India - Carbon Tetrachloride (CTC) Sector Plan Implementation Project : environmental assessment

E914 February 11, 2004 Environmental and Social Review of Carbon Tetrachloride (CTC) Sector Plan Implementation Project Prepared By Consultancy Development Centre (CDC) (Supported by DSIR, Ministry of Science and Technology, Govt. of India) for Ozone Cell Ministry of Environment and Forests Government of India 11 February, 2004 F1L~~~~~ . I  CONTENTS EXECUTIVE SUMMARY Chapter I: INTRODUCTION Chapter II: REVIEW OF CTC SECTOR PLAN FROM ENVIRONMENTAL AND SOCIAL VIEW POINT o Environmental Aspects o Social Aspects o Options and their Implications Chapter III: IMPACTS & MITIGATION MEASURES IN CTC PHASE OUT PROJECTS o CTC Production Sector o CTC Consumption Sector Chapter IV: MONITORING & VERIFICATION FRAMEWORK o Regulatory Framework * Water and Air Act * Hazardous Wastes (Management & Handling) Rules * Manufacture, Storage and Import of Hazardous Chemicals Rules * Factories Act * Notification on Environmental Statements * Ozone Depleting Substances (Regulation and Control) Rules o Verification Framework Process Assessment (with and without CTC) Baseline Conditions and Data Analysis Environment Management Plan for Dismantling/Closure Manpower Rehabilitation Plan * Social Monitoring Plan Annexure: CHECK UST FOR VERIFICATION PROCESS 1  EXECUTIVE SUMMARY 1.0 Carbon tetrachloride (CTC) is an ozone depleting substance listed in Annex-B group II of the Montreal Protocol on Substances that Deplete the Ozone Layer. The CTC sector plan proposed by the Government of India aims to reduce CTC production and consumption to a level consistent with the obligations of India under the Montreal Protocol. The baseline production and consumption of CTC in India (computed on the basis of data for 1998-2000) are 11,505 ODP tons and 11,553 ODP tons, respectively. As per CTC phase out schedule applicable to India, the production and consumption of CTC are to be reduced by 85% in January, 2005 and 100% in January 2010. 2.0 To achieve the required consumption and production reductions, the CTC Sector plan proposes a series of activities. These include timely completion of on-going activities already approved by the Multilateral Fund (and being implemented through different agencies), implementation of new investment and non-investment activities with priority in the process agent sector and those enterprises already identified during the preparation of this plan. In addition, the proposed plan also includes initiation of CTC phase-out activities in small-scale enterprises in the metal cleaning and textile industries, as well as the introduction of production quotas for non-feedstock applications. 3.0 Based on aforesaid considerations, the present study was undertaken to identify the environmental and social aspects to assess the potential impacts and mitigation/ enhancement measures in sub-project implementation, to examine the relevant regulations and to suggest a monitoring and verification framework so that the CTC phase out activities are carried out in an environmentally sound and socially acceptable manner. 4.0 In Chapter I of this report, the CTC phase out schedule, CTC production and consumption for feedstock and non-feedstock purposes, the activities proposed for the CTC sector plan implementation in India and the purpose of conducting environmental and social review of CTC phase out in different sub-sectors are explained 5.0 The Chapter II outlines the generic environmental and social aspects of the CTC sector plan, as also the options and their implications in Chlorinated Rubber (CR) sub- sector, as an example. The options and scenario analysis include 'do nothing', total closure, emission abatement and conversion to non-ODS process. Among the options, the conversion to non-ODS process is generally preferred while the option of 'do nothing' is ruled out because of Montreal Protocol commitments. The option of total closure may be necessary in certain cases due to non-availability of proper substitutes and plant conditions. The emission abetment option will not phase out the use of CTC. Residual CTC will remain in the final product, unless proper purification systems are adopted. 6.0 The implications of CTC phase out process on occupational health, product quality and durability and financial implications for payment of compensation in the event of lay-off due to process closure/ dismantling are explained. 2  7.0 The Chapter III deals with the impacts, which are likely to be caused in the project activities for curtailment of production and consumption of CTC. As there are currently no commercially available technologies in India to convert CTC to other non-ODS products, it is likely that any quantity of CTC exceeding the demand of the local DV acid chloride industry would have to be disposed of. Any technology options to eliminate the unwanted quantity of CTC should not generate other environmental problems. The choice of technology or measures to address this residual CTC production should conform to the regulations and policies of the Government of India. In case, final destruction of CTC is required, only destruction technology approved by the Parties shall be used. If the CTC phase out plan results in such a situation, appropriate measures will be required to ensure that appropriate environmental studies be undertaken as part of the permitting process. Furthermore, any changes to chloromethane production facilities resulting from the implementation of CTC phase out should be subject to environmental permitting procedures. 8.0 For metal cleaning operations, the use of chlorinated solvents such as trichloroethylene , perchloroethyene and methylene chloride, aqueous and semi- aqueous technologies, as well as cleaning with petroleum solvent, ketones and alcohols are the most likely substitutes for CTC in solvent and process agent applications. The final decision will have to be made on a case-by case basis by participating enterprises and reviewed by the Ozone Cell through experts. 9.0 The Chapter IV explains the existing laws/ regulations, which are applicable to CTC phase out activities and suggest a framework for monitoring and verification measures required to be taken for compliance of relevant regulatory requirements and specific needs for mitigation/ enhancement on a case by case basis. 10.0 Within the existing regulatory framework, the enterprises are required to obtain necessary approval from the concerned authorities including the State Pollution Control Boards and Factories Inspectorate. The regulatory framework for monitoring and regulation of CTC phase out projects will include: * Water (Prevention and Control of Pollution) Act, 1974; * Act (Prevention and Control of Pollution) Act, 1981; * Hazardous Wastes (Management and Handling) Rules, 1989; * Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989; * Factories Act, 1948; * Notification concerning annual Environmental Statements 1993; and, * Ozone Depleting Substances (Regulation and Control) Rules, 2000 11.0 The environmental aspects to be looked into during verification process at different stages of project implementation are explained. The verification should entail assessment of process (with and without CTC), baseline environmental conditions, environmental management plan for dismantling/ closure, manpower rehabilitation plan and social monitoring plan including community involvement. The verification is to be carried out an independent audit team under the supervision of Ozone Cell. A checklist of issues to be audited during the verification process is provided for reference. 3  CHAPTER 1: INTRODUCTION 1.1 The Government of India has taken a number of policy and regulatory measures to encourage adoption of ozone-friendly technologies. These include, among others, the preparation of a country program for the phase out of ozone depleting substances (ODS), certification of ODS consumption in phase out projects, licensing export and import of ODS, and system of granting duty exemptions for goods needed for non- ODS projects approved by the Multilateral Fund for the Implementation of the Montreal Protocol (hereafter "the Fund" or "MLF"). 