The sponsor has plans to ensure that the proposed project will upon implementation of the specific agreed measures, comply with the environmental and social requirements - the host countries laws and regulations and the World Bank/IFC environment and social performance standards 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 ESAP, which is being agreed upon by IFC and KCIL and will address the compliance gaps with IFC’s requirements.
Social and Environmental Assessment and Management Systems
Land and natural environment: KCIL has the following manufacturing operations:
The Alco complex is located in Ankleshwar, state of Gujarat, and it is 5-km distant from the Ankleshwar railway station and 100 km distant from the Vadodara airport. The 1000 m north and east perimeter of the complex premises is surrounded by a 20 m wide greenbelt. Other operations associated to the complex include (a) a bio-compost facility located in the Village Sengpur at approximately 20 km from Ankleshwar, (b) a wind-farm located in Village Dhank in Rajkot, Gujarat, and (c) a small (16 homes) residential colony close to the plant housing approximately 40 people. KCIL has a long term lease for the chemical complex and the housing colony land with the local authorities, and owns the land for the bio-compost plant and the wind farm.
The Renukoot complex is located in a rural area in Renukoot in the state of Uttar Pradesh an approximately 1.2 km distant from the Renukoot railroad station. This complex also has an associated housing colony, within a 0 to 1 km radius of the complex, consisting of approximately 810 houses, school, temple, club, hospital, for its officers and workers. There are also three villages located at approximately 3 km from the plant.
The associated Salt Works operation is located in a 1200 acres open lot, 3 km distant from the ocean and at approximately 60 km from the Malija rail station in Gandhidham, Gujarat.
- Environmental and Social Assessment.
The company puts strong emphasis on energy and resource conservation and focuses on the minimization of its effluents, emissions, and solid wastes through reuse and recycling initiatives The Central Pollution Control Board has selected the Distillery operation at the Alco complex as a model plant for achieving zero discharge. In addition, the Alco complex has also been granted several awards for sound environmental performance (i.e., 2004 ICMA Award for Water Resource Management, 2004 TERI Corporate Environmental Award, and 2004 Gujarat Safety Council for achieving Zero accidents on one million man-hours worked.) To assess its alignment with its strategic plan, KCIL will develop safety and environmental performance indicators such as, water consumption per ton of end product manufactured, power consumption per ton of end product manufactured, steam consumption per ton of end product manufactured, environmental costs per ton of end product manufactured, mass of DQO in the effluent per ton of end product manufactured, number of reportable accidents, absenteeism rate, etc. Each site has community outreach programs which are handled directly by members of the Kanoria family.
- EHS management and organization.
Both KCIL complexes have ISO 9001 (quality), ISO 14001 (Environmental Management System) and OHSAS 18001 (Occupational Safety and Health Management System) certifications. Each plant has specialized personnel dedicated to implement the EHS practices. To benefit from the synergies among the two complexes and to better manage the EHS aspects at corporate level, KCIL will establish an EHS management corporate structure as part of the Corporate Risk Management Initiative to be soon established as indicated in the ESAP.
- Training, monitoring, and reporting.
Training is periodically given to all employees including contracted workers. As part of the project, Alco will conduct additional training related to manual handling of hazardous materials, and overall safety practices as indicated in the ESAP.
The Alco plant has a fully equipped laboratory for the monitoring of liquid effluent parameters. Ambient air monitoring, stack monitoring, solid waste analysis and treated effluent analyses and annual environment audits are conducted by third parties and submitted to the local authorities. Workplace noise levels are monitored periodically and the levels reported are within the acceptable local and IFC requirements. Solid waste generation and characterization as well as water consumption data are also submitted to the local authorities. All environmental operating permits for air, water and hazardous waste handling for each, the chemical unit, the distillery unit and the Bio-compost Sangpur plant are up-to-date.
