Deepak’s main manufacturing site, Taloja complex, is located inside the industry zone of MIDC. The proposed IPA II project is located inside Deepak’s Taloja complex. All other facilities for fertilizer business and nitric acid manufacturing processes are located in Taloja or other Deepak sites, all of which are within well-developed industrial zones. There is no community near any of these plants. Therefore, PS5: Land Acquisition and Involuntary Resettlement, PS6: Conservation and Sustainable Management of Living Resources, PS: 7 Indigenous Peoples, and PS8: Cultural Heritage are not considered to be applicable to the project. 

   The key E&S issues and risks associated with this project include: Deepak’s corporate E&S management systems and procedures to ensure consistent E&S performance at different plant sites, occupational health and safety management during construction of the project, operational hazards and process safety management during operations; resources efficiency, pollution prevention and control measures at various facilities and for the proposed project; effective management of all contractors during constructions as well as during operations stage and road transportation of hazardous materials and related community health, safety and security issues.

Mitigation measures for the potential E&S impacts have been identified and are incorporated into an Environmental and Social Action Plan (ESAP). The potential adverse E&S impacts of this project are considered few in number, of limited significance and readily mitigated through the company’s existing robust systems and procedures. This is therefore a Category B project according to IFC’s Policy on Environmental and Social Sustainability.

    Environmental and Social Assessment and Management System

Deepak hires external experts to conduct E&S assessments for its projects according to Indian laws/regulations and its own technical standards. Most of its operations (viz. those in Taloja Complex) are certified to management systems compliant with international standards, such as: ISO 9001 (quality), ISO 14001 (environment), and OHSAS 18001 (occupational health/safety). In addition, at corporate level, Deepak has its own environmental, occupational health/safety (OHS), and process safety standards, which meet Indian regulatory requirements.

For the development of new projects, Deepak has operational procedures as well as project teams to look at the inception, feasibility, mobilization and construction stages of the project. These operational procedures will be structured and consolidated to ensure management of E&S risk in a consistent manner for the upcoming project. As indicated in the ESAP 1, the company will extend its existing environmental and social management system (ESMS) to cover all its current and future facilities, to address environmental, social, occupational health and safety issues, consistent with IFC Performance Standard (PS) requirements, to ensure regulatory compliance as well as that with the World Bank Group (WBG) General EHS guidelines and sector specific EHS guidelines, as applicable. The ESMS will cover aspects such as internal and external communication, the standard operating procedures (SOPs) for hazard identification and risk assessment (HIRA), emergency preparedness and response procedures, waste management, resource efficiency, etc. and various documentation formats to ensure uniformity in EHS management practices across Deepak’s units. The company will consistently implement the ESMS requirements across all the existing units of Deepak as well as the proposed facilities in the future, including those under the project.

Policy

DFPCL’s E&S policy reflects its strong commitment to environmental conservation and employee health and safety. Its environmental policy requires Deepak to take steps towards environmental conservation and protection by curtailing the generation of pollutants to eliminate and minimize end of pipe treatments. (https://www.dfpcl.com/about/safety-health-environment/). The policy promotes certification of its E&S management system and reduction of pollution loads.

Identification of Risks and Impacts

EHS risks for any new projects are initially identified and mitigated during preparation phases through Deepak’s internal procedures of environmental impact identification and assessment, and health risk assessment. External experts are then contracted for comprehensive environmental and social impact assessment as required for regulatory permits. During operational phases, EHS risks are identified through formalized internal/external auditing programs for E&S performances and informally through frequent inspections. All these audits and inspections are summarized with corrective actions to mitigate the non-compliances.

In case of any new greenfield facility to be developed, company will conduct EIA as required by the local regulations, or a full scale environmental and social impact assessment, a limited or focused environmental and social assessment, or straightforward application of environmental siting, pollution standards, design criteria, or construction standards.

