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 Environmental and Social Action Plan (ESAP).
- PS1: Social and Environmental Assessment and Management Systems
WCPM has in place a comprehensive Quality Management System (QMS) certified by ISO 9001:2000 as well as an ISO 14001:2004 certified Environmental Management System (EMS). Both certifications were obtained from Det Norske Veritas (DNV). The company is in the process of setting up an Occupational Health and Safety Management System, for which it intends to obtain OHSAS 18000, also from DNV. As required by Schedule I of the Ministry of Environment and Forests (MoEF) Environmental Impact Notification Act, 1994, WCPM was required to submit a Rapid Environmental Impact Assessment (REIA) and Environmental Management Plan (EMP) to MoEF to obtain Environmental Clearance for the project. WCPM commissioned an independent REIA, which was completed in September 2006 and submitted to the Karnataka State Pollution Control Board (KSPCB) in December 01, 2006. As required under the MoEF’s EIA Notification and Clearance process, a Public Hearing on the REIA is scheduled for February 20, 2007 at Ambedkar Hall in Dandeli. The Public Hearing was advertised in the The Times of India on January 20, 2007. The Minutes of the Public Hearing will be provided to IFC as soon as available. The ESRS and ESAP will be revised, if necessary, to incorporate any significant issues raised during the Public Hearing that have not been addressed in the original ESRS/ESAP. WCPM is in possession of No Objection Clearance (NOC) for the existing plant, a copy of which has been provided to IFC. Copies of all Government clearances, permits and authorizations for the new project will be provided to IFC within 30 days of receipt by the company.
The REIA (Tables 7.1 and Table 9.1) includes a number of recommended mitigation measures to ensure that all environmental impacts associated with the expansion project – during both construction and operation - are incorporated into the EMS. The REIA also includes recommendations (Table 8.1) in regard to the environmental monitoring program that WCPM has in place. WCPM has reviewed all of these recommendations and has agreed to incorporate any that are not currently addressed in its existing EMS, and to address these issues in the manner recommended in the REIA. The company will provide IFC with a revised copy of the EMS reflecting these changes as a condition of first disbursement.
- PS 2: Labor and Working Conditions
WCPM currently employs approximately 4200 people directly or through contractors in the Dandeli plant and office complex. The project will result in a net increase of 150 employees, although jobs will be lost in some Departments and increase in others. No employees will be retrenched as a result of the project; all reductions in staff will be achieved by natural attrition. WCPM provides highly subsidized housing to approximately 50% of its workforce; this percentage is expected to remain approximately the same after project completion. Existing employees will be provided with training to ensure them a position in the plant after project completion. The negotiations of a Tripartite Settlement between WCPM and a Joint Negotiations Committee take place every four years; the most recent settlement was agreed in 2004. The company has involved union representatives throughout the planning of all significant elements of the project. WCPM has a Human Resource (HR) Policy and Procedures in place that include a formal employee appraisal process, merit rating and promotions guidelines, requisite job related and occupational health and safety training programs, references to all labor related statutory requirements with which the company must comply, policy on the formation of workers organizations, a process for raising and addressing employee grievances, and a written commitment to equal opportunity for all of the workforce. Although prevailing cultural norms limit the number of women seeking employment in the plant, the company has made efforts to increase employment opportunities for women in other activities, particularly in its farm forestry research and development efforts, which currently provides employment to some 850 people, of whom 200 are women, a number that is expected to double over the next five years.
The company has confirmed that it complies with all Indian labor regulations and standards. The minimum age of employees at the plant is 18 years of age. WCPM is sourcing all new machinery and equipment from large, reputable European vendors, all of which will meet international safety standards and be equipped with automatic shut off controls and lock devices to prevent unsafe operation. Employees are provided with personal protective equipment (PPE) appropriate to task requirements and trained in the proper use of this equipment. WCPM has a system of warnings and fine to enforce use of PPE, which has the support of the unions as well as the Industrial Safety Committees for each Department. Noise levels in the chipper house area exceed World Bank group (WBG) limits, and extra effort is given to enforce the use of hearing protection in this area. All employees undergo annual medical examinations that include hearing tests, pulmonary check ups and blood tests. The company provides training to all employees on basic OHS principles and procedures, including safe use of equipment, need for and proper use of PPE, accident prevention, fire control, emergency response. Medical care is provided to all employees and their families. WCPM maintains a well equipped hospital in Dandeli, near to the plant, which can handle a wide range of injuries and illnesses. Employees and family members with more serious conditions are transferred to nearby government or other hospitals, with costs covered by the company’s medical policy.
