While all Performance Standards are applicable to this investment, IFCs environmental and social due diligence indicates that the investment will have impacts which must be managed in a manner consistent with the following Performance Standards. If IFCs investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards

PS 1 – Assessment and Management of Environmental and Social Risks and Impacts
PS 2 - Labor and working conditions
PS 3 - Resource Efficiency and Pollution Prevention
PS 4 – Community Health, Safety and Security
If IFC’s investment proceeds, IFC will periodically review the the project’s ongoing compliance with the Performance Standards
The plant is located on 483.41 acres (approximately 1.95 million m2) of government land located in Gudipadu village which has been sold to the company (in 2009) by the Andhra Pradesh Industrial Infrastructure Corporation Limited (APIIC). The mine area comprising of 1123.32 acres (approximately 4.54 million m2) includes 992.42 acres (approximately 4.02 million m2) of privately owned lands. These lands were purchased on a willing buyer-seller (most of this occurred in in 2007-08). There is no involuntary resettlement associated with the land take for the project. Hence PS5 on Land acquisition and Involuntary Resettlement is not applicable to the project.

IFC’s review also indicated that no impacts related to Biodiversity (PS6), Indigenous Peoples (PS7) or Cultural Heritage (PS8) are expected due to the company’s operations hence these do not apply.

This is a Category B project according to IFC’s Policy on Environmental and Social Sustainability because a limited number of specific environmental and social impacts may result which can be avoided or mitigated by adhering to generally recognized performance standards, guidelines or design criteria.

All infrastructure associated with BCL operations is existing including that associated with mining operations and no new land take is envisaged.. Key environmental and social (E&S) issues associated with this project include: the company’s capacity and systems to manage social, environmental, health and safety aspects of the plant operations in compliance with legal requirements as well as IFC Performance Standards (PSs) and the World Bank Group (WBG) EHS Guidelines; engagement with local communities in accordance with local requirements and IFC PSs; assurance of fair, safe and healthy working conditions in line with legal requirements as well as IFC PSs; management of wastes, emissions and effluents from its operations in compliance with WBG EHS guidelines (general as well as those for cement manufacturing); energy and water efficiency of the operations; life and fire safety (L&FS) management and emergency response; and livelihood maintenance and restoration for the project affected families/land sellers.

IFC's appraisal considered the environmental and social management planning process and documentation for the project and gaps, if any, between these and IFCs requirements. Where necessary, corrective measures, intended to close these gaps within a reasonable period of time, are summarized in the paragraphs that follow and (if applicable) in an agreed Environmental and Social Action Plan (ESAP). Through the implementation of these measures, the project is expected to be designed and operated in accordance with Performance Standards objectives.

Environmental & Social Impact Assessment (ESIA): As per the applicable requirements, the company has completed a separate ESIA and Environmental and Social Management Plan (ESMP) for both the plant (including the CPP) and the mine (in 2008 and 2013, respectively). Based on these, the company has received Environmental Clearance, Consent to Establish/operate and other regulatory permits for the plant and mine (except the mining lease, which as mentioned above, is currently under finalization). The company will ensure compliance with the ESMP, approved mining plan and requirements under obtained regulatory permits for operating the plant and mine.



There are two other cement plants/mine within the project area belonging to Penna and Ultratech cements. As per available information, these plants were established in 1993 and 2006-07 respectively.

The baseline environmental and social monitoring for the project ESIA captured the impacts due to these pre-existing cement plants; therefore, the ESIA for the project has already taken into consideration the cumulative impacts. The specific status and mitigation measures being followed/proposed for the plant (related to air quality, noise emissions, wastewater management etc.) are discussed in the relevant sections below.



Land purchase for the project, as has been stated above, was done on the basis of a willing buyer-seller basis. The area/village where the mine is located is adjacent to the mine area of Penna Cements. Land has been purchased by both BCL (from the year 2007-2011) and Penna Cements (from the year 2005-2008) from the same village (Gudipadu) resulting in cumulative impacts of land loss. These cumulative losses have resulted in landlessness of 135 land sellers and another 38 land sellers have lost more than 60 percent of their lands.