The Renukoot plant has a fully equipped laboratory for the monitoring for several of the effluent parameters measured (pH, chemical oxygen demand, chlorides, total suspended solids, total dissolved solids, biological oxygen demand.) Ambient air monitoring, solid waste analysis and few treated effluent analysis are commissioned to an independent certified company. Annual environment audits are also conducted by a third party authorized by the local authorities. Workplace noise levels are monitored periodically and the levels reported are within the acceptable local and IFC requirements, with the exception of those near the power house turbine. Since those levels may further increase as a result of the expansion, KCIL is committed to install the needed measures to ensure employees are not exposed to dangerous noise levels. As part of this project, and in response to the accident the company had at this complex in March 2006, KCIL has commissioned a comprehensive safety audit to achieve internationally benchmarked safety standards as indicated in the ESAP. For its expansion, Renukoot commissioned an environmental impact assessment and obtained all needed expansion environmental permits. Copy of this document was submitted to IFC.
Labor and Working Conditions
KCIL’s human resources policy establishes the terms of employment and working conditions for both plants including procedures such for hiring, training, promotion, insurance, salary and compensation, vacation, etc., in accordance with the Indian labor laws. All employees have access to the human resources policy and procedures. KCIL also has formal mechanisms to handle and resolve employees and contracted laborers complaints. The Indian government authorities sporadically conduct labor inspections to ascertain compliance with local labor laws.
Alco’s employees are organized through a committee elected by workmen. The most recent agreement between company and employees was reached in January, 2007. Renukoot employees are organized in a trade union with which KCIL engages in three year long term agreements. The most recent agreement was signed in 2004. Renukoot anticipates increasing its workplace by approximately 40 employees as a result of the project expansion. At salt works, all labor is contracted out, working in seasonal basis. KCIL complies with Indian labor laws by ensuring contracted workers are covered with all social security requirements.
KCIL is an equal opportunity employer. All hiring and promotions are merit-based. There is no child or forced labor at any of its operations. The company also ensures that the contract laborers are at least 18 years old. The company has procedures for hiring and ensuring the safety of contractors. As part of this project, KCIL will enhance its current contractor’s safety practices and procedures as indicated in the ESAP.
- Occupational health and safety (H&S).
KCIL has appropriate medical services for all its operations. Dedicated medical doctors conduct periodic medical check-ups and attend medical employees’ complaints. Regular check-ups for own employees are also conducted and pre-employment medical check-ups are also conducted. The company has trained personnel, available at all times, to handle first aid/emergency requirements and maintains an ambulance in premises 24 hours/day. KCIL has established a health and safety (H&S) policy which is visibly displayed and communicated to all employees. It has also developed H&S procedures and set safety targets and objectives aiming to achieve “zero accidents.” H&S training is periodically given to all own and contracted employees, and employees are provided with and required to use personal protective equipment (PPE.) To achieve its safety objectives, KCIL has established safety committees for each of its departments at each site. As part of this project, KCIL will develop programs to improve its current health and safety programs as indicated in the ESAP.
Pollution Prevention and Abatement
Alco Complex
This integrated organic chemical complex has a distillery plant and a chemical plant to manufacture seven different alcohol based products. Solid products include Pentaerythritol (TG) Pentaerythritol (NG), Di-Pentaerythritol, Sodium Formate, and Hexamine. Liquid products include Formaldehyde-37% and 43%, Acetaldehyde, Acetic Acid (G) and (D), Industrial Alcohol, Ethyl Acetate. The company is market leader in pentaerythritol, formaldehyde and hexamine.
- Raw Materials and Resource Consumption.
Main raw materials used include ammonia, methanol, caustic soda and molasses. KCIL has implemented actions to optimize water use thus reducing the amount of effluent to be treated. It reduced its water use from 12.5 kl of water / kl of alcohol produced to 8.8 k of water / kl of alcohol produced. It also recycles between 25% and 30 % of its effluent by sending it back to the fermentation process. The Alco complex self-generates all its steam and power requirements through (a) a 2000 KW capacity power plants based on bio gas as fuel (54%), (b) a 2000 KW wind power system (4%), (c) a 1400 KW natural gas unit, (d) a 300 KW capacity back pressure turbine, and (e) an 800 KW diesel generator set. The bio-gas is generated from the primary anaerobic biodigestion process as part of the distillery wastewater treatment plant (WWTP) and the natural gas is bought commercially.
