Key environmental and social issues associated with Doshion’s water and wastewater treatment business are summarized below. Environmental, social and health and safety issues will continue to be addressed by the Company consistent with requirements of IFC Performance Standards as agreed in IFC’s investment documents and associated agreements. The Company has a strong management system that provides effective oversight of its environmental, social and health and safety performance. Adoption of IFC Performance Standards by the Company as part of its management system requirements will further strengthen the existing E&S management system.
PS1: Social and Environmental Assessment and Management System
Doshion has a large number of EPC and turnkey contracts currently underway, and additionally has four long term BOOT concessions for supplying potable/treated water to industrial and municipal customers. These include:
- Water and wastewater treatment for Nagarjuna Oil Corporation Limited (NOCL) in Cuddalore, Tamil Nadu, India – Doshion was awarded a Build-Own-Operate-Transfer (BOOT) concession for a period of 20 years by NOCL to provide treated industrial quality water and treatment of wastewater from refinery operations. An EIA for the overall NOCL refinery was completed in January 2012. The project will treat 20 MLD of surface water, and 4-5 MLD of wastewater treatment capacity. Treated effluent will be discharged to sea in compliance with local regulatory requirements. The project is being undertaken by Doshion in compliance with requirements established by an overall environmental and social impact assessment conducted for the NOCL refinery in Cuddalore, Tamil Nadu. The project is expected to begin commercial operations by the end of 2012.
- 24 x7 potable water supply concession for Shivpuri – Doshion was awarded a PPP concession for a period of 25 years by the Nagar Palika Parishand Shivpuri under a public private partnership scheme. Although a separate EIA is not required for the project, the Company’s activities are approved through a regulatory permit system that covers environmental and social aspects of the project. The scope of work includes financing, detailed planning, design and engineering, construction, procurement, and commissioning of water supply scheme comprising of 42 MLD capacity (upgradable to 63 MLD capacity in Phase II), approximately 15 km of raw water transmission pipe from the Madikheda dam, electric subs station with electric transmission lines, new water distribution networks totalling in length of about 100 Kms, rehabilitation of existing distribution Network of approximately 87 Kms, construction of 12 elevated service reservoirs of varying capacity and installation of flow meters. Doshion will also provide operations and maintenance, and tariff collection services under the terms of the concession. The project is expected to begin commercial operations by the end of 2012. It is anticipated that the project will provide uninterrupted (24x7) access to safe potable water to about 172,000 residents of Shivpuri. Tariff structure and mechanisms for adjustment have been agreed with the local government. Adequate tariff and access provisions are made for those unable to afford as per the concession agreement.
- Two relatively smaller desalination concessions in the state of Rajasthan – (i) desalination project for Rajasthan Mines and Minerals Ltd. for execution of 20MLD Brackish Water Desalination under DBOOT basis for a period of 15 years; and (ii) desalination for TWAD under BOOT basis for a period of 7 years.
Doshion’s environmental management team has overall responsibility for ensuring consistency and compliance with local regulatory requirements. Potential impacts of proposed projects are identified during the planning stage (through government led impact assessment processes), and are used to prepare specific environmental control plans containing identified mitigation measures consistent with local regulatory requirements. In India, the local governments select sites for locating water and wastewater treatment infrastructure, and obtain documented approval from the affected communities for location of the facility. Environmental and social impact assessments are typically prepared by the government for all concession projects, the scope of the assessment being project specific. The government ensures that potential impacts of the project are identified and addressed during the project planning stage, and are used to prepare specific environmental control plans containing identified mitigation measures. For municipal water supply projects, Doshion is contractually obligated to comply with national and local requirements set forth in the concession documents. Doshion’s environmental management team has overall responsibility for obtaining appropriate permits and approvals from various government agencies, and ensuring all operations are consistent with the terms of the concession agreements. Moving forward, additional to regulatory requirements, Doshion will ensure that compliance with IFC Performance Standards is included throughout the project life cycle, from project selection through construction and operations in relation to contractual scope of work. The Company will ensure compliance with IFC PS for its subcontractors as well, including EPC contractors for all construction-related PS3 and PS4 mitigation measures identified in environmental control plans/EIAs etc., through inclusion as mandatory requirements in contract documents, and programmatic monitoring of implementation.
