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 environmental and social requirements - the host country laws and regulations, IFC Performance Standards and WBG/IFC environmental, health and safety guidelines. The information about how these potential impacts will be addressed by the company/project is summarized in the paragraphs that follow.
- PS1: Social and Environmental Assessment and Management Systems:
PLL’s management proactively addresses environmental, social, occupational health and safety (EHS) aspects associated with its operations. The company’s mission, amongst other objects, is to maximize value for all stakeholders. The company has, at its Dahej terminal, implemented quality and EHS management systems (EHSMS), which are certified to ISO 9001, ISO 14001 and OHSAS 18000 standards. Further, the company will implement a quality and EHS management system certified to ISO 9001, ISO 14001 and OHSAS 18001 standards at Kochi, within 18 months of the terminal commissioning. The EHS management system at PLL’s Dahej terminal is well implemented on the ground.
PLL has a process in place to undertake environment and social assessment (ESA) of projects it proposes to implement. The company will appropriately embed IFC’s Performance Standards in its ESA process and also the EHSMS. PLL will ensure that ESAs undertaken for future projects including ongoing management of EHS aspects, are consistent with the provisions of IFC’s Performance Standards. The company has undertaken CEIA, both for terrestrial and marine impacts, for the project. The EHS impact management and mitigation plans (EMP) based on CEIA findings are adequate and address relevant environmental and social impacts. The company has received Ministry of Environment and Forests (MoEF), Government of India (GoI) environmental clearance for Dahej terminal capacity expansion and for the Kochi terminal.
The company, together with the ESA, undertakes a preliminary risk analysis including for worst case scenarios and maximum credible loss scenarios. Further, PLL requires the EPC contractor to: undertake a detailed quantitative risk assessment (QRA) as also a hazard and operability (HAZOP) study; and incorporate findings of the detailed QRA and HAZOP in project detail engineering. PLL will ensure through appropriate engineering and management measures that:
- risks are contained within the terminal premises both at Dahej and Kochi terminals; and
- the individual and societal risks are within international criteria and best practice norms.
Moreover, the company will, based on the results and findings of the detailed QRA and HAZOP study:
- prepare an onsite and offsite emergency and disaster management plan (EDMP);
- link the EDMP with local area EDMP;
- communicate the EDMP to local communities; and
- conduct periodic onsite as also offsite training/mock drills including with the participation of local communities.
The principal associated facility for PLL’s LNG terminals is the RLNG transmission pipeline. The RLNG transmission pipelines are and will be laid, owned, operated and maintained (O&M) by third parties. Presently, the RLNG transmission pipeline owners/operators are GAIL and GSPL, both public sector gas transmission utilities. PLL has processes in place to review the ESA undertaken by the owners of the RLNG transmission pipelines. The company will make available IFC’s Performance Standards to GAIL and GSPL and make commercially reasonable efforts to encourage both GAIL and GSPL such that:
- the ESAs for the RLNG transmission pipelines are consistent with IFC Performance Standard requirements; and
- the RLNG pipelines are laid and operated/maintained as per IFC Performance Standards and WBG/IFC EHS guidelines. While a new RLNG transmission line is proposed to be laid by GAIL from the terminal up to both Mangalore and Coimbatore for the Kochi terminal, no new RLNG pipeline is proposed on account of Dahej expansion.
The company’s EHS organization includes:
- a corporate head with oversight responsibilities for all facilities; and
- EHS cells at each facility with qualified EHS personnel including a marine biologist at each location.
The EHS organization, besides management of EHS aspects during operation, also ensures that the EPC contractor meets PLL’s EHS requirements during construction. The company will implement an EHS monitoring and management program including for ambient air quality, noise, emissions and discharges, salinity ingress, marine environment impact (including water quality, shoreline changes, sea floor changes, sediment quality, biological characteristics and bio-assay for any waste water released), channel morphology survey and bathymetric survey of dredged material disposal site.
