DCC’s typical projects are part of a larger development and do not require any land acquisition or cause involuntary resettlement to be managed in accordance to PS5: Land Acquisition and Involuntary Resettlement. However, a screening procedures will be put in place to screen for significant land acquisition and involuntary resettlement related risks associated with the larger development for which the company will bid, as presented under PS1 section below. Although DCC does not have any under-construction or operational projects as yet, DCC’s business activities  are typically located within the premises of a larger development in greenfield projects (master development) and are located in urban areas in brownfield projects as also in centralized DC projects. In light of this, DCC’s activities are not likely to have risks and impacts which will have to be managed in accordance with PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7: Indigenous Peoples; and/or PS8: Cultural Heritage.

A description of the principles and procedures that Tabreed currently uses to address and manage E&S risks for its business activities, including the way in which the company deals with PS5 through PS8 issues, and how these will be adopted and modified in some instances by DCC to ensure that the company’s activities comply with IFC’s Performance Standards, has been provided below in the PS1 section of this review.                                                  

This is a category B project according to IFC’s Policy on Environmental and Social Sustainability. The project facilities will be constructed or operated either within premises of existing facilities or larger developments or on relatively small parcels of land (less than one acre for a DC plant capacity of 15000 RT) or within the RoW of existing roads. The key risks and impacts will therefore be limited, few in number, site specific, and largely reversible. Any adverse impact can be minimized, avoided or mitigated by adhering to generally recognized international industry performance standards, guidelines, or design project criteria. Accordingly, the key E&S issues related to the project and reviewed at appraisal are: capacity of DCC to build the facilities in accordance with IFC PSs; emissions to air, water and land during construction and operation; labor working and living conditions; community health, safety and security; life and fire safety; management of water, wastewater, solid  and hazardous wastes, and refrigerants; emergency preparedness and response; and stakeholder engagement.

DCC will be required to implement an ESMS, which has been defined to include the company’s Human Resource (HR) Policies and Procedures, and in accordance with IFC PSs, to undertake its future projects and manage its environmental and social performance. IFC will require that DCC, within a timeframe to be agreed with IFC, adopt and implement the ESMS and framework outlined in the sections below. Going forward, IFC will review third party ESMS audits and third party ESDD reports for company’s future projects and if required, provide recommendations to strengthen the relevant processes.                                                   

Environmental and Social Assessment and Management System - Policy

Tabreed has an integrated Quality, Environment, Health and Safety Management System (IMS) certified to the requirements of ISO 9001:2015, ISO 14001:2015, ISO 45001:2018 and ISO 50001:2018. The system is implemented at each project site during construction and O&M. Additionally, Tabreed has in place an Employee Policy Handbook, which lays down all policies and procedures related to human resource (HR) management and a Supplier Code of Conduct (SCC) that covers compliance with law, health, safety, environment, quality, labor & human rights, and ethical business conduct of suppliers and vendors. The IMS, the HR policies and procedures and the SCC together comprise Tabreed’s ESMS. The ESMS is currently aligned with the UAE’s national requirements and standards and needs to be modified to meet Indian national requirements, IFC PSs including Good International Industry Practice (GIIP) on some aspects as described in the subsequent sections. Accordingly, DCC will, as mentioned in ESAP # 1: (i) modify and adopt Tabreed’s existing ESMS for its India operations by incorporating Indian national requirements and IFC PSs and align with GIIP as per applicable and relevant parts of the World Bank Group (WBG) Environmental Health and Safety (EHS) Guidelines; and (ii) prior to undertaking projects in other  countries outside India, further modify this ESMS to meet the national regulations of the respective countries and expand the scope of the upgraded ESMS to also cover those countries.

Under the IMS, Tabreed has developed its Health, Safety, Environment and Quality (HSEQ) Policy, which covers both on-roll employees and contract workers. The company will, as mentioned at ESAP # 1, modify the HSEQ Policy for its India operations to make it a Health, Safety, Environment, Social and Quality (HSESQ) Policy that is aligned and consistent with IFC PSs. The company will, through this HSESQ policy, commit to requiring all of its projects and all of its subsidiaries to implement the modified ESMS to comply with the provisions of IFC PSs on an ongoing basis.