To assess the impact of private (including cumulative impacts) land take for the project, the company has commissioned a third party consultant to undertake a Social Impact Assessment (SIA) and develop a Livelihood Restoration Plan (LRP) for the land sellers impacted by the project. The SIA and LRP developed for the project has; (a) drawn a socio-economic baseline of land owners (pre- and post-land sale); (b) assessed impacts on income and livelihoods; and (c) proposed a detailed plan including an individual livelihood restoration matrix for each of the impacted land owners. The LRP among other measures identifies; (a) eligible and skilled members from the land seller family for employment and ranks them in order of priority in line with the magnitude of impact; (b) members who have interest and aptitude for a range of suggested skill building program to enhance employability; (c) vulnerable persons and support required; and (d) women members who could be either employed or supported through skill building and enterprise development. The SIA and LRP also propose measures for community benefits and support based on community needs and expectations.



T
he company has a commitment to provide employment to eligible and willing members of the land seller family. In line with this commitment, the company has, till date, provided employment to 129 members of the land seller family. It has also, based on the agreement and commitment by the land sellers and the village representatives, allowed the land owners to continue agricultural activities on impacted/sold lands. The company will, going forward, implement the LRP and other measures as detailed in the SIA. The company will internally monitor and report upon the progress of the LRP implementation. The company will undertake a completion audit of the livelihood activities which will identify any remaining gaps and corresponding corrective actions if applicable.



Policy and Management Systems: The company has a documented EHS management policy which sets forth its vision and mission with respect to EHS and social aspects. Sagar has adequately implemented integrated management systems (IMS) on quality, environment and health and safety at its plants which are certified as per the requirements of ISO 9001, ISO 14001 and OHSAS 18001. The policies, procedures and management programs and their implementation was noted to be consistent with IFC PSs.



The company has initiated EHS management procedures implementation in line with the requirements of the Sagar’s IMS. Post the proposed acquisition, as set forth in the ESAP, the company will complete implementation of an Environment, Health & Safety and Social Management System (EHSMS) for the plant and the mine. The EHSMS will also incorporate the requirements of IFC PSs and applicable WBG EHS guidelines and requirements. As part of the implementation of the EHSMS, the company will ensure implementation of procedures and management programs at least on: (a) pollution prevention and EHS monitoring; (b) resource efficiency especially energy efficiency including objectives and targets on resource consumption and improvement programs; (c) internal and external auditing; (d) solid and hazardous waste management; (e) chemicals management; (f) emergency preparedness and response plan including processes on regular inspection and maintenance of fire safety systems, training and mock drills; (g) management review; and (f) stakeholder engagement including ongoing engagement with affected communities.



Organization: Responsibility and authority for managing the EHS issues and risks is currently divided between the Manager- Process and Quality Control (PQC), and the Safety Engineer. The PQC Manager is responsible for management of environmental aspects including ensuring regular monitoring, whereas the Safety Engineer is responsible for health and safety aspects in the plant. Additionally, the Mines Manager (along with the supervisors) is responsible for health and safety management for mining operations. Community relations including the liaison function is currently directly being handled by the BCL p
lant head with support of the HR and administration personnel. The company will going forward employ a dedicated and qualified EHS representative to manage the EHS aspects linked to its operations. The company will also assign qualified staff/personnel who will be in-charge of the LRP implementation and other stakeholder engagement activities. These actions are defined in the ESAP.



Emergency response (including fire safety): As discussed in the section on occupational health and safety (OHS) under PS2 below, the plant was noted to have fire hydrant systems covering the CPP and coal yard (for the CPP) and fire extinguisher covering the entire plant areas. A fire alarm system has been provided in the CPP. However, currently the remaining area of the plant has not been covered under the fire hydrant systems and the fire hydrant of the CPP has not been maintained. Also, during the visit, the fire extinguishers were not operational due to lack of maintenance and no fire extinguishers have been provided in the colony. Therefore, as per the ESAP, the company will ensure that adequate fire safety systems (including fire hydrant, fire alarm and/or fire extinguishers) are provided in the entire plant (including coal storage yard and colony) and mine as per national standards and good international industry practices and timelines agreed with IFC. As part of the EHSMS processes, the company will ensure adequate inspection and maintenance of fire safety systems.