In the context of the project, the company will need to update the ESA for Dahej expansion, to address potential impacts on account of the proposed 5th storage tank or the second jetty, if considered. Accordingly, the company will:
- undertake additional ESA (including updating of the QRA to address the changed scope of the Dahej Expansion project) in accordance with IFC Performance Standards;
- update the ESA documents, as necessary, to reflect this change in Dahej Terminal’s scope and make it available to IFC for review; and
- obtain necessary regulatory approvals. The company will also make available the detailed QRA for the Kochi terminal for IFC’s review. This ESRS document will be updated as additional ESA documentation pertaining to Quantitative Risk Assessment and ESA become available.
- PS2: Labor and Working Conditions:
The company has implemented a well documented Human Resource (HR) Policy and Manual. Further, conditions of work/employment for workmen/labor are stipulated in detail under the model standing orders, which the company adheres to.
The model standing order details:
- classification of various categories of workmen;
- communication of terms of employment including hours of work, pay days, shifts, wages;
- eligible leaves and holidays;
- procedures for temporary lay-off;
- termination of employment; and
- disciplinary procedures.
The HR manual describes policies and procedures pertaining to:
- recruitment (including internal recruitment, induction, orientation and probation);
- grade structure, emoluments and benefits;
- employee welfare;
- leaves;
- performance management, increment and promotions; standard of conduct and performance;
- grievance redress;
- misconduct and disciplinary action;
- relocation, transfers, exit, termination and separation;
- retirement benefits; and other items.
The company has articulated policies on equal opportunity as also on alcohol and drug abuse/creating a drug free environment. The company will review IFC’s Performance Standard 2 (PS2) provisions on grievance redress mechanism and update its grievance redress procedure to make it consistent with IFC’s PS 2. The company has commissioned a third party to carry out a training need analysis and will develop a training and career development program based on the outcome of the training need analysis. Conditions of employment as well as wages and benefits are communicated to employees through intranet, formal system of periodic dialogues, employment letters and notices. The company will prominently display the Standing Orders (conditions of work), in the local language at each of its facilities. The company has procedures in place to ensure that contractors meet national labor laws.
Occupational health and safety forms an integral part of PLL’s HR philosophy and is embedded in the employee performance management system. Further, PLL has processes in place to ensure that outcome of risk assessment is addressed in facility design and operation philosophy. The company will, on an ongoing basis, manage occupational health and safety through the OHSAS 18001 certified management system. Occupational health and safety training process for employees and contract workers is already in place. However, it will be upgraded further, based on the outcome the third party training need analysis, which is currently underway.
- PS3: Pollution prevention and abatement:
The company’s EHSMS requires adherence to host country environment management, pollution prevention and control requirements. PLL will also incorporate, in its EHSMS, all applicable World Bank Group/IFC pollution prevention and abatement requirements. While provision for grid electricity exists at each terminal location, the principal source of electrical energy typically is captive gas turbine generators (GTGs). Waste heat from GT flue gas is recovered for regasification through the STV route. The principal point source of air emissions are the stacks attached to the GTGs. Emission of particulate matter, sulphur di-oxide are negligible and emission of oxides of nitrogen from the GTG will be well within IFC norms. The GTGs are and those proposed will be equipped with lean burn low NOx technology. On account of the project, no material increment in ground level concentration of SPM, RPM, SO2 and NOx as also noise levels is expected. The company will ensure that the refrigerant used in air conditioning system as also the fire extinguishers, comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements. PLL is implementing a scheme to use chilled water system (based on cold recovery during re-gasification), which will reduce the need of refrigerant for air conditioning. The EMP details adequate measures to minimize fugitive emissions to air and to mitigate air quality as also ambient noise level impacts during construction. The company will ensure that the planned mitigation measures are duly implemented during construction and operation.
