Dahej-SEZ, where the new facility under the project will be built, was established in 2010 spreading over 18,000 ha of land, as a part of Dahej Petroleum, Chemicals and Petrochemicals Investment Region (PCPIR) within Delhi-Mumbai Investment Corridor (DMIC). Government-led land acquisition for the entire SEZ was completed about 10 years ago, and there are no known instances of any legacy disputes or grievances related to involuntary displacement or compensation claims for the land associated with the project. The company has leased the land from Dahej-SEZ for 30 years, through a well-established transparent process, purely on commercial terms. Hence, PS5 (Land Acquisition and Involuntary Resettlement) does 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 that can be avoided or mitigated by adhering to generally recognized performance standards and guidelines.

 Environmental and Social Assessment and Management System

As per its risk management policy, the company has institutionalized the process for identifying, minimizing and mitigating (financial as well as non-financial) risks which are periodically reviewed. These include: securing critical resources; ensuring sustainable plant operations; cost competitiveness including logistics; completion of CAPEX; maintaining and enhancing customer service standards and resolving environmental and safety related issues.

As a part of regulatory approvals for the proposed facility in Dahej, CFS conducted EIA studies with the help of external consultants to identify the environmental impacts due to the proposed project and develop the appropriate mitigation measures, which are also included in the environmental permit conditions. The ESIA thus prepared and the subsequent environmental clearance is disclosed together with this review summary. Since the project is in a notified industrial zone, as per the Indian ESIA regulations, public consultations were not required for this project, as part of the permitting process.  

Policy

Through its CSR policy (https://www.camlinfs.com/docs/CSR%20Policy.pdf), CFS has articulated its commitment to grow in a socially and environmentally responsible way, while meeting the interests of its stakeholders. The company has also developed quality and food safety policies are part of its management systems described below. The company’s EHS policy is standardized at Tarapur, and building upon that as a template, customized EHS policies are developed across other facilities, in accordance with specific local situation and regulations.

Management Programs 

In India, CFS has implemented quality and food safety management systems certified compliant with ISO9001:2008 (for its manufacturing facility and R&D laboratories in Tarapur and Mumbai), and FSSC 22000 Food Safety System Certification (for Tarapur).

For management of EHS aspects at Tarapur facility, the company has developed adequate policies, procedures, organizational capacity, work instructions, monitoring program and training requirements. During the site visit to Tarapur facility a robust implementation of the management system and its documentation was observed across the facility.

CFS plans to implement and certify similar management systems at its proposed facility in Dahej once the facility is operational.

Organizational Capacity and Competency

CFS has full-time dedicated EHS team in place at its operational facility in Tarapur to manage the EHS related issues (including regulatory compliance), with defined roles and responsibilities. The EHS team, comprising of EHS Head and two safety officers plus other technicians, is supported by an independent external consultant hired on a retainer basis. The EHS team reports to the Global Senior Vice President (Manufacturing, Technical and Projects) at corporate level through the General Manager (Works) at the facility level. The EHS team as well as the external consultant monitor the EHS performance, conducts safety audits and ensure compliance with applicable regulatory requirements. Similar organization shall be replicated at the Dahej facility, once it is operational.

Emergency Preparedness and Response

For its Tarapur site, the company has developed risk management programs covering fire, chemical spill, personal injury during work, natural calamity, sabotage risks. The risk assessment is done as part of the preparation of the On-site Emergency Response Plan, and necessary arrangements are made to control fire, chemical spill and avoid injuries or any harm to life.

Accordingly, potentially hazardous areas have been identified and evacuation routes and assembly points have been designated and clearly marked. An emergency control center has been designated at the security office at the main entrance, and adequate fire-fighting systems, including fire hydrants, are installed across the facility. Mock drills are conducted regularly to ensure the emergency preparedness.

CFS has an on-site first aid and occupational health center, in addition to its own ambulance, for any emergencies. As the Tarapur factory is in a government approved industrial area, an off-site emergency control plan has also been prepared by the local government and industrial estate authorities; and CFS together with other neighboring industrial units play an active role, as members of Mutual Aid Response Group.

Similar emergency preparedness and response systems, including monitoring equipment for toxic gases, dust and liquids, plans will be developed and implemented at the proposed new facility under the project, at Dahej.

Monitoring and Review

CFS has developed comprehensive monitoring program and a set of key performance indicators (KPIs) for the operational and EHS aspects of its facilities. Accordingly, the company regularly monitors its stack emissions and ambient air quality, workplace air quality and noise levels, process effluents, safety statistics, as per the applicable legal requirements and its own monitoring calendar. The company’s workplace monitoring covers relevant parameters, such as presence of hydrocarbons, percentage of oxygen, illumination and noise. The basic monitoring and analysis capability (including equipment) is available in-house, in addition to the monitoring services provided by external vendors. Moreover, as part of the project, the company will install online monitoring equipment for wastewater and stack emissions at the proposed new facility at Dahej.

