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 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 is summarized in the paragraphs that follow.
Corporate environmental, social, and health and safety management systems:
To manage the environmental, social development and occupational health and safety aspects of its operations, the Company obtained ISO 14001 certification at both plants in 2001. JK Paper recognizes the need to strengthen management of occupational health and safety at CPM and JKPM. To this end, the Company will develop and implement a certifiable occupational health and safety (EHS) management system based on OHSAS 18000 standards, within a timeframe to be agreed with IFC. The Company is implementing a total productivity maintenance (TPM) program at both plants.
National and local government permitting requirements:
CPM has a “Consent to Operate” issued by the Gujarat Pollution Control Board (GPCB), which is valid through to September 23, 2006. National permitting requirements relevant to the Project include an “Environmental Clearance” from the Ministry of Environment and Forests (MoEF), Government of India (GOI), a “No Objection Certificate” (NOC) from GPCB, “Consent to Establish” from GPCB and, prior to commencement of operations, “Consent to Operate” from GPCB. CPM was required to obtain a clearance from Ministry of Environment and Forests (MoEF), Government of India (GoI), for the project. However, in light of the nature of the project, the clearance requirement has been waived. Application for NOC is being processed by GPCB and will be issued in due course. Once issued by GPCB, copies of the Consent to Establish and Consent to Operate will be made available to IFC. While CPM has valid permits/authorizations under the Hazardous Waste (Management and Handling) Rules (HWMH Rules), these need to be updated to include additional hazardous wastes including empty oil and paint containers and carbuoys and oil soaked wastes.
Land acquisition, compensation and physical and/or economic resettlement:
Project facilities will be located within the existing plant, in land already held by the Company. In 2005, to prepare for construction of the proposed new board plant, it was necessary to relocate one of CPM’s worker settlement (Khetibadi colony) of approximately 70 households, which occupied an area close to South West end of the plant premises. In consultation with the affected households, the Company constructed 70 units of worker housing within the plant boundary, adjacent to 21 existing housing units. Workers from Khetibadi colony were relocated to the new quarters in 2005 and the Khetibadi colony was demolished. The Company has confirmed that the affected families are satisfied with the relocation, as the new houses are of superior quality than the original units. To document compliance with World Bank Group (WBG) policy Operational Directive (OD) 4.30 (Involuntary Resettlement), the Company has agreed to provide IFC with a written report that describes in detail the relocation process, consultations undertaken, number of people affected, and outcomes achieved. Submission of a report satisfactory to IFC will be made a condition of first disbursement of loan. The Company has reviewed OD 4.30 and the WBG Operational Policy note (OPN) 11.03 (Management of Cultural Property in Bank Financed Projects). In the event of any future land acquisition, the Company will ensure full compliance with these policies.
Community consultation and disclosure:
In addition to IFC’s environmental category B disclosure requirements, the Company has undertaken a public hearing for approval of the project in accordance with the GoI’s Environmental Impact Assessment (EIA) notification requirement. The Public Hearing was conducted on October 26, 2005 at village Patharda, Taluka Songadh, District Surat. Attendees raised issues pertaining to possible reduction in forest cover as a result of CPM extracting bamboo from the forest (though no additional bamboo extraction is proposed); water pollution and, in particular, adsorbable organic halides (AOX); water consumption; and lack of local employment opportunities. Further, to ensure effective communication with local communities, the Company will develop and implement a community consultation and disclosure program, in consultation with IFC.
Fiber source:
CPM has a 10-year lease from Gujarat Forest Department to extract bamboo from designated tracts in natural forests, and meets nearly 70% of its pulpwood requirement from these sources. Bamboo harvesting operations are undertaken under the guidance of the State Forest Department, to ensure a sustainable yield in accordance with plans approved by the GoI. The Company has confirmed that the local community is fully apprised of these operations. The balance of fiber is obtained from farm forestry initiatives, primarily eucalyptus plantations. In 2004, the Gujarat Forest Department gave permission to CPM to undertake bamboo rhizome planting, for commercial extraction, in degraded segments of its lease area. The Company has already planted 674,000 bamboo rhizomes and expects to reach a total of 2.5 million in the next few years, further diversifying its raw material source and enabling it to meet any future increase in fiber requirement. Fiber source for the proposed coated duplex board project will be 8000 tpa of waste paper, 24,000 tpa of imported mechanical pulp, 21,500 tpa of hardwood pulp and 6,000 tpa of surplus pulp from CPM. The Company has reviewed and will comply with IFC OP 4.36 (Forestry) and OP 4.09 (Pest Management) in its bamboo and farm forestry operations at both CPM and JKPM. Towards this end the Company will adopt an Integrated Pest Management (IPM) program and reduce its reliance on synthetic pesticides.
