Annual Environment & Social Monitoring Report (April 2009 to March 2010)

Environment & Social Performance Report July 2010

IND: Mundra Ultra Mega Power Project

Prepared by SENES Consultants India Pvt Ltd.

The Environment and Social Performance Report is a document of the borrower. The views expressed herein do not necessarily represent those of ADBs Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the Terms of Use section of this website.

Annual Environment & Social Performance Report Tata Ultra Mega Coal Fired Power Plant, Mundra
Period: April 2009 to March 2010
Submitted to: Coastal Gujarat Power Ltd (CGPL) Prepared by: SENES Consultants India Pvt Ltd.

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Table of Contents
1 Introduction ........................................................................................................................ 1
1.1 1.2 Background ............................................................................................................................. 1 Objective ................................................................................................................................. 1

Environmental & Social Management ............................................................................... 2

2.1 2.2 ESPR Preparer ........................................................................................................................ 2 Environmental & Social Responsibility .................................................................................. 2

2.3 Environmental Management Plan (EMP) & Social Management Plan (SMP) Implementation ................................................................................................................................... 3

Compliance by CGPL with the Environmental & Social Requirements............................ 3

3.1 Compliance with Country Requirements ................................................................................ 3

3.2 Compliance with Safeguard Requirements including the Environmental Management Plan and the Social Management Plan ........................................................................................................ 6

4 5

Environmental and Social Progress of Project Underway................................................ 14 Summary of Safety Performance and any Corrective Action .......................................... 16

List of Annexure

Annexure 1: EHSS Compliance Details ............................................................................................... 19

Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

QUARTERLY ENVIRONMENTAL AND SOCIAL PERFORMANCE REPORT (ESPR)

Reporting Period: April 2009 to March 2010 EPSR Completion Date: Aug 2010

1
1.1

Introduction
Background

Coastal Gujarat Power Limited (CGPL), a wholly owned subsidiary of the Tata Power Company Limited will build, own and operate an ultra mega power plant at Mundra in Gujarat. The project includes five supercritical units of 800 MW each, with total capacity of 4000 MW. The plant will use 12 Million Metric Ton Per Annum (MMTPA) of imported coal as fuel, and sea water for once through cooling of condensers. Power will be evacuated through six 400 KV power lines to benefits the states of Gujarat, Maharashtra, Punjab, Haryana and Rajasthan. The project has started in September, 2007 with the targeted commercial operation of the first unit is February, 2011 and that of the fifth unit in June, 2012. CGPL has sought financial loans from several international banks including the International Finance Corporation (IFC) and Asian Development Bank (ADB). As per the common term schedule to loan agreement between CGPL and the Lenders; Tata Power has entrusted SENES Consultants to carry out Environment Health Safety and Social (EHSS) compliance audits on a quarterly and annual basis during the construction period. 1.2 Objective

The purpose of this Annual Environmental & Social Performance Report (ESPR) is to report on CGPLs compliance with the Environmental and Social Performance Requirements of IFC/ADB (including implementation of the Environmental Management Plan and the Social Management Plan) and to asses any corrective actions implemented/proposed. The ESPR encompasses implementation by CGPL of all phases of the Project. It includes:
Contact information for responsible individuals Compliance by CGPL with environmental and social requirements for the Project Environmental and social aspects of the Project under implementation Occupational health and safety performance and significant incidents Sustainable development initiatives and community relations

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2
2.1

Environmental & Social Management

ESPR Preparer

Report prepared by: SENES Consultants India Pvt. Ltd. Telephone: 022-27576298 / 32986995 E-mail: mdakhore@senesindia.com / hkolatkar@senesindia.com / spramanik@senesindia.com Signature: Report Date: July 2010

2.2

Environmental & Social Responsibility

The chart below indicates the current Social, Environmental, Occupational Health & Safety organization in CGPL.

Currently, the on-site teams dedicated for Health & Safety, CSR & CDP activities, EMP implementation, HR & Labour Aspects in CGPL are marked in the organizational chart above. As recommended in the ESPR of 2008-09 CGPL has augmented it HSE staff strength through deployment of an Associate Group Head Safety and Safety Stewards which has led to the effective implementation of specific safety plans and procedures including close communication with the contractors in addressing project HSE risks. Periodic visits are also being made by a female doctor at the CGPL medical centre for health surveillance of the female workers. Additional staff is also recruited by the CSR department and the same is reflected in the documentation and implementation of CSR activities thereby demonstrating compliance to ESMP commitments.

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

2.3

Environmental Management Plan (EMP) & Social Management Plan (SMP) Implementation

The following groups of the Tata Power Corporate Office and CGPLs on-site team are responsible for EMP and SMP implementation: Tata Power Corporate Office : Sustainability & SHE Group; HR - Land Acquisition, R&R, CSR On-site team at Mundra: Safety & Environment; HR Labour & Health; CSR

As compared to the earlier annual audit report, CGPL has demonstrated considerable improvement in health and safety management system through development of well defined performance standards (with guidance from Dupont), specific procedures and guidelines (HIRA, SCAR etc), key performance indicators (LTIs, Near Misses, Fatalities etc), recruitment of additional staff etc to monitor HSE compliance and take necessary corrective actions. Additional thrust has been provided by CGPL in formulating specific HSE plans and Emergency Response Plan and communicating the same to the project contractors for necessary implementation. Safety training and emergency drills are also being periodically undertaken by CGPL and project contractors to enhance safety related awareness onsite. Adequate measures have also been taken to monitor worker health including female workers through health surveillance programs. The incident reporting and contractor vigilance initiatives of CGPL have been further strengthened in response to the fatalities and LTIs that have been recorded for this fiscal year. However CGPL as a preventive action could explore enhancing the engagement of contractors (particularly DOOSAN subcontractors) and depute personnel with functional experience in mechanical erection and are well aware of the risks related to the project activities that are under progress.