 CFS currently employs about 320 employees across its facilities in India, and about 260 employees overseas, viz. Italy (about 48 employees), Mexico (110), China (70), Brazil (20) and the USA (12). In addition, the company employs over 290 unskilled workers in India through three manpower agencies on contractual basis mostly for non-core activities at its facilities such as forklift operators, housekeeping, gardener, material handling, and a few skilled workers. Currently women employees constitute less than 10% of the regular workforce, with all of them working in corporate office and R&D labs.

For the proposed project in Dahej, the company expects to employ about 150 regular employees including about 30 casual workers on contract basis, once the facility reaches its normal production levels.

Working Conditions and Management of Worker Relationship

Human Resources Policies and Procedures

CFS’s corporate HR department oversees the HR management across its facilities in India, supported by the HR teams at each facility. The HR management in its overseas facilities is handled by respective team in accordance with the local labor law requirements.

In India, the HR team comprises of seven full time employees in corporate office and Tarapur facility, and is responsible for key aspects of HR management such as: hiring, training, performance appraisal, compensation and benefits, rewards and recognition, career development, and ensuring compliance with the statutory requirements as well as CFS’s HR policy.

Documented HR policies and procedures are in place covering the regular employees, which are consistent with the national labor laws and PS2 requirements. The terms of employment and other details about the HR policies are communicated to the employees through a formal appointment letter and a staff handbook provided to all new recruits as part of induction and onboarding.

The company operates 24x7 in three shifts of 8 hours each. Overtime is paid as and when needed, with the payment at double rate as per the statutory requirements. In addition to salaries, the company provides other benefits such as subsidized canteen, transportation allowance and medical insurance. 

The company’s HR department also monitors the labor contractors and ensure that they meet all the statutory requirements regarding the contract labor. Specifically, it closely monitors and ensures that the wages are duly paid by labor contractors/manpower agencies to the casual workers, and complies with other requirements such as payment of provident fund contributions.

Non-Discrimination and Workers’ Organization

The company’s HR policy articulates its commitment to non-discrimination and freedom of association. The company also has formal and documented Sexual Harassment and Whistle Blower Policies approved by its Board, to ensure that there is no discrimination.  A recognized trade union is active at CFS’s Tarapur facility, and the company engages with this union from time to time. As per its policy to respect the freedom of association of the workers, CFS shall not prevent formation of a workers’ union at the planned facility in Dahej in the future.

Training and Human Resources Development

The company’s HR and EHS departments develop training plans covering regular as well as contract employees, and training budget is allocated accordingly. EHS issues form an important part of CFS’s training calendar, including induction training, which is mandatory for each new employee.

In addition, internal and external trainings are organized based on the specific training needs of the workforce, delivered as per training calendar and the records are maintained.

Grievance Mechanism

Currently, the employees of the company can share their grievances through their supervisors or the HR department; however there is no formal process for receiving, recording, handling and resolving grievances. Therefore, the company, as per ESAP #1, will develop and implement a formal grievance handling procedure which will: specify different channels of receiving grievances from regular employees as well as third-party workers; formalize a channel to allow grievances to be presented anonymously; document procedures for handling and resolving the grievances at different levels of the organization; and provide feedback to the concerned employee as well as the management. The company will communicate the updated grievance mechanism to all the employees and third-party workers through awareness campaigns as well as by updating the HR manual and staff handbook.

Occupational Health and Safety

The company has established robust systems and procedures to manage occupational health and safety aspects of its operations including process/equipment safety and workplace safety for its employees.

For process safety, the company’s EHS and operational departments regularly evaluate the manufacturing process from EHS points of view to identify hazards and determine remedial measures. This includes: (i) control of hazards using engineering systems and incorporating safety features in the process equipment and (ii) process control by performing process checks and controlling of critical process parameters.

For workplace safety, the company has developed standard requirements for safety training, mandatory use of personal protective equipment, work permit system, safety committee and safety audits, monitoring of accidents and near misses etc.

Further, the company reviews the Material Safety Data Sheets (MSDS) for the chemicals used in the process, for identifying health hazards at the workplace; and regular workplace monitoring is carried out to assess any impacts on the employees. The company’s industrial hygiene and health program includes pre-employment and periodic medical check-ups.

Workers Engaged by Third Parties

For all contract workers, recruited through labor contractors, CFS ensures their compliance with the requirements of Contract Labor Act provisions, through relevant clauses in contracts and also through regular monitoring of contractors by its own HR team. The workers engaged by the contractors are required to undergo safety training and follow all the EHS related standard operating procedures. For the proposed facility in Dahej too similar arrangements will be implemented.