Source of power, steam and energy, including fuel storage during construction and operation:
The principal sources of power and steam for the existing plant are a chemical recovery boiler of 30 tph capacity and three coal-fired boilers of 16, 28, 55 tph capacity respectively. Power is generated by two 3MW turbo generators and one 12MW turbo generator. The smaller turbines are for standby purposes and the 12 MW unit is operated to meet CPM’s total (11.1 MW) power requirement. The principal boiler fuel is coal. Under the project, a new boiler (70 tph capacity) utilizing coal and pet coke is proposed. In addition, a new 12 MW turbine is proposed, to partly meet increased electricity and steam demand from the new board plant. The Company will provide adequate secondary containment in all fuel storage areas.
Air emissions and noise during construction and operation:
The principal point source of air emissions in the existing facilities are the chemical recovery boiler and the power boilers. All boilers are fitted with electrostatic precipitators (ESPs). After Project completion, the new power boiler, lime kiln and chlorine dioxide plant will be three additional sources of air emissions. The Company monitors emissions from existing sources at both CPM and JKPM regularly, and provides these results to the GPCB and Orissa Pollution control Board (OPCB) respectively. Flue gas monitoring is also carried out periodically by both independent auditors and the GPCB and OPCB. Results of stack monitoring routinely conform to relevant host country standards. At present, particulate matter emissions from existing boilers at CPM exceed WBG emissions guidelines. The Company will implement appropriate measures including design modification, if necessary, to ensure that air emissions from existing and proposed new facilities meet WBG and host country guidelines. The Company will capture and combust non-condensable gases and ensure that odor from the plant remains within acceptable limits. Recent ambient air quality monitoring indicates that concentrations of particulate matter in the vicinity of the plant frequently exceed WBG guidelines. To achieve compliance, the Company will implement measures to reduce and contain fugitive particulate emissions, particularly in raw material and coal storage areas, through appropriate dust control measures. During construction, the Company will ensure that fugitive emissions resulting from excavation and earth moving are suppressed. Once the Project is commissioned, the Company will regularly monitor point source emissions from all existing and new sources, as well as ambient air quality in the vicinity of the plant, to ensure regular compliance with WBG and host country requirements
Refrigerant used in chillers/air conditioning system and fire extinguishers will comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements. The Company will monitor noise levels, during both Project construction and operation, to ensure that these remain within host country and WBG requirements. If required, the Company will take appropriate measures to reduce noise to acceptable levels. If undertaking high noise generating activities at night, the Company will take prior written consent from affected communities.
Source and volumes of water consumed including efforts to minimize water use:
CPM’s entire fresh water requirement (26,000 m3/day) is drawn from the Ukai left bank canal. The Company has implemented a program to recycle paper machine water, and the Project requirement (an additional 4,000 m3/day) will be supplied by recycled effluent. The Company expects to reduce its specific water consumption from current levels of 180 m3/t of product to 75 m3/t after implementation of the Project. Nonetheless, there is scope for additional water conservation and recycling efforts. The Company will develop a water conservation/recycling/reuse action plan for both existing and proposed facilities, within a timeframe to be agreed with IFC. One component of this program will be to install facilities for rain water harvesting to recharge the groundwater. The Company will ensure that drinking water complies with WHO and/or GoI standards. Construction water is being made available from existing sources.