Implementation of the selected Environmental Performance Indicators is recommended to be undertaken on a fast track basis.

3
3.1

Compliance by CGPL with the Environmental & Social Requirements

Compliance with Country Requirements

This section intends to describe the compliance of project operations with applicable national and local environmental, social, labor, occupational health and safety laws and regulations including the conditions included in the relevant permit / clearance documents issued by Ministry of Environment and Forests, Gujarat Pollution Control Board, and any other Authority dealing with Environmental and Social Matters. The project has received Environmental Clearance from MoEF, Forest and Coastal Regulation Zone Clearances from the Gujarat Department of Forests & Environment and Consent to Establish from the Gujarat Pollution Control Board.

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

Sl. Regulatory Approval Conditions No Applicable EC conditions

1 2 Preparation of Comprehensive EIA based on full Done one year data and submission to MoEF

Compliance Status

Installation of FGD (Flue Gas Desulphurization) Space allocation of FGD and technical unit, in case the Sulphur content in coal is to ever specification is found to be in line with the exceed 1% or the CEIA based air quality modeling project requirement and plans indicates a GLC exceeding 80 g/m3 of SO2 at any location in the impact zone CGPL has undertaken an assessment of its projects impacts on coastal & marine environment, to represent the changes in intake & outfall locations and also the Finalize mode (open/closed channel) of water external coal handling & conveyance systems. CRZ clearance obtained and its withdrawal, intake & outfall locations modification is in progress. Protect sensitive coastal & marine environment Dredging has been primarily assessed to be Ensure that the project activity does not affect beyond CGPLs scope and a minor part of the flow, hydraulic and thermal regimes large-scale dredging A plan determining the generation and disposal of For project activities in coastal and marine environment obtain CRZ clearance prior to start of work and carry out physical modeling through an expert organization / institution, to be able to: capital & maintenance dredging shall be submitted to MoEF and abide by directions given on dredging aspects of the operations

Reconciliation of land requirement for the project Reconciliation done and the project has as part of land acquisition procedure and no been preliminarily assessed not to have landfilling of the site to be carried out included any landfilling from external sourcing. The following equipment / measures control to be Provision of these measures has been planned and progress documented in the provided as part of the project: quarterly audit reports of the project. The Flue stacks of 275m height same will continue to be assessed in the High efficiency (>99.9%) ESP to ensure future audits. PM<100mg/Nm3 Low NOx burners First aid provision at the medical centre and Dust extraction & suppression systems (such as sanitation arrangement at the labor camp bag filters, water spray systems) in dusty areas was found to be adequate. (such as coal & ash handling, transfer areas) Ash pond with impervious lining, for disposal of unutilized fly ash in the form of HCS First-aid & sanitation arrangement for drivers and other contract workers, during construction phase

The following conservation measures to be Green belt development for the project has provided: been initiated through INTACH and

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

Sl. No

Regulatory Approval Conditions

Compliance Status
has been rainwater mangrove stage and

Rain water harvesting (scheme to be prepared & considerable visible progress documented in this regard. submitted) Green-belt around plant, ash pond and township Efforts towards implementing harvesting schemes and site covering 1/3rd of total project area development are at an initial Mangrove development expected to progress 7 Monitoring of ambient air environment

Taking into account the inconsistency in the air quality monitoring results the need for continuous monitoring was expressed. A continuous ambient air quality monitoring station has been commissioned by CGPL at the site office and was reported to be in operation from April10 onwards.

Forest Clearance
7 Overall status In-principle clearance obtained from MoEF, for diversion of 130 ha of forest land. Nonforest land for CA has been identified, fenced. Fuelwood supply at the labor camp is presently being met through local xerophytic shrubs and undergrowths

CRZ Clearance
8 Prepare & implement a DMP to meet with any The Emergency & Disaster Management eventualities that may arise during construction Plan (EDMP) prepared by CGPL have been reviewed and found to be adequate with the project needs. To meet the water requirements during Narmada water being available from construction, groundwater shall not be tapped in government is being utilized to meet the any case projects water requirements during construction phase. No groundwater sourcing practiced within the site, although intermittent usage of ground water sourcing from local community areas is still being practiced. CGPL to ensure minimal sourcing of water from local community areas. Provisions for protection of coastal environment Usage of CRZ areas has been assessed to be beyond CGPLs scope and a minor part of from: large-scale CRZ use by a different Construction labour by locating construction developer (Adani). camps outside CRZ area, and providing sanitation, water supply & fuel amenities Disposal of debris, sewage generated during construction removed and disposed as per

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Sl. No

Regulatory Approval Conditions

GPCB guidance

Compliance Status

Consent to Establish
12 None of the conditions seem to be specifically applicable for the construction phase of the project, except for those relating management of wastes generated during construction phase which has been assessed to require a significant change in the way it has to be tracked.

No such instances of inspection or review of CGPLs environmental and safety compliance provisions for the project have been reported to be non-compliant in which significant fines have been imposed, operations closed down, or other actions related to Project performance have been taken. Preliminary assessment does not indicate any new or emerging environmental issues, such as pending regulations that could affect significantly the environmental, social or safety performance of Project operations. Preliminary assessment does not indicate any significant deviations / non-compliance with respect to national laws on social issues. No other regulatory compliances have been assessed to be required for implementing EMP. 3.2 Compliance with Safeguard Requirements including Management Plan and the Social Management Plan the Environmental

