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:
GSPL’s management proactively addresses environmental, social, occupational health and safety (HSE) aspects associated with its operations. The company’s HSE policy focuses on promoting sustainable development, communication with all stakeholders and to be a responsible corporate citizen. The company has a documented HSE management system in place. The company’s HSE management system (HSEMS) includes procedures for:
- aspect and impact identification;
- compliance with legal and other requirements;
- setting out - system and HSE performance improvement objectives;
- development and implementation of management programs;
- structure and responsibilities;
- training, awareness, communication and co-ordination;
- documentation;
- operational control;
- emergency preparedness and response;
- internal and external audits;
- internal reporting and external communication;
- HSE management for contractors; and
- management review.
The HSE management system is well implemented on the ground. The company will embed IFC Performance Standards in its HSE management system and will obtain ISO 14001 and OHSAS 18001 certification for its HSEMS by December 2009.
The criteria used by GSPL in pipeline route planning include:
- avoidance of wildlife sanctuaries, national parks, reserved forests, breeding grounds and archaeological monuments;
- avoidance of mining, defense establishments and other sensitive areas;
- safety of people, environment and property;
- avoidance of planned development zones and non agricultural land with development potential;
- minimization of rocky, marshy and cultivated areas;
- favorable ground profile and hydraulic gradients;
- minimization of rail, river, stream, road and canal crossings;
- availability of infrastructure facilities like land, electric power and water for intermediate stations;
- availability of easy access to the route for pipe laying, construction, operation and maintenance; and
- shortest possible length.
Further, to minimize risk for resident communities and structures, route planning for trunk lines ensures a minimum distance of:
- 100 m from habitable dwellings;
- 50 m from structures, monuments, property corners, existing/planned electrical lines; and
- 15 m from existing/planned pipelines.
While trunk lines are laid in relatively low population density rural areas, spur lines and feeder lines for bulk consumers, which typically operate at lower pressure, are required to be laid in peri-urban and urban areas at times, with appropriate safeguards like increased pipe thickness and lesser distance between SV stations. In such cases, the pipelines are routed along the existing Right of Way (ROW) of roads and streets.
GSPL 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 in the HSEMS. GSPL will ensure that ESAs undertaken for future projects including ongoing management of HSE aspects are consistent with the provisions of IFC’s Performance Standards. The HSE impact management and mitigation plans (EMP) based on ESA 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 Phase II segments and has applied for Gujarat Pollution Control Board (GPCB) and MoEF clearance for balance of the project (Phase III and loop line). The company will make available to IFC, copies of all regulatory clearances as and when these are obtained by the company.
The company, in addition to the ESA, undertakes a rapid risk assessment (RRA) for each project, including for worst case and maximum credible loss scenarios. GSPL, based on the findings of the RRA and in accordance with host country as also industry best practice norms, implements a risk mitigation plan, which includes:
- minimum cover of 1.0 – 1.5 m for all pipelines;
- pipeline wall thickness specified according to the location class;
- minimum distance of 100 m from habitable dwellings, 50 m from structures, monuments, property corners, existing/planned electrical lines and 15 m from existing/planned pipelines;
- three layered poly-ethylene coated pipe;
- cathodic protection for corrosion prevention;
- hydrostatic testing of all pipelines post-construction;
- sectionalizing valves at intervals of 32, 24 and 16 kms for class I, II and III locations respectively;
- cathodic protection linked to the SCADA system;
- periodic surveys to ensure adequacy of cathodic protection systems;
- SCADA based leak detection system;
- intelligent pigging every 5 years;
- preventive maintenance program;
- pipeline marker signs along the alignment with emergency contact number prominently displayed;
- smoke detectors in control rooms;
- ambient gas detectors linked to SCADA system at sectionalizing valve stations and other over-ground installations;
- audible alarms linked to ambient gas detectors, to alert local community, at all SV stations, metering stations and MCS; and
- physical patrolling of pipeline route including walk throughs and aerial surveys.
