The key environmental and social issues for this project include the following:
- Environmental and social management system
- Wastewater treatment and discharge
- Operation hazard and hazard operability study
- Greenhouse gas emission and energy efficiency
SAPL 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 Egyptian 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 SAPL is summarized in the paragraphs that follow. Further information is provided in the attached ESAP, which is agreed upon by IFC and SAPL and will address the compliance gaps with IFC’s requirements.
- Social and Environmental Assessment and Management Systems
Land and natural environment: SAPL’s existing PET manufacturing site is located in a heavy industrial zone, seven km west of Haldia port in West Bengal, India. There are scattered residential houses inside the industrial zone. The nearest houses are around one km away from SAPL site. The proposed new PET site is located in a dedicated petrochemical zone inside the property of Port Authority in Damietta, Egypt. There is no residential community at or near the Damietta Port. The EIA for the Indian site and the draft ESIA for the Egyptian site both indicate that there are no natural protected areas or protected species at or near the sties.
Environmental and Social Assessment:
SAPL contracted external experts to conduct environmental and social assessments for the proposed Egyptian site according to both Egyptian regulatory requirements and IFC Performance Standards. IFC reviewed the draft ESIA with major data and preliminary conclusions. According the draft ESIA, the proposed project will meet both local regulatory requirements and IFC policy/guidelines upon successful implementation of the mitigation methods. SAPL is committed to finalize the ESIA before the construction and ensure that the ESIA meets both local regulatory requirements and IFC E&S policies and guidelines.
Environmental, health, and safety (EHS) management and organization:
The EHS management at the Indian site is under technical and HR managers. SAPL plans to apply for ISO 14001 for its Indian operations. In accordance with the ESAP, SAPL will establish an independent EHS department, reporting to the plant manager. Furthermore, SAPL will set up an effective corporate EHS management system based on the requirements of IFC Performance Standards.
Training, monitoring, and reporting:
SAPL has an established program to provide necessary training for all its employees in the field of environmental and social performances related to its operations. SAPL also conducts routine environmental, health and safety monitoring for its operations. SAPL keeps its environmental and social performance records through its internal reporting structure, and discloses information at its plant gate in India as stipulated by the Pollution Control Board of the State Government. SAPL agrees to disclose its annual E&S performance reports at its website.
- Labor and Working Conditions
Human Resources Policy and Management:
SAPL has a Human Resources policy which specifies the terms of employment and working conditions at its Indian site. 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. HR department also works as an employee grievance mechanism. SAPL only hires employees older than 20. The HR management meets both local regulatory and IFC policy requirements. As stated in the ESAP, SAPL will make the human resources function as a corporate function and ensure that the HR management at its proposed Egyptian operation meets both local regulatory and IFC policy requirements.
There are approximately 250 employees and 50 contractors at the Indian operations. There is no further hiring plan for its Indian operations. At the proposed Egyptian plant, SAPL may have 350 to 400 employees, in which 30 to 40 are from India, and the remaining 300 to 350 employees are mainly hired locally from Damietta, Egypt. All hiring at SAPL are strictly merit-based and there are relevant non-discrimination and equal opportunity rules in the HR policy.
Worker’s Organization:
There is a labor union at the SAPL Indian plant, which is a branch of a nationwide union. Almost all the labors belong to the union. There are no strikes or other union unrests in SAPL operation history. As a routine process, the union represents members in the collective bargaining for salary and other benefits.
Retrenchment:
There is no retrenchment for this investment. The proposed new plant in Egypt will hire 300 to 350 local employees.
Occupational health and safety (OHS):
The safety engineer under the technical manager leads the OHS works at the Indian plant. Operational safety is highly emphasized in the operation. There are effective OHS procedures and adequate personal protection equipment (PPE) provided for each position. In accordance with the ESAP, SAPL will review the PPE procedures for all positions and enforce procedures strictly. There is routine OHS training including annual refreshers for its employees. There is no serious accident in the operation history of SAPL. The monitored parameters for workplace conditions and drinking water quality meet both local regulatory requirements and good international industry practice. As stated in the ESAP, SAPL will monitor the E. coli in the drinking water for the Indian plant.