Deepak has finished an environmental and social impact assessment (ESIA) for IPA II project according to local regulatory requirements. As indicated in the ESAP 2, Deepak will contract external experts to review the ESIA against IFC Performance Standards (PS) to identify any gaps and prepare ESIA addendums to meet all IFC PS requirements. The ESIA addendum should be finished before equipment installations. The ESIA and addendums will include an environmental management plan (EMP) and a stakeholder engagement plan. Accordingly, once the ESIA/addendums are finalized, Deepak will disclose them locally as well as on its website as part of its ongoing stakeholder engagement.

Management Programs

EHS management teams at each major unit are responsible for educating, training and motivating employees to understand and comply with corporate EHS performance procedures. Systematic monitoring of environmental performance and process safety measures is in place for air emissions, liquid effluent controls, waste management, occupational health/safety tracking, and process safety management. Non-conformities to the technical standards are monitored and followed up by the management. While there are sufficient E&S procedures for individual EHS issue, Deepak is working to establish a corporate E&S management system to ensure performance consistency at each operation units, especially as more plants are being built outside of its main Taloja complex. As indicated in ESAP 1 and as part of this investment, Deepak will establish a functional corporate level E&S management system to oversee and manage E&S performances at all sites and units across the group, including the planned new production sites.

Organizational Capacity and Competency

There is a dedicated Board director who oversees the E&S operations. At the main Taloja complex, an EHS head manages the daily EHS operations. The corporate EHS head will report to the president for manufacturing, and is supported by EHS team at Taloja complex. There are fulltime EHS heads or part-time coordinators at each operation units depending on the scales of EHS works. All these EHS heads and coordinators report to respective unit heads. The E&S management at Taloja complex is supported by a compliance software system, which was developed by a prestigious management consulting firm. The compliance software system notifies each responsible manager when identifying a statutory non-compliance in the E&S reporting system, which allows the E&S management to take an early and effective mitigation. Similar EHS management structure will be established for the proposed new facilities to be developed under the project.

Emergency Preparedness and Response

Fire prevention is covered as part of routine safety inspections. Any work which may result into heat, sparks, flames are done under the permit system and during such jobs close supervision is ensured. There are sufficient firefighting equipment and sufficient firefighting water/foams onsite, which are all properly maintained. Toxic/flammable gas sensors and automatic fire detectors are installed at all critical locations with connection to central operation room. Automatic sprinkler systems are installed for all fuel/flammable chemical storage tanks. Each site has its own dedicated fire-fighting team with necessary equipment.

Deepak has well documented emergency response (ER) plans as required by corporate safety procedures. At each unit, there are quarterly ER drills and annual comprehensive ER/evacuation drills. ER scenarios are drilled to ensure employees are familiar with various emergency situations. For the comprehensive ER/evacuation drills, industry zone fire brigade, EHS managers form neighboring plants, and nearby hospitals are invited to participate. Deepak has not had any major process safety accident or incident in recent operational history.

At MIDC industry zone, chemical companies join mutual aid response group (MARG) to coordinate emergency response in the industry zone. MARG holds quarterly meetings and conduct annual joint drills to allocate the maximum ER resources in case of a real emergency.

Monitoring and Review

Deepak has instituted comprehensive environmental and OHS/process safety monitoring programs with key performance indicators (KPIs). The KPIs include point source emissions, workplace air quality/noise levels, effluents, ambient air quality/noise levels, waste handlings/disposals, near-miss, recordable accident, fire, release/spillages of chemicals and damage to environment, emergency preparedness, training to employees, permit system, etc. EHS performance is summarized through weekly/monthly reviews of KPI performances. A monthly E&S compliance report is prepared by the EHS heads of each facility, for the review of president of manufacturing and the entire management team. Action plans are proposed in the monthly report with responsible parties and mitigation deadlines. The monthly report also reviews the implementations of the previous action plans.

Besides routine/random EHS inspections, EHS heads also organize comprehensive annual EHS/process safety audits, which are conducted by the internal and external auditors alternately. The internal auditors consist of EHS and manufacturing heads/engineers from other units, while the external auditors are EHS/process safety experts from other industries. At current stage, the dedicated board member oversees all the monitoring and review work on EHS issues. After implementation of ESAP 1, the corporate EHS unit will lead all the monitoring and review work. 

