Key environmental and social issues relating to the project are summarized below along with specific information on how potential impacts will be addressed by Cairn. Upon implementation of the mitigation measures described below and in the attached Action Plan, the project will comply with environmental and social requirements, namely the laws and regulations of India, IFC’s Performance Standards on Social and Environmental Sustainability and applicable IFC environment, health, and safety guidelines.
Performance Standard 1: Social and Environmental Assessment and Management Systems
Organizational Capacity to Manage and Implement the Management System
Cairn has developed and adopted a Health, Safety and Environment (HSE), Security and Corporate Social Responsibility (CSR) Policies, Guiding Principles and a HSE, Security and CSR Management System (HSEMS). Cairn has also explicitly stated in these documents that the Company will commit to implement IFC’s Performance Standards. The HSEMS provides the company’s HSE manager and staff with procedures to implement the HSE planning and provides a performance target setting process which includes:
Establishing strategic HSE objectives which are made available to concerned stakeholders;
Setting specific annual HSE objectives that support the longer term objectives;
Establishing annual HSE plans to meet these objectives;
Implementing the HSE plans;
Monitoring the progress of HSE plans; and
Reviewing the process and providing feedback.
The Cairn’s Policies and Guiding Principles include the following commitments:
Cairn’s HSE Policy declares the company’s commitment to the protection of its employees, stakeholders, and the health and sustainability of the environment in all of their activities. Cairn believes strongly in establishing controls for all personnel involved in their activities to protect the human and natural environment. Health and safety awareness and training programs are a key requirement for all employees and contractors.
Cairn’s CSR Policy declares the company’s commitment to respect the rule of law, implement management systems and strive to operate its businesses honestly and with integrity, respecting the rights and dignity of all employees as well as the different cultures and rights of individuals and indigenous peoples, and contributing to community development.
Cairn’s Guiding Principles, which were revised in June 2006, specifically commits the company to strive to meet key international standards (specifically the Universal Declaration of Human Rights [UDHR] and Voluntary Principles on Security and Human Rights), to conduct all activities in accordance with IFC Performance Standards and guidelines and to not conduct exploration or production operations in World Heritage Sites (as designated by the United Nation Educational, Scientific and Cultural Organization (UNESCO)) or environmentally sensitive areas (as assessed by Cairn, in collaboration with the relevant host governments).
Cairn’s philosophy is anchored on the principle that its greatest strength is the quality and commitment of its employees, consultants and contractors. The Guiding Principles define Cairn’s approach towards employees, including a policy on equality of opportunity, for fostering a positive working environment which respects an individual’s personal dignity and freedom from discrimination. It also commits the company to not employing forced, bonded or child labor and recognizes that all employees have the right to freedom of assembly, association and collective bargaining. All human resource policies in Cairn are in compliance with the law of the land
In furtherance of the above policies and systems, Cairn has an established Corporate Framework Public Consultation and Disclosure Plan (PCDP) which governs its communications programs and on-going stakeholder engagement for each of its areas of operations in India. The Corporate Framework PCDP describes the approach to inform and consult stakeholders affected by Cairn’s projects in compliance with the company’s policies, local and Indian national regulatory requirements and IFC’s Performance Standards. More detailed PCDP’s have been prepared (and will be prepared for future projects as required) to address the specific circumstances and requirements of each key project in India. Separate more detailed PCDP’s for Cairn’s activities in Andhra Pradesh, Rajasthan and Gujarat have been in place since 2006. The Corporate Framework PCDP has recently been updated to reflect consultation approaches to be taken with respect to linear pipeline projects, and the more detailed PCDPs for the Group’s operations in Rajasthan and Gujarat have been expanded to address consultation and engagement with stakeholders affected by the pipeline and its upstream and associated above ground facilities. Important components of the PCDPs include mechanisms to address any grievances and to monitor and evaluate the public consultation process. The local level and site specific PCDP’s are ‘living documents’ which are reviewed and updated regularly to record the consultation process, outcomes and lessons learned and to ensure that plans for on-going consultation are current and effective.
Similarly, the Cairn has an established Corporate Framework Land Acquisition and Compensation Plan (LACP) which outlines the principles, guidelines and approaches to be followed in acquiring land or right -of-user (ROU) for any of Cairn’s operations in India. The Corporate Framework LACP provides guidance on mitigation and compensation for any land acquisition, right-of-use, resettlement or economic displacement of households in accordance with Indian national regulatory requirements and IFC’s Performance Standards. More detailed LACPs have been prepared (and will be prepared for future projects as required) to address the specific requirements for each State where there is a need for land acquisition or ROU for Cairn’s operations. Further details of the land acquisition and right-of-user process in Rajasthan and Gujarat are provided under Performance Standard 5: Land Acquisition and Involuntary Resettlement of this document.
Environmental and Social Impact Assessment (ESIA)
The ESIA for the hydrocarbon development in RJ-ON-90/1 block in Barmer, Rajasthan was completed in December 2004. Additionally, Cairn has prepared an Environmental Baseline for air and noise and an ecological and environmental assessment in the area of the block. These documents were utilized for the development of the ESIA. A Social Baseline Study was also completed in September 2004.
Cairn prepared as part of the ESIA, a risk assessment for the oil and gas field development in Rajasthan. The assessment used the Maximum Credible Accident (MCA) analysis to quantify the likelihood of accidents occurring, and for determining the appropriate contingency plans, including the procedures for the development of a Disaster Management Plan.
Cairn conducted appropriate consultation meetings with communities and presented the ESIA and supporting documents to the Environmental Authorities in Rajasthan State and to the Ministry of Environment & Forest (MoEF). The Environmental Clearance for the project was granted by the MoEF in March 2006 and the Consent to Establish (CTE) was granted by the Rajasthan State Pollution control Board in April 2007. The Rajasthan block presently covers an area of approximately 3467 km2. The ESIA covered the entire area and used baseline data collected during a three month period from March 2004 to May 2004 (considered summer months –pre-monsoon) and in addition used data collected by other Indian agencies.
The ESIA for the proposed oil evacuation pipeline with associated facilities from the Mangala Terminal in Barmer, Rajasthan to Salaya terminal, in Gujarat was completed in September 2007. A Hazard and Operability Study (HAZOP), and Hazard Identification Study were also prepared for the pipeline. Cairn India has presented a copy of the final ESIA and Environmental Management Plan (EMP) to the MoEF as part of the environmental clearance process for the project. A technical assessment of the project by the Expert Appraisal Committee of MoEF has been completed and Cairn is currently waiting for the issuance of the Environmental Clearance.