1.2 Carbon tetrachloride (CTC) is an ozone depleting substance listed in Annex B, Group II, of the Montreal Protocol on Substances that Deplete the Ozone Layer. The CTC Sector Plan proposed by the Government of India aims to reduce CTC production and consumption to a level consistent with the obligations of India under the Montreal Protocol. The CTC phase out schedule that is applicable to Article 5' countries (including India), is as follows: * Consumption o 85% reduction of CTC consumption by 1 January, 2005; o 100% reduction of CTC consumption by 1 January 2010; * Production o 85% reduction of CTC production by 1 January 2005; o 100% of reduction of CTC production by 1 January 2010. The latest CTC consumption (2001) and production levels are 42,639 ODP tons and 18,105 ODP tons, respectively. To be in compliance with the Montreal Protocol, India must reduce its consumption and production levels for non-feedstock applications to 1,725.75 ODP tons and 1,733 ODP2 tons, by 1 January, 2005. The demand for CTC in India for feedstock and non-feedstock applications is more than 40,200 MT per year Article 5 refers to the Montreal Protocol article where developing countries are allowed an extended period of time to accomplish their ODS phaseout objectives. 2 ODP refers to ozone depleting potential, which is the strength of a given substance to deplete stratospheric ozone. 4  (average demand during the period from 1998 to 2000). CTC is used as a feedstock as well as a process agent and solvent. Demand is met by local production of CTC and imported CTC. The average production level of CTC during 1998 - 2000 is about 19,000 MT, which is supplemented by imports of some 21,300 MT per year. On average, about 33,800 MT of the total supply of 40,200 MT was used in the applications considered as feedstock by the Montreal Protocol. Major feedstock applications in India include the use of CTC for the production of CFCs, and the use of CTC for the production of DV acid chloride3. The remaining amount of CTC (40,200 MT less 33,800 MT used as feedstock, laboratory reagents and export ) is consumed by the process agents industry and the solvent sector. The average consumption of CTC in the process agents industry, between 1998 and 2000, is approximately 2,600 MT. A balance of 3,800 MT of CTC is believed to be used in the solvent sector, a large proportion of which is used in small-scale applications. 1.3 As a Party to the Montreal Protocol, India is required to submit its annual production and consumption data for all controlled substances under the Montreal Protocol to the Ozone Secretariat of the United Nations Environment Program (UNEP) in Nairobi (in accordance with Article 7 of the Montreal Protocol). The data reported by the Ozone Cell on behalf of the Government of India, as required by Article 7 of the Protocol, particularly the data for 1998-2000, was used for establishing the baseline levels for production and consumption of CTC during the compliance period. The official baseline consumption and production levels for India are 11,505 ODP tons and 11,553 ODP tons, respectively. (Table 1.1). The estimated CTC consumption and production in 2001 is presented in Table 1.2. Table 1.1: Average CTC Consumption and Production (per Article 7) During 1998- 2000 Reported Data (Article 7) 1998 1999 2000 Baseline Consumption (ODP tons) 6,270 16,099 12,147 11,505 Production (ODP tons) 6,614 15,897 12,147 11,553 3DV acid chloride in an intermediate chemicalfor production of cypermethrin and other synthetic pyrethroids 5  Table 1.2: Estimated CTC Consumption and Production in 2001 MT Total MT Supply 41,120 Domestic Production 16,459 Import 24,661 Demand 38,705 Feedstock Applications 32,649 Consumption* 6,056 *An estimate based on identifiable consumption 1.4 To achieve the required consumption and production reductions, India's CTC Sector Plan proposes a series of activities. These include timely completion of on-going CTC-phaseout activities already approved by the MLF (and being implemented through different agencies), implementation of new investment and non-investment activities with priority in the process agent sector and those enterprises already identified during the preparation of this plan. In addition, the proposed plan also includes initiation of CTC phase-out activities in small-scale enterprises in the metal cleaning and textile industries, as well as the introduction of production quotas for non-feedstock applications. The project includes three separate components, as presented below. CTC-User Investment Activities: Compensation of CTC-using enterprises converting to non-CTC technologies through grant-based assistance linked to the amount of CTC actually utilized. The target CTC-using sectors are: process agent (including chlorinated rubber, pharmaceuticals) and solvents. These conversions will typically involve minor changes in manufacturing and process equipment to accommodate non- ODS substitutes. 6  Production Closure Compensation: Support to a phased reduction in CTC production that is not destined for feedstock applications. Non-Investment Activities: Support to strengthen capacity of the Government of India to effectively oversee implemention of the CTC Sector Plan and address CTC phase-out needs of small CTC users through a multi-pronged approach, including national awareness, Solvent Sector Information Exchange and Capacity Building and a Management Information System (MIS). 1.5 The phasing out of CTC is likely to yield significant environmental benefits, both local and global. In terms of CTC phaseout, the CTC Sector Plan will support the elimination of the non-feedstock usage of over 6000 metric tons (MT) of CTC over the 6-year project implementation period. Local benefits are likely to accrue because CTC is a toxic substance and a suspected carcinogen and its elimination in non- feedstock applications will reduce the hazards of CTC exposure. There could nevertheless be incremental environmental risks if the substitute chemicals are also toxic or flammable or otherwise create a new risk for the users. On the social front, it is expected that some enterprises may decide to fold their operations given the lack of suitable substitutes (such as in chlorinated rubber application). Sound planning and a structured approach would be required for monitoring any possible layoffs associated with project implementation and, if warranted, labor adjustment mechanisms. An Environmental and Social Review (ESR) has been prepared to assess the extent of the environmental and social issues and to evolve an appropriate mechanism and framework for the phase out of CTC. 1.6 Based on aforesaid considerations, the present study was undertaken to identify the environmental and social aspects, assess the potential impacts and mitigation/ enhancement measures in sub-project implementation, examine the relevant regulations and to suggest a monitoring and verification framework to ensure the CTC phase out activities are carried out in an environmentally sound and socially acceptable manner. 7  CHAPTER 1: REVIEW OF CTC SECTOR PLAN FROM ENVIRONMENTAL AND SOCIAL VIEW POINT Environmental Aspects 2.1 The CTC sector plan for curtailment of CTC production and consumption in non- feedstock applications will have implications from environmental viewpoint both at global and local level. The environmental benefits at the global level will be in terms of ODP reduction in compliance with the Montreal Protocol commitments for protection Ozone layer. The amount of CTC to be eliminated is expected to exceed 6000 MT. Alongside, it will have environmental and health implications at the country level through phase out of CTC which is a suspected carcinogen (cancer causing agent). The exposure to CTC takes place through air, water and food which is absorbed in the gastro-intestinal tracts and subsequently distributed throughout the body with higher accumulation in the liver, brain, kidney, fat and blood. The workers in CTC consuming enterprises such as metal cleaning and textile industry are directly exposed to CTC related occupational health hazards. Unfortunately, epidemiological investigations in such enterprises are not available to help ascertain the nature and extent of occupational health hazards due to CTC exposure.. 