Under the HSESQ policy, the company will, as mentioned at ESAP # 2, commit to: (a) assess, develop and implement/undertake and monitor projects in accordance with IFC PSs; and (b) completing an E&S risk screening based on a third party E&S due diligence (ESDD) with IFC PSs as the reference framework (including a consideration of climate change related risks) prior to bidding for/entering into a contract for any project.

Identification of Risks and Impacts

Aspects, impacts and risks of the company’s business activities have been assessed as part of IMS development. The IMS includes a risk management procedure requiring a HSE risk assessment which includes: generic risk assessment for all routine O&M activities; and a task risk assessment (TRA) for all maintenance related non-routine activities performed either by Tabreed staff or by contractors. The procedures provide templates for conducting the risk assessment along with criteria for classification of risk. Further, in the business development stage, a third party consultant is appointed to conduct a due diligence of the prospective customer and whether it has all the permits including those related to environment, safety and land title. DCC will, as mentioned at ESAP # 2, require that the ESDD be undertaken with IFC PSs as the reference standard. Further, as part of the IMS modification at ESAP # 1, the company will put in place a screening procedure to ensure adherence to IFC PSs in the projects it bids for/contracts.

In all cases where DCC’s equipment, facilities and operations are located within an existing real estate/commercial/retail building or premises, the company will undertake a third party ESDD, apply the screening procedure mentioned at ESAP # 2 and will proceed to bid/contract only if after application of the screening procedure DCC has obtained assurance that the project can be developed and implemented in accordance with the provisions of IFC PSs. In order to obtain this pre-bid/pre-contracting assurance, DCC will commission a qualified third party to undertake an ESDD with IFC PSs as the reference framework including: (a) carrying out a Life and Fire Safety (L&FS) risk assessment; (b) identifying risks that the project’s water use will cause water stress to third parties, including local communities; areas of known biodiversity value; and areas known to provide ecosystem services; (c) identifying whether any unchangeable aspect of the DC project design or specification conflicts with PS requirements; and (d) identifying whether there are significant ongoing disputes/litigation and conflicts related to E&S matters involving the real estate/commercial/retail building or premises. Further, in cases where the company is considering contracting with a greenfield retail/commercial development or a recent development, which is located in an urban area, the ESDD will additionally define the magnitude of any involuntary physical and economic displacement as per IFC’s PS5, where applicable.

In cases where DCC is considering bidding/contracting with an existing industrial establishment, in addition to L&FS, water stress, project design, disputes/conflicts/litigation, the company will also obtain assurance that there are no legacy site contamination issues, if the company’s equipment, facilities and operations will be located within the industrial establishment’s premises. In case of greenfield projects in peri-urban and rural areas, in addition to L&FS, water stress, project design, disputes/conflicts/litigation, the ESDD and E&S risk screening will also include: (a) screening of biodiversity risk, including critical habitat (CH) screening; (b) mapping the project area of influence to confirm, or otherwise, the presence of Indigenous Peoples; (c) defining the magnitude of involuntary physical and economic displacement as per IFC’s PS5, where applicable; and (d) screening for project effects, if any, on items of non-replicable cultural heritage and critical cultural heritage. Where the company is required to set up a centralized DC system in a city or municipality, DCC will design, build and operate the centralized DC system in accordance with IFC PSs.

