 7.74 million hectares in 2014, representing only 0.9% of the Brazilian territory. The native forests of Brazil occupy an area of just over 517 million hectares (more than 98% of the country s forests). The vast majority of the country s planted forests are located in the south of Brazil, while the native forests that provide timber are almost exclusively part of the Amazon. There is a small section of native forest that is still being harvested for wood in the dwindling Atlantic Forest on the east coast. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 7

12 Pine and eucalyptus are the two predominant timber species that are produced, processed and traded in Brazil. The main softwood export ports of Brazil comprise São Francisco do Sul, Paranaguá and Itajaí. For hardwood, the most significant ports for export are Belém, Paranaguá, Santarém and Vila do Conde. The eucalyptus plantations occupy 5.56 million hectares of planted forest areas in the country, representing 71.9% of the total and are located mainly in the states of Minas Gerais (25.2%), São Paulo (17, 6%) and Mato Grosso do Sul (14.5%). Of the total 7.74 million hectares of planted forests in Brazil, 4.88 million hectares (63%) are certified by FSC and PEFC. Uruguay According to the U.N. FAO, 10.0% or about 1,744,000 ha of Uruguay is forested, according to FAO. Of this 17.5% ( 306,000 ) is classified as primary forest, the most biodiverse and carbon-dense form of forest. Uruguay had 978,000 ha of planted forest, 70% of the total planted forest area is Eucalyptus (Eucalyptus spp). Change in Forest Cover: Between 1990 and 2010, Uruguay lost an average of 41,200 ha or 4.48% per year. In total, between 1990 and 2010, Uruguay gained 89.6% of its forest cover, or around 824,000 ha. The country has a stable legal environment conducive to investment in the sector and a national code of good forestry practices for achieving sustainable production, fulfilling the requirements of international demand. (LINK) Detailed description of Supply Base a. Total Supply Base area: 21,5 millions ha (Portugal and Spain) b. Tenure by type: Private: 15,4 millions ha;; Pública: 6,1 milhões ha c. Forest by type: Temperate: 21,5 millions ha d. Forest by management type: Plantations: 16,9 millions ha;; Natural/Semi natural: 4,6 millions ha e. Certified forest by scheme: FSC: ha PEFC: ha Note: There is a possibility that up to 2% of secondary material has originated in eucalyptus plantations located in Brazil and Uruguay, countries which together have an area of 868,62 million ha and 8,71 million ha occupied by forest plantations and certified areas of 7,19 million hectares by FSC and 3,32 million ha by PEFC. 5.4 Chain of Custody system The BP is certified with a FSC Chain of Custody certificate with FSC Controlled wood in the scope of the certificate. Critical control points of the FSC CoC system were evaluated also during SBP assessment. The BP has implemented FSC credit system. All the input materials are received either with FSC certified claim, FSC Controlled wood claim or the material is covered by organisation s own Controlled wood verification system. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 8

13 The controlled wood Due Diligence System includes only primary material from Portugal. During the 2016 year the BP has used secondary material sourced from primary wood from several countries (Spain, Uruguay and Brazil).This material entered as FSC Controlled Wood. Incoming wood reception register and supplier list are maintained. All material is checked during the arrival and correctly recorded in the internal system. No physical separation is needed. Based on the credit account management the proportion of the SBP-compliant and SBP-controlled biomass can be calculated. BP has done also PEFC chain of custody evaluation. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 9

14 6 Evaluation process 6.1 Timing of evaluation activities The assessment was integrating also FSC and PEFC audits, which was carried out from 23th to 25th May. Two days were needed for the SBP onsite audit and two additional days for the documentation review prior the audit Activity Location Auditor(s) Date/time Opening meeting of the evaluation* SBP_Open NCR s and OBS evaluation SBP_Documents and procedures review. Inputs review Office, RS 23/05/ Office, RS 23/05/ Office, RS 23/05/ : Break RS 23/05/ :00-14:00 Interview with Purchasing department representative and reception visits if needed Purchasing department RS 23/05/ :00-15:00 GHG calculation review Office, RS 23/05/ :00-17:15 Presentation of the results of the first day of assessment Office, RS 23/05/ :15-17:30 Opening meeting Office, RS 24/05/ :30-10:00 FSC_Open NCR s and OBS evaluation Office, RS 23/05/ NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 10