2.2 Although the use of CTC for feedstock purposes is outside the purview of the CTC Sectot Plan, an issue of concern is the possible leakage and emissions of CTC during production, handling and transportation for feedstock purposes. In view of the fact that considerable quantities of CTC (often beyond stoichiometric requirement) are used in the feedstock production processes and sizable CTC losses have occurred during handling, the environmental implications of CTC use in feedstock applications will need to be addressed for effective implementation of CTC phase out objectives. Many of the these issues have already been addressed through the CFC production phaseout project. 2.3 From environmental viewpoint, the CTC sector plan for phase out of CTC production is not likely to cause any negative impact except in the unlikely case of dismantling,, storage and disposal of equipment and chemicals during closure of production 8  activities which need to be carried out with proper safeguards. This situation arises because it is not expected that any of the CTC producers will actually shutdown their production facilities. It is expected that they will simply reduce production to levels needed to service CTC requirements in feedstock applications. 2.4 On the other hand, the environmental implications of CTC phase out in CTC consuming enterprises include the following: (i) Incremental risk depending on the properties of the substitutes such as toxicity and flammability; (ii) Occupational health and safety; (iii) Pollution potential of technologies/processes using non-CTC substitutes; (iv) Emission Control, effluent treatment and solid waste management requirements; and, (v) Residual effect, if any, on the products manufactured from non-CTC substitutes. Social Aspects 2.5. From the social viewpoint, the CTC sector plan needs to be seen in the context of investment and cost-effectiveness, business and employment opportunities with specific reference to poverty alleviation and compatibility with the industrial policy of the government. 2.6. The owners of some of the CTC consuming enterprisesmay decide to close down the industrial operations partly or entirely which will entail job losses and associated social implications. In cases of lay offs, the enterprises will be legally bound to pay the provident fund and gratuity to the workers as per statutes and other obligation. Some of the enterprises provide voluntary retirement scheme, redeployment and retraining facilities which depend on the management policy of such enterprises. There is no statutory provision for payment of compensation to the laid-off staff. However, the Supreme Court of India has issued a ruling requiring that compensation for labor redundancy resulting from closure of business on environmental reasons should be minimum of 6 years' annual salary and admissible benefits. Therefore, the 9  Supreme Court ruling could be used for computation of compensation payable to the workers facing lay-offs. While the final compensation to displaced workers is likely to be decided on a case-by-case basis, implementation of the CTC Sector Plan will include a mechanism for identifying such cases and monitoring the appropriate implementation of compensation and rehabilitation measures. 2.7. Yet another aspect which needs to be checked during CTC phase out projects is in the metal cleaning sector where CTC is used for metal cleaning such as tubes in refrigerators, circuit breakers and electric installations. In the event of CTC phase out and without proper substitutes, the product quality and durability may be affected. 2.8. Summing up, the environmental and social aspects which need to be taken into account for deriving the benefits of CTC phase out activities include the following: * Environmental protection, occupational health and safety in processes/unit operations using non-CTC substitutes; * Leakage in use of CTC for feedstock purposes; * Environmental and social issues in dismantling/closure of CTC production and consumption enterprises; * Rehabilitation of manpower facing lay-offs in case of dismantling/closure of plants; and, * Effect of CTC phase out on the quality and durability of consumer products which are currently based on CTC application. Options and their Implications 2.9 The purpose of this section is to examine the likely environmental and social issues associated with the options available. From environmental and social viewpoint, the overall implications of the CTC Sector plan may be considered in the context of the following generic options: (i) Do nothing scenario 10  (ii) Total closure (iii) ODS emission abatement (iv) Conversion to non - ODS process The following sections examine the alternative analysis scenario in the case of one specific sub-sector, as an example of the analysis of alternatives which will be undertaken at the subproject level. The case in point is that of conversion of the manufacturing of chlorinated rubber to non-CTC technology. The use of CTC in this application is that of a process agent. Similar assessments will be undertaken by each CTC-consuming enterprise as part of their decision-making and alternative of analysis effort as they seek to replace CTC with non-ODS substitute. Option I: Do nothing Scenario 2.10. If the option of 'Do nothing' is considered, India will not be able to fulfill its commitment under the Montreal Protocol, by which it has to achieve a reduction of 85% of the baseline in CTC production and consumption by the year 2005. Thus, the objectives of the country programme for ODS phase out will not be met. The do nothing scenario is therefore not a feasible scenario. 2.11 CTC is not only an ozone depleting substance but also a suspected carcinogen. Studies of concentrations detected in a wide range of indoor and outdoor samples indicate that the general population can be exposed to CTC through air, food and drinking water which is absorbed from the gastro-intestinal and respiratory tracts and distributed throughout the body, with the highest concentrations detected in the liver, brain, kidney muscle, fat and blood. Hence, do nothing approach will not be a desirable option. 2.12 As discussed above, the implications of other options are reviewed with specific reference to the Chlorinated Rubber (CR) sub-sector. Option 2: Total Closure  2.13 India is the second largest producer of chlorinated rubber (CR) in the World, with robust domestic demand for consumption in heavy duty coatings for protection against corrosion in industrial plants for use in marine coatings to protect ships, on-shore and off-shore steel structures, etc. Several industries in the country are dependent upon the use of heavy duty paints and performance inks based on CR. Any disruption in availability of CR will have a detrimental effect on these industries, and closure in any case is against the general principles and guidelines for categories of incremental costs. However, in specific cases, considering the plant conditions and cost of CTC phase out through other options, total closure may be opted provided the social impact in terms of labour adjustments are taken care of. For mitigation of environmental impacts due to plant closure which will involve dismantling, storage and disposal of equipment containing hazardous chemicals, necessary precautionary measures will have to be taken as per hazardous wastes (Management on Handling) Rules, 1989 with prior approval of the closure plan and under supervision of concerned State Pollution Control Board. Option 3: ODS Emission Abatement 2.14 The arguments against opting for emission abatement system in Indian conditions are: * It requires a long period for development and stabilization, and even in non Article 5(1) countries such systems are more effective only in large units with concerted efforts stretching over 10 years or more, and involving large expenditures; * Operation of these systems requires uninterrupted power supply, highly skilled man-power for