Internal audits are conducted periodically and overseen by senior management. Routine monitoring and supervision activities are undertaken by operational staff according to established procedures, including periodic reporting on key environmental, social and occupational health and safety control factors. The company’s EH&S management team periodically inspects facilities to verify performance of compliance with applicable requirements.
Doshion and its subsidiary project companies will adopt IFC’s environmental and social Performance Standards as part of the applicable legal and other requirements in its management system. In addition, the company will incorporate formal procedures for environmental and social screening in terms of existing and new Projects (business lines) and related new Projects (business line) into its marketing strategy, commercial planning, and project bidding processes. The management system will be extended to incorporate community engagement, including clear procedure on disclosure and consultation with potentially affected communities.
PS2: Labor and Working Conditions
Doshion employs about 1,700 people directly, while the number of sub-contracted employees can vary significantly depending on construction activities at any given time. Doshion has a Human Resources policy that complies with local regulatory requirements, and is applied consistently to all direct employees. As required by law, the policy is included in employment contracts, and addresses working conditions, terms of employment, and wages and benefits. This information is provided in the form of an employee handbook at the time of induction. As is common practice in India, although not explicitly stated, employment relationships recognize the principals of non-discrimination and equal opportunity. Although there is no union at Doshion, under Indian labor laws, employees have the right to freedom of association and have the opportunity to collectively represent to the management any issues or grievances that they may have.
The minimum employment age at Doshion is 18 years. Doshion ensures that child labor or forced labor is not employed directly or by subcontractors through verification of relevant documents. Working hours on site vary by the nature of activity and phase of project, with most labor intensive phases being at the construction phase during which there are continuous operations. Civil construction activity is largely subcontracted, for which unskilled labor is often procured from nearby towns and villages. Managing the influx of labor into local communities and providing worker accommodation is the responsibility of the subcontractor. Regulatory requirements in India do not require the Company to provide direct oversight of wages, working or living conditions of subcontracted labor. Wages are paid monthly and calculated on the basis of the hours worked, inclusive of overtime. Terms of employment for sub-contractors are as per local labor laws and the Company relies on regulatory agencies for ensuring that sub contractors comply with applicable labor laws. Moving forward, Doshion will review its human resources policy to ensure consistency with IFC Performance Standard 2 on labor, working and living conditions for any labor employed by Doshion, either directly or through sub-contractors.
Occupational health and safety of employees at Doshion is managed by the Human Resources department. Human resources are managed effectively at Doshion with policies and procedures applied consistently in all its operations which are distributed geographically throughout India. Project (subsidiary) companies hire staff directly in compliance with Company policy. Where subcontractors are employed, manpower providers are strictly selected based on having adequately trained labor force and in full compliance with Doshion''s EH&S standards. There is a plan for accident prevention and worker safety consistent with local regulatory requirements. All employees in the company have to undergo a training program at induction and subsequently regarding worker health and safety relevant to their job activity. Facilities are audited yearly by regulatory agencies to monitor compliance with labor regulations. Although a single fatality of a subcontractor was reported from an unforeseeable traffic accident in 2011, the Company has been in compliance with regulatory requirements and has recorded no significant lost time incidents or fatalities in its operational history for its employees.