An on-site emergency response plan was available at the plant which defines the roles and responsibilities for various teams and processes to be followed during various emergencies. The plant and mine has identified and marked assembly points. The plant has an occupational health center (OHC) which has a doctor (who stays on-site) and 2 male nurses. There is also an ambulance to be used for medical emergencies. However, the plant does not conduct regular mock drills. Now with the proposed acquisition, the emergency response plan will also be re-drafted in line with that implemented at Sagar’s other plants. As per the ESAP and as part of implementation of the EHSMS, the company will ensure development and implementation of an emergency response plan. Also, the company will ensure regular training of required personnel through both classroom training and mock drills. Mock drills will be conducted to cover all potential emergencies and all shifts.



Monitoring and review: Though there are no structured monitoring and review processes, the company conducts quarterly stack emissions and ambient air quality monitoring. Also, the energy consumption is closely monitored. Regarding health and safety, the accidents and incidents are recorded. However, the company is not conducting any ambient air quality monitoring in the core and buffer zone (i.e. outside the facility). Also, no occupational health monitoring is being conducted.



To strengthen the monitoring and review processes, as p
er the ESAP and as part of implementation of the EHSMS, the company will develop and implement a specific EHS monitoring procedure for the plant which will at least cover; (a) environmental monitoring – stack emissions, ambient air quality, fugitive dust emissions, ambient air quality, treated sewage; workplace noise and dust, groundwater level and groundwater quality (in the plant and mine area as well as the project area as required under the ESMP); (b) OHS monitoring - workplace noise and dust monitoring, accidents, incidents, lost time injuries, and first-aid cases; (c) regular internal and external inspections and audits; (d) energy and water consumption; (e) EHS training; (f) regular inspection of fire safety systems; (g) specific frequencies for various monitoring activities and key performance indicators and tolerance limits on all environmental and OHS parameters; and (h) regular reporting to all stakeholders including affected communities, regulatory authorities, plant and company management. The monitoring and review processes will be in line with the applicable legal requirements as well as applicable WBG EHS Guidelines (General as well as those for Cement manufacturing). Regular monitoring and reporting will be conducted as per the procedure and reports will be generated with a summary of these indicators. Any corrective actions as required based on the monitoring results will be agreed and implemented.



Stakeholder engagement: As part of the ESIA and environmental clearance process, a public hearing was conducted in the project area to inform and gather feedback on the project and related activities. The feedback from these meetings have been included in the ESIA and are a part of the commitments that the company has made for carrying out development activities in the area.



Stakeholder and community engagement activities are directly handled by the unit/plant head who in turn is supported by personnel from human resource and administration department. Stakeholder engagement activities include regular meetings with the communities and local village representatives. However, these engagements are mostly informal and often driven by needs and specific demands of the communities/village representatives. These meetings are not properly documented and there is a lack of proper/systemic follow up/monitoring mechanism to ensure that the outcomes or agreed way forward are implemented and grievances resolved. The company, in response to community’s demands and expectations has implemented community development activities focusing on health, water and sanitation and livelihood support. The company also supports the maintenance and improvements of common property resources like the temple, village community hall, panchayat building etc.



As a part of the SIA and the LRP and based on community feedback, a list of community needs has been identified. The company will going forward, plan and implement community development activities. T
he company will also implement the stakeholder engagement programme and grievance redressal mechanism proposed as a part of the SIA. The implementation of these activities would be done in consultation with the community and the progress of the same would be monitored and reported as a part of the EHSMS.

The company currently employs 428 persons of whom 106 are on the direct payroll of the company and the remaining (322) are engaged by long term contractors (presently five). Currently the HR system and practices of the company are geared to meet the statutory requirements. The HR department (together with the administration and security department) is headed by a General Manager and supported by two personnel who manage the HR, administration and security functions of the company.