Based on the outcome of the RRA, the company prepares an appropriate Emergency Response Plan (implemented at MCS level) and a Crisis Management Plan (implemented at Corporate Level). The company is in the process of linking these Emergency Response Plans to the district and state disaster and emergency response plans. Further, GSPL will, for all critical locations along the project pipeline routes ensure that individual and societal risks remain within industry best practice norms.
While GSPL transports gas from:
- GSPC – Niko gas field;
- Petronet LNG terminal; and
- Shell LNG Terminal.
These have not been considered associated facilities as the viability and existence of these gas sources does not exclusively depend on the project. While Petronet LNG’s terminal is also connected to Gas Authority of India (GAIL) gas grid (GAIL has capacity to offtake the entire RLNG produced by the terminal), GSPC-Niko as also Shell LNG terminal gas is consumed entirely by consumers on the existing pipeline. Downstream associated facilities would include bulk consumers including gas distribution companies proposing to offtake gas from GSPL’s proposed pipelines and whose viability and existence would depend exclusively on the project. GSPL will, going forward and in accordance with IFC’s Performance Standards, implement procedures to:
- identify both upstream (gas sources) and downstream (bulk consumers including distribution companies) associated facilities;
- make available IFC’s Performance Standards to owners/operators of such associated facilities; and
- make reasonable efforts to encourage owners/operators of such associated facilities such that they: undertake ESAs for the facilities that are consistent with IFC Performance Standard requirements; and construct, operate and maintain their facilities as per IFC Performance Standards and WBG/IFC HSE guidelines.
GSPL has employed in-house fulltime qualified professionals both at corporate and operations levels, for oversight of HSE aspects across all of the company’s operations. The company’s HSE organization includes:
- a corporate head with oversight responsibilities for all projects, operations and maintenance of pipelines and facilities;
- qualified HSE officers at each base station for day to day management of HSE aspects including oversight of implementation the HSEMS; and
- ROU officers for each proposed pipeline, who engage with landowners from whom ROU is proposed to be/has been acquired.
The HSE organization, besides management of HSE aspects during operation, also ensures that the project/EPC contractor meets GSPL’s HSE requirements during construction. GSPL’s HSE requirements are clearly communicated to the project/EPC contractors and are included in the contract documents. The project/EPC contractors are also required to appoint qualified HSE professional to oversee HSE aspects during laying of pipelines. Further, the company will undertake an annual third party HSE audit of the pipeline and facilities for the first three years to obtain an opinion on the HSE status.
- PS2: Labor and Working Conditions:
GSPL is in the process of preparing its Human Resource (HR) Policy and Manual. The company will review IFC’s Performance Standard 2 and incorporate its provisions into its HR Policy and Manual, which is under preparation. GSPL is currently managing HR and labor working conditions as per GSPC’s HR policies and procedures. GSPC’s HR manual covers:
- employee grade structure and procedures pertaining to their appointment, probation, confirmation and reversion;
- recruitment, selection and training procedures;
- performance management, career development, increment and promotions;
- employee welfare;
- maintenance of service book and service records;
- procedures for cessation of employment, resignation/separation, discharge, termination, retrenchment and superannuation;
- terms of employment including hours of work, shifts, emolument and benefits;
- eligible leaves and holidays;
- grievance redress; and
- standard of conduct, misconduct and disciplinary procedures.
Conditions of employment as well as wages and benefits are communicated to employees through employment letters and notices. GSPC’s HR policies and procedures are consistent with the provisions of IFC’s PS2 provisions. The company has procedures in place to ensure that contractors meet national labor laws.
Occupational health and safety forms an integral part of GSPL’s corporate culture. The company will evaluate the possibility of embedding it in the employee performance management system. Further, GSPL has processes in place to ensure that outcome of risk assessment informs project 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.
