There is no land acquisition, nor any involuntary resettlement required under the project nor are any adverse impacts on biodiversity, natural habitats, forests, or protected or sensitive areas or cultural property expected on account of the Project. Accordingly, PS5: Land Acquisition and Involuntary Resettlement; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7 Indigenous Peoples; and PS8: Cultural Heritage are not considered applicable to the Project.

 The proposed corporate investment is in a company with operations existing at JKPM and CPM since 1962 and 1966 respectively. The key risks and issues related to the paperboard expansion project at CPM and the existing operations at JKPM and CPM are  primarily related to: construction management, emissions to air, land and water; employee working and living conditions including occupational health and safety during project construction and operation; community health and safety and security; supply chain management particularly in sourcing wood; and adequacy of systems in place to manage these risks and impacts.

This is a Category B project as the risks and impacts associated with the project construction and operations are limited and can be readily addressed through mitigation measures by adhering to generally recognized performance standards, guidelines or design criteria.                                                  

 Environmental and Social Assessment and Management System:

JK Paper’s corporate philosophy commits to “environmental and social care”. In accordance with the corporate philosophy, CPM has implemented its own integrated quality, environment, health and safety management system (IMS) certified to international standards. CPM’s IMS is certified to ISO 9001:2008, ISO 14001:2015 and ISO 45001:2018 standards. The corporate ESMS for the company has been developed and is in the process of further updation based on the inputs from site level IMS update to meet IFC PS requirements. Part of Wood sourcing at CPM is certified to FSC-Control Wood standards. Further, CPM has formal employee management (HR) and community relations (CR) policies and procedures. The IMS, the FSC certified wood sourcing management system, HR and CR policies and procedures all together constitute the ESMS at each plant. The  ESMS of CPM, in addition to compliance with national requirements,  also incorporates IFC PSs and the relevant and applicable parts of World Bank Group (WBG) Environment, Health and Safety (EHS) General Guidelines, 2007, WBG EHS Guidelines for Pulp and Paper Mills, 2007, WBG EHS Guidelines for Perennial Crop Production, 2016, and WBG EHS Guidelines for Thermal Power Plants, 2008. The company has also undertaken third party training for its management staff as part of its IMS updation and finalization.

Policy

CPM has in place QEHS Policy, Human Resource Policies and policies and procedures for FSC-Control Wood System. While the intent of these policies is broadly in line with the principles of IFC PSs, JK Paper is simultaneously upgrading these policies to appropriately incorporate and reflect the relevant requirements of IFC PSs. The site level ESMS include procedures to periodically review the plant level EHSS Policies and ESMSs to ensure that they remain relevant and provide a framework to address the risks, impacts and opportunities as these evolve over time.

Identification of Risks and Impacts

CPM, as part of their IMS, has undertaken a structured identification of risks and impacts through formal Hazard Identification and Risk Assessment Process (HIRA) and Aspect, Impact and Significance (AIS) determination processes. Some of the key risks and significant aspects/impacts identified include those relating to: handling, storage and use of chlorine; emissions to air and water; handling, storage and disposal of hazardous wastes; fire risk in coal, wood chips, wood and finished product handling and storage areas, among several others.

For the proposed expansion project, the company has undertaken an environmental impact assessment (EIA) in accordance with the national regulatory requirements in May 2019 and received regulatory environment clearance in October 2019. The company further received Consent to Establish (CTE) in February 2020 for starting construction activities. The EIA has the outline of an Environmental Management Plan (EMP): (a) measures to mitigate adverse impacts; (b) monitoring requirements for ensuring the mitigation measures are implemented effectively and in a timely manner; (c) organizational and financial resources for carrying out the measures; and (d) an implementation schedule for these activities.

The EIA addresses key environmental risks and impacts and identifies environmental and social mitigation measures for the project, covering construction and  operation  phases, including those pertaining to: dust, emissions to air, air quality, noise and ambient conditions; water and wastewater; runoff management and rain water harvesting; handling, storage and use of hazardous materials; solid waste; traffic and traffic safety; handling, storage and disposal of hazardous wastes; occupational health and safety; preliminary qualitative risk assessment; monitoring, reporting and supervision; and budgetary requirements to comply with national law and international standards, including IFC PSs. CPM has contractually required the contractors to implement the mitigation/management measures as per EIAs, construction stage EMP and additional measures consistent with good international industry practices (GIIP) including those discussed below in construction and operation of the project in accordance with IFC PSs.

