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The key environmental and social issues for this
project include the following:
- Environmental and social management system
- Wastewater treatment and discharge
- Operation hazard and hazard operability study
- Greenhouse gas emission and energy efficiency
SAPL has presented plans to address these impacts to ensure that
the proposed project will, upon implementation of the specific
agreed measures, comply with the environmental and social
requirements - the Egyptian laws and regulations and the IFC Environment
and Social Performance Standards and the World Bank Group (WBG)
environmental, health and safety guidelines. The information about
how these potential impacts will be addressed by SAPL is summarized
in the paragraphs that follow. Further information is provided in
the attached ESAP, which is agreed upon by IFC and SAPL and will
address the compliance gaps with IFC’s
requirements.
- Social and Environmental Assessment and Management Systems
Land and natural
environment: SAPL’s existing PET
manufacturing site is located in a heavy industrial zone, seven km
west of Haldia port in West Bengal,
India. There are scattered residential houses inside the industrial
zone. The nearest houses are around one km away from SAPL site. The
proposed new PET site is located in a dedicated petrochemical zone
inside the property of Port Authority in Damietta, Egypt.
There is no residential community at or near the Damietta Port.
The EIA for the Indian site and the draft ESIA for the Egyptian
site both indicate that there are no natural protected areas or
protected species at or near the sties.
Environmental and Social Assessment:
SAPL contracted external experts to conduct environmental and
social assessments for the proposed Egyptian site according to both
Egyptian regulatory requirements and IFC Performance Standards. IFC
reviewed the draft ESIA with major data and preliminary
conclusions. According the draft ESIA, the proposed project will
meet both local regulatory requirements and IFC policy/guidelines
upon successful implementation of the mitigation methods. SAPL is
committed to finalize the ESIA before the construction and ensure
that the ESIA meets both local regulatory requirements and IFC
E&S policies and guidelines.
Environmental, health, and safety (EHS) management and
organization:
The EHS management at the Indian site is under technical and HR
managers. SAPL plans to apply for ISO 14001 for its Indian
operations. In accordance with the ESAP, SAPL will establish an
independent EHS department, reporting to the plant manager.
Furthermore, SAPL will set up an effective corporate EHS management
system based on the requirements of IFC Performance Standards.
Training, monitoring, and reporting:
SAPL has an established program to provide necessary training for
all its employees in the field of environmental and social
performances related to its operations. SAPL also conducts routine
environmental, health and safety monitoring for its operations.
SAPL keeps its environmental and social performance records through
its internal reporting structure, and discloses information at its
plant gate in India
as stipulated by the Pollution Control Board of the State
Government. SAPL agrees to disclose its annual E&S performance
reports at its website.
- Labor and Working Conditions
Human Resources Policy and Management:
SAPL has a Human Resources policy which specifies the terms of
employment and working conditions at its Indian site. These include
procedures for hiring and recruiting, probation, training,
performance review, promotion, insurance, salary and compensation,
resignation, lay-off and firing, leave and vacation, and retiring.
HR department also works as an employee grievance mechanism. SAPL
only hires employees older than 20. The HR management meets both local
regulatory and IFC policy requirements. As stated in the ESAP, SAPL
will make the human resources function as a corporate function and
ensure that the HR management at its proposed Egyptian operation
meets both local regulatory and IFC policy requirements.
There are approximately 250 employees and 50 contractors at the
Indian operations. There is no further hiring plan for its Indian
operations. At the proposed Egyptian plant, SAPL may have 350 to
400 employees, in which 30 to 40 are from India, and the remaining 300 to 350
employees are mainly hired locally from Damietta, Egypt.
All hiring at SAPL are strictly merit-based and there are relevant
non-discrimination and equal opportunity rules in the HR policy.
Worker’s Organization:
There is a labor union at the SAPL Indian plant, which is a branch
of a nationwide union. Almost all the labors belong to the union.
There are no strikes or other union unrests in SAPL operation
history. As a routine process, the union represents members in the
collective bargaining for salary and other benefits.
Retrenchment:
There is no retrenchment for this investment. The proposed new
plant in Egypt
will hire 300 to 350 local employees.
Occupational health and safety (OHS):
The safety engineer under the technical manager leads the OHS works
at the Indian plant. Operational safety is highly emphasized in the
operation. There are effective OHS procedures and adequate personal
protection equipment (PPE) provided for each position. In
accordance with the ESAP, SAPL will review the PPE procedures for
all positions and enforce procedures strictly. There is routine OHS
training including annual refreshers for its employees. There is no
serious accident in the operation history of SAPL. The monitored
parameters for workplace conditions and drinking water quality meet
both local regulatory requirements and good international industry
practice. As stated in the ESAP, SAPL will monitor the E. coli in
the drinking water for the Indian plant.
- Pollution Prevention and Abatement
Raw materials and resource consumption:
The major raw material consumption at the Indian site is as
follows; purified terephthalic acid (PTA)
(150,000 t/y), monoethylene glycol (MEG)
( 60,000t/y), water ( 400 t/d), furnace oil (9,000 t/y) for power generation,
and coal (28,000 t/y) for process heating. At the Egyptian site,
the proposed major raw material consumption is PTA (275,000 t/y),
MEG (110,000 t/y), water (250 t/d), electricity (48,200 MWhr/y) from the national grid, and natural gas
(3,000 Nm3/hr) from the national gas network for process heating.