   The HR function is structured at two levels: Corporate level at Pune headed by President HR and dedicated HR team headed by assistant vice president (AVP)/ general manager (GM)/ Head HR at each plant. The corporate HR team at Pune has dedicated verticals for different functions such as organizational development, talent acquisition, operations, industrial relations, change management, HR processes, etc.

As of December 2018, STL has a staff strength of 1133 (including management & non-management staff), in addition to about 580 contract workers (including contract workers/ loaders on daily wage, and third-party employees). Across all the categories, both at STL as well as Deepak group level, the percentage of women staff/workers remains between 2-3 percent. Approximately 75 new employees and contractors will be hired for IPA II and other expansion projects.

Human Resources Policies and Procedures

Deepak’s HR policy is applicable to all units and STL being 100 percent subsidiary of DFPCL follows the same corporate HR policies and procedures. The same policy will apply to the proposed project once it becomes operational. The HR policies and procedures are consistent with the requirements of Indian labor laws and the requirements of IFC PS2.

HR Policies and procedures are maintained on an internal portal named “I manage” which is accessible to all the employees. The HR processes include the job description for the various positions including purpose and roles and responsibilities of the job, organization structure, outcomes/value addition, financials & work relations. The leave policy captures annual leave (includes privilege leave, sick leave & casual Leave). The company has a 100 days onboarding program to ensure that the policies and processes are well communicated to the employees.

Working Conditions and Term of Employment

The working condition of the all the employees in the management cadre of Deepak staffs are guided by the HR policies. The joining letter for the management staff captures employee grade, various allowances, medical benefits, leave, provident fund (PF), and such other benefits, increments, retirement age, 6-month probation period, as well as house rent allowance (HRA), choice pay, performance award, medical expense reimbursement, mobile phone reimbursement, provident fund and gratuity, superannuation (wherever applicable), leave etc. The workmen (non-management staffs) are guided by the standing orders as per the industrial employment standing orders act, 1946; as well as governed by the applicable union agreement for the workmen. The same policies will be extended to the facilities being developed under the project.

Workers Engaged by Third Parties

The contract workers are guided by the service contract agreement signed by the company with the various contractors hired by the respective units. The HR department at respective plants have detailed checklist to ensure local labor law requirements are complied by the contractors. As indicated in ESAP 4, Deepak will, as a part of the EPC and operations and maintenance (O&M) contracts for the proposed project, require the respective contractors to: identify all compliance requirements under the national labor and employment laws and PS2 covering its employees and sub contractors’ workers including on terms of employment, minimum age, non-discrimination and equal opportunity, freedom of association, worker accommodation and occupational health and safety; put in place a grievance mechanism for the EPC contractor’s employees and sub contractors’ workers; and implement procedures to demonstrate compliance with the national laws and Deepak’s labor standards.

Overtime Hours:

Currently, the company practices paying of overtime at double the normal wages as stipulated under local regulatory requirements. Going forward, the company will document its overtime policy, for workmen or contract workers working at various units of Deepak consistent with the applicable regulatory requirements and shall provide the information to the employees and workers as per IFC PS2 requirements.

Labour Accommodation: 

The company has provided staff quarters to workmen in Taloja (especially in the early years where no nearby residential areas were available near to industrial area); however, this facility is not much in demand and both staff and workmen prefer to arrange their own accommodation. No accommodation facility is provided to the contract workers during operations stage.

Workers’ Organization

There is no restriction on freedom of association at Deepak and recognized worker unions are active at different operational units of Deepak for its regular as well as contracted workforce.

Non-discrimination and Equal Opportunity

Deepak has a policy of equal opportunity and diversity at workplace. The policy mentions that Deepak is committed to the principle of equal employment opportunity for all employees without any discrimination on the grounds of age, color, disability, marital status, nationality, social or ethnic origin, race, religion or belief, HIV status, gender, sexual orientation. The Company strives to maintain a work environment that is free from any harassment based on above considerations. This equal opportunity policy is subject to applicable regulations, qualifications and merit of the individual.