Application of the screening procedure will lead to the following outcomes: (a) the acceptance of contracts in which the company’s environmental and social standards (including IFC’s PSs) can be met; and (b) the re-evaluation, renegotiation, or decision on rejection of contracts that cannot be implemented according to IFC PSs. In applying the screening procedure, the company will review: (a) the E&S impact assessment studies of the retail/commercial/industrial establishment project it proposes to contract with and significance of gaps with DCC’s policies and the IFC PSs requirements; (b) E&S mitigation, management and monitoring measures (or E&S Management Plan, ESMP) it is contractually required to implement against the requirements of DDC’s HSESQ policies, IFC PSs and GIIP as described in the WBG EHS Guidelines; and (c) will identify gaps and implement additional measures, within its contractual obligations, to meet the requirements of IFC PSs. In case the risks and impacts of the retail/commercial/industrial establishment project, that the DCC proposes to contract with, are significant, and gaps in mitigation measures with respect to the DCC’s policies (including IFC PSs requirements) are also significant, the company will re-evaluate, renegotiate, or take a decision on not bidding/rejection of the contract.

Management Programs

The IMS includes procedures for: aspect, impact and risk identification and significance determination; HSE risk assessment; energy management system framework; implementation of mitigation measures and operational controls based on the outcome of the aspect, impact and risk assessment process; compliance with regulatory requirements; setting objectives and targets; incident and accident handling, recording, reporting, investigation and analysis; emergency preparedness and response; responsibility and resource allocation; training and awareness; communication, participation and consultation; contractor management; monitoring, recording, reporting and documentation of environmental, health and safety performance; periodic third party and internal audits of each project site; and management review.

The IMS includes operation control procedures for: occupational health, hygiene and welfare; heat stress; noise control; job stress; vibration; manual handling; basic first aid and cardiopulmonary resuscitation; housekeeping; fire safety; permit to work; electrical safety; hazard communication; chemical safety; road safety management; lone workers; contrabands, drugs and alcohol; personal protective equipment; access control; working at heights; lifting operations; hand and power tools safety; compressed gas cylinders; lifting and mobile equipment; hot work operations; excavations; office safety; environmental management; waste reduction action plan; crisis management plan; project health, safety and environmental plan; and environmental management plan for projects). The company will, as part of the ESMS upgrade mentioned at ESAP # 1, develop and implement procedures for: identifying and assessing risks related to labor and working conditions of contractors’ workers for effective implementation of the labor and human rights policy in the SCC.

The procedures are implemented in each project through a project specific environmental management plan (EMP) and health, safety & environment plan (HSEP). For brownfield projects, the IMS requires that the company conduct a due diligence of health, safety and environmental management procedures of the customer. If the procedures are found to be at par with Tabreed’s IMS, the customer procedures are adopted; else Tabreed implements its own procedures under the IMS.

As indicated above, DCC’s typical projects are part of a larger development and do not require any land acquisition or cause involuntary resettlement. Further, a screening procedures will be put in place as part of the ESMS upgrade mentioned at ESAP # 1, to screen for significant land acquisition and involuntary resettlement related risks associated with the larger development for which the company will bid, as presented under PS1 section above. However, centralized DC system for municipalities may require land acquisition and cause involuntary resettlement (including that of landowners or informal settlers) for setting up the cooling facility and laying of the pipeline.  As part of the ESMS mentioned at ESAP # 1, for centralized DC system for municipalities, where land has been recently acquired in anticipation or in preparation of the project, and any involuntary resettlement has occurred or will occur on account of DCC’s project, the company will undertake a land acquisition and involuntary resettlement review against IFC PS5 requirements and implement mitigation measures that meet the PS5 requirements. A land acquisition policy and procedure, consistent with IFC PS5, will be prepared and implemented as part of the ESMS upgrade under ESAP # 1.

Organizational Capacity and Competency

Tabreed has a HSEQ function that manages the health, safety and environment aspects of all of its projects. The HSEQ function reports to the Chief Operating Officer of Tabreed. There are in all ten dedicated HSEQ staff in the HSEQ function and five staff are trained lead auditors for ISO 14001 and 45001. During construction, a HSE Engineer is assigned to the site as a shared resource among projects. The HSE Engineer reports to the Project Manager at site and the Corporate HSEQ Head. During O&M, personnel on the-roll of Tabreed (in case of this project on the roll of DDC or Tabreed) is deployed in the project for plant operations and preventive maintenance. These employees are trained on HSE. All employees of Tabreed have key responsibility areas on HSE and are required to undertake activities adopting safe practices and managing pollution in an environmentally sound manner. The company will, as mentioned at ESAP # 3, put in place a HSE organization comprised of at least one corporate HSE expert with provision for appropriately expanding the team when the number of projects in DCC’s portfolio increases. Tabreed’s human resource team is comprised of 35 personnel and the company will also, when required, deploy dedicated staff for human resource management in its India operations.