15 FSC/PEFC:Documents and procedures review;; staff interview. Office, RS 24/05/ :00 13:00 Break RS 24/05/ :00-14:00 SBP/FSC/PEFC: Chain of custody review (site tour);; interview with roundwood acceptance department Interview with Sales department representative Production facilities RS 24/05/ :00 15:00 Sales department RS 24/05/ :00-16:00 SBP/FSC/PEFC: Records Office, 24/05/ :00-17:15 Presentation of the results of the second day of assessment Office, RS 24/05/ :15-17:30 Opening meeting Office, RS 25/05/ :30-10:00 Last information s, stakeholders comments and documents Office, RS 25/05/ :00 13:00 Auditor preparation Office, RS 25/05/ :00 16:00 Closing meeting of the evaluation Estimated end of the evaluation Office, RS 25/05/ :00 17:45 25/05/ :00 NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 11

16 6.2 Description of evaluation activities The annual audit visit was focused on management system evaluation, division of the responsibilities, document and system, input material classification (reception and registration), analysis of the existing FSC CoC system and FSC CoC system control points as well as the collection of the energy and emission data. Stakeholder consultation was done to verify specific open NCRS from last evaluation. Description of the assessment evaluation: All SBP related documentation connected to the SBP as well as FSC CoC/Controlled sources system of the organisation, SBP Procedures, GHG related data, Supply Base Reports, were evaluated during the assessment. Auditor was welcomed in Enermontijo. Audit started with an opening meeting attended by the Quality Manager, the Chief Officer and the external consultant that supported the company in the SBP implementation. Auditor provided information about audit plan, methodology, auditor qualification, confidentiality issues, and assessment methodology and clarified verification scope. During the opening meeting the auditor explained CB s approval related issues. After that auditor went through all applicable requirements of the SBP standards nr.2, 4, 5 and instruction documents 5a, 5b and 5c covering input clarification, existing chain of custody and controlled wood system, management system, CoC, recordkeeping/mass balance requirements, emission and energy data and categorisation of input and verification of SBP compliant and SBP Controlled feedstock/ biomass. During this process overall responsible person for SBP system and as well as other persons having key responsibilities within the system were interviewed. After that, roundtrip around BP s pellet production was undertaken. During the site tour reception process were observed, applicable records were reviewed, pellet factory staff was interviewed and FSC system critical control points were analysed. At the end of the audit findings were summarised and audit conclusion based on use of 3 angle evaluation method were provided to the quality manager and to Industrial Production Responsible Composition of audit team: Auditor(s), roles Rui Simões Qualifications Forestry engineer > 20 year experience in forest project, management and works. Author of several fluvial and desertic restoration projects and field works. FSC, PEFC in SBP and COC auditor for NEPCon. International experience working on english, spanish and french language, besides mother portuguese. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 12

17 6.3 Process for consultation with stakeholders A formal stakeholder consultation was not conducted for this annual audit as no comments were received from any stakeholder during the period between audits. However some stakeholders (plant neighbours) were consulted regarding open non-conformity from last audit. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 13

18 7 Results 7.1 Main strengths and weaknesses Strengths: -From a sustainability perspective, the high rate of secondary feedstock consumption, from both sawmills and pulp/paper mills;; - The application for PEFC chain of custody certification besides FSC as a double system to control Weaknesses: - Very small amount of FSC controlled material received, and no amount of FSC certified during the reporting period. -Other issues see the non-conformities NCR and observation OBS reports below. 7.2 Rigour of Supply Base Evaluation Not applicable. 7.3 Compilation of data on Greenhouse Gas emissions The organization has employed external consultant who helped the organization with implementation of the system for collection of the emission and energy data. The main challenge for the organization was to use new templates for SAR and Static Biomass Profiling Data Sheet. 7.4 Competency of involved personnel Involve personnel, roles Joana Carvalho, Quality manager Giovanni Alencastro, external consultant Qualifications Industrial Engineer, specialized on renewable energies. SBP competency was acquired with SBP/FSC external training sessions. Joana is the person inside the plant with more knowledge about the SBP certification implementation, Forest Engineer, specialized on certification. External Consultant on FSC, PEFC and SBP for forestry and industries. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 14

19 João Rocha Páris, CEO Horácio Rosa, Industrial Production director Manager Licensee SBP competency was acquired with SBP/FSC external training sessions. Mechanic Engineer. SBP competency was acquired with SBP/FSC external training sessions. 7.5 Stakeholder feedback No feedback came during the period between audits, so a formal stakeholder consultation was not conducted for this annual audit. Comments from consulted stakeholders regarding open non-conformity are included on Non Conformity Reports. 7.6 Preconditions No preconditions were issued. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 15