maintenance and upkeep of plant facilities and sustained training and experience; * Frequent power disruptions and consequent malfunctioning of abatement systems will, in fact, lead to higher emissions; * Such conditions are difficult to achieve in Article 5(1) countries with comparatively smaller facilities; * Technology transfer is difficult to procure for Article 5(1) countries; 12  * Lack of experience will render it difficult to operate the sophisticated emission abatement system; * This option is more expensive than other options; * The emission abatement system does not resolve the problem of substantial quantity of residual CTC in the end product. Installation of a solvent exchange system to get over this problem is costly and the required technology is not available; and, * Finally, adoption of emission abatement is at best an interim solution and continues to rely on CTC; 2.15 An emission abatement system in principle consists of devices for collection, treatment, recovery, disposal, emission and quality control. This can be applied for various applications, including soil conservation, water purification, and air vapor purification or recycling. An emission abatement system is characterized by strict control of operations. A large number of valves and joints in the plant need to be controlled for emissions/ leakage; pumps and sealing systems of the reactors also need to be modified or replaced for sealing. It is also sensitive to electrical fluctuations, which can lead to higher emissions of CTC. 2.16 The incremental cost of the emission abatement system has been worked out for a plant having capacity of 550 MT of CR per annum. The incremental investment cost for this plant is worked out at US$ 2,199,230. The incremental operating cost for this plant (NPV for four years) is worked out at US$ 779,636; this provides total cost for this plant of $2,978,866. These estimates do not include the cost of licensing of technology or engineering consultancy charges over the period of operationalizing the emission abatement system; such cost would have to be added to the incremental investment cost of this option. 2.17 With emission abatement system alone, enterprises will not be able to completely phase out the use of CTC. Additional purification systems must be put in place in order to remove and recover CTC that is entrapped in the final product. Failure to do so will result in having about 3.5% of CTC used on chlorinated rubber remaining in the 13  product and eventually emitted to the atmosphere. Furthermore, the product with this level of CTC content has become increasingly unacceptable as customers are discriminating against chlorinated rubber with a CTC content of more than 10 ppm. Even if the Indian chlorinated rubber producers decide to exercise this option, they will not be able to do so because they do not have access to the product purification technology. Option 4: Conversion to Non-ODS Process 2.18 The actual cost of conversion of chlorinated rubber plants could vary significantly depending on the conditions of the existing equipment and the process employed. Alternative technologies for chlorinated rubber have only recently emerged. Due to the lack of experience with regard to these new technologies, it is difficult to estimate as to what the actual cost for conversion at each enterprise would be. Depending on which types of technologies and/ or technology providers the enterprises will have an access to, conversions may involve modifications of existing plants or rebuild the whole new plants and additional costs will be required for technology licenses and fees. Moreover, not all existing plants will be able to access the new non-CTC technologies. It is important to note that the cost of conversion, particularly for smaller factories, may likely be more expensive as unit cost of smaller plant capacity is normally higher. Depending on the existing process and plant design, some plants may require complete replacement of all existing equipment. 2.19 The technology for use of aqueous media as a solvent could be a viable alternative to the current process based on CTC. However, the advantage of CTC elimination is achievable with higher volumes of materials handling and unit operations. It also requires proper treatment facilities for large volume of waste water containing high AOX (Adsorbable Organic Halogen Compounds) and hazardous waste. 2.20 Switch over to non-ODS substitutes is a generally preferred option not only for Chlorinated Rubber but also for other sub-sectors. Some enterprises have opted for use of trichloroethylene and perchloroethylene as metal cleaning solvent while the pharmaceutical /chemical enterprises have opted for specific substitutes to suit their 14  process requirement. For instance, in production of 4-nitobenzyl bromide instead of CTC, use of N-bromosuccinide (NBS) and dichlorophosphoric acid for production of pyrophosphoryl chloride have been proposed. While these substitutes will help reduction of ODP, necessary precautions will need to be taken for prevention and control of pollution, health hazards and for safety. 15  CHAPTER III: IMPACTS & MITIGATION MEASURES IN CTC PHASE OUT PROJECTS CTC PRODUCTION SECTOR 3.1 In the previous chapter, a generic review of environmental and social implications for CTC phaseout were examined, including a more detailed analysis of alternatives in the context of different scenarios for a specific sub-sector (Chlorinated Rubber) . This section examines in more detail the likely impacts and suggests mitigation measures in the CTC phase out activities for the production as well as consumption sectors. 3.2 Production is defined by the Montreal Protocol as CTC produced in the country, minus the amount destroyed by technologies approved by the Parties and minus the amount used as feedstock in the manufacture of other chemicals. In the Indian context, where no CTC is destroyed, production means the amount locally produced, minus the amount used as feedstock in the manufacture of other non-ODS chemicals. There are two feedstock applications in India. These are CTC used for CFC production and for the production of DV acid chloride. 3.3 While CTC used as feedstock for CFC production is declining due the CFC production closure agreement between the Government of India and the Executive Committee of the MLF, the demand for CTC for the production of DV acid chloride has been increasing. CTC produced and eventually used as feedstock for the production of DV acid chloride is not considered as a controlled substance by the Montreal Protocol. To comply with the Montreal Protocol phase-out schedule for the consumption sector, CTC consumption in the process agent industry and the solvent sector must be eliminated. Therefore, the demand for CTC and CTC production after 2010 will only be limited to the DV acid chloride industry plus what may be exported for non-ODS applications (i.e. other feedstock applications). 3.4 Like most CTC producers in the world, CTC producers in India employ CTC production technologies that yield CTC plus two additional co-products: methylene 16  chloride (also referred to as C2) and chloroform (often referred to as C3). There has been over the years five CTC producers in India. Two of them have stopped production of CTC. These two shutdown plants employed a chemical reaction process that yielded only CTC. However, the remaining manufacturers are, in fact, chloromethane manufacturers. The chemical process used for manufacturing CTC generates two co-products whose demand is increasing as mentioned previously. The process employed by these three active facilities has limited flexibility in terms of production ratios for the three products. Efforts to minimize or eventually phase out the production of CTC will affect the supply of methylene chloride and chloroform unless there is a demand for CTC used as feedstock that is substantial enough to absorb all the surplus CTC. Otherwise, the surplus CTC would have to be destroyed or incinerated as being done in some Article 2 countries. The preparation of a CTC phase-out plan in the production sector must therefore take into account the demand of co-products and the need for India to meet this demand in order to prevent any disruption to the industry that depends on these co-products; a situation that would drastically increase the overall cost of CTC phase-out in the country. The phase-out plan for CTC production should also give due consideration to the fact that there will be continued demand for CTC in feedstock applications and, most likely, other applications that are considered as exempted uses by the Montreal Protocol. 