- Air Emissions, Liquid Effluents, and Ambient Conditions.
The Alco stack emissions are controlled prior being released to the atmosphere. The process (acetic acid, acetaldehyde, and formaldehyde) emissions are controlled prior being sent to the atmosphere. Air emissions concentrations from the boilers (particulate matter, SOx, NOx) and processes are measured every three months and comply with the local requirements as well as IFC requirements. Ambient concentrations, which are also measured every three months, are in compliance with IFC requirements, with the exception of particulate matter, which does not consistently comply. The particulate matter levels appear to be associated to the wind velocities in the area. This site has a state of the art effluent treatment system achieving the requirements set by the local authorities. It has separate effluent treatment plants for the distillery and chemical operations.
The Distillery WWTP comprises of anaerobic bio-digesters, a reverse osmosis (RO) plant, a multi-stage evaporation system (MSES), mechanized bio-composting, spray dryer, and a sulphur removal plant. Between 65-70% of the treated water is recovered and used in the cooling tower as make up clean water. Between 30-35 percent of the concentrated effluent is converted into a powder which is partly used for generating hot air required by the system and for manufacturing organic fertilizer. This is the only distillery in India that has installed bio-methanation, RO, MSES, bio-composting and spray dryer for achieving zero effluents discharge. The gases from the bio-digesters are treated prior sending them to the power plant for use. KCIL is also first in the country to install this type of technology.
The Chemical WWTP has a two stage activated sludge aerobic system and a tertiary treatment system with which it achieves the norms set by Government Pollution Control Authority. Part of the treated effluent is recycled back to the process/ cooling towers and the remaining effluent is discharged to Government approved common effluent treatment plant underground drainage system.
- Solid and Hazardous Wastes.
Hazardous wastes generated at the plant include waste activated carbon, waste lubricating oil, and biological sludge from the chemical and the distillery WWTPs. The waste carbon, and the biological sludge from the chemical WWTP are disposed at, Bharuch Enviro Infrastructures Ltd (BEIL), the government authorized common hazardous waste disposal site for incineration and land filling. The waste lubricating oil is sold to authorized users/recyclers, and the biological sludge from the distillery WWTP is used in the bio-compost plant at Sangpur for production of bio-compost. KCIL conducts periodic chemical characterization of the compost to monitor this product does not contain harmful compounds.
- Operational Safety.
The plant has safety measures, in place, to control the overall safety of its operations (i.e., guarded rotating parts, color-coded pipelines, scheduled instruments calibration, isolated surfaces areas, double earthing for storage tanks and motors, etc.) KCIL completed the HAZOP study for the Formaldehyde plant of which a copy was submitted to IFC. As indicated in the ESAP, HAZOP studies for the other plants are being commissioned and are anticipated to be completed by September’07.
- Fire Prevention and Emergency Response.
The plant has prevention/response programs in place (i.e., trained fire/emergency response brigades available at all times, periodic emergency response drills, fire prevention/response equipment such as alarms, sprinklers, signals, hydrants, and extinguishers throughout the plant.) It also has a 670 m3 dedicated fire water reservoir. The last emergency response drill was conducted on November 2006. The next one is planned for April’07.
As part of this project and as indicated in the ESAP, KCIL will implement several actions to further enhance the safety of the Alco operations. In addition, from now on, KCIL is committed to periodically update the on-site and off-site emergency response plans and to complement the emergency response equipment. The company is member of the Ankleshwar Disaster Prevention and Management system, which prepares for, coordinates and handles natural and industrial emergencies.
- Green House Gases (GHGs).
At the Alco complex the emissions of GHGs are not significant, given that it uses natural gas, wind power, and the collected gases generated in the biodigestor,
- Transportation.