Environmental Compliances:
At the Indian plant, SAPL generates approximately 200 t/d
wastewater, which is treated on site through both anaerobic and
aerobic processes before being discharged to the surface water
channel. Air emissions from the coal-based heater are scrubbed by venturi wet scrubber. The monitored parameters
for wastewater effluents, air emissions, and ambient air/noise meet
both local regulatory requirements and WBG guideline limits. At the
Egyptian plant, SAPL will generate approximately 250 t/d
wastewater, which will be treated before being discharged to the
public sewer network. According to the initial analysis and
modeling calculations of the draft ESIA, the wastewater effluents,
air emissions, and ambient air/noise will meet both local
regulatory requirements and WBG guideline limits upon successful
implementation of the mitigation methods.
Solid and hazardous wastes:
The household solid wastes at both sites are picked up by municipal
contractors for sanitary disposal. The major industrial solid
wastes are off-spec oligomers, which are
sold for other industrial usage. The used catalysts are sent back
to the manufacturers for regeneration. The other limited amounts of
hazardous wastes generated at the Indian site are sent to the West Bengal hazardous waste disposal center
for recycling and disposal. The other limited amounts of hazardous
wastes generated at the Egyptian site will be sent to the hazardous
waste disposal center in Alexandria
for recycling and disposal.
Operational hazard:
Some of SAPL’s raw materials are
hazardous materials. The transportation, storage, and handling of
these materials at the Indian plant meet local regulatory and WBG
guideline requirements. As stated in the ESAP, SAPL will conduct
hazard operability (HAZOP) studies after the debottle-necking
works completion at the Indian site in 2008. SAPL will also conduct
HAZOP for the Egyptian site during the detailed design phase.
Fire prevention and emergency response:
There is adequate fire fighting equipment onsite with proper
maintenance at the Indian site. There is a clinic for both routine
first aid and emergency care. SAPL has its own fire truck and
firefighting team. The external fire trucks and ambulance could
reach the site in five to ten minutes. Fire prevention and
emergency response (ER) are included in new employee trainings and
annual refreshers. SAPL conducts routine drills for fire fighting.
Greenhouse gases (GHG) and energy efficiency:
At the Indian site, SAPL generates 101,500 t/y GHG directly from
onsite power plant and process heating. At the Egyptian site,
according to preliminary estimates from the ESIA, SAPL will
generate 47,800 t/y GHG directly for process heating and generate
19,400 t/y GHG indirectly from power purchase. After both plants
are put into normal operation, both plants will generate 168,700
t/y GHG. As required in the ESAP, SAPL will conduct a comprehensive
energy efficiency audit at its Indian site in 2008 as a mitigation
method to increase energy efficiency and reduce GHG emission.
- Community Health, Safety, and Security
Community health, safety and security:
Both sites are located inside designated industrial zones. There
are scattered houses in the Haldia industrial
zone in India,
while there are no residential areas at or near the Damietta industrial zone in Egypt. The qualitative
risk assessment (QRA) for the Haldia site
indicated, under worst case scenario (pool fire), all impact zones
for significant damages are within the plant borders. The QRA for
the Egyptian site is still under preparation. However, the nearest
residential area from the Egyptian site is approximately three km
away from the site, and this is unlikely to be impacted by the pool
fire.
Emergency preparedness and response:
The raw materials and products at the Indian site are transported
from and to Haldia port. The seven km
transportation route does not go through residential areas. The raw
materials and products at the Egyptian site are transported
directly from the neighboring Damietta
port. None of the SAPL’s raw
materials and products is toxic. SAPL has ER plans available and
conducts routine fire fighting drills for both onsite and offsite
emergency. SAPL will implement similar ER system at the Egyptian
site.
Security personnel:
SAPL hires external agency for plant security at the Indian site,
which conducts routine ID checks at the gates plus security
monitoring. The security personnel do not have any firearms. For
serious security issues, SAPL reports directly to the local police
station.
- Cultural Heritage
The project area at the Egyptian site is not included in or near
any potential archeological sites, which are known to the Egyptian
Government. However, there is always a potential to find buried
antiquities in the Nile delta
area. As indicated in the ESAP, SAPL will prepare a Chance Finds
Procedure of potential buried antiquities for the construction
works.
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Client's
community engagement
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SAPL engages with communities near its Indian site
on an ad-hoc basis. As a member of local industrial association,
SAPL also participates in community meetings six to seven times a
year. SAPL supports some specific projects with regards to
disaster relief, education, public health, and local
infrastructure works. There is no established grievance mechanism
at the Indian plant. As stated in the ESAP, SAPL will set up a
formal community grievance mechanism.
SAPL has held its first public consultation meeting at its
Egyptian site in September 2007. During the peak construction
period, there will be approximately 1,000 contract laborers
working at the Egyptian site, including 200 management staff and
technical laborers from India and China. SAPL will prepare a
labor camp management plan to minimize the social, cultural, and
environmental risks during the construction phase. In addition,
SAPL will hold a second formal public consultation meeting at the
Egyptian site before the major construction works, and maintain
regular communications with the local communities.
Please contact the following for inquiries or concerns about the
environmental and social impacts of this project.
Contact in India:
Biswanath Chattopadhyay,
Executive Director & Chief Executive Officer
“Dhunseri House”, 2nd Floor,
4A, Woodburn Park,
Kolkata – 700 020, India
Telephone: 00 91 33 2280 6972 / 2283-6128 (6 lines)
Contact in Egypt:
Amr A. Fayed, Resident Manager
21 Emtedad Abass
El Akad st.
Flat 82, Rabaa El Adawia
El Istesmary.
Nasr City, Cairo, Egypt
Telephone: 00 202 2690 2321
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