Grievance Mechanism

The company has put in place a procedure for handling grievances from its employees. The grievances are handled by unit committee (unit HR and unit Head), sector committee (sector HR Head and Sector Head) and central committee (President HR and Executive Director). The grievances are to be resolved within 5 working days by each committee with provision for automatic escalation to next level committee, if not resolved within 5 working days. The mechanism provides for anonymity to be maintained depending on the nature of the grievance. Employees are expected to register his / her grievance through online system or through the grievance redressal form to be routed through Manager. The company has a policy to prevent sexual harassment at work place and has put in place the Internal Complaints Committee (ICC) in line with The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013; the company as indicated in ESAP 3, will form these committees at unit level. As indicated in ESAP 3, i) the company will update grievance handling procedure (covering contract workers as well) in accordance with the requirements of this performance standard, The grievance redressal mechanism will also have a provision for tracking of the grievances and reporting back to the senior management on the status of grievances addressed/ pending or could not be addressed; and ii) gradually constitute ICC at various units (already existing at corporate level). 

Protecting the Work Force

The company has a policy on prohibition of child labor and forced labor at work. The policy prohibits employing any individual who have not completed 18 years of age and also prohibits the use of forced labor and no employee is made to work against his/her will. No child labor was reported during site visit to Taloja operational facility.

Occupational Health and Safety

All major manufacturing units at Deepak are certified by OHSAS 18001. There are routine OHS training, including new employee training and annual refreshers. Job hazard analysis (JHA) is conducted and updated for each operation position. Based on JHA, OHS operation procedures are developed and proper personal protection equipment (PPE) is provided. The OHS procedures (e.g. PPE usage) are enforced strictly. The OHS management is also implemented through a set of safety tools and methods, including periodic inspections, walk through/observation, peer-to-peer behavior check, etc. Deepak has key performance indicators targets (e.g., total recordable incidents, work permit review, etc.) for OHS performance. Contractors working at Deepak sites are subjected to the same company OHS rules. The total recordable incident rates (TRI) for employees and contractors are lower than the industry averages.

Deepak has a comprehensive set of workplace air quality and noise level monitoring, which include dust, ammonia, NOx etc., for all important operation positions. The monitoring data shows that the company is compliant with local regulatory requirements and good international industry practices.

The main Taloja site is crowded and OHS management is difficult for maintenance and renovation/expansion constructions. As indicated in the ESAP 5, Deepak will develop an enhanced contractor OHS management plan to prevent serious OHS accidents during the IPA II and other expansion/new project constructions. The plan should include major components of construction OHS management, including, but not limited to, reasonability, prevention, monitoring, reporting, mitigation, medical services, ER etc.

Supply Chain

The raw materials are mainly from other large chemical companies. Child labor or forced labor are unlikely.

    Resource Efficiency and Efficiency Projects

Natural gas and electricity are the main energy sources for Deepak’s operations at Taloja, which accounts for more than 80% of current energy consumption. Natural gas is supplied thorough pipeline, and electricity is purchased from national grid. Natural gas is primarily used for internal power generation, heating/steam, and as the raw material for ammonia and methanol production. Small quantity of balance steam (and associated power) is supplied by coal-based co-generation system. Deepak has installed initial phase of 300 kW solar power to compensate for some fossil fuels usage. Going forward, more solar panels will be installed at other Deepak plants in the future.

Energy, water, and raw material consumption/loss are monitored monthly at Deepak. Based on these monitoring data, Deepak generates its own efficiency criteria based on different equipment configurations. External experts are contracted to conduct resource efficiency audit periodically. Efficiency opportunities are also identified through these audits for future implementation, normally together with equipment retrofits or production expansions.

The energy efficiencies for nitric acid, ammonium nitrate, calcium ammonium nitrate, etc. meet good international industry practices (GIIP). However, the energy efficiency for ammonia is slightly lower than GIIP. Deepak is working on feasibility to increase ammonia production capacity at Taloja complex by 15% and increase energy efficiency by 6%. After this improvement, the energy efficiency for ammonia production will meet GIIP. Reverse osmosis (RO) is adopted for further treatment of the wastewater and recycle. Deepak is in a process to get permission of connecting onsite effluent treatment plant discharge to downstream of the central effluent treatment plant. If approved, Deepak can recycle more than 50% of waste water.

