India - Maharashtra Petrochemical Project

Document of The World Bank FOR OFFICIAL USE ONLY Report No. 13260 ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) JUNE 30, 1994 Operations Evaluation Department This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. CUR NCY EQUIVALENTS Currency Unit = Rupees (Rs.) Rs. 1.00 = Paise 100 US$ 1.00 = Rs. 28.01 Rs. 1,000,000 = US$35,702 (As of June 1992) LIST OF ABBREVIATIONS AND ACRONYMS BPCL Bharat Petroleum Corporation Ltd. C2/C3 Ethane/Propane EG Ethylene Glycol EL Engineers India Ltd. EO Ethylene Oxide ERR Economic Rate of Return FCC Fluidized Catalytic Cracking FRR Financial Rate of Return GOI Government of India HAZOP Hazards and Operability HDPE High Density Polyethylene IPCL Indian Petrochemicals Corporation Ltd. ICG Internal Cash Generation LDP Low Density Polyethylene LLDPE Linear Low Density Polyethylene LPG Liquified Petroleum Gas MGCC Maharashtra Gas Cracker MPCB Maharashtra Pollution Control Board OGL Open General License ONGC Oil and Natural Gas Commission OSBL Off Site Battery Limit PP Polypropylene FISCAL YEAR April 1 - March 31 FOR OFFICIAL USE ONLY THE WORLD BANK Washington, D.C. 20433 U.S.A. Office of Director-General Operations Evaluation June 30, 1994 MEMORANDUM TO THE EXECUTIVE DIRECTORS AND THE PRESIDENT SUBJECT: Environmental Impact Evaluation on India - Maharashtra Petrochemical Project(Loan 2505-IN) Attached is the Environmental Impact Evaluation on India - Maharashtra Petrochemical Project (Loan 2505-IN) prepared by the Operations Evaluation Department. This project was conceived in the early 1980s to make use of natural gas liquids for the manufacture of ethylene and propylene and their derivatives. The main objective of the project was to improve the competitiveness and productivity of India's basic petrochemical sector. The project was implemented by Indian Petrochemical Corporation Limited (IPCL) at Nagothane, located some 120 kilometers to the south of Bombay. The preparation and implementation of this project coincided with the period of heightened resettlement and environmental awareness both at the Bank and in India. On the one hand, legislation with respect to water and air pollution had been put on the books in India since 1974, culminating with the Environment (Protection) Act of 1986; and on the other, the Bank issued its first Operational Manual Statement (OMS-2.36) entitled: "Environmental Aspects of Bank Work" in May 1984, which was followed by a more elaborate and comprehensive OD 4.00 in 1989. In addition, the Bank's views about resettlement issues had been articulated in OMS-2.33 (1980) and its successor OD 4.30 (1990). As a result, the project received considerable attention regarding these issues during its preparation and appraisal. Before the commissioning of the complex, an Environmental Impact Assessment was conducted in 1988 in connection with the expansion project of the Nagothane plant. This formed the baseline data against which the corporation's environmental protection achievements were evaluated. On the whole, IPCL is a company with excellent environmental credentials and it is in compliance with all environmental rules, regulations and standards. It has been the recipient of many environmental awards and is justly proud of its impressive afforestation achievements (352 hectares of planted area in a total site area of 818 hectares - nearly a million trees). Despite the measures introduced to facilitate resettlement and interaction with the surrounding communities, the company eventually agreed to provide employment for some 600 villagers in order to ease the tension with the community. There was also an unfortunate explosion during the commissioning of the plant in 1990 which led to many fatalities. These events have made the cooperation extremely sensitive to hazard and accident prevention as well as to the need for harmonious relationship with the surrounding community. Robert Picciotto by H. Eberhard K6pp Attachment This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization.  FOR OFFICIAL USE ONLY ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) TABLE OF CONTENTS Page No. PREFACE .............................................. BASIC DATA SHEET .......................................... EVALUATION SUMMARY ................................... vii PART I: Project Background. ................................. 1 PART II: Evolution of Involuntary Resettlement and Industrial Sector Environmental Protection Policies in the Bank - Operational Manual Statements 2.33 and 2.36 . .. 2 PART III: Environmental Protection Policy in India .................... 4 Guidelines for Siting of Industry ......................... 5 PART IV: Procedure Adopted For Maharashtra Complex ................. 6 PART V: Environmental Impact Assessment for Maharashtra Gas Cracker Complex at Nagothane ....... .................................... . 7 Project Site's Natural Resources ....... ...................... . 8 Baseline Data ....... .................................. . 8 Environmental Impacts ............................... 8 Mitigation Plans ................................... 10 PART VI: Environmental Protection Achievements ..................... .11 Overall Assessment ................................. 12 Lessons Learned and Recommendations ..................... 14 This Report was prepared by Farrokh Najmabadi (Task Manager) and Abbas Gholi Bakhtiar (Consultant) who audited the project in March 1994. Eneshi Davis provided word processing assistance. This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. ANNEXES Annex 1: Letter of location approval from Department of Environment and Forest to the Department of Energy ................................ 16 Annex 2: Maharashtra Pollution Control Board ............................ 19 Annex 3: Impact of Activities on Environmental Parameters ............... ..22 Annex 4: Impact Matrix Severity Assessment ............................. 23 Annex 5: Osha Noise Exposure Limits ................................. 24 Annex 6: Ambient Air Quality ...... ............................... 25 Industrial Effluents ....................................... 25 Annex 7: Water Quality in the Amba River Estuary Measured at Station 4 ...... 26 -1- ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) PREFACE 1. This is the Environmental Impact Evaluation for a loan extended by the World Bank to India in 1985 for the construction of a petrochemical complex at Nagothane in the State of Maharashtra. The objective of the project was to improve the competitiveness and productivity of India's basic petrochemical sector. The loan for US$300 million was fully disbursed and closed in September 1991. 2. This Environmental Impact Evaluation focusses on resettlement and environmental aspects of the project, documenting the results of the mitigation plans and the overall success of the environmental program. 3. The Environmental Impact Evaluation was prepared by the Operations Evaluation Department (OED). An OED mission visited India in March 1994 and discussed the environmental impact of the project with the Government of India, the Maharashtra State Government and the Borrower. Their kind cooperation and assistance is gratefully acknowledged. 4. The draft Environmental Impact Evaluation was sent to the Borrowers for comments and those received have been reflected in the report.  - ii - ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) BASIC DATA SHEET LOAN POSITION (amounts in US$ million) As of March 31. 1994 L&n Original Disbursed Cancelled R.aid Outstanding 2505-IN 300.00 300.00 0.00 79.80 220.20 CUMULATIVE ESTIMATED AND ACTUAL DISBURSEMENTS Bank Fiscal Year ................ (Disbursements in US Dollars Million) and Semester ending Estimated Actual Actual % of Estimated 1986 December 31 - 6.3 - June 30 18.9 9.9 52 1987 December 31 32.7 20.0 61 June 30 51.6 41.3 80 1988 December 31 85.4 71.8 84 June 30 134.5 147.0 109 1989 December 31 208.4 214.1 103 June 30 253.5 242.4 96 1990 December 31 274.7 245.4 89 June 30 289.1 282.4 98 1991 December 31 300.0 288.9 96 June 30 - 293.8 98 1992 September 30 - 300.0 100 - 1ii - PRJECT TIMETABLE Item Date Planned Date Revised Date Actual Identification Sept./Oct. 1980 - Sept./Oct.1980 Appraisal Jan. /Feb. 1981 Oct./Nov.1982 Oct./Nov.1982 Post Appraisal August 1984 Board Presentation June 1981 June 1983 March 1985 Loan Signature May 1985 Loan Effectiveness August 1985 Loan Closing Sept.30, 1990 Sept.30, 1991 Sept.30. 1991 Loan Completion Sept.13, 1991 Planned dates are as in the Project Brief. Revised dates are as in the Issues Paper. Delay between identification and post appraisal was due to time taken by government for project approval and decision on ownership. Post appraisal, among other issues, reviewed technology selection. Loan amount was fully utilized with the last disbursement on September 13, 1991. PROJECT IMPLEMENTATION Project Components Mechanical Completion Commissioning SAR assessment: Process Plants October 1989 December 1989 Utilities Plant August 1989 End 1989 Actual Performance: Contract Actual Gas Cracker Feb. 1989 Oct 1989 July 1991 LDPE Dec 1988 Oct 1989 Sep 1991 PP Dec 1988 Mar 1989 April 1989 EO/EG Nov 1988 Oct 1989 Nov 1991 LLDPE/HDPE Feb 1990 Apr 1992 Being commissioned Utilities Mid 1988 Sep 1989 Dec 1989 - iv - STAFF INPUTS (in staff weeks) Fiscal Year Prearaisal Appraisal Negotiation Supervision Qth IQW 1980 .6 - - - - .6 1981 11.4 - - - 2.7 14.1 1982 .1 - - - .2 .3 1983 16.0 85.8 - - 4.3 106.1 1984 1.5 - - 4.0 5.5 1985 42.7 6.0 .8 18.5 67.9 1986 - 9.6 - 9.6 1987 - 19.0 - 19.0 1988 - 20.8 1.3 22.2 1989 - 14.6 - 14.6 1990 - 5.7 - 5.7 1991 - 9.7 - 9.7 1992 - 24.0 - 24.0 1993 - 5.4 - 5.4 Total 28.1 129.9 6.0 109.6 31.0 304.6 MISSIONS Stages in Month/ SW in Specialization Performance Project Cycle Year Persons Field represented Rating Problems Through Appraisal Preparation 9/80 2 2 Eng, FA Appraisal 10/82 4 5 Eng, Eco, FA Sector Spec. Post Appraisal 7/84 4 3 Eng, Eco. FA Updating, Technology review Supervision 1 3/86 1 1 Eng 1 2 9/87 1 3 Eng 1 3 10/88 3 2 Eng, FA 1 4 9/90 1 2 Eng 2 Explosion, LLDPE 5 5/91 3 3 Eng, Eco, FA 2 delays 6 11/91 3 2 Eng, Eco, FA 3 Project Completion 1 4/92 1 2 Eng -vi - SUPERVISION RATINGS (Form 590) Evaluation Development Legal Management Availability I&l Qvrall Obiectives Covenants Performance Funds 1985 1 1 - 1 1 1986 1 1 - 1 1 1987 2 1 - 2 1 1988 1 1 - 1 1 1989 1 1 1 1 1 1990 2 1 1 1 1 1991 2 2 1 1 2 1992 3 3 1 2 1  - vii - ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) EXECUTIVE SUMMARY Introduction 2. The project for which a loan in the amount of US$300 million was approved in March 1985, was prepared by Indian 1. With an increasing quantity of Petrochemical Corporation UPCL) and appraised gas liquids becoming available from the Bombay during a heightened resettlement and High operations, the Maharashtra Petrochemical environmental consciousness both at the Bank Project was conceived in the early 1980s to and in India. make use of these natural gas liquids for the manufacture of ethylene and propylene and their 3. The new OMS 2.33 was issued in derivatives. The main objective of the project February 1980 in order to alert Bank staff to was to improve the competitiveness and possible hardships and adverse social productivity of India's basic petrochemical consequences of involuntary resettlement that sector. This was to be achieved by constructing may be occasioned by certain types of a world scale ethylene plant using gas liquids development projects such as construction of which are the most economic feedstocks. The dams, new ports and towns, large mining project was designed to produce, as marketable operations, construction of canals, highways, products, low density polyethylene (LDPE) , electric transmission lines and the like. It linear low density polyethylene/high density required that all large construction projects, polyethylene (LLDPE/HDPE), and similar to those mentioned earlier, should be polypropylene (PP), to be sold to the examined by Bank staff at the time of conversion industry; ethylene glycol/ethylene identification and appraisal to determine whether oxide (EG/EO) which are intermediates for people must be displaced, and, if displacement synthetic fibre and detergent industries; a small is unavoidable, to reduce it to a minimum amount of acetylene black, which would be sold compatible with the purpose of the project. to the tire manufacturing as well as printing and ink industries. 