The sponsor 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. The information about how these potential impacts will be addressed by the sponsor/project is summarized in the paragraphs that follow.
- Air emissions from all sources:
The new milling plant will be equipped with high efficiency cyclones to remove dust generated in the process. Because of an unreliable local power system, power for all processing equipment at both facilities is supplied by diesel generators. The oil company has confirmed to URL that the diesel fuel has a sulphur content of 500 ppm (0.05%) as per IS1460-2000 that they are mandated to supply, which will ensure that air emissions comply with World Bank Group (WBG) guidelines. URL conducted stack tests of its 4-ton capacity boiler in Samana in November 2003; the results were broadly within both local and WBG emissions limits for all key parameters. At the same time the company carried out an ambient air quality test and, for all parameters except SPM, these were within WBG guidelines. This was a one-off sample, however, and may have reflected unusual activity at the facility at the time of testing. The company has been advised to check the ambient air quality in line with WBG guidelines at the property boundary and over a 24 hour period, and to take corrective action if needed.
- Liquid effluents:
The Gurgaon facility is equipped with effluent treatment plants able to treat up to 400 m3 per day of parboiling process effluent. The Samana facility processes approximately 150 m3 of effluent, and has a separate system with a capacity of 150 m3 for treating domestic water. Effluent is tested weekly at Samana, as will be the case at Gurgaon. Recent test results indicate that the treated wastewater complies with WBG discharge guidelines save for occasional peaks for total suspended solids (TSS). The company has been advised to monitor and take corrective action if this is a regular occurrence, and also to check for oil and grease, coliforms and temperature increase. Treated waste water is used for irrigation of green belts and farmlands around the milling facility, as will be done at Gurgaon.
- Solid wastes:
All main byproducts from the plant (i.e., bran and husk) are saleable on the local market. The company has studied the feasibility of installing a cogeneration plant fueled by rice husk at the Gurgaon facility and concluded that the cost of cogeneration and the legislative environment for the purchase of power is not conducive at the present time. URL will continue to monitor these issues, and has indicated that it intends to pursue this option in future, at such time as conditions become more favorable. URL will update IFC on the viability of this option in the Annual Environmental and Social Monitoring Report (AMR) it submits to IFC. Most of the packing materials at the raw material stage are jute sacks, which are reused 2-3 times and are biodegradable. Finished goods are packed as per customers’ requirement and dispatched. Recently the company has switched to jute packaging for some of its finished products for the domestic market. The cyclones collect approximately 320 tons of non-reusable agricultural dust every year which is disposed by local contractors at appropriate landfills or used as filler.
- Noise:
The milling facility in Samana does not generate any significant noise outside the buildings, nor will the new plant in Gurgaon. URL has tested the noise levels at the plant in Samana and found them all to within acceptable levels (< 85dB) as per host country’s guidelines, with the exception of the generator room. URL currently provides hearing protection to employees working in this area. The company is replacing the existing generators at Samana, however, with sets similar to those to be used in the Gurgaon plant, which are equipped with cladding to ensure that noise is within acceptable levels. The new generators at Samana are expected to be in place by the end of March 2005.
- Fire and explosion:
Fire and explosion risks will be kept low at the Gurgaon plant by adhering to good cleaning standards and prevention of dust build-up in silos, which will be equipped with detectors for moisture and heat. Both plants are fully equipped with firefighting equipment, fire alarms and extinguishers, and staff are fully trained in the use of this equipment. Fire drills are conducted every 5-6 months for all operators. At the new Gurgaon plant, URL is installing a ring main hydrant system, which will draw from a gravity-fed dedicated storage tank with a capacity of around 275m3. The company enjoys a good track record in this matter.
- Use of insecticides:
In accordance with export quality requirements, use of chemical pesticides is kept to a minimum. URL has provided IFC with a complete list of insecticides used in its operations and confirmed that all of these are applied in low volumes and in accordance with manufacturers’ recommended procedures. The company is an authorized applicator and user under the relevant Government statutes, and application is done under strict health and safety procedures, using appropriate personal protective equipment. Methyl bromide, which URL uses as a fumigant, is permitted for use in India until 2015 under the provisions of the 1991 Montreal Protocol.
