Company has demonstrated a capacity to manage the issues identified during construction to date and has presented plans to manage anticipated impacts as described below.
PS 1: SOCIAL AND ENVIRONMENTAL ASSESSMENT AND MANAGEMENT SYSTEMS – IFC’s review considered the Company’s management of its environmental, health and safety performance in the establishment and operation of its facilities; compliance with national and local permitting requirements; and the Company’s engagement with local communities regarding environmental, health and safety performance.
The WII operations are confined to the fabrication and machining of metal components and assembly of electric motors and generators utilizing materials – copper wire, steel plate, iron bars, aluminum pipes and paint – sourced on the open market. No primary processing of materials will be undertaken at the WII plant.
As a light industry in an established industrial zone, WII was exempted by India’s national environmental protection rules from undertaking a formal Environmental Impact Assessment of its construction and operations. However, in accordance with the requirements the Tamil Nadu Pollution Control Board (TNPCB), WII did commission an Environmental Management Plan to assess the characteristics of the plant’s resource requirements and waste streams (emissions to air, waste water and solid waste) and ensure that operations meet standards prescribed by TNPCB.
While this Management Plan provides predicted levels of the performance for the plant’s operations based on pollution control equipment design specifications (e.g., process air emissions filtration and wastewater treatment), it lacks any details on how this predicted performance will be monitored, internally reported and corrective action, if any, will be undertaken and audited. WII is required to submit annual reports on its performance to the TNPCB and submit to periodic inspections by TNPCB officials to maintain its operating licenses. However, a more regular environmental monitoring regime, similar to that in place at WEG’s more complex central manufacturing facility in Jaraguá do Sul, Brazil, will be required to ensure continuous compliance with good industry practice, as specified in the IFC Environmental Health and Safety Guidelines for Metal, Plastic and Rubber Manufacturing.
In addition to an Environmental Management Plan, WII was also required by the SIPCOT authority to commission a Risk Analysis for its use of LPG and hydrogen gas in its production processes by independent consultants. The report provides a detailed assessment of risks associated with the handling and storage of these gases and clear guidelines on what safety measures are required to minimize the risk of fire, explosion and worker exposure to these hazardous materials.
WEG Brazil maintains an ISO 14001 certified environmental management system, which includes an environmental policy and a Company management commitment to continuous environmental performance through assessment, gap analysis, objectives and goals setting, monitoring, training, reporting and performance review. The incoming operations management of WII intends to operate the plant with similar systems and will aim for ISO14001 certification within two years of operation. Consistent with ISO standards, WEG extends its commitment to responsible environmental performance to its supply chain by incorporating quality assurance and compliance with established environmental laws and regulations into its materials procurement contracts. WII will adopt the same procurement procedures.
PS2: LABOR AND WORKING CONDITIONS – IFC’s review considered BPC’s operations with regard to fair, safe and healthy working conditions in its operations.
Human Resource Policy, Management and Training – WII currently employs a staff of approximately forty expatriate and Indian national professionals in engineering design and operational planning as well as construction supervision, sales and marketing. The WII manufacturing plant will require up to 600 full time employees once it is in full operation. WII commissioned a Bangalore-based human resource consultancy to design a human resource management system that is both consistent with WEG’s corporate HR policies and compliant with local labor laws and requirements. The outcome of this effort is an Administration Manual, which is provided to all WII employees at the time of their induction. The manual details Company core values, organization, policies for recruitment, progression and termination terms of employment, such as working conditions, wages and benefits, hours of work, overtime arrangements and overtime compensation, annual and sick live, maternity, vacation or holiday are established by local labor regulations. As does WEG’s Corporate HR policies, WII policies prohibit the employment of underage workers and discrimination in hiring, training, promotion and benefits.
The incoming WII operations management does not anticipate that labor unions will be active in its plant. While it does not intend to discourage the formation of unions, it prefers to foster cordial relations between management and the workforce through clear channels of grievance and grievance redress, which are detailed in the WII Administration Manual.