At the corporate and at each site there is a safety committee comprised of company and contractor’s representatives. HSE training and awareness program are implemented for all employees and contract workers at corporate, other offices and at each project site. This includes induction training, daily tool box talk, mock drills, and refresher courses.

In the upgraded ESMS, the in-house HSE and Social team will be responsible for: application of the pre-bid/pre-contracting ESDD and screening procedure together with appropriate decision authorities in the company; oversight of implementation of the corporate ESMS, and consistent application of the company’s E&S policies across each of its projects, O&M and monitoring follow up on improvement actions; monitoring and reporting E&S performance to DCC’s Board, investors and lenders; corporation wide oversight of internal, external and corporate audits, corrective actions and management review processes; oversight of implementation of any corrective action plan or environment and social management plan at each project site /subsidiary companies based on the ESDD and third party audits; and overall oversight of effectiveness of ESMS implementation.

Monitoring and Review

DCC will adopt Tabreed’s monitoring and review procedures as part of its ESMS mentioned at ESAP # 1. Tabreed’s corporate HSEQ head receives a one-page templated monthly project dashboard on various HSE parameters during construction and O&M stages of projects. The dashboard includes: statistics on hazard and near miss report; hazard and incidents trend analyses; statistics on HSE efforts or leading indicators ; statistics on trainings, including training conducted for contractors. Further, immediate information on any major incident or emergency incident at site is given to Corporate HSEQ Head. In addition to these parameters, as part of upgrade of the ESMS mentioned at ESAP # 1, DCC will also monitor and report energy (electricity and fuel) source and consumption, greenhouse gas (GHG) emissions, water source and consumption, refrigerant type and consumption, quantity and type of solid and hazardous waste generated and disposed, incident frequency rate and severity rate, findings from internal, corporate and third party audits, and corrective actions implemented, compliance with labor laws particularly for contractors’ workers; employee and community grievances received and redressed; and security incidents.

The HSE Engineer at site during construction stage conducts daily monitoring of contractor activities to identify departure from safety procedures. During project development stage, at each stage a [corporate HSE Audit] is conducted. A project closeout report is prepared after completion of construction stage in which the contractor performance including HSEQ and results of project audits are presented among other details. Corporate HSE audits are conducted during O&M stage twice in a year. Plant audits are also conducted during maintenance activities. The Head HSEQ undertakes positive reinforcement activities such as operating from any one project site for an entire day observing the activities conducted at site to form a view on the HSE risks involved and adequacy of procedures established at site for management of such risks. DCC will also adopt these procedures as part of its ESMS mentioned at ESAP # 1. 

Further, as part of the ESMS upgrade, the company will (i) undergo an annual third party audit (mentioned at ESAP # 1) covering ESMS and ESAP implementation including a review of the ESDD, the bid screening procedure and ESMP gap analysis undertaken during the year; and (ii) implement corrective actions based on the findings of this annual third party audit. The analysis of information from the internal and third party audits and evaluation program will feed into the annual management review process.                                                   

 Human Resources (HR) Policies and Procedures

At a typical project construction site there could be between six and eight  DCC employees and about 100 – 125 contract workers. At a typical O&M site depending on the size of the project, there are be about 11 DCC staff and two contract workers at each location.

