As mentioned above, the proposed facility is located in a SEZ being developed by HBS. The SEZ land is part of the Panoli Industrial Area, developed by GIDC in 1980s with a total area of 1100 hectares, which is now a chemicals hub with about 300 chemicals manufacturing facilities. The land parcel of 307 acres was leased by GIDC to HBS in 2009 for 99 years. Publicly available satellite images show no activity/agriculture on the site after 2009. HBS has now further sub-leased part of this land to MTPL for development of their facility. As this is a notified industrial area since 1980s, no involuntary resettlement is thus expected and therefore, PS5 (Land Acquisition and Involuntary Resettlement) is not applicable. 

Similarly, considering that the facility is proposed to be located in an established industrial area, PS6 (Biodiversity Conservation and Sustainable Management of Living Natural Resources), PS7 (Indigenous People) and PS8 (Cultural Heritage) are not applicable to this project. 

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.

Key environmental and social (E&S) issues associated with this project include: (a) adequate assessment of E&S risk and impacts associated with the proposed facility; (b) development and implementation of adequate E&S management systems; (c) assurance of fair, safe and healthy working conditions in compliance with local regulatory requirements and relevant Performance Standards during construction and operation of the facility (for both employees and contract workers); (d) resource efficiency of the operations (energy and water); (e) monitoring and management of air emissions, wastewater treatment and discharge, solid and hazardous waste and hazardous waste as per World Bank Group (WBG) EHS Guidelines; and (f) life and fire safety management including emergency preparedness and response

Environmental & Social Impact Assessment (ESIA): An Environment Impact Assessment (EIA) report has been completed for the proposed facility. The EIA report was completed for clearance from the State Pollution Control Board (SPCB). Based on the same, the company has obtained the Consent to Establish from the SPCB. Based on the EIA, an environmental management plan (EMP) has been prepared and the same will be implemented by the company. Also, required regulatory permits for operation of the facility like Consent to Operate, fire no-objection certificate and factory license will be obtained by the company.

E&S Policy and Management Systems: The company plans to implement environmental and occupational, health and safety (OHS) management systems at the facility as per ISO 14001 and OHSAS 18001 requirements. To meet the requirements of the IFC PS’s and as per the ESAP, the company proposes to hire an external consultant to develop the E&S management system (ESMS) as per IFC PSs and include key elements specified under PS1 i.e. E&S policy, detailed risk assessment of operations, organization capacity, management programs on all key risks and impacts, monitoring and review, stakeholder engagement and emergency planning and response. As defined in the ESAP the ESMS will include key management programs at least on the following: (a) environmental and OHS risk assessment of the proposed operations; (b) Life and fire safety and emergency preparedness and response program; (c) pollution prevention processes including hazardous materials management, solid and hazardous waste management plans; (d) OHS management program; (e) contractor management programs to supervise their compliance with legal requirements and IFC PSs; (f) resource efficiency program with specific commitments on resource efficiency; (g) monitoring and reporting framework including the key E&S performance indicators for effectiveness; (h) Stakeholder mapping and community grievance mechanism; (i) roles and responsibilities of all personnel involved; (j) environment and OHS training for employees and contractor workers; and (k) periodic management review. The ESMS will be shared with IFC and will be implemented within agreed timelines.

E&S Organization: The company has hired a Head of EHS for the proposed facility, who will report to the Director - Operations. As per the requirements of ESMS implementation and defined roles and responsibilities, additional resources will be hired by the company.

Emergency response: The proposed facility will have a fire safety system with fire extinguishers, sprinklers in raw materials storage area, coal storage and finished goods storage areas, fire hydrant systems covering the entire facility area, fire alarm systems (with smoke detectors in control rooms/unmanned areas), dedicated fire water storage and pumping systems.

As part of the implementation of the ESMS, an emergency response plan (ERP) will be prepared covering likely potential emergencies including potential off-site emergencies due to hazardous chemicals storage. The ERP will include composition of various emergency response teams and describe roles and responsibilities of various people. Regular training and mock drills will be conducted on fire safety, first-aid and emergency response.