Post-acquisition, the company will adopt the Human Resource Systems and practices of the parent/sponsor company. To this effect, orientation training and strengthening of the HR department (including recent hiring of the general manager) has been initiated. Sagar’s HR Policies and Practices are generally consistent with IFC Performance Standards but these are applicable to employees only. The HR Manual for Sagar covers employee working conditions and terms of employment including amongst other aspects such as code of conduct, terms and conditions of employment, hiring and promotion/performance management policy and practices, employee welfare, leave, hours of work, overtime, emolument and benefits; misconduct and disciplinary procedures and employee grievance mechanisms, separation etc. Conditions of employment as well as wages and benefits are communicated to employees through employment letters and in the induction briefing given to employees at the time of joining. Sagar plants have a workers’ union to represent worker’s rights and collectively negotiate the engagement terms with the management. This union enjoys a cordial relationship with the plant management. The existing BCL plant does not have a workers union. However, the management supports the formation of the union and would facilitate its formation and accept/recognize its mandate to represent workers.



The company will develop, for this plant, additional policies compliant with PS 2 provisions particularly related to contract workers. This will include among other aspects; (a) development and implementation of a formal contractor oversight procedure to ensure ongoing legal compliance; and (b) bringing improvement in the grievance management system of the company including procedures enabling contract workers access to the grievance mechanism (to include collection of anonymous complaints, time bound closure of concerns/complaints, feedback to aggrieved workers/employees, documentation, analysis and reporting to senior management). The company provides housing and accommodation facilities to staff and employees and the facilities/amenities are in accordance with good industry practices and PS 2 guidelines. The company will strengthen its systems and processes to manage risks and concerns associated with supply chain (especially with respect to child and forced labour and occupational health and safety (OHS). These requirements are defined in the ESAP.



Occupational Health and Safety (OHS): As menti
oned above, the Safety Engineer is responsible for implementation of various health and safety procedures at the plant. All new employees and workers are provided a safety induction. Also, regular 5 minute tool box talks are conducted and a general safety briefing is provided every Monday. The moving equipment was noted to be adequately guarded and handrails have been provided at all locations in the plant. The bagging and packing lines are largely automatic and bags are filled and loaded through the machine. Therefore, manual handling and consequent dust emissions are minimized. All employees and contract workers are provided the required personal protective equipment (PPE) including hard hats, safety shoes and mask (depending upon the area). For high noise areas, ear muffs are provided. Usage and compliance with PPE requirements could not be verified at the site as the plant was not operating. The plant has a work permit system for dangerous works including work at height, confined space entry, hot work etc. Training programs have been conducted on electric safety, first-aid and firefighting. The plant also has a safety committee with equal representation of workers and management which was meeting regularly (till the plant was operational) to discuss safety issues. As per available data (being maintained for April 2014 to March 2015), there has been one lost time injury in October 2014 and 14 first-aid injuries. As mentioned above under PS1 and as per the ESAP, the plant will now implement an EHSMS in line with Sagar’s IMS and therefore, all the OHS procedures will be documented and strengthened.

Resource efficiency and energy supply: The main source of electricity for the plant is the coal based CPP. The CPP utilizes coal from various countries i.e. Australia, Indonesia and South Africa with approximate Gross Calorific Values (GCV) of 6,000 kcal/kg, 4,800 kcal/kg and 5,000 kcal/kg. The plant requirement is about 12 MW and currently the remaining power is supplied to the grid. The surplus installed capacity was provided in order to cater to the demands of any future expansion of the plant. The CPP reports to have consumed 78,000 tons of coal in the last year (April 2014 to March 2015) due to reduced production which is approximately 236 tons/day (considering 330 days of operation). The expected coal consumption at full capacity is expected to be 400 tons/day. The boilers in the CPP are Circulating Fluidized Bed Combustion (CFBC) type with air cooled condensers and a manufacturer’s guarantee for 84% efficiency. As per the EU’s Integrated Pollution Prevention and Control Best Available Technology Reference (IPPC-BREF) documents, this is considered as one of the best available technologies for power plants. Also, the air cooled condensers help in reducing water consumption for the CPP to about 615 m3/day whereas it would have been considerably higher with water cooled condensers. The plant also has three diesel generator (DG) sets (two 220 KVA and one 160 KVA), which are used as back-up for lighting and maintenance during CPP shutdown.



Similar coal as used in the CPP is also fuel for the rotary kiln and daily consumption is expected to be about 380 tons/day. The plant has been manufacturing PPC using fly ash and the proportion of PPC production (with respect to OPC) is expected to increase in the future from 70%-30% to 50%-50%. Also, the plant may produce PSC using blast furnace slag. Consequently, besides the reuse of waste from power generation and steel manufacturing operations, the plant will reduce energy consumption and avoid greenhouse gas emissions (GHG) due to lower clinker use per unit of cement produced.