4. The OMS 2.33 was superseded in June 1990 by OD 4.30 which enlarged the scope of resettlement screening by requiring that: Evolution of Involuntary Resettlement and "any operation that involves land acquisition or Industrial Sector Environmental Protection is screened as a category A or B project for Policies in the Bank - Operational Manual environmental assessment purposes should be Statements 2.33 and 2.36 reviewed for potential resettlement requirement - viii - early in the project cycle", thus making it pieces of legislations have been enacted in India: mandatory for all large industrial projects. (i) The Water (Prevention and Control of Pollution) Act of 1974; (ii) The Air 5. Although environmental issues had (Prevention and Pollution Control) Act of 1981; been receiving ample attention in the Bank and finally, (iii) The Environment (Protection) projects, the first Operational Manual Statement Act of 1986. (OMS - 2.36) entitled: "Environmental Aspects of Bank Work" was issued in May 1984. The 8. In 1981, the Indian Department of OMS articulated the reasons why attention to Environment and Forests was created in the environmental considerations was necessary and Central Government in order "to provide explicit discussed the Bank's policy and approach. recognition to the pivotal role that environment According to this OMS, the review of the conservation must play for sustainable material environmental aspects of projects, sector and development". economic work, including the adherence to Bank policy and its conformity with environmental Guidelines for Siting of Industries standards and guidelines was entrusted to the Environment, Science and Technology Unit. 9. Upon the initiative of the Indian The important step taken by the Bank was to Department of Environment, an expert team bring the treatment of environmental issues into formulated a comprehensive set of guidelines the project cycle. (which were issued in 1985) for the siting of industries including areas to be avoided, siting 6. The consideration of environmental criteria, environmental impact assessment arising issues continued to receive increasing attention out of air pollution, liquid effluents, noise as the Bank's organization evolved with the pollution, vibration and occupational safety and creation of an Environmental Department. The health. An important aspect of these new above-mentioned Statement was also superseded guidelines was the necessity of preparing an in 1989 by the issuance of a new Operational Environmental Impact Assessment (EIA) to Directive (OD) 4.00 which, once again, defined identify the potential impacts of large industrial the Bank's approach to environmental issues and projects on the environmental system. The through its Annexes, laid out the procedure to be guidelines further required that through the followed in the project cycle. In the new OD, ElAs, baseline data would be established so that Environmental Assessments (EAs) became the the environmental impact of executed projects major tool for addressing the environmental could be compared with such data. The issues of large industrial projects. Such EAs approaches adopted towards environmental were expected to identify ways of improving the screening of the projects were almost parallel projects environmentally by preventing, and simultaneous both in the Bank and the minimizing, mitigating or compensating for Government of India. adverse effects and to propose environmental management, training and monitoring plans. Procedure Adopted for Maharashtra Complex Environmental Protection Policy in India 10. In 1980, the Government of India appointed a site selection committee, including 7. Despite the evolving policy in the environmental experts, to investigate the Bank, the environmental considerations in this suitability of several sites in the vicinity of Uran project were more influenced by the gas separation plant. The recommended site was environmental protection legislation and located about 2 kilometers from the village of activities in India. Since 1974, these major Nagothane in Maharashtra State's Raigad - ix - District. The site area chosen (around 567 which deals with rural development and hectares) consisted of predominantly assistance to the resettled population. The agricultural, but very rocky, land. It was afforestation and horticultural development expected that only two villages would be directly constitutes a part of this plan. Dairy farming affected by the project and there would be need was selected as one of the activities with good for the resettlement of nearly 2150 persons. potentials for the region. Accordingly, a cattle Subsequently in 1984, the Department of development center was established in Environment issued its final approval of the site Nagothane to provide breeding services for the and stipulated a series of environmental cattle, free of cost at the farmgate. IPCL also guidelines that had to be followed by IPCL. In arranged for free vaccinations. Training practically all respects these guidelines were in programs for economic milk production were line with those of OMS 2.36 (1984) which was, organized in order to improve the skills of local at the time, applicable to this project. farmers.There is also a section in the EIA which deals with rural development and assistance Environmental Impact Study Environmental Protection Achievements 11. The application for expansion of the 13. IPCL has successfully implemented Maharashtra Complex in 1988 prompted the its resettlement and environmental protection need for a comprehensive Environmental Impact plans. It has in place air quality monitoring Assessment. The Assessment prepared by stations, situated at specific locations, that Engineers India Limited (EIL) built on the automatically measure various air quality baseline data already collected by IPCL since parameters including pollutants and transfer the 1986 and methodically addressed the various results to a central station for collation, issues as if it was dealing with the first phase of averaging, conversion and reporting. The the project (it should be noted that in 1988/89 effluent water quality is also regularly measured the first phase had not, as yet, been and analyzed in water quality reports. Such commissioned). The Assessment started by reports are submitted to the Maharashtra describing the project, the natural resources at Pollution Control Board as evidence of the site, the baseline data on the physical and compliance. The corporation periodically has to biological conditions (the ambient air quality, file an application and receive a 'consent to water quality in the Amba river and the estuary operate order'. where industrial effluents would be discharged), the resettled population, the expected 14. The above measurements are environmental impact of the plant, the mitigation supplemented by studies carried out by the plans, management and training plans and the National Oceanographic Institute at six stations monitoring procedures. The Assessment also over a distance of 30 kilometers in the Amba contained a section on risk analysis based on river estuary. The last study between October three worst case scenarios, discussing the 1990 and May 1991 indicated that the water and consequences of equipment failures on the plant, sediment quality were close to the baseline, personnel, structures and the population outside within the natural variability expected for the the plant. This Assessment, which formed a estuarine environment. Moreover, variations in part of the project preparation documents, is the phytoplankton pigments, zooplankton biomass background study against which the and microbenthic biomass compared well with corporation's environmental protection the results of the earlier studies. achievements will be evaluated. 15. IPCL has carried out a most 12. There is also a section in the EIA impressive afforestation program at Nagothane. - x - More than sixty species of fast growing and 18. IPCL is a company with excellent resistant plants have been planted. The total environmental credentials. Its health, safety and afforestated area now approached 352 hectares environmental policies are both comprehensive (94% of the available land area of 375 hectares). and demanding in that it requires that its various The average survival rate has been two thirds units comply with all environmental regulations (940 thousand trees out of 1.41 million planted) during design, construction and operation of all with a survival per hectare rate of around 2670. facilities of the corporation. IPCL has been the The program also covers demonstration fruit winner of many awards in the past, most notably orchards where mango, coconut, guava, citrus the 1989 FICCI (Federation of India Chamber of and pomegranate trees are planted. IPCL is Commerce and Industry) award in "recognition assisted in the efforts by BAIF Development of outstanding contribution to Environment Research Centre (an NGO). Preservation and Pollution Control". Recently Nagothane was awarded the third prize of the 16. With the help to BAIF, IPCL is also Maharashtra State Government's Vanashree engaged in other community development Award for its afforestation efforts. activities such as training of villagers in first aid treatment, soap and detergent powder making, 19. The plant was supposed to eventually mango graft preparation, pre-primary use the effluent water for the irrigation of its educational methods of teaching, handicraft greenbelt. This has not been totally achieved, preparation, masonry and carpentry skills, use though various species are being tested for their of plastic mulching, kitchen garden promotion, response. The plant needs to continue with such non-farm skills for the youth such as mechanical demonstration projects, not only to conserve raw and electrical repairs, water resource water, but to convince the villagers about the development, self help group formation, dairy safety of using the effluent water for agricultural cattle development through insemination (nearly purposes. In addition, the construction of a fish 2300 cases achieved), environmental awareness pond will go a long way in allaying the fears of programs, extension services and, even, sports the surrounding population about the quality of competition amongst neighbouring village the treated water from the plant. schools. This program appears to have already had some positive results in that the average 20. Notwithstandingtheriskanalysisand annual income from dairying has risen by 84% Hazop studies and other measures taken for the and 76% the resettled families are now engaged early detection of hazards, the failure of a flange in the sale of milk. in the gas cracker unit offsie battery limit (OSBL) area led to a very serious accident in 17. At Nagothane, the environmental September 1990 with many fatalities. Since the activities are supervised by Health, Safety and accident, IPCL has further reinforced its safety Environment (HSE) Department headed by a efforts and instituted many programs aimed at a Deputy General Manager reporting directly to heightened safety consciousness among the the Executive Director in charge of the whole personnel. In addition to regular monitoring, operation. On the environment and ecology inspection and safety auditing, IPCL has a side, the HSE is manned by environmental comprehensive emergency program in case of engineers and horticulturalists. The Department accidents. These efforts appear to have regularly runs training courses in variety of improved the situation: in 1993 the severity rate environmental subjects for the plant personnel at of accidents - number of days lost per million Nagothane. man hours -- has dropped to 42 from 663 in 1992. While all this indicated the efficacy of the measures taken by IPCL, it is still a matter of Overall Assessment concern that despite several requests by the - XI - Bank, the Government of India has not yet results. The corporation has a serious