Unarmed security personnel will be employed via contractors and as per the ESAP, the company will develop a Code of Conduct for such personnel aligned with the PS requirements.

Monitoring and review: As set forth in the ESAP and as part of the ESMS, a monitoring and reporting framework will be developed which will describe: (a) key performance indicators (KPIs) on E&S compliance and performance as well as objectives and targets on sustainability (resource efficiency); (b) monitoring processes (e.g., daily/weekly/monthly inspections, internal/external audits) including regular environmental monitoring (as per the EMP as well as parameters specified in the WBG EHS Guidelines) and OHS monitoring (accidents, incidents, near-misses) with specified frequencies; (c) reporting requirements in specific formats; and (d) process of regular management review by senior management. Regular monitoring will be conducted as per the described monitoring and reporting framework with key aspects reported in the annual monitoring report submitted to IFC. 

The proposed facility will employ 1500 workers (by operation of Phase-I) and this will increase to 2100 (by operation of Phase-II) with about 40% of them being third party workers. 5% of the workforce is expected to be female.

Human Resource (HR) policies and procedures, working conditions and terms of employment: The company has hired an HR manager at the facility level, who will also be responsible for industrial relations and corporate social responsibility. MTPL will also hire a corporate HR head.

The company plans to hire employees who will be hired as trainees initially followed by probation before they are appointed as permanent on the company payroll. All trainees/employees will be provided wages and benefits (e.g. provident fund) as per applicable labor law requirements. The wages will be at least minimum wage and all trainees/employees will be covered under personal accident policies.

As set forth in the ESAP, MTPL will develop and implement HR policies/procedures which are aligned with the national labor law requirements as per the requirements of PS2 and cover non-discrimination, grievance mechanism, freedom of association, prevention of child and forced labor and contract workers management. The policies will be communicated to all employees and workers through induction and their ease of access will be ensured through appropriate means.

Non-discrimination and Equal Opportunity: As discussed above, the company will document a specific policy on non-discrimination and equal opportunity.

Freedom of Association: The company does not prevent freedom of association and based on past experience, expects that the permanent employees will become part of the union. The HR manager is, therefore, responsible for managing industrial relations. As discussed above, the company will document a specific policy on freedom of association.

Child Labor and Forced Labor: Considering the operations and as per policy, only people aged 18 years or more will be hired. Age verification will be collected for all employees and workers. As discussed above, the company will document specific policies on prevention of child labor and forced labor.

Grievance mechanism: As discussed above, the company will develop and implement a grievance mechanism aligned with PS2 requirements with a consistent and well-structured system of documenting grievances received and processed. The mechanism will also allow for submitting anonymous grievances and ensure there is no retribution. The company will also create awareness among employees regarding the grievance mechanism.

Occupational Health and Safety (OHS): As mentioned under PS1, the company plans to develop and implement an OHS management system as per OHSAS 18001 requirements. Some of the key OHS management measures expected to be implemented by the company as described in the EIA include:

(a) Appoint of an industrial safety officer;

(b) Building plans and installations in compliance with the applicable legal requirements and approved by competent authorities.

(c) Adopting reasonably practical measures to minimize the risk of accidents;

(d) Pre-employment and periodic medical check-up for all employees;

(e) Training provided to all workers for all the hazardous process operations, which will be supervised by experienced supervisors; 

(f) Provision of suitable personnel protective equipment (PPE);

(g) Installation of flame proof electrical fittings, flame arrestors etc., as needed;

(h) Periodic inspection and testing of pressure vessels, equipment and machines;

(i) Good housekeeping within the facility premises;

(j) Regular training of employees on fire-fighting, work permit system, first-aid and safe handling of hazardous chemicals;

(k) Implementation of accident-incident reporting system;

(l) Display of suitable notices/boards at designated locations indicating appropriate hazard warnings; and

(m) Availability of material safety data sheets (MSDS) for all the chemicals.

As discussed above under PS1 and as per the ESAP, OHS management program will be developed and implemented as part of the ESMS. The program will integrate the measures described above and cover all employees and contract workers.

