IFC requires that this document is made available through the World Bank InfoShop and to the locally affected community no less than 30 days prior to project consideration by the IFC Board of Directors. The Summary of Project Information (SPI) also provides details of where the ERS has been made available to the locally affected community. The SPI must be sent to World Bank InfoShop no less than 30 days prior to project consideration by the IFC Board of Directors.

This is a Category B project according to IFC’s Procedure for Environmental and Social Review of Projects because a limited number of specific environmental impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria. The review of this project consisted of appraising technical and environmental information submitted by the project sponsor. The following potential environment, health and safety, and social impacts of the projects were analyzed. - Site location (including land ownership and land use), and environmental conditions; - Environment, health, and safety (EHS) management; - Water source and liquid effluent; - Air emissions, workplace monitoring, and ambient air quality; - Workplace and ambient noise levels; - Hazardous materials handling; - Mercury bearing Brine sludge landfills; - Other solid/hazardous waste handling and disposal; - Occupational health and safety; - Fire prevention and emergency response plans; - Energy consumption and energy efficiency; - Community involvement and relationship; - EHS situations at other DSCL operation locations.

The company 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, host country laws and regulations and World Bank/IFC environment and social policies and the environmental, health and safety guidelines. Information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow. - Kota Complex consists of several manufacturing plants: power plant, calcium carbide plant, cement plant, chloralkali plant, fertilizer plant, PVC plant, PVC compounding plant, and common supporting units. It is located at Shriram Nagar, Kota, Rajasthan, India with the total land of 791 acres. This land is leased from state government for 99 years (from 1963 to 2062). The Kota complex is within an industrial area declared by Rajasthan State Government and Pollution Control Board. It is approximately 5 km away from the major residential area. However, there is a residential colony belonging to another Shriram Group company, adjacent to the Kota complex with approximately 2,000 residents. There is no land purchase involved in the proposed project. - The Kota Complex has certificates for ISO 9001:2000, ISO 14001:1996, and OHSAS 18001:1999. An environmental impact assessment (EIA) for this project, with executive summary in both English and prevailing local language, has been prepared according to IFC’s requirement. Both DSCL Kota complex and IFC have EIA copies, which is available for review upon request. - DSCL has a corporate level EHS management system. General manager of EHS is responsible for corporate wide EHS issues and reports to the corporate management board. There is a corporate level EHS policy. DSCL has developed an implementation procedure for the corporate EHS policy to increase the EHS managerial efficiency. - The liquid effluents meet both local regulatory requirements and WBG/IFC guideline limits, with the exception of total suspended solids (TSS) and total nitrogen (TKN), which meet the local requirements, but fall slightly short of WBG/IFC guidelines. DSCL will increase the management and efficiency of the wastewater treatment plant to ensure complete compliance with WBG/IFC guideline. - At the Kota complex, there are bag filters and electrostatic precipitator (ESP) to control air emission. The air emissions meet both local regulatory requirements and WBG/IFC guideline limits. The workplace air quality also meets WBG/IFC’s requirement, with the exception of dust levels at a few locations in cement plant and calcium carbide plant inside Kota Complex, which meets local guidelines but fall slightly short of WBG / IFC guidelines. DSCL will take effective steps to reduce dust generation. The ambient air quality meet both local government regulations and the WGB/IFC guideline limits. DSCL will monitor SO2, NOx and particulate matter (PM) in the neighborhood of the Kota Complex, including the residential colony, as ambient air monitoring parameters. - Various crushers, mills, blowers/compressors, and pumps inside the DSCL Kota Complex generate elevated noise levels. The ambient noise levels at the housing colony meet both local regulatory requirements and WBG/IFC guideline limits. DSCL will build the sound absorption walls or other applicable devices, wherever possible, to reduce the workplace noise levels. - Various hazardous gases and liquids are stored in tanks onsite. All the tank storage areas are in good shape and meet the industry practice. The chlorine and ammonia storage tanks are tested for comprehensive integrities every two and five years, respectively. The tests are conducted by external licensed tank-testing companies. There is no leaks found during the appraisal auditing for the tanks and various connection pipes. - There are three closed and one active land fill cells for mercury bearing brine sludge on site, which is generated from chloralkali production. As part of the Project, DSCL Kota will phase out the old technology generating mercury sludge. Landfills have multiple asphalt/concrete layers, leachate collection system, and leachate treatment facility. The treated leachate meet both local regulatory requirements and WBG/IFC guideline limits. There are three groundwater monitoring wells to monitor the groundwater contamination for the landfills. Mercury is not detected in any of the wells. DSCL will add other priority pollutant (PP) metals, besides mercury, as the groundwater monitoring parameters. Mercury is not detected in the soil samples. - The domestic solid wastes generated on site are sold to licensed disposers, who transport it outside the complex. The ESP ash, wastewater treatment sludge, and wastes from calcium carbide manufacturing are sent to the cement kiln as final disposal and produce cement. The waste petroleum products and waste heavy-metal catalysts are recorded and sent to the licensed recyclers. - The project has been reviewed in the context of IFC’s Position