Further, a gap assessment of the EIA against IFC PS requirements was undertaken by a third party and an ESAP developed based on the gaps identified. CPM is implementing the ESAP and its implementation is being monitored by a third party. The company has in addition to the EMP developed as part of regulatory EIA process, a detailed environmental and social management plan (ESMP) and a construction’ health and safety manual through a third party. The ESMP and construction health and safety manual implementation for the expansion project is being periodically monitored through quarterly third-party audit since March 2020.

Gujarat Electricity Board has plans to build a 800 MW coal based Supercritical thermal power plant (including decommissioning of 2x120 MW Units) in the project area of influence. The EIA does not include a cumulative impact assessment (CIA) taking into account the impacts from the thermal power plant. CPM will, as mentioned in ESAP #1, complete a CIA particularly for impacts on air quality and water resources.

CPM has in place a Controlled Wood Policy covering their farm forestry operations under which these plants verify the source of wood to avoid sourcing wood harvested illegally, in violation of traditional or civil rights, from high conservation value (HCV) forests or forests where HCV areas are threatened due to the forest management activities, from forests being converted to plantations or non forest uses, and from forests where genetically modified trees are planted.

The project facilities are being built inside the existing plant premises and farm forestry operations are undertaken in privately owned land parcels. While the EIA has undertaken a biodiversity assessment, it is not aligned with IFC PS6 requirements. CPM will, as mentioned at ESAP #2, undertake a supplemental natural and critical habitat (NH/CH) screening study and based on the study findings, and develop a biodiversity action plan (BAP), as needed.

In future, if any Scheduled Tribe (ST) farmers show interest in the farm forestry program, CPM will facilitate their participation in adherence to ICP principles.

Management Programs

CPM’s ESMS include standard operating procedures (SOPs) for: aspect, impact and risk identification; compliance with regulatory requirements; development and implementation of management programs, including SOPs for managing EHSS risks and impacts from operations and maintenance; incident and accident handling, recording, reporting, investigation and analysis; emergency preparedness and response; EHSS organization, responsibility and resource allocation; training and awareness; communication and consultation; monitoring, recording, reporting and documentation of E&S performance; quarterly internal and annual external audit of the ESMS; management review; and EHSS performance reporting to the JKPL management. The ESMS of CPM is updated to incorporate IFC PSs and applicable WBG EHS Guidelines (currently in the process of finalization after training feedback). As indicated at ESAP #3, prior to start of project operations, CPM will further upgrade its ESMS to align it with new plant’s requirements.

The ESMP includes EHSS policy and objectives, roles and responsibilities allocation, monitoring and reporting procedures, internal and third party audit procedures, corrective action procedures and plans for project site EHSS management in accordance with GIIP including: surface water, groundwater and contaminated runoff management plan; traffic management plan; hazardous materials and hazardous wastes management plan; labor influx and worker accommodation management plan; worker medical checkup, vectors and disease management plan; occupational health and safety management plan; emergency response plan; stakeholder engagement and grievance mechanism; security management plan; monitoring and reporting plan; internal and third party audit plan; and contractor/sub-contractor management plan.  As indicated in ESAP #4, the ESMPs will be further updated to include the following: contaminated material, soil, water and site management plan; structure decontamination and dismantling plan; construction management plan for excavation/backfilling at site, transportation of construction material; dust management plan; noise management plan; equipment operation and maintenance plan; lighting and illumination management plan; construction, demolition and other solid waste management plan; wastewater and sewage management plan; chance find procedure etc.

Organizational Capacity and Competency

At CPM, while overall responsibility for ESMS implementation is with the plant head, dedicated Environment, Safety, Medical, Community Relations and Human Resource (HR) /Personnel Management/Industrial Relations personnel have been employed to oversee the day to day implementation of each plant’s ESMS. Any biodiversity related aspects at each plant is managed by the raw material sourcing team.  The company has also dedicated 2 EHS staffs for construction stage ESMS implementation and monitoring. The company has currently 13 contractors hired for the expansion project and each contractor has dedicated one EHS personnel for HSE implementation and monitoring. Before the start of the construction, all the contractor EHS personnel are provided training as part of induction and subsequently as part of ongoing monthly meetings to discuss implementation gaps as well as improved practices to improve EHS performance of the contractor workforce.