Workers engaged by third parties: Third party workers (~40% of the workforce) for material movement, ancillary jobs and other non-core activities, will be hired by the company through contractors. HR team at the facility will be responsible for management of contractors. As per the ESAP and as part of the HR manual, a contractors’ management plan will be developed which will describe procedures to be followed for ensuring contractors’ compliance with applicable legal requirements.

As regards construction, the company has already contracted the two contractors for civil construction of the proposed facility . There will be separate contractors mobilized on-site for pre-engineered building (PEB) and electrical and fire safety systems. At the peak of construction, 350 construction workers are expected to be onsite.

The company has included general safety and labor compliance requirements in the agreements signed with the current contractors. No detailed documented EHS processes have been agreed between the company and the contractors. Also, the worker accommodation were noted to have scope for improvement in provisions of basic facilities. As per the ESAP, the company will develop documented EHS procedures for construction as well as requirements on worker accommodation including roles and responsibilities and consequences of noncompliance. Also, a grievance mechanism will be implemented for contract workers. The same will be included in the contracts with contractors. In addition, implementation of these procedures will be verified through a sixmonthly audit to be completed by an external consultant (acceptable to IFC).

Supply Chain: The company will source Natural rubber primarily from Indonesia and Vietnam. Typically, rubber is grown by small farmers and processed by companies to make sheet and crumb. It is then traded on the exchange and sold by trading houses. The company will purchase from the traders. Synthetic rubber and Carbon Black will be sourced from reputed manufacturers from India and abroad. The company’s control and leverage on these suppliers is expected to be low.

As per the ESAP, MTPL will develop a supply chain sustainability policy and have specific goals/commitments on sourcing from sustainable sources (e.g. from participants of Global Sustainable Platform for Rubber) which comply with PS2 and PS6 requirements on Supply Chain. The policies will be implemented within agreed timelines. 

Power Supply and Air Quality: The main source of power at the facility will be the state grid. Also, back-up Diesel Generator (DG) sets (two nos. of 2000 KVA capacity each) will also be provided, however, their use is expected to be limited as the power supply in the state is generally reliable.

For steam generation, three coal-fired boilers (two nos. of 30 tph capacity each and one with 20 tph capacity) will be provided. As a stand by, furnace oil (FO)-fired boiler (12 tph capacity) will also be provided. All boilers will be provided with stacks of adequate height (44 m for FO-fired boiler and 64 m for coal-fired boilers). Also, the coal-fired boilers will be provided with an Electro-static Precipitator (ESP) for pollution control.

As per ambient air quality (AAQ) monitoring conducted during the EIA, the facility will not be located in a degraded air shed and the modelling results indicate that the expected incremental impact from the air emissions of oxides of Nitrogen (3.7 µg/m3 ), particulate matter (5.05 µg/m3 ) and Sulphur dioxide (4.32 µg/m3 ) are expected to be less than 25% of the AAQ standard and thus in compliance with the World Bank Group (WBG) EHS guidelines.

Currently, the company has designed the ESP for meeting the applicable state standard for PM emissions (i.e. 150 mg/Nm3 ). However, as per WBG EHS Guidelines, the PM emissions should comply with 50 mg/Nm3 . Therefore, as per the ESAP, the company will ensure that the ESP is designed to meet WBG EHS guideline limit of 50 mg/Nm3 and the relevant purchase orders with technical specification will be shared with IFC.

All process emission stacks e.g. attached to master mixer, chemical preparation, carbon handling system will be provided with dust collectors and adequate stack height in compliance with SPCB standards

Regular ambient air quality and stack emissions monitoring will be conducted as per the EMP as well as parameters specified in the WBG EHS Guidelines.

Water and Wastewater: The expected fresh water consumption after commissioning of full capacity of Phase 2 of the facility is expected to be 1000 m3 /day with main process uses for boilers (steam generation, ~410 m3 /day), cooling towers (~270 m3 /day), domestic uses (72 m3 /day) and hot water generation for curing (33 m3 /day). The source of the water will be state industrial development corporation, which is in turn sourcing its water from a river. Water be treated through softening for cooling tower use and reverse osmosis (RO) for boiler feed and drinking.