Paper on Persistent Organic Pollutants (POPs) and meets the criteria for Best Available Technology as well as Best Environmental Practices. The PVC manufacturing is through calcium carbide production route, which is based on abundant local resources, such as limestone and coal. As part of the project, the company is also voluntarily replacing mercury cells with membrane cells for chlor-alkali production. Most of the company’s PVC resin production is used for the manufacturing of pipes and conduits which are used for irrigation in rural areas, for the supply of drinking water in the urban areas and for protecting cables. In the present scenario, using alternative materials for these applications would have a negative impact on India’s efforts to reduce poverty. - The DSCL Kota complex has well established occupational health/safety management system. . All onsite employees, including contract employees, are required to participate in annual EHS trainings and fire fighting/first aid refresher courses. DSCL commits to continually increase the health/safety issues with the emphases of strengthening the EHS disciplines and trainings for temporary contractors. - There is an established fire prevention program at DSCL Kota, and the company is compliant with various local firefighting regulations. The DSCL Kota Complex has updated hazard and operability study (HAZOP). DSCL will continue conducting comprehensive safety auditing using adequately experienced safety experts/team specialized in chloralkali, ammonia, and PVC productions. There is an emergency response (ER) plan available in Kota Complex, and the Kota Complex conducts onsite ER drill every six-month, and conducts off-site ER drill every year. Local authorities at Kota have developed a comprehensive off-site emergency plan to mitigate the effect of any toxic gas release or fire. DSCL is a team member of District Crisis Group, which is chaired by the Collector (the most senior district official) .The plan addresses mutual aid amongst industries and support from local administration. Necessary medical information has also been documented and distributed, which will be useful during an emergency. - The operation of DSCL Kota is energy intensive. There is an internal committee inside Kota Complex to work on energy efficiency and energy conservation. Various projects were implemented in the past 12 years to increase the productivity and reduce energy consumption. As a result, the unit energy consumption have dropped by 11% to 50% for different products in that period. - There is no record for complaints of DSCL’s operation from the residential colony and other nearby communities. No social issues associated with DSCL operations or proposed expansion were found during the two site visits by IFC social and environmental specialists. However, the overall economic situation in the Kota area is declining and several public sector industrial units near DSCL have closed. DSCL Kota has developed several philanthropic community development programs to help the local communities. The major community development projects include establishing medical centers in the communities; funding a new community school building, and promoting education by sponsoring scholarships; providing drinking water to local communities during the dry season; sponsoring various culture activities in Kota area; and technical support to farmers through seminars, field demonstrations and meetings. The sponsor has expressed and interest in developing a more sustainable social development program with IFC technical support. - DSCL Bharuch Complex located inside a chemical industrial zone in Bharuch, Gujarat State. It consists of a power plant and a chloralkali plant. The general EHS and social issues at Bharuch Complex are similar to those of Kota Complex. The Bharuch Complex has certificates for ISO 9001:2000, ISO 14001:1996, OHSAS 18001:1999, and SA 8000:2001.The liquid effluents and air emissions meet both local regulatory requirements and WBG/IFC guideline limits, with the exceptions of total suspended solids (TSS). The brine sludge landfill onsite is in good shape. There is an established fire prevention program and ER plan on site. - There are two sugar mills in DSCL, Sugar Ajbapur and Sugar Rupapur. Both mills are now implementing Integrated Management System (IMS) for quality, environment, and occupational health/safety. Various EHS and social issues meet the requirements of WBG/IFC policies and guidelines, with the exception of PM emission at both facilities. DSCL will take effective applicable methods for the emission control at both sugar mills to ensure the PM emissions meet the WBG/IFC guideline limits. - DSCL runs a chain of agro-input retail stores, called Hariyali Kisan Bazaar, which are positioned as one-stop shopping centers to meet the occupational needs of farmers. The chain sells seeds, fertilizers, pesticides, animal feed/supplement. All the stores and warehouse are licensed by the local agriculture departments. The employees are trained for general health/safety issues, as well as handling of poisonous chemicals. There is no prohibited pesticides sold at all the stores. The Hariyali Chain also provides consulting services on correct usage of agro-products. - DSCL will develop a Corrective Action Plan (CAP), wherever required with an implementation schedule, in accordance with the requirements of this Environmental Review Summary (ERS).

The following supporting documents provide further details of environmental and/or social issues: - Environmental Impact Assessment for Modernization and Expansion Project at DSCL Kota Complex, prepared by DSCL.

Accordingly, IFC concludes that the proposed project will meet the applicable World Bank/IFC environment and social policies and the environmental, health and safety guidelines upon successful implementation of the agreed mitigation measures.

IFC will evaluate the project's compliance with the applicable environmental and social requirements during the lifetime of the project through the following methods: - Review of the annual monitoring reports (AMRs) prepared for the project - The status of implementation of any measures contained in the Corrective Action Plan; - Ongoing performance of project-specific environmental, health and safety activities; - Periodic site supervision visits will also be conducted, if necessary.