Cairn prepared a Conceptual Design Study for the Preliminary Route Selection for the Oil Export Pipeline. This study identified four possible routes for the pipeline. From these four, the Mangala (Barmer District, Rajasthan) – Salaya (Jamnagar District, Gujarat) or 3B with a total length of 531 km was selected. In 2007, Cairn determined that additional refinement for the selected route could improve the number of special features, such as pipeline bends, and avoidance of environmentally sensitive areas and more densely populated areas. Thus a refinement of the selected route was performed through a desk review and field reconnaissance. During the field reconnaissance additional specific areas that needed to be avoided were encountered. These included micro re-routings to avoid settlement areas, dwellings, areas of steep slopes, sand dunes in desert areas and to minimize road crossings. The selected route was then further refined to avoid these areas and the final pipeline length increased to approximately 600 km.
Management Program
Cairn has developed and implemented a Health, Safety and Environment (HSE), Security and Corporate Social Responsibility (CSR) Policies, Guiding Principles and a HSE, Security and CSR Management System (HSEMS). Based on the guiding principles and commitments of the Company, specific HSE plans for the oil and gas field development, Barmer to Salaya Pipeline and contractors have been prepared for the construction and operation of the project.
As part of the HSE implementation, Cairn has established milestones with respect to HSE and CSR. The transition from construction phase to operation phase will also be assessed by Cairn, and appropriate operation phase management plans will be developed to address this new working phase.
A Management of Change (MoC) is in place and this defines the arrangements necessary to identify and control the HSE impacts of all changes in development activities, operational activities or organizational arrangements. The MoC is a dynamic document and consultation with the Project and Operations groups and with the concerned functional groups will be an ongoing process.
A register is maintained to identify and track regulatory clearances and submissions required for the development project. Periodic Independent external audits will be conducted to assure conformance of the development project with Indian Legislations, IFC’s Performance Standards, Action Plan and Environmental Management Plans.
Cairn has also developed as part of its management system a procedure for managing “CR during Gated Procedures”. The purpose of the gated procedure is to ensure that Corporate Responsibility (CR) risks are assessed and managed throughout the lifecycle of a project in a structured and consistent manner. It defines gates at which appointed Gatekeepers undertake specific review activities, recommend approval (or otherwise) to progress to the next stage of the process, and, where appropriate, define conditions that must be fulfilled prior to or during the next stage of the process. Cairn’s Gated Procedure involves a six stage process which includes: (i) assess, (ii) select, (iii) define, (iv) sanction, (v) construct, and (vi) operate. Specific deliverables will be developed for each stage.
Training
As part of its HSE and CSR management system, Cairn will provide training to its employees on all aspects of environment, health and safety and corporate social responsibility, and will ensure that all contractors receive and are aware of Cairn’s management system. The Cairn India Corporate Responsibility (CR) Management System provides a framework for how HSE risks are managed in Cairn’s business activities. HSE competence and training are integral parts of the process to ensure appropriate levels of HSE performance in Cairn and to minimize risk. Line and functional Managers are provided training and familiarization on procedures and guidance to ensure fit-for-purpose standards of competence and training. Such competence is attained through identification of HSE requirements, commencing from recruitment / selection / placement for the role, and continuing during on-going assessment of individual HSE competence and behavioral skills to verify individual performance against defined criteria, training to ensure and enhance technical and management competency standards to meet the assigned role, and measuring and monitoring of competence to identify and correct gaps in training and personnel competence.
Contractor Management Plan
Each contractor will have a Health, Safety, Environment & Security (HSE & S) Plan that will ensure the contractor’s commitment to the Cairn HSE Policy during the design, construction and commissioning of the Barmer to Salaya oil evacuation pipeline (BSPL) project. The Contractor Management Plan will describe the method of planning and implementation of all BSPL project work, in compliance to the HSE regulations in force, Cairn HSE procedures and in compliance with the conditions stated in the environmental and safety permits issued for the project. The contractor’s Plan shall address the relationship between HSE & S management policy & procedures and equipment and be under continual review over the project period. The contractor HSES plan shall be approved by Cairn.
The Contractor Management Plan shall have adequate controls by way of supervision and inspection to ensure adherence of all statutory requirements pertaining to the activities carried out by its employees and sub-contractors. The controls and arrangement within the HSE management system will provide a structure to ensure that risks, to personnel, equipment and the environment are kept as low as is reasonably practical (ALARP)
Cairn has developed and implemented a strategy to ensure that the BSPL project is delivered in compliance with the company HSE Standards and procedures. The key features of the strategy are:
Project management and supervision will be vetted to ensure their experience and competence in HSE & S management
The HSE & S plan will be documented and communicated through effective and appropriate means to all personnel and implemented accordingly
The contractor will nominate dedicated HSE personnel to supervise contractor and sub-contractor activities. The key HSE & s indicators will be recorded and reported as part of the monthly HSE reporting. Cairn HSE staff will carry out periodic audits / inspections of contractor activities and any gaps or deficiencies in the HSE management system / areas of improvement will be identified and preventive and corrective action plans implemented.
The contractor, sub-contractor and their suppliers will implement a comprehensive transport management plan wherein the contractor will be responsible for road transport safety management within their sphere of activities related to the project. A road transport policy directive and journey management Plan (JMP) will be an integral part of the Contractor transport management plan.
A Permit to Work (PTW) system will be implemented as required based on the Job safety analysis of activities and risk assessment. Personnel involved in the administration and operation of the PTW system will receive training and information as appropriate to the responsibilities and duties as set out in the PTW procedures. Supervisors will ensure that pre-job inspection of work sites will be undertaken and that a Task Risk Assessment will be carried out prior to work commencement.
The contractor will ensure that the JSA / Risk Assessments are carried out to identify all the hazards and risk associated in the work for the project and that information is communicated to the staff responsible to carry out the work.
The contractor will manage the liquid and solid wastes generated during the construction phase in compliance with regulatory requirements and will implement a strategy and procedure to minimize waste generation, waste recycling and safe disposal.
The contractor will ensure that all accidents, incidents and near miss are reported to the Cairn project team in accordance with the applicable reporting procedure.
Vulnerable Groups
As part of Cairn’s HSE and CSR management system, there is provision to ensure that potential risks and impacts to vulnerable groups are assessed, avoided where possible and that appropriate mitigation measures are applied, including measures to enable vulnerable or disadvantaged individuals and groups to benefit from project opportunities equally with the rest of the affected community.