20 8 Review of Biomass Producer s Risk Assessments Not applicable. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 16

21 9 Review of Biomass Producer s mitigation measures Not applicable. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 17

22 10 Non-conformities and observations NCR: 02/16 NC Classification: MAJOR Standard & Requirement: SBP Standard # 4 requirement Description of Non-conformance and Related Evidence: 2016 The BP has not demonstrated its commitment to occupational health and safety according to this requirement: The health and safety representative has not been appointed: Catia Baila, is the person more aware of the health and safety plan and she has a control from an administrative point of view but she is not in change on doing any monitoring or control of the implemented procedures. BP has some procedures and risk control in place, but during the facilities visit it was confirmed that the staff wasn t wearing security vest and no signal about security distance were found (security indications in place or from the staff). No evidences of health and safety training has been provided to the audit team (no records and no confirmation during interviews). During the facility tour other security signal were found, operators wear personal protection equipment s as security boots or gloves and a Health & Safety Programme developed by an outsourced company exists, thus this NCR is considered minor Organization has contracted a responsible for Health and Safety which was interviewed during the audit and it was possible to see some improvements in many areas: -Enquiry about Health and Safety to workers was done;; -Training sessions were held to workers;; - PPE (Personal protective equipment) was visible during the audit However during the audit it was possible to see risky situations related to truck unloading and loading operations involving the drivers or other operational helpers. In fact during roundwood unloading operations there was no safety procedure held about distance safeguard from the loader machine from the operator or from the truck driver. During the audit it was not possible to verify the training record of loader machine operator. Also at loading operations it was not used any safeguard related to worker/driver falling risk. At the truck entrance of the Plant it was not seen any sign about these safety issues to be seen by external drivers. Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. Timeline for Conformance: 3 months from report finalization NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 18

23 Evidence Provided by PENDING Organisation: Findings for Evaluation of PENDING Evidence: NCR Status: OPEN Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 03/16 NC Classification: MAJOR Standard & Requirement: SBP Standard # 4 requirement Description of Non-conformance and Related Evidence: 2016 During the stakeholder consultation some questions were raised about legislation, rules and regulations. During the audit process all of the issues were verified as: -Industrial License nº1460 from 27/04/2010, and its renovation at 06/02/2012 with number 1616;; -Residual Operational Authorization from 15/11/2010 CCDRLVT;; Air particles self-controlling letter from authorities CCDRLVT 27/05/ Air particles measurements for air quality by accredited Sondarlab from 2015 and 2016;; -Atmospheric pollution analysis report about CO, NOx, SO2,COV, PTS, H2S from accredited SONDAR 16/10/2015;; - Last forest authorities (ICNF) plant visit report on 26/04/2016 In the plant the following conditions were verified: - preventive measures of low levels of powder in the air thought irrigation methods;; - a closed fence around the Plant station to prevent the most part of industrial noise;; -asphalt cover of all the log yard was not complete, but the on process to complete the present summer season. The conclusion of the audit in connection of the complaints is that all the issues were well addressed by BP, with one exception, the industrial timetable. In fact the Renovation industrial license (1616) states that the loading and grinders activities must be suspended from 7 pm, and that couldn't be evidenced during the audit. In fact interviewed workers, neighbours and the Plant time-table includes this activity until 12 pm which constitutes a minor non-conformity. It is considered as minor because it wasn't evidenced those activities were regular During the audit it was possible to verify the asphalt was covering the majority parts of the plant. The Plant time-table for the activities was still the same from last year, meaning noisy activity until 24:00h. The interviewed people gave different answers about the working activities and noise: - Filipe Piteira and other BP personnel stated working activities until 20:00 hours;; - Parish administrative representative (Junta de Freguesia) and neighbour café were telling that didn t heard noise comments anymore. But administrative representative complained NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 19

