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. Further information is provided in the attached documentation.
- Environment and Social Assessment and Corporate environmental, social, and health and safety management systems:
OCL’s Sponsors and management are sensitive to environmental, social, occupational health and safety (EHS) aspects of their operations but these are not managed under an overall documented management system. The company will, within a timeframe agreed with IFC, progressively implement a corporate integrated EHS management system (IMS) consistent with ISO 14001 and OHSAS 18000 standards across all of its divisions including cement, refractory and sponge iron. The company has carried out Environment Impact Assessment (EIA) studies for the clinker capacity addition and for expansion of mining operations. Further, OCL has undertaken an Environmental Examination (EE) of the stand alone cement grinding unit. Prior to expansion of mine production to meet additional limestone requirements for the project, the company will carryout an EIA and SIA study, acceptable to IFC, in accordance with WBG policies OP 4.01 Environmental Assessment, OD 4.20 Indigenous Peoples and OD 4.30 Involuntary Resettlement.
- National and local government permitting requirements:
OCL’s existing plants have valid “Consents to Operate” (or have applied for renewal) issued by the Orissa Pollution Control Board (OPCB). The company will, prior to first disbursement, obtain OPCB “No Objection Certificate” (NOC) and “Consent to Establish” (CTE) for both, the proposed clinker line and the stand alone cement grinding unit. Further, OCL will, prior to disbursement for the proposed new clinker line component of the project, obtain environmental clearance for proposed clinker line capacity addition from Ministry of Environment and Forest (MoEF), Government of India (GoI). The company will make available to IFC, copies of the above environmental clearances, consents and authorizations, as and when these are obtained. Further, the company will comply with all applicable host country labor laws and demonstrate compliance with them.
- Land acquisition, compensation and physical and/or economic resettlement:
OCL has existing mining lease of 987 hectares (ha) for Lanjiberna deposit (in Sundergarh District, Orissa) but has surface rights over 333.43 ha. OCL will commence progressive land acquisition of the balance area based on its mining plan. The company will, prior to commencement of any further land acquisition, develop a land acquisition and resettlement plan acceptable to IFC, and in accordance with WBG policies OD 4.20 and OD 4.30. This land acquisition and resettlement plan will form the basis for any further land acquisition by the company. Clinker capacity addition project does not involve additional land acquisition but the company is in the process of acquiring 517 acres of land for the standalone cement grinding plant at/near Mania/Biswali in Cuttack District of Orissa. Further, the company has, in April 2006, completed acquisition of another 21 acres of land within its mining lease. The average price paid was 11% above the one year (preceding announcement of the project) average price of non project related sale/purchase of land in the vicinity of the respective sites.
- Management of Cultural property:
There is a cemetery, a cultural property, located within the mining lease area (under Kherameta hamlet). OCL has reviewed IFC Operation Policy Note OPN11.03 Cultural Property and will adhere to OPN 11.03 in management all cultural property related to mining operations and the project. The company is committed to not disturbing the cemetery and will retain the cemetery as it is.
- Land-use change impact:
Mine lease area includes currently worked area, sparsely vegetated mixed forest land, tenanted land and government land. OCL has made necessary payments to the state government for compensatory afforestation; developed a water management scheme to mitigate material impact on drainage pattern in the mine lease area; and has prepared a rehabilitation plan for mined out areas. Prior to commencement of mining operations in the balance of mining lease area, the company will, where relevant and applicable, develop an action plan in accordance with WBG operational policy OP 4.04 Natural Habitats.
- Source of power, steam and energy, including fuel storage during construction and operation:
Total energy consumption will increase on account of the project but the principal source of power will continue to be grid electricity with coal as the principal kiln fuel. Other fuel used in refractory plant kiln and standby power generation unit include furnace oil (FO) and heavy fuel oil (HFO), which are stored in over-ground tanks with adequate secondary containment. In addition to furnace oil, the refractory unit also uses producer gas as a fuel. A producer gas generator (2800 Cu m/hr capacity) is located on the Rajgangpur plant premises. High speed diesel (HSD), the principal fuel for mining equipment is stored in underground storage tanks with secondary containment. In the proposed standalone cement grinding unit also, grid power is the primary source of energy with diesel generation backup. Further, coal will be consumed in the hot gas generator.