Tabreed has an Employee Policy Handbook (HR Manual) which lays out the HR Policies and Procedures applicable to all employees. The Employee Policy Handbook is tailored to meet employee management requirements in UAE. DCC will, as mentioned at ESAP # 4, update the Employee Policy Handbook to align it with national employment regulations of India and IFC PS2 provisions. While initially HR functions for DCC will be managed centrally from UAE, gradually as business progresses, the company will put in place HR personnel based in India.

The HR Manual covers key policies including: recruitment, training, working hours, salary, wages and benefits, leaves, performance management, workplace conduct, code of business conduct, disciplinary procedures, whistleblower procedure, prevention of sexual harassment policy and separation among other procedures.

Working Conditions and Terms of Employment

Working conditions and terms of employment are communicated to Tabreed’s (and will be communicated to DCC) employees through their respective employment letters, at the time of induction and through the Employee policy Handbook which will be available on the intranet.

Workers’ Organization

DCC will be committed to complying with relevant laws of India related to employees/workers unions/organizations. This commitment will be included in the upgraded Employee Policy Handbook mentioned at ESAP # 4 and verified as part of the periodic third-party audits.

Non-discrimination and Equal Opportunity

Commitment to equal opportunity and non-discrimination is articulated in the Employee Policy Handbook, the code of business conduct and Tabreed adheres to it in recruitment, training, terms of employment, promotion, discipline, and retirement. DCC’s updated Employee policy Handbook will also explicitly articulate commitment to non-discrimination, equal opportunity and prevention of gender-based violence.

Grievance Mechanism

Tabreed’s HR Manual has policies and provisions to prevent workplace violence; anti-weapons policy; and policy on prevention of sexual harassment with procedures in place for redress of complaints related to sexual harassment. Further, the HR Manual has in place an employee grievance redress mechanism with timebound resolution and escalation procedures. The grievance policy also articulates a commitment to non-retaliation. While the grievance procedure does not provide for anonymous complaints and confidentiality protection, the mechanism states that such grievances may be confidentially processed through the whistleblower process. The grievance process does not cover contract workers.

DCC will, as part of its HR Manual upgrade mentioned at ESAP # 4, upgrade the employee grievance mechanism by including procedures for documentation, analysis and reporting of grievances received and resolved to senior management. With respect to their contractors and sub-contractors, the company will ensure that a formal grievance mechanism is accessible to all workers.

Protecting the Work Force

The Employee Policy Handbook states that candidates below the age of 18 will not be considered for any position and evidence of age is collected at the time of recruitment. There are no policies in the Employee Policy handbook that may be construed as forced labor, but as part of the Employee Policy Handbook upgrade mentioned at ESAP # 4, DCC will articulate a policy on prevention of forced labor.

Occupational Health and Safety

Tabreed (and consequently DCC) manages occupational health and safety (OHS) through the ISO 45001:2018 certified management system that includes: HSE Policy; HSE objectives; risk assessment processes; roles and responsibility allocation; [corporate and site safety committee]; training and safety promotion measures for employees and contract workers; provision of safety signage; provision of personal protective equipment; emergency response plans; accident investigation, reporting and corrective action procedures; work permit system and safe work procedures for various activities that expose workers and employees to hazardous conditions; safe design procedures; access to medical facilities near each site; periodic internal and corporate audit, and management review. The OHS system includes periodic medical examination program for workers covering both employees and contract workers. Tabreed monitors leading and lagging indicators and undertakes analysis of nature and causes of accidents to strengthen accident and incident prevention. Tabreed had no fatal accidents in the year 2017, 2018, 2019 and 2020 and the lost time injury frequency rate (LTIFR) has been consistently zero against the set targets of 1.2, 1.1, 1.0 and 1.0 in these four years respectively. These lost time injury frequency rates are comparable to equivalent OSHA benchmark incidence rate, which is less than 1.0 for this industry.

Workers Engaged by Third Parties

Tabreed has a Supplier Code of Conduct (SCC) that covers compliance with local laws, health, safety, environment, quality, labor and human rights, ethical business conduct and requires suppliers to treat people with respect and dignity, encourage diversity, remain receptive to diverse opinions, promote equal opportunity for all, and foster an inclusive and ethical culture.