24 about the air pollution (fine sawdust powder) on the plant surroundings and the problem of the road, which were always full of forest feedstock wastes;; A closer neighbour family was very affirmative about noisy activities until very late, reaching until midnight, frequently even if it wasn t on a daily basis. Also this family was complaining directly to Enermontijo and to environmental police about air sawdust in the house and garden. Environmental police agents after site diligences issued two notifications about environmental irregularities to competent authorities. Exhibit 11 - Official letter 3209/16/DSEPNA Based on the interviews results it is not possible to close the non conformity. Corrective action request: Timeline for Conformance: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 6 months from report finalization Evidence Provided by PENDING Organisation: Findings for Evaluation of PENDING Evidence: NCR Status: OPEN Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 04/16 NC Classification: MAJOR Standard & Requirement: SBP Standard # 4 requirement Description of Non-conformance and Related Evidence: 2016 The BP as on its Manual 11. has a mechanism in place for comments and complaints about SBR or SBP certification, which includes the details of documentation, investigation and remedial actions. However, in the past there were received some complaints (in regards to pollution or noise) and these were not addressed at full extend. Taking into the consideration that the procedures were updated after the complaint were received and the responsible person is aware about the updated procedures this is considered as minor NCR BP didn t present any addressed complaints according to its procedures. During the audit it was possible to interview a neighbour family who confirmed many complaints about sawdust and noise since the plant installation. Also a notification of environmental police agents was not addressed like a complaint. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 20

25 Also this family had complained directly to PB plant being last times on September 2016 and February Based on this interview result it is not possible to close the non conformity. Corrective action request: Timeline for Conformance: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 3 months from report finalization Evidence Provided by PENDING Organisation: Findings for Evaluation of PENDING Evidence: NCR Status: OPEN Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 01/17 NC Classification: Minor Standard & Requirement: SBP Standard # 2 requirement 6.3 Description of Non-conformance and Related Evidence: Supply Base was defined by BP as the larger borders of the countries where the feedstock comes: Primary feedstock from Portugal and Secondary feedstock from Portugal. Spain, Brazil and Uruguay. Primary feedstock is verified based on transportation documents for each load;; Secondary feedstock is verified with supplier declarations and verification program sampling loads every month. But from Navigator pulp/paper mills, GT176079, BP has recorded the place of the mills but did not develop any origin verification of the wood. For this supplier the BP has presented two declarations: Supplier Declaration Exhibit 9 and also 2016 Fibrous Raw Materials Exhibit 10. During the audit it was not concluded that the BP could ensure the place of harvesting for all secondary feedstock. This is considered a minor non conformity to this indicator, as no sales of SBP claimed material were done during the reporting period. Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. Timeline for Conformance: 12 months from report finalization Evidence Provided by PENDING Organisation: NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 21

26 Findings for Evaluation of PENDING Evidence: NCR Status: OPEN Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 03/17 NC Classification: Minor Standard & Requirement: SBP Standard # 5 requirement: ID5b: Description of Non-conformance and Related Evidence: The biofuel share of biodiesel (6,75%) was not included on SAR document by BP but it is on CB comments. 2/ Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. Timeline for Conformance: 12 months from report finalization Evidence Provided by PENDING Organisation: Findings for Evaluation of PENDING Evidence: NCR Status: OPEN Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No OBS: 01/17 Standard & Requirement: SBP Standard # 5 requirement ID5b;;5.1.5) Description of findings leading to observation: Report Section Appendix E p 11.5 BP methodology to calculate the total fossil fuel used is a linear calculation from records of the total machines used on production. Cross checking from fuel supplier invoices has turned an extra volume of fuel (6220 l) not explained by presented data. No initial or final stocks were presented. Observation: All data used for reporting energy should be justified by BP. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 22

27 11 Certification decision Based on Organisation s conformance with SBP requirements, the auditor makes the following recommendation: Certification approved: Upon acceptance of NCR(s) issued above Certification not approved: Based on auditor s recommendation and NEPCon quality review following certification decision is taken: NEPCon certification decision: The Biomass Producer has been certified by NEPCon as meeting the requirements of the specified SBP Standard, the certificate can be maintained. Major non-conformities were identified and these must be closed within 3 or 6 months from the report finalization. Certification decision by: Ondřej Tarabus Date of decision: 17/07/2017 Next surrveilance audit should take place: within 12 months more frequently (please specify) NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 23