Annual GHG emissions from fuel combustion (with plant and CPP operations at full capacity) are estimated to be 863,000 tons of carbon dioxide equivalent (tCO2e) per annum which includes 131,000 tCO2e per annum of emissions from CPP. The specific CO2 emissions are estimated to be 525 t/kg of clinker and 210 t/kg of equivalent cement (assuming a clinker cement ratio of 70%) which are in line with the WBG Guidelines for Cement manufacturing i.e. 400-525 t/kg and 150-350 t/kg of equivalent cement, respectively.



In terms of electric energy consumption, based on available data for financial years 2014 (ending March 2014) and 2015 (ending March 2015), the plant has been operating at total consumption of 106.54 and 114.6 kWh/t of equivalent cement. This is within the range specified in the WBG Guidelines for Cement manufacturing i.e. 90 to 150 kWh/t of equivalent cement.



Considering that the plant has never run at i
ts full capacity, the specific energy consumption is expected to improve in the coming months (post the proposed acquisition). Also, in line with the initiatives taken at other Sagar plants, the plant will implement the energy efficiency best practices and investigate the opportunities for further improvements.



Air Emissions: The principal point source of air emissions are the stacks attached to the coal mill, pre-calciner/pre-heater/kiln, cooler, cement mill and CPP. Also, stacks are provided at various bag filters provided for dust extraction units. Electro-static Precipitators (ESPs) have been provided for the cooler and CPP stacks whereas bag filters are provided at the other stacks. Bag filters have been provided at all potential dust generation points including the limestone crusher and along the belt conveyor at the transfer points. The principal emissions from these point sources are expected to be Particulate Matter (PM) from all these sources and as per available data, ESPs and bag filters have been designed for meeting the limit of 50 mg/Nm3 for PM and thus the plant is expected to meet the national standards as well as the WBG EHS Guideline limit for PM for existing kilns i.e. 100 mg/Nm3. This is evident from the quarterly stack emissions monitoring conducted by the plant (data available for last 4 monitoring rounds) for stacks attached to cement mill, coal mill, cooler, and pre-calciner/pre-heater/kiln where the PM emissions are reported to be below 50 mg/Nm3. Also, the on-line monitoring has been provided for PM, sulfur dioxide (SO2) and oxides of nitrogen (NOx) in the cooler stack and the CPP stack. As new standards have been notified for the cement plants (without co-processing) which are applicable from 1st June 2016, as per the ESAP, the company will upgrade its pollution control systems to meet the new emission limits for PM, SO2 and NO2 (i.e. 30, 100, and 800 mg/Nm3) and load based standard of 0.125 kg/ton of clinker (applicable from 1st January 2017). The Sponsor is also undertaking a similar upgrade at their other cement plants.



The emissions from the CPP are also controlled through an ESP. The monitoring results of emissions from the CPP as per quarterly stack emissions monitoring (data available for last 4 monitoring rounds) are within the legal limits as well as WBG guidelines.



As per the ESIA, the baseline air quality for suspended particulate matter (SPM), SO2 and NOx respectively was within the corresponding national ambient air quality standards (NAAQS) (applicable at the time of the ESIA). As per the ESIA, the predicted worst-case incremental impact on ground level concentration (considering both the plant and CPP emissions and taking into account that impact on air quality due to other cement operations in the area is already included in the baseline) of SPM, SO2 and NOx was estimated to be 5.02, 11.36 and 13.16 µg/m3 against the applicable limits of 200, 80 and 80 µg/m3, respectively which was withi
n the allowable 25% incremental impact as per WBG General EHS Guidelines and also the resultant concentrations were expected to be within the NAAQS and limits as per WBG General EHS Guidelines. The company has conducted ambient air quality monitoring at three locations within the plant area and the results are well within the NAAQS as well as limits as per WBG General EHS Guidelines. However, currently the company does not conduct any ambient air quality monitoring outside the plant area i.e. in the project area as defined in the ESIA. As set forth in the ESAP, and as part of the EHS monitoring procedure, regular AAQ monitoring will be conducted in the project area (both inside and outside the plant) in line with the requirements of environmental clearance and environmental monitoring program described in the ESIA. Based on the monitoring results, any required corrective actions for example, additional pollution control equipment, development of green belt etc. will be taken by the company.