This section intends to describe current compliance of the project with IFC/ADBs environmental & social policies and guidelines, Environmental & Social Management Plans and present the key environmental & social performance indicators. The current project activities for the period (April 2009 to March 2010) have been assessed with respect to IFC/ADBs environmental & social policies, guidelines and standards and EHSS compliance to the same has been provided in Annexure 1. An earlier assessment of compliance of the project activities with the Environment Management Plans reveals that most of the provisions of the EMP are too generic to be actually implemented and tracked. Necessary efforts have been made by CGPL to define the EPIs relevant to this project however implementation of the same is yet to be initiated. Although primary monitoring of environmental components is being implemented by CGPL from December 2007 onwards however taking into account the inconsistency of the air quality results necessary recommendation have been made for undertaking continuous monitoring of ambient air quality. In line with the recommendation CGPL has installed and presently operating an automated continuous air quality monitoring system onsite. Review of primary air quality monitoring data indicated high SPM and RPM levels at the monitoring locations thereby exceeding the National Ambient Air Quality Standards. Day time and night time noise levels were recorded above 56 dBA and 46 dBA respectively and complied with the day (75dBA) and night (70dBA) time noise standards specified for

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

industrial area. Flouride in drinking water samples was found to marginally exceed the IS: 10500 permissible limits for potable water. Total coliform count >10MPN /100ml was recorded in the potable water samples analyzed. Social Management Plan Implementation The Performance Standards applicable to implementation stage of social aspects are PS 1 Social and Environmental Assessment and Management Systems, PS 2 Labor and working conditions, PS 4 - Community Health, Safety and Security. PS 7 Indigenous People will not be applicable as the local community does not fall in to the definition given in PS 7 1. PS 8 Cultural Heritage is also not applicable as the land acquired was barren or agricultural land without any culturally important site or monument. Compliance to the PS applicable is insured by various departments in CGPL. Compliance to PS 1 i.e. management program; organizational capacity; training; community engagement; monitoring; and reporting are carried out by Corporate Social Responsibility (CSR) department of CGPL. Compliance with PS 2 is insured by Human Resource department. Compliance to PS 4 aspects like
Travel Safety Plan to reduce community exposure to construction induced traffic accidents is taken care by Safety Department, Natural Resource Management which in this case is ground water in surrounding areas is managed by Environmental Department and Community exposure to diseases is managed by HR department through labor health checkups.

Apart from the PS 1 to PS 8, the implementation of Social Management Plan was divided in to development and implementation of the following plans, besides a few generic measures:
Labor Influx Management Plan Local Hiring and Purchasing Plan Community need assessment Livelihood opportunities and market linkages Community Development Program (being formulated) Stakeholder Engagement Framework Grievance Redress Procedure

Performance Standard 7 recognizes that Indigenous Peoples, as social groups with identities that are distinct from dominant groups in national societies, are often among the most marginalized and vulnerable segments of the population.

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

Labor Influx Management Plan The projects worker population varied from 4000 to 10000 in the last year. CGPL had labor camp for 4000 nos. of migrant labors at the start of last year, which was upgraded to accommodate around 8000 workers. Some of the workers are locals from nearby areas. The rest of them, mostly supervisor or above grade workers, have found accommodation in the nearby villages. Disease exposure, natural resource depletion and increase of supporting economic activities are the primary anticipated impacts due to labor influx.
Disease Exposure

The information received by SENES did not highlight any efforts from the CGPL or contractors side to perform preliminary health check up of the workers for transferable diseases. The CSR has carried out one health camp on reproductive health for the affected villages and some health awareness camps inside the labor colony, which did not produced any significant information on transferable diseases. After SENES comments in the first visit, CGPL has started preliminary check up i.e. physical inspection and checking blood pressure (as mentioned by Dr. N.A Jha). The discussion reveled that more than 100 workers were sent back due to medically unfit conditions. The medical records and the discussion with medical staff do not reveal presence or treatment of any worker for transferable disease till date. Most of the workers stay in the labor camps and as very few workers are detected with transferable diseases. Thus labor camp and labor check up has brought down the risk associated with the diseases exposure of the local population. Absence of any lady doctor, though around 30 - 40 ladies were present in the labor camp was pointed out as lacuna in the first and second audit report. The record keeping of the clinic in the labor camp also was commented upon for being inadequate. In the last quarterly audit the health facility and record keeping were found to be in satisfactory condition. CGPL has made arrangement for a lady doctor to visit the labor camp every Friday, which sound adequate in the present condition.
Depletion of natural resource water

Water is most important and scarce resource in Kutchchh, especially fringe area i.e. near sea shore areas, where the project is located. At the time of first audit, water (for drinking and construction) was being sourced from private contractors, who in turn were sourcing it from near by borewells (some time from the PAPs farms also). At the peak of its construction activity the project was consuming more than 2000 KLD water, which was mostly coming from ground water. This was violation of the conditions of Environmental Clearance provided by the MoEF. Though there is no quantitative study to confirm this, it was felt that the near potable water available in the area is being consumed at much faster rate than the native community would have. At the time of first audit CGPL was working on a pipe line water connection from Gujarat Infrastructure Limited, which is taking water from Sardar Sarovar Nigam Limited (Narmada

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water). At present the pipe line is complete and the RO plants established to purify the water are running. The peak of civil construction activity is also over reducing the construction water demand. CGPL has a permission of drawing 2000 KLD from the pipe line, of which they claim to be using only 1000KLD at present. Thus the depletion of natural resource in the surrounding area is not a major risk to the project now. In the first and second audit CGPLs efforts to establish another water source through Dew Harvesting project were highlighted. It appears the project has met with limited success and would not be viable as dependable standby option. The workers living inside the camp have less contact with near by villagers. The camps are isolated and are considerably away from the existing settlements. The camps do not have any centralized kitchen, markets and entertainment facilities. Thus an informal market has come up near the western boundary of the project. The informal market contains several vegetable, grocery, meat and fish shops. It also contains three theaters and one clinic. This market provides the local villagers employment and business opportunity which was not planned by CGPL.
Economic Development