3.5 Since the existing production technologies for chloroform and methylene chloride will continue to generate CTC as a by-product, it is likely that there will be surplus of CTC in the future given that the overall demand for CTC is now declining rapidly with the phase-out of CFC production. Nevertheless, in the early years of the CTC Sector Plan, it is expected that reduction in CTC consumption will result in a reduction in the import of CTC and no immediate impacts on local production (i.e. we will see an import substitution effect). There are no incremental environmental issues associated with this substitution. Once imports have been largely replaced by local production, CTC producers may start reducing their CTC outputs by further reducing the ratio of CTC to the other co-products, C2 and C3. Again, there are no incremental environmental issues associated with this reduction. Environmental issues arise only when CTC is produced in excess, requiring some form of transformation or disposal. It is highly uncertain if 17  and when this would happen, given that there continues to be significant growth in DV acid chloride production. 3.6 As there are currently no commercially available technologies in India to convert CTC to other non-ODS products, it is likely that any quantity of CTC exceeding the demand of the local DV acid chloride industry would have to be disposed of. Any technology options to eliminate the unwanted quantity of CTC should not generate other environmental problems. The choice of technology or measures to address this residual CTC production should conform to the regulations and policies of the Government of India. In case, final destruction of CTC is required, only destruction technology approved by the Parties to the Montreal Protocol shall be used. If the CTC phaseout plan results in such a situation, appropriate measures will be required to ensure that appropriate environmental studies be undertaken as part of the permitting process. Furthermore, any changes to chloromethane production facilities resulting from the implementation of CTC phase out should be subject to establishment environmental permitting procedures. The preferred scenario selected by the CTC producers for the purpose of determining the incremental cost of CTC production reduction was based on the reduction of total chloromethane production and not on disposal or incineration of excess CTC, which itself is a very expensive proposal. 3.7. The CTC production phase-out strategy developed by the Government of India should attempt to minimize the cost of meeting demand of all chloromethane products. For environmental and economic reasons, the incineration option should be avoided to the extent possible. The least-cost adjustment path for chloromethane production has to take into account the demand of methylene chloride, chloroform, and CTC. CTC CONSUMPTION SECTOR 3.8 This section examines the issues and options available to enterprises when considering the replacement of CTC with non-ODS substances. 3.9 The project proposals in various industrial sectors where CTC is currently used as process agent or solvent include many possible substitutes for CTC including 18  (i) Aqueous media (ii) Trichloroethylene (iii)Perchloroethylene (iv)No clean options 3.10. The substitutes proposed to be used for CTC phase out will no doubt result in ODP reduction and associated benefits. However, these are not free from environmental problems form the view point of pollution and safety particularly when trichlroethylene is used. 3.11. Use of aqueous media in chlorinated rubber and chlorinated paraffin production has been proposed primarily on account of the cost advantage as compared to other non- ODS technologies. While the use of aqueous media as a solvent in place of CTC offers a viable alternative, it will involve expenditure for handling large volume of wastewater and treatment facilities for wastewater containing high AOX (Adsorbable Halogenated Compounds) which can otherwise cause adverse impacts when discharged into watercourse without necessary treatment. It will also require facilities for handling of hazardous semi-solids generated in the process. 3.12. For metal cleaning operations, the use of chlorinated solvents such as trichloroethylene , perchloroethyene and methylene chloride, the aqueous and semi- aqueous technologies, as well as cleaning with petroleum solvent, ketones and alcohols are the most likely substitutes for CTC in solvent and process agent application The final decision will be made on a case-by case basis by participating enterprises and reviewed by the Ozone Cell through their experts. 3.13. Aqueous alkaline cleaning is preferred for cleaning requirements with less complicated shapes, a minimum of different metal substrates and where inorganic residues are to be removed. Since cleaning efficiency is less than for solvent cleaning, an ultrasonic system is normally incorporated in the wash stage. The usual sequence is a 4-stage system with Ultrasonic wash - rinse - final rinse - hot air drying. Demanding applications may need a further rinse stage with de-onized 19  water. Where rusting is a problem, a vacuum drier can be considered if incorporation of a rust inhibitor treatment is not practical. 3.14. Rusting can be prevented by use of a rust inhibitor to the bath in the last rinse stage. An oil separation system (wash fluid regeneration) is essential to remove oils from the wash fluid and should be part of the OEM's standard package. A waste water treatment plant is needed to minimise discharge of harmful effluent to the environment if internal or outside tertiary waste treatment facilities are not accessible 3.15. Solvent cleaning is usually the preferred option by enterprises for complicated shapes and where oils and grease are to be removed. Techniques of vapour degreasing in low emission equipment of various types were developed in the late 1980's in response to pressure from legislation relating to environmental and worker health protection. This change was not an upgrading of cleaning technology. Cleaning performance was the same but emissions to both the working and outside environments were greatly reduced. Equipment cost is higher and batch times are longer because of the additional steps in the cycle. 3.16. The recent re-classification by the EU of trichloroethylene (TCE) from Class 3 carcinogen to Class 2 (i.e..same as CTC) led to a study of the health and safety aspects of this solvent as replacement for CTC in metal cleaning. As a result, the following restrictions have been adopted in USA, based on European developments, to ensure the protection of worker health and safety: * Closed equipment is to be used when surface cleaning with trichloroethylene; and, * A workplace Threshold Limit Value - Time- Weighted Average (TLV-TWA) for trichloroethylene of 5 ppm (26.9 mg/m) is required. 3.17. Trichloroethylene nevertheless remains the most widely used metal cleaning solvent in USA and this situation is not expected to change in the short term. Its use in Europe will decrease considerably over the coming years as a result of the regulatory 20  requirements arising from the EU re-classification. Perchloroethylene remains in Class 3 in Europe. TLV-TWA values range from 10 (Sweden ) through 25 (USA) to 50 ppm (UK, Germany). It is the standard solvent for dry-cleaning in Europe and USA. 3.18. Perchloroethylene (PCE) is used in metal cleaning in the same type of closed equipment as TCE, with similar investment costs. PCE has a higher boiling-point (121 deg.C compared to 87 deg.C), and power requirements are higher for internal solvent distillation and since the work pieces are cleaned at a higher temperature. The higher operating temperature also means that equipment must be closed, not only to minimize workplace exposures, but also to provide adequate and fast drying under vacuum. In closed equipment, the hot metal of the work pieces is cooled much more easily during drying, which is important for throughput. 