The sponsor 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 policies and Performance Standards, and the World Bank Group (WBG)/IFC 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 documentation.
- PS1: Social and Environmental Assessment and Management Systems:
The sponsors are committed to upgrading management of environment, social, occupational health and safety (EHS) aspects associated with the operations of the company. While EHS aspects have not been managed under a structured system in the past, the company will, within a timeframe agreed with IFC:
- put in place an EHS management system (EHSMS) across all of its operations, with IFC Performance Standards, ESRS and ESAP requirements appropriately incorporated, which will be certified to ISO 14001 and OHSAS 18001 standards;
- appoint a fulltime appropriately qualified senior executive at the corporate level for oversight of EHS aspects across all of Electrotherm’s operations; and
- appoint qualified professionals as EHS managers at each of the operating locations/facilities.
In the interim, the company will, within a timeframe agreed with IFC, commission a third party environment, health and safety audit of its manufacturing facilities at Palodia and Samakhiyari. The Terms of Reference of the EHS audit will incorporate relevant provisions of IFC PS1 and IFC EHS guidelines. At both the Kutch and Palodia plants, as part of the EHS audit, the company will also undertake a benchmark monitoring of work area environment quality, including for presence of dust and heavy metals, to demonstrate compliance with IFC environmental guidelines for occupational health and safety. Further, based on the outcome/results/findings of the third party EHS audit including the benchmark work area environment monitoring, the company will develop and implement an EHS action plan (corrective action plan) to address opportunities for improvement identified in the audit. The company has carried out a Rapid Environmental Impact Assessments (REIA) for the mini blast furnace and the power plant proposed at the Samakhiyari facility; has delineated mitigation measures; and will implement appropriate mitigation measures for all identified impacts. The company will augment the REIA by:
- undertaking supplemental work, acceptable to IFC, to make the REIA consistent with IFC PS1 provisions;
- carrying out a quantitative risk assessment (with domino effects and incorporating any potential exacerbation due to earthquakes) for the existing and proposed facilities (including the risk on account of the proposed producer gas plant) at Samakhiyari;
- based on the outcome of the QRA, design the plant and provide engineering as also management measures, to ensure that the risks are contained within the plant premises, and individual as also societal risks remain within industry/international norms; and
- develop and implement a Disaster and Emergency Management Plan, with the outcome of the QRA appropriately incorporated.
Further, the company will make available to IFC relevant consents/clearances/permits and authorizations for the Project, as and when these are obtained by the company. The company will put in place, within a timeframe agreed with IFC, EHS standards for contractors, their sub-contractors as also contract/casual workers and ensure adherence to the EHS standards during construction and operation.
- PS2: Labor and Working Conditions:
Conditions of work/employment for workmen/labor are stipulated in detail under the model standing orders, which the company subscribes to. The Standing orders detail:
- classification of various categories of workmen;
- communication of terms of employment including hours of work, leaves, pay days, shifts, wages; eligible leaves, holidays and leave records;
- procedures for temporary lay-off;
- termination of employment; and
- disciplinary procedures.
The company will prominently display the Standing Orders (conditions of work), in the local language at each of its plant and project locations. The company has articulated standalone policies and procedures pertaining to:
- performance management, managerial grade structure, emoluments and benefits;
- leave policies; and
- employee welfare.
Conditions of employment as well as wages and benefits are communicated to employees through employment letters and notices. The company will, within a timeframe agreed with IFC, develop and communicate to all employees, a documented Human Resource (HR) Policy and Manual applicable to all employees, with IFC PS2 provisions appropriately incorporated. In the interim, within a timeframe agreed with IFC, the company will, develop and communicate to all employees policies and procedures, which are consistent with the provisions of IFC Performance Standard, particularly on:
- grievance redress;
- disciplinary action;
- conduct of security personnel; and
- maternity leave and benefits.
