The sponsor has presented plans to address these impacts to ensure that the proposed project will comply with applicable host country laws and regulations and World Bank Group requirements. The information about how these potential impacts will be addressed by the sponsor is summarized in the paragraphs that follow.
The pulp and paper operations of this company involve five separate plants, one in northern India and the remainder in the forest areas of central India. The company was required to carry out an environmental audit of its facilities. The results of this audit indicate that the company is operating in compliance with Indian regulations and standards for this industry. The company is also generally in compliance with IFC’s waste emission guidelines, with exceptions as discussed below, and that upgrading to address specific issues is underway.
Plant siting in all cases does not raise any substantial issues. The plants are usually remote from larger urban centers, although workers’ villages may have been established in the immediate vicinity. The Shree Gopal unit in Haryana was originally in an agricultural area but the town of Yamunanagar has grown up around it. No cases of site contamination were identified during the environmental audit. None of the sites impact on any environmentally-sensitive areas.
Air emissions from power and recovery boilers meet IFC’s SO2 and NOx limits, but are slightly over the limit for particulates in all cases. These boilers are fitted with electrostatic precipitators, and the company will improve the performance of this equipment and add additional pollution control equipment as needed to comply with the World Bank Group guideline. Total S emissions, calculated based on very limited data from the plants, is over the limit specified in the World Bank Group guideline, and the company will improve its monitoring in this regard and determine a program and schedule to achieve compliance. As a result of the process and equipment used, odors due to release of TRS are minimal. The company is installing lime kilns for reprocessing of their lime sludge, and these will be fitted with appropriate pollution control equipment to ensure that they meet World Bank Group air emission guidelines from the outset.
All of the mills have comprehensive wastewater treatment facilities using the activated sludge process, and as a result have no problems in meeting both national and World Bank Group wastewater effluent limits. The company has recently started measuring AOX levels in their effluents, and in all cases they are meeting the World Bank Group guideline for this parameter. However, the environmental audit identified the need for improved laboratory procedures to ensure the accuracy of these (and other) analyses, and the company has committed to the required improvements in quality control.
The major solid waste issue at all plants, except for APR, is the disposal of lime sludge, which is currently stockpiled on company land in the vicinity of the mills. At the Ballarpur plant, the lime sludge disposal area has been partially reclaimed and successfully revegetated. However, the company is installing lime kilns, which will result in recycling of the lime sludge, rather than land disposal as now practiced. Other sludges, construction waste and miscellaneous waste are also sent to landfills, which are on company property and properly managed. At some plants, wastewater treatment sludges are sold to other operators for use in particle board production.
All of the units use elemental chlorine in their bleaching process. The World Bank Group guideline specifies that elemental chlorine should be phased out in favor of other Elemental-Chlorine-Free (ECF) bleaching processes. The company has recognized the need to reduce elemental chlorine use and is moving to install oxygen delignification prior to bleaching in the Ballarpur and Shree Gopal plants, and is considering other options for the smaller facilities in Orissa. As noted previously, the plants are already achieving the World Bank Group guideline for AOX in their effluent water, and this upgrading will further reduce this parameter.
Storage and handling of hazardous chemicals and other materials was found to be reasonable and adequate at all units. No PCBs or friable asbestos is used at any of the sites. General housekeeping is adequate to good in all cases, although the environmental audit did note some instances of poor maintenance practices, which the company will address. The company is very safety conscious, and warning and information signs regarding safety practices are common. Equipment is properly guarded, and personal protective equipment is provided. The company provides detailed training for staff in safety practices. Medical clinics for workers are provided at all plants.
Fire protection equipment includes fire extinguishers and hydrants, and overall management of fire risks is adequate in all cases. All plants have a detailed emergency response plan, and staff have been trained in handling emergency situations.
Wood supply is from two types of sources. Bamboo is harvested from government forest concessions in central India, using labor from local forest villages. The company only has rights to harvest bamboo, which comprises 25% of the forest cover; all remaining tree species are reserved for harvest by local (tribal) people. Harvesting practices ensure the regrowth of the bamboo plants, and this harvesting is sustainable. The majority of the wood supply (including eucalyptus, acacia, poplar and casuarina) is purchased from smallholders who grow trees as an auxiliary crop on their farms. The company has nurseries and an extension service to provide improved, fast-growing planting stock and to assist villagers in tree culture. The forestry operations of the company are fully compliant with OP 4.36 Forestry and OP 4.20 Indigenous Peoples.
The environmental audit identified a need for standardization of laboratory procedures and practices, including quality control, and adoption of uniform reporting practices for environmental and health and safety matters across the group. The company will incorporate these findings into the comprehensive Environmental Management System (EMS) which is currently being developed to cover all operations. The company is applying for ISO 14001 certification for its EMS.
All of the units are very active in supporting community services in their local area. These include supplying (tree) planting stock for use by the community, financial support for medical clinics, contributions to local schools and colleges, supply of potable water, provision of buildings such as meeting halls for public use, and sponsorship of cultural, educational, sporting and recreational events.