3.19. Techniques have also been developed for hydrocarbon (HC) solvent cleaning. These use non-aromatic isoparaffins (C9-C12) such as Exxon Actrel, Isophar H or Shellsol TK, with high flash-points(>55 deg.C), and very low levels of carcinogenic aromatics such as benzene. They have found favour primarily in situations where chlorinated solvents are either banned or severely restricted and aqueous cleaning is not well suited. The major disadvantages of HC cleaning are: (i) Costs of equipment and chemicals are significantly higher; (ii) Cleaning performance is inferior to chlorinated solvents; and, (iii) Risk of fire (reduced by having explosion-proof motors and other precautions) 3.20. The Hind Metal and Tubes(HMT) has run trials with aqueous alkaline cleaning for brass coils and pipes but with unacceptable results. Of the solvent cleaning techniques, trichloroethylene cleaning has been selected because it is considerably more cost-effective than hydrocarbon cleaning. Trichloroethylene is an indigenous product and available at less cost than the imported solvents. 3.21. The closed degreaser with internal recycle would be compatible for all three types of solvents. TCE boiling point is much lower which simplifies solvent recovery and 21  reduces cooling time. Considering the health and safety risks due to the suspected carcinogenic properties, use of TCE solvent in a closed solvent degreaser is a must. CTC is a very strong and effective solvent and the cleaning is possible with cold dip facility. For TCE also, cold cleaning would be possible. However, TCE cleaning requires more time than CTC. Due to the higher boiling point of TCE the drying time also will be more. 3.22. A floor pan or bund is needed for each installation to prevent any ground water contamination in the event of spill or leakage of trichloroethylene. The capacity of the pan should be greater than the total solvent inventory of the machine. If the pan is made of steel, it should be earthed. Since concrete is permeable to chlorinated solvents, a bund of this material needs to be of a suitable quality of concrete and also needs to be lined with a laminate or other material that covers capillary cracks and is suitable for TCE service. 3.23. Exposure of workers to trichloroethylene vapours should be kept to a minimum (which is the reason for the choice of closed systems). The ventilation system will therefore need to be optimised and provision made for worker protective equipment when transferring fresh solvent and sump wastes to and from the distillation/recovery unit. Accidental exposure to liquid TCE and other solvents requires the immediate availability of adequate facilities for eyewash and for showering. 3.24. The use of TCE as cleaning agent is generally safer than the use of flammable substances, but the hazards of TCE are such that it requires careful handling. To avoid acute exposures or the development of chronic exposure situations during routine operations, it is important to spell out the use of protective equipment and handling procedures during such procedures as unloading, degreaser tank make- up and spent solvent transfer. People should be trained before they are permitted to become operators in the cleaning area. Periodic retraining is also recommended. Periodic air quality sampling in the work areas is necessary. 3.25. While TCE degrades rapidly in the atmosphere, it degrades only slowly if it is allowed to reach aquifers or other groundwater supplies. Therefore, handling 22  practices and training must include training to avoid spills and leaks in order to protect water supplies from contamination. 3.26. Sump wastes and spent solvent need to be disposed in an environmentally acceptable manner and in accordance with local and governmental regulations. The current practice of disposing such wastes on open fields should be reviewed. Incineration in an appropriate cement kiln should be examined for acceptability. 3.27. This section illustrates the need for precautionary measures for most conversions from CTC to non-ODS substitute. Each alternative comes with advantages and disadvantages and different performance parameters. Each enterprise will be encouraged to make technical decisions that are consistent with its operational framework and to utilize substitutes that are benign and have the least needs for mitigation. In this regard, the subproject cycle will therefore be designed to facilitate the provision of technical assistance to assist with the choice of substitute, in particular with the introduction of no-clean and cleaner production technologies. 23  CHAPTER IV: MONITORING & VERIFICATION FRAMEWORK 4.1 India's CTC Sector Plan is to be implemented through a number of subprojects in the production and consumption enterprises. This requires a defined framework for monitoring and verification (audit) at different stages of project cycles. Along with monitoring and verification of CTC phase out targets , the subproject cycle will include on-site verification of environmental protection, occupational health and safety measures and any impacts on employment and staffing . This will be an important requirement to ensure compliance with applicable laws and regulations thorough appropriate mitigation/ enhancement measures. In addition, for subprojects which may involve job losses, it will be necessary to develop a monitoring system to assess the impact on labour displacement and modalities for manpower rehabilitation, including measures to provide an adequate level of financial compensation 4.2 This section enlists the existing laws/ regulations which are applicable to CTC phase out activities and suggest a framework for monitoring and verification measures required to be taken by the enterprises for compliance of regulatory requirements and specific needs for mitigation/ enhancement on a case by case basis. Rel!ulatory Framework 4.3 In consonance with its policy to ensure that the industrial activities are pursued in an environmentally sound and socially acceptable manner, the Government of India has enacted laws and notified regulations from time to time. 4.4 For mitigation of adverse effects, enhancement of protection measures and review of environmental requirements in industrial operations, the regulatory framework includes the following: * Water (Prevention and Control of Pollution) Act, 1974; * Act (Prevention and Control of Pollution) Act, 1981; * Hazardous Wastes (Management and Handling) Rules, 1989; * Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989; 24  * Factories Act, 1948; * Notification concerning Annual Environmental Statements, 1993; and, * Ozone Depleting Substances (Regulation and Control) Rules, 2000. Water and Air Act 4.5 As per provision of the water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981, the enterprises should obtain ''consent" of the concerned State Pollution Control Boards/ Pollution Control Committees at the U.T. level for discharge of effluents and emissions from their operations. For seeking consent, the enterprises need to submit the details of their processes/ operations alongwith particulars of effluent and emission control systems. Depending on the nature of industrial operations, the Pollution Control Boards/ Committees give consent for a period of one to five years which is subject to renewal on expiry of the consent validity period and periodic monitoring to verify the compliance of prescribed effluent and emission standards. Hazardous Wastes (Management Handling) Rules 4.6 As per Hazardous Wastes (Management and Handling) Rules, 1989, the enterprise need to seek "authorization" from the concerned State Pollution control Boards/ Committees for handling and disposal of hazardous wastes within the industrial premises and in designated disposal