The outside workers who are residing in nearby villages are contributing to the local economy. Though the villagers have opposed the idea of providing housing to outside workers earlier, later they have started providing them the required housing, which in turn provides them with earning source. Local Hiring and Purchase Plan The local hiring & purchase plan primarily requires developing procedures & practices to maximize opportunities for hiring local workers, allowing access to jobs for the local population in an organized & fair manner as well as respecting local cultural & social norms. A local hiring procedure has been found to be established accordingly and the practice has lead to hiring of locals from affected villages and non-affected villages. CGPL maintained a procedural co-ordination with the local village committees and the project contractors, to support local hiring and employment in three different areas. Recently, as mentioned in the first quarter report of 2010, villagers became aware of the short life of construction related activity. In a meeting held on 17th April 2010 with CGPL, the villagers expressed their willingness to be employed in operation stage of the project activity through, employment and vehicle contracts.
Employing locals in construction activity

The village committee or Surpanch is asked to provide a list of people who would like to get employed with the construction activity. In monthly meeting with Human Resource department the CSR department identifies list of jobs available with all the contractors who

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

are working for CGPL. The list is matched with the list provided by Surpanch according the skill requirement and the particular persons are contacted for the jobs.
Shops on site

The site houses more than 4000 workers. There is a requirement for Tea shops in the construction area and labor colony. These shops are allocated to locals from affected villages. During all the site visits the shops were assessed to be a good source of income for the local population.
Small Contracts

Small contracts viz. repairing roof of school, building toilets, maintenance of labor camp are offered to locals. These contracts were observed to be useful in building the base of entrepreneurship in locals.
PAP in local hiring and purchase plan

The CSR activity though proactively is targeting many areas, lack clarity about working with Project Affected People. All of the documents including SIA clearly mention the income restoration of PAP as priority; CGPL does not identify them separately for any of its activity. List of PAP separately which they would refer the kind of help they have received was not available with CSR till end of the third quarter audit in 2009. At present, list of possible candidates for all the opportunities of income generation is generated by the Panchayat and handed over to CSR. If the Panchayat does not give priority to PAPs, they do not appear on the CGPLs list of beneficiaries. As per the list provided by CSR department in the last audit, 7 % of PAPs have received contracts of supplies, 1% has received contracts and 22% have received tea or provision shops making the total percentage of benefited PAPs 30%. Earlier audits had identified the lack of data base on PAP with CSR. In order to improve the basis and to track the effectiveness of the CSR activity, auditors have suggested CSR to carry out in depth census survey of the PAPs to track changes in their socio economic condition. CSR has taken the initiative and carried out survey of all the PAPs. The questionnaire, and hence the survey also, concentrated more on education and training levels of the PAPs. The result of the survey provides elaborate information on education level and technical skill set available with the PAP community but fails to capture the present income level of the PAPs which was one of the fundamental requirements of this census survey. A more targeted questionnaire needs to be designed to track the socio-economic changes in the life of PAPs. Efforts should be made to retrieve the original census survey data from ILFS which will help CSR department to compare changes in socio-economic status of PAPs. Further CGPL CSR department also need to deploy a skilled agency capable of generating the income related data of the PAPs through required modification of the questionnaire and subsequent surveys.

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Community Need Assessment The Community Need Assessment study identified following components to be addressed.
Water supply Consultations with the nearby communities by CGPL, did not bring forth water supply as a prioritized need. However, one such need in the form of RO plant for school is budgeted for the upcoming financial year. Sanitation While interacting with women self help group the need for sanitation facility was felt. The need was addressed by associating with Government of Indias Total Sanitation Campaign which has State Government and UNICEF as partners. The government contributes 2250Rs/ person for Bellow Poverty Line families and 1250Rs/person for Above Poverty Line families. CGPL facilitated the campaign by contributing additional finance to erect the structure of the toilet. The community also responded by adding its own finance and adding bathroom to the toilet and thus making the solution complete. The activity started in Oct aims to provide 204 toilets till the end of March. . Community and Reproductive Health CSR department have redesigned the earlier model of health camp based on feedback from villagers. Transportation and Connectivity One kilometer of village road was concretized. Education Distributed school kit (school bag, books, compos box etc.) to primary school children in Tunda and Wand village. Roof restoration was carried out for one school in Tunda. Water troughs and animal shelters Almost all the villages have sufficient water troughs. One trough was built in the area where fodder is made available to the cattle. Veterinary Services One Foot and Mouth Disease Vaccination camp and one Camel vaccination camp are being carried out. Repair and renovation of Common property resources This work is carried out as and when the demand comes. Drainage system and Park wall restoration was carried out in Mota Kandagra. Around 10 speed breakers were also provided in the villages.

Livelihood opportunities and market linkages As an extension of local hiring and purchase plan, livelihood opportunities and market linkages identification plans for developing the communities skills, exposure and experience for long term income stability. Livelihood restoration being carried out is summarized briefly in the following table.
Sl. No. 1 Area Entrepreneurship Status & activities undertaken by CGPL Training centre established and local entrepreneurship being fostered adopting iLead program, for technical trades. The plan was to train people in various streams viz. plumbing, welding and computer training. In practice only computer awareness training was imparted which was assessed not useful by the local

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra population. Lack of availability of trainers and lack of jobs for the trained has forced this program closer since last one year. 2 Fodder supply Providing fodder to cattle being considered a holy activity among the adjacent communities, and there is an existing trust working on fodder distribution to the cattle. Based on survey, 2000 nos. of cattle were identified to need fodder supply. Accordingly a new trust (with 3 of 11 members from CGPL) has been formed and budget allocated for stock fodder. The trust is being encouraged to augement income from other sources & donations, thereby reducing dependence on CGPL, over a long term. Only initial talks with Indian Institute for Rural Management, Anand have been undertaken by CGPL, on this aspect.

