The sponsor has presented plans to address these impacts to ensure that the proposed project will, upon implementation of the specific measures agreed, comply with applicable host country laws and regulations and World Bank/IFC requirements. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. (Further information is provided in the attached documentation.)
The ISMT plant is located in the Maharashtra Industrial Development Corporation (MIDC) industrial area. The project site is approximately 3 km away from Nagapur Village, which is the nearest populated area and about 8 km away from the town of Ahmednagar. The plant to be acquired as part of the project is also located in the MIDC industrial area and at approximately 2 km from the Toldwwadi Village and between 6 to 8 km away from the town of Baramati. Neither of the two sites is located near sensitive habitats nor there is a need for resettlement or economic displacement as a result of the project.
The stack emissions for the boiler and the rotary hearth furnace at the ISMT demonstrate that these units are operated in compliance with the applicable World Bank guidelines for particulates, NOx, and SOx. The sponsor will provide the induction furnace air emission concentrations before the first disbursement. If the testing demonstrate that the emissions are above the World bank guidelines, the sponsor will also submitted the proposed measures to reduce the concentrations to acceptable levels.
The stack air emissions (particulate matter and SOx) at the rotary hearth furnace, the walking beam furnace, and the thermic fluid heater for the facility to be acquired were reported to be in compliance with the applicable World Bank guidelines.
The ambient air quality at the main gates of the ISMT facility as well as the facility to be acquired is monitored. The parameters measured comply with the Indian requirements at both sites. However, the particulate matter concentrations are greater than the 50 ug/m3 applicable World Bank guideline. Though the particulate matter concentrations are higher than the norm, the same is attributable to general atmospheric pollution in the area on account of vehicular traffic, etc. The sponsor will continue implementing measures to ensure that no fugitive emissions are generated as a result of their operations.
The water used for the process and drinking purposes is obtained from the industrial complex water supply system. Both plants recirculate the cooling water used in the process reducing thereby the overall amount of water consumed.
The liquid effluents, process and domestic waters, generated at both facilities, are treated on on-site wastewater treatment plants and comply with the Indian requirements. However, the treated total suspended solid concentrations at both sites are greater than the 50 mg/l applicable World Bank guideline. The sponsor will inform IFC about the additional measures to be taken to reduce these concentrations before the first disbursement. The treated water is used to irrigate the sites green areas.
The sanitary sewage is also treated and will comply with the applicable World Bank coliform concentration guideline of 400 MPN/100 ml at both sites.
Industrial solid residues generated at both sites include scrap and scales and sludges. The scrap is sold for recycling. The sludge generated at the wastewater treatment plants is taken to a sludge drying bed and then use for landfilling/leveling within the plants premises. The scale collected from the scale pits and quenching tanks is also used for landfilling/leveling in the plants premises.
Fuel oil is the fuel used at both plants. In addition acetylene, sulfuric acid and caustic soda are also used in the process. The fuel and chemicals are properly handled and stored. The fuel oil tanks have double containment to prevent risk of soil contamination in case of leaks or accidental spills. The chemicals storage areas are located separated from the process an away from potential inadvertent accident sources.
Noise levels will continue to be maintained below 85 dB(A) complying thereby with World Bank guidelines. When the noise levels are higher, the employees are required to use hearing protection. Fuel and hazardous materials are properly stored and handled. The fuels and raw materials storage areas have secondary containment to reduce the risk of soil contamination in case of accidental spills or leaks.
The merger of ISMT and KSTL will result in redundancy of 105 staff (38 from ISMT and 67 from KSTL). Compensation packages were negotiated under a collective bargaining process between representatives of the Company and the staff/workmen (the union). Company and Union representatives jointly act on a bilateral committee to address day to day problems and redress grievances. The redundancies, most of which are from support departments (finance and accounts, secretarial, legal, human resources, commercial and trainees), are divided into bargainable and non-bargainable categories.
The bargainable category, representing about 71 % percent of redundancies, includes clerical, technical, and a few workmen positions. The company will offer a package of assistance to the bargainable redundancies, including vocational rehabilitation, opportunities for service on a contractor basis or redeployment in the group’s other facilities and compensation. Financial compensation will be determined based on the number of years of service and number of years left to retirement.
The non-bargainable category affects 27 managerial and officer level employees. Non-bargainable redundancies are given up to a three month period during which time they will remain on the employment rolls and will be paid full salary, but will be given time to search for new jobs. The Company has contracted a reputable recruitment agency to provide career counseling and other employment assistance to non-bargainable retrenchies. On securement of a new position, the Company will pay the employment placement fee.
Indian Seamless will ensure that the environmental, health and safety measures are up to date and that the employees are properly trained. Personal protective equipment will continue to be provided to and required to be used by the employees including hard hats, and dust masks and hearing protection to be used in working in areas with high dust and noise levels. The employees will receive pre-employment and periodic medical check-ups.
Qualified personnel will continue implementing health and safety programs, and Indian Seamless’s will continue training the employees in occupational health and industrial safety issues.
The sponsor has developed contingency and emergency response plans for the events of fire, explosion, gas leakage, etc. The sponsor has a fire prevention system in place including a fire emergency response program, has a designated fire brigade available at all times, and regularly conduct fire training and drills. The plant has a hydrant distribution system throughout the project grounds as well as hydrants and fire extinguishers.
As part of Indian Seamless’s environmental management plan, the sponsor will maintain a monitoring program that includes periodic air quality and stack emissions testing, process and domestic wastewater concentration assessments; risk and incident control programs; as well as periodic environmental audits.
Indian Seamless will have a Department for Environmental and Occupational Protection in charge of overseeing these activities at both sites.