The key environmental and social issues for this project include the following:
- Air emission
- Wastewater treatment and discharge
- Solid and hazardous waste management
- Occupational health and safety
- Fire protection and emergency response
- Operation hazard and hazardous material management
- Human resource policy and grievance mechanism
- Community health/safety
- Community relationship and development
- Land acquisition process
MFL 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 IFC Environment and Social Performance Standards and the World Bank Group (WBG) environmental, health and safety guidelines. The information about how these potential impacts will be addressed by MFL is summarized in the paragraphs that follow. Further information is provided in the attached ESAP, which is agreed upon by IFC and MFL and will address the compliance gaps with IFC’s requirements.
1. Social and Environmental Assessment and Management Systems:
Land and natural environment:
MOL purchased 65 ha land for MFL’s new project site from the Gujarat Industrial Development Corporation (GIDC) in Dahej area, Gujarat State, India. GIDC is a state government agency for promotion of industrial development. GIDC set up the industrial zone in Dahej area in mid-1990s. At present stage, there are several existing large petrochemical and metal processing plants in the industrial zone, including three chlor-alkali plants with larger or similar capacities. The project area is a costal barren land without cultivation. The nearest community is approximately three km from the site. According to environmental impact assessment, there is no natural protected area or protected species at or near the site.
Environmental and Social Assessment:
MFL hired external experts to conduct an environmental impact assessment (EIA) and an associated quantitative risk assessment (QRA) for the proposed chlor-alkali and captive power project according to Indian regulatory requirements. The EIA and QRA indicate that the project has limited impacts to the environment and nearby communities upon successful implementation of the proposed mitigation methods in both documents. In accordance with the ESAP, MFL will revise the EIA and QRA to meet all IFC requirements.
Environmental, health, and safety (EHS) management and organization:
There are EHS managers at each plant site of MOL. In accordance with ESAP, MOL will hire an experienced corporate EHS coordinator and set up an effective corporate EHS management system. MFL will also hire its EHS manager soon, draft all EHS programs and procedures prior to the trial production, and set up an effective EHS management system after the trial productions. MFL management also considers applying ISO and OHSAS certification.
Training, monitoring, and reporting:
MOL has an established program to provide necessary EHS training for all its employees related to its operations. MOL conducts routine environmental, health and safety monitoring for its operations. For the proposed new site, MFL will set up the EHS training, monitoring, and reporting programs as part of its preparation of overall EHS programs and procedures prior to the trial production.
2. Labor and Working Conditions:
Human Resources Policy and Management:
The MOL has a corporate level human resources (HR) policy that specifies the terms of employment and working conditions at MOL. These include procedures for hiring and recruiting, probation, training, performance review, promotion, insurance, salary and compensation, resignation, lay-off and firing, leave and vacation, and retiring. The employees have access to the HR policy and procedures. The HR function is a corporate function covering each plant, including the proposed MFL plant. MOL has the open-door policy for management to handle the employee grievance. The HR office also works as a grievance mechanism for the employees. MOL complies with national law and does not hire workers below the age of 18.
Worker’s Organization:
There is no local or nation-wide union at MOL. MOL management is committed not to discourage the employees forming a union. There is collective bargaining for compensations and benefits at MOL. MOL management handles the collective bargaining according to the local regulatory requirements. If the case could not be settled at MOL, the case will be transferred to the local court for judiciary decision.
Non-Discrimination and Equal Opportunity:
The hiring and promotion at MOL is solely merit-based with preference to the local residents. MFL will hire approximately 350 employees and 400 contractors. Majority of the new employees/contractors will be hired locally from Dahej region. GIDC set up the industrial zone in Dahej area 10 years ago, and there are enough experienced labors to meet MFL requirement. As stated in the ESAP, MFL will provide female-friendly working environment, including but not limited to, female restroom, locker and shower room, preferential allotment of work shifts, and promote the hiring of female employees for proper positions.
Retrenchment:
Retrenchment is not expected for this project. The company will hire approximately 500 new labors for the MFL plant. In addition, depending on the stages of the construction, 200-1000 construction workers will be hired through contractors.
Occupational health and safety (OHS):
Operational safety is highly emphasized in the operation at MOL. There is routine OHS training including new employee training and annual refreshers. For the new MFL plant, all the OHS operational procedures for each position will be prepared by June 2008, and all the employees should be trained for OHS procedures based on their positions before the trial production. In accordance with the ESAP, MFL will develop workplace air quality/noise monitoring programs, and track the statistical trends of near-miss and accidents.
3. Pollution Prevention and Abatement:
Raw materials and resource consumption:
The major raw material consumption in MFL comprises industrial salts (310,000 t/y), sulfuric acid (3,500 t/y), coal (192,000 t/y), and water (5,600 t/d). The water is supplied by GIDC from the upstream of a nearby river. Industrial salts are from local salt plants in Dahej area. All the power requirements will come from the onsite coal-based captive power plant. MFL will not purchase power from the grid during normal operation.