Dairy Cooperative

SHG for tie and dye Self Help Groups formed within the villages. They are regularly products meeting as mentioned in the list of meetings. CGPL arranged for one lecture by Vivekanad Rural Training Institute. Market linkage Initiatives for market linkages of handicrafts initiated by CGPL, augmentation for with further progress anticipated handicrafts

Community Development Plan One of the promised submittals the Community Development Plan is not ready yet. CSR department officials expressed that, rather than preparing Community Development Plan for the affected four villages, they wanted to target 25 villages around the project and create a larger development plan. To facilitate the decision making CSR department carried a Community Satisfactions Index and Community Awareness Index Survey through Tata Institute of Social Sciences in March 2010. The results of the survey were expected to arrive in May 2010, which will form the guideline for the Community Development Plan. Stakeholder engagement framework CSR department and overall CGPL have effectively engaged all the stakeholders at various decision making processes. CGPL has established and identified the village committee composed of 12 people from the village as its last contact point. This helped CGPL is responding to the requirements of the village rather than confronting individuals. This also helped in establishing transparency and trustworthiness. This pro active approach has helped CGPL in reducing grievances also. Land Acquisition (LA) is a general source of grievances in most of the projects. In this particular project the land which was acquired was mostly grazing land. For the communities, especially Rabari community which is predominant in Vandh village, fodder supply for the cattle was a major issue. CGPL has taken proactive steps and is providing fodder to cattle in

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the affected villages. Land Acquisition procedure is almost over. Thus the grievances of community are not of serious nature. In case LA complaints, the CSR team forwards the issue to Team Lead Public Relation (TLPR). The TLPR will take up the issue with LA department. TLPR communication will inform the concerned person about status of his complaint. An unstructured grievances redressal was working through various departments of CGPL. After SENES comments in quarter two audit in 2009, the following Grievances Redressal Cell is formed as mentioned bellow.
Head Site HR - Sh. Nayan Taunk (He is also handling portfolio of erstwhile Chief Administration) Head Security Sh. Manoj Malik Chief Admin Capt P Tewari Member CSR Sh. S Sharma Village Rep Respective Sarpanch of concerned village (However for PAP its only TundaVandh, therefore Sh. Kirti Gor)

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Environmental and Social Progress of Project Underway

It is understood based on discussions, site observations and review of project progress documents that a time period of 31months has elapsed since the project zero date of 1st September, 2007 and project is currently on schedule. Formalities for land acquisition and transfer of land titles to CGPL continued. NOC for mortgage of 160 Ha. Govt. land in favour of Indian and ECB Lenders planned for next month. Major engineering is completed and all major packages are awarded. Construction is continuing in full swing. A summary progress of current project activities is listed herewith:
All major packages are awarded. Total out of 98 nos. 95 packages are awarded; material despatch and deliveries are continuing. Boiler Area - Structural and mechanical erection of boilers units (Unit#20, Unit#30, Unit#40 and Unit#50) under progress. Hydrotest of boiler Unit#10 completed and ESP erection for the same is in advance stage of completion. TGB Area - Civil and structural works of the TG area is under progress. External Linkages - Work on new coal jetty is progressing and is expected to be ready by Nov 2010 along with ship unloading facilities. Work in progress for 400 KV transmission lines of Mundra-Vadavi, Mundra-Jetpur, Mundra-Limbdi, and Gandhar-Navsari; civil work in progress for Bhachau 400/220 KV substation. BOP Area - Brackish Water RO (BWRO) commissioned with Narmada Water; foundation, structural fabrication and erection of both external and internal coal handling system in progress; earthen embankment for ash pond completed and civil works for ash handling system in progress; concreting work of CW intake channel completed the excavation of outfall channel under progress.

The document reviews undertaken, do not contain detailed status of the progress made in EHS related items and the status of all related permits & approvals. The only design changes to the project, with potential significant environmental & social implications are:
Change in intake & outfall locations, due to optimization of the projects marine components with that of the adjacent Adani Power facility External coal conveyance system from railway to conveyor

These changes have been assessed for their environmental & social implications. Compliance assessment of the environmental approvals received is presented in earlier sections of this report. Significant environmental & social issues reported during the period and corrective actions initiated in line with the audit recommendation have been provided below:

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A. Environment

Inconsistencies in the periodic air quality monitoring data observed have been addressed through the installation and operation of a continuous ambient air quality monitoring station onsite. Current disposal practice of solid waste generated from canteens and labor camp including sewage need to be discontinued in line with the Indian regulations and IFC standards. A STP to this regard has been commissioned and being operated by dedicated O&M personnel with necessary efforts also being made by CGPL in reuse of the treated sewage for green belt development. CGPL to provide continued support in the initiatives taken by INTACH in recycling food waste into compost for development of green belt. Further improvement need to be demonstrated by CGPL with respect to waste management initiatives undertaken with respect to segregation of recyclables at source and their recycling through local vendors. Recycling of food waste is considered to provide impetus in improvement of current waste management practice. Absence of project specific EPIs has been identified to be critical with respect to monitoring of project environmental performance. Necessary efforts have been taken by CGPL in defining relevant EPIs; Commitment towards implementing them on a fast track basis clearly expressed by CGPL. Technical specifications, procurement and commissioning status of packages/ equipments viz. low NOx burners, FGD, ESPs, STP etc related to the environmental implications have been verified and are seems to be reasonably in-line with the requirements and plans. Intermittent sourcing of ground water from the local villages to be restricted to the possible extent, with enhanced efforts in undertaking rain water harvesting.