PS3: Pollution Prevention and Abatement
Doshion undertakes EPC contracts, as well as long term concessions for operations and maintenance of water and wastewater treatment plants that produce effluents, process residuals and miscellaneous waste streams that are managed in compliance with local/Indian regulatory requirements. Additionally, the Company also produces limited quantities of wastewater from its manufacturing units (pipe and specialty water chemicals). Effluent from all the Company''s operations are treated in compliance with local regulatory requirements and the Company has never had a violation of any of its effluent discharge/emission permits. Recognizing that although Doshion may not be contractually obligated, Doshion will design, build and operate all water and wastewater treatment facilities in relation to its scope to be in compliance at all times with IFC/WBG guidelines in relation to its contractual scope of work. Compliance will be monitored, and any non-compliance rectified in accordance with good industry practice within a reasonable period of time.
Potable water supply projects undertaken by Doshion are required to comply with Indian Drinking Water Specifications (IS: 10500: 1991), requirements of which are consistent with WHO drinking water standards. Compliance with applicable standards are monitored as per concession requirements by third party vendors certified by the local government. While the municipal water supply concessions at Shivpuri produces limited quantities of process wastewater that can be readily reused for agricultural/related applications, process effluents from its treatment operations at NOCL and desalination concessions produce effluent that need further treatment prior to discharge to comply with local regulatory requirements. The Company has consistently maintained compliance with applicable permit requirements.
Management of solid and hazardous materials, wastes and residuals at Doshion’s facilities complies with local regulatory requirements. Licensed subcontractors are used for the collection and disposal of solid and hazardous materials, including small amounts of spent resins (which are disposed in sanitary landfills as non hazardous waste). Significant quantities of solid waste are generated as part of water and wastewater treatment operations. Dewatered sludge from water treatment operations is disposed only in municipal sanitary landfills by the local government. Doshion''s procurement procedures contractually require that its suppliers and subcontractors comply with applicable regulatory requirements and Company policies. As a process of continuous improvement in its performance, Doshion will review its solid and hazardous materials and waste management practices (training, handling, transportation and storage) at its operations for consistency with applicable IFC requirements in relation to Projects, especially with respect to explosive and/or hazardous chemicals stored on site at its manufacturing facilities, and handling/transportation of chlorine gas.
Doshion’s principal energy usage includes electricity procured from the grid is estimated to be about 3,600 MWh per year. Net green house gas (GHG) emissions attributable to Doshion’s annual consumption of electricity are estimated to be about 3,500 metric tons of carbon dioxide equivalents per year. Although, GHG emissions from the projects being currently considered for IFC financing will not exceed 100,000 tons of carbon dioxide equivalents per year, Doshion will explore opportunities for energy efficiency in its operations to reduce operational cost and their carbon footprint. Further, consistent with IFC PS3 requirements on GHG emissions, Doshion will monitor and quantify GHG emissions as well as those avoided, in accordance with internationally recognized methodologies. Should the level of GHG’s exceed 100,000 tons of carbon dioxide equivalents per year, Doshion is required to evaluate technically and financially feasible and cost-effective options to reduce or offset project-related GHG emissions during the design and operation of the project.
PS4: Community Health Safety and Security
Engineering controls and staff training are provided to mitigate risks and issues associated with Doshion''s operation of its concessions, which includes transport, storage and use of hazardous chemicals. Doshion will use gaseous chlorine for disinfection. Handling of chlorine at these facilities is in compliance with stringent national requirements and there have been no accidents reported to date. At Doshion''s facilities, the use and storage of hazardous chemicals are subject to stringent safety standards as stipulated under Indian regulatory requirements. The company ensures that chemical stores provide for adequate containment and neutralizing systems to minimize the impact of release. Doshion is required to have an emergency prevention and control plans which specifies responsibilities, ensures appropriate response equipment and materials are in place, and details a set of procedures to be followed to minimize the harm of any potential accident. Moving forward, Doshion will review its scope of emergency response and update procedures as needed, including drills to test the effectiveness. Doshion will also add a community involvement component that addresses appropriate behavior and safety measures to be implemented in the event of a hazardous chemical release beyond the plant boundaries, including during transportation of such materials.