Industrial effluent (~400 m3 /day) will mainly be generated from cooling tower, softener plant, RO plant, curing drain and boiler blowdown. It will be treated in an ETP on-site with flocculation, settling and filtration. Domestic sewage (~180 m3 /day) will be treated in the STP with an activated sludge process. The treated effluents from both the STP and ETP will be further treated through a RO plant and reused for gardening, toilet flushing, coal sprinkling and ash quenching. In the monsoons, the reuse for gardening will be replaced by cooling tower makeup. Also, a rainwater harvesting system will be provided with provisions for groundwater recharge.

Regular effluent quality monitoring will be conducted as per the EMP as well as parameters specified in the WBG EHS Guidelines.

Resource Efficiency: The key resource efficiency features included in the design of the processes include:

(a) Implementation of rainwater harvesting system;

(b) Use of Nitrogen proposed for curing of tires to reduce water consumption;

(c) Condensate recovery system for the boiler;

(d) Use of 5% reclaimed/regenerated/crumb rubber in the tire manufacturing (against an industry benchmark of 2-3%) and with a long-term goal of utilizing 10%; and

(e) Reuse of wastewater as mentioned above.

Also, the company has designed the roof of the facility to enable installation of solar panels on the roof with a potential capacity of 4 MW and expected power generation of 15000 kWh/day. This is a future plan, which will be executed in phases and currently this is not part of the project costs.

Hazardous Materials Management: The key hazardous materials stored and use on-site will include Sulphur (40 MT), Naptha (40 kiloliters (kL)), Diesel (40 kL), FO (kL) and Coal.

Sulphur will be stored in a licensed dedicated storage area with explosion proof lighting. The Sulphur charging stations will have flameproof lighting and explosion proof measures. Similarly, Naptha, Diesel and FO will be stored in licensed storage areas in underground/aboveground storage tanks, respectively. For coal storage, a dedicated covered shed will be provided with water sprinkling arrangements. Also, the shed will be provided with drains and catch pit to ensure run-off is treated adequately.

As per the ESAP and as part of the ESMS, a specific hazardous materials management plan will be implemented with required instructions and training to people on storage and handling of these materials.

Solid and hazardous waste management: The facility is expected to generate recyclable non-hazardous waste (like paper, packaging, metal etc.) which will be sold to external agencies for recycling. The key hazardous waste generated at the facility will include used/spent oil, oil-soaked cotton waste/gloves, discarded containers of hazardous chemicals/waste and ETP sludge. All hazardous waste will be disposed of to authorized recyclers/treatment, storage and disposal facilities except oil-soaked cotton waste/gloves, which may be sent to cement companies for co-processing or common incineration.

As per the ESAP and as part of the ESMS, a specific hazardous waste management plan will be implemented with required instructions and training to people on storage, handling and disposal of hazardous waste.

Greenhouse Gas (GHG) Emissions: As per expected fuel and power consumption, the project, the GHG emissions from the facility operations are estimated to be approximately 35000 tons of CO2/annum (32000 tons direct and 3000 tons indirect).

In terms of disclosure of E&S information, the publication of the ESRS and ESAP will be company’s first disclosure of such information. As per the ESAP and as part of the ESMS, MTPL will develop a community / stakeholder grievance mechanism i.e. a process to receive and responding to the grievances from neighboring communities and stakeholders.

MTPL will locally disclose this ESRS at the following address as well its website: http://yaipl.com:

Mahansaria Tyres Private Limited

Plot No. 3551-B, HBS Special Economic Zone (SEZ)

GIDC, Panoli, Ankleshwar

District Bharuch – 394116

Gujarat.

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

Mr. Sumit Garg

Deputy Vice President

Mahansaria Tyres Private Limited

105, Creative Industrial Estate

72 N M Joshi Marg, Lower Parel

Mumbai 400011.

Phone: 022 – 2305 2122/2305 2223/4023 4561

Email: sgarg@yaipl.com