While Tabreed has an employee grievance redress mechanism, the same is not available to contract workers. Further, though Tabreed reviews accommodation provided to contract workers, they have not articulated standards for workers accommodation. While contractor’s/vendor’s HSE management capacity and compliances are assessed before contracting a new contractor, there are no procedures to undertake ongoing monitoring of contractor compliance with SCC or national laws. The company will, as part of the HR Manual upgrade mentioned at ESAP # 4, implement a periodic third-party audit process to obtain assurance that its contractors are compliant with labor laws of India and the SCC including requirements related to grievance mechanism and worker accommodation.

DCC will, as part of the update of ESMS mentioned at ESAP # 1, expand their contractor management and oversight procedure by including: (i) a compliance checklist against the applicable legal requirements and PS2 provisions and a periodic internal audit and third party audit procedure; (ii) labor working conditions performance criteria as part of contractor qualification, selection and contract renewal decision; (iii) procedures to ensure consistency of worker accommodation provided by contractors with good international practice as reflected in relevant IFC guidance on worker accommodation; (iv) requirements to enable contract and sub contract workers to access an appropriate grievance mechanism; (v) procedures to ensure that engagement of migrant workers is on substantially equivalent terms as non-migrant workers performing the same work; and (vi) procedures to prevent and redress gender based violence.

These requirements will be included in the contractual agreements with contractors. The company will further ensure that it has procedures, capacity and resources in place to regularly review and monitor the performance of its contractors especially with respect to working conditions, workers’ accommodation, OHS and protection of work force.

Resource Efficiency

Resource efficiency objectives and targets are set every year and achievement monitored particularly in relation to fuel, electricity and water consumption. The plants will be designed with energy efficiency features like variable frequency drives for pumps and cooling tower. DC cooling plants consume 2070 kWh of electricity per RT/year compared to 3680 kWh/RT/year for conventional cooling systems. DC cooling plants consume 17 m3 of water per RT/year..

Tabreed’s plants have enabled reuse of 4 Million m3 of treated sewage water in 2020. Further, in the four prospective projects reviewed, it was estimated by DCC that the makeup water requirement will be 2 Million m3/year. Makeup water could be either treated sewage from the respective facility’s treatment plant or municipal supply in all of the four projects.

Greenhouse Gases

The four prospective projects reviewed as part of IFC’s review would result in total consumption of 237 Million kWh of electricity at peak load and small amount of diesel for standby diesel engine per year. The likely refrigerant leak from the chillers in these four projects would be 550 Kg per year compared to 5400 kg per year for conventional cooling systems. This would amount to an average greenhouse gas emission of about 203,000 tCO2e per year, assuming that the four prospective projects are pursued by DCC. The Coefficient of Performance (cooling delivered divided by energy used to deliver the cooling) of the DC system  to be used by DCC is 5.4 as compared to 2.4 for conventional systems. As part of the upgraded ESMS, the company will account and report GHG emissions as per GIIP. DCC will be using chillers that have HFC 134a (R134a) as the refrigerant, which has a global warming potential of 1300. The DC systems to be used by the DCC will result in a better performance in terms of GHG emissions due to the 43% lower energy consumption as compared to conventional cooling systems. This is in addition to the fact that refrigerant leaks in DC chillers to be used by DCC will be about 90% lower than conventional cooling systems. Further, the company has assessed the possibility of transitioning to hydrofluoroolefins (‘HFO’) but in light of the fact that HFO based chillers are not available in capacities of 2000 RT or more in India, DCC is unable to make that transition in its operations at this point. However, when HFO based chillers are available that meet DCC’s project design requirements, DCC will use HFO based chillers. In addition to putting in place R134a leak minimization procedures as part of the ESMS, the company will, as mentioned at ESAP # 5, put in place a policy and an action plan to transition from hydrofluorocarbons (‘HFC’) to alternative refrigerants or technologies over a period of time.