- PS3: Pollution prevention and abatement:
The company’s HSEMS requires adherence to host country environment management, pollution prevention and control requirements. GSPL will also incorporate, in its HSEMS, all applicable World Bank Group/IFC pollution prevention and abatement requirements. While the primary source of energy at GSPL’s installations is grid electricity, diesel generator (DG) sets are provided for backup power. The principal point source of air emissions are the stacks attached to the DG sets. GSPL will ensure that DG set emissions (though these are for standby operation only) meet WBG/IFC norms. On account of the project, no material long term increment in ground level concentration of SPM, RPM, SO2 and NOx as also noise levels is expected. The company will provide acoustic enclosure for DG sets as per host country regulations. The company will ensure that the refrigerant used in air conditioning system as also the fire extinguishers gases, comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements. 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 during operation and there is a maximum short term demand of 50 m3/day expected at each construction section. No material impact is anticipated on account of increased water consumption due to the project. The company will ensure reuse of water used for hydrostatic testing, to reduce fresh water withdrawal. The company will ensure that drinking water complies with GoI standards.
There is no process waste water generation. Domestic waste water generated at MCS/SV stations, will be discharged through septic tank and soak pit route. 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 surface water bodies or on land.
Hazardous wastes generated on the company’s MCS/SV station premises include minor quantities of spent oils and filter. The company uses nickel – cadmium batteries for back-up power. 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.
To prevent loss of top soil during construction as also to prevent sedimentation of surface water bodies, GSPL implements erosion control measures including among other measures:
- slope stabilization (rip/rap);
- avoidance of excavation during monsoon/rainy season; trench water discharge in a manner to avoid sedimentation of water bodies and wetlands;
- provision of water bars;
- controlled discharge of hydrostatic testing water;
- early revegetation after pipe laying;
- segregation and separate stockpiling of top soil on the non traffic side of the ROU; and
- spreading back of the topsoil after pipe laying.
Rocks and other construction waste are disposed off at pre-selected sites or reused in slope stabilization or stream banks; or construction of access roads.
GSPL’s makes available natural gas/RLNG for consumption, which results in GHG reduction through replacement of fuels with higher GHG intensity. The company will, under its HSEMS, implement procedures 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, laying of pipelines, infrastructure and in selection of equipment. The company will plan the alignment of pipelines in a manner to ensure that no resident communities lie within 150 m of over-ground sections. Further, GSPL will for all communities resident within 500 m of underground sections and within 1000 m of over-ground sections:
- develop a community emergency response plan;
- communicate the community emergency response plan to the said communities;
- link the community emergency response plan to district and state emergency response plan;
- undertake periodic onsite and offsite training, mock drills and community awareness programs including with participation of the said resident communities; and
- ensure that individual and societal risks remain within international criteria and best practice norms.
GSPL will ensure that EPC/project contractor adopt good HSE practices during construction and in particular ensure that its employees and EPC contractors:
- 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;
- restrict night time activities to low noise generating activities;
- use construction equipment with appropriate noise mufflers/provision for attenuation of noise; 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 contractors 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, GSPL 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.
GSPL’s above ground facilities (MCS, metering station and SV stations) are guarded by armed security personnel sourced from reputed security service providers. GSPL will, review IFC’s Performance Standard 4 (PS4) provisions on security personnel related aspects, and update the security procedure to ensure that:
- past records of security personnel employed is screened;
- security personnel have clear objectives and permissible actions laid out;
- security personnel are trained in avoidance of human rights violations, use of fire arms and handling various situations with clear procedures;
- security incidents are recorded, investigated and corrective action implemented;
- bonafide complaints against security personnel are investigated/disciplinary actions implemented; and
- there is a grievance mechanism for aggrieved members of community or employees, in the event of a violation of the code for security personnel.
