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 host country laws and regulations and the World Bank/IFC (WBG) environment and social policies and the environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the company is summarized in the paragraphs that follow.
- Environment and Social Assessment and Corporate environmental, social, and health and safety management systems:
The Company management is sensitive to environmental, social, occupational health and safety (EHS) aspects of their operations. The Company has already implemented a certified integrated EHS management system (IMS) based on ISO 14001 and OHSAS 18000 standards (since November 2003) at the Ajbapur facility and proposes to implement a similar IMS at the Rupapur facility by December 2006. The Company will develop and implement a certified IMS at the proposed new plants at Loni and Hariyawan within a timeframe to be agreed with IFC as also for Hariyali Kisan Bazaar retail store chain in a progressive manner. The Company will, within a timeframe to be agreed with IFC, carry out an environmental and social impact assessment (ESIA) for the proposed new plants at Loni and Hariyawan and also, a cumulative air quality impact modeling, prediction and assessment (CAQIA) for the four plants (Rupapur, Ajbapur, Loni and Hariyawan) taken together. The Company will implement the environment and social management plan developed based on the outcome of the ESIA and CAQIA. Agreement with IFC on a Terms of Reference for the ESIA and commencement of the ESIA and CAQIA will be a condition of disbursement.
- National and local government permitting requirements:
The company’s existing plants have valid “Consents to Operate” issued by the Uttar Pradesh Pollution Control Board (UPPCB). The Company will have its Consent to Operate under the Air Act updated and get diesel generator (DG) sets included in the consent. National permitting requirements relevant to the proposed new plants include a “No Objection Certificate” (NOC), “Consent to Establish” and, prior to commencement of operations, “Consent to Operate” from UPPCB. The Company will obtain all relevant permits prior to first disbursement and will make copies of these available to IFC. While the Company has valid permits/authorizations for existing operations 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/carbuoys and oil soaked wastes. The Company will get the authorization under HWMH rules updated during next renewal due in May 2006.
- Land acquisition, compensation and physical and/or economic resettlement:
The capacity expansion at Ajbapur plant is proposed within the existing plant premises and no land acquisition is proposed. For the proposed new plants, the Company has acquired 198 acres of agricultural land at Loni and 143 acres at Hiriawan from individual farmers. The land acquisition at Loni involved 187 number of purchase agreements with farmers and the average price paid was 17-20% above the one year (preceding announcement of the project) average price of non project related sale/purchase of land in the vicinity of the proposed plant site. The land acquisition at Hariyawan involved 103 number of purchase agreements with farmers and the average price paid was 17 - 20% above the one year (preceding announcement of the project) average price of non project related sale/purchase of land in the vicinity of the proposed plant site. The Company is also in the process of acquiring 5-10 acres and 35-40 acres of village revenue (panchayat) land at Loni and Hariyawan respectively. At both these locations, the Company will provide equivalent land at alternative locations that is acceptable to the respective panchayats. The Company is in the process of obtaining a land use change (from agricultural to industrial use) permit from Uttar Pradesh (UP) government. The Company will make available a copy of the land use change permit to IFC. The land acquisition, as confirmed by the Company, did not involve any physical resettlement. To document compliance with World Bank Group (WBG) policy Operational Directive (OD) 4.30 (Involuntary Resettlement), the Company has agreed to provide IFC a written report that describes in detail the acquisition 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 the 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:
The Company has a community engagement plan in place for sugarcane development and extension, within its command area (village meetings, training, rallies and “nukkad natak” - village plays). In addition to IFC’s environmental category B disclosure requirements, to ensure effective communication with local communities, the Company will, in consultation with IFC, develop and implement a community consultation and disclosure program, for the sugar operations of the Company.
- Sugarcane sourcing:
The Company has been allocated a sugarcane command area of 365,000 ha by the UP government for the existing and the proposed new plants. The sugarcane growing intensity (percent of land within the command area under sugarcane cultivation) in the allocated command area is 23% but the Company hopes to increase this to 46% by 2007-08, to meet its requirement of ~53 million quintals of cane. The Company has implemented a cane development program that includes rallies, training program, village meetings and nukkad natak to achieve this target. Further, the Company and their consultants have together developed a yield enhancement technique “Shriram Ganna Utpadan Technique” (SGUT), to encourage farmers to adopt sugarcane cultivation and also to enhance yield and income per hectare from sugarcane cultivation. Under the SGUT program, the Company is also experimenting with intercropping in sugarcane field to improve cash realization and reduce cash cycle for the farmers. Sugarcane pricing is administered by the state (UP) government and the Company ensures that the approved prices are paid to the farmers. The Company makes all payments to farmers through banks and has a secure electronic system in place to record sugarcane purchases and payments made to each farmer. Farmers have the option to sell their produce at the plant gates or at collection centers set up, at several locations in the command area, by the Company. Where farmers sell their produce at the plant gate, the Company pays the farmers INR 5/100 kg more as compared to sales made at collection centers. The Company sells molasses (to distilleries) and surplus bagasse (to paper plants for use as a fuel source) at a market determined price. The Company has a three-pronged information and grievance management system for farmers. There are information kiosks at Hariyali Kisan Bazaar (a chain of retail stores for agricultural inputs, general provisions and Fast Moving Consumer Goods, set up by the Company at various locations), Plant and Collection centers to disseminate procurement scheduling related information, a complaint management counter at the plant gate and a payments counter at the plant gate to handle payment related issues.