Supply Chain

The main raw material for the manufacture of diphenols (HQ & Catechol) are Phenol and Hydrogen Peroxide which are available domestically as also in the international market, mainly from China. Moreover, a leading chemicals manufacturer is setting up a Phenol and Acetone manufacturing facility in Dahej SEZ itself, and hence can be readily and easily sourced from within the SEZ. The other critical raw material is the catalyst which is patented product of the company’s subsidiary CFS Europe SpA and will be procured from them. All the raw materials are highly specialized chemical and produced by reputed international manufacturers, with highest standards of quality and safety. Moreover, globally this industry is strictly regulated owing to intrinsic EHS risks. As such, E&S risks related to OHS or biodiversity as envisaged by the IFC PSs are not expected in the supply chain of CFS.

 IFC’s assessment considered the Company’s operations regarding resources consumption (water, energy, fuel), efforts to optimize resource inputs, waste minimization and management practices as well as the storage and handling hazardous materials used in the construction and operations of facilities.

For all the processes the technology that will be applied has been developed by CFS or its subsidiaries, and in all the cases the technology has been selected considering material and energy saving and high quality of the final products.

Resource Efficiency

CFS has included in the design of its new facility in Dahej, several resource efficiency / cleaner production measures, such as:

-          The use of heterogeneous catalyst, which is developed in-house, instead of acidic catalyst for di-phenol process, together with Fixed Bed Vapor Phase technology instead of dimethyl sulfate (green chemistry);

-          Fully automated process plant to ensure better control, improved housekeeping and prevention of losses and pollution.

-          To further reduce the handling losses and minimize risks of spillage during transportation, the company is planning to procure raw materials through pipelines from neighboring industries within the SEZ.

-          All operations are designed to be continuous instead of batch process, to enhance resource efficiency.

-          At least 98% solvent recovery as an integral part of the project design (Table 2.3 in the EIA report).

-          Efficient boiler systems, with additional accessories for improved energy efficiency, including installation of cogeneration unit. The company is exploring the possibility of additional investments for using biomass for generation of thermal energy.

-          Segregation of wastewater, recycling of treated effluent for gardening and recycling 90% of condensate from effluent treatment.

-          Waste to energy using plasma technology instead of incineration. The waste heat from plasma plant is used in sodium sulfate recovery plant.

As a part of the project, CFS is installing a combined steam and power cogeneration system with capacity of 50 tons per hour (TPH) steam and 4.4 MW power generation at Dahej facility. This is considered to be  more efficient than only having a steam boiler, as the power thus produced from the cogeneration system entirely meets the electricity requirement for the proposed project. As and when needed, the company will procure backup power from Torrent Power, an independent power producer in the area.

GHG Emissions

The GHG emissions from the project comprise of those due to the coal combustion in the boiler of the cogeneration system (100 tpd or 33,000 tons of imported coal per year) used for steam and electricity generation. This will result in estimated GHG emissions of around 84,000 t CO2e/year.

Pollution Prevention

Air Emissions and Ambient Air Quality

The flue gas emissions from one combined 45 m high stack for the steam boiler of the cogeneration system as well as the thermo-pack (10 million kcal/hr thermic fluid heater) will pass through the cyclone separator followed by an electrostatic precipitator (ESP).  The process emissions will be from six stacks for reactors, one stack for the raw material storage and one stack for the plasma gasification process. There will be a provision of water scrubber followed by carbon adsorption tower to control volatile organic compounds (VOCs), as well as hot gas filter to control other parameters (such as: HCl, SO2, CO, TOC, HF, NOx, total dioxins and furans) in accordance with the environmental permit conditions and WBG EHS Guidelines for Large Volume Petroleum-based Organic Chemicals Manufacturing.

As part of the ESIA study, ambient air quality monitoring was carried out during period of March 2015 to May 2015, twice a week for a period of 12 weeks, to assess the baseline air quality. Based on data obtained, it was observed that, during the study period, the value of PM10 at monitored locations ranged between 85-63µg/m3 while the value PM2.5 fluctuated in the range of 44-26µg/m3. SO2 and NOx were observed to be in the range of 21-8µg/m3 and27-15µg/m3respectively, while HCl and HF were found to be Below Detectable Limit. The value of CO (Carbon Monoxide) was found to be in the range of 0.8-0.5mg/Nm3, while the value of TOC (Total Organic Carbon) was found in the range of 1-0.4 mg/Nm3. The value of VOC at monitored locations ranged between 1- 0.5 ppm. The average concentrations of PM10, PM2.5, SO2 and NOx were observed to be within prescribed limit at all locations.