and submitted a copy of the report of the Mashelkar businesslike attitude to this important aspect of Committee to the Bank, though the relevant its activities and is not willing to cut corners. It authorities in the Government of India have knows that it is cheaper, in the long run, to informed the Bank that the report has not yet bring in the environmental considerations into been made public and they have yet to take a the design of potentially polluting industrial final view of the findings. activities such as petrochemical units at the very earliest state. The staff of the corporation are 21. Despite all the measures taken by the constantly reminded about their responsibilities Maharashtra State Government in terms of in this area, through publications, seminars, compensation, provision of alternate land, etc., training courses and other means. Any further and the rural development activities by IPCL elaboration on the lessons learned would be a including all the confidence building measures repetition of the subjects discussed in the Bank's and interaction with the surrounding Operational Directive 4.00 and what it communities, some two years ago, the villagers recommends. staged a three day lock-in of the plant managers and operators, demanding employment. After tense negotiations and the intervention of the Lessons Learned and Recommendations State Government, the two sides came to an agreement, whereby some 600 villagers (one 23. There is, however, an area member from each resettled family) entered the where both the Bank and the Borrower fell short plant's employment. Given their lack of skills, of applying the lessons of experience. To begin many are employed in gardening and other non- with, there was little follow up on OMS 2.33 skilled activities, while a few of the younger (Involuntary Resettlement - 1980) by the Bank elements have been trained for semi-skilled jobs. staff who appear to have been satisfied with the In a densely populated country where title to compensation scheme provided by the land (even if it is rocky and of not much use for Maharashtra Industrial Development Corporation agriculture) is very precious and the Government to the villagers whose land was taken (SAR para has historically been the largest provider of 7.04) in accordance with the provisions of the employment for people, incidents of this nature Maharashtra Resettlement of Project Displaced are not rare. While it is always difficult to Persons Act of 1976. A better familiarity with strike a reasonable balance between the the OMS 2.33 would have alerted the staff that imperative of cutting costs (especially under the resettlement of some 2150 persons required competitive and liberalized conditions) and the a plan which should, inter alia, have addressed need for harmony with the surrounding the issues of training and employment. community, the essence of a good resettlement Conversely, in a country such as India where the plan is to detect such dissatisfaction and quickly Government owns little land, but has historically devise means of diffusing the problem. In the been very active in economic development, there event, the matter was amicably resolved and is a long experience in involuntary resettlement relations have gradually improved with the which should have been tapped by the surrounding community. Borrowers. The objective of providing people displaced by a project with the means to 22. All in all, from the environmental improve, or at least restore, their former living point of view (in its wider sense encompassing standards, earning capacity, and production the resettlement results), this project has had an levels requires serious planning and follow up outstanding outcome. The mindset, the through implementation. This is not a subject commitment and the rational planning at IPCL that can be treated as an afterthought because the have all been responsible for the remarkable costs of inattention are normally high. - xii - 24. Despite the foregoing, IPCL is a dialogue so that their wishes a company that has historically been actively are understood at the earliest stage; involved in the community at Vadodara and has been responsible for many bridge-building acts (2) Attention to integrating the affected with the resettled community at Nagothane. communities in the activities of the Many of the resettled group were employed by enterprise is the surest way of the contractors during the construction period enlisting their goodwill; and the corporation has provided shelter, infrastructure and social services. The (3) Along with the environmental contribution of the corporation in terms of considerations, the human environmental protection and management was dimensions of the Bank's project documented earlier and evaluated. On the work should be internalized and whole, what has been achieved is creditable more rigorously pursued throughout because IPCL realizes that its eventual success the project cycle. If a plan is depends on harmony with the surrounding designed and agreed to, it should community. There are a few lessons that are receive full attention during worthy of reemphasis: supervision and be monitored regularly. (1) Although civil servants are generally well intentioned, they sometimes fail (4) Good practices should be to communicate with those who are disseminated throughout the Bank directly affected by their actions. and the Borrowing countries, so that For successful resettlement, the costly inattention is eliminated. affected groups must be brought into ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) I. Project Background 1. With an increasing quantity of gas liquids becoming available from the Bombay High operations, the Maharashtra Petrochemical Project was conceived in the early 1980s to make use of these natural gas liquids for the manufacture of ethylene and propylene and their derivatives. The main objective of the project was to improve the competitiveness and productivity of India's basic petrochemical sector. This was to be achieved by constructing a world scale ethylene plant using gas liquids which are the most economic feedstocks. The project was designed to produce, as marketable products, low density polyethylene (LDPE) , linear low density polyethylene/high density polyethylene (LLDPE/HDPE), and polypropylene (PP), to be sold to the conversion industry; ethylene glycol/ethylene oxide (EG/EO) which are intermediates for synthetic fibre and detergent industries; a small amount of acetylene black, which would be sold to the tire manufacturing as well as printing and ink industries. 2. The project for which a loan in the amount of US$300 million was approved in March, 1985, was prepared by Indian Petrochemical Corporation (IPCL) and appraised during a period of heightened resettlement and environmental consciousness both at the Bank and in India. As a result, the environmental issues received a fair amount of attention right from the beginning. In the section on Environmental considerations, the SAR (para. 8.06) addresses issues of air and water quality and relates the measures that would be taken by the project to mitigate air and water pollution in order to comply with the rigorous Maharashtra State standards. Of equal concern was the resettlement of nearly 300 families (from two hamlets - Velshet and Ambeghar) whose land was to be purchased by The Maharashtra Industrial Development Corporation (MIDC) for the project (initially 567 hectares - SAR para 7.04 - which was subsequently enlarged to 818 hectares). The SAR also addressed the safety consideration in the following section and stated that "assurances have been obtained that IPCL will carry out a detailed safety audit by qualified consultants prior to commissioning of the project to assess the impact of the risks of the project area, and to the surrounding community" (para. 8.09). 3. The project's environmental and resettlement design was initially more affected by the existing legislation in India than the demands of the Bank. The mission reports, up to the end of 1982, referred only to the question of site selection and the manner in which the location of the plant would be determined by a site selection committee. Subsequently and before final appraisal, the Bank received a note on environmental consideration from IPCL, particularly addressing the organizational aspects of air pollution monitoring and liquid effluent disposal. But the detailed standards that were eventually adopted were prescribed by the Maharashtra State Pollution Control Board, in pursuance of legislations enacted in 1974 and 1981 regarding water and air pollution control (these legislations will be discussed later). -2- II. Evolution of Involuntary Resettlement and Industrial Sector Environmental Protection Policies in the Bank - Operational Manual Statements 2.33 and 2.36 4. The new OMS 2.33 was issued in February 1980 in order to alert Bank Staff to possible hardships and adverse social consequences of involuntary resettlement that may be occasioned by certain types of development projects. It articulated the Bank policy with respect to projects which required involuntary resettlement and gave guidance in the preparation, negotiation and implementation of a resettlement plan. While defining the type of projects, the OMS referred to those that entailed a major change of land use such as construction of dams, construction of new ports and towns, large mining operations, protection of grazing areas, construction of canals, highways, electric transmission lines and the like. 5. Generally, the Bank required that all large construction projects such as dams, irrigation schemes and so on, should be examined by Bank staff at the time of identification and appraisal to determine whether people must be displaced, and, if displacement is unavoidable, to reduce it to a minimum compatible with the purpose of the project. It was, therefore, necessary to have a resettlement plan in which various issues would be discussed and the resettled populations' help sought in designing a series of actions for smooth resettlement of the community. As for compensation, the OMS recognized that payment of cash compensation alone may not be adequate and that other measures should be introduced in order to enable the resettled population to have income-generating assets and opportunities. It is clear from the foregoing that industrial projects (even large plants) did not completely fall within the purview of the OMS 2.33. It, nevertheless, sensitized the Bank staff to the issues of involuntary resettlement and, in the case of this project, the fate of the villagers inhabiting the hamlets of Velshet and Ambeghar. 6. The OMS 2.33 was superseded in June 1990 by OD 4.30. This document enlarged the scope of the resettlement screening by requiring that: "any operation that involves land acquisition or is screened as a category A or B project for environmental assessment purposes should be reviewed for potential resettlement requirements early in the project cycle". Through this OD the resettlement issues were enlarged and the resettlement plans were required to address matters related to environmental protection and management. Moreover, all large industrial projects that involved land acquisition, such as this Petrochemical project, needed a thorough review through the project cycle. 7. Although environmental issues had been receiving ample attention in the Bank projects, the first Operational Manual Statement (OMS 2.36) entitled: "Environmental Aspects of Bank Work" was issued in May 1984. This OMS articulated the reasons why attention to environmental considerations was necessary and classified the environmental problems in the following categories: global, regional and local. The Bank had found that projects in most economic sectors might have significant environmental implications especially in agriculture, energy, transportation industry and urban development. The Bank maintained that, in principle, prevention would be preferable and generally less costly than remedial action. The Bank's approach would, therefore, be tailored to local circumstances taking into account the vast differences among the developing countries; and the Bank would periodically publish environmental guidelines which would suggest acceptable ranges to be followed by the Bank operations, unless in borrowing countries' standards were stricter. 