Members of scheduled castes and scheduled tribes constitute a minority (in the range 7-22%) within communities situated along the pipeline route. Members of scheduled castes and tribes live amongst other members of mainstream society; are not isolated or disconnected from larger socio-economic structures of the area, and do not have separate ancestral territories or settlements. As such they do not meet the key characteristics of indigenous people as defined in IFC’s Performance Standard 7. However, cognizance has been taken of the socio-economic circumstances of members of scheduled castes and tribes in identifying vulnerable groups, assessing impacts and in planning appropriate mitigation measures.
Community Engagement
Stakeholder identification and consultation has an important role to play in managing the Group’s business relationships at both corporate and local levels. Cairn India Group Public Consultation and Disclosure Plan (PCDP) outlines the Group’s initiatives to inform and consult those people affected by the Group’s projects in India in compliance with the Group’s policies, local regulatory requirements and IFC’s Performance Standards on Social and Environmental Sustainability. These consultations form the basis on which on-going community engagements are planned, developed and implemented. Wherever possible, the company seeks to engage with representative bodies of those affected by their operations. There is provision to establish a grievance mechanism or procedure in order to receive and address the affected households / communities’ concerns or grievances due to project related impacts. The grievance mechanism is designed to be easily accessible to all segments of affected households / communities and at no cost, and without impeding access to other statutory processes or other remedies.
There are existing ongoing Rajasthan Joint Venture (JV) initiatives and activities focused on community development in the project areas through consultation with the community at large, panchayat members, implementing NGOs and the District Administration. The Rajasthan JV has held direct consultations with affected community members and the Panchayati Raj institutions such as the Zila Parishad and the village Panchayats. A very significant part of the consultation process with directly affected households takes place during regular interactions between the Rajasthan JV officials and individual land owners and concerned village and revenue officials during the temporary land lease and permanent land acquisition process. Extensive interactions are also held on a regular basis with land owners / farmers during on-going surveys, project construction and other activities. Consultations are held both on an individual and organized collective basis, and representatives from the District Administration take part in the consultation process.
The Rajasthan JV supports various existing community development projects in Rajasthan block through local NGOs, international voluntary organizations, the District Administration and the village panchayats. The community development programs are conceptualized and designed in consultation with key stakeholders especially, the District Administration, community leaders, prominent local NGOs, and the Zila Parishad. Discussions with the village committees aid in identifying and prioritizing community development programs, beneficiaries, implementation methodologies, key project milestones, etc. Most of the community development programs are executed by employing people from the local community. Some of the major community development initiatives carried out by the Rajasthan JV in the Rajasthan block include:
Local infrastructure development (rural school renovation and improvement, construction of rainwater harvesting structures, support for improving district water supply systems)
Community health support (health diagnostic camps, blindness alleviation program, equipment provision to differently-abled people, donation of ambulance, supply of anti-snake venom and anti-rabies vaccines, strengthening of community health services)
Animal Health Support (donation of mobile ambulance for veterinary care, animal health camps)
Public welfare programs such as computerization of government offices, provision of drinking water facilities in public areas, grant for medical assistance and educational scholarship to needy and deserving individuals)
Improving education standards in rural school (refurbishment of schools, donation of books, computer, sponsoring ‘Theatre in Education’ program, teaching aids and kits)
Sports and cultural activities / programs (National Day celebrations, inter-school sports competition, support to Thar Mahotsav)
Support for establishing livelihood creation and income enhancing activities in the traditional sector of dairy development as well as small and medium enterprise development and skills development of local communities
Cairn in partnership with IFC is also currently supporting programs for socio-economic development of local communities in the Rajasthan block under an IFC- Cairn Linkage Program.
Program components include:
Establishing an Enterprise Centre to promote local economic development
Rural Dairy Development
Child and Maternal Health Awareness Initiative
Monitoring and Reporting
Cairn’s procedures for HSE include monitoring as an integral part of the project development. Cairn will have personnel monitoring HSE aspects during the construction and operation phase to ensure compliance with the management plans, HSE management system, and GoI regulations and requirements.
The Environment Management Program (EMP) will be monitored as per the monitoring and measurement plan, as part of the project operation manual. External and internal audits will be carried out to assess compliance; the results from the external audits will be presented to the concerned functional and operational group, and corrective and preventive action where required will be implemented in a time bound manner. Regulatory compliance reports as per the statutory requirements will be prepared and communicated to the environmental authorities.
During the ESIA process a monitoring program with timeframes was developed by Cairn. In addition, Cairn is required under its procedures to present an Annual HSE Assurance Letter to its Board of Directors. The aim is to obtain a “snapshot-in-time” perception of HSE performance of the project from key Line Managers. The information provided will be consolidated to identify both those areas where progress has been made and those areas of weaknesses that still need to be addressed. The findings will then be circulated for subsequent HSE work plans and programs.
Performance Standard 2: Labor and Working Conditions
As previously discussed under PS 1, Cairn’s Guiding Principles define the approach to managing Corporate Responsibility in accordance with the Group’s policies, which include Group Health, Safety and Environment (HSE), Security and Corporate Social Responsibility (CSR) Policies. Conformance with the Guiding Principles and Policies is mandatory across the Cairn India Group. The company also seeks to promote the application of the Guiding Principles by its contractors and in its non-operated activities. To support the delivery of the commitments made in the Guiding Principles and Policies, Cairn has implemented a Group HSE Management System (HSEMS) which is supported by detailed procedures and guidelines which are appropriately communicated to employees. Cairn’s policies on human resources and procedures are in accordance with Indian laws and regulations in force, the core ILO Conventions and IFC’s PS 2.
Cairn is an equal employment opportunity employer, and its Guiding Principles and Policies include specific provisions to foster a positive working environment which respects an individuals personal dignity and which is free from less favorable treatment on the grounds of gender, disability, race (including color, ethnic or national origin), creed, marital status, age, sexual orientation, responsibility for dependents, religion or beliefs, or any other inappropriate distinction. Cairn does not employ forced, bonded or child labor and recognizes that all employees have the right to freedom of assembly, association and collective bargaining.
Construction work on the pipeline will be carried out simultaneously in several spreads along the pipeline route. Additionally construction work on the terminals /heating stations will also be undertaken in parallel with pipeline construction. Thus there will be several locations of construction work going-on at the same time.
The methodology and details of work to be undertaken in constructing the pipeline will be finalized in consultation with contractors, and a detailed contractor’s work plan and schedule will be prepared and approved by Cairn before construction commences. A predominantly skilled and technical workforce will be required for pipeline construction, since it is envisaged that much of the work will be mechanized in order to meet the project schedule. Cairn will require contractors to make best efforts to source available and suitable skilled workers from local areas in Rajasthan and Gujarat The unskilled workforce required for pipeline construction will be preferentially sourced from local communities nearby areas where the work is being undertaken along the pipeline route.
