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 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 and the company management are committed to achieving high environmental, social, occupational health and safety (EHS) outcomes in the project. While EHS aspects have not been managed under a structured system in the group, the company will, within a timeframe agreed with IFC, implement an EHS management system (EHSMS) certified to ISO 14001 and OHSAS 18001 standards with IFC Performance Standard requirements appropriately incorporated.
- The project though green-field is proposed on a 121 acre site located within an existing industrial area, which was developed more than a decade ago. The site for the project has been leased to the company on a 99 year lease.
- The company has carried out a social and environment assessment commensurate with the nature and scale of impacts including an Air Quality Impact Assessment (AQIA). Further, the company will, within a timeframe agreed with IFC:
- carrying out a risk assessment (with domino effects and incorporating any potential exacerbation due to earthquakes) for the proposed facilities;
- based on the outcome of the risk assessment, 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 risk assessment 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 IFC’s Performance Standards and EHS guidelines during construction.
- PS2: Labor and Working Conditions:
- Conditions of work/employment for workmen/labor are stipulated in detail under the model standing orders, which the company will adhere 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 the project site.
- The company will apply HNG’s HR policies, which are currently articulated as stand alone policies notified from time to time. However, HNG is in the process of reviewing its HR policies/practices and proposes to put in place a HR Manual delineating policies and procedures pertaining to: recruitment, selection, retirement and cessation of employment; performance management including training and development; emoluments and benefits; leave policies; resolving employees concerns; non discrimination and harassment; confidentiality; code of conduct. Conditions of employment as well as wages and benefits are communicated to employees through employment letters. HNG will review IFC’s Performance Standard 2 provisions and incorporate them in the HR policies and practices. The company will, within a timeframe agreed with IFC, implement in its operations HNG’s updated HR policies and procedures, with IFC’s PS 2 provisions incorporated. Further, the company will, within a timeframe agreed with IFC, also develop and implement procedures to ensure that EPC, construction and labor contractors engaged by the company and/or on the project site, meet national labor laws.
- The project will employ about 200 employees directly and engage about 150 contract labor (in material handling, packaging etc). The company proposes to employ trained technical professionals (diploma, engineers and management staff) as direct employees and about 25 workers. The company will, as part of the project, construct a 25 house township, to provide bachelor and family accommodation as needed to the direct employees.
- While HNGFG 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, the company will, within a timeframe agreed with IFC, implement procedures including making appropriate provisions in EPC, construction and labor contracts to ensure that the contractors engaged at the Project site adhere to applicable IFC EHS guidelines during construction and operation stage.
- PS3: Pollution prevention and abatement:
- The company has identified key environmental aspects and potential significant impacts of the project and will address these in project design. Going forward, the company will manage environmental impacts under the ISO 14001 certified EHSMS. The company is evaluating the feasibility of introducing a flue gas waste heat recovery component as part of the project and will implement a rainwater harvesting program.
- Water for the project, 1200 KLD, will be drawn from Narmada canal, pumped to site through a 1.5 km underground pipeline. The pipeline will be laid along the right of way (ROW) of existing roads and pipes. The project includes a RO plant for treating raw water, which will be used both for cooling and domestic purposes. The company will ensure that drinking water meets IFC’s EHS guidelines.
- While furnace is designed for dual fuel firing, the primary source of energy (fuel) upon commissioning will be natural gas. The project will also draw 3.8 MW electricity from the grid. Principal air emissions from the project will be particulate matter (PM), sulphur dioxide (SO2) and oxides of nitrogen (NOx), from the furnace and fugitive dust emissions from raw material handling. The project design includes provisions to control fugitive dust emissions. The project will with its present design meet host country and IFC PM and SO2 emission standards. The company will, before project commissioning implement a mitigation plan to demonstrate compliance with IFC and host country NOx emission standards.
- A broader evaluation of the project’s environmental impact takes account of the project’s effects on ambient air quality as well as emissions concentrations. In this respect, analysis shows that ambient air quality will remain within local limits. This analysis is summarized in the table attached.
- The background level of particulate matter in ambient air is already close to the Indian limits. The project will add around 0.25% to background levels. Similarly, the incremental impact on SO2 levels on account of the project will be 13% of the present variation and 2.5% of the national standards and remain well within the national ambient air quality standards. Hence, incremental impact on ambient PM and SO2 levels have not been considered material. The project’s NOx contribution to ambient air will be half the natural variations in baseline, and will increase ambient concentrations by 12.5% of Indian air quality requirements. In conclusion, the project will be fully compliant with Indian air quality requirements.
- IFC’s General EHS Guidelines describe an approach to ambient air quality impacts, in which a project’s contribution to ambient concentrations of pollutants should not take more than 25% of the pre-project “headroom” between baseline standards and air quality limits. The project meets this requirement for the three pollutants considered, and the project is therefore considered compliant with IFC’s ambient air quality requirements.
- In addition, the company will develop and implement an ambient air quality monitoring protocol to confirm the accuracy of the analysis discussed above, and will implement measures to reduce emissions should the monitoring indicate this is necessary.
- While no process effluent (excepting the recycled cooling water) will be generated from the project, 32 KLD of domestic sewage is expected to be generated. A sewage treatment plant is proposed in the project. Treated sewage will meet IFC norms and will be used on premises for irrigation.
- The company will manage hazardous and other wastes in accordance with good industry practices and IFC guidelines. In particular: the company will 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.
- The company will provide acoustic enclosures for high noise generating equipment 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 levels is not expected and at plant boundary noise level is expected to meet host country and IFC limits.
- 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 greenhouse gas emission with NG as primary fuel (including emissions on account of purchased electricity and CO2 emission from batch decomposition) is expected to be 134,000 tCO2. The furnace has been designed with attention paid to energy efficiency, and operational efficiency is expected to be indicative of worldwide good practice. Further, the company is evaluating the techno-commercial feasibility of implementing measures for flue gas waste heat recovery to enhance energy efficiency of the project, and will install such a system should it be shown to be cost-effective.
- 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 Chandrapura (1km) from the project site. The company will ensure that there is minimal impact on community environment, health and safety, during both construction and operation. 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.
- 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.
- While local labor will be used for semi-skilled and unskilled work, an influx of about 600 laborers is expected during the peak construction period. The company will ensure that appropriate amenities/facilities for labor are provided by the EPC/construction contractor 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 company will outsource security services and the security personnel may be armed. The company will, within a timeframe agreed with IFC and before start of operations, 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.