Air Emissions and Ambient Air Quality

The main sources of air emissions in DCC’s projects are during construction of DC systems: fugitive dust emissions; particulate matter (PM), sulfur dioxide (SO2) and oxides of nitrogen (NOx) from construction equipment and vehicles, from stationary sources like diesel generators (DG) at the project sites; and dust emission from transport of construction material/waste. The company will as part of the upgraded ESMS mentioned at ESAP # 1 put in place procedures to suppress fugitive dust emissions through installation of perimeter fence, sprinkling of water, tyre wetting, storage of excess excavated earth, covered transport of construction material and rubble, and controlled movement of vehicles within the project site. Further, regular maintenance of DG sets and transport vehicles will be undertaken to minimize PM, SO2 and NOx emissions. The company will monitor ambient air quality to assess compliance with national ambient air quality standards at its project sites. The company will also monitor emissions from DG sets to assess compliance with national standards.

The main sources of emissions to air in the O&M phase are the backup DG sets and the refrigerant leak from chillers. The company will have procedures in the ESMS to monitor the emissions from DG sets and leaks from chillers to assess compliance with national standards and in line with GIIP as per WBG EHS Guidelines.

Noise and Vibration

Noise and vibration during construction is due to DG sets, construction equipment and transport of construction material and waste.  The company will regularly monitor daytime noise levels at project sites, limit use of heavy noise and vibration generating equipment to during day time to the extent possible  and ensures mufflers are provided in noise generating equipment. Chillers, backup DG sets and cooling towers are the main source of noise and vibration in DCC’s operations. The company will install chillers, cooling towers and DG sets with appropriate noise reduction devices and vibration attenuation/isolation design such that noise and vibration from the chillers will be maintained within workplace and ambient noise levels as per national standards and WBG EHS Guidelines.

Wastewater Treatment

Generation of wastewater is mainly limited to sanitary and equipment cleaning wastewater in the construction stage, and cooling tower blowdown of about 2.43 m3/RT/year,  and sanitary wastewater in the O&M stage. Tabreed manages cooling water quality through blowdown based on cycles of concentration and condenser tubes cleaning based on approach temperatures. Typically, sewage from construction and O&M stage is treated through either a sewage treatment plant provided by the owner of the premise/building to which the company is providing DC services or through a septic tank and soak pit. Cooling tower blowdown and cooling water filtration/treatment backwash is typically mixed with treated sewage and disposed with the treated sewage wastewater. In the four prospective projects reviewed, the total cooling tower blowdown expected to be generated would be 304,000 m3/year and it would be disposed together with the treated sewage. 

Solid Waste Management

Typically the solid waste from the construction stage is surplus excavated earth, construction debris and other wastes (packing material, metal, cement bags, drums/carbuoys etc.). Surplus excavated earth is typically used for area leveling, back filling and for localized leveling work at site. DCC will have procedures in place to segregate and store construction solid waste in designated areas within the project sites and dispose these through authorized agencies. The company will identify wastes that can be recycled and 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. 

Solid waste in the O&M stage is primarily spent cooling water treatment plant spent media, sludge and grit from the cooling water treatment plant. Other solid waste that is generated once in few years is maintenance scrap from maintenance of the chillers, cooling towers or DG sets. All of these will be disposed through authorized waste disposal agencies.