Considering the number of hazardous chemicals that will be stored at the proposed facility (acetone, methyl isobutyl ketone, methanol etc.), and the risks and impacts due to fugitive emissions of those chemicals on the ambient air quality and nearby communities, the company will conduct a non-methane hydrocarbons (NMHC) modelling to estimate toxic VOC fugitive emissions from tank farms and reaction devices and to calculate the VOCs concentrations along the fence lines and at the residential areas (ESAP#3). Based on the results of this exercise, CFS will develop an action plan/necessary mitigation measures to manage these risks and impacts.

Water Consumption and Wastewater

The fresh water requirement for domestic and industrial purposes shall be met through the water supplied by Dahej-SEZ. The estimated water consumption will be about 640 m3/day, of which about 430 m3/day will be used for industrial purposes and the rest will be for domestic use.

The industrial wastewater generated from the process will be first segregated into two different streams: (i) with high total dissolved solids (TDS) and (ii) low TDS stream. The high TDS stream will be sent to sodium sulfate recovery unit, from where 430 m3 of water will be recovered and recycled back in the process. The low TDS stream of about 350 m3 will be treated in CFS’s on-site effluent treatment plant (ETP). In addition, the domestic sewage (about 10 m3/day) will be treated in a high efficiency packaged sewage treatment system. About 250 m3 of the treated effluent will be used for gardening and remaining about 100 m3 will be sent to the drainage network of the industrial zone as per the permit condition. It will then be sent to Dahej - Vilayat common effluent treatment plant outside the SEZ, from where it is discharged to the sea in compliance with local regulatory requirements for the entire industrial zone. 

Wastes

As per the ESIA study, hazardous waste generation from the proposed facility in Dahej will include: spent carbon from ETP, discarded carboys, barrels, bags and such containers, spent carbon, spent catalyst, distillation residue, and used/spent oil, which will be disposed of through a licensed contractor as per the environmental permit conditions.

Adequate controls for the storage and handling of the waste will be put in place. The designated hazardous material storage room will be constructed as per regulatory requirements for safe storage of hazardous waste till disposal. The quantities of solid waste thus generated and disposed of will be monitored and reported to the regulatory authorities through annual environmental statement.

The proposed project site is in industrial area, connected by wide national highways. Hence the impact of vehicular movement on surrounding communities is expected to be minimal. While some of the vehicular movement will be for transporting small quantities of hazardous materials, most important raw materials (phenol and hydrogen peroxide) will likely be procured by pipeline from the neighboring facilities in SEZ.

The fence line of the new facility in Dehej, while located in the industrial zone, is about 300 m from the nearest receptor of the nearby residential community (Luvara village); and the project may pose risks to the health and safety of this neighboring communities. EHS risks to the surrounding communities due to the project have been assessed (including quantitative risk assessment - QRA) as part of the ESIA (Chapter 6).  The risk assessment considers worst-case scenarios such as explosion, fire and leaks based on the facility layout and technology to be used and, accordingly, the needed mitigation measures are proposed. 

As per the buffer zone (and green belt) requirements in the permit conditions, the production areas of different plants in the SEZ are at safe distance from each other and from the nearby community. Mutual aid coordination mechanism is already in place.

Emergency Preparedness and Response

Building upon the emergency response plan for its Tarapur facility, NMHC modelling undertaken as per ESAP#2 and the QRA conducted as part of EIA, the company will develop emergency response plan and procedures for its Dahej facility (ESAP#3).  This emergency response plan will include the communication to and training of the nearby communities related to response to emergencies and will involve the local authorities in the development of community preparedness planning in the event of a major accident. 

Security Personnel

The company employs unarmed security from licensed security agencies. The security guards are trained in emergency response, firefighting and first-aid as they are expected to play an important role in case of emergencies.

As per CFS’s published CSR policy, the company implements projects for promoting healthcare, education (including special education and employment enhancing vocation skills) especially among children, the differently abled, tribal communities and for reducing inequalities faced by socially and economically backward classes. The company’s annual report includes a section on its CSR activities.

For the establishment of its new facility in Dahej as part of this project, the company has already started engaging with local stakeholders – especially regulatory authorities, suppliers, and contractors; so far, there has been limited engagement by the company with the local communities, including Luvara village.

As per ESAP#4, CFS will develop a documented stakeholder engagement plan for the project, including specifically, the provision of EHS information and emergency response plan to stakeholders, especially to the neighboring community. Moreover, as part of the stakeholder engagement plan, the company will establish a channel for the nearby communities to share their grievances and concerns related to EHS issues (during construction and operation); and will establish a documented procedure for handling the grievances internally.  

Contact Person: Santosh Parab

Company Name:  Camlin Fine Sciences Limited

Address:  F/11-12, WICEL, Opp. SEEPZ, Central Road, Andheri (E), Mumbai-400093, INDIA

Email:   santosh.parab@camlinfs.com

Phone:  +91-22 67001000 Ext. 202

Facsimile: +91-22 28324404