Recycling and treatment of process effluent and domestic waste water:
The present level of waste water generation at CPM is 20,000 m3/d, or 138 m3/t of paper, which complies with the GoI’s Corporate Responsibility for Environment Protection (CREP) for large pulp and paper mills standard of 140 m3/t. After project completion, total waste water generation will be 19,000 m3/day (131 m3/t of paper), a reduction of 5% that will be achieved by recycling schemes. Currently, CPM’s domestic waste water is discharged to a septic tank and then fed to the effluent treatment plant (ETP). After commissioning of board Plant, an additional 4000 m3/d of effluent will be generated, making the total effluent volume 23,000 m3/d i.e. 67 m3/t of paper and board. The existing ET Plant having design capacity of 30,000 m3/d can handle the total waste water generation from existing plant and proposed board plant. As part of the project, the ETP will be upgraded to enable recycling of 4,000 m3/d in the Coated Duplex Board Plant. Moreover, implementation of a chlorine dioxide dominant bleaching sequence, which will be completed by June 2006, will reduce the AOX load from current levels of 1.4kg/t of paper to 1.0 kg/t of paper, as required by the CREP. Within a timeframe agreed with IFC, the Company will develop a plan to further reduce AOX levels to 0.4 Kg/t of air dry pulp (ADP), in accordance with WBG guidelines for Pulp and Paper Mills. CPM will install a spill collection system in the pulp mill to further reduce the pollutant load in the effluent stream. The plant segregates the paper machine and pulp mill effluent streams and treats each separately. Paper machine effluent is clarified in a separate clarifier and is partially reused in the paper machine, with the balance used as input water for the pulp mill, reducing fresh water requirements. After Project completion, treated effluent characteristics will meet all relevant host country and WBG requirements.
Community environment, health and safety during both construction and operation:
The Company will ensure that there is minimal impact on community environment, health and safety, during both construction and operation. Specifically, the Company will ensure that its employees and construction contractors:
- provide appropriate barriers and lighting at excavation sites, especially where such sites have open access or are likely to be accessed by members of local community;
- ensure the stability of all structures and slopes in the vicinity of construction site that may be impacted by excavations, movement of heavy equipment, dumping of excavated earth and rubble, seepage/leakage or landscape changes;
- train equipment operators and drivers in safe driving techniques and develop a materials movement plan to ensure that vehicle movement during construction has minimal impact on life patterns of nearby communities;
- undertake appropriate measures to reduce fugitive emissions from storage and transport of excavated earth and other construction material. The Company will ensure that all construction rubble and excavated earth is transported in covered trucks only; and
- undertake dust control measures in both the construction and operation phases such as sprinkling of water on access roads, excavated earth and open unpaved ground, to ensure that ambient air quality complies with WBG guidelines and host country requirements.
Provision of housing, hygiene facilities, water, and power (including fuel storage) during construction and operation: The Company will ensure that appropriate facilities for labors and employees are provided during both the construction and operation phases. In this regard the Company will provide, or require its contractors to ensure, the following:
- at construction sites and labor camps, provide appropriate facilities and amenities including housing, toilets, washing and cleaning water, potable drinking water and cooking fuel;
- ensure that potable water is available for drinking purposes and appropriate quality water is available for washing and cleaning; and
- treat sanitary waste water to meet WBG requirements prior to discharge. During construction, the Company will ensure that sanitary waste water is treated and disposed through septic tanks and require contractors to comply with WBG and host country guidelines in cases where construction waste water is discharged to surface water bodies.
Hazardous materials management:
CPM handles and stores several hazardous materials. Chlorine toners are stored appropriately and two chlorine sensors have been installed in the chlorine handling area to ensure continuous monitoring of chlorine in the work environment. Respiratory personal protective equipment (PPE) including chemical cartridge respirators, canister gas masks, air line respirators and self contained breathing apparatus are also provided in chlorine handling area. Washing stations in the pulp mill and recovery area are located not more than 25 meters from potential accident zone, and the Company will install additional washing stations near the chlorine storage area. The Company has an on-site emergency response plan and undertakes regular drills of the plan. Other hazardous materials are stored with adequate secondary containment. During construction, the Company will require contractors to develop appropriate procedures and facilities for storage and handling of oils and lubricants and management of spills including appropriate temporary secondary containment facilities. The Company will provide appropriately contained facilities for storage of hazardous materials at all existing and new facilities. In addition, the Company will make PPE available to workers handling hazardous materials, enforce the use of PPE, provide training to employees handling hazardous materials, and provide washing stations in material handling areas. The Company will ensure that relevant material safety data sheets are posted at appropriate locations and necessary antidotes for accidental exposure are available and readily accessible. During construction, the Company will undertake, or require contractors to undertake, the above measures. The Company will not use packing, insulation, roof cover or other materials that contain asbestos.
Fire and life safety and emergency response:
A Risk Assessment has been carried out as part of the REIA for the proposed duplex board plant project and CPM will implement the recommended mitigation measures. Fire management system needs to be upgraded in the raw material storage yard, coal storage yard and paper finishing, packaging and storage areas. The Company will install necessary equipment and implement appropriate management system for prevention, detection and control of fire, electrocution and spills, in accordance with acceptable engineering practices. The Company will develop and display emergency response procedures at prominent locations in its plant, train employees on these procedures, and periodically conduct drills.
