Atul has presented plans to address these impacts to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host country laws and regulations and the World Bank/IFC environment and social policies and the environmental, health and safety guidelines. Information about how these potential impacts will be addressed by Atul is summarized in the paragraphs that follow. Further information is provided in the attached Corrective Action Plan (CAP), which is agreed upon by IFC and Atul and will address the compliance gaps with IFC’s requirements.
- Land and natural environment:
Atul owns the land for both, Atul and Ankleshwar sites. The Atul site is located by the Par River, which is approximately 8-km from the Arabian Sea. The majority of the Atul site is undeveloped and has been preserved by Atul as a natural protection area, in cooperating with World Wildlife Fund (WWF) – India. The Atul operations are the only industries in the Atul area. The Atul site also houses a residential colony of approximately 1,100 houses. At approximately 1.5 km from Atul site, there is a farming community. The major land usage in the Par River basin is mango orchard. There are no endangered species in or near the Atul site. The Ankleshwar site is located inside a chemical industry park – Ankaleshwar industrial estate, which is one of the largest and well organized in India.
- EHS management system:
There is a corporate Safety, Health, and Environment (SHE) Department in Atul, which report directly to the vice president of infrastructure. There are EHS coordinators in each manufacturing division and key operation process. The SHE department also leads the operations of onsite water treatment plant, wastewater treatment plant, waste incinerator, and landfill. Four manufacturing divisions have got ISO-9001 and ISO-14001 certification. The remaining two divisions of colors and aromatics are working for the certification. Atul also adopts the voluntary initiatives of Responsible Care(. Atul has contracted a third party to conduct a comprehensive EHS/social auditing for its operations. The final auditing report will be available for IFC review.
In accordance with the CAP requirements, the SHE department will systematically review the recommended corrective actions raised in the proposed or existing EHS audits, assessment, and hazard and operability study (HAZOP), and prepare an implementation plan with responsible party, timeline, and budget for both sites.
- Water source and wastewater treatment:
The Atul site obtains fresh water from the Par River. There is a water treatment plant in the Atul site, which supplies processes water, and drinking water for the residents in the colony and nearby villages. The treated water meets both local regulatory and WBG/IFC requirements for drinking water. At the Ankleshwar site, water is obtained from the local municipal supply.
Both sites have respective internal wastewater treatment plants, where wastewater is treated before discharge. Treated wastewater at the Atul site is discharged by a submerged pipeline to the Par River 4-km downstream of the site during the high tides. At the Ankaleshwar site, the treated wastewater is discharged to a common effluent creek that discharges to the sea. The effluents meet both local regulatory requirements and WBG/IFC guideline limits, with the exceptions of total nitrogen, chemical oxygen demand (COD), and total suspended solids (TSS), which exceed the WBG/IFC guideline limits. In accordance with the CAP, Atul will start monitoring adsorbable organic halogen (AOX) and benzene, ethylbenzene, toluene, xylenes (BETX), and reduce the levels of total nitrogen, COD, and TSS, and meet all the WBG/IFC guideline limits by project completion. Atul will also take practical methods to minimize the upset of the biological treatment thus avoiding overflow of untreated wastewater.
- Air emissions and ambient air quality:
Atul obtains its energy from captive coal-fired power plants located on site. Onsite air emission sources include power plants, incinerator, and emissions from various processes. Emission control equipments are widely used onsite, including bag filters, water scrubbers, acid/alkali scrubbers, and electrostatic precipitators (ESP). The dust collected from the bag filters and ESPs are utilized to manufacture bricks onsite. The air emissions meet the local regulatory requirements and the WBG/IFC guideline limits, with the exception of particulate matter (PM). As required in the CAP, Atul will take applicable methods to reduce the PM levels and meet the WBG/IFC guideline limit for PM by project completion.
The ambient air quality concentrations meet both local regulatory requirements and WBG/IFC guideline limits, with the exception of PM level. Atul will take practical steps to further control fly ash and coal dust inside the plant and to mitigate the dust generation by its raw material transportation in accordance with the CAP. Atul will also start monitoring the ambient air quality at its residential colony.
- Workplace and ambient noise levels:
The workplace and ambient noise levels meet both local regulatory requirements and the WBG/IFC guideline limits. Atul will start monitoring ambient noise level at its residential colony, as required in CAP.
- Solid and hazardous wastes:
The major solid wastes generated onsite are packing wastes and household wastes, which are picked up and disposed of by municipal government contractors.
The Atul site generates mercury sludge from the chlor-alkali process for chlorine manufacturing which is disposed at an onsite landfill. The landfill has triple concrete/HDPE composite linings with leachate collection system. The leachate is transferred to the wastewater treatment plant for treatment. The other inorganic hazardous wastes generated onsite and the sludge from the wastewater treatment plant are also disposed at the landfill. The landfill has groundwater monitoring wells located at each corner. The monitoring results do not show mercury detection in the groundwater. Atul will also start monitoring other priority pollutant metals in the groundwater. Atul has started replacing the mercury cells with membrane cells for chlor-alkali process, which are more efficient and do not generate hazardous wastes. At present stage, there are 22 membrane cells and 10 mercury cells. Atul plans to phase out all the mercury cells by 2012.