Monitoring and Review

CPM has in place an EHSS monitoring plan taking into account the identified risks and impacts and regulatory monitoring requirements.  CPM has installed online continuous monitoring system for air emissions and treated effluent quality. The current monitoring program includes: emissions to air, ambient air quality, ambient noise levels, energy and water consumption and efficiency, drinking water quality, wastewater generation, treated domestic wastewater quality, treated industrial effluent quality, surface water quality, ground water quality, hazardous wastes generated and disposed, other solid waste generated and disposed, health and safety data, accidents/incidents, training and drills, community development initiatives, and security incidents. The analysis of information from the monitoring and audit programs feeds into periodic management system review process to assess efficacy of the ESMS and to identify measures to further strengthen the ESMS. CPM has commenced monitoring and analysis of information related to stakeholder engagement, employee and community grievance redress, community health and safety, workplace environment quality, night time noise levels at sensitive receptors, total reduced sulphur emissions from recovery boiler, hydrogen sulphide emissions from lime kiln and total phosphorus, total nitrogen and total suspended solids in treated effluent.

CPM will, as part of the new expansion, review the current EHSS monitoring program and align it with the monitoring requirements as per applicable WBG EHS Guidelines, IFC Performance Standard requirements and information requirements of key stakeholders. CPM has in place procedures for quarterly internal audits, annual third party ESMS audits and statutory safety audits. The findings of these audits and overall performance monitoring feed into the monthly departmental review meetings and six monthly ESMS management review process. The ESMS management review process is led by the plant head at each plant. The construction stage monitoring and review is also integrated into the existing monitoring and review program, wherein monthly review meetings are conducted with the contractors and their EHS representatives. The contractors are also provided multiple checklists to report EHS performance on monthly basis; the consolidated EHS reports from the contractors and the monitoring findings by CPM EHS staff related to construction activity are presented on monthly basis for management review.

Emergency Preparedness and response

CPM has onsite and offsite emergency response plan in place. Joint emergency response drills with district emergency management authority is undertaken every year. CPM has adequate fire-fighting facilities with full-fledged fire safety systems at the existing facility as per the National Building Codes and other good engineering practices. The existing fire-fighting arrangements will be suitably augmented during the implementation of the proposed expansion.

 Human Resources Policies and Procedures

The current strength of the workforce at CPM is around 2218 including management cadre staff (398), workmen (705) and contractual labour (1525). The workmen category includes technician, operator, helpers etc. The contract workers are mainly involved in loading/unloading, wood handling, coal handling, material movement, security and housekeeping. Contract workers are hired through different contractors. The project will create direct employment to about 300 persons during operations. In addition, it would generate indirect employment to about 1000 persons in the industries and service organizations and material handling, etc., which will be supported by the operations of the mill. The construction stage of the project is expected to generate employment to about 1000 persons for about 18 months.

CPM has in place certified standing orders and human resource policies and procedures aligned with PS2 provisions, which together include procedures relating to compliance with applicable labor laws, attendance and working hours, leave, conduct and discipline, employee grievance redress, wage and compensation,  working age, prevention of child and forced labor, equal opportunity and nondiscrimination, freedom of association and collective bargaining, and avoidance of sexual harassment, working age, and industrial relations. Human resource & Industrial Relations (HR & IR) team oversees the effective implementation of these policies. CPM has 14 member HR/PM/IR teams respectively. The company will, as part of the ESMS, upgrade process: make available the HR Policies and Procedures through intranet to all employees; through provision of handbook and training programs to communicate the HR policies to employees and workers that do not have access to intranet; implement appropriate audit procedures to obtain assurance on statutory compliance by contractor/service providers with applicable labor laws.

Working Conditions and Terms of Employment

Basic terms and conditions are communicated in the employment letter to direct employees. Details pertaining to benefits, leaves, deductions, hours of work, overtime arrangements and overtime compensation, breaks and such other are specified in the HR policies and procedures, certified standing orders and in the collective bargaining agreement.

Worker Accommodation

CPM provides housing to the staff and workmen category. Apart from that, labour accommodation has been provided to the construction workers on company’s land outside the project premises. The company has developed labour accommodation guidelines and the accommodation facilities are monitored by the EHS department on a periodic basis.

Workers’ Organization

CPM has a registered workers’ union (for the direct workmen). The most recent collective bargaining agreement was for 4 years commencing April 2016, which covers all the workmen and graded staff. Further, contract workers are part of another union and have signed a separate tripartite memorandum of understanding between the union, contractors and deputy labor commissioner based on which various contractors provide wages and benefits to their employees.

Non-discrimination and Equal Opportunity

CPM has in place formal non-discrimination and equal opportunity policy and procedures aligned with PS2 provisions.

Retrenchment

There are no plans for retrenchment at CPM. The company currently follows the requirements related to layoff and retrenchment as per Indian industrial dispute act, 1947. The company will, develop and maintain a retrenchment policy and procedure that meets PS2 provision (ESAP #5).