There is no process water requirement and water (50-60 m3/day) for domestic purposes will typically be sourced from the water supply grids. No material impact is anticipated on account of increased water consumption due to the project. PLL will implement a scheme to recover and use the condensate water (generated from condensed moisture in the air used for re-gasification), to further reduce fresh water withdrawal and also undertake rainwater harvesting. The company will ensure that drinking water complies with GoI/WHO standards.
There is no process waste water generation barring the condensate water, which is will be consumed/used in the process and the balance will be used on premises for irrigation. Domestic waste water will be discharged through septic tank and soak pit route at Dahej. At Kochi, a sewage treatment plant is proposed and treated wastewater will be used on premises for irrigation. However, during construction, due to influx of labor higher volumes of sanitary effluent generation is expected. The company will ensure that EPC contractor makes available appropriate sanitation facilities such that sanitary wastewater is not discharged untreated into the sea/other surface water bodies.
Hazardous materials used/to be used on premises include minor quantities of lubricating and hydraulic oils. Hazardous wastes generated on the company’s premises include minor quantities of spent oils and used lead acid batteries. The company will store all hazardous materials and wastes in designated areas with adequate secondary containment and dispose hazardous wastes through authorized entities in accordance with host country requirements. During construction, the company will require contractors to develop appropriate procedures and facilities for storage and handling of oils, lubricants and for management of spills including provision of temporary secondary containment facilities. The company will segregate and store scrap as also other waste material, in designated areas both during construction and operation. Further, the company will ensure that EPC contractor implements mitigation measures indicated in the EMP to minimize adverse impact during construction.
The company ensures that tankers, tugs and other jetty operations are in accordance with MARPOL and SOLAS requirements/standards, to prevent marine pollution impacts. LNG spill, if any, is expected to vaporize rapidly without material impact. PLL will ensure that tankers, tugs and shore operations have adequate provisions for oil spill prevention, containment and clean-up.
PLL’s business, making available RLNG for consumption, encourages GHG reduction through replacement of fuels with higher GHG intensity. PLL’s facilities also use GTGs to meet their electrical energy needs. Further, the company has designed its LNG regasification process to recover waste heat from GTG flue gas. The company will continue to identify and harness opportunities for improving energy efficiency of its operations and thereby reduce GHG emissions.
- PS4: Community health, safety and security:
The company as a corporate policy adopts good international industry practices in design and construction of facilities, infrastructure and in selection of equipment. Most of the project construction work will be within the project site at Kochi and existing terminal premises at Dahej. Moreover, because the nearest local community habitations are located more than 1 Km from the terminal/project sites, respectively, minimal community environment, health and safety impacts are expected. Further, the company will ensure, through a QRA, HAZOP, appropriate engineering and management measures, that risk associated with each of the terminals is contained within the terminal premises and societal risks are within international criteria/best practice norms. PLL will ensure that EPC contractor adopts good EHS practices during construction and in particular ensure that its employees and EPC contractor:
- train equipment operators and drivers in safe driving techniques;
- develop a materials movement plan to ensure that vehicle movement during construction has minimal impact on normal life patterns of nearby communities;
- undertake appropriate measures to reduce fugitive emissions from storage and transport of excavated earth and other construction material; and
- periodically monitor ambient air quality as also noise levels in potentially affected communities/villages, and implement mitigation measures where required.
Where an influx of laborers is expected during the project construction period, the company will ensure that appropriate amenities/facilities for labor are provided by the EPC contractor during construction. In this regard the company will provide, or require its contractors to ensure that:
- to the extent possible, members of local community are employed as construction laborers;
- labor camps, have appropriate facilities and amenities including housing, toilets, washing and cleaning water, potable drinking water and cooking fuel;
- treated sanitary waste water meets IFC/WBG requirements prior to discharge; and
- potential host community impacts on account of influx of labor are assessed and managed.