The peak total workforce is expected to ramp up to approximately 2500 persons spread across multiple locations during construction. It is expected that separate EPC contractors will commissioned for construction of the pipeline, terminals and other facilities. The pipeline contract will include the establishment of several construction camps for the labor force. Sites for the construction camps have not yet been identified
In the course of operation of the project the total workforce will be approximately 250 persons
Performance Standard 3: Pollution Prevention and Abatement
Cairn, as part of its HSE Management System, has prepared pollution prevention plans for the field developments as well as for the construction of the pipeline. The Environment Management Program (EMP) detailed in the ESIA documents is intended to minimize adverse impacts and enhance beneficial impacts during the life cycle of the project. The EMP forms the basis on which the regulatory authorities assess and grant environmental clearance and permits and carry out inspections to ensure compliance with the environmental clearance and permit conditions. The contractors will be required to develop pollution prevention plans that meet Cairn’s standards and HSE plans. These plans will need to be reviewed and approved by the appropriate personnel of Cairn.
The proposed project will comply with the applicable IFC’s Performance Standards and applicable guidelines including the Onshore Oil and Gas Environmental, Health and Safety Guidelines, and Waste Management Facilities Environmental, Health and Safety Guidelines dated April 2006.
Oil and Gas Field Development
Atmospheric Emissions:
The Rajasthan block is located in a semi arid and transitional zone between desert in the west and the Aravali range in the East and has a dry climate.
Cairn developed a baseline for the climatic conditions in the surrounding areas of the block. Ambient Air Quality (AAQ) monitoring was carried out at 39 locations distributed over the block during the period March 2004 to May 2004. Various specialist agencies in their field of work were engaged to carry out the baseline data monitoring, analysis and interpretation. The parameters that were measured included (i) suspended particulate matter (SPM); (ii) respirable particulate matter; (iii) sulfur dioxide; (iv) nitrogen dioxide, (v) carbon monoxide; and (vi) hydrocarbons. The gathered data was compared to the national standards for ambient air. The comparison showed a satisfactory result, as none of the parameters values exceeded the national standards.
During the construction phase of the upstream facilities, it is expected that the site preparation, including earth movement, will generate dust particulates that could affect the ambient air. Additionally, the large number of trucks and heavy trucks, and other gaseous material in the area will most likely generate chronic emissions. The emissions during this phase of the project are expected to be temporary. Cairn will put in place mitigation measures including among others the following:
Areas with heavy vehicular traffic will be watered to control dust; where feasible and required
Management procedures for the handling of soil, top soil and other materials will be put in place to minimize the risk of wind blown material and dust;
Waste material generated from the construction will not be burned on-site;
Procedures for appropriate behavior of truck drivers delivering materials will be put in place e.g. covering material to avoid dust release;
All trucks will be checked and maintained to ensure trucks have the proper engines and exhaust equipment per the standards set by the CPCB. Additionally, no trucks or vehicles will be left running when not in use;
Access roads utilized by the project will be improved by using bitumen or concrete to minimize dust generation; and
Personal protective equipment will be required for personnel working in these areas of high dust.
The air emissions during the operational phase will vary and will be generated from single and group sources. These include: (i) diesel generators (DG); (ii) hot oil heaters; (iii) power generation/turbines; (iv) gas processing; (vi) and other equipment such as the incinerator.
Cairn has modeled the impacts on air quality from SO2 and NOx and these were compared to data gathered during the baseline assessment. It is expected that the emission levels for the proposed activities will be within the National Ambient Air Quality Standards (NAAQS) established by the Government of India’s Central Pollution Control Board (CPCB). Cairn has proposed mitigation measures to minimize the air emission impacts. The background SO2 and NOx concentration band in the air emission modeling carried out by National Environmental Engineering Research Institute (NEERI) in the area are 5.3-11.4 and 5.1-14.9 µg/m3 respectively. Nevertheless, the following actions will also be taken:
For continuous emissions equipment i.e. flaring (emergency conditions), hot oil heaters, DG sets and a captive power plant will be installed with stack heights in accordance with the Central Pollution Control Board (CPCB) standards. In addition, equipment such as low NOx burner and low sulfur fuel will be installed and used;
A plan to manage all of the emissions from vehicles, burning of waste material (not allowed), type of fuel use will be put in place to minimize emissions;
A maintenance program will be established to reduce fugitive emissions and individual stacks will comply with the standards established by the CPCB, and IFC guidelines
Cairn will put in place a post project monitoring (PPM) program for emissions generated by the project during the operation phase. The PPM will include the monitoring requirements as per the statutory guidelines and as stipulated in the HSE permits and consents and IFC Performance Standards and health and safety environmental guidelines.
The associated gas generated at the Rajasthan block will be utilized for power generation purposes. A flare system designed in accordance with best oil practices has been designed. The flare system will be used to burn the associated gas in case of shut-down, plant upset condition, and emergency situations. Under normal operations there will be a pilot flare maintained, since the associated gas will be utilized for captive power generation. The power required to operate the MPT and the well-pad facilities will be generated in the captive power plant located in the MPT facility
Three air pollution scenarios for the captive power generation plant were considered for modeling carried out by NEERI. These are power generation by fuel based on natural gas, crude oil and combined crude oil and natural gas. The maximum ground level concentration (GLC), as determined in the modeling studies, predicted the following for SO2: Nil, 19.40, and 10.87 µg/m3. Similarly, the predictions for NOx are 11.86, 14.99 and 14.63 µg/m3. These levels are well within the baseline values. However, the detailed design under implementation has finalised on dual fuel engines with natural gas as primary fuel option and Diesel as stand by fuel.
Greenhouse Gas Emissions
The GHG emissions due to the operation of the MPT facility are primarily generated due to the release of the CO2 from the associated gas (approximately 30% by wt of the associated gas). Additionally the burning of the associated and the natural gas for power generation would generate GHG emissions. Currently there is no plan for Carbon Capture and Sequestering (CCS) to mitigate the GHG emission. The estimated annual GHG emission from the MPT operation over the life of the production period will vary from 0.3 million to 1 million T per year.
Cairn will maintain a monitoring program for GHG and will establish programs to minimize the emission of GHG, according to data obtained.