28 12 Surveillance updates 12.1 Evaluation details Audit took place from 23 to 25 of May. Details can be found in point 6.2 above Significant changes No significant changes which would be affecting the management of SBP or FSC chain-of-custody certification Follow-up on outstanding non-conformities NCR: 02/17 NC Classification: MAJOR Standard & Requirement: SBP Standard # 2 requirement 6.5 Description of Non-conformance and Related Evidence: During the audit it was possible to confirm that BP was recording the origin of feedstock supplied with FSC certified claim. The only FSC certified input entered only during 2017 year (PALSER GR from 09/05/2017). However in the case of FSC controlled wood inputs from Navigator, BP did not keep the records of the origin as it was done only based on declarations (as addressed by NCR 01/16 and NCR 01/17). Corrective action request: Timeline for Conformance: Evidence Provided by Organisation: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 3 months from report finalization Before the ending of report a supplier Verification Audit was conducted to The Navigator Company, by NEPCon. Findings for Evaluation of Evidence: The Verification Audit to The Navigator Company (TNC) was focused on the origin of the wood supplying both pulp plants, which were supplying Enermontijo. The origin was evidenced by TNC based on invoices, contracts, and Due Diligence System. The Organization has recorded the regions of origin, from Iberian Peninsula and South American countries. CLOSED NCR Status: Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 24

29 NCR: 01/16 NC Classification: minor Standard & Requirement: SBP Standard # 2 requirement 6.2 Description of Non-conformance and Related Evidence: BP includes in their procedures the record of the identity of the primary processor but it was not found in procedures the record of place of harvesting of the wood. For example there were not assurance that the place of origin of wood stumps of secondary feedstock from The Navigator Company, was within their SBE and was not recorded on BP system. Nevertheless on 2015 period this feedstock was not classified as SBP Compliant so it is a minor NCR. Corrective action request: Timeline for Conformance: Evidence Provided by Organisation: Findings for Evaluation of Evidence: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 12 months from report finalization During the reporting period BP has not purchased any inputs classified as SBP-compliant Secondary Feedstock. Only during 2017 a FSC certified input entered (PALSER GR from 09/05/2017). The place of origin and the identity of the primary wood processor was recorded by BP. The only record available was verified and responsible staff confirmed the BP procedure. It was correctly verified by documents of origin send by supplier (phytosanitary manifest), confirming origin declaration. NCR Status: CLOSED Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 05/16 Standard & Requirement: NC Classification: minor SBP Standard # 5 requirement 5a 3.7.1,;;5.1.1 Description of Non-conformance and Related Evidence: BP has calculate energy used to haul forest products to the plant in l/t, using the travel distance,tonnes of biomass by truck and references to trucks consumption. Distance and load data were well supported in evidences. However data of fuel consumption was not based on real measurements and the calculated values are not well done on GHG table, with a score in a range of 0,01 l/ton Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 25

30 Timeline for Conformance: Evidence Provided by Organisation: Findings for Evaluation of Evidence: Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 12 months from report finalization New SBP instruction document 5b does not require to record the fuel consumption anymore. New SBP instruction document 5b does not require to record the fuel consumption anymore. NCR Status: CLOSED by update Instructions. Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 06/16 NC Classification: minor Standard & Requirement: SBP Standard # 5 requirement 5a Description of Non-conformance and Related Evidence: BP is using for its feedstock mainly Pinus pinaster, Pinus pinea and Eucalyptus sp., but also other residuals species are sourced. Material is classified at the entrance point using the internal classification registered in the IT system. Problems found on classification or its accuracy were the lack of evidences to classify pine logs as thinnings or stemwood (long rotation forestry) so the amount of volumes used into this classification was an estimation from its supply responsible (António Páris). Nowadays there is a specific procedure at the entrance point (8.1 Manual exhibit1): The truck driver and/or supplier contact will be asked if the forest activity in the harvesting place was a final felling or thinning. During the unloading, BP staff will identify the prevailing age of the material and the load will be classifies as more or less of 40 years. This information is recorded in the IT system. Corrective action request: Timeline for Conformance: Evidence Provided by Organisation: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 12 months from report finalization At the entry of each truck the driver is questioned about information from forest location, forest size, age of wood in two classes (more or less 40 years) and phytosanitary manifest number. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 26

31 Findings for Evaluation of Evidence: During the audit the records were fully verified and searches using several filters on information. Also an entry was verified and the questions were well answered by driver. NCR Status: Closed Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 07/16 NC Classification: minor Standard & Requirement: SBP Standard # 5 requirement 5a Description of Non-conformance and Related Evidence: BP has included energy used for forestry from a public report of eucalyptus plantations in Brazil including every forest management practices from soil preparation, plantation until the final felling. Justification of this source used by BP is because of the accuracy of study in similar conditions. BP didn't found any local study with same precision. The same value of 3,28 l/ha for eucalyptus has been used for pine and other forest management practices. A minor non-conformance is issued because BP didn't use the data as much accurate as possible,in the local reality. Corrective action request: Timeline for Conformance: Evidence Provided by Organisation: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 12 months from report finalization New SBP instruction document 5b does not require to record the energy data for soil preparation, plantation and harvesting but allow to use Biograce II data instead which was done by the organization. Findings for Evaluation of Evidence: SAR document contain the information about the soil preparation, plantation and harvesting. The organization has used Biograce II data. CLOSED by update Instructions. NCR Status: Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 27