The project is not expected to exacerbate community exposure to disease due to changes in land/hydrologic or other terrestrial/air quality/hydrologic regimes. However, PLL will require the EPC contractor, where relevant and applicable, to implement measures to minimize risk of community exposure to disease due to influx of large pool of laborers. Security personnel are armed but are sourced from reputed security service providers. The company has well defined security procedures and the security department is led by qualified professionals. PLL will, review IFC’s Performance Standard 4 (PS 4) provisions on security related aspects and update the security procedure to make it consistent with IFC’s PS4 provisions.
- PS5:Land Acquisition and Involuntary Resettlement:
PLL adheres to host country requirements when acquiring land for its projects. The company will incorporate the provisions of IFC’s Performance Standard 5 (PS 5), in its land acquisition policy and procedures. However, no land acquisition is proposed either at Kochi or for Dahej expansion. Kochi terminal will be located at Puthuvypeen Island on 32.4 ha accreted land. The Kochi terminal site has been allotted to PLL by Cochin Port Trust (CPT) and is located at the entrance/mouth of the channel to Cochin Port. In case of Dahej terminal expansion, additional land, to be reclaimed from the sea, may be needed for the 5th tank. While fresh land acquisition of private land, is likely not required under the project, in the event of any land acquisition, it will be undertaken by PLL in accordance with IFC’s PS 5 on land acquisition and involuntary resettlement, as applicable. Further, in case of ROU acquisition for the RLNG pipeline from Kochi terminal to Coimbatore/Mangalore, PLL will make available IFC’s Performance Standards to GAIL and make commercially reasonable efforts to encourage GAIL such that:
- the ESA for the RLNG transmission pipeline is consistent with IFC Performance Standard requirements; and
- the ROU acquisition is consistent with IFC Performance Standard 5 on Land acquisition and involuntary resettlement.
Entire 250 ha accreted land on Puthuvypeen island, including PLL’s Kochi terminal, is proposed to be developed by CPT as a Special Economic Zone (SEZ), which may potentially impair seafront access/livelihood of fishing communities. To mitigate any potential impact on the livelihood of fishing communities operating out of Puthuvypeen island, CPT proposes to construct a fish landing terminal for the use of these fishing communities. Experimental trawling and other relevant information made available in the marine studies for Dahej, indicate low fishing potential even during peak fishing season. Hence, material adverse impact on livelihood due to increased tanker traffic at Dahej is not expected.
- PS 6: Biodiversity Conservation and Sustainable Natural Resource Management:
PLL develops its projects to protect and conserve biodiversity and to promote sustainability. The company has carried out a Comprehensive Marine EIA and will implement mitigation measures in consultation with Central Water and Power Research Station (CWPRS), National Institute of Oceanography (NIO) and as per the EMP, to minimize impacts on the marine environment. PLL will be using STVs and SCVs for re-gasification at Kochi (as already being used at Dahej), to avoid withdrawal and discharge of significant quantities of sea water and the associated impacts. Channel deepening and harbor basin development at Kochi will involve a dredging volume of 12.5 x 106 m3.
The company will:
- consult with CWPRS/NIO to develop a dredging plan;
- deploy appropriate equipment to minimize re-suspension/spread, increase in turbidity conditions and to avoid over dredging;
- dispose of dredged material at a pre-selected approved site (as per CWPRS recommendations) and in a manner so as to avoid contamination/pollution or material impact in the disposal area; and
- undertake periodic bathymetric survey of the disposal site.
The Kochi site has casurina plantation/treelots, which will be felled. The company will undertake compensatory afforestation in consultation with the Forest Department. Further, the company will ensure that mangroves in the vicinity of the proposed terminal are protected; and RLNG pipeline and other associated facilities are laid/constructed at least 50 m from any mangrove or forest areas.
In the event a second jetty is proposed to be constructed at Dahej, the company will undertake an ESA acceptable to IFC, to identify and mitigate any marine impacts on account of construction and operation of a second jetty. Further, this ESRS will be updated to reflect the results and findings of the abovesaid ESA. The updated marine EIA (April 2005) indicates that PLL’s existing jetty operations have not resulted in any material impacts on the marine environment.