GHG Emissions

IFC investment will not incur additional GHG emissions on account of the maintenance capex and working capital requirements of the fertilizer business. The new IPA II project will generate approximately 197,000 tons of equivalent CO2, mainly from fuel consumption and electricity purchase.

As part of this project, Deepak will install N2O catalyst conversion devices for all existing nitric acid manufacturing processes in Taloja. The small nitric acid process at Srikakulam site is in the process of closing down with increased capacities of other nitric acid plants. In line with ESAP 6 and 7, Deepak will propose a N2O catalyst conversion plan and install the conversion devices at four existing nitric acid manufacturing processes at Taloja complex by the end of 2020.

These N2O conversion devices will reduce approximately 900,000 tons of equivalent CO2. Besides, Deepak is also committed to install N2O catalyst devices for planned nitric acid manufacturing processes, which can reduce GHG emissions up to 700,000 tons of equivalent CO2.

Pollution Prevention and Compliances

Deepak plants are operated under strict environmental standards and managed in accordance with ISO 14001, OHSAS 18001 and good international industry practices. The main air emissions from the operations are particulate matters (PM), NOX, SOX, and ammonia. There are necessary tail gas treatment installations, including electrostatic precipitations (EPC), nitrous oxides removals, scrubbing, etc. As a result, all the monitored air emission parameters meet local regulatory requirements and the WBG EHS Guideline limits.

All the wastewater is treated at the onsite wastewater treatment plants through physical /chemical / biological treatments and reverse osmosis (RO) for recycle. The treated wastewater is discharged to industry zone common wastewater treatment plant for further treatment before discharged to surface water body or ocean. The main pollutants in wastewater are total suspended solids (TSS), ammonium nitrogen, nitrate, phosphorus, BOD, and COD. The monitored parameters for the discharged wastewater meet local regulatory requirements and are compliant with the WBG EHS Guideline limits.

Key pollutants in both air emissions and liquid effluents are monitored online, which are connected to state pollution control board and ambient air monitoring results are disclosed at the main plant gates. Fugitive emissions of ammonia and NOX are monitored at critical locations inside plants to ensure plant site safety. Ambient quality and noise levels at key locations are also monitored and compliant with all local regulatory requirements. 

The sanitary wastes are collected by municipal contractors for disposal.  Off-grade products are generally recycled for reprocessing. By-products are purified and sold to other industries as raw materials. RO rejections, non-recyclable industry solid wastes, and hazardous wastes, such as hazardous material containers, waste petroleum products, etc., are disposed at the licensed industry waste disposal/recycle sites, designated by MIDC or other industry zones. For the new IPA II project, all the EHS performances will be designed to meet both local regulatory and IFC requirements.

Hazardous Materials and Operation Hazard

There are hazardous materials among Deepak’s raw materials, intermediate products, and products. The manufacturing, storage, handling, and transportation of these materials may pose high risks to employees and nearby communities alike. Deepak has established and implemented full elements of process safety management (PSM) system. Hazard operability study (HAZOP) is required for all new processes, conducted by external experts. HAZOP is updated whenever any process is modified and conducted by internal PSM team. All the recommendations from HAZOPs are implemented. If necessary, quantitative HAZOP is required for critical processes.  Even without any modification, HAZOP for critical processes are required for updates every five years based on production experience or available new technology.

Fire detectors, leak detectors, and toxic gas sensors are installed in all key locations at each site. All these detectors/sensors are connected to the central control rooms together with all other process data. Deepak does not have underground storage tanks. All tank farms have proper bottom and secondary containment structures with sufficient holding capacity in case of leak.