- General employee health and safety:
General housekeeping standards at the Samana facility are excellent. Both employees (numbering approximately 300) and contractor staff (approximately 1000) are provided with uniforms and requisite personal protective equipment (e.g., dust masks for workers in the milling unit). Use of this equipment, both by employees and by contractor staff, is strictly enforced, and non-compliance can result in termination. URL conducts induction training, including occupational health and safety issues, for both its own employees and contractor staff. Other health and safety measures such as safeguarding of machinery, use of hearing protection, and fire protection are controlled by a designated safety engineer. URL requires that all its employees undergo health checks by a local physician every six months, which as and when required may include respiratory examinations, blood and urine analysis and hearing tests. In instances where respiratory or hearing problems are identified, the employee is given treatment, placed on medical leave, re-examined by the physician before being allowed to return to full time work, and reassigned to a part of the plant where re-exposure (either to dust or noise) will not be an issue.
- Source and volumes of water required for both plants including efforts to minimize water use:
The aggregate of all peak requirements of water at Gurgaon is expected to be around 1000m3 per day. However, peak usage at peak production is estimated at 600-700 cubic m3 per day, a level that is likely to be reached some years hence. The bulk of the usage is for parboiling, and some smaller amounts for domestic purposes. The existing plant at Samana has an estimated water requirement of approximately 350 cubic meters per day. Water for both plants is drawn from boreholes on the property, against registration with the Central Ground Water Authority. Raw water is pretreated to ensure that it is of sufficiently high quality for use in parboiling. As discussed, the company has wastewater treatment plants at both facilities. Process wastewater is currently treated to a level that it can be discharged on the property for irrigation and horticulture. At the current time, it is not economically viable to reuse this water. However, the Gurgaon plant has been designed to incorporate an additional process module that will treat the water to a standard that allows it to be reused in the parboiling process, should the cost of ground water extraction increase to the point that it makes financial sense to do so, or if mandatory reuse legislation is introduced.
- Plant hygiene and product quality:
URL has been certified under the Hazard Analysis and Critical Control Points (HACCP) food safety management system and maintains both plants to international standards of hygiene and product quality. At Samana, 100% of the raw material is sampled and tested for quality. URL has fully-staffed laboratories to test for impurities, contamination and quality. The company operates to provide a very high degree of product assurance, which is backed up by multiple systems of 100% checking, scientific sampling plans, in-process quality assurance programs. These are supported by well equipped sensory panels, quality control laboratories, microbiology laboratories and a molecular biology (DNA) laboratory. The company also runs a Rice Research Development Centre at Mysore, which provides a referral service for certain chronic problems. In addition, the company employs a number of competent consultants to provide knowledge and expertise. At the Gurgaon plant, URL has installed a state-of-the art molecular biology laboratory, managed by a PhD biotechnologist, who has several years of experience working in similar laboratories in the US, to sample and test the purity of the basmati strain – the only such facility globally dedicated to evaluating and maintaining basmati varietal purity.
- Use and disposal of hazardous materials:
Chemical use in the product testing laboratories at Samana and Gurgaon are minimal. Wastes from the Gurgaon Molecular Biology laboratory are neutralized in accordance with internationally-accepted protocols and disposed of in the effluent treatment after neutralization.
- Corporate social responsibility efforts:
The company facilities are located in light industrial areas, and the company enjoys good relations with its neighbors. URL meets or exceeds all national statutory requirements in terms of the salaries and benefits it provides its employees. Its salaries are very competitive and it provides a medical reimbursement program, leave/travel allowance, and a group pension plan to all employees. The company has also developed a highly successful farmer extension program, which it provides free of charge to local farmers, to encourage cultivation of basmati and assist them in lowering input costs and improving yields. The program (Farmers’ Advisory Cell or FACE)] - which includes radio spots, radio call-in shows, and a toll-free ‘basmati hotline’- is not “branded” as a URL service, and farmers who use the services are free to sell their harvests to any buyer. URL has also developed a 16-acre research facility and program (FOSTER), to grow, test and evaluate different varieties of basmati, for the purpose of assessing optimal growing conditions and regimes. The information from this program is fed back to the farmer extension service, to ensure that the advice being given to farmers reflects the company’s most current findings.