8. According to this OMS, the review of the environmental aspects of projects, sector and economic work, including the adherence to Bank policy and its conformity with environmental standards was entrusted to the Environment, Science and Technology Unit. This Unit was expected to provide -3- training, advice and operational assistance on environmental matters in order to enhance the environmental quality of projects. The statement also brought the treatment of environmental issues right into the project cycle by requiring that: (i) projects be reviewed by regional staff in conjunction with the Unit to identify, as early as possible, those which, if carried out, would probably have significant environmental effects; (ii) the Project Brief to outline the measures needed to avoid or mitigate serious environmental risks; (iii) during the appraisal phase, the projects staff to evaluate the future magnitude and timing of adverse effects and assess whether the preventive, mitigating or remedial measures recommended would be adequate; (iv) the loan agreements may contain covenants or other provisions concerned with the environmental aspects of the project; and (v) environmental aspects be regularly and routinely reviewed with the borrower by supervision missions. The cycle would be completed by the Operations Evaluation Department (OED) undertaking, at its discretion, reviews through its own staff or in collaboration with the Unit or by hiring suitable consultants to work with OED staff. 9. These statements were superseded in October 1989 by the issuance of Operational Directive (OD) 4.00 which, once again, defined the Bank's approach to environmental issues and, through its Annexes, laid out the procedures to be followed in the project cycle. In the new OD, environmental review remained an integral part of project identification, preparation, appraisal process and the Environmental Assessment (EA) became the major tool to be used for addressing the environmental issues. Thus, the Task Managers were directed to assign, on the basis of the nature, magnitude and sensitivity of the environmental issues, one of the four categories', to the project in the Initial Executive Project Summary (IEPS). Among the type of projects which fall under category A and for which the preparation of EAs became mandatory, large scale industries and industrial estates were included. 10. In defining the purpose and nature of EAs, the OD has the following to say: "The purpose of EA is to improve decision making and to ensure that the project options under consideration are environmentally sound and sustainable. All environmental consequences should be recognized early in the project cycle and taken into account in project selection, siting, planning, and design. EAs identify ways of improving projects environmentally, by preventing, minimizing, mitigating, or compensating for adverse impacts. These steps help avoid costly remedial measures after the fact. By calling attention to environmental issues early, EAs (a) allow project designers, implementing agencies, and borrower and Bank staff to address environmental issues in a timely and cost-effective fashion; (b) reduce the need for project conditionality because appropriate steps can be taken in advance or incorporated into project design, or alternatives to the proposed project can be considered; and (c) help avoid costs and delays in implementation due to unanticipated environmental problems. EAs also provide a formal mechanism for interagency coordination on environmental issues and for addressing the concerns of affected groups and Category A: EA is normally required as the project may have diverse and significant environmental impacts. Category B: More limited environmental analysis is appropriate, as the project may have specific environmental impacts. Category C: Environmental analysis is normally unnecessary as the project is resolving to have significant environmental impacts. Category D: Environmental projects for which separate EAs are not required, as environment is a major focus of project preparation. -4- local nongovernmental organizations (NGOs). In addition, the EA process plays an important role in building environmental management capability in the country. Like economic, financial, institutional, and engineering analyses, EA is part of project preparation and is, therefore, the borrower's responsibility. Close integration of EA with these aspects of project preparation ensures that (a) environmental considerations are given adequate weight in project selection, siting, and design decisions; and (b) EAs do not delay project processing". 11. The Operational Directive further defined the outline of a Project Specific EA Report. It suggested that the EA report should include the following items: (i) an Executive Summary; (ii) the Policy, Legal and Administrative Framework in the Borrowing country; (iii) project description especially in the geographic, ecological, social and temporal context; (iv) baseline data of physical, biological and socioeconomic conditions; (v) environmental impacts including identification and assessment of the positive or negative consequences likely to result from the implementation of the project; (vi) analysis of alternatives; (vii) mitigation plan consisting of feasible and cost effective measures that may reduce potentially significant adverse environmental impacts to acceptable levels; (viii) environmental management, training and monitoring plans. 12. The above is a shortened version of a highly elaborate and comprehensive set of directives that have gone a long way to sensitize the Bank and its staff to the environmental issues and become an integral part of project screening, all the way to implementation. The directives set out very clearly the procedure that needs to be followed in the case of large industrial projects, similar to the one that is the subject of this Environmental Impact Evaluation. Although the project was prepared in the early 1980s and, therefore, prior to the issuance of OMS 2.36, the project staff were, nevertheless, mindful of the environmental implications. But, as was pointed out earlier, the environmental considerations in this project were more influenced by the environmental protection legislations and activities in India. III. Environmental Protection Policy in India 13. India's attention to environmental issues may be traced to its constitution in which the State is directed "to protect and improve the environment and to safeguard the forests and wildlife of the country". During the last two decades, India has made considerable progress in the establishment of a policy and regulatory framework for protection of environment. The important legislations in this area are: (i) The Water (Prevention and Control of Pollution) Act of 1974; (ii) The Air (Prevention and Pollution Control) Act of 1981; and finally, (iii) The Environment (Protection) Act of 1986. 14. This attention to the protection of environment and the preservation of the quality of life has also become a part of the Indian economic development plans since the early 1970s. With each successive plan, the emphasis has become greater and more demands are now being placed for adherence to the environmental norms and guidelines in the choice of locations and operation of development projects. 15. In 1981, upon the recommendations of a Special Committee, the Department of Environment and Forests was created in the Central Government in order "to provide explicit recognition to the pivotal role that environment conservation must play for sustainable material development"'. This 2 Report of the Tiwari Committee, September 15, 1980. -5- department was intended to serve as the focal point in the administrative structure of the Central Government for planning, promotion, and coordination of environmental and forestry programs. The main activities of Department included conservation and survey of flora, faura, forests and wildlife, prevention and control of pollution, afforestation and regeneration of degraded areas and protection of environment. Guidelines for Siting of Industry 16. Already in 1980, the Industrial Policy Statement by the Government of India recognized the need for preserving the ecological balance and improving the living conditions in the urban centers of India. On the basis of this Policy Statement, indiscriminate expansion of the existing industries and the setting up of new industrial undertakings within the limits of metropolitan cities and larger town came under strict control. But the policy had not touched upon the implications of setting up an industry in ecologically sensitive areas which would have an effect on the overall development process. 17. Upon the initiative of the Department of Environment, an expert team formulated a comprehensive set of guidelines for the siting of industries including areas to be avoided, siting criteria, environmental impact assessment arising out of air pollution, liquid effluents, noise pollution, vibration and occupational safety and health. These guidelines, issued in 1985, set up a procedure for a select group of industries (metallagical, mining coal, petroleum, pulp and paper, fertilizer, cement, chemical and petrochemical, pharmaceuticals, fermentation, rubber, paints, leather and tanning, electroplating, insecticide, synthetic resins and plastics, synthetic fibre) whereby such industries would only be licensed after: (a) the State Director of Industries confirms that the site of the project had been approved from environmental point of view by the competent State Authority; (b) the entrepreneur commits both to the State and the Central Government that he will install the appropriate equipment and implement the prescribed measures for the prevention and control of pollution; and (c) the concerned State Pollution Control Board has certified that the proposal meets with the environmental requirements and that the equipment installed or proposed to be installed are adequate and appropriate to the requirement. 18. An important aspect of these new guidelines was the necessity of preparing an Environmental Impact Assessment (EIA) to identify the potential impacts of large industrial projects on the environmental system. The guidelines, therefore, recognized that not all projects required such elaborate EIAs, but that large industrial projects or industrial estates invariably needed the assessment in order to establish the baseline data and later measure the environmental impact against such data. The EIAs were also required to address other topics such as an environmental management plan, disposal of liquid effluents, air pollution, abatement, disposal of solid waste, noise and vibration, occupational safety and health, maintenance and operation of environmental control systems, housekeeping, human settlements and housing areas, transport systems, recovery and reuse of waste products, afforestation and disaster planning. 