Further, the company will, within a timeframe agreed with IFC, also develop and implement procedures to ensure that the labor contractors and the company’s conversion agents/contract manufacturers meet national labor laws. While Electrotherm will, on an ongoing basis, manage occupational health and safety through the OHSAS 18001 certified EHSMS, the company will, within a timeframe agreed with IFC, put in place departmental, plant level and corporate safety committees, comprised of both worker and management representatives. Further, in the interim, the company, to upgrade the EHS status at the existing plants, will implement a corrective action plan based on the results/findings/outcome of the third party EHS audit referred to at PS1 above.
- PS3: Pollution prevention and abatement:
Electrotherm has identified key environmental aspects and potential significant impacts of the Projectand addressed these in design. Going forward, the company will manage environmental impacts under the ISO 14001 certified EHSMS. The Projectincludes a 17 MW waste heat recovery power plant and the design includes various energy efficiency measures as well. The company proposes to explore options for recycling and reuse of water so as to reduce water consumption. Further, the company will implement a companywide program to harvest rainwater. While the primary source of energy at Kutch will be the captive power plant (30 MW), about 15 MW will be drawn from the grid as well. Grid electricity is the primary source of energy at Palodia plant. Primary source of water at both locations is piped water drawn from Gujarat Water Supply and Sewerage Board grid. While the present water consumption is 135 m3/day at the Kutch facility, an additional 600 m3/day will be sourced on account of the Project. Principal air emissions are:
- particulate matter (PM), sulphur di-oxide (SO2), oxides of nitrogen (NOx), from DRI, power plant boiler and MBF stacks;
- PM emissions from crusher bag house stacks;
- PM and other fugitive emissions from fume/dust extraction system stacks; and
- fugitive emissions during construction.
The EMP details mitigation measures and the company proposes to install:
- high efficiency electrostatic precipitators (ESPs) (for DRI Kiln/ Waste Heat Recovery Boiler, Power Plant Boiler, MBF stack and MBF flare stack); and
- baghouse (for coal crusher).
In the existing facilities, the company proposes to install/has installed:
- baghouse (for existing induction furnace);
- cyclone separator and bag filter (for Mg converter, Zinc coating unit, core cleaning section and barrel grind section).
While the air emissions from ESPs will meet host country and IFC limits, emissions from baghouses and cyclone separators will exceed IFC limits. The company will, develop an action plan to implement measures to meet IFC emission limits. Further, the company will monitor air emissions at the Kutch plant, to demonstrate compliance with IFC requirements and if required, within the first year after disbursement, implement appropriate corrective measures to meet IFC requirements. The company will ensure that the refrigerant used in air conditioning system, and in fire extinguishers across all of its facilities (existing and proposed), comply with the Ozone Depleting Substances Rules set by the GOI under Montreal Protocol requirements. The project is designed to achieve an effluent rate of 60 m3/day, which is in addition to the existing effluent generation rate of 20m3/day. The company proposes to recycle treated effluent and use the balance treated effluent for irrigation on premises. The effluent treatment plant (ETP) will be designed to meet host country and IFC norms. Domestic sewage at 8 m3/day is expected to be generated under the project, in addition to the existing sewage generation of 13.5 m3/day. Domestic sewage will be disposed through septic tank and soak pit route as is presently being done in the existing plant. The company will, within a timeframe agreed with IFC, upgrade management of hazardous materials and wastes to be in accordance with good industry practices and IFC guidelines on hazardous materials management. In particular, the company will, within a timeframe to be agreed with IFC, implement a program to:
- segregate and store all hazardous material appropriately under secondary containment;
- identify all hazardous wastes generated as per host country rules on hazardous waste handling and management; - label, segregate and store all hazardous wastes under secondary containment; and
- dispose hazardous wastes through authorized entities only.