Grievance Mechanism

CPM has a joint grievance redressal committee with Union representatives and a formal grievance redress procedure for ensuring its amicable Solution in reasonable time. However, not many grievances have been received as per the committee records. The grievance redress procedure is updated as part of the ESMS upgrade process at  CPM to: (a) provide for anonymous complaints and confidentiality protection, where the aggrieved person so desires; (b) ensuring service provider/contractors’ employees access to an appropriate grievance mechanism; and (c) improve documentation, analysis and reporting of grievances received and resolved to senior management.

Protecting the Work Force

CPM has in place formal and well-defined HR Policies and Procedures for prevention of child and forced labor at its operations, including its supply chain.

Occupational Health and Safety

CPM manages occupational health and safety through their OHSAS 18001 certified management system that includes: OHS Policy; OHS objectives; roles and responsibility allocation; safety committee composition and procedures; safety induction, training, tool box talk procedures for employees and contract workers; provision of safety signage; provision of emergency response facilities (leak sensors, SCBA, online breathing apparatus/continuous airline, containment tanks, wash showers etc.) as relevant in chlorine and hazardous material handling areas; accident investigation, reporting and corrective action procedures; work permit system and safe work procedures for various activities that exposes workers and employees to hazardous conditions; periodic internal and third party audit, and management review. CPM provided personal protective equipment (PPE) to workers and have required contractors to provide PPE to their workers. The OHS system includes periodic general medical examination program for workers and will be upgraded to a targeted health surveillance program covering both employees and contract workers.

CPM will continue to focus on further improving use of activity specific PPEs, particularly under dangerous working conditions. CPM has an active safety training program in place. CPM ensures that doctors or para-medical staff are available or that there is access to emergency medical facilities and ambulance is available at plants together with facilities for administering first aid. Firefighting equipment has been provided at CPM. To further upgrade OHS management, CPM has undergone third party safety audits and are implementing a comprehensive improvement action plan based on the findings of the third-party audit. This includes among other findings: conversion of underground fire hydrant system to over ground system at CPM. CPM has commenced the following: monitoring leading and lagging OHS indicators; analysis of nature and causes of accidents; and use of safety risk mitigation hierarchy in risk evaluation to strengthen accident and incident prevention. The monitoring data indicates improving safety performance trend at CPM. At CPM, reportable accidents are 7 between 2017 and 2019. Total person days lost is zero since 2015; the total lost time workdays have also been zero since 2016. The OSHA incidence rate at CPM is less than 1 is within internationally recorded levels for this industry.

Workers Engaged by Third Parties

CPM has procedures in place to review contractor compliance with key statutory requirements, particularly related to wages, overtime, leave, age and OHS performance. CPM has developed a labour and workers management plan by including: (i) a comprehensive compliance checklist against the applicable legal requirements and PS2 provisions and a periodic internal audit procedure; (ii) procedures to ensure consistency of worker accommodation provided by contractors with IFC PSs consistent with IFC/ EBRD guidelines for worker accommodation; (iii) requirements to enable contract workers can access an appropriate grievance mechanism; and (iv) procedures to ensure that engagement of migrant workers is on substantially equivalent terms as non-migrant workers performing the same work. CPM will make continuous efforts to implement the provisions mentioned including updation of the management plan to include OHS performance criteria as part of contractor qualification, selection and contract renewal decision.

Supply Chain

CPM sources wood primarily from farm forestry operations. 100 % of wood sourcing at CPM is certified to FSC Control Wood standards. In accordance with FSC requirements, CPM and the farmers and contractors associated with their respective farm forestry programs are required to adhere to the 10 FSC principles including those related to workers’ rights. CPM have in place procedures to verify adherence to these principles in their farm’ forestry and wood sourcing activity, including training of resource persons involved in ensuring compliance to the FSC requirements. CPM is already undertaking training of the contractors, aggregators involved in its supply chain. Further, CPM will, as part of the ESMS, upgrade: (a) extend the scope of existing policies and procedures on prevention of child labor, forced labor and OHS to also cover their farm forestry and wood sourcing operations through contractors; and (b) implement a suitable oversight program to obtain assurance on compliance with these requirements.