The solid products and the solid waste sent to the hazardous waste disposal site are transported via truck. The liquid products are transported by road in tankers and cisterns. All transportation activities are contracted out by the company. To ensure safety during transportation, the company has programs in place to handle transportation of hazardous materials. As part of this project and as indicated in the ESAP, KCIL will develop additional measures to improve transportation safety.
Renukoot Complex
This chlor-alkali complex currently produces:
- caustic soda with liquid chlorine, hydrochloric acid and hydrogen as by-products,
- stable bleaching powder,
- lindane and its formulations, and
- aluminum chloride, polyaluminum chloride, trichlorobenzene, and chlorinated paraffin wax as co-products.
It also bottles nitrogen, and hydrogen which are generated as sub-products. The expansion will increase the caustic soda capacity by 110 tpd, the liquid chlorine capacity by 90 tpd and the hydrochloric acid capacity by 35 tpd.
The Renukoot complex also operates the following facilities:
- two 25 MW captive coal based power plant in Renukoot comprised of a circulating fluidized bed combustion boiler of 105 tph and 110 tph respectively with two generators;
- three steam boiler, of 5thp, 8 tph and 14 tph respectively;
- a captive salt plant in Gujarat which will be fully mechanized by 2009 and will install a salt washing unit by April 2007; and
- a 26 ha residential colony close to the plant for its managers and workers. It houses approximately 810 houses, school, temple, club, hospital, shopping center, playgrounds, etc.
The coal is obtained from two sources:
- by road from the Bina mines, which are located at approximately 50 km from the plant, and
- by rail and then road from the Kari mines which are also located at approximately 50 km from the plant.
The company obtains the salt, which is the main raw material for the caustic soda production, from:
- its captive salt works located near Samakhiali, Gujarat,
- salt manufacturers located in Maliya-Miyana near the railroad station in Gujarat, and
- a leased salt works area located in the state of Rajasthan.
Once processed, the salt is transported by road and then by railroad (Gujarat Maliya and Rajastan Nawa stations) to Renukoot where the plant is located. The production, at KCIL salt works, is seasonal and typically extents from December to June. Approximately 65 % of its production is sent to the Renukoot complex and the remaining 35% is exported. The company sends the packed salt to a storage area closed to the railroad, by truck. Product to be exported is sent approximately 78 km distant to the Kandla Port also by truck. KCIL anticipates having completed the mechanization of its salt manufacturing facilities by 2009.
The company planted an 83 hectares green belt around the industrial complex. Until now it has planted approximately 3.8 million native species trees and will continue planting at a yearly rate of 10000-12000 trees as per local requirements.
As per agreement with the local authorities, KCIL committed by 2006 to reduce the mercury consumption from 60 g/ton of caustic soda produced to 50 g/ton of soda produced. Also as indicated earlier, KCIL committed with the Indian Central Pollution Control Board to phase out the mercury cells technology for caustic soda production by installing membrane cells technology and to eliminate entirely the mercury cell technology from its operations by 2012.
In addition, KCIL also committed to implement an aggressive mercury management program to significantly reduce the exposure of human lives and the environment to mercury will be completely eliminated. Key actions already implemented and in compliance with the local requirements including filtration system for demercurization of caustic soda lye and caustic hydrogen gas, installation of two mercury distillation units (in May 2002 and May 2003), sludge washing system before disposal in secured, lower than requires leachable mercury concentration in brine sludge, and reduction of mercury consumption at levels lower than agreed.
As required by the local authorities, KCIL conducts monthly mercury mass balances to track mercury consumption and releases to air, water, and residues. As part of this project, KCIL will submit to IFC the results of these mercury mass balances in the annual monitoring report and clarify as needed unusual mercury levels.
Overall environmental improvements per ton of caustic soda to be achieved as a result of the mercury-cell technology phase-out include:
- mercury reduction from current 45 g/ton of caustic soda produced to zero,
- reduction in wastewater generation from 4.29 m3 to 0.80 m3, and
- low power consumption.
Raw Materials and Resource Consumption.