- Pollution Prevention and Abatement
Raw materials and resource consumption:
The major raw material consumption at the Indian site is as follows; purified terephthalic acid (PTA) (150,000 t/y), monoethylene glycol (MEG) ( 60,000t/y), water ( 400 t/d), furnace oil (9,000 t/y) for power generation, and coal (28,000 t/y) for process heating. At the Egyptian site, the proposed major raw material consumption is PTA (275,000 t/y), MEG (110,000 t/y), water (250 t/d), electricity (48,200 MWhr/y) from the national grid, and natural gas (3,000 Nm3/hr) from the national gas network for process heating.
Environmental Compliances:
At the Indian plant, SAPL generates approximately 200 t/d wastewater, which is treated on site through both anaerobic and aerobic processes before being discharged to the surface water channel. Air emissions from the coal-based heater are scrubbed by venturi wet scrubber. The monitored parameters for wastewater effluents, air emissions, and ambient air/noise meet both local regulatory requirements and WBG guideline limits. At the Egyptian plant, SAPL will generate approximately 250 t/d wastewater, which will be treated before being discharged to the public sewer network. According to the initial analysis and modeling calculations of the draft ESIA, the wastewater effluents, air emissions, and ambient air/noise will meet both local regulatory requirements and WBG guideline limits upon successful implementation of the mitigation methods.
Solid and hazardous wastes:
The household solid wastes at both sites are picked up by municipal contractors for sanitary disposal. The major industrial solid wastes are off-spec oligomers, which are sold for other industrial usage. The used catalysts are sent back to the manufacturers for regeneration. The other limited amounts of hazardous wastes generated at the Indian site are sent to the West Bengal hazardous waste disposal center for recycling and disposal. The other limited amounts of hazardous wastes generated at the Egyptian site will be sent to the hazardous waste disposal center in Alexandria for recycling and disposal.
Operational hazard:
Some of SAPL’s raw materials are hazardous materials. The transportation, storage, and handling of these materials at the Indian plant meet local regulatory and WBG guideline requirements. As stated in the ESAP, SAPL will conduct hazard operability (HAZOP) studies after the debottle-necking works completion at the Indian site in 2008. SAPL will also conduct HAZOP for the Egyptian site during the detailed design phase.
Fire prevention and emergency response:
There is adequate fire fighting equipment onsite with proper maintenance at the Indian site. There is a clinic for both routine first aid and emergency care. SAPL has its own fire truck and firefighting team. The external fire trucks and ambulance could reach the site in five to ten minutes. Fire prevention and emergency response (ER) are included in new employee trainings and annual refreshers. SAPL conducts routine drills for fire fighting.
Greenhouse gases (GHG) and energy efficiency:
At the Indian site, SAPL generates 101,500 t/y GHG directly from onsite power plant and process heating. At the Egyptian site, according to preliminary estimates from the ESIA, SAPL will generate 47,800 t/y GHG directly for process heating and generate 19,400 t/y GHG indirectly from power purchase. After both plants are put into normal operation, both plants will generate 168,700 t/y GHG. As required in the ESAP, SAPL will conduct a comprehensive energy efficiency audit at its Indian site in 2008 as a mitigation method to increase energy efficiency and reduce GHG emission.
- Community Health, Safety, and Security
Community health, safety and security:
Both sites are located inside designated industrial zones. There are scattered houses in the Haldia industrial zone in India, while there are no residential areas at or near the Damietta industrial zone in Egypt. The qualitative risk assessment (QRA) for the Haldia site indicated, under worst case scenario (pool fire), all impact zones for significant damages are within the plant borders. The QRA for the Egyptian site is still under preparation. However, the nearest residential area from the Egyptian site is approximately three km away from the site, and this is unlikely to be impacted by the pool fire.
Emergency preparedness and response:
The raw materials and products at the Indian site are transported from and to Haldia port. The seven km transportation route does not go through residential areas. The raw materials and products at the Egyptian site are transported directly from the neighboring Damietta port. None of the SAPL’s raw materials and products is toxic. SAPL has ER plans available and conducts routine fire fighting drills for both onsite and offsite emergency. SAPL will implement similar ER system at the Egyptian site.
Security personnel:
SAPL hires external agency for plant security at the Indian site, which conducts routine ID checks at the gates plus security monitoring. The security personnel do not have any firearms. For serious security issues, SAPL reports directly to the local police station.
- Cultural Heritage
The project area at the Egyptian site is not included in or near any potential archeological sites, which are known to the Egyptian Government. However, there is always a potential to find buried antiquities in the Nile delta area. As indicated in the ESAP, SAPL will prepare a Chance Finds Procedure of potential buried antiquities for the construction works.