B. Social Achievements Some of the remarkable achievements of CGPLs social action plan are as follows. Fodder supply: Fodder supply to the villagers cattle is a very successful scheme from CGPL. The system is right now funded by CGPL but is on its way to be financially independent. Total Sanitation Campaign: The government campaigns effectiveness was enhanced by ensuring CGPL and villagers contribution. Self Help Group: Establishment of small self help groups and allowing them to mature in terms of financial management will help the community in long term.

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

Greater autonomy to CSR: The CSR department can now take decisions up to 5 lakh rupees worth contracts which will earlier taken by procurement department. Employment Opportunities: CGPL has provided employment opportunities to locals through shops on site and small contracts. Stakeholder Engagement: CSR department and overall CGPL have effectively engaged all the stakeholders at various decision making processes. CGPL has established and identified the village committee composed of 12 people from the village as its last contact point. This helped CGPL is responding to the requirements of the village rather than confronting individuals. This also helped in establishing transparency and trustworthiness.

Way ahead Results of the Community Satisfactions Index and Community Awareness Index Survey to be analyzed with the census survey carried out by CSR so that basis of the Community Development Plan can be prepared. Employment of the villagers through various contracts during Operation stage of the project needs to be studied. A time bound Employment or Training Plan need to be prepared in consultation with the villagers, with the help of census survey results. Skilled agency to be engaged for questionnaire design and actual conduction of census survey. A more targeted questionnaire needs to be designed to track the socioeconomic changes in the life of PAPs. Plan for vocational training and market linkages of the Self Help Group needs to be prepared and implemented. New strategy for health camps needs to be decided and implemented

Summary of Safety Performance and any Corrective Action

The project has towards the end of the reporting period, clocked around 28.19 million man-hours with 4 no fatalities and 12 no Lost Time Incidents. The major safety performance indicators for the project, as calculated at the end of the reporting period are tabulated (Table-1) herewith: Table 1: Safety Performance Indicator Status (April 2009 to Mar 2010)

Sl.No
1 2 3 4 5

Performance Indicators
Induction Training - Attendees LTIs First Aid Cases Medical Treatment Cases (MTC) Actual Person Hours Lost

Apr-Jun 2009
3659 3 228 4 400

Reporting Period Jul Sep Oct-Dec 2009 2009

7919 5 358 1 1219 7131 1 558 1 408

Jan-Mar 2010
6327 3 521 4 12027

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

Sl.No
6 7

Performance Indicators
Total Person Hours Worked LTI Frequency Rate

Apr-Jun 2009
5130324 -

Reporting Period Jul Sep Oct-Dec 2009 2009

6671652 Jul-0.67 Aug-0.92 Sep- 0.83 Jul-13.54 Aug-933.4 Sep- 847.1 2 42 2 6671652 Oct-0.63 Nov-0.55 Dec-0.48 Oct-599 Nov-517 Dec-461 19 49 0

Jan-Mar 2010
9725994 Jan-0.63 Feb-0.03 Mar-0.00 Jan-379 Feb-2.92 Mar-5.17 10 73 2

LTI severity Rate 8 9 10 11 Fire Cases Near Misses Fatality

Apr 3.079 May 2.89 June 3.01 1 21 0

General assessment of safety performance, safe work practices and implementation of procedures, indicate reasonably good safety awareness among the contractors. The key health and safety issues identified during quarterly audits carried out for this year and necessary corrective action taken by CGPL to mitigate the same have been referred below: Fatalities and LTIs are adequately investigated and findings documented and communicated to the contractor for necessary corrective actions. However the close engagement of contractors in minimizing fatalities at potentially high risk operational areas needs to be strengthened.

Augmentation of HSE staff recommended has been complied by CGPL through recruitment of Associate Group Head-Safety, Safety Stewards and Medical Officers. Gaps identified with respect to the integration and communication of CGPLs safety plans, procedures and performance indicators with that of the project contractor (M/s DOOSAN) have been complied with. CGPL to take this ahead in demonstrating continual improvement in safety performance. Formulation and implementation of a Travel Safety Management Plan recommended for minimizing risks associated with travel of personnel and material movement. Appreciable initiatives have been undertaken by CGPL in formulating such a plan, carrying out awareness exercise for CGPL staff and imparting safe driving and behavioural training to drivers. Additional efforts are also required towards expediting the construction of staff colony to minimize travel safety risks to CGPL staff. Mock drills for emergency response need to be carried out frequently by CGPL and learning/findings from such exercise need to be documented and shared to ensure effective response. Management of health and safety of workforce to be initiated through discontinuation of make-shift camps, expediting the operation of new labor camp, monitoring health of female workers and provision of recreation and common cooking facilities at the

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

camps. Although the new labor camp has been operational since end of January 2010 it was found to be occupied by security personnel. Possible challenges cited by CGPL regarding relocation include satisfaction of workers with the make shift arrangements and general apprehensions in adjusting to the new labor camp set up. However in anticipation of conflict of the workforce with the local communities, CGPL is advised to analyze the potential risks of such make-shift camps and evaluate its preparedness to address such identified risks. CGPL to also address the grievances of residing workforce with respect to the existing cooking arrangements and make necessary provision for recreation facilities at camp. Health surveillance of female workers has been initiated with a female doctor visiting the medical centre once a week.

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra

Annexure 1: EHSS Compliance Details

Issue No 1 Description Status (New/Old) Old Assessment Recommendation Priority Compliance Status

Social & Environmental Assessment & Management System Social and Environment assessment Conducted environment assessment for both the land and marine component of the project, supplemented to address change in sea water intake and outfall locations, external coal handling system and in response to lenders queries on the assessment primarily relating to additional environmental considerations (such as cumulative impacts) The environment and social action plan prepared in November, 07 has been assessed to identify actions required to comply with lenders requirements, as applicable to the relevant project phases. It is assessed that there is sufficient scope for utilization of dredge spoil generated from capital and maintenance dredging of intake and discharge channels, by Adani. Currently staff strength to take initiatives, monitor as well as document such initiatives is generally assessed to be below requirements for health, safety, environment and social functions Assessed to be sufficient in general, with clear gaps on travel safety, waste management, spill prevention & control Carry out regulatory due diligence on environmental aspects of facilities being developed by Adani, that are part of external linkages to the project Medium In view of limited leverage of CGPL over Adanis environmental performance, it is now recommended that sufficient awareness of regulatory developments and compliance exists, with information available in public domain. Although included in ESAP, CGPLs leverage/influence on any such action by Adani is very weak. The dredge material from capital dredging as however been observed to be utilized for large reclamation needs in the area.