Minimization, recycling and disposal of solid and hazardous wastes during construction and operation:
Housekeeping at CPM requires improvement in the coal handling plant, pulp mill, bleaching plant and causticizing plant. The Company recognizes this and has undertaken a program of continual improvement under its TPM activities. The Company will submit a detailed plan and timetable for achieving these improvements, to be agreed with IFC. Lime sludge is stored in an open and uncontained area of CPM’s premises prior to disposal. According to the Company, GPCB has indicated that lime sludge does not fall under its hazardous waste categories. As a result, CPM applied for and was granted permission to dispose of lime sludge in an abandoned stone quarry in Songadh, which it currently leases for this purpose. Present storage and handling of lime sludge also causes adverse impact on ambient air quality. As required by CREP, CPM must commission a lime kiln by 2007, which will eliminate land-based disposal of lime sludge. The plant also generates fly ash, which is being given to brick manufacturers. Part of fly ash not lifted by fly-ash brick manufacturers is used to fill the abandoned stone quarry. The Company will maximize reuse of excavated earth and rubble wherever possible and ensure that all remaining solid wastes generated are appropriately segregated and disposed of as per regulatory authorizations. At all facilities, the Company will construct appropriately contained storage facilities for storage of hazardous wastes and comply with GoI regulations as regards their handling, storage, transport and disposal.
Occupational health and safety during construction and operation: During both construction and operation the Company will:
- ensure that employees and contract labor are provided environmental and occupational health and safety training, including potential exposure to hazardous conditions and materials;
- provide appropriate PPE and actively enforce its use;
- post safety signage at appropriate locations in a culturally appropriate language;
- undertake annual monitoring of work place noise levels and conduct benchmark hearing tests for all employees exposed to high levels of noise;
- implement a targeted health monitoring program for employees and contract labor exposed to hazardous conditions;
- constitute a safety committee comprised of management and worker representatives to conduct periodic health and safety audits and identify areas where improvements are needed; and
- develop and implement an emergency response plan and communicate its contents to all relevant stakeholders.
Other facilities:
Although the project is to be implemented at CPM, key issues at JKPM were reviewed as well. Regarding effluent generation, JKPM is very close to achieving elemental chlorine free (ECF) operations. The first stage of bleaching is the only stage where elemental chlorine is used, together with chlorine dioxide. The Company expects to increase pulping capacity at JKPM from 110,000 tpa to 130,000 tpa in future and intends to convert the system to ECF at that time. JKPM’s effluent management and treatment process is a benchmark unit for best practice in India. Current effluent level of 90 m3/t is significantly lower than the CREP requirement of 140 m3/t. JKPM undertakes farm forestry activities and bamboo working in natural forests, using similar procedures as at CPM. The plant also generates fly ash which is being supplied to fly ash Brick manufacturer Part of the fly ash not lifted by fly ash brick manufacturers and lime sludge are disposed of in an area outside the plant boundary, adjacent to an ephemeral stream. Slopes in the disposal area have not been stabilized and there are signs of erosion. The Company is aware of this situation and will implement a program to cover and revegetate the fly ash heap to reduce erosion and possible sedimentation of nearby watercourses. To comply with CREP, a lime kiln is to be installed by 2007, which will eliminate the need for land-based disposal. Use of PPE, including eye and ear protection, gloves and appropriate footwear, is not universally enforced. JKPM management is aware of this situation and will implement a program to ensure strict enforcement of PPE use among employees and contract workers. Housekeeping is generally excellent, although additional improvements are underway in the recausticizing plant, coal fired boiler, coal yard and paper finishing, packaging and storage areas.
Corporate social responsibility efforts, including HIV/AIDS awareness:
In consultation with communities in the vicinity of the project site, the Company will undertake corporate social responsibility initiatives. IFC will provide details of its IFC Against AIDS program to the Sponsor for distribution to its employees, contractors and among nearby communities, in a culturally appropriate manner.
Timely reporting on environmental and social performance to IFC:
The Company will, in a format to be agreed with IFC, submit Annual Environmental and Social Monitoring Reports (AMRs) timely within 90 days of the end of its financial year.