19. The latest legislation is the Environment (Protection) Act of November 1986. This act does in no way abrogate the previous legislations regarding water and air pollution (especially the parts that deal with the Central Board for the Prevention and Control of Water Pollution as specified in the 1974 Act and the State Boards for the Prevention and Control of the Water Pollution and Air Pollution as created by the 1974 and 1981 Acts), but specifies standards for emission or discharge of environmental -6- pollutions for the purpose of protecting and improving the quality of the environmente. It further delegates authority to the Central and State Boards referred to above to negotiate with industry and arrive at a time bound program for the treatment of environmental pollutants to bring them in line with national standards. It also permits the Central and State Boards to specify more stringent standards, on a case by case basis, if the conditions so warrant, provided that the reasoning is recorded in writing. The Act has many articles dealing with the procedures for sampling, submission of samples for analysis, the functions of environmental laboratories, etc. It has a section that deals exclusively with the factors that may be taken into consideration for the Central Government in prohibiting or restricting the location of industries in different areas. In its Schedules I and II, the Act prescribes emission and discharge standards for 31 industries. These standards are, in general, similar to those adopted in the Industrialized countries. IV. Procedure Adopted For Maharashtra Complex 20. In 1980, the Government of India (GOI) appointed a site selection committee, including environmental experts, to investigate the suitability of several sites in the vicinity of the Uran gas separation plant (located on the coast to the south of Bombay). Under the then applicable rules, the Nagothane site was recommended by the committee taking into account the following site selection criteria: (i) reasonable proximity to natural gas supplies and to the merchant ethylene market in Bombay; (ii) a sparsely populated area where the adverse social and environmental effects on the existing population should be minimal; (iii) consistency with the Maharashtra State Government's policy of encouraging industrial development in the most backward areas of the State; and (iv) the availability of abundant water supplies and necessary transport facilities (PR, para 48). The recommended site was located about 2 kilometers from the village of Nagothane in Maharashtra State's Raigad District. The total land area requirement was put at around 567 hectares including about 100 hectares for the township. 21. The site area chosen consisted of predominantly agricultural, but very rocky, land and was relatively sparsely populated. It was expected that only two villages would be directly affected by the project and there would be need for the resettlement of nearly 2150 persons. The major part of land was owned by villagers; a small portion was under State Government forests. The Maharashtra State Government had announced in March 1982 certain areas in and around the project site as industrial for acquisition, and proceedings were started for the purchase of the land and resettlement shortly thereafter. Despite the rocky nature of the terrain which necessitated considerable amount of excavation, earthwork and site levelling, this site was selected because it affected only a relatively small number of people. While the resettlement of the affected population was carried out in accordance with the provisions of The Maharashtra Resettlement of Project Displaced Act of 1976 (in terms of compensation and other pertinent issues) and physical possession was taken by 1985, there were other mitigating activities by IPCL which will be discussed under the Environmental Impact Assessment section below. Water and air quality standards and water discharge effluent are regulated for all industries. The effluent disposal standards are in effect for the following categories (i) standards for disposal of effluent form specific industries including the chemical industry based on Minimum National Standards (MINAS); (ii) standards for disposal of effluents for all industries depending upon the ultimate point of disposal of effluent; for example, standards are set for disposal in surface water, onto open land, public sewers, agricultural land and marine and estuary areas; (iii) standards for disposal of sewage; and (iv) standards for effluent disposal of toxic effluent under the provisions of the Environment (Protection) Act of 1986. -7- 22. Upon the acceptance of the site by the Department of Petroleum and based on the interministerial discussions, the Department of Environment gave its final approval in December 1984. But from the environmental point of view, it made a number of conditions that the petrochemical complex had to meet (Annex 1). As can be readily seen from these stipulations, the complex had to meet very general but stringent standards which were very much in line with the recommendations of the Bank's then applicable OMS 2.36 dated May 7, 1984 and its pollution control guidelines. The technical design of the project and its component plants proceeded on the basis of these guidelines. With the plant's construction approaching completion, the Maharashtra Pollution Control Board issued a letter of consent in January 1988, specifying exactly the emission, effluent and other standards with which the plant had to comply (Annex 2). 23. Subsequently, when the Indian Petrochemical Company applied to the Authorities to expand its cracking and downstream capacities in 1988, it was asked, in line with the prevailing legislations and rules, to prepare an Environmental Impact Assessment of the project. This job was entrusted to Engineers India Limited (EIL) who finished their report in 1989. By this time, the treatment of environmental issues had also taken a leap in the Bank. In addition to the issuance of Environmental Guidelines by the Environment Department in August 1988, setting out the pollution standards for 55 large industries, the procedure for environmental screening of industrial projects had become an important part of project preparation. As a result, the Environmental Impact Assessment was also required by the Bank, before the expansion project could be processed. In the event, it came as a part of the preparation work submitted by IPCL for the Second Petrochemicals Development Project (Loan 3258/3259-IN). V. Environmental Impact Assessment for Maharashtra Gas Cracker Complex at Nagothane 24. Since the Environmental Impact Assessment was undertaken and completed before the commissioning of the First phase of this complex, it provides the baseline data against which the impact of this project can be measured. As noted earlier, the legislative requirements and the operational guidelines at the inception of the First phase only called for compliance with certain standards in terms of site selection, water and air pollution. Through time, with the changes in legislation, IPCL was required to submit an EIA, explaining, in detail, all its mitigation plans including the environmental management and monitoring procedures it would adopt in order to safeguard the environment. This evaluation, therefore, takes as its point of departure the EIA, rather than the less comprehensive framework in force during the early 1980s. 25. The EIA was prepared with the intention of its eventual submission to the Maharashtra State Pollution Control Board for the issuance of the permit and as a part of the documents required at the project preparation stage. After a general description of the existing plant and the expansion project, the EIA contained the replies to an exhaustive questionnaire which the company was required to file with the State authorities. The questionnaire had several sections dealing with general information, details of the site, process details, energy requirements, details of the construction plan, meteorological data pertaining to the proposed site, water requirements, waste water details, solid waste, sewage and domestic waste, atmospheric emission, ambient air quality within 10 kilometers of the plant site, other environmental considerations such as noise and odor, pollution control measures, work environment hygiene and housekeeping, greenbelt development, environmental management and cost estimates. -8- Project Site's Natural Resources 26. Nagothane is located some 120 kilometers south of Bombay on the highway to Goa. Water resources in the Nagothane region are relatively abundant and have already been tapped for other industrial uses. The Amba river is the main source of water supply to the project. The district is relatively deforested, except for an area southwest of the plant where timber is being exploited. Wildlife is not abundant save in those areas under forest cover. Areas north of plant (downstream the Amba river) are under agricultural cultivation. Baseline Data 27. The report provided a comprehensive set of baseline data on the physical and biological conditions. The ambient air quality had been measured during a 24 months period (May 1985 to May 1987) on a continuous basis through one stationary and one mobile measurement units. This consisted of the recording of meteorological (temperature humidity, rainfall, etc,) and air pollution (suspended particles, sulfur dioxide S02 nitrogen dioxide NO2, etc) parameters at the plant site and within a radius of ten kilometers from the plant. The data were then analyzed to determine the climatic behavior, its seasonal changes and the background pollution level at the Nagothane site. 28. A similar process of data collection was undertaken for the baseline water quality at four location in the Amba river, including measurement of temperature, salinity, pH, inorganic nitrates, phosphates, ammonia, dissolved oxygen, biochemical oxygen demand (BOD), trace metals and suspended solids. In addition to hydrographic study of this river (which would supply process and township water to the complex), the biological characteristics were also determined for the estuary section where the plant effluents were expected to be discharged. Since the treated effluent is discharged through a pipeline into the estuary, the actual point of discharge was selected after a hydrographic and oceanographic study was completed in the area by the National Oceanographic Institute. As a result of the study, a point of discharge was selected that maximizes disposal into the bay waters and diminishes the likelihood of back mixing into the estuary area. 29. The report also contained a census of the affected population residing within a radius of 2 kilometers from the center of the site (13539 persons) and between 2 kilometers and 5 kilometers from the centre of the site (a further 6481 persons). Of this total, the resettlement of only 2153 persons was anticipated as the complex would only affect three villages out of a total of 24 within the five kilometers radius. A baseline survey was also conducted by Bharati Agro-Industries Foundation (BAIF) in 26 villages around Nagothane which indicated the extremely poor productivity of the land and the need for introducing appropriate agro based technology to generate employment and income in the region. A report prepared on the basis of this survey identified the need for organizing training of the village youth in both agro and non-agro based activities to enable the villages to raise their level of skills required for self employment. Environmental Impacts 30. The EIA had two large sections dealing with atmospheric emissions and liquid effluents from each single process unit as well as the offsite facilities and utilities. This was accompanied by a detailed water balance and a water budget indicating the requirements for domestic (sanitary and -9- drinking), industrial (make-up for cooling towers, water plant, hose stations, tanker washing and make-up fire water), agricultural (gardening and horticulture) and township water. The report, thus, predicted the physical, chemical and biological characteristics of the effluents to be treated before discharge into the estuary. 