Quantitative risk assessments (QRAs) are conducted for all important storage tanks, including ammonia, IPA, and methanol. QRA models show the exclusive zones under the credible worst-case scenarios are all within Deepak properties. In line with the ESAP 8, Deepak will review all existing QRA results and propose mitigation methods to reduce impacts in case of an accident related to storage tanks. Fulltime staffing positions will be avoided or minimized in the exclusive zones. If less serious impact zones cover other industries or communities, the ER drills should involve these industries or communities.

   Community Health and Safety

There is no community near Deepak sites. Based on the air emission data and ambient air quality data, the normal operations at Deepak plants have limited impacts to the communities nearby. The QRA results show that the major impacts of exclusive zones are all within Deepak properties. Deepak will review the QRA results. If the calculated less-serious impact zones due to chemical storage accidents cover any communities, Deepak will redesign its emergency response plans and involve the community in its ER drills.

Deepak’s raw materials and products are transported with railroad or by road trucks/tankers. The road conditions are not ideal for heavy truck transportation and there are communities along the main transportation routes. All the raw material and product transportation are contracted to licensed specialized transportation companies for hazardous material transportation. There has been no major transportation accident in Deepak operation history.

To ensure transportation safety, the logistic department tracks real-time movements of ammonia and technical ammonia nitrate road trucks / tankers through GPS geoinformation systems. The logistic controller can reach out to truck / tanker drivers anytime. All the transportation routes are pre-planned. If any truck / tanker is off the planned route or speed, an alarm will sound in the control room. The controller can then reach out to the driver for clarification.

Emergency Preparedness and Response

Transportation of hazardous materials can pose significant risks to the communities and can result in emergency situations. To minimize such risks of emergency situations, specialized equipment and ER features are required on all road trucks / tankers. Deepak provides weekly safety training for truck drivers while they are waiting for loading/unloading turns. All drivers need at least one training per calendar year. The training covers defensive driving, hazardous scenarios, communications, emergency response, etc. Deepak also provides related trainings for hospitals and polices in nearby areas. In case of an emergency, the driver can call Deepak, transportation companies, customers, and police for emergency responses.

Security Personnel

The company will, as part of the ESMP for both constructions and operations, implement formal procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out;  personnel are trained in handling various situations with clear procedures; security incidents are recorded, investigated and corrective action implemented; security personnel are trained in avoidance of human rights violations; bona fide complaints against security personnel are investigated/disciplinary actions implemented; and there is a grievance mechanism for aggrieved members of community or employees in the event of a violation of the code for security personnel. 

    Stakeholder mapping / analysis

Most of Deepak operations are located in land provided by the industrial authorities and the community is usually located far from the operational project sites. Public consultation is done as a part of EIA for the plants listed in EIA notification issued by the government. The last public consultation was done for the NPK project in 2016. Plants located at K1 to K8 plots are certified for ISO 14001:2015 and as a part of the standard the company has a Procedure for “Consultation and Communication”. The external communication and community grievances are handled as per this procedure.

Deepak also has a foundation named Ishanya Foundation which is the implementing agency for Corporate Social Responsibility (CSR). The foundation identifies the key target beneficiaries, community needs and accordingly programs/projects are implemented. However, this is currently only operating in Pune (corporate office) and nearby villages of Taloja plant. Ishanya Foundation prepares community development and engagement plan every year and the same is presented to board for approval. On approval the various initiatives & projects are executed in both urban and rural areas which are mainly focused on livelihood and women empowerment, education and health as per CSR Policy.

As part of corporate ESMS, Deepak will develop stakeholder engagement procedure and grievance redressal mechanism for the external stakeholders including affected community.  

    Deepak will disclose this document in English at Deepak website (http://www.dfpcl.com/DFPCL/). For inquiries or concerns about the environmental and social impacts of this project please contact:

Project: Ammonia Taloja Project

Company Name: Deepak fertilisers & Petrochemicals corporation limited

Contact Person: Arun Agrawal

Email: arun.agrawal@dfpcl.com

Phone: +91 9820500811

Project: IPA-2, Taloja Project

Company Name: Deepak fertilisers & Petrochemicals corporation limited

Contact Person: Makrand Samant

Email: makarand.samant@dfpcl.com

Phone: +919987287275