The company 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 company is summarized in the paragraphs that follow.
The site is located in the industrial area on the south side of the G.T. Road in Ghaziabad, at approximately 15 km from New Delhi, India. Carbon black feedstock is transported by truck (and, in the future, by rail) from ports or refineries and stored in aboveground storage tanks. The feedstock is transferred to the reactors for the reactions to take place. The carbon black generated in the reactors is quenched, captured in bag houses, pelletized, and packed. Approximately 70 percent of the bag house gas is used for in-house power generation, and the remaining 30 percent is used to dry the pelletized product before the combusted gases are released to the atmosphere. Prior to their release to the atmosphere, these gases are burned and flared.
- Water Source and Liquid Effluent
CCIL obtains its fresh water from the company''s three deep wells located within the premises and approved by the local authorities. The existing water wells are sufficient to satisfy the water requirement of the new co-gen plant. As part of the project, CCIL will begin collecting rainwater to use in the process. Process wastewater is currently treated in the onsite wastewater treatment plant (WWTP).
The WWTP:
- skims the wastewater to collect floating light oil; and
- flocculates/precipitates it to remove heavy oil/carbon sludge.
The liquid effluents are compliant with both World Bank/International Finance Corporation (WB/IFC) guidelines and Indian regulations. As part of its upgrades, CCIL has recently completed the construction of a 5,050 m3 oil/water separator to improve the quality of its wastewater. The new co-generation plant will increase the load to the WWTP by an additional 30 Kl/day. Since the WWTP design capacity is 816 Kl/d it will comfortably accommodate the new total volume of 475 Kl/d. The domestic wastewater generated is treated on-site in septic tanks.
- Air Emissions
As part of the project, CCIL will upgrade the bag houses by installing a modular system which will facilitate maintenance and ensure air emissions control at all times. All air emission sources will have concentrations of 50 ppm ensuring compliance with IFC particulate matter requirements. Ninety five percent of the feedstock used by CCIL is domestic and has low sulfur concentrations ranging between 1% and 1.5 %. As a result, sulfur oxide emission levels are very low and within the IFC requirement. CCIL reuses approximately eighty percent of the tail gas produced for power generation, an additional 15 percent for drying and the remaining five percent is burned at a recently installed flare stack, thus releasing to the atmosphere low amounts of CO2 and H2O. CCIL conducts periodic stack emissions monitoring of SO2, NOx, and particulate matter.
CCIL will also conduct retrofitting of auto-packers and bag packers and replacement of elevator and screw conveyors which, in addition to optimizing the operation, will enhance the handling of the dust material and reduce generation of particulate matter.
As part of the project, CCIL will increase its co-generation capacity from 4.4 MW to about 15 MW by using all tail gas produced. After the project, CCIL’s carbon black production will then not only be a zero particulate emissions operation but will also provide energy and steam to nearby factories which otherwise would be burning fossil fuels to satisfy their own needs. CCIL has commissioned an environmental impact assessment (EIA) of the new cogeneration plant and will submit it to IFC for review, prior to the first disbursement of the IFC investment and before the construction of the plant begins. The local authorities also require the submission of the EIA. The new co-generation plant will be located within CCIL’s existing premises.
- Ambient Conditions
CCIL conducts ambient air quality monitoring at three locations. The nitrogen oxides and sulfur oxides at these locations are compliant with both WB/IFC guidelines and Indian regulations. However, particulate matter (PM) at the three locations exceeds both WBG/IFC guidelines and Indian regulations. It is assumed, that the high particulate levels are mainly due to external factors (unpaved outside road, emissions from other industrial operations located nearby, traffic from the nearby highway, etc.) since CCIL has in place high efficiency bag houses, has conducted an extensive clean up of its premises on major roads, process areas, office areas, and also has an on-going program to clean any dust generated while keeping normal production particularly in the packing and warehouse areas. CCIL contribution to the particulate matter concentrations in the ambient air will be further reduced after the implementation of the additional improvements, as part of this project, including further paving and the planting grass on plant premises.
The ambient noise levels along the property lines meet the WBG/IFC guidelines and Indian regulations, with the exception of occasional minor breaches which might be caused by heavy traffic on the major highway along the property line.
- Solid/Hazardous Wastes
This plant has a well structured program for segregation, reuse and/or recycling of its wastes. Once collected and according to the type of waste, they are sent to the appropriate destination (i.e., authorized recyclers, reuse, landfill, etc.) The sludge resulting from the treatment of the industrial effluents are temporally stored in an on-site impervious pit built in 2004. The WWTP sludge as well as the other wastes (i.e., skimmed light oil, carbon/heavy oil sludge, and metal/paper/wood scrap), are sold to companies licensed by the local authorities for either reuse or final adequate disposal.