31. While the activities during construction were expected to have some transitory impacts on the environment, the more sustained and permanent impact was expected for the operational phase. In this respect a matrix of activities and their impact on environmental parameters was constructed in order to highlight the most deleterious activities and the pressures on resources (Annex 3). This was followed by a detailed quantification of the impact of each activity on the environmental parameters (negative impact was quantified using scores 0, 1, 2, 3, 4 and 5 in the increasing order of severity): raw water resources, ground water resources, air quality, noise and odor, water quality, land use pattern, human resettlement, Forests/National Parks/Sanctuaries, housing, infrastructure, services and environmental hazards (Annex 4). The result of this impact assessment is given in the table below: Table 1. Impact of Activities on Environmental Parameters Activity Cumulative Score Air Quality 13 Noise and Odor 9 Water Quality 8 Land Requirement 7 Infrastructure 9 Services 10 Environmental Hazard 12 32. The EIA also contained a section on risk analysis which had been carried out by an expatriate (US) engineering company. Based on three worst case scenarios, the consequences of equipment failures on the plant, personnel, structures and the population outside the plant were evaluated. The recommendations of this study were incorporated in the design of the complex. The main recommendations consisted of: (i) provision of adequate distance between process units; (ii) provision of gas detectors and low emission level alarms at strategic locations; (iii) construction of blast walls around the ethylene oxide storage vessels; (iv) provision of water curtain around the furnaces; (v) blast proofing of all process unit control rooms; (vi) use of double wall cryogenic tanks for the storage of ethylene/propylene feedstock; and (vii) fireproofing of the support structure of flare line. 33. In addition to the above, IPCL has already carried out HAZOP (Hazard and Operability) studies on all the major process units of the complex. These Hazop studies have indicated the need for minor modifications to the plant. Much of this work has been completed and others are under implementation. While the risk analysis has shown that the risk to outside population due to accidents in the complex is low and within the acceptable limits, there is need to keep the population density in the ethylene oxide/ethylene glycol, polypropylene and gas cracker process units as low as possible. - 10 - Mitigation Plans 34. The gaseous wastes from petrochemical plants are sulfur dioxide, oxides of nitrogen, particulate matter, odorous materials and lighter hydrocarbons. Since the feedstock (a mixture of ethane and propane) contains negligible sulfur, emissions of S02 in flue gas will be in traces. Process technologies and equipments were selected in a manner as to minimize fugitive emissions. Besides providing adequate stack height for the captive power plant (100 meters, beyond the inversion zone in the region) which might burn Low Sulfur Heavy Stock (LSHS) in periods of low natural gas availability, cyclones separators were used for the removal of fine powders e.g. in the polymer plants. 35. Air pollution monitoring is carried out by two fixed and one mobile analyzer stations. The two fixed stations are located in the material stores area and near the township. The mobile van is mounteO on a trolley attached to a prime mover and is fully air-conditioned with a power generator. All the instruments in all the thiree stations are provided with particulate filters. For accurate flow measurement, laser drilled critical orifices are used. A central station that continuously receives the data consists of an Enviro-logger. This device converts the data to the corresponding units, calculates periodic averages and can prepare reports in the format specified by the Maharashtra Pollution Control Board. 36. As for the effluent discharge, an attempt was made in the design of the plants to reduce leakage, minimize production of wastes, recirculate the wastes and separate the pollutants to the extent possible. Based on their treatability the separated pollutant streams were: storm water from the production units and offsite areas; process industrial effluents comprising oil contaminated streams; chemicals contaminated streams; spent caustic streams; and sanitary wastes. For the treatment of the effluents, the process waste water is pumped to an equalization tank from where the waste water goes for oil removal. The contaminated rain water also joins this flow. Thence the pretreated spent caustic waste is mixed with the oil-skimmed process and rainwater in the flash mixer. The flow then passes the clariflocculator and pH adjustment tank in which chemicals are added for chemical treatment. The precipitates formed due to chemical reaction and coagulation are allowed to settle in the clariflocculator unit where additional oil-skimming facilities are provided. After chemical treatment, the effluent is subjected to biological treatment in an Extended Aeration tank where the treated sanitary waste water is also introduced. This treated effluent is finally transferred to a clarifier unit in which sludge is allowed to settle. The clarified effluent from this clarifier is collected in the Guard Ponds where it is mixed with the waste water from cooling tower blow down. From the Guard Ponds the effluent is pumped to the estuary after once more flowing through filters to remove any traces of oil. The treated effluent can be returned to the system if its quality is not found to be suitable for disposal. 37. As for the sludge, it is accumulated from various sources in the sludge thickener unit. The sludge from the final clarifier is also taken to an Extended Aeration tank and then conveyed to the thickener unit. This thickened sludge is subsequently pumped to sludge drying beds. 38. To reduce the noise level due to compressors, pumps and other machinery, emphasis was put on good preventative maintenance and avoidance of equipment failure. Noise was contained by the proper design and engineering practices and the use of silencers, sound proof materials, sound absorbers and mufflers. The mitigation plan aimed at achieving a noise level in the plants in accordance with noise levels prescribed by Occupational Safety and Health Administration (OSHA) of the United States as given in Annex 5. 39. There is also a section in the EIA which deals with rural development and assistance to - 11 - the resettled population. The afforestation and horticultural development constitutes a part of this plan. Dairy farming was selected as one of the activities with good potentials for the region. Accordingly, a cattle development center was established in Nagothane to provide breeding services for the cattle, free of cost at the farmgate. IPCL also arranged for free vaccinations. Training programs for economic milk production were organized in order to improve the skills of local farmers. VI. Environmental Protection Achievements 40. Annex 6 shows the actual ambient air and effluent water quality as measured at the plant. It is quite clear that the plant meets the pollution standards in all respects. This compliance was recorded in the latest consent that was issued by the Maharashtra Pollution Control Board in December 1993 for the plant to continue its operation. The environmental laws of India require that IPCL periodically file for a 'consent to operate order' at which time the company has to provide the relevant Pollution Control Boards with comprehensive environmental audit statements. 41. The studies carried out by the National Oceanographic Institute at 6 stations over a distance of about 30 kilometers in the Amba river estuary were reported for a period of 8 months from October 1990 to May 1991. These studies involved detailed investigations with respect to water quality, sediment quality and biological characteristics and their tidal variability, in order to evaluate changes, if any, in the environment quality due to the release of waste water. The data was then compared with the baseline data collected before the commencement of waste water discharge. These studies indicated that the water and sediment quality were close to the baseline within the natural variability expected for the estuarine environment. Variations in phytoplankton pigments, zooplankton biomass and microbenthic biomass compared well with the results of the earlier studies. Moreover, the fish catch composition remained comparable with that of the earlier study. In effect the impact of the waste water discharge into the Amba river estuary at Kankule has been negligible (Annex 7). This study has been repeated once more in the second half of 1993 and the report will be available sometime later this year4. 42. IPCL has carried out a most impressive afforestation program at Nagothane. The objective of this program was to develop a greenbelt around the plant to act as bufferzone, scavenger of air pollution, absorbent of noise pollution, etc. By using a part of the treated effluent for irrigation, the program also aimed at reducing water pollution and generally improving the overall ecosystem. More than sixty species of fast growing and resistant plants have been planted with 29 species falling under effluent water irrigation experiment. In this experiment 73% of the saplings have responded very well (growth of 120 centimeters in one year). The total afforestated area now approached 352 hectares (94% of the available land area of 375 hectares). The average survival rate has been two thirds (940 thousand trees out of 1.41 million planted) with a survival per hectare rate of around 2670. The program also covers demonstration fruit orchards where mango, coconut, guava, citrus and pomegranate trees are planted. IPCL is assisted in these efforts by Bharati Agro Industries Foundation (BAIF) Development Research Center that has been engaged in rural development, animal production and cattle breeding, agro forestry and afforestation and other similar activities for two decades. The Scientist at the National Oceanographic Institute reported that these later investigations have not indicated any deterioration in the estuarine environment. - 12 - 43. With the help of BAIF, IPCL is also engaged in other community development activities such as training of villagers in first aid treatment, soap and detergent powder making, mango graft preparation, pre-primary educational methods of teaching, handicraft preparation, masonry and carpentry skills, use of plastic mulching, kitchen garden promotion, non-farm skills for the youth such as mechanical and electrical repairs, water resource development, self help group formation, dairy cattle development through insemination (nearly 2300 cases achieved), environmental awareness programs, extension services and, even, sports competition amongst neighbouring village schools. This program appears to have already had some positive results in that the average annual income from dairying has risen by 84% and 76% the resettled families are now engaged in the sale of milk. 44. At Nagothane, the environmental protection activities are overseen by Health, Safety and Environment (HSE) Department headed by a Deputy General Manager reporting directly to the Executive Director superintending the whole Nagothane operation. The department has a staff of more than 20 persons in four divisions: Health, Safety, Environment and Ecology and Fire. The Environment and Ecology is manned by two environmental engineers, two horticultural ists and four horticultural assistants. The department also has functional links with several other divisions which fall under a different line management, but supply the environmental data to the HSE Department. These divisions are the Effluent Treatment Plant which comes under Operations and Utilities; the Air Quality Monitoring Stations which comes under Instrumentation; and Laboratory which comes under the Quality Control. The department is also functionally linked with the Executive Director - Technical - at the corporate level. 45. The HSE Department has been running training courses for the plant personnel at Nagothane. The courses cover a wide range of subjects such as: applicable statutory rules on environment, water pollution control and management, air pollution monitoring, solid waste management, risk analysis, emergency management plans, safety, afforestation , socio-economic activities in the surrounding communities. The number of personnel attending these diverse training courses has increased from 372 in 1990 to 419, 439 and 405 in 1991, 1992 and 1993, respectively. Overall Assessment 46. IPCL is a company with excellent environmental credentials. Its health, safety and environmental policies are both comprehensive and demanding in that it requires that its various units comply with all environmental regulations during design, construction and operation of all facilities of the corporation. IPCL has been the winner of many awards in the past, most notably the 1989 FICCI (Federation of India Chamber of Commerce and Industry) award in "recognition of outstanding contribution to Environment Preservation and Pollution Control". Recently Nagothane was awarded the third prize of the Maharashtra State Government's Vanashree Award for its afforestation efforts. 