Hazardous Materials and Wastes

DCC uses chemicals for corrosion inhibition, algaecides/biocides, scale prevention and [for spent water treatment media regeneration]. The company will, as part of its ESMS mentioned at ESAP # 1, put in place procedures for appropriate storage, handling and use of these chemicals within containment, access controls, display of material safety data sheets and measures to be taken in the event of worker exposure to these chemicals. The hazardous wastes generated at in the construction and O&M stages include used engine oils, oil filters, left over paints, leftover chemicals, empty drums/containers for oils, paints, chemicals, used lighting bulbs. DCC will, as part of the ESMS mentioned at ESAP # 1,  have procedures to segregate, label and store hazardous wastes within contained areas and dispose them through authorized entities for treatment, reuse/recycling or disposal. The company will, as part of the upgraded ESMS mentioned at ESAP # 1, implement duty of care procedures to confirm that the hazardous material / waste operators are transporting, handling, storing, treating and disposing of the materials / wastes appropriately in line with GIIP. DCC will be using chillers with HFC134a (R134a) as the refrigerant, which has zero ozone depleting potential and a GWP at 1300. Under the Kigali amendment to Montreal Protocol, a freeze on use of R134a will come into force in India in 2028 and phaseout will commence from 2032. In light of this, DCC will, as mentioned at ESAP # 5, develop and implement a transition plan to use alternatives to R134a like HFOs or other refrigerants or technologies. 

DCC’s construction of centralized DC systems may involve working in public areas or areas accessible to public particularly when laying pipelines. The company will as part of the ESMS mentioned at ESAP # 1, implement documented Road Safety Management procedures to address community health and safety including: material movement planning; traffic management; speed controls and vehicle monitoring; backup alarms; training of equipment operators and drivers in safe driving techniques; provision of patrols/traffic marshals where required. The procedure will be applicable to: DCC’s sites and activities; modes of transport employed by DCC; vehicles owned or rented by DCC and all persons operating such vehicles; and contractors, their personnel and subcontractors, conducting or utilizing all modes of transport for or on behalf of DCC. Further, the ESMS will have procedures for: barricading of excavated areas; safety signage; illumination; reducing fugitive emissions; restriction of night time activities to low noise generating work; monitoring and mitigation of ambient air quality and noise impacts; developing a materials movement plan to ensure that vehicle movement during construction has minimal impact on daily life patterns of nearby communities; and undertaking community safety awareness.

Infrastructure and Equipment Design and Safety

The company’s DC plant will be designed and constructed to international standards and relevant local standards. Before commissioning of the plant a third party agency will be appointed by DCC to certify the plant construction and functioning. Further, all structures and facilities that the company constructs must be approved by regulators before they are commissioned into use.

Community Exposure to Disease

To minimize the risk of increased incidence of communicable diseases, all of DCC’s employees and contract workers will undergo health check-up and have access to medical assistance/facility. DCC will, as part of the upgrade of ESMS mentioned at ESAP # 1, implement procedures to provide standardized worker accommodation that is in line with GIIP. [Further, DCC will design its facilities and implement measures including location of cooling tower, provision of efficient drift eliminators in the cooling towers, treatment of cooling water, cooling water quality monitoring and other measures to prevent community exposure to risk from legionella bacteria.]

Emergency Preparedness and Response

The IMS (and consequently DCC’s ESMS) has procedures for putting in place Emergency Preparedness and Response Plan (EPRP) at each site. For construction, the contractor is required to prepare an EPRP that is reviewed and approved by the company. During O&M, EPRP of the master project (larger real estate/industrial establishment) is reviewed, gaps (if any) are identified and EPRP that fulfils the requirements of the company’s IMS/ESMS is prepared and implemented. All personnel are trained to respond to the potential emergencies at site through training drills and mock drills.

The company will, as part of the ESMS upgrade mentioned at ESAP # 1, include procedures to: (a) systematically assess offsite risk and develop offsite emergency response plans where applicable; (b) communicate the emergency response plan to key stakeholders including where relevant to neighboring communities; and (c) undertake where relevant joint drills with external stakeholders.

Security Personnel

Typically, DCC’s facilities are part of a larger development and hence the company does not directly engage security guards for such projects. For centralized DC projects for municipalities (e.g. standalone City DC System) the company will need to engage security services. A documented security personnel procedure will be implemented, as part of the ESMS upgrade mentioned at ESAP # 1, including procedures for ensuring that: past records of security personnel employed are screened; permissible and impermissible actions are laid out; security personnel are trained in avoidance of human rights violations including among other aspects related to sexual harassment, gender based violence, community and employee interactions; 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.