WEG applies a broad range of its labor policies to its supply chain through its procurement contracts under the rubric of “Social Responsibility”. Suppliers are required to comply with local labor and tax obligations, are prohibited for using child labor in the production cycle and are required to develop internal policies against discrimination in the workplace in accordance with the standards of international labor conventions. Moreover, suppliers are required to extend these policies to their own business partners. WII will incorporate the same requirements into its own procurement contracts.
Occupational Health and Safety during Construction and Operations – Approximately 400 construction workers are employed on the site of the WII plant. Good housekeeping and safety practices were in evidence during the site visit, including the use of personal protective equipment (PPE, e.g., hard hats, gloves, safety glasses, harnesses for men working at height) and protective barriers to restrict access to excavation areas. Six contractors are at work under the coordination of a general construction contractor that is an affiliate of one of India’s largest engineering and construction companies (Larsen & Toubro). Each contractor employs a safety officer to promote safety awareness, monitor worker observance of safety policies and procedures, and record and take corrective action for any near miss or lost time accidents. Each safety officer reports to the WII Factory Manager, who is responsible for day-to-day site supervision. In over 900,000 person hours worked, there have been only 12 reportable incidents (including near misses) resulting in a total of eight lost time person hours between June 1, 2009 and March 15, 2010. Site management is instructed to prevent the access of workers contracted to materials suppliers unless they are equipped with appropriate PPE.
Construction workers employed at the Project site are housed off site, outside of the boundaries of the SIPCOT industrial complex, in rented housing or temporary labor camps established by their contractors. At the current stage of construction (erection and electro-mechanical outfitting), the majority of the workforce is highly skilled and typically moves with contractors from building site to building site.
The incoming WII operations management is committed to Good International Industry Practice in the occupational health and safety (OHS) of its workers. Once the plant is commissioned, WII will undertake an audit of its manufacturing processes to assess the risk of worker exposure to chemical and physical hazards, heat and noise. On the basis of this audit, WII will develop an OHS management system compliant with OHSAS 18001that, at a minimum meets IFC’s OHS guidelines as contained in the IFC Environmental, Health and Safety General Guidelines and Guidelines for Metal, Plastic and Rubber Products Manufacturing.
PS3: POLLUTION PREVENTION AND ABATEMENT – IFC’s review considered the Company’s plans for controlling the impact of the Project’s construction and operations on the surrounding natural environment.
Pollution Prevention, Resource Conservation, Energy Efficiency – As a condition of its consent to establish operations within the SIPCOT industrial complex, WII must meet the standards established by the TNPCB governing control of fugitive dust (during construction), ambient and point source air emissions, wastewater and process effluent discharge, solid waste disposal and noise. The WII plant will be equipped with the most modern and resource (water and energy) efficient equipment available on the market. Rainwater harvesting and storage has been integrated into the factory design and a five meter perimeter of the project site, amounting to 24% of the entire site, has been reserved as a “green belt” for vegetation.
Air emissions - The main source of air emissions from the WII plant will be from shot blasting to remove surface impurities from metal components before assembly and painting. Shot blasting units will be equipped with a high efficiency cyclone separators combined with a bag filters to capture particulate emissions. The separators are rated to remove nearly 100% of particulates of 5 microns and larger and maintain a dust emission from a 12 m stack height of less than 50 mg/Nm3, well within the standards set by TNPCB and nearly matching the maximum efficiency target established by the IFC Environmental, Health and Safety Guidelines.
WII will import electricity from the grid and consume an estimated 12, million kWh at full operating capacity. The WII factory will be equipped with 3 x 750 KVA diesel generators as standby power supply during periodic power supply interruption (currently estimated at 2-3hrs per day).