- Source of power, steam and energy, including fuel storage during construction and operation:
The principal sources of power and steam for the existing plants are bagasse based co-generation plants. There are 2 x 46 and 1 x 29 tph steam capacity boilers at Rupapur and three (75, 60, 60 tph capacity) boilers at Ajbapur respectively. Power is generated by 2 x 3 and 1 x 2.5 MW turbo generators at Rupapur and 2 X 3 MW, 1 X 1.5 MW and 1 X 7.5 MW turbo generator at Ajbapur. In addition, during the non crushing period (approximately 6 months), DG sets are operated There are 3 x 380 KVA DG sets at Rupapur and 380 and 1000 KVA DG sets at Ajbapur. Under the project, new bagasse based boilers (2 x 60 tph capacity) are proposed at Loni and Hariyawan each. In addition, new 12 MW turbo-generators are proposed at Loni and Hariyawan each. Further, the Company proposes to install an additional boiler at Ajbapur of 60 tph capacity with a 20 MW turbo-generator. There is one 4 KL and two (20 and 60 KL) underground HSD storage tanks at Rupapur and Ajbapur respectively. The Company will, within a timeframe to be agreed with IFC, undertake integrity testing of the existing underground storage tanks and provide secondary containment where needed. At the new plants, the Company will construct only above-ground tanks for LDO/HSD storage and will provide adequate secondary containment.
- Air emissions and noise during construction and operation:
The principal point source of air emissions in the existing and proposed facilities are the co-generation boilers and DG sets. The boilers at both existing plants are fitted with wet scrubbers and ash handling systems. At present, particulate matter emissions from the existing boilers at both Rupapur and Ajbapur exceed WBG emissions limits. The Company will develop an action plan and implement appropriate measures, including design modifications, if necessary, to ensure that air emissions from existing and proposed new facilities meet WBG and host country guidelines, within a timeframe agreed with IFC. A major source of fugitive particulate emissions is bagasse handling and storage. Recent ambient air quality monitoring at both Rupapur and Ajbapur facilities indicates that concentrations of particulate matter in the vicinity of the plant frequently exceed both WBG and host country guidelines. To achieve compliance, the Company will develop an action plan and implement measures to reduce and contain fugitive and point source particulate emissions through appropriate emission control measures and particulate suppression 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
The Company will ensure that the refrigerant used in chillers/air conditioning system and fire extinguishers comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements. Ambient and workplace noise levels at the Rupapur and Ajbapur facilities regularly exceed WBG and host country norms. Within a timeframe to be agreed with IFC, the Company will, develop an action plan to ensure that ambient noise levels meet WBG norms. The Company will monitor noise levels during both project construction and operation, and implement appropriate measures to ensure that these remain within host country and WBG requirements. Results from this testing will be reported to IFC annually. The Company will, in accordance with host country regulations, undertake acoustic treatment of DG set/DG set room to ensure a 25 dB (A) insertion loss in noise levels from the DG set. 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:
Rupapur and Ajbapur facilities meet their entire fresh water requirement (650 and 700 m3/day at Rupapur and Ajbapur respectively) from groundwater sources (bore wells). The water requirement of approximately 700 m3/day at each of the proposed new plants will be met from groundwater extraction as well. The Company will meter all groundwater withdrawals and 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.