Main raw materials used include salt, benzene, ethyl alcohol, and aluminum. All plants have programs to recycle wastewater thereby reducing water intake. The process water is obtained from the nearby Gobind Sagar Reservoir. With the expansion the water consumption will increase to approximately 578 m3/h but it is not expected to significantly impact the reservoir.
Air Emissions, Liquid Effluents, and Ambient Conditions.
The main sources of air emissions at the site include the coal steam boilers, the coal captive power plant, the mercury cells house, the hydrochloric acid unit, the lindane operations, and the calcium hypochlorite production. The 25 MW captive power plant is a state of the art system with a highly efficient electrostatic precipitator (ESP) to control the particulate matter released to the atmosphere. The two stacks from the two steam boilers have cyclones and bag filters to control their air emissions. KCIL has programs to reduce generation of fugitive emissions from coal handling. The boilers and power plant stack monitoring results demonstrated that these units are in compliance with local authorities but yet need to achieve IFC requirements for particulate matter. As part of this project and as indicated in the ESAP, KCIL will upgrade the particulate emissions controls to achieve compliance with the IFC requirements. Even though it is anticipated that the generation of NOx will be very low given that the boiler operates at relatively low temperature, as part of this project, KCIL will begin periodically monitoring NOx and SOx emissions. The emissions from the mercury cells house stack (chlorine, hydrogen, and mercury vapors) are controlled with a water scrubber and an activated carbon unit prior being released to the atmosphere. They comply with local and IFC requirements.
The hydrochloric acid unit has two scrubbers to remove residual HCl before venting the gases throughout six stacks. The caustic soda flakes plant air releases has systems in place to ensure complete combustion. The calcium hypochlorite plant has the greatest potential for chlorine emissions since this plant is connected to the other plants and transfers chlorine for their operations. Before releasing the gases from this plant to the atmosphere, they are passed through a chlorine absorption/neutralization system to ensure adequate control. Emissions from the anhydrous aluminum chloride plant are passed through a packed scrubber prior releasing the gases through three stacks to the atmosphere. The lindane plant has six bag filters to control dust emissions before discharging the release gases through four stacks to the atmosphere. The lindane formulations operation has dust collectors to remove dust before releasing gases through two stacks to the atmosphere. As part of this project and as included in the ESAP, KCIL will conduct processes stack emissions monitoring and will submit as needed improvement actions to ensure compliance with local as well as IFC requirements. From then on, KCIL will conduct periodic process stack monitoring.
Ambient air conditions are measured and the results demonstrate compliance with local and IFC requirements, with the exception of particulate matter which is high due to wind blowing conditions. It is anticipated that the emissions will not increase as part of the expansion, maintaining therefore the current ambient conditions unaltered.
The mercury bearing effluents are treated in a dedicated WWTP. One hundred percent of the mercury bearing treated effluent is recycled back into the process and the sludge generated is disposed off-site. Non-mercury liquid effluents are also treated in a separated WWTP prior being discharged. The treated process and power plant effluents are discharged to the Dongia Nullah River. The chlorine concentrations of the discharged liquid effluents will be reduced to comply with the applicable IFC requirements. The domestic effluents from the residential colony are also discharged into the Dongia Nullah River without treatment. As part of this project KCIL will install a treatment control system to reduce pollutant loads of colony domestic effluents at acceptable IFC levels. The expansion will increase the total effluent amount released to the river by approximately 7 m3/h.
Solid and Hazardous Wastes. The Renukoot complex process generates:
- mercury contaminated brine sludge,
- benzene hexachloride sludge from the production of lindane and
- non-hazardous lime sludge.
The additional brine sludge which will be generated as part of the expansion will be properly handled. There is a dedicated hazardous wastes landfill within the complex premises which has been constructed with all safety measures (i.e., impervious lining, retention wall, underground leachate/seepage monitoring systems, etc.) Residues from Lindane production (alpha and beta isomers of benzene hexachloride) are used in the production of trichlorobenzene; however there is a remainder which is properly landfilled in the secured hazardous waste disposal site. The non-hazardous poly aluminum chloride filtration cake is disposed in a nearby landfill designated by the local authorities for non-hazardous wastes. The fly ash collected from the power plant ESP is partly used for making fly ash bricks (a million/yr) in an ash brick plant built by KCIL within the complex premises. The remaining fly ash is collected by nearby cement plants and used in their process. The bottom ash is also collected, a 30 percent is recycled and use back in the boiler and the remaining 70 percent is used in masonry work.