32 NCR: 08/16 NC Classification: minor Standard & Requirement: SBP Standard # 5 requirement 5a Description of Non-conformance and Related Evidence: External chipping fuel data used were sourced by one of BP suppliers and it is aceptable and conservative. Electric data is a realistic value but it was not based in any evidence so a minor nonconformity is issued. Corrective action request: Timeline for Conformance: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 12 months from report finalization Evidence Provided by Organisation: Findings for Evaluation of Evidence: New SBP instruction document 5b does not require to record the energy used for chipping separately. New SBP instruction document 5b does not require to record the energy used for chipping separately. NCR Status: CLOSED by update Instructions. Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 09/16 NC Classification: minor Standard & Requirement: SBP Standard # 5 requirement 5a Description of Non-conformance and Related Evidence: BP has average moisture values for each feedstock categories, and they are realistic with default values. But these averages were not very robust for year 2015: -Chips from forestry residues have only data from one site, from August to November, representing 5% of total amount of this category;; -Sawdust and chips moisture data was only recorded on a few days Corrective action request: Timeline for Conformance: Evidence Provided by Organisation: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 12 months from report finalization Procedures of BP include now moisture measures over all inputs except roundwood. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 28

33 Findings for Evaluation of Evidence: During the audit the measurement of inputs was seen and records were verified. They were done in a hourly basis. NCR Status: CLOSED Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 10/16 NC Classification: minor Standard & Requirement: SBP Standard # 5 requirement 5a 6.1 Description of Non-conformance and Related Evidence: The received profiling information doesn't includes the forestry practices description, with consistency with SBR. Corrective action request: Timeline for Conformance: Evidence Provided by Organisation: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 12 months from report finalization New SBP instruction document 5c were used and Static profiling data were provided. Findings for Evaluation of Static profiling data were evaluated as containing all required Evidence: informaiton. NCR Status: CLOSED by update Instructions. Is the non-conformity likely to impact upon the integrity of the affected SBPcertified products and the credibility of the SBP trademarks? Yes No NCR: 11/16 NC Classification: minor Standard & Requirement: SBP Standard # 5 requirement 5a 8.3 Description of Non-conformance and Related Evidence: Proportions of hardwood and softwood included on Profiling data are not consistent with other consumption data. Exh, 5 Corrective action request: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 29

34 Timeline for Conformance: Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. 12 months from report finalization Evidence Provided by Input data (proportions) from hardwood and softwood is now Organisation: recorded at Static Biomass Profiling Data. Findings for Evaluation of The input data were verified at SBR (Exhibit 4), SAR (Exhibit 2) Evidence: and Static Biomass Profiling Biomass Data (Exhibit 3), and they are robust. NCR Status: CLOSED Is the non-conformity likely to impact upon the integrity of the affected SBP- Yes certified products and the credibility of the SBP trademarks? No NCR: 12/16 Standard & Requirement: NC Classification:minor SBP Standard # 2 requirement 2C,.4.1 Description of Non-conformance and Related Evidence: The SBR covers the most part of important features. It is done on latest version of SBP website on the audit date. However it doesn't include a concise summary of why a SBE was determined to be required or not required. Corrective action request: Timeline for Conformance: Organisation shall implement corrective actions to demonstrate conformance with the requirement(s) referenced above. Note: Effective corrective actions focus on addressing the specific occurrence described in evidence above, as well as the root cause to eliminate and prevent recurrence of the nonconformance. By the next annual surveillance audit Evidence Provided by 2016 SBR Organisation: Findings for Evaluation of Evidence: Organization has included a justification about SBE not being developed. NCR Status: CLOSED Is the non-conformity likely to impact upon the integrity of the affected SBP- Yes certified products and the credibility of the SBP trademarks? No NCR: 13/16 NC Classification: minor Standard & Requirement: SBP Standard # 5 requirement 5a Description of Non-conformance and Related Evidence: BP has demonstrated the truck loads from real 2015 data, and distance to Setubal. Fuel consumption is still based on same academic work as above and not on real measurements. NEPCon Evaluation of Enermontijo: Public Summary Report, First Surveillance Audit Page 30