Noise
Cairn has designed the upstream project such that the sound pressure level in the work areas will not exceed 85 dBA. In any areas where this level can not be attained there will be restricted access for personnel and practicable mitigation measures will be sought to reduce the noise level below 90 dBA. The noise level at the perimeter of the project fence will not exceed 60 dBA. Among some of Cairn India’s mitigation measures to minimize the noise levels are:
The development of a green belt which will contribute to the noise attenuation;
A program to monitor the areas where noise levels are expected to be high will be put in place to ensure that proper HSE are followed;
It will be ensured that provision of and use of Personal Protective Equipment (PPE) is strictly followed by all employees and contractors. Training on the proper use of the PPE will be facilitated.
Water Resources
Given the scarcity of fresh water in the Rajasthan area, Cairn India commissioned a water resources feasibility study to assess the expected water requirements during drilling, construction and commissioning at the oil and gas field development area, and to identify the optimal means of addressing the water requirements with the least environmental and social impacts. The study showed that the option to use the Thumbli saline water aquifer is the best alternative. The study confirmed that the impact of the abstraction of water to existing fresh water resources and users will be negligible.
The volume of water requirement for the oil and gas fields development is estimated at approximately 25,000 kl/day and this will be met from the Thumbli saline aquifer. The abstraction wells will be located approximately 20 km from the MPT. The field will consist of up to 24 deep bore-wells. Authorization for saline water abstraction has been obtained from the Central Ground Water Authority Ministry of Water Resources, Govt. of India.
The abstracted saline water will be treated at the desalination plant (located at the MPT ) and this will meet water requirements for the Mangala, Aishwariya and Bhagyam field. For the other southern fields the fresh water requirements will be minimal and will be supplied by authorized local third parties.
Water Injection Requirements
To achieve optimum exploitation of the Mangala, Aishwariya and Bhagyam reservoir pressure support will be required from the beginning of the operations. Therefore, the major water requirement for these fields will be for re-injection purposes. It is expected that 23,000 – 25,000 kl/day would be required for the life of the reservoir. However , once yields from the reservoir begin to decline so will be the water requirement. Water required for re-injection purposes will also be sourced from the Thumbli aquifer.
Cairn, as part of its monitoring plan, will put in place a program that will track and maintain and up-to-date record of all decisions made with respect to the abstraction and supply of water, and if a deviation is observed from baseline data, corrective action and a different approach will be taken.
Wastewater Generation
Produced water generation from the oil and gas development will be one of the major sources of wastewater. Cairn has designed water treatment facilities to manage this impact from the project. This water will be treated to specific criteria to be used in the re-injection process to maintain reservoir pressure. The produced water quantity generated will vary with the age of the field. It is anticipated that the Mangala field development will generate about 300,000 barrels of water during the maximum water-cut phase. This produced water will be treated and injected back into the oil reservoir. There will be no surface discharge of produced water.
In the southern fields’ produced water will be treated on site in their own well pad facility. Since the produced water from these fields is expected to be minimal, it will be solar evaporated in suitably designed solar evaporation ponds. In cases where large amounts of produced water are generated from the reservoir, a package treatment facility will be installed to meet the dump well discharge standard.
Cairn has developed specific criteria for the treatment of all produced water, sewage waste water, and re-injection water. In addition, specific recommendations to maintain the effluent treatment facilities have been developed
Solid Waste Generation
Cairn has a strategy for the treatment of waste which includes the philosophy of source reduction, reuse, recycle and natural degradation. As part of this strategy Cairn has a solid waste management plan, which is implemented by all employees and contractors.
The hazardous waste generated at the processing facilities will be collected, classified, treated and disposed of according to specific criteria stipulated in the applicable Indian environmental regulations, and to the specific conditions stipulated in the environmental permits / consents for the facility. Hazardous waste that needs further treatment will be stored in a special storage yard which will be built in accordance with legislation stipulated by the Ministry of Environment and Forests (MoEF), CPCB and IFC’s Waste Management Facilities Environmental, Health and Safety Guidelines.
Cairn will design a captive and integrated landfill site which will also include a high temperature incinerator. The integrated landfill will be located within the MPT facility area and will be used for final disposal of the hazardous waste. A specific procedure has been put in place for the selection and design of the landfill. A management and monitoring plan to control and mitigate any impacts from the landfill will be developed including a landfill closure procedure.
Emergency Preparedness
A comprehensive emergency preparedness plan will be in place during the construction and operation phase. The plans will be designed in accordance with the requirements of Oil Industry Safety Directorate (OISD), Tariff Advisory Committee (TCA) of India, NFPA standards and safe engineering practices. The plans will have early detection and suppression systems.
Oil Pipeline Evacuation with Associated Facilities from Mangala Terminal to Salaya Terminal
The crude oil pipeline extends from the Mangala terminal in the district of Barmer, Rajasthan to Salaya terminal near Jamnagar via Viramgam in the state of Gujarat. The pipeline has been divided into two segments, the first one from Mangala to Viramgam with an approximate length of 340 km and the second one from Viramgam to Salaya terminal approximately 260 km in length. The pipeline route has been selected to avoid environmentally sensitive areas and areas with high population density, and to minimize the number of crossings of national and state highways, railway routes, river and canal crossings. The pipeline is heated using the Skin Effect Heat Management System (“SEHMS”) method, and insulated with 3 layers of poly urethane foam and encapsulated in a High Density Polyethylene outer sheath to protect it from water invasion and damage. The pipeline is buried in its entirety to a minimum of 1.0 m depth, within a 30 m wide pipeline corridor. The pipeline corridor will be acquired on ‘Right of User’ (ROU) basis and the land after installation of the pipeline will be available to farmers for agriculture purpose.
The necessary heat for operating the SEHMS will be provided by heating stations that will consist of power generating units of no more than 1 MW in capacity, and a total 32 of these units will be installed at every 18 km interval. Intermediate crude oil storage and pumping and distribution facilities will be installed at Viramgam and Salaya in Gujarat. Two crude oil buffer storage tanks of 15,000 bbls will be installed at Viramgam and three crude oil buffer storage tanks of 150,000 bbls capacity will be installed at Salaya. There will also be four condensate storage tanks of 350,000 bbls at Salaya. There will be one head pump station at Mangala and one intermediate pump station at Viramgam, both with normal outlet pressures of 79.5 barg and 50% sparing on the pumps (i.e. a 2 out of 3 operating philosophy). Both terminals will have the appropriate fire fighting and emergency equipment, waste management facilities, and secondary containment areas. The Virangam and Salaya terminals will require 8 and 10 MW gas based power generation respectively for heating, pumping and dilutents mixing.