Regarding fugitive emissions from mining operations, the company has provided water sprays at the hopper for the primary crusher as well as all transfer points and has provided a covered belt conveyor for transfer of limestone. Also, the company will ensure mining in areas as per the approved mining plan with required clearances from the mining lease boundary and nearest settlement (Gudipadu village located at 700 m from the mine boundary). Water sprinkling will be conducted during transport of limestone. As per the approved mining plan, the company will develop the green belt along the mine boundary starting with the boundary closes to the crusher and also within the plant areas. Also, to control fugitive emissions from coal handling, the company will ensure that the capacity of the coal storage yard is assessed (and expanded if required) and adequate coverage and dust suppression systems are provided.



As regards noise, as per the predicted noise levels (using a point source model) from the plant are expected to be less than 55 dB(A) without considering any attenuation factors. However, BCL will develop a green belt around the plant. Though no modelling has been carried out for the mining operations, the company will develop a similar noise barrier around the mine. Also, as part of the EHS monitoring procedure, the company will conduct regular ambient daytime and night time noise monitoring at the plant and mine boundaries to ensure compliance with the national ambient noise standards and WBG EHS guideline limits. Also, greenbelt development, discussed above, will support in compliance with the limits.



Water supply and wastewater: The plant’s water requirement of about 1,000 m3/day (including for the cement plant, CPP and domestic use) will be met through groundwater extraction. The company has obtained permission from the groundwater department of the Government of Andhra Pradesh for the same (dated 2009). The company will extract water at
the specified pumping rate so as to not impact other nearby users of groundwater. For the mining operations, initially the groundwater will be used and post-development of the mining pit, water from the pit will be utilized for dust suppression. However, considering that the Yadiki Mandal (where plant and mine are located) is one of the over-exploited zones, the company will agree with IFC on terms of reference (ToR) for development of groundwater management and sustainability plan for the plant. Based on the ToR, a plan will be developed by an external consultant (acceptable to IFC) within agreed timelines. The plan will describe various measures the company will take to reduce its groundwater abstraction including use of mine pit water for the plant, rainwater harvesting and reuse of rainwater and reuse of treated effluent from the sewage treatment plant (STP) as well as other offset measures outside the plant including groundwater recharge projects in the neighboring villages. The company will prepare an implementation plan for these measures and agree on timelines with IFC.



There is no process effluent. The sewage generated from the plant and colony is being disposed of in septic tanks. As per the ESAP and in order to comply with permit conditions, the company will install a Sewage Treatment Plant (STP) to treat domestic sewage generated from the plant and colony to meet national standards and WBG EHS guidelines. The treated effluent will be used for green belt development and dust suppression. Further, the company will also ensure that drinking water complies with national standards. Currently the storm water is discharged outside, however, the plant will also have a rainwater harvesting system with groundwater recharge/reuse (which is also expected as an outcome of the groundwater review discussed above). The company will ensure creation of settlement ponds before disposal (if required).



Hazardous materials and waste management: The storage and use of hazardous materials at the plant is generally limited to diesel (fuel for the generators, stored in underground storage tank), oils, lubricants and chemicals for the water treatment plant (for the boiler feed water). During the site visit, it was noted that oils and chemicals were stored in open without any secondary containment. As per the ESAP and as part of the EHSMS implementation, the company will prepare and implement a hazardous materials management plan in order to ensure storage, handling and use of hazardous materials on-site is in accordance with good industry practices including but not limited to: (a) secondary containment; (b) spill prevention and control; and (c) provision of protective equipment and training of all workers involved in storage, handling and use of these chemicals.



The explosives used in the mining operations will be stored and handled by authorized personnel in accordance with the permit conditions.



Material management: The raw meal is stored in
a 7000 ton capacity silo. Clinker is stored in a 25000 ton capacity silo whereas cement is stored in three 5000 tons silos. Fly ash is stored in a silo. Gypsum and slag are stored in covered sheds.