WCPM’s Industrial Relations Department includes a staff of seven health and safety officers. The Department tracks accident and injury events, including lost time injuries and costs associated with accidents, on a monthly basis for all Departments. Accident Investigation Reports are prepared for all lost time injuries (LTIs). These statistics and analyses are reported monthly to the Executive Director, all Departments heads, and the Safety committees for each of the four plants (pulp mill, chemical recovery, power house and paper machine). The facility is designed with strategically located fire exits and fire fighting equipment throughout the plant, office complex and other structures, and has a fire hydrant system and dedicated water storage facility to handle fire emergencies, and is in full compliance with all applicable Indian regulations. Periodic fire safety and response training and drills are held, and all fire fighting equipment is regularly serviced and certified. WCPM requires that all construction contracts for work done on plant premises include specific occupational health and safety (OHS) provisions. The company’s OHS Officer inspects all construction and other on-site works to ensure compliance with these requirements, which cover all relevant laws, regulations and standards of the Government of India.
- PS 3: Pollution Prevention and Abatement
In the context of the project, WCPM will close down the existing pulp mill, adopt a super-batch pulping process that will be largely spill free, eliminate elemental chlorine from all of its pulp bleaching process, adopt a two-stage oxygen delignification process, reduce specific water consumption and further upgrade its effluent treatment plant (ETP) to meet the requirement. These improvements will ensure that WCPM complies fully with all provisions and deadlines of the GoI’s Corporate Responsibility for Environment Protection (CREP) for large pulp and paper mills, and will position WCPM as an industry leader in environmentally sound pulp and paper production in India.
The power requirement for WCPM’s operations currently totals 24 MW, obtained from a combination of sources, including turbo alternators, grid power, and multi-fuel diesel generators. The project will double the energy requirement to approximately 51 MW (installed capacity of co-generation plant will increase from 40.3 MW to 70.3 MW), which will be met from the same sources and addition of new turbo generator set(s). Total coal fuel requirement will increase by only 62%, because of efficiency features of the new boiler and chemical recovery boiler, improving energy efficiency and reducing energy costs per unit of output. Similarly, the new lime kiln includes a system for collecting and incinerating non-combustible gases, which will both improve energy efficiency and reduce plant and ambient odors associated with the plant. Currently 59% of the total fuel requirement is from coal, with the balance from black liquor. Stack emissions testing and ambient air monitoring were carried out as part of the baseline assessment for the REIA. Both stack emissions and ambient results meet all relevant Government and WBG limits for oxides of nitrogen (NOx), sulfur dioxide (SO2) and total suspended particulates (TSP). SO2 emissions are generally lower because of the low sulfur content of most Indian coal supplies, which average 0.5-0.8%. The REIA team tested the sulfur content of WCPM supplies, which was found to be 0.5%. Average NOx and TSP emissions are expected to fall as a result of the project, in part owing to the improved solids firing of both the new chemical recovery boiler and efficient new lime kiln. The REIA tested fugitive emissions (TSP, methyl mercaptan) at several locations at the plant and found these to be negligible. The REIA report recommended, however, that the design of the new project include additional measures to reduce fugitive emissions where possible and WCPM has agreed to implement such measures, particularly in the chipper house, coal crusher, digester, and coal storage area. WCPM will provide IFC with a fugitive emissions control plan prior to first disbursement, and undertake annual testing of fugitive emissions at identified locations as part of the Annual Environmental and Social Monitoring Report (AMR) submitted to IFC.