Other wastes generated are DRI bed ash, boiler bottom ash, fly ash, MBF/GCP sludge, MBF slag, steel making slag, scales from bar/rod milling operations, waste refractory material, paint sludge from paint shop and used oils/lubricants/paints. The company will dispose of the DRI bed ash in a secured land fill and consume MBF/GCP sludge as also mill scales in a sintering plant proposed under the Project. While boiler bottom ash will be land filled, the company proposes to set up a fly ash brick plant for fly ash consumption/disposal and has prepared a 10 year action plan to ensure that the entire annual fly ash generated is consumed by the end of the 10th year. MBF slag will be granulated in the cast-house granulation machine and sold to cement manufacturers. Steel making slag will be used for paving/soling in the plant area. The company will, within a timeframe agreed with IFC, implement a boiler bottom ash disposal management plan. The management plan shall define:
- appropriate selection criteria for land to be used for filling with bottom ash;
- prohibited fill and disposal areas and techniques; and
- criteria for compaction, drainage and final cover.
The company will dispose of waste refractory material through treatment, storage, disposal facility as approved by GPCB. The critical ambient considerations in the context of the proposed project are impacts due to suspended particulate matter, SO2, NOx and noise emissions. Baseline SPM and RSPM levels in ambient air is high (129 – 182 µg/m3 and 41 – 84 µg/m3 respectively). The predicted incremental impact at nearby habitation is less than 10% of present levels and the maximum impact is expected within 300 m of the source (on plant premises). The company will implement measures to ensure and demonstrate that SPM in ambient air on its premises remains below 200 µg/m3, the consented ambient air quality levels. SO2 and NOx levels in ambient air is expected to remain within host country and IFC limits at nearby habitations/sensitive receptors. However, the company will implement measures to ensure that the SO2 levels on plant premises remains below 80 µg/m3, the consented ambient air quality levels. The company will provide acoustic enclosures for high noise generating equipment like turbine, diesel generator sets, compressors and other high noise generating equipment, and also design the foundations appropriately so as to minimize vibrations and noise. Material impact on ambient noise and groundwater levels is not expected. The company will, within a timeframe to be agreed with IFC, implement a companywide program on monitoring of ambient air quality and where required, will implement appropriate mitigation measures to meet IFC limits. Ambient noise levels at plant boundary is expected to meet host country and IFC limits at the existing plants and after the proposed Project. In view of the fact that nearly 17 MW of power will be based on waste heat recovery, net 98,712 tCO2 emission is expected from the Kutch facilities. The company will, besides timely submission of annual environmental and social monitoring reports (AMRs), also submit quarterly status reports on implementation of the Environmental and Social Action Plan (ESAP), appended to this ESRS. The quarterly status reports will be continued till all action items in the ESAP have been implemented and closed out.
- PS4: Community health, safety and security:
The nearest resident community is at 1.6 km from the Kutch plant. The company will ensure that there is minimal impact on community environment, health and safety, during both construction and operation. The company has, as part of the environmental assessment, identified likely community health and safety impacts and will implement mitigation measures for the identified impacts. The company will, as part of the EHSMS, put in place procedures to mitigate risk of uncontrolled release of hazardous materials, including risk to communities from hazardous material transport. Further, the company will, within a timeframe to be agreed with IFC, prepare and implement an onsite and offsite Disaster and Emergency Management Plan, and link it to the district emergency response plan. The project is not expected to exacerbate community exposure to disease either due to changes in land/hydrologic or other terrestrial/air quality/hydrologic regimes or due to influx of large pool of migrant laborers. The company has outsourced security services and the security personnel are armed. The company will, within a timeframe agreed with IFC, develop and implement procedures for ensuring 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:
The project involved acquisition of 182 acres of land adjoining the 67 acres of land on which the existing DRI/steel and DI plant is located. Land was acquired from 18 households belonging to villages Chhadwada and Samakhiyari in Kutch District of Gujarat. The land acquisition was completed on a willing buyer-willing seller basis in October 2006 and involved no involuntary resettlement. The capacity expansion at Palodia and in the electric vehicles facility is proposed on existing plant premises and no land acquisition is proposed. The price paid for the acquired land was at least 25% above the average price of non project related sale/purchase of land in the vicinity of the proposed plant sites. The prices were arrived at based on negotiated settlement after consultations with the farmers. The company will put in place a grievance redress mechanism to receive and respond to grievances pertaining to land acquisition.