The main waste streams generated from the mining operations will be the overburden and screen rejects. The same will be stored temporarily and then used for the buffer greenbelt development. The dust from air pollution control equipment i.e. a bag filter and ESPs, will be recycled back into the process. The fly ash generated from the CPP will be stored in the fly ash silos and transferred pneumatically for PPC production. The oil containing wastes including waste oil will be collected and sold to an authorized recycler. Sludge generated from the STP will be used as manure for plantation/green belt development. Other recyclable waste generated in the plant e.g. paper, metal will be sold to recyclers and general solid waste is also disposed of through external agencies.



As per the ESAP and as part of the EHSMS implementation, the company will develop and implement a waste management plan in accordance with good industry practices at all facilities in order to: (a) identify all hazardous and non-hazardous wastes generated as per rules on hazardous waste handling and management; (b) label, segregate and store all hazardous and non-hazardous wastes; (c) dispose of hazardous wastes through authorized entities only; and (d) maintain records of all wastes disposed from site.

The company’s infrastructure and application of equipment comply with good industry practices. The nearest main road is that connecting Yadiki and Tadpatri, located at 6.8 km from the plant. From the main road, there is a single lane access road to the plant. There are no habitations or communities residing along the access road connecting the project site. However, this access road is also used by communities to access the main road linking to the nearest town. Impacts expected during operations are linked to increase in traffic with up to 200 trucks on the road daily mainly as result of incoming transport of raw material and dispatch of cement. To manage traffic related issues during operations phase, the company will develop and implement a traffic management plan to mitigate potential impacts and this will be consistent with IFC’s requirements. This will include measures like speed control, appropriate provisions for safe movement of trucks, deployment of traffic marshals, truck parking, minimizing dwell time and provision of facilities for drivers at the site amongst others. Strengthening of this road would also be taken if (as and when required) to ensure that it is safe for movement of the traffic and results in minimal impact on communities. Further, the company will ensure that drivers including those on contract are trained in safe driving techniques. The company will also undertake appropriate measures to reduce fugitive emissions and periodically monitor ambient air quality and noise levels in nearby communities/villages, and implement mitigation measures where required.



The company employs unarmed security guards to safeguard and protect its equipment and assets. The security guards are engaged through a registered agency and managed by two security officers engaged by the company. The company will going forward implement formal procedures related to screening of security guards past records, security personnel objectives and permissible actions, training in avoidance of abusive conduct, recording and investigating security incidents; investigation of bona fide complaints against security personnel and disciplinary actions. A grievance mechanism for aggrieved members of community or employees in the event of a violation of the code for security personnel will also be defined.



The mining operations for the project will include the use of explosives for blasting purposes. These explosives will be stored in an isolated and secured location and the blasting activities will be carried out by qualified personnel. The project will ensure that; (a) it employs low intensity blasting with micro-delays; and (b) monitor vibrations to assess impacts of blasting on nearby communities/households. In the event of an impact, the company will undertake steps to mitigate impacts including the option of resettling the households to another location. Such relocation (if required) will be done in consultation and support of the affected communit
ies and the village representatives.



Going forward, the company will develop and update/strengthen its onsite and offsite emergency management plan to cover aspects like natural hazards, explosion, arson and other security risks. The off-site emergency plan will be communicated to communities and stakeholders. Training (including mock drills) and awareness building activities will be undertaken to sensitize communities to risks and plans/measures in place to mitigate these.

The project enjoys a good and harmonious relationship with the nearby communities. The SIA/LRP report suggests and documents the strong support and goodwill that the project has in the affected village. It goes on to suggest that this goodwill is the result of employment and opportunities that the project has provided to the community. The company’s community engagement activities include regular meetings with the village representatives and the general community. These engagements focus around planning and implementation of community development activities and other needs of the village. The company continues to provide priority to local youth (eligible and willing village) in its employment process.

As mentioned above, the stakeholder and community engagement activities are directly handled by the unit/plant head. The company, in response to community’s demands and expectations has implemented community development activities focusing on health, water and sanitation and livelihood support. The company also supports the maintenance and improvements of common property resources like the temple, village community hall, panchayat building etc. The company will going forward, plan and implement community development activities based on the inputs from the SIA and LRP. The implementation of these activities would be done in consultation with the community and monitored both internally as well as externally.