 RESOURCE EFFICIENCY

The project involves several pollution prevention and resource efficiency measures. These include: switch to elemental chlorine free (ECF) process; replacing existing conventional old digesters with state-of-the-art Rapid displacement heating (RDH) cooking; replacing old recovery boiler with new high pressure and efficient recovery boiler; installation of new bleached chemi-thermomechanical pulp (BCTMP) plant to substitute costly imported pulp; generating more bio-fuel (black liquor solids) based energy; state-of-the-art Multilayer Coated Board Machine with energy efficiency; high pressure, high efficiency Fluidized Bed Combustion (FBC) boiler for better power generation through co-generation; higher efficiency turbo generators with low specific steam/t kWh; high efficiency Electrostatic Precipitators (ESP) for coal fired boiler, Recovery boiler and Lime kiln; non-Condensable Gases (NCG) collection system to collect Non-Condensable Gases and incinerate them in Lime kiln; producer gas (PG) plant to fire gas in lime kiln to reduce consumption of furnace oil; water conservation, rain water harvesting and efficient water management measures; recycling and water conservation to reduce specific fresh water consumption; and upgradation of waste water treatment plant by segregating the colored and noncolored effluents with tertiary treatment.

Energy and Material Efficiency Projects

Post project, electrical power consumption is expected to increase from 958 kWh/t of product to 1111 kWh/t of product which is within the range considered as good international industry practice (GIIP). Process steam consumption will come down from 7.37 t/ton of paper to 7.22 t/ton of paper and utilization of energy from the recovery boiler as a percent of total energy consumed will increase from 22.5% to 35.7%. The total energy consumed will be 15.43 GJ/t of product.

Water 

Specific water consumption at CPM will come down from 43m3/t of product to 38 m3/t of product which is within the range of GIIP. The water is sourced from Ukai dam at CPM.

Greenhouse Gases

As indicated at ESAP #6, CPM has commissioned a third-party to undertake post project GHG inventory. However, estimated GHG emissions post project is expected to be about 550,000 tCO2e per annum per annum calculated based upon scope 1 and scope 2 emissions. CPM will report its GHG emissions on an annual basis, as part of its AMR format.

POLLUTION PREVENTION

The environmental impacts from construction activities are those typical of most construction sites and include: dust generation; soil erosion and sediment loading increases; noise; waste management; potential spills of hazardous and other material; construction debris disposal; domestic solid waste and wastewater from construction camps; increased water usage; and construction vehicle traffic. As indicated under PS 1, CPM is implementing a construction stage ESMP, that includes specific mitigation measures that meets applicable aspects of IFC PSs and applicable and relevant aspects of WBG EHS Guidelines. Some of the specific mitigation measures to be applied include: installation of sediment traps to reduce sediment in runoff generated during land clearing/filling, collection, storage and disposal of liquid and solid wastes generated during dismantling and construction through authorized treatment and disposal facilities; implement measures to minimize risk of spill and overflow during transportation; constructing paved roads early where feasible and cleaning of paved roads; provision of water sprays to control dust on roads and stockpiles; wheel washing of transport vehicles; and covered transport of construction materials in trucks. To minimize silt runoff, the procedures will require provision of sediment traps at the project sites, and where required sand bag barriers to direct flow to sediment traps and use the trapped silt as filling material on site, if not contaminated.

Temporary impacts to air quality may occur during the construction phase. The main sources of air emissions at the project sites are: fugitive dust emissions; and particulate matter (PM), sulfur dioxide (SO2) and oxides of nitrogen (NOx) from construction equipment and vehicles, and from stationary sources like diesel generators (DG) at the project sites.  The construction contractors will be required to undertake: water spraying in vehicle movement areas for dust suppression; covered transport of material; management of fill/excavated earth and construction material, wetting stockpiles; restricting excavations and construction material handling during high wind conditions; vehicular movement planning to minimize trips; wheel washing; minimizing drop heights for friable material; minimizing time for which excavated/fill earth is left loose at site; management of pollution from vehicular and equipment emissions including through regular maintenance of DG sets and transport vehicles to minimize PM, SO2 and NOx emissions; and other measures for minimization of fugitive dust emissions (e.g., covering stockpiles). An increase in ambient noise levels is expected during the construction period due to increased traffic, use of earthmoving and other construction equipment. CPM will require contractors to: limit use of heavy noise and vibration generating equipment to during day time to the extent possible; ensures mufflers are provided in noise generating equipment; implement equipment tuning program to minimize noise at source; not undertake high noise generation activity at night near residential areas; and undertake transportation planning to minimize traffic through communities at night in residential areas. CPM is implementing a monitoring program covering ambient air quality and ambient noise levels at sensitive receptors to demonstrate compliance with WBG EHS Guideline limits.