The Mangala, Aishwariya and Bhagyam oil fields will export waxy crude oil with a pour point of approximately 40˚C, i.e. the crude will solidify at ambient ground conditions. After considering and evaluating a wide range of possible methods of overcoming issues associated with transporting waxy crude oil, the concept and solution selected in early 2007 was to construct a “heated” pipeline which can continuously maintain the temperature of the oil above the Wax Appearance Temperature (“WAT”) of 50-65˚C, and if necessary re-heat the oil to a temperature greater than the Wax Dissolution Temperature (“WDT”) of 70-75˚C. The design flow rate is 150,000 bopd.
The selected concept for the 591 km Barmer to Salaya Pipeline (“BSPL”) is a hot crude oil 24” pipeline with a wall thickness of 10.6mm, made of carbon steel. In order to ensure continuous power supply for the SEHMS an 8” Carbon steel gas pipeline will be installed in the pipeline trench beside the oil export line in order to supply fuel gas to the 1MW gas engines installed at the 32 heating stations every 18 km along the route. This line will be capable of a throughput of 12 MMSCFD and will operate at a normal throughput of 6 MMSCFD of gas from the Raageshwari Gas field.
The first 4 heating stations (before the gas pipeline from Raageshwari runs parallel to the oil line) will be diesel driven as the oil entering the pipeline from the Mangala tank farm will be at 90˚C. It would only be in a shutdown situation lasting longer than 15 days without draining the pipeline, that it would be necessary to provide rented, diesel generators at these stations. The SEHMS will maintain the temperature at 65-70˚C (i.e. above the WAT) to prevent wax deposition. It will, however, be rated at ~75˚C (i.e. above the WDT) to allow melting of wax in case of prolonged shut-down, and in the event that the pipeline has cooled below the pour point and the crude has solidified. With the pipeline operating normally prior to a prolonged shut-down of the heating system it is expected that it would take more than 11 days for the oil to cool down to pour point. For a pipeline with the entire length cooled to below pour point it is estimated that the restart of the line at low rates could be achieved within at most 5 days, and at full rates it could be achieved within 13 days.
Pigging facilities for the oil pipeline will be installed at ~150 km intervals to allow removal of any wax deposited on the pipeline during intelligent pigging operations (where a pig with a number a measuring devices that can identify any potential erosion or pitting of the pipeline is sent down the line using the oil flow as a driving force). Normal pigging operations will be performed if any increases in pressure drop are observed along the pipeline. However, as the pipeline should continuously contain oil at a temperature above the WAT, this should not be necessary. Intelligent Pigging Operations will be performed on a 5 yearly basis.
River, canal and highway crossings
The pipeline will cross major five seasonal rivers, namely the Luni, Sukri, Banas, Mahanadi, and Brahmani rivers. All rivers with water flow, canal and rail crossings will involve the boring (or drilling) of a hole beneath any obstacles to provide a conduit for the pipeline. The pipeline will cross (and sometimes re-cross) a number of streams and local drainage flow paths. There are only a few major river crossings, and in which water flows only in the monsoon season. No problems are anticipated in obtaining approval to cross these rivers and no difficulties are expected in constructing the crossings.
Major road crossings will also be bored and only single-lane roads will be crossed using an open cut trench, while ensuring that passage via a local detour is available at all times and that the work will be completed expeditiously.
Clearing and grading
A 30 meters ROU will be cleared off vegetation and any other obstacles for the pipeline construction. RoU boundaries will be clearly demarcated and no work or encroachment will be allowed outside this perimeter. Special areas or trees that need to be protected or saved will also be flagged or fenced in prior to the clearing. Scrub and other vegetation will be stockpiled along the RoU for its use in the reinstatement process. Earth movement will be minimized as much as practicable as possible and Cairn India has a process in place to ensure compliance.
Air Emissions
The construction activities during pipeline laying, such as excavation, embankment formation, transport of construction materials, handling, laying and jointing of pipelines, etc. will generate fugitive dust emissions. A marginal increase in the levels of oxides of nitrogen, carbon monoxide and hydrocarbons is envisaged due to the movement of vehicles for transportation of construction material and DG sets. These emissions will be temporary and confined to a localized effect during the construction period. The air quality modeling carried out for the construction equipment and DG sets along the pipeline route for SO2 and NOx indicates that the incremental Ground Level Concentration (GLC) of emissions due to the construction activities will be minimal, and the Ambient Air Quality will be within the National Ambient Air Quality standards. Cairn India has established mitigation measures to minimize these impacts.
There will be no impact on air quality due to the pipeline during the operational phase. However, heating stations (Gas Engine Generator - 1 MW capacity) located at intervals of 18 km along the pipeline route, and power generating units at storage terminals will contribute to atmospheric emissions of SO2, NOx, CO, particulates and hydrocarbons. As natural gas and / or diesel is envisaged to be used as fuel to run the engines, NOx and SO2 will be the air pollutants of significance. The air quality modeling carried out with various sources of emissions at Viramgam and Salaya terminals, and at Wankhaner and Sanchore heating stations, showed that the impact on the air quality due to gas based power plants will be insignificant. The fugitive emissions of VOC is not likely to be materially significant, since it is proposed that the vent gases from the fixed roof tanks will be collected and connected to the natural gas pipeline, and no VOC emissions are expected from the storage tanks. Adequate stack heights as per the regulatory norms will be provided to ensure wider dispersion of pollutants. Regular inspections of tank roof seals and preventive maintenance of valves and other equipment will be undertaken.
Wastewater Generation & Disposal
The crude oil pipeline will be insulated, buried and coated with a cathodic protection layer. This therefore will protect the pipeline from water ingress, discharge due to leakage, corrosion and sabotage. There is no production or processing activity proposed at the Viramgam terminal location, hence there will be no generation of process effluent. The effluent from washing will be generated in minor quantities on an occasional basis, and the wash water free of floating oil will be treated in a skid mounted package treatment plant sourced from reputed manufacturers of such systems. There will be no discharge of treated waste water outside the plant premises.
The Heating Stations and the Crude Oil storage Terminals will have very few regular staff manning the facilities since they are not production units. Staffing will consist of a few operators for the pump and electrical and control system and security personnel. The sewage generated from the toilet blocks will be routed to a septic tank designed to comply with relevant Indian Standards. The treated sewage will be routed to soak pits.