- Management of emissions to air:
The principal point source of air emissions in the existing and proposed facilities are the stacks attached to clinker cooler, kiln, packing plant, coal mill, CVRM and cement mill. The principal emissions are particulate matter (PM), SO2, NOx and CO. Adequate emission control equipment including ESPs, bag filters, low NOx burners and controls on excess air in kiln, have been provided in the existing plant and also proposed in the EMP for the new plants/facilities. Current emissions meet IFC norms and with the proposed pollution control facilities, the project will be able to meet IFC air emission requirements. However, PM emissions from limestone crushers in the mines, though compliant with host country requirements exceed IFC particulate matter emission norms. Further, at the standalone cement grinding unit, proposed outlet PM emission will be less than 100 mg/NM3, which though compliant with host country requirements, may exceed IFC PM emission norms. OCL will design, engineer and install appropriate particulate matter emission control equipment to meet IFC PM emission limits.
- Ambient Air and Noise:
While SO2 and NOx concentration in ambient air meet host country requirements both at the mines and in the existing plant, suspended particulate matter (SPM) concentrations in ambient air exceeds IFC’s norms at the mines as also at the plant. To achieve compliance, the company will, within a timeframe agreed with IFC, develop an action plan and implement measures to reduce fugitive and point source particulate emissions at both the mines and the existing plant. The company will ensure adherence to the mitigation measures for management of emissions, discharges and ambient air quality detailed in the EMP. Once the project is commissioned, the company will implement emission and ambient air quality monitoring program as detailed in the EMP and regularly monitor point source emissions from all existing and new sources, as well as ambient air quality in the vicinity of the plant as also mines, to demonstrate regular compliance with IFC and host country requirements. Ambient noise levels at the mines and at the cement plant meet IFC and host country norms and will remain compliant after implementation of the project as well. The company will, in accordance with host country regulations, demonstrate a 25 dB (A) insertion loss in noise levels from the DG set and if required, will undertake acoustic treatment of DG set/DG set room. The company will ensure that the refrigerant used in chillers/air conditioning system and the fire extinguishers comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements.
- Source and volumes of water consumed including efforts to minimize water use:
Fresh water requirement is met from Nakti Nala and borewells at Rajgangpur. The project will result in an increased consumption of fresh water. This increase in consumption of fresh water is not expected to have a material impact on water availability in the region. The company will continue to reuse treated ETP and STP effluent. At the standalone cement grinding unit, water requirement will be met through groundwater extraction. The company will also ensure that drinking water complies with WHO and/or GoI standards.
- Recycling and treatment of process effluent and domestic waste water:
There is no process waste water generation in mining operations. Collected rainwater and pit water is reused on site in dust suppression, pumped to local fields for irrigation and also pumped to the sponge iron plant for use. Periodic monitoring of quarry/pit water quality is undertaken and it meets host country requirements. Oil containing water from equipment garage/workshop is recycled after oil entrapment and domestic wastewater from the mining colony is disposed through septic tank and soak pits. To prevent contamination of surface water bodies by rainfall runoffs, garland drains around quarry and dumps, check dams along surface water migration routes and retaining walls around dumps are proposed. In the cement plant also, the waste water generated is essentially domestic waste water, which will increase on account of the project and will continue to be treated in the existing ETP. Treated effluent will meet IFC and host country standards and will be reused in the plant as cooling water or for dust suppression. Domestic wastewater from the township is currently being treated in a sewage treatment plant (STP). The treated effluent meets IFC standards and is used in irrigation of green belt. Under the project, the STP capacity will be increased to meet the increased load on account of the project. The treated effluent will meet IFC norms. In the proposed new cement grinding plant, the township effluent and canteen effluent will be treated in a STP and the process wastewater will be treated in an ETP to IFC standards and reused for irrigation on premises.
- Hazardous materials management:
Explosives are stored by the company for mining operations. The magazines have been constructed with adequate safety zone and their design has been approved by the host country regulators. Management of other hazardous materials needs to be improved. The company will designate appropriately contained storage areas for all hazardous materials at the all of its 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 require contractors to develop appropriate procedures and facilities for storage and handling of oils and lubricants and management of spills including provision of temporary secondary containment facilities. The company will comply with IFC guidelines on hazardous materials management in the existing plant, mines and stand alone cement grinding unit.