The project has been designed to enhance energy efficiency and significantly reduce emissions by replacing the existing plant with a complete new state-of the art pulp mill that utilizes “super batch” (modified batch) pulping, new paper machine, and new lime kiln. Average greenhouse gas emissions (GHG) will be reduced significantly from current levels. Further reductions will be achieved by installation of a new steam boiler and chemical recovery boiler, both using best available technology, which will ensure high efficiency combustion. Because total GHG emissions will nonetheless exceed 100,000 tpa, WCPM will undertake a baseline quantification of GHG emission, in accordance with a timetable agreed with IFC, to enable annual monitoring of ongoing energy efficiency. Monitoring results will be included in the AMR that WCPM is required to submit to IFC.
Water for the plant is drawn from the perennial river Kali for which the company has obtained permission from the relevant authorities. As part of its TQM system, WCPM has an ongoing water conservation program. The current consumption of 80,000 cubic meters per day (m3/day), as against a consented quantity of 85,000m3/day, is expected to increase to approximately 100,000 m3/day after project completion. The project includes a number of water conservation measures and, although production capacity will increase by 95% (from 163,750 tpa to 320,000 tpa), the water requirement will increase by only 25%. The company expects to reduce its specific water consumption from current levels of 166 m3/t of product to106 m3/t after implementation of the project. The REIA concluded that the increased withdrawal from the Kali will not result in any negative impacts on downstream users, even during the lean season, when minimum flow decreases to approximately 900,000 m3/day. All captive plantations managed by WCPM are rainfed. Water use for WCPM’s farm forestry research and planting operations is not significant, and is further minimized by the use of drip irrigation and metered controls on greenhouse misters. Water for all other purposes (housing colonies; sanitary, ablution and canteen facilities, irrigation of gardens) is not expected to increase significantly as a result of the project. As mentioned, WCPM is undertaking plantation activities over unproductive agricultural land to ensure sustainability of raw material supplies. WCPM will plant approximately 6000 ha per year over the next six years, under a subsidized distribution of seedling scheme and contract farming efforts.
In 2002-03, WCPM installed a new effluent treatment plant (ETP) to comply with requirements set by the KSPCB. The ETP has two streams one for combined effluent from pulp mill, chemical recovery plant, power house along with domestic effluent and second stream for combined paper machine effluent. The first stream is based on an activated sludge process with diffused aeration system for treatment of effluent. The second stream has only a primary clarification stage, along with sludge handling system for treatment of paper machine combined effluent. Treated effluents from both streams are mixed together prior to the polishing pond, which is equipped with aeration facilities for boosting up the dissolved oxygen level. Sludge generated from the ETP is supplied to board manufacturers for secondary uses. In accordance with KSPCB consent conditions, treated effluent is tested daily in WCPM’s in-house laboratory, both at the final discharge point and at the confluence point where Halmaddi nala joins the river Kali. WCPM provides a monthly summary of test results to KSPCB, and KSPCB also carries out effluent testing as and when required to confirm test results. Test results indicate that the quality of treated effluent complies regularly with limits set by KSPCB and the WBG for all relevant parameters. Part of the project will be to increase ETP capacity for the paper effluent treatment stream, to handle the additional load resulting from the new paper machine. The capacity of the existing ETP will be sufficient to handle the additional load from the augmented pulp production. During project construction, startup, and operations, WCPM will ensure that treated effluent at all time meets KSPCB and WBG limits as per General Environmental Guideline document. If situations arise that are likely to affect the ETP’s ability to treat wastewater to the required quality standards, WCPM will halt operations until the situation can be rectified and normal operations have been resumed. The project will result in the complete elimination of elemental chlorine from all of WCPM’s pulp bleaching processes and reduce the load of adsorbable organic halides (AOX) to 1.0 kg/t of paper, as required by the CREP.
Hazardous materials are managed in accordance with requirements set be national legislation and industry good practice. WCPM does not use any agrochemicals in any of the plantations it manages, nor in its greenhouses or nurseries. All hazardous materials used in processing are stored either in bulk tanks in the processing areas, or in a single controlled storage area (for smaller volumes). In the past several years. Solid wastes currently comprise of fly ash and bottom ash from boilers, lime sludge from the lime kiln, chipper dust, and residual fiber sludge from the ETP. Fly ash is sold to brick manufacturers and cement companies for use as inputs materials and also for land filling in low lying area and other possible uses. Solids from the ETP, as noted above, are sold to cardboard and egg carton manufacturers. Lime sludge is recycled as raw material for the lime kiln and chipper dust is either used as raw material in boilers or sold. Volumes of all of these solid wastes are expected to increase by approximately 60% as a result of the project (with the exception of lime sludge, which will increase to two and a half times the current volume); however, the additional volumes will continue to be disposed in the same manner.