Environmental Compliances:
MFL will generate 2,600 t/d wastewater during normal operation, which is primarily treated onsite and discharged to the GIDC common effluent treatment plant for further treatment. MFL’s effluent accounts for approximately 4% of GIDC treatment capacity. GIDC discharges its treated effluent to the deep sea. The discharge point is 11 meters beneath the surface and approximately 15 km offshore. As stated in the ESAP, MFL will set up additional reverse osmosis (RO) process to further treat and recycle the wastewater, especially the cooling water. Once the RO process is put into operation, the wastewater discharged to GIDC common effluent treatment plant will be not significant.
The EIA estimates that the emissions from the power plant and various other manufacturing processes meet all the local regulatory requirements and the World Bank Group (WBG)/IFC guideline limits. The modeling in the EIA also predicts that the ambient noise and air qualities at communities nearby meet all the local regulatory requirements and the WBG/IFC guideline limits, with the exception of particulate matters (PM), which exceeds WBG/IFC guideline limits. The project site is a dry barren area with high PM background, and the PM contribution from the project is negligible upon successful implementation of the mitigation methods required in the EIA.
Solid and hazardous wastes:
MFL will generate approximately 22,000 t/y fly ash from the captive power plant and 20,000 brine sludge from chlor-alkali process. The fly ash will be sold for construction industries, and brine sludge will be disposed at an onsite landfill with composite impermeable liner system. The household solid waste generated onsite will be picked up by municipal contractors for offsite disposal. Waste petroleum products are the main hazardous wastes generated onsite, which will be sold to the registered recyclers for recycle or disposal.
Hazardous materials and operation hazard:
MFL will manufacture significant amount of chlorine and other hazardous materials. The manufacturing, storage, handling, and transportation of these materials pose serious dangers to the employees and nearby communities. MFL will set up all necessary OHS programs and procedures in 2008 and provide sufficient training for the new employees before the trial production. As stated in the ESAP, MFL will install chlorine monitors at important locations across the site and along the property lines, which are monitored and recorded at the central control room. According to the ESAP MFL will also conduct hazard operability (HAZOP) studies once the production processes are stabilized. The HAZOP will be updated whenever any processes are modified.
Fire prevention and emergency response (ER):
MFL will install adequate fire fighting equipment at the proposed site. MFL will also have a common/shared fire fighting brigade. There will be a clinic onsite which will be visited by mobile team of shared medics. Large plants at the GIDC industrial estate have their own fire fighting and ER teams, while medium and small sized plants establish common/shared teams. GIDC has an ER coordination center, which coordinates emergency response and leads inter-plant mock drills twice a year. In case of major fire or chemical leak, the ER coordination center can call the fire fighting and ER teams from other plants for help. MFL will draft ER plan and have routine internal fire fighting and ER dills besides the inter-plant mock drills.
Greenhouse Gases (GHG):
The greenhouse gas for the MFL project is from the coal-based boilers, which generate about 364,000 t/y carbon dioxide. MFL has a plan to gradually use hydrogen manufactured in the process to replace coal. It plans to reduce carbon dioxide generation to 268,000 ton/y in five years. There is no indirect greenhouse generation for this project. All the equipment at MFL will be new and the key electrolysis technology for chlor-alkali production will be adopted from Japan. The overall energy efficiency at MFL will be among the best in India.
4. Community Health, Safety, and Security:
Community health, safety and security: The two nearest villages are approximately three km away from the MFL site. The EIA concludes that the normal operations at MFL has limited impacts to the nearby communities. According to the modeling calculation in QRA, the impact zones under various explosion and leak scenarios are mainly restricted inside the MFL property. Coal is transported to the site from jetty, five km from the site, and industrial salts are also transported by road from nearby sea salt plants. Chlorine will be transported by road to the chemical plants at other industry estates in the region. The road conditions are fair.
Emergency preparedness and response:
MFL will have ER plans available and conduct routine drills for fire fighting and potential chemical explosion/releases. GIDC coordinates inter-plant mock drills twice a year, which involve the local hospitals and representatives from nearby villages. In accordance with the ESAP, MFL only contract with transportation companies that have defensive driving programs, acceptable safe driving records, and sufficient emergency response methods.
Security personnel:
MFL hires external agency for site security, which conducts routine ID check at the gates and security monitoring. The security personnel do not have any firearms except for the head of the security team. For serious security issues, MFL reports directly to the local police station..
5. Land Acquisition and Involuntary Resettlement:
GIDC set up the industrial zone in Dahej area in mid-1990s. In December 2006, MOL purchased 65 ha land for the MFL project from GIDC at the Dahej industrial zone. At the time of purchase, the area is an empty barren land without any human settlement and cultivation. The MFL project does not involve any economic or physical displacement.