- Operational Safety.
As part of the process, the plant handles chlorine, nitrogen, oxygen, hydrogen, and dissolved acetylene cylinders. KCIL has dedicated areas for its storage and has implemented the needed safety precautions (periodic check-up, fire prevention systems, alarms, liquefied chlorine maintained at about minus 10 degrees Celsius, etc.) to prevent the risk of explosions. Recently, the plant has significantly strengthening its chlorine tank filling safety measures by upgrading the filling process, reinforcing employee training, and upgrading the operating procedures. At the lindane plant, measures are taken to reduce the risk of benzene leaks.
Safety measures in place at the plants include suitable safeguards for all the moving parts, the proper earthing devices for needed equipment, and in-house checking and third party periodic testing of underground tanks and vessels. As part of this project, KCIL will further enhance its safety procedures including periodic testing of vessels valves, pipelines conditions, fire prevention equipment systems, etc, as indicated in the ESAP.
- Fire Prevention and Emergency Response.
Renukoot operations have appropriate fire prevention systems including fire extinguishers, water storage, fire pumps, backup generators, etc. The plant is part of the Mutual Aid Program established among the industries in the industrial complex. This program ensures fire fighting and medical aid assistance in case of emergency. The Mutual Aid Program is structured so that the companies meet periodically and maintain trained response brigades at all times. The company has developed an on-site emergency response plan and trained personnel to handled emergencies. As part of this project, the emergency response plan will be further enhanced to include aspects such as, safe assembly points, escape routes, etc. as indicated in the ESAP. The company has commissioned a safety assessment by a specialized chlor-alkali company to identify and control the potential hazards due to the new projects and modifications in their processes. Copy of the recommendations and implantation schedules will be submitted to IFC as indicated in the ESAP.
- Green House Gases (GHGs).
The expansion will have a significant impact in the reduction of GHGs since approximately 93,500 kWH/day less will be required. The total saving of coal will be about 81.5 MT/day which in turn will reduce the generation of 1.23,644 Kg of CO2. KCIL will begin calculating its GHGs levels generated and continue supporting initiatives to reduce green house gases.
- Transportation.
For transportation of goods, the company relies on railroad wagons and contracted road trucks and tankers. KCIL is responsible for any leak/accident of the vehicles. Even though the company has procedures in place to train employees on the hazards of the material transported, and response in case of emergencies, KCIL will further enhance its program to ensure that there are appropriate systems in place. The company is currently completing an extension of its railroad siding so that the coal supply coming from mines is entirely transported via railroad thus eliminating the associated road transportation risks. In addition, the company is also working with the local authorities to also have the coal coming from the Bina mines to be transported via rail.
Community Health, Safety and Security
KCIL has programs in place to reduce negative risks to the nearby communities. KCIL conducts periodic off-site emergency response drills at both complexes and closely coordinates with the Mutual Aid Program at both sites, Ankleshwar and Renukoot, to ensure the community is aware of risks and prevention measures related to the chemical complex. To ensure safety during transportation, the company has programs in place for handling of hazardous materials and safety transportation; however, as indicated above, KCIL will enhance its current Safety Transportation Programs. Community grievances are addressed and when resolved, a copy is sent to the local environmental authorities.
Product Stewardship. KCIL is committed to produce safe products, disclose the inherent risks in the use and handling of its products, and share the good environmental and safety practices it applies in its industrial sites. KCIL conducts training for buyers and users of its products about safe handling and proper use of their products, and in 2007 it anticipates publishing a product safety brochure to be distributed to buyers and users of its products. In addition, with this expansion project, KCIL will have a mercury free product.