- Minimization, recycling and disposal of solid and hazardous wastes during construction and operation:
Waste management in the existing operations needs significant improvement, which can be achieved by adhering to the EMP. The company will implement procedures to segregate and store waste in designated areas. Solid waste from raw water treatment plant at the existing cement mill, will be used for filling up low lying land within the plant. Sludge generated from STP will be used as manure for plantation/green belt development. The company is also considering charging STP sludge in the kilns. In the standalone cement grinding unit, ETP solid waste will be land filled and STP sludge will be used as manure on the plant premises. However, ETP and STP sludge will be characterized to assess if these are hazardous before disposal process is designed. Oil sludge from furnace oil will continue to be consumed in the refractory plant kilns. Waste oil will continue to be stored in leak proof and appropriately labeled steel drums at “Spent Oil Storage Site” and will be disposed through authorized entities. The domestic solid waste from the plant and township will be collected and sent to municipal waste disposal site allocated by local administrative authorities. Part of rejects generated in the mining operation is sold to crusher operators, who use it as construction material and in roads. Dolomite containing waste is also sold out and is used in steel 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. Hazardous waste storage and handling practices need to be improved both in the existing plant and in the mining equipment workshop. 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. Solid wastes generated in the mines will be stored and handled as per the EMP detailed in the mining EIA and in accordance with the mine rehabilitation plan.
- Fire and life safety and emergency response:
The company carries out fire safety training and conducts mock drills. Fire safety in the coal handling and storage area as also in the producer gas generation plant needs to be improved. The company will, within a timeframe agreed with IFC, undergo a fire safety audit and carryout a quantitative risk assessment (QRA) for the producer gas generation plant. Further, the company will, based on the outcome of the fire safety audit and QRA, develop an action plan to improve fire safety status of its plant. 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.
- Occupational health and safety during construction and operation:
The company conducts occupational health and safety training/awareness programs for employees and contract labor at the existing facilities. The company has a safety committee (comprised of management and worker representatives) at the existing plant and mine operations. The company has implemented a targeted health monitoring program for employees and has commenced requiring outsourced service providers to implement a health surveillance program for contract labor exposed to hazardous conditions. The company undertakes annual monitoring of work place environment including noise levels and particulates. However, Occupational health and safety status needs to be further improved.
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 training to dumper, tipper and mining equipment operators on safe operation of equipment and defensive driving;
- provide appropriate PPE and actively enforce its use;
- post safety signage at appropriate locations in a culturally appropriate language;
- constitute a safety committee also at the proposed stand alone cement grinding unit, 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.
- 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. In the mine areas, members of the local community walk through the site to access a market across the mine. The company must designate an appropriate and safe access road for members of local community to access the local market.
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;
- periodically monitor ambient air quality in potentially affected communities/villages and implement mitigation measures where required, in the event of deterioration of air quality;
- 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 IFC and Government of India guidelines;
- periodically assess availability and quality of surface and groundwater and mitigate any impacts in the event of significantly decreased availability or material deterioration in quality;
- monitor ambient noise levels in potentially affected communities and implement mitigation measures, where required;
- adhere to safe blasting procedures and ensure that security guards prevent any unauthorized entry during blasting;
- do not carryout blasting at night;
- adhere to safe explosive charge and use multi delay in a hole to mitigate noise and vibration impacts; and
- develop a material movement plan, which minimizes inconvenience to local communities.
- Provision of housing, hygiene facilities, water, and power (including fuel storage) during construction and operation:
It is expected that at the stand alone cement grinding plant, 800 laborers will be employed during construction. The company will ensure that appropriate amenities/facilities for labor and employees are provided during both the construction and operation. 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;
- that potable water is available for drinking purposes and appropriate quality water is available for washing and cleaning;
- treated sanitary waste water meets IFC 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 IFC and host country guidelines in cases where construction waste water is discharged to surface water bodies; and
- assess potential host community impacts on account of influx of labor, and implement mitigation measures.