Management Program

Old

Need of development of a separate dredge disposal plan required to be assessed, as identified in the ESAP

Medium

Organizational capacity

Old

Reassessment of planned staffing as well as urgently executing the plans, particularly for the health and environment functions

High

Reassessed and strengthening done.

staff

Training

Old

Fulfill assessed training gaps and prepare specific training plans on health, labour hygiene and onsite environment management

High

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Issue No 5 6 Status (New/Old) Old Old

Description Community Engagement Monitoring and Reporting

Assessment Assessed to be sufficient and effective Internal reporting on assessed to have gaps EHS aspects

Recommendation Sustain with project progress Establish strong internal reporting system at least on a weekly basis, and improve upon current reporting to make it robust in terms of coverage of project progress dynamics and their EHS aspects Development and implement project specific EPI;s to monitor project environmental performance

Priority Medium Medium

Compliance Status To be continued Although significant improvement assessed on H&S aspects, monitoring & reporting on environmental aspects needs improvement EPIs defined need to be now implemented by CGPL on a fast track basis

New

Absence of well defined Environmental Performance Indicators (EPIs)

Medium

Labor & Working Conditions 8 Human Resource Policy Working Relationship Working conditions and terms of employment Workers Organization Non-discrimination and equal opportunity Retrenchment Grievance mechanism Child Labour Forced Labour Occupational Health & Safety Old Assessed to be generally in compliance with all the standards relating working conditions and worker relationship management Sustain with project progress High

Old

Current awareness on travel safety needs assessed to be inadequate

A complete overhaul of the current travel safety practices is required with strong awareness building exercises

High

Appreciable initiatives have been undertaken by CGPL in formulating a Travel Safety & Management plan, carrying out awareness exercise for CGPL staff and imparting safe driving and behavioural training to drivers. Additional efforts are also required towards expediting the construction of staff colony to minimize travel safety risks to CGPL staff.

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra
Issue No 10 Status (New/Old) Old

Description

Assessment PPEs, rest rooms, safety induction, potable drinking water, being provided at the work site

Recommendation Provide enhance dust control measures especially in batching plant, blasting and paint shop areas

Priority Medium

Compliance Status Although significant improvement in housekeeping is observed throughout the project the challenges related to dust control and housekeeping continue to exist in the operational areas viz. ash pond, fabrication yard, batching plant etc. Provision of drinking water and sanitation facilities onsite was found to be adequate. PPE usage among workers has been observed to be extensive and satisfactory. Safety signs and posters have been displayed in critical project operational areas. Augmentation of HSE staff initiated by CGPL through recruitment of Associate Group Head-Safety, Safety Stewards and Medical Officers. First aid training has been reported to be consistently performed with subcontractors also being trained on first aid intervention. Integration of CGPLs safety plans; procedures and performance indicators with that of the project contractor (M/s DOOSAN) have been complied with. CGPL is suggested to take

11

Mobile toilets to be provided at locations with considerable workers presence Sustain PPE usage in critical areas, enhance safety awareness and specific attention on compatible PPE usages on site

Medium

12

Medium

13

Current man power allocation to drive basic safety provision and monitor occupational health concerns requires staff strengthening on priority basis and as already identified by CGPL

Medium

14

New

Communication and contractor engagement to manage and mitigate project safety related risks was found inadequate

Integration of safety management system of CGPL and DOOSAN

High

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Issue No Status (New/Old)

Description

Assessment

Recommendation

Priority

Compliance Status this ahead in demonstrating continual improvement in safety performance.

15

Non-Employee Workers

Old

Assessed to be inadequate as part of currently operating labour camp and health facility on site. Dependency of the labour for basic amenities, on the adjacent informal markets cropping up just outside fence yard has been observed

Expedite the initiatives planned by CGPL in order to fulfill the inadequacies - significantly, room occupancy, ventilation, surface drainage, hygiene awareness, occupational and general health needs, entertainment & recreational facilities, construction of amenities block, education and child care facilities. Make shift labour camps to be discontinued and relocated into the new labour camp. Objective specific water testing to be carried out to ensure safe drinking water and also prevention of communicable diseases

High

Although the new labor camp has been operational since end of January 2010 it was found to be occupied by security personnel. Possible challenges cited by CGPL regarding relocation include satisfaction of workers with the make shift arrangements and general apprehensions in adjusting to the new labor camp set up. However in anticipation of conflict of the workforce with the local communities, CGPL is advised to analyze the potential risks of such make-shift camps and evaluate its preparedness to address such identified risks. CGPL to also address the grievances of residing workforce with respect to the existing cooking arrangements and make necessary provision for recreation facilities at camp. Health surveillance of female workers has been initiated with a female doctor visiting the camp medical centre once a week.