Groundwater will not be used for construction or domestic use. Generation of wastewater will mainly be limited to sanitary wastewater/sewage from labor accommodation and project office areas during construction. CPM will, as part of the ESMP implementation, ensure that construction wastewater (from equipment cleaning, transit mixer washing and other equipment washing/maintenance work) will be disposed through an oil water separator and settling tank. The treated wastewater will be used in dust suppression. The construction stage sewage will be treated through septic tank and soak pit. The company will require contractors to provide portable toilets with holding tank at locations where fixed toilets is not possible. CPM will ensure that non-hazardous construction waste will be used for site filling or disposed in authorized municipal locations. Other wastes (packing material, metal, debris, cement bags, drums/carbuoys etc.), garbage from worker accommodation are collected, segregated, stored and disposed of to re-users or in government authorized debris treatment and disposal facilities.

Hazardous materials that will be stored at site during construction include: gas cylinders, diesel, lubricating oils, transformer oil, paints, batteries and other chemicals, and hazardous wastes (used oils, waste/residual paint, oil/paint soaked rags/material, filters, empty oil/paint/chemical drum/barrels, spent batteries etc.) are expected to be generated during construction. These hazardous material and hazardous wastes handled/generated at site during construction will be: stored under segregation and containment; handled/used with appropriate care and personal protective equipment; and hazardous waste will be disposed through entities authorized to handle, recycle and dispose hazardous wastes.

Surplus excavated earth will be generated at the site and used for area leveling, back filling and for localized leveling work at site. CPM will require contractors to segregate and store construction solid waste in designated areas within the project site and dispose these through authorized agencies. CPM will identify wastes that can be recycled and will dispose these to re-users/recyclers. Waste that cannot be reused/re-cycled will be stored in bins and disposed of through licensed waste contractors. At the end of construction, a post-construction survey of the construction area will be conducted to confirm that all debris and wastes have been removed and appropriately disposed of.

Air Emissions and Ambient Air Quality

Measurements of baseline particulate Matter of 10 micrometers or less (PM10), PM2.5, Sulphur Dioxide (SO2) and Oxides of Nitrogen/Nitrogen Dioxide (NO2) indicates that are all within national ambient air quality standards.

Emissions to air from the project will be primarily from power boiler, recovery boiler and lime kiln, and fugitive emissions from coal handling. The design emissions rate from the power boiler of 30, 100 and 100 mg/NM3 for PM, SO2 and NOx are within GIIP limits. The design emission rate from recovery boiler of 30, 600 and 300 mg/NM3 for PM, SO2 and NOx will meet national regulatory limits. The emissions from lime kiln at 150, 400, and 500 mg/NM3 for PM, SO2 and NOx are as per national regulatory limits. The maximum incremental ground level concentration of PM, SO2 and NOx is predicted to be 1.59, 9.48 and 6.03 ug/m3 respectively, which is well under the 25% GIIP threshold and post project ambient air quality will meet national ambient air quality standards. Further, the total particulate load, SO2 as S load, and NOx as NO2 load emitted from recovery boiler will be 0.121,0.302 and 0.901 and lime kiln will be 0.09, 0.00 and 0.3 kg/t of air dry pulp respectively is within GIIP levels. The particulate load, SO2 as S load and NOx as NO2 load from the power boiler at 0.365, 1.217 and 1.217 kg/t of air dry pulp respectively is within the GIIP levels.

CPM will, as part of the ESMS upgrade, also commence monitoring emission of total reduced Sulphur (TRS) and hydrogen sulphide (H2S). Non-condensable gas (NCG) gases will be burnt in lime kiln.

Wastewater Treatment

With implementation of the project, CPM process will become elemental chlorine free (ECF). CPM has an effluent treatment plant with activated sludge process. A significant portion of the treated effluent is supplied to nearby villages for irrigation. Currently this program covers 223 farmers irrigating an area of 1050 acres. For the proposed project, additional 400 acres of land has been identified, and prior consent obtained from the farmers for irrigation of the additional wastewater generated in the operation phase post the proposed expansion. The remaining effluent is discharged in a natural drain (the Ghoda Nala) which discharges into Tapi river. The CPM effluent generation will reduce from 36 to 29m3/t of paper after the project. The effluent generation at about [42] m3/t of air dry pulp at CPM is within GIIP levels.

Post project, the total load of TSS, BOD, COD and AOX at 0.72, 0.48, 3.6 and 0.22 kg/t of air dry pulp is within GIIP levels. The concentration of TSS, BOD, COD and AOX that will be discharged from CPM will meet regulatory limits. CPM will, as part of the ESMS upgrade, also commence monitoring load of total nitrogen and total phosphorus discharged. Depending on the monitoring data, CPM may have to optimize N and P dosage. An on-site sewage treatment plant is being setup as part of the expansion project to treat all domestic sewage.