BCL will disclose this ESRS at its website: http://www.bmmcements.in/esrs disclosure, as well as locally at the following addresses:
Vice President’s Office
BMM Cements Limited
Gudipadu (Village and Post)Yadiki Mandalam,Anantapur District,Andhra Pradhesh.Pin Code 515 408Phone 08558 200272


Any queries and/or comments about the project may be directed to:

Mr.Honnur Saheb V
Vice President
BMM Cements Limited
Gudipadu (Village and Post)Yadiki Mandalam,Anantapur District,Andhra Pradesh.Pin Code 515 408Phone 08558 200272

Broad Community Support is not applicable for this project

Title	Anticipated completion Date
Employ dedicated and qualified environment, health and safety (EHS) representative to manage the EHS aspects linked to the plant operations. Also, assign qualified staff/personnel who will be in-charge of the LRP implementation and other stakeholder engagement activities.	12/31/2015
Develop and implement an Environment, Health & Safety and Social Management System (EHSMS) for the plant and the mine (aligned to IMS), which includes (but is not limited to) the key procedures described in the Environmental and Social Review Summary document and incorporates the requirements of IFC PSs and applicable WBG EHS guidelines.	06/30/2016
(a) Share the implementation plan and purchase orders for providing fire safety systems covering the entire plant (including the colony). [to be completed by 31st July 2015] (b) Ensure that adequate fire safety systems (including fire hydrant, fire alarm and/or fire extinguishers) are provided in the entire plant (including coal storage yard and colony) and mine as per timelines agreed with IFC and in accordance with national regulations and good international industry practice.	12/31/2015
Upgrade the plant pollution control systems to meet the new emission limits for PM, SO2 and NO2 (i.e. 30, 100, and 800 mg/Nm3) and load based standards of 0.125 kg/ton of clinker (applicable from 1st January 2017) in line with the new cement industry emission standards. [to comply with load based standards by 1st January 2017]	06/01/2016
Conduct regular ambient air quality monitoring in the project area (both inside and outside the plant) in line with the requirements of environmental clearance and environmental monitoring program described in the environmental and social impact assessment report. The first round of monitoring results to be shared with IFC. Based on the monitoring results, agree with IFC on a time based action plan to implement corrective actions to ensure compliance with the IFC’s PS and WBG EHS Guidelines.	12/31/2015
(a) Share the implementation plan and purchase orders for installing a Sewage Treatment Plant (STP) to treat domestic sewage generated from the plant and colony to meet national standards and WBG EHS guidelines. [to be completed by 31st July 2015] (b) Install the STP as per timelines agreed with IFC.	12/31/2015
(a) Agree with IFC on terms of reference (ToR) for development of groundwater management and sustainability plan for the plant. [to be completed by 31st July 2015] (b) Based on the ToR, develop the plan through an external consultant (acceptable to IFC) within agreed timelines, describing various measures the company will take to reduce its groundwater abstraction including use of mine pit water for the plant, rainwater harvesting and reuse of rainwater and reuse of treated effluent from the STP as well as other offset measures outside the plant including groundwater recharge projects in the neighboring villages. [to be completed by 31st October 2015] (c) Prepare an implementation plan for these measures and agree on timelines with IFC. [to be completed within one month of receiving the report or 30th November 2015, whichever is later]	11/30/2015
Strengthen and update Human resource management system/practices especially linked to contractor oversight and monitoring to ensure statutory as well as PS 2 compliance (refer PS 2 section above).	07/31/2015
(a) Develop and agree on the provisions, budget and timelines with IFC for implementation of the Livelihood Restoration Plan for the affected land losers. [to be completed by 15th July 2015] (b) Full implementation of the livelihood restoration measures in line with requirements of the Livelihood Restoration Plan (LRP) [to be completed by 31st December 2016] (c) Carry out completion audit of livelihood restoration activities to assess compliance and gaps if any.	06/30/2018
Develop and implement; (a) a traffic management plan; (b) a vibration monitoring programme to assess impacts on surrounding communities; and (c) and Plans proposed around waste management / hazardous materials management etc.	07/31/2015
Ensure that the capacity of the coal storage yard is assessed (and expanded if required) and adequate coverage and dust suppression systems are provided.	06/30/2016