sites. Manufacture. Storage and Import of Hazardous Chemicals Rules 4.7 The CTC related projects will be subject to compliance of the Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989. In accordance with these Rules, the enterprises are required to carry out safety audit as well as prepare on-site and off- site emergency plans for submission to and review by the designated authorities including the Pollution Control Boards and Factories Inspectorate. Factories Act 4.8 For occupational health and safety, the threshold limits of emissions and safety measures (such as protective gloves, masks etc.) are prescribed under the Factories 25  Act, 1948 and these are enforced through the Factories Inspectorate. The industrial activities for CTC phase out should comply with the requirements of the Factories Act. Notification on Environmental Statements 4.9 In accordance with this notification (dated 22nd April, 1993), the enterprises are required to submit their Annual Environmental Statements to the respective State Pollution control Boards/ Pollution Control Committees at U.T. level by 30th September. The statements are to include the following data/ information in regarding to the industry: * Water and raw material consumption; * Discharge of water and air pollutants per unit of output; * Hazardous wastes and solid wastes from process and pollution control facilities; * Composition and quantum of hazardous wastes and solid wastes and the practices adopted for their disposal; * Impact of the pollution abatement measures on conservation of natural resources and cost of production; * Additional measures/ investment proposed for environmental protection; and, * Any other particulars for improving environmental quality. Ozone Depleting Substances (Regulation and Control) Rules 4.10 The Ozone Depleting Substances (Regulation and Control) Rules, 2000 have laid down the monitoring and reporting requirements for various activities including destruction of ozone depleting substances (ODS) and use of non-ozone depleting substances. The beneficiary enterprises are required to comply with the requirements as stipulated in the Rules. In the context of the CTC Sector Plan, this will include the application of provisions for registration with the Ozone Cell, import licenses and limitations on allowable uses of CTC. Its is expected that the Ozone Rules will be amended to include a ban on the use of CTC in the applications where CTC phaseout is being supported under this project. Verification Framework 26  4.11 Notwithstanding statutory obligations for compliance of relevant laws/regulations, it is necessary to adopt a protocol for the CTC phase out projects to verify that the environmental and social aspects are duly incorporated and implemented at different stages of project cycles. This verification protocol will in effect become the defacto environmental and social management framework (EMF)for the project. The protocol will be designed in accordance with the overall verification framework, as discussed below. 4.12 The subproject cycles for the CTC consuming enterprises and for the CTC producers involve various action points and actors as presented in the following Tables. The shaded sections represent the major milestones for execution of EMF requirements. Table 4.1: Proiect Cycle for CTC Consuming Enterprise Step. Action Actors 1. Ozone Cell sends letter to enterprises MOEF/ Ozone Cell/ PMU indicating project initiation and CTC phaseout requirements 2. Enterprise sends expression of interest to Enterprise, with PMU Ozone Cell and project proposal support 3. Initial verification! audit. In addition to PMU consultant under verifying CTC usage, this step will include a Ozone Cell supervision preliminary verification of environmental and social issues. 4. Endorsement of verification findings Ozone Cell/ PMU 5. Confirmation of eligibility and grant amount to Ozone Cell/ PMU enterprise (including equipment disposal plan) 6. Financial agent prepares subgrant agreement Fl and signature of grant with enterprise 7. Interim verification(s) (optional) PMNU consultant 27  8. Enterprise conveys completion notice to Enterprise MOEF 9. Final verification/ audit (including verification PMU consultant under of equipment disposal) Ozone Cell supervision 10. Notification to Bank of subproject completion Ozone Cell/ PMU and request for disbursement clearance 11. Review and clearance of verification report and Bank disbursement clearance 12. Disbursement Fl Table 4.2: CTC Producer Annual Work Programme Cycle S.No Action Actors 1. Issue quotas Ozone Cell/ PMU 2. Annual Material Balance Audit PMU, with producer support 3. Half-Yearly Audit Ozone cell/ PMU 4. Disbursement PMU, clearance by Bank 5. Quarterly CTC Production report OC/ PMU CTC producers 4.13 As per the above Tables, verification/ audit for the CTC producers is on half yearly basis and for CTC consuming enterprises it is to be done in the following phases: (i) Initial verification on submission of the project proposal (ii) Interim verification (optional) during implementation of project; and, (iii) Final verification on completion of project. 28  4.14 The verification exercises shall be carried out by independent consultant(s) reporting to the Ozone Cell's PMU and the project proponents will be required to provide relevant information as needed. The initial verification at the beginning of the project should include verification and documentation of baseline conditions and measures required for implementation of projects in an environmentally sound and socially acceptable manner. The verification is to be undertaken on the basis of information furnished by the project proponents and site visit for physical verification. The verification team may suggest additional measures/ modifications based on which an action plan alongwith time schedule should be prepared by the enterprise. Work is currently underway to develop the verification protocol which is to guide this initial verification. This will include appropriate sections covering the key elements covering environmental and social issues. 4.15 The interim verification, where undertaken, during execution of projects is for verification of the progress in implementation of various measures as proposed/ recommended in the initial stage. 4.16 The final verification on completion of projects is to verify as to whether the action plan and time schedule for environmental safeguards and social considerations have been duly implemented and whether any further action needs to be taken. Again, this verification step will be governed by a verification protocol which is to include necessary aspects referring to environmental and social issues. 4.17 The various aspects to be assessed during the verification should include the following: (i) Process Assessment (with and without CTC) (ii) Baseline Conditions and Data Analysis (iii) Environment Management Plan for Dismantling/Closure (iv) Manpower Rehabilitation Plan (where required) (v) Social Monitoring Plan These aspects of the verification framework are further elaborated below. Various aspects of these questions will be examined during the subproject cycle, in accordance with the status of project execution. 29  Each of these aspects are discussed and elaborated further in the following paragraphs Process Assessment (with and without CTC) 4.18 The existing and proposed process/unit operations and the justifications for selection of CTC substitutes and technologies should be assessed. These should include data relating to raw materials requirements, pollution potential, occupational health and safety implications in various unit operations using the selected CTC substitutes. The relevant information should be furnished by the enterprise. Baseline Conditions and Data Analysis 4.19 At the initiation stage of a project, based on information furnished by the enterprise and site visit, verification needs to be carried out to assess the baseline conditions and analysis of available data on various aspects of environmental concern. These include the following: * Requirement of raw materials (including CTC substitutes) and their characteristics. * Water requirement * Waste water generation * Characteristics of wastewater * Wastewater treatment systems and their performance * Method for disposal of treated effluent * Process emissions and their characteristics * Emission control systems and their performance * Ambient air quality in the work place and surrounding areas. * Treatment and disposal of solid wastes/ hazardous wastes from the process/effluent treatment plant * Status of compliance with the regulatory requirements. 