Solid Waste Management

CPM will dispose (a) 100% of the fly ash to fly ash brick and cement manufacturing units; (b) 100% of lime sludge by re-burning in the lime kiln for reuse in the process and about 40 tpd of lime grit will be disposed in an abandoned stone quarry; (c) 100% slaker grits by usage in road repair and road making ; and (d) 100%  wood dust by using it as fuel in boilers.

Hazardous Materials

CPM will dispose hazardous waste to authorized entities. ETP sludge from CPM is disposed to fiberboard manufacturers. CPM has undertaken a full characterization and toxicity characteristic leaching procedure (TCLP) test of the ETP sludge and this will be repeated as part of the upgraded ESMS post the project. Used oil from CPM is disposed to authorized recyclers and will be continued after the project. As part of project, CPM is upgrading its procedures, facilities and practices relating to segregation, labeling, handling, storage, and disposal of solid and hazardous wastes in line with GIIP requirements.

Pesticide Use and Management

CPM, as part of its FSC Policy has committed to: identification and avoidance of highly hazardous pesticides; appropriate use of pesticides that are used; and promotion of nonchemical methods of pest management as part of integrated pest and vegetation management strategy. CPM does not use WHO Class 1a and 1b pesticides and ensures that if WHO class II pesticides have to be used, these are used by personnel with proper training and equipment, and there are appropriate facilities to handle, store, apply and dispose them off.

While CPM encourages farmers to not use chemical pesticides and weedicides, in instances of high termite infestation, farmers are advised to use Imidacloprid, a WHO Hazard Class II pesticide. CPM as per its SOP for pesticide use and management will: (a) when advising farmers to use Imidacloprid, also train them in its proper use, use of appropriate PPE, controlling access to it, and appropriate handling, storage and disposal mechanisms; and (b) implement a program to identify a less hazardous alternative to this pesticide.  In the farm forestry operations,  CPM will work with farmers, cooperatives and suppliers on an ongoing basis to: (a) assess if any WHO Hazard Class Ia, Ib and II pesticides are used and enable their replacement with less hazardous alternatives; and (b) enable appropriate disposal or reuse of containers associated with the pesticides use. 

Community Health and Safety

There are communities in the immediate vicinity of CPM plant, including employee colonies. The plant has access from major roads and the material receiving gate is typically located on these major roads. Movement of trucks into the chipper and log yard is regulated. As part of the ESMS upgrade, CPM has developed procedure for onsite traffic management. CPM will use this procedure to implement a site specific  traffic management plans, including the following: parking, movement, access control, restriction on speed, norms for deployment of marshals/traffic scouts, documentation requirements (valid licenses, road tax certificate, gate/entry pass), dedicated truck parking areas, driver rest areas, and dealing with transport emergency situations (accidents, injuries). The traffic management plan will include procedures to identify choke points and management of traffic arising from plant operations at choke points will be done through scouts/traffic marshals who will be trained and engaged by CPM. In addition, for the drivers and helpers who regularly visit the plants, CPM will have procedures instituting a training program on defensive driving and dealing with transport emergencies.

CPM has put in place a community health and safety plan to address risks associated with significant influx of labor, an assessment of community exposure to health and disease risks from water-borne, water-based and vector-borne diseases. The plan has procedures for health check-up of incoming workers and provision of adequate medical assistance and on-site medical facility. CPM has a full-fledged Occupational Health Centre within the mill premises manned by two dedicated doctors, assisted by two nurses and other supporting staff. CPM will ensure that the suggested mitigation measures in the community health and safety plan are implemented and regularly monitored.

Infrastructure and Equipment Design and Safety

CPM has in place procedures to identify and meet statutory requirements for structural safety, stability and integrity related to infrastructure and equipment including procedures for testing as required. CPM is required to undertake pressure vessel testing, lifting tools and tackles testing and structural stability/integrity assessment for all major equipment and machinery (like boilers, all air storage tanks, compressed tanks etc.) on a periodic basis.
 

Ecosystem Services

CPM will: (a) undertake a review of main water users and uses downstream of intake point; (b) assess the downstream consumption, lean season water availability (in the Ukai dam) and their respective water intake.

Security Personnel

CPM has 2 permanent security staff and 1055 outsourced security personnel for site and colony. There are 5 armed guards at CPM. CPM IMS cover security personnel procedures on the basis of security risk assessment for the plant; the procedure needs to be updated on a regular basis based on ongoing security risk assessment

While security personnel are trained in the performance of their duties and limited level of behavioral training provided, the latter is not structured and formalized at CPM. CPM will, as part of their implement additional procedures for ensuring that: past records of security personnel employed are screened; security personnel have clear objectives and permissible actions laid out; security personnel are trained in use of fire arms and 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.