47. While the disaster at Bhopal in the mid 1980s has resulted in an increased awareness of the potential adverse environment impact of the petrochemical projects, the consciousness at IPCL dates back to the early days of constructing the Vadadora complex in Gujarat which also received accolades in connection with its environmental performance'. The corporation continues to pioneer work in the 5 See the BTOR dated May 22, 1984 in which the following statement appears: "IPCL is one of the most environmentally conscious companies I have visited anywhere". The BTOR then goes on to enumerate IPCL's various programs aimed at enhancing the quality of environment. - 13 - environmental field, e.g. by the sponsorship of R & D efforts for the development of waste treatment technology for the chemical sector. To supervise the environmental performance of the various processing units, IPCL maintains a department at headquarters staffed with scientific and technical teams qualified in waste treatment and disposal, water ecology and environmental chemistry. 48. As noted earlier, the Nagothane plant is equipped with automatic and continuous air quality monitoring stations. The system is so designed as to collect data from three stations placed far apart, to analyze and collate the data and automatically transfer the results to the control room. For water quality monitoring, the laboratories operate in parallel with the water treatment plants, regularly analyzing samples from various parts of the process for chemical and biological parameters. Such data is routinely used to adjust and correct the operation treatment parameters of the treatment plants. 49. Notwithstanding the risk analysis and Hazop studies and other measures taken for the early detection of hazards, the failure of a flange in the gas cracker unit offsite battery limit (OSBL) area led to a very serious accident in September 1990 with many fatalities. Since the accident, IPCL has further reinforced its safety efforts and instituted many programs aimed at a heightened safety consciousness among the personnel. In addition to regular monitoring, inspection and safety auditing, IPCL has a comprehensive emergency program in case of accidents. These efforts appear to have improved the situation: in 1993 the severity rate of accidents -- number of days lost per million man hours -- has dropped to 42 from 663 in 1992. While all this indicated the efficacy of the measures taken by IPCL, it is still a matter of concern that despite several requests by the Bank, the Government of India has not yet submitted a copy of the report of the Mashelkar Committee to the Bank, though the relevant authorities in the Government of India have informed the Bank that the report has not yet been made public and they have yet to take a final view of the findings. 50. The experience with afforestation has been highly successful. The recent demonstration should open a new area of activity for the horticulturalists at the plant, with a possible spin off in the neighbouring villages. The plant was supposed to eventually use the effluent water for the irrigation of its greenbelt. This has not been totally achieved, though various species are being tested for their response. The plant needs to continue with such demonstration projects, not only to conserve raw water, but to convince the villagers about the safety of using the effluent water for agricultural purposes. In addition, the construction of a fish pond will go a long way in allaying the fears of the surrounding population about the quality of the treated water from the plant. 51. Despite all the measures taken by the Maharashtra State Government in terms of compensation, provision of alternate land, etc., and the rural development activities by IPCL including all the confidence building measures and interaction with the surrounding communities, some two years ago, the villagers staged a three day lock-in of the plant managers and operators, demanding employment. After tense negotiations and the intervention of the State Government, the two sides came to an agreement, whereby some 600 villagers (one member from each resettled family) entered the plant's employment. Given their lack of skills, many are employed in gardening and other non-skilled activities, while a few of the younger elements have been trained for semi-skilled jobs. In a densely populated country where title to land (even if it is rocky and of not much use for agriculture) is very precious and the Government has historically been the largest provider of employment for people, incidents of this nature are not rare. While it is always difficult to strike a reasonable balance between the imperative of cutting costs (especially under competitive and liberalized conditions) and the need for harmony with the surrounding community, the essence of a good resettlement plan is to detect such dissatisfaction and quickly devise means of diffusing the problem. In the event, the matter was amicably resolved and relations have gradually improved with the surrounding community. - 14 - 52. All in all, from the environmental point of view (in its wider sense encompassing the resettlement results), this project has had an outstanding outcome. This is due to the fact that there is an environmentally friendly management culture in IPCL. The corporation takes pride in its achievement and is mindful of the need to preserve and enhance the environment. Those that are closely involved with environmental issues are knowledgeable, conscious, dedicated and motivated. As one high official in the Ministry of Environment and Forestry put it: "no less can be expected from the public enterprises that should be at the forefront of this awareness". Though the environmental record of many Indian public enterprises does not fit this expectation, that of IPCL is a remarkable example. Given the philosophy, the policies, the effective monitoring and management, this performance is regarded as highly sustainable. Lessons Learned and Recommendations 53. The environmental achievements of IPCL constitute a good checklist of do's and don'ts. The mindset, the commitment and the rational planning have all been responsible for the remarkable results. The corporation has a serious and businesslike attitude to this important aspect of its activities and is not willing to cut corners. It knows that it is cheaper, in the long run, to bring in the environmental considerations into the design of potentially polluting industrial activities such as petrochemical units at the very earliest state. The staff of the corporation are constantly reminded about their responsibilities in this area, through publications, seminars, training courses and other means. Any further elaboration on the lessons learned would be a repetition of the subjects discussed in the Bank's Operational Directive 4.00 and what it recommends. 54. There is, however, an area where both the Bank and the Borrower fell short of applying the lessons of experience. To begin with, there was little follow up on OMS 2.33 (Involuntary Resettlement - 1980) by the Bank staff who appear to have been satisfied with the compensation scheme provided by the Maharashtra Industrial Development Corporation to the villagers whose land was taken (SAR para 7.04) in accordance with the provisions of the Maharashtra Resettlement of Project Displaced Persons Act of 1976. A better familiarity with the OMS 2.33 would have alerted the staff that the resettlement of some 2150 persons required a plan which should, inter alia, have addressed the issues of training and employmente. Conversely, in a country such as India where the Government owns little land, but has historically been very active in economic development, there is a long experience in involuntary resettlement which should have been tapped by the Borrowers. The objective of providing people displaced by a project with the means to improve, or at least restore, their former living standards, earning capacity, and production levels requires serious planning and follow up through implementation. This is not a subject that can be treated as an afterthought because the costs of inattention are normally high. 6 This was elaborated in OD 4.30 para. 18: Access to Training, Employment and Credit - Normally, general economic growth cannot be relied upon to protect the welfare of the project-affected population. Thus, alternative employment strategies are needed for nonagricultural displaced people, or where the land that can be made available is not sufficient to accommodate all the displaced farmers. The resettlement plan should, where feasible, exploit new economic activities made possible by the main investment requiring the displacement. Vocational training, employment counseling, transportation to jobs, employment in the main investment project or in resettlement activities, establishment of industries, incentives for firms to locate in the area, credit and extension for small business or reservoir aquaculture, and preference in public sector employment should all be considered where appropriate. - 15 - 55. Despite the foregoing, IPCL is a company that has historically been actively involved in the community at Vadodara and has been responsible for many bridge-building acts with the resettled community at Nagothane. Many of the resettled group were employed by the contractors during the construction period and the corporation has provided shelter, infrastructure and social services. The contribution of the corporation in terms of environmental protection and management was documented earlier and evaluated. On the whole, what has been achieved is creditable because IPCL realizes that its eventual success depends on harmony with the surrounding community. There are a few lessons that are worthy of reemphasis: (1) Although civil servants are generally well intentioned, they sometimes fail to communicate with those who are directly affected by their actions. For successful resettlement, the affected groups must be brought into a dialogue so that their wishes are understood at the earliest stage; (2) Attention to integrating the affected communities in the activities of the enterprise is the surest way of enlisting their goodwill; (3) Along with the environmental considerations, the human dimensions of the Bank's project work should be internalized and rigorously pursued throughout the project cycle. If a plan is designed and agreed to, it should receive full attention during supervision and be monitored regularly. (4) Good practices should be disseminated throughout the Bank and the Borrowing countries, so that costly inattention is eliminated. - 16 - Annex 1 ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) LETTER OF LOCATION APPROVAL FROM DEPARTMENT OF ENVIRONMENT AND FOREST TO DEPARTMENT OF ENERGY Subject: Location of Petrochemical Complex at Nagothane based on Bombay High Gas as Feed Stock Dear Sir: The proposal of locating the petrochemical complex at Nagothane, Maharashtra has been considered by the Appraisal Committee of the Department of Petroleum. Based on the opinion of the Committee and the discussion that have taken place, the site selected is acceptable to this Department. This Department has the following observations from environmental angle with regard to the proposed Petrochemical Complex: i) The proposed plant should utilise sweet natural gas only practically free from Sulphur as feed stock for petrochemicals, power generation and other utilities. ii) The project authorities should establish and maintain the air and water pollution control facilities at the highest efficiency at all times. Records of performance should be periodically and regularly supplied to the department of environment and the concerned state authorities. Before final disposal, effluents should conform to the limits prescribed by State/Central Board Prevention and Control for different parameters. iii) All possible efforts should be made to use the treated effluent for agriculture and afforestation purposes. They should maximise the recycling/use the treated