- PS5: Land Acquisition and Involuntary Resettlement (no land acquisition involved but acquisition of Right of Use in land involved):
GSPL, for laying, operation and maintenance of pipelines, acquires right of use (ROU) from land owners, on a 20 m wide strip of land along the pipeline route alignment. All GSPL pipelines are buried (with a soil cover of 1 – 1.5 m) except for short over-ground portions at MCS, metering stations and SV stations. In acquisition of ROU, GSPL adheres to host country requirements - Gujarat Water and Gas Pipelines (Acquisition of Right of User in Land) Act, 2000 (GW&G Act) for ROU acquisition in the state of Gujarat as also Petroleum and Mineral Pipelines (Acquisition of Right of User in Land) Act, 1962 (PMP Act) for acquisition of ROU in Gujarat and elsewhere in India. The ROU is acquired by the government as per the provisions of the above acts and vested in the company, through a notification in the official gazette.
In ROU acquisition, while ownership of land vests with the land owner, the land owners forgo the right to:
- build permanent structures anywhere within the ROU;
- construct or excavate tanks, wells/borewells, reservoir within the ROU;
- plant trees within the ROU; and
- undertake any activity within the ROU, which may cause damage to the pipeline.
Where the land is used for agriculture, the land owners may continue to cultivate the land after the pipeline is laid. However, where the land is used for tree plantations (fruiting or of timber variety), the land owners forgo the right to continue plantation activities within the ROU. For cases where ROU is acquired through tree plantations, GSPL, to enhance livelihood of plantation land owners, allows alternate and acceptable cropping opportunities on land that falls within the ROU. Further, the company acquires land, on a willing seller - buyer basis, for setting up of MCS, metering stations and SV stations.
GSPL, in accordance with host country laws, provides compensation to land owners, at 10% of market value, for the ROU acquisition.
The criteria used to arrive at market value of land includes:
- last five year land sales/transaction statistics as per records;
- market value determined by the government for the purpose of fixing stamp duties for land transactions;
- market value of land as cited by prominent persons from the respective villages;
- recent compensation awards for similar land and for similar purpose, in the vicinity of the land where ROU is to be acquired, where applicable;
- market value of government wasteland fixed by government agencies, where applicable; and
- recent willing seller-buyer price that the company has paid for acquiring land (if nearby), for setting up SV station or MCS, where applicable.
The compensation for damage to crops during construction is arrived at by a committee of horticulture experts set up by the company. The Committee determines the compensation to be paid based on the:
- crop yield; and
- recent market price of the produce in organized whole sale markets like Agricultural Produce Market Committee (APMC).
In case of loss sustained on account of felling of fruiting trees in the ROU, the horticultural committee has developed, for each of the species encountered in the region, a compensation framework based on:
- balance productive life of the tree;
- the expected fruit yield during the balance life;
- price obtainable for the fruits based on recent prevailing prices in organized wholesale markets;
- total obtainable timber from the tree over its productive life;
- price obtainable for the timber; and
- cost incurred by the tree owner, which is deducted from the compensation paid.
In case of trees with only timber yield also, the horticulture committee has prepared a framework similar to the above excluding any potential revenues from fruits. Though the company provides compensation for timber (from both fruiting and non fruiting trees), it also allows land owners to take away the timber, after the tree is felled.
While the company has processes in place to ensure that the pipeline routing avoids any structures, there are instances where during land survey, structures are encountered within the ROU. In such cases as well, the company makes reasonable efforts to locally realign the pipeline to avoid such structures. In cases where local realignment to avoid structures is not possible, the company appoints a third party to value the structure and compensates owners of the structure based on the valuation submitted by the third party. While such incidences are few, the company will, develop a procedure to ensure that the third party values the structure at replacement cost, and that the relocation of the occupants, if any, meets the provisions of IFC’s PS5.