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra
Issue No 16 17 Status (New/Old) Old Old

Description Supply Chain General Requirements

Assessment No specific need assessed Design stage pollution prevention & abatement measures shall be assessed during subsequent audits -

Recommendation

Priority High -

Compliance Status

Pollution Prevention and Abatement Technical specifications, procurement and commissioning status of packages/ equipments viz. low NOx burners, FGD, ESPs, STP etc related to the environmental implications have been verified and are seems to be reasonably in-line with the requirements and plans. Recycling/reuse potential should be tapped as part of water usage during construction activities. Planned initiatives for reuse of treated sewage waste water to be expedited Continuous ambient air quality monitoring station to be installed and operated onsite in view of robust data needs Take up waste management planning along the entire chain of waste management and undertake implementation of the same immediately. Specific waste management contractors could be deployed to ensure reuse/recycle, offsite treatment and responsible disposal of hazardous and non hazardous waste. Start up and stabilization to be speeded up to avoid current practice of on-land disposal of untreated/partially treated sewage

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Pollution prevention, resource conservation and energy efficiency

Old

No specific water resource conservation practices or procedures are evident during the current construction stage

High

Reuse of treated waste water for green belt development has been put in practice by CGPL. Progress on rainwater harvesting is awaited. Continuous air quality monitoring station is being operated by CGPL from Apr10 onwards. Although visible improvement has been noticed in the management of scraps viz. metals, wood etc the disposal of food waste and recyclable waste still remains to be of concern.

19

New

Review of data obtained through periodic air quality monitoring revealed inconsistencies Excepting concrete related construction waste, no specific waste management procedures and practices seem to be evident from the site observations and discussions with site personnel. A 500 KLD STP has been commissioned and trial run in progress

Medium

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Wastes

Old

High

The performance of the STP installed at the labor colony was found to be satisfactory with dedicated O&M personnel deployed to supervise its proper

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Issue No Status (New/Old)

Description

Assessment

Recommendation waste water

Priority

Compliance Status operation and maintenance.

21

Hazardous Materials

Old

Storage and handling of fuel, lubricants & other oils seem to lack sufficient secondary containment and spill control & response facilities

Keep track of all hazardous material storages and ensure containment measures, spill control & response facility are established, utilized and maintained.

Medium

Additional measures with respect to spill prevention and control at fuel and lubricant storage areas required. Adequate training need to be imparted to contractor workforce to enhance awareness on spill prevention and control measures. The Emergency Response & Disaster Management Plan has been reviewed and was found to be in commensurate with the project associated health and safety risks.

22

Emergency preparedness and response

Old

CGPL has prepared an onsite emergency preparedness & response plan and does not envisage the need of such plan for offsite emergencies with the current construction activities. The existing plan shall be reviewed during subsequent audits.

Monitor and document potential offsite emergencies specifically those relating transport and reassess the need of offsite emergency response plan which may gain significance with increased scale of construction activities.

Medium

Community Health, Safety & Security 24 Environment and natural resource issues Old Project water sourcing practices from the local communities and current local procurement expectations assessed for the need to be balanced Awareness to be built on long term community water sourcing impacts and ensuring controlled water sourcing from the Narmada Pipeline. Fuel wood sourcing by the labours also need to be controlled and avoid potential community impacts Medium Ground water sourcing from nearby villages still being practiced. Additional thrust required from CGPL in identification and assessment of alternative sources and provision of rain water harvesting structures. Local xerophytic shrubs and undergrowth is being utilized by labors as fuelwood to avoid

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Annual Environmental & Social Performance Report (FY 09-10) CGPL Power Plant, Mundra
Issue No Status (New/Old)

Description

Assessment

Recommendation

Priority

Compliance Status pressure on natural resources.

25

Community exposure to diseases

Old

Currently awareness on potential community exposures to disease especially due to large labour influx, is non existence. This specific concern gains prominence due to sparse local population and a very high regional labour influx

Review potential sources of such community exposure (transferable diseases) and build sufficient capacity with the onsite health infrastructure to be able to address this concern.

Low

The medical records and the discussion with medical staff do not reveal presence or treatment of any worker for transferable disease till date. Most of the workers stay in the labor camps and very few workers are detected with transferable diseases. Thus labor camp and labor check up has brought down the risk associated with the diseases exposure of the local population. Regular checking of all incoming workers and maintaining records especially for communicable diseases is essential.

Land Acquisition & Involuntary Settlement 26 Project design Old No such change in design observed as part of the review document Regular community consultation being carried out, method of compensation for grazing land and related CSR activities were decided after consultation -

27

Consultation

Old

Focus consultation with the project affected people to be carried out periodically.

Medium

CGPL to continue with their sustained efforts in carrying out regular community consultations. Formal grievance redressal mechanism has been put in

28

Grievance Mechanism

The grievance redressal mechanism to be streamlined and documented, to

Medium

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Issue No Status (New/Old)

Description

Assessment

Recommendation avoid potential conflict in future

Priority

Compliance Status place by CGPL and was found to be effective. However documentation to be maintained especially about PAPs to avoid future conflicts. Although CGPL has provided employment opportunities to locals however long term opportunities were found to be lacking. CGPL to adequately plan to ensure long term employment and business opportunities for the local communities. Visible progress has been witnessed in the green belt development program (utilizing indigenous species) being implemented by INTACH. Further efforts have made by the concerned agency in recycling food waste as compost for green belt development. CGPL to adequately support INTACH initiatives in taking this ahead.

29

Economic displacement

Old

CGPL provide employment opportunities through training, site jobs and allotting shops to the local communities

Focus on providing such opportunities to the project affected people recommended

Medium

Biodiversity Conservation and Sustainable Natural Resource Management 30 Protection and conservation of biodiversity Habitat Modified habitat Natural habitat Critical habitat Legally protected areas Invasion of alien species Management and use of renewable natural resources Natural & Plantation forest Fresh water and marine ecosystem Old No such sensitivities identified as part of pervious assessment, except for the existing invasive species of Prosofis julifera Implementation of planned conservation initiatives should be monitored with experienced environmental manpower to ensure the integration envisaged with waste management is in concurrence with project progress. Compensatory afforestation against the acquired forest land to be strictly followed Medium

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