Water consumption
During pipeline construction the water requirements will be minimal and is estimated to be 100 m3/day. Water for the pipeline and terminal construction and operation phases will be sourced from permitted water supply sources and agencies. Water required for hydro testing will be sourced from the desalination plant located at the MPT, and the hydro test used water will be recycled for use in other sections of the pipeline. Residual hydro testing water will be tested for toxicity and pollutant characteristics prior to disposal at approved effluent treatment facilities.
Potable water for domestic use in the camps will be sourced from local providers. Wastewater generated at the camps will be treated in septic tanks followed by disposal in soak pits.
Impacts to biodiversity
The pipeline alignment route was selected because it avoids all environmentally and ecologically sensitive areas in Rajasthan and Gujarat states. The pipeline route avoids passage through any National Parks or Sanctuaries or any other biosphere reserves. It is noted that in the Barmer district, there are three endangered plant species, however, the detailed cadastral level survey of these species reveals that they do not occur within the vicinity of the pipeline corridor. The Cairn pipeline construction plan will ensure that proper procedures are followed and that the construction crew are trained on careful excavation of trees and specific plant species, creation of nurseries and replanting of trees.
Emergency preparedness
The pipeline will be deigned in accordance with the Indian seismic design codes and guidelines for seismic design of buried pipelines. Due consideration will be given to the applicable seismic zone design code requirements for the design of the crude oil storage tanks at Viramgam and Salaya terminals. In general pipelines are sufficiently flexible to absorb the seismic energy and thus the potential to cause damage to the crude oil pipeline and thus the surrounding environment is unlikely. The pipeline has also been designed to include a special coating to avoid corrosion, a cathodic protection system, a PUF insulation system to block heat radiation, and installation of automatic sensor systems that will detect earth movement, illegal excavation and other third party intrusions.
As previously indicated, Cairn developed a hazard identification analysis for the pipeline construction and based on recommendations from the study appropriate mitigation measures will be incorporated in the design, construction and operation of the pipeline system and the storage terminals. In addition hazard operability studies will be carried out to identify and mitigate risks associated with the operational aspects of the pipeline and crude oil storage.
Cairn will develop emergency response plans for the operation phase for the entire project prior to commencing operations
Decommissioning Plans
The pipeline and associated facilities will need to be decommissioned after their commercial life has ended, or if there is a change of management strategy or for operational requirements. Cairn will assess the best alternative for the decommissioning process and will design a plan which will address the best options. The assessment conducted will take into consideration technical, environmental and social impacts, health and safety and stakeholders opinions.
Performance Standard 4: Community Health, Safety and Security
Cairn’s oil and gas field development will be developed within the approved concession. The nearest settlement is over 1km from the Mangala Processing Terminal (MPT), and widely separated households (dhanis) are found in the area surrounding the field development. The design and siting of the field development facilities has avoided any areas of relatively more dense population.
The pipeline will traverse various land use categories used by 65 villages in two districts in the State of Rajasthan and 178 villages in six districts in the State of Gujarat. The Rajasthan area is sparsely populated and about 80-90% of the total population lives in rural areas. One of the criteria for the pipeline route selection was to avoid and minimize aligning the pipeline corridor in areas of high population density, such as in the vicinity of village settlements. There will be no physical resettlement of any households along the entire pipeline route.
Community Safety
Cairn has identified vehicular traffic as the main risk for community safety. Cairn has taken precautionary measures to avoid traffic accidents. Cairn India has management plans in place to manage high traffic flows in the areas of the project construction and operation, and will require its contractors to meet HSE standards and procedures for transportation. Employees and contractors will need to prepare according to Cairn ’s HSE procedures a Journey Management Plan (JMP). Adherence to the regulations of the Government of India and the Road Transport Safety specifications will also be required. As part of road safety measures, trucks will carry essential first aid equipment to respond to minor incidents and have emergency aid contacts for summoning external assistance, in the event of major incidents.
Cairn will employ licensed transport contractors and will require adherence to all the provisions under the Motor Vehicles Act. Provisions for emergency response and Transport Emergency (TREM) cards will be issued and safety related awareness counseling will be given to drivers to foster defensive driving techniques and to minimize transportation risks.
Cairn will develop a comprehensive emergency response plan for the handling and management of spills, leaks, fires as well as natural disasters, and will train all employees and contractors. The layout of the facility will ensure that adequate safe distance is maintained from the terminal high risk areas and the facility boundary in the unlikely event of fire and/or explosion. In addition the communities along the pipeline route will be informed of safety measures. However the risk is considered minimal as the pipeline is buried, insulated and has sabotage and leak detection mechanism for immediate response.
Community Health
Cairn has been actively supporting community development initiatives in Barmer in consultation with the District Administration, elected leaders and the community at large. The programs under way since 2003 include:
Partnering with the international NGO, Sight Savers International for a comprehensive eye care program that addresses reversible blindness and increasing community awareness to prevent visual impairments. This program is being implemented in collaboration with a local NGO, Barmer Jan Seva Samiti as part of the local capacity building objective.
Supporting the Department of Health to conduct health camps for local communities in villages
Provision of equipment to differently-abled people
Provision of an ambulance to the District Hospital that caters to the local communities across the district to provide better emergency services
Provision of support for anti-snake venom and anti rabies vaccinations, two critical requirements in the far flung health centres across the district
Supporting training programs for community health workers, including traditional birth attendants, on safe practices and awareness on key issues
As part of IFC’s previous investment with Cairn, and under existing community development programs, Cairn and IFC are in partnership to design, fund and implement socio-economic development programs in Barmer. The programs are being implemented under the banner of the IFC-Cairn India Linkages Programs and one of these programs includes a two year health project titled: “Child and maternal health awareness initiative (CMH)”. This initiative was launched in July 2007, and aims to address the following issues:
Community health – child and maternal care, immunization and family planning;
Awareness of HIV/AIDS prevention among the communities, truckers and migrant labor in the vicinity of Cairn’s area of operation
This program is being implemented by the Centre for Development and Population Activities (CEDPA) from New Delhi, in collaboration with three local NGO’s.
Security
Cairn recognizes the rights set out in the Universal Declaration of Human Rights (UDHR) and seeks to apply its principles within Cairn’s ‘sphere of influence’ and activities. Cairn applies a ‘rights aware approach’ in identifying any human rights at issue in the company’s activities, assessing where the issue occurs within the spheres of influence of Cairn’s business, and defining action to be taken to address issues. Cairn is committed to conducting all activities in accordance with IFC’s Performance Standards and guidelines. Cairn will use non armed private security for the security monitoring of all its activities. Cairn will ensure that proper training in ethical conduct and human rights are provided to the security personnel in accordance with their HSE policies and the Government of India regulations. Any allegation of misconduct by the security personnel will be investigated by Cairn’s personnel in accordance with Incident Investigation and Reporting procedures and will be properly documented, and will monitor the status of the investigation for full and proper resolution.