30  Environment Management Plan for Dismantling/Closure 4.20 The beneficiary enterprise needs to prepare an Environment Management Plan (EMP) to ensure that the potential environmental issues are duly addressed during dismantling/ closure. The EMP should include the following: * Baseline environmental scenario - Water Quality - Air Quality - Soil characteristics - Noise levels * Sequence of dismantling/closure plans * Measures for plant operation and safety requirements * Decontamination or destruction details * Storage/disposal of dismantled equipment * Treatment/disposal of unusable chemicals, if any. * Monitoring plan including community involvement. Manpower Rehabilitation Plan 4.21 The CTC phase out projects may involve job losses on account of process modifications or dismantling of certain equipment and unit operations or closure of production/manufacturing activities. In such cases, the workforce in different categories likely to be displaced should be enlisted and a Manpower Rehabilitation Plan (MRP) should be prepared by the enterprise. In addition to statutory benefits such as Provident fund and gratuity, the MRP should specify the modalities and details of rehabilitation proposed for displaced personnel such as redeployment, compensation and voluntary retirement scheme (VRS). Depending on the aptitude and interest of the personnel facing lay-offs, provision of retraining facilities for other jobs or support for entrepreneurship development are among the other options which need to be considered for preparation of the manpower rehabilitation plan. 4.22 To streamline the implementation of MRP, the enterprise should, in advance, disclose the compensation package proposed for the persons facing lay off. It should be 31  checked during verification process. To assess the effectiveness of labour adjustment, follow-up sample survey needs to be organized under the aegis of PMU. 4.23 As per GOI statutes, the employees facing lay off are entitled to get the provident fund and gratuity benefits from the enterprise depending on the length of their service. Also, according to the Supreme Court ruling, compensation for labour redundancy from closure of business on environmental ground should be a minimum 6 years annual salary and admissible benefits. Social Monitoring Plan 4.24 A monitoring mechanism including representatives of the workforce in the industry and of local conmmunity needs to be set up by the enterprise for participatory involvement in monitoring implementation of environmental and social welfare measures. The issues/indicators for monitoring could be grouped into following categories: * Benefits from the projects * Preventive and mitigative measures for environmental safeguards and occupational health and safety; and, * Social welfare measures including labour adjustment in cases ofjob losses. 4.25 The enterprise should be responsible for reporting arrangements for public disclosure which may include dissemination of relevant information through print/electronic media, query-response service and periodic consultative meetings for interaction with the stakeholders. Based on verification of baseline conditions and analysis of data for environmental parameters (such as water quality, air quality and waste management) and interaction with the stakeholders, the key indicators for monitoring of environmental and social welfare measures should be enlisted and reported to PMU. CAPACITY BUILDING In addition to the investment activities, the CTC phase out plan proposes key non investment activities to strengthen capacity for adhering CTC phase out needs of Consuming Sectors. These include: 32  (i). Information exchanue : The information exchange programme is required for raising awareness regarding the Montreal Protocol and to ensure that the industry has sufficient time to plan for its phase out of CTC. This would also help to improve the knowledge of CTC end uses of the available alternatives that are environment friendly and do not compromise safety. (ii) Awareness activities: It is essential to carry out awareness campaigns about knowledge updates pertaining to phase out requirements of CTC in accordance with the phase out plan, Government interventions, rules and regulations, availability of technical and financial assistance, alternative technologies, etc, through media, network of industry representatives and associations and direct communication wherever possible. (iii) Setting up Alternative Technology Services Units: To provide support in termns of technical and required operational administration to ensure successful conversion to non-CTC technologies. The units would also be involved in development of a promotion and delivery system to reach out to uses that are geographically dispersed throughout the country. (iv) Training for Capacity Buildin2: Training will facilitate the switch over of large proportion of informal enterprises using CTC in their manufacturing/production process. The target group is primarily technical institutions and distributors who can assist in dissemination of information to end-user industry. (v) Management Information System (MIS) : Development of a MIS would facilitate effective supervision and monitoring implementation of activities to be undertaken in the CTC phase out Plan. This could also be used as a tool for disbursements, performance audits of enterprises and generating progress reports and impact analysis. 33  Annexure CHECK LISTFOR VERIFICATION PROCESS 1. Process Assessment * Existing process and unit operations * Proposed process and unit operations with non-CTC substitutes 2. Baseline conditions and data analysis * Raw material requirement per ton of product. * Water requirement per ton of product. (process, steam, cooling/ others). * Waste water generation (kilolitre per ton of product) and its sources. * Waste water characteristics (concentration of pollutants before and after treatment) * Waste water treatment systems and their performance efficiency * Method for disposal! recycling of treated effluent . Emissions of air pollutants (per ton of product) and their sources. * Emission control systems and their performance efficiency * Ambient air quality in the workplace and in surrounding areas * Composition and quantity of solid wastes and method of disposal. * Quantity of hazardous wastes (as specified in the Hazardous Wastes Management and Handling Rules) from process/ effluent treatment plant and method of disposal. * Status of compliance with regulatory requirements o Water Act o Air Act o Hazardous Wastes (Management and Handling Rules) o Manufacture, Storage and Import of Hazardous Chemicals Rules o Factories Act o Ozone Depleting Substances (Regulation and Control) Rules o Annual Environmental Statements  3. Environment Management Plan for Dismantling/ Closure o Baseline environmental scenario (Water Quality, Air Quality, Soil characteristics and Noise levels) o Sequence of dismantling/closure plans o Measures for plant operation and safety requirements o Decontamination or destruction details o Storage/disposal of dismantled equipment o Treatment/disposal of unusable chemicals, if any. o Monitoring plan including community involvement. 4. Manpower Rehabilitation Plan o Payment of Provident Fund and Gratuity; o Compensation as per Supreme Court Ruling and o Other labour adjustment plan (redeployment, VRS, retraining and support for entrepreneurship) 5. Social Monitoring Plan o Constitution of monitoring mechanism o System for monitoring of environmental parameters (water, air, soil) o Public disclosure system o Social welfare measures C: DOCUiE-I Iwb923 9ULOCALS-1I Temp k.notes.datalV1652455.doc 0