Solid Wastes – WII estimates that in full operation, the factory will generate up to 50 tons of scrap metal waste (e.g., copper wire, steel plate, and aluminum), and much smaller amounts of wood and paint sludge, which will be sold to TNPCB approved recyclers. Sewage treatment sludge, generated at an estimated 10 kg per day, will be used as fertilizer for the factory’s green belt. Chemical sludge, generated by the factory’s painting and metal coating processes at an estimated 2 kg per day, will be disposed in a land fill within the factory site lined with an impervious membrane. Used oil generated at an estimated 6.5 liters per day, will be stored in designated areas constructed to contain spills for eventual sale to authorized recyclers.
Wastewater – WII will consume an estimated 64 m3 per day and generate 58 m3 of wastewater per day at full operation. The Environmental Management Report estimates that 9 m3 will be consumed by process requirements (painting, cooling, hydraulic testing) and 55 m3 will be consumed by domestic requirements. Process wastewater containing oils, grease, solvents and metals will be separately treated with oil skimming, flash mixing and flocculation, and the precipitate dried and disposed in a secure on-site landfill. The remaining chemically treated effluent will be combined with domestic wastewater for aerobic biological treatment including chlorination and filtration (sand and activated carbon). Treated wastewater will be used for irrigation of the factory’s green belt and treated sludge will be used as fertilizer.
The predicted quality of the combined treated effluent will be well within the parameters established by the TNPCB and IFC’s Environmental, Health and Safety Guidelines for those same parameters. To conform with IFC’s Guidelines, WII will periodically test this treated effluent for trace metals, acids, alkaline, oils and solvents to ensure the integrity of its process wastewater treatment system.
Hazardous Materials – WII will use small quantities of hydrogen and liquid petroleum gases in its production line. The Risk Analysis undertaken by the Company indicated that these gasses have an “intermediate” degree of hazard based on indices established by the U.S. National Fire Protection Association. A supply of 5,000 kgs of LPG and 20 cylinders of hydrogen (equivalent capacity of 47 liters of water) will be maintained on site. Based on the recommendations of the Risk Analysis Report, the Company has determined the safest location within the plant for the construction of its hydrogen and LPG storage areas, and it is outfitting these areas with the recommended safeguards to control fire and explosion in the storage and handling of these materials, including a sprinkler systems, gas leak detectors, an evaporation basin (for LPG storage) and concrete enclosures (for hydrogen). The Risk Analysis Report indicates that in the event of gas explosion or fire, the event will be contained within the perimeter of the WII plant. There is no risk from gas explosion or fire to any community or industry located beyond the walls of the plant.
In coordination with the SIPCOT authority, WII will develop an emergency response and management plan to manage the potential for explosion and fire associated with its gas storage or with any other accident that requires the support of public services (e.g., police, fire department, local hospitals).
GHG Emissions – WII will consume approximately 12 million kWh of electricity on an annual basis at full production. Sixty percent of Tamil Nadu’s installed power capacity is coal-based. It is estimated that at full production, WII will emit approximately 12,000 tons of carbon dioxide on an annual basis.
PS 4: COMMUNITY HEALTH AND SAFETY – IFC’s review considered the risks and impacts to health and safety of neighboring communities during the construction and operation of the Project, including emergency preparedness and response, as well as the security measures put in place by the client to safeguard its personnel, property and assets.
WII operations are entirely contained within the SIPCOT Hosur (Phase II Expansion) industrial complex. The plant site boundary, as are the boundaries of neighboring industrial plants, is walled and fenced to prevent access by residents of the nearby Moranapalli village. An all weather two lane service road links the plant directly to the National Highway. There are no residential or commercial settlements within the industrial complex. Since the commencement of construction in June 2009, the construction labor force has been housed offsite in rented accommodations or temporary labor camps provided by each major contractor. Workers are transported between their accommodations and the project site by bus and work a single daylight shift. All construction activities at the site cease at sunset and only security guards remain on site through the night.
WII commissioned a Risk Analysis of the storage of hydrogen and LPG within the plant as a condition of its permission to establish within SIPCOT. As noted above, the Risk Analysis Report indicates that in the event of gas explosion or fire, the event will be contained within the perimeter of the WII plant. There is no risk from gas explosion or fire to any community or industry located beyond the walls of the plant.