Performance Standard 5: Land Acquisition and Involuntary Resettlement
The implementation of the above hydrocarbon development and crude evacuation projects require certain lands to be acquired on temporary basis for exploratory work (seismic surveys, exploratory drilling, appraisal, approach roads etc), certain others on permanent acquisition basis for establishing facilities (well-pads, well-sites, process facilities etc), and acquisition of Right of User (RoU) for laying the pipelines .
This Cairn India Group Framework Land Acquisition & Compensation Plan (LACP) outlines the principles and guidelines being followed in acquiring land/RoU for any of the Group’s operations in India and in providing associated compensation covering loss of the use of land, physical displacement, impacts to assets such as built structures, seasonal and perennial crops and impacts to livelihoods and economic displacement.
The Framework LACP has been prepared in accordance with the Land Acquisition Act ("LAA") which governs land acquisition in India, internationally recognized standards such as the IFC’s Performance Standards (especially Performance Standard 5 on Land Acquisition and Involuntary Resettlement) and in line with the Equator Principles. Framework Land Acquisition and Compensation Plans (LACP) will be prepared by the Cairn India Group for each state, where there is a need for land acquisition for carrying on its activities. The LACP will elaborate the details of the extent and location of any lands, RoU’s etc to be acquired, detailed information on the land/RoU acquisition process, the principles used for determination of compensation amount, method and procedure for payment of monetary compensation, etc.
Permanent land acquisition and compensation for Cairn India Group operations in India are undertaken in accordance with the Land Acquisition Act (LAA) which governs land acquisition in India. It is a comprehensive legislation which addresses in detail all the facets of the land acquisition process and provides a credible mechanism to determine the quantum of compensation. In addition to its Corporate Framework Land Acquisition and Compensation Plan (LACP), Cairn India Group disclosed in 2007 a Rajasthan Framework LACP, after consultation with the District Administration and the IFC, to address and mitigate all temporary and permanent land acquisition and resettlement related impacts in Rajasthan, associated with seismic investigations, well drilling and completion, construction camps, production and processing facilities, pipelines and access roads. The Rajasthan Framework LACP also specifically addressed measures to ensure compliance with IFC’s PS 5.
The Rajasthan Framework LACP has since been expanded to address land acquisition and ‘Right of User’ (ROU) requirements for the pipeline and negotiated land purchase for the associated above ground facilities in Rajasthan. Similarly a Gujarat Framework LACP has been prepared to specifically address land acquisition and ROU requirements for the pipeline and its associated above ground facilities in Gujarat. Acquisition of ROU is being undertaken in accordance with the Petroleum & Minerals Pipelines (Acquisition of Right of User in Land) Act, 1962 (PMP Act).
Oil and Gas Field Development
Permanent land acquisition for the Mangala Terminal commenced prior to IFC’s existing investment and finalization of the Corporate and Rajasthan LACPs. As part of IFC’s existing investment with Cairn. it was agreed that the Mangala permanent land acquisition process would be subject to an independent review to ensure that the requirements of IFC Performance Standard 5 on ‘Land Acquisition and Involuntary Resettlement’ were met, and if not, to prepare and disclose a Corrective Action Plan (CAP). Land acquisition for Phase-I and IIA has been completed and Phase-II is substantially complete. An independent review is currently being planned to be carried out once the Phase II land acquisition is totally complete.
Pipeline
The pipeline originates at the Mangala Terminal in Rajasthan. The pipeline will be routed via the Viramgam Terminal near Ahmedabad and will terminate at the Salaya Terminal in Gujarat. The pipeline traverses Barmer and Jalore districts in Rajasthan, and traverses Banaskantha, Patan, Ahmedabad, Surendranagar, Rajkot and Jamnagar districts in Gujarat. The total length of the pipeline is approximately 600 km of which about 150 km is located in Rajasthan and 450km in Gujarat.
The pipeline passes through land belonging to the inhabitants of 243 villages (65 villages in Rajasthan and 178 villages in Gujarat). The pipeline alignment has been selected in order to avoid common settlement areas and dwellings and thus there is no planned physical resettlement of any households. However a total of approximately 20,000 agricultural land parcels will be directly affected by construction of the pipeline (approximately 7 percent in Rajasthan and approximately 93 percent in Gujarat). Based on the Social Baseline Survey and Impact Assessment (ERM Report) of the proposed pipeline agricultural lands are generally tilled by the land owner household and there are relatively few instances of share-croppers and renters. The pipeline construction will be carried out in several spreads along the pipeline route. At any given location along the pipeline route construction work will be for a short duration (approximately 3 months). Hence, most impacts are temporary and transient and most land parcels will only be partially affected. Following pipeline construction, land within the 30m wide ROU will be returned to its former use, with some restrictions such as constructing buildings and planting trees. The estimated total extent of land that will be required for ROU along the 600 km pipeline is 1800 ha.
Approximately 35 and 55 ha of land will be permanently acquired for the processing, storage and other facilities at Viramgam and Salaya terminals respectively. Approximately 10 ha will be permanently acquired for other above ground facilities (heating and pigging stations), associated with the pipeline.
Performance Standard 8: Cultural Heritage
Cairn’s Guiding Principles specifically commit the company to conduct all activities in accordance with its Health, Safety & Environment (HSE) and Corporate Social Responsibility (CSR) Policy. These Cairn Policies are in compliance with the IFC’s Performance Standards and guidelines. Cairn will not conduct exploration or production operations in World Heritage Sites (as designated by the United Nation Educational, Scientific and Cultural Organization (UNESCO)). The ESIA for the Rajasthan Block and the ESIA for the oil evacuation pipeline and associated facilities from Mangala terminal in Rajasthan to Salaya terminal in Gujarat did not identify any cultural heritage property that would be affected by the project. Nevertheless in implementing the project Cairn will put in place measures to avoid impacts to cultural property, including establishing a ‘chance finds’ procedure (refer to attached Action Plan).
In case any archaeologically significant site is encountered, work in that section will be suspended and the district authorities notified. As per the Indian regulations, all archaeological finds are national property and experts will be deputed by the GoI to supervise the handling of any unexpected or chance finds to prevent damage. The contractors will be instructed to ensure that no worker may possess or remove an archaeological artifact from the project area will be strictly enforced. As part of its management system Cairn will prepare a “chance finds” procedure.