Going forward, as part of the ESMS upgrade CPM will: (a) implement procedures aligned with PS4 provisions on security personnel; (b) strengthen their onsite and offsite emergency management plan to cover aspects like natural hazards, chemical leak, arson and other security risks; (c) engage with communities including providing training and building awareness with off-site emergencies/risks and (d) ensure adequate training to security personnel on company’s policies and applicable PS 4 requirements.

Stakeholder mapping and Stakeholder Engagement Plan

CPM as part of their IMS, has procedure for receiving and responding to communication from external parties. Further, CPM will through the JKPL corporate website publicly disclose environmental clearance compliance reports, fly ash generation and utilization report, groundwater quality monitoring report, environmental submission to the respective state pollution control board (SPCB) and corporate social responsibility spend related information. Stakeholder engagement activities are carried out by the community relations and corporate social responsibility (CSR) team (for community development, grievance collection and handling) and by the forestry team (for farm forestry purposes). The company, in addition to CSR activities (based on a need-based CSR assessment), has also developed Corporate environment responsibility (CER) plan for the local community development within the vicinity of the project area for 5 years, the implementation of which will also be done through consultations with the affected villages and communities and the concerns/ issues raised during public hearing.

CPM has developed a formally defined processes for stakeholder identification and engagement. CPM has extensive corporate social responsibility programs and there is engagement with the communities in this context, which is also used for formalizing the stakeholder engagement plan.

The company, as part of its ESMS, has prepared a Stakeholder Engagement Plan (SEP) with stakeholder profile, identification of key concerns, expectations, impact and influence, and risk rating of various stakeholder groups. It includes detail on engagement strategy, information disclosure, monitoring, reporting and guidance on maintaining records of stakeholder consultations. SEPs will be developed to ensure ongoing community engagement during current operations, and operation phases of the proposed expansion projects. Further, as part of the SEP, the company has developed a plan for ongoing disclosure of information to key stakeholder groups which will need to be further strengthened and monitored on an ongoing basis.

Consultation

CPM undertook public consultations as part of the public hearing requirement for obtaining environmental approval. Public consultation was conducted as per the Environmental Impact Assessment (EIA) Notification 2006 at CPM in April 2019. Prior to the public hearing, public notice of 30 days was published in two daily newspapers for getting responses from public and intimating time, date and venue of the public hearing. About 247 persons attended the public hearing meeting and 30 persons (from various groups including local farmers, working women, Sarpanchs, etc.) raised their concern on various issues, such as discharge of treated wastewater, air and odour emissions, ground water contamination and employment opportunity for the locals, and the CSR program in the nearby villages.

There is consultation with local opinion leaders and villagers as part of the extensive CSR program implemented by JKPM and CPM. Appropriate mechanism for periodic and ongoing consultation with neighboring communities is also put in place as part of the SEP. The company will work towards improving the documentation of the stakeholder engagement records.

External Communications and Grievance Mechanisms

CPM has external communication procedure as part of their IMS. This will be further upgraded to cover environmental, OHS and social aspects and sharing of relevant information with neighboring communities on an ongoing basis. Further, CPM has also put in place a formal procedure for grievance redressal mechanism (GRM) to receive and address concerns and grievances from the external community. CPM will further work towards dissemination of the of the GRM to the affected communities and ensure that the grievances are addressed in a timely manner.

Information Disclosure and Ongoing Reporting to Affected Communities

CPM has shared the summary of the EIA before the public hearing with the local communities. The environmental clearance awarded for the project has also been disclosed to the local villages.  JKPL will disclose this ESRS, ESAP through its website. CPM will disclose the ESRS and ESAP to the neighboring communities in an appropriate form and language at a third party location nearby. Further, CPM will periodically disclose information on status of implementation of the ESAP.                                                   

Considering the nature of the investment, JKPL will disclose this ESRS and ESAP through its website and these will also be disclosed in the local language and English in Fort Songadh at the following address:

Unit CPM 

Address: Central Pulp Mills (Unit CPM)

P.P. Central Pulp Mills – 394660

Fort Songadh, District Tapi, Gujarat

Mobile: 9328921006

Email ID: nka@cpmjk.jkmail.com

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

Contact Person: V. Kumaraswami

Company Name: JK Paper Ltd.

Mob: 9871394893

Email ID: vkmr@jkmail.com

Facsimile: +91-11-23712680