While ROU acquisition notification and compensation award framework are finalized in advance of the pipeline laying work, actual payment of compensation is undertaken at the time of pipeline laying. The compensation award amount for each land owner is determined prior to commencement of work on the land owners land; noted on a panchcase (document detailing the actual compensation to be paid for ROU, crops, structures and trees); and a sign off is obtained on the panchcase including those of the land owner, the company’s ROU official, the ROU field staff deployed by a ROU consultant whom the company engages to manage the filed work involved in the ROU process and the local revenue inspector. The work of laying the pipe commences soon after signing of the panchcase for a 5 km stretch/section at a time. The company works with the local government and typically endeavors to complete compensation payment for each 5 Km section, within the construction period for the section i.e. within two months of commencement of work at each section. Compensation distribution date is notified to each land owner and receipt of compensation paid is obtained. Compensation payment is by cheque only in the presence of local revenue officials and the Sarpanch (head of the elected local self government institution – village panchayat). Minutes of compensation payment is prepared. The company will implement procedures, in accordance with IFC’s PS5 provisions, to ensure that in the event households and structures have to be relocated, the due compensation is paid sufficiently in advance to the affected households and will also facilitate the relocation process.
In urban and peri-urban areas, the pipeline is laid in the existing ROW of roads and streets. No ROU is acquired from land owners. However, in the event ROU is to be acquired in urban and peri-urban areas, GSPL will, in accordance with IFC PS 5 provisions, provide compensation to land owners to make up the losses incurred at replacement cost. The company has procedures to provide compensation for losses incurred by land owners during operation and maintenance of the pipeline. Further, the company will review and incorporate the provisions of IFC’s Performance Standard 5 (PS5) in its ROU acquisition policy and procedures.
The company requires the EPC/project contractors to restore the land after pipe laying work is completed. The company’s ROU officials inspect the land restoration work carried out by the contractor. The company has procedures in place to ensure that any additional damage to crop, trees or structures outside the ROU is compensated by the Contractor. In such instances, where complaints are received by the company’s ROU officials/filed staff deployed by the company’s ROU consultants, an additional panchcase is prepared, with the land owner, for the identified damage and the company requires the contractor to compensate the land owner for the damage. In the event of a dispute pertaining to additional damage, the company has procedures whereby:
- a corporate compensation committee visits the site to assess the damage and the compensation that is due; and
- the company pays the compensation to the land owner and settles such compensation against claims submitted by the contractor.
- PS6: Biodiversity Conservation and Sustainable Natural Resource Management:
GSPL develops its projects to protect and conserve biodiversity and to promote sustainability. The company plans the pipeline alignment to avoid:
- protected areas including wildlife sanctuary, national parks, reserved forests, breeding grounds of key species and archaeological monuments; and
- to minimize river, stream and canal crossings.
The company develops and implements mitigation plans to minimize impacts due to:
- hydrostatic testing including for drawal and discharge of water from/to streams;
- laying of pipeline across rivers, streams and wetlands with aquatic or other fauna;
- laying of pipe in breeding areas;
- blasting activities in the vicinity of sensitive areas; and
- through forest/protected areas.
The company will, where the pipeline is routed through protected areas and forests, develop and implement mitigation plans, in accordance with IFC PS6 provisions, to ensure that critical habitat are not disturbed and any habitat fragmentation is appropriately mitigated. The company will plant 10 trees for every tree felled on account of the project through a social forestry program, in consultation with and participation of local population, civil society organizations and forest department. Further, the company will undertake compensatory afforestation, in consultation with the local forest department.
- PS7: Indigenous Peoples (IPs):
The company, in accordance with host country requirements, is required to assess if indigenous peoples (scheduled tribes as per Indian legislation), are likely to be affected on account of the project. While the project is not expected to materially transform, degrade or impact lands and resources on which indigenous peoples are dependant, the company needs to implement procedures to identify and mitigate all identified impacts on IPs. The company will embed provisions of IFC’s Performance Standard 7 in its ESA process and develop procedures to identify and mitigate, where relevant and applicable, impacts on IPs due to the project.
- PS8: Cultural Heritage:
The company has procedures in place to avoid, during pipeline route planning, monuments and structures of archeological importance. While the mitigation plan addresses chance finds, the company will, in accordance with PS8 provisions, develop and implement a chance find procedure in its HSEMS including for finds of archaeological (prehistoric), paleontological, historical, cultural, artistic, and religious values, as well as unique natural environmental features that embody cultural values, such as sacred groves.