Atul also generates approximately two tons of various organic wastes per day. The organic wastes generated at Ankleshwar site are disposed of at a licensed incinerator. The incinerator is designed to destroy dioxins/furans, and dioxins/furans are also monitored. The organic wastes from Atul site is incinerated at an onsite incinerator. The incinerator is designed to destroy dioxins/furans. However, there is no monitoring of dioxins/furans from the incineration emissions. Atul agrees to dispose of all the chlorinated wastes at the Ankleshwar incinerator before the dioxins/furans are monitored and the results meet both local regulatory requirements and best industrial practices. Atul will also improve the segregation of chlorinated and non-chlorinated organic wastes. At the Atul site, a new incinerator will be commissioned in the next few months which is expected to achieve complete destruction of dioxins and furans. As required in the CAP, Atul will monitor dioxins/furans routinely if the onsite incinerator is used to dispose of chlorinated organic wastes.
- Operation hazard and hazardous materials:
There are a phosgene plant and a chlor-alkali plant inside Atul site. Besides, there are various other processes with operational hazards. Atul has conducted hazard and operability studies (HAZOP) for all the processes. The HAZOPs, prepared by both external consultants and internal process safety specialists, are updated whenever a process is modified.
The phosgene, which is manufactured as an intermediate, is consumed internally at other plants of Atul site. The phosgene plant is audited annually and has being audited and certified by an external certification agency as having safety control devices, procedures and training programs. In addition, a third party consulting firm conducted a process safety audit for the phosgene plant in April 2004. Phosgene is only stored onsite for maximum one day’s consumption. All the storage tanks are checked every two years for integrity. The phosgene plant has automatic monitoring/alarm system with extra ventilation and ammonia/water sprinkling, which can neutralize the toxicity of phosgene. The operation room is positively pressured and the phosgene transferring line is jacketed with nitrogen layer and computerized monitoring for leak. Atul is now contracting consultants to conduct a quantitative risk assessment for the phosgene plant. There is no recordable accident in the phosgene plan in the past 30 years.
Chlorine is also manufactured as an intermediate at chlor-alkali plant and consumed internally at other plants of Atul site. There is an automatic monitoring alarm system at the chlor-alkali plant. All the storage vessels are operated under negative pressure and tested for leak every month.
The hazardous raw materials used at Atul include diesel, toluene, methanol, isopropanol, etc. Most of the hazardous materials are stored in the above-ground storage tanks with secondary containment walls. Toluene, methanol, and isopropanol at the polymer division are stored at the underground tanks. The integrity of the tanks is checked two years ago, and the groundwater and soil are monitored regularly. Atul will start monitoring BETX in the groundwater monitoring in accordance with the CAP. All the raw materials are transported to the site, via truck on the highways, by the suppliers. The conditions of the highways are good. As required in the CAP, Atul will provide defensive driving trainings for its own and contractor drivers.
Atul’s agrochemical division does not manufacture banned chemicals or pesticides listed in World Health Organization’s IA and IB categories.
- Occupational health/safety:
Atul has an established occupational health and safety (OHS) management. All employees are required to have at least 16-hour’s EHS training per year. SHE department conducts routine inspection for the OHS situation at each division, and present the findings and corrective actions in the monthly management review meeting. There is an onsite clinic at Atul site with three doctors for first aid. As required in the CAP, Atul will review its personal protection equipment (PPE) inventory, check the PPE effectiveness, and improve its PPE procedures for some critical processes, such as phosgene and chlorine manufacturing. Atul should also enforce its OHS procedure, promote near-miss management, and reduce the recordable incidence rate in accordance with the CAP.
Fire prevention and emergency response: Atul has a well established on-site emergency management plan for potential fires and chemical releases. Atul has its own fire brigade with fire trucks and ambulances. There are two onsite fire fighting / emergency response (ER) drills per year, for which it invites local government agencies and the fire departments to participate in. Atul also provides ER training for the residents of its residential colony. As required in the CAP, Atul will also conduct one off-site ER drill per year for mitigation of the potential toxic gas release or fire. Atul will release related material safety data sheets (MSDS) to the local hospitals and involve the local hospitals for all the ER drills in accordance with the CAP. Atul will also expand its ER trainings to the nearby villages.
- Labor situation:
To increase its competition, Atul has significantly reduced its labor force in recent years through voluntary early retirement and slowing down hiring process. Atul follows all the local regulations related to the retrenchment process.
- Community relationship:
Atul keeps fairly good relationship with local villages. Atul provides drinking water for the nearby villages at the lower reaches of Par River. The villagers can also send their children to Atul’s elementary and middle schools. In addition, Atul set up a charitable trust, Atul Rural Development Fund in 1978, which provides the various welfare services to the nearby rural area.