The only hazardous wastes produced by WCPM’s operations are used oil from plant machineries and waste oil sludge from DG sets. Spent chemicals from chemical recovery section are fully recycled. The existing quantity of spent chemical is 500 tonnes black liquor solids per day; after the proposed expansion it will be 1,500 tonnes per day. ETP sludge of approximately 2 tonnes per day is re-used in duplex machines. Used oil is sold to authorized vendors and waste furnace oil sludge is used as fuel in the rotary lime kiln, in accordance with provisions of the Hazardous Waste (Management and Handling) Rules (1989, 2000, 2002, 2003). Environmental, health and safety during construction will be jointly managed by the WCPM team and the prime construction contractor, which has not yet been selected. As noted, WCPM will ensure that all construction contracts include specific environmental, health and safety (EHS) provisions, and that the prime contractor follows WCPM’s internal safety procedures, which comply with all relevant laws, regulations and standards of the Government of India. Implementation of these requirements will be the responsibility of the contractor and will be monitored daily by WCPM’s OHS Department.
- PS 4: Community Health, Safety and Security
As part of its overall management system, WCPM has prepared, and periodically updates its On-Site and Off-Site Emergency Preparedness Plan (EPP) which includes Crisis Management systems, which consider both situations that will affect the plant itself and the communities outside the plant boundaries. The EPP includes scenario planning for major risks and incidents, during both normal and emergency scenarios. The REIA prepared for the plant expansion included a risk assessment and Disaster Management Plan, which included a comprehensive analysis of potential risks, as well as a Maximum Credible Accident (MCA) Analysis and Consequence Analysis. These analyses calculated the Fire and Explosivity Index (F&EI) and Toxicity Index (TI) for key activities associated with the expansion project. The REIA’s findings are being reviewed by the Company’s Safety Committees, and modifications based on these findings will be adopted in both the EPP and the plant’s standard operating procedures, as required. In addition, the WCPM management team has reviewed PS4 and indicated that the facility will comply with its requirements in full.
WCPM has a strong and positive relationship with the Dandeli municipality on emergency response, security and safety issues. WCPM built, maintains and staffs the only fire station in Dandeli, located just outside the plant gates and including two fire engines, a fire tower, and 24-hour firefighting personnel. Contracted security personnel are drawn largely from Dandeli, and there have been no significant incidents between security guards and local residents. Emergency preparedness and response plans are developed and revised with extensive input from labor organizations, civic organizations, local police personnel, district health officers, and other municipal officials. WCPM conducts regular drills of the Emergency Response and Crisis Management Plans jointly with staff from the Dandeli police, local hospitals and other local agencies. The company takes part in an annual emergency planning exercise with members of both a Local Crisis Group and a District level Crisis Group, which include members from relevant municipal authorities and civil society. The company has designated a contact person within the organization who will be responsible for receiving and responding to questions, concerns or complaints raised by nearby communities or other stakeholders. The contact details (phone number and email address) for this individual will be displayed on signage at the plant entrance, as well as on all published materials distributed to the general public.
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management
None of the activities or developments undertaken in the context of the project is expected to have a negative impact on biodiversity conservation or sustainable resource management. Rather, the REIA concluded that the company’s efforts to extend farm forestry practices to currently degraded land is expected to have significant positive impacts, including improved water retention, reduced soil erosion, and improve soil fertility. In addition, the company’s ongoing research and development (R&D) efforts to improve pulp yield of both acacia and eucalyptus species expected to continue to result in improved productivity per unit of production without additional resource inputs, as well as to improve incomes for small scale farmers involved in tree cultivation, by utilizing land that cannot support other types of agriculture.