- Recycling and treatment of process effluent and domestic waste water:
The present levels of waste water generation are 650 and 600 m3/d at Rupapur and Ajbapur facilities respectively, which complies with the Government of India’s Corporate Responsibility for Environment Protection (CREP) requirements for sugar industry (100 liters/t of cane processed). The Company will generate an estimated 600 m3/d of effluent from each of the proposed new plants as well. The Company will install an effluent treatment plant (ETP), similar in process and capacity to the ETPs at its existing plants. Further, the Company will at all times ensure that commissioning and operation of the ETP is commenced at least one month before the start of cane crushing. In the existing plants, treated effluent is used on premises for irrigation purposes and the same is proposed in the two new plants as well. The Company will, within a timeframe to be agreed with IFC, construct facilities for storage of treated effluent, with a minimum of 15 days storage capacity. The Company will undertake benchmark monitoring of treated effluent to demonstrate compliance with WBG guidelines and will at all times ensure that the treated effluent characteristics 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 at plants and at Hariyali Kisan Bazaar:
The facilities at Rupapur, Ajbapur and the proposed new facilities store or will store several hazardous materials, including sulphur, lubricants, fuel oil. The Company will provide appropriately contained storage areas for all hazardous materials at all existing and new facilities. In addition, the Company will make personal protective equipment (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. 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 retails hazardous materials like pesticides and other consumables through its chain of Hariyali Kisan Bazaar (HKB) retail stores. Further, the Company has an agreement with Bharat Petroleum Corporation Limited, which sets up petrol/diesel stations on HKB premises. Given that significant amounts of pesticides are stored and handled at HKB stores, in addition to the petrol/diesel stations, the Company will implement a documented system to comply with IFC’s Hazardous Materials Management Guidelines and WBG guidelines on pesticide handling. This system will be developed within a time frame to be agreed with IFC and will apply to all HKB outlets. The Company will comply with IFC guidelines on hazardous materials management in the existing and proposed sugar plants as well. The Company will not use packing, insulation, roof cover or other materials that contain asbestos.
- Pest Management and pesticide handling:
The Company encourages pragmatic use of pesticides. The Company has reviewed and will comply with IFC’s OP 4.09 (Pest Management) in its cane development operations. Towards this end the Company will adopt an Integrated Pest Management (IPM) program and reduce its own reliance on synthetic pesticides. This effort will include dissemination of procedures for the safe selection, handling and use of chemical pesticides to small scale farmers located in its command area, in accordance with WBG guidelines on pesticide handling and use. The Company will also provide information to encourage farmers to adopt IPM approaches such as biological control, cultural practices, and the development and use of crop varieties that are resistant or tolerant to pests.
- Fire and life safety and emergency response:
The Company undertakes fire safety training and conducts mock drills. Fire safety at the Company is adequate. However, the Company will undertake periodic review of fire safety status at both the existing facilities as also the proposed new plants. Where required, the Company will install all 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 at the existing and proposed plants as well as at HKB facilities.
- Minimization, recycling and disposal of solid and hazardous wastes during construction and operation:
Scrap management at both Ajbapur and Rupapur plant needs significant improvement. All wastes need to be segregated and stored in designated areas and disposed off appropriately. Further, both the existing facilities generate fly ash, which is disposed off in low lying areas within plant premises. The Company will explore the feasibility of encouraging reuse of the fly ash in fly ash brick manufacture or in cement plants. ETP sludge is vermi-composted and used on premises as manure. Press mud/filter sludge is given to farmers as manure. The Company will get the ETP sludge, Press Mud/filter sludge fully characterized and will commission a study by an appropriate research institution, to identify any potential impacts on soil and groundwater, on account of use of treated effluent, ETP sludge and press mud/filter sludge in agriculture. The Company will, within a timeframe to be agreed with IFC, develop and implement procedures for appropriate disposal of bio-medical waste generated in the existing and proposed plants. During construction, 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 (existing and proposed), the Company will identify all hazardous waste generated, segregate them, construct appropriately contained storage facilities for hazardous wastes and comply with GoI regulations as regards their handling, storage, transport and disposal.
- Occupational health and safety during construction and operation:
The Company conducts occupational health and safety programs for employees and contract labor at the existing facilities and also at the new project sites. The Company has a safety committee (comprised of management and worker representatives) at the existing facilities at Rupapur and Ajbapur. During both construction and operation the Company will:
- ensure that all employees and contract labor are provided environmental and occupational health and safety training, including on 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 environment including noise levels, particulates and SO2 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 also at the proposed new facilities, 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.
- Corporate social responsibility efforts, including HIV/AIDS awareness:
The Company undertakes community development programs in its command area including, contribution of INR 3.0 Million for construction of roads/bridges, financial assistance to the tune of INR 80.0 Million to the growers (for cane seed, fertilizers etc) and subsidies/incentives for sinking of new bore wells, purchase of Diesel engines. In past 3 years, the Company has provided financial assistance for apprx.1000 new borings and 300 diesel engines. In consultation with communities in the vicinity of the project site, the Company will further expand its corporate social responsibility initiatives. The Company has a program in place to build awareness on HIV/AIDS for employees, truckers and for local community. IFC will provide details of its 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.