After recently building a new unloading system, CCIL is now dismantling the old system and expects to remove the oil- contaminated top soil and complete the clean-up by end of May 2006. Contaminated soil in other plant areas (i.e., along the abandoned railroad tracks) will be also removed. The contaminated soil as well as hazardous contaminated debris will be disposed by government authorized companies at licensed disposal facilities.
CCIL is currently upgrading the railroad infrastructure (i.e., loading/unloading, rail tanks, etc.) and anticipates having it ready by end of May 2006. The length of the railroad is approximately 1,150 km distance from Barauni to the CCIL plant. It will have 72 cars available and will be fully owned by Indian Railways.
- Workplace Monitoring
CCIL implemented a noise abatement plan, including building sound absorption walls around noisy equipment (i.e., utility blowers/compressors and pumps.), installing sound prevention acoustic walls and acoustic hoods, which significantly reduced noise levels. In addition, employees entering these areas are required to use personnel protective equipment. CCIL will continue introducing improvements to further reduce noise levels in noisy areas. Workplace dust concentrations are compliant with both WBG/IFC guideline and Indian regulations. CCIL conducts periodic noise and dust monitoring in work areas.
To ensure safety operations during the transportation of feedstock and final product by its contractors, CCIL has recently developed a Contingency Safety Transportation Plan and has developed procedures to ensure that all drivers are fully trained and follow the safety procedures that have been developed. A copy of this plan has been submitted to IFC.
CCIL has an environmental policy and has developed an Environmental Management System based on this policy. In addition, it has an environmental engineer overseeing the environmental, health and safety aspects of the plant operations and has begun work towards obtaining the following:
- an ISO 14000 certification; and
- membership in the British Safety Council.
- Health/Safety/Fire Prevention
The plant practices good housekeeping, with safety signs, in English and Hindi (local language), adequately placed throughout the plant. CCIL’s own personnel are provided with and are required to use personal protective equipment (PPE). Contractors are required to furnish basic PPE to its employees prior to entering CCIL premises. CCIL has a health and safety training program for its own employees and requires that contractors in turn train their own employees.
The company has preventive and control programs to address the exposure of its employees and contractors to work-related risks. Recently, CCIL conducted a Hazard Operations (HAZOP) assessment for its tank farm and boiler operations, resulting in a series of recommendations (i.e., CO detection systems, fire prevention measures for furnace fuel oil tank, improved alarm systems, etc.) that will be implemented as part of this project.
The surface of the new unloading area is paved and is inclined so that in case of leaks, the oil will be collected and sent to the oil/water separator located within the tank farm. CCIL will continue implementing prevention and safety measures to further enhance its operations. CCIL will elevate the tank farm pipelines that are very close to the ground to facilitate its maintenance and will in turn pave the surface under these pipelines as part of this project. It will also strengthen its maintenance programs to prevent leaks by replacing old valves/pumps, as needed, and by introducing sound practices during materials loading/unloading, pipes plugging/unplugging, etc.
The plant has trained fire brigades and safety prevention equipment in place (i.e. extinguishers throughout the plant for the various types of fires, hydrants, etc.)
Contingency and emergency response plans have also been developed. Copies of these documents have already been submitted to IFC.
There are several oil storage tanks in the tank farm area, as well as two 5,000 m3 diesel tanks. CCIL has recently completed the installation of a containment wall for the furnace oil tank thus preventing soil contamination from accidental leaks and spills in the tank area.
The employees have access to on-site medical check-ups and to a nearby hospital when needed. CCIL provides subsidized meals and snacks to its employees in a comfortable canteen that has been recently built.
- Communication and Consultation
Internal and external communications are important for CCIL. CCIL has an effective internal grievance system for complaints. Concerns from external groups or members of the local community are channeled to the department in charge of the specific environmental, health, safety, or social issues under the coordination of the General Manager- Human Resources.
- Corporate Social and Environmental Responsibility
There is no record for complaints of CCIL’s operation from nearby communities. CCIL promotes and participates in activities that contribute to the development of the surrounding local communities (i.e. community development at two nearby villages –Chipyana and Dhundahera, renovation of a nearby heritage site, adult literacy drive using software developed and donated by another Indian industry, scholarships to meritorious school children.) CCIL is also beginning to play a proactive role in establishing good relationships among industries located nearby. In addition, CCIL conducts periodic HIV awareness programs for the truck drivers.