effluent within the plant. The discharge to the Amba River should be in such a manner that it should not upset the conditions normally existing in the river in an adverse manner. iv) The detailed plan for the disposal of solid wastes and waste materials of toxic nature should be drawn out in detail and furnished to this department and other regulatory agencies of State/Centre. v) The spent catalysts disposal should be carefully regulated and they should not be mixed with other solid wastes for disposals in low lying area. They may be sent back to the manufacturer for recycling and records maintained for this purpose. vi) The proposed flare system design should be smokeless at all times even during shut down and start up operations and should be maintained luminous at all times. - 17 - vii) The height of the stack should be a minimum of 100 metres, to achieve the proper dispersion of emissions. A gaseous dispersion model is advocated. The levels of SO2 NO. and SPM should be within the MINAS standards stipulated for such plants by Central Board of the Standards prescribed by State Board till such time. viii) Micrometereological observations of the proposed site should be made from the pre- construction stage and should be continued. ix) The air and water quantity (including ground water) in this region should be monitored at regular intervals from the pre-construction stage and continued thereon. For this purpose, the number of monitoring stations for air and water quality monitoring stations should be decided in consultation with State and Central Water Pollution Control Boards based on the metereological considerations and the water regime and tidal conditions. x) Noise and Vibrations within the plant environment require attention and they should be brought down to safe levels to avoid occupational hazard to the individuals working within the plant. xi) Out of the total area required, part of it comes under the reserved forest category. The plant authorities should develop/undertake compensatory afforestation of an equivalent area in the nearby lands. The development and maintenance of these will be the responsibility of the plant authorities. xii) The development of a green belt and in township areas around the plant site between the plant should be the responsibility of the plant authorities. While taking the land use plan of the area for the plant as well as the township, amenities and social facilities care should be taken at the planning stage itself to avoid cutting down of the existing old trees within the area to the maximum possible extent. The trees chosen for development of green belt and afforestation should be such that they will be able to offer maximum green cover (canopy). xiii) During the construction phase, large amount of labour force is going to be deployed at the site. Their fuel requirements places a great demand and destruction of the nearby trees. The fuel supply or requirements of the labour should be arranged by the proponent/contractor. This should be suitably built into the Contractual obligations. xiv) Details of pollution control devices and methodologies of treatment should be provided to department when finalised. xv) The standards laid down by occupation health of the workers should be adopted and followed. If Indian standards in this regard are not available the relevant standards of OSHA/ILO/WHO should be followed. xvi) Proper safety precautions, fire hazard precautions should be planned and implemented. Various precautions to prevent accidents should be provided with alternate arrangements and they should be constantly reviewed and updated. xvii) The project proponents should prepare an environmental management plan for the proposed activities and their long term plans envisaged in this regard, incorporating the various suggestions made to minimise the impact of pollutants (due to setting of this - 18 - industry) in the region. The environmental management plan shall clearly indicate the budgetary provisions to implement the various stipulations made above and sent to this Department and regulatory authorities. These provisions shall also include the requirement in respect of families displaced from the site or due to the location of the unit. The measures taken in this regard and benefits provided to such displaced families by the project authorities should be communicated to this Department. Report on the implementation of various suggestions and the data gathered as above should be submitted to the Department at regular intervals. - 19 - Annex 2 ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) MAHARASHTRA POLLUTION CONTROL BOARD Consent to: IPCL - Maharashtra Gas Cracker Complex at Nagothane, Raigad District Consent is hereby granted under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 (hereinafter referred to as "the Act") to M/s. Indian Petrochemicals Corporation Ltd. (Maharashtra Gas Cracker Complex Division), Nagothane, Distt. Raigad (hereinafter referred to as "the applicant") to discharge the effluent from their proposed factory in the water pollution prevention area of the Konkan Coastal Area Basin subject to the provisions of the Act and the Rules and Orders that may be made thereunder and further subject to the following terms and conditions: 1. The Consent is granted for a period up to 31-8-1990. 2. The Consent is valid for the manufacture of 1) Ethylene - 300,000 MT, 2) Propylene - 90,000 MT, 3) Ethylene Glycol - 50,000 MT, 4) Ethylene Oxide - 5,000 MT, 5) LDPE - 80,000 MT, 6) LLDPE - 135,000 MT, 7) Polypropylene - 60,000 MT, 8) Butene-I - 15,000 MT, 9) Acetylene - 3,000 MT, 10) Wire & Cable Compound - 25,000 MT, 11) Acetylene Black - 2,400 MT, 12) Pyrolysis gasolene - 17,000 MT, 13) C, Cut-- 18,000 MT, 14) Di-ethylene glycol - 4,245 MT - all in MT/annum. 3. The daily quantity of industrial effluent from the factory shall not exceed 14,400 in'. 4. The daily quantity of domestic effluent from the factory shall not exceed 2,640 m, that from the township being 5,000 in'. 5. Treatment, disposal and implementation period i) Domestic effluent: a) Treatment: It shall be treated in properly designed and well maintained septic tank followed by filters, so as to bring the quality of treated effluent as: 1. Total Suspended Solids Not to exceed 100mg/liter. 2. B.O.D. 5 days 200C Not to exceed 100mg/liter. b) Disposal: The treated effluent shall be used for gardening on the green belt as much as possible, remaining should be disposed in the saline zone of Amba River at the specified point. - 20 - c) Implementation Period: The arrangement for treatment and disposal shall be completed before commissioning of the plant. ii) Industrial effluent a) Treatment: The applicant shall provide the required treatment to bring the final effluent to the following standards: 1. pH Between 5.5 & 9.0 2. Suspended Solids Not to exceed 100mg/liter 3. B.O.D. 5 days 20*C Not to exceed 100mg/liter 4. C.O.D. Not to exceed 250mg/liter 5. Dissolved oxygen Not less than 5mg/liter 6. Oil & Grease Not to exceed 10mg/liter 7. Phenolic compounds Not to exceed 1mg/liter 8. Carbon Chloroform extract Not to exceed 0.05mg/liter 9 Sulphides Not to exceed 2.0mg/liter 10. The Bio-assay test on fish shall show 90% survival in 96 hrs. b) Disposal: The treated effluent shall be used on green belt as much as possible. Remaining should be disposed in saline water zone of Amba River at the specified point. c) Implementation period: The arrangement for treatment and disposal shall be completed before commissioning of the plant. 6. The factory authorities shall comply with the provisions of the Water (Prevention & Control of Pollution) Cess Act, 1977. They shall regularly submit to the Board the returns in the prescribed form and pay the cess as specified under Section 3 of the said Act. 7. The factory authorities shall comply with the conditions for air pollution control as below: i)a) The applicant shall establish at least one year before commissioning of the manufacturing plants a minimum of 3 ambient air quality and micrometeorological monitoring stations to monitor Sulphur Dioxide, Nitrogen Oxides, Suspended Particulate matter and Hydrocarbons just outside the factory premises in three directions and submit the report thereof to the Board every month. b) The temperature inversion studies shall be carried out regularly for one year and intermittently for next 2 years and data submitted to the Board. ii) The Acetylene Black plant shall be provided with dust collector of sufficient capacity to limit the emissions of particulate matter to 150 mg/Nm. iii) All the outlets of waste gases from the process shall be connected to the flare stack. The flame stack height shall not be less than 100 metres. - 21 - iv) The flare provided shall ensure complete combustion of the Hydrocarbon/Carbon Monoxide and other combustible matter. v) In case of episodal pollution the process plants shall be shut down and control measures taken immediately. The occurrence of such episodal emissions shall be reported to this Board within 24 hours. vi) A continuous monitoring system shall be provided for Oxygen and Carbon Dioxide from the flare stack and report submitted to Board every month. vii) The captive power plant shall be operated on lean gas or LSHS (not exceeding 10% of time). viii) The applicant shall maintain green belt round the factory having minimum width of 100 metres. ix) The applicant shall install the alternate electric power source sufficient to operate all facilities installed by the applicant to maintain compliance of consent conditions. x) Clearance of M.P.C. Board shall be obtained at every stage i.e. Design specifications, Installations and performance test of the air and water pollution control equipments etc. 8. The factory authorities shall install a separate meter showing the consumption of energy for operation of domestic and industrial effluent treatment plants. The quarterly returns of this energy consumption shall be submitted to Board under intimation to respective Regional and Sub Regional Officer on 10th of January, April, July & October. - 22 - Annex 3 0 ~ 0 Plant Commissioning Water Requirements Effluent Discharge Gascous Emissions 0> Fugitive Emissions Raw Material Storage Raw Material Handling z Product Storage Product Handling Spills and Leaks Shutdown/Start-up Equipment Failures Plant Operations Solid Waste Disposal Transport of Workers Movement of Vehicles Housing of Workers Medical & Other Needs L - - 23 - Annex 4 00 Movement of Vehicles Housing Needs Water Requirement Effluent Discharge Gaseous Emmissions Fugitive Emmissions - 0 0 0 0 - Raw Material Storage Raw Material Handling Product Storage Product Handling Spills and Leaks Shut down/Start-up Equipment Failure Plant Operations Cumulative Score - 24 - Annex 5 ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) Osha Noise Exposure Limits DURATION SOUND LEVEL HOURS PER DAY (dBA 8 90 6 92 4 95 3 97 2 100 1 105 0.5 110 Less Than 0.5 115 - 25 - Annex 6 ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) Ambient Air Quality Parameter Permissible limit At Nagothane Plant milligram/cubic meter milligram/cubic meter Sulfur dioxide (SO2) 120 10-20 Nitrogen Oxide (NOJ 120 15-25 Suspended Particulate Matter (SPM) 500 70 - 100 Total Hydrocarbons 160 Industrial Effluents Parameter Permissible limit Treated Effluent Quality at milligram/liter Nagothane Plant Suspended solid 100 (max) 2-90 BOD 50 (max) 2-30 COD 250 (max) 4 - 50 Phenolic compounds 1 (max) nil Sulfides 2 (max) 0-1 Oil and grease 10 (max) 0-4 Dissolved oxigen 5 (min) 5-7 Total Disolved Solids 1500 (max) 500 Hexavant chromium 0.1 (max) nil pH 6.5 -8.5 7-8.5 Bioassay test of fish 90% survival 100% min. (96 hours) - 26 - Annex 7 ENVIRONMENTAL IMPACT EVALUATION INDIA MAHARASHTRA PETROCHEMICAL PROJECT (LOAN 2505-IN) Water Quality in the Amba River Estuary Measured at Station 4 (milligram/liter except pH) Parameters Before Discharge of After Discharge of Nagothane Wastewater* Nagothane Wastewater Nov-Jan 1986/87 Jan-May 1990 Mean Mean Suspended solids 110 194 Salinity 35.4 35.7 Dissolved oxygen 6.6 6.0 BOD 1.3 (max) 1.9 NO3 338 409 NO2 20 31 NH4 36 10 pH 8.0 8.0 * This estuary was under the influence of pollutants from other industries in the Bombay area.