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Quarterly Environment & Social Monitoring Report (October 2011 to December 2011)
The Environmental and Social Performance Report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s 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.
Environmental and Social Performance Report March 2012
IND: Mundra Ultra Mega Power Project
Prepared by SENES Consultants India Pvt Ltd.
Quarterly Environment & Social Performance Report – Tata Ultra Mega Coal Fired Power Plant, Mundra
Period: October to December 2011
Submitted to: Coastal Gujarat Power Ltd (CGPL)
Prepared by: SENES Consultants India Pvt Ltd.
Table of Contents
1 Introduction ........................................................................................................................ 1
1.1 Background ............................................................................................................................. 1
1.2 Objective ................................................................................................................................. 1
1.3 Project Status .......................................................................................................................... 2
2 Environmental & Social Management ............................................................................... 2
2.1 ESPR Preparer ........................................................................................................................ 2
2.2 Environmental Management Plan (EMP) & Social Management Plan (SMP)
Implementation ................................................................................................................................... 3
3 Compliance with CGPL Environmental & Social Requirements ...................................... 3
3.1 Environmental Aspects ........................................................................................................... 3
3.2 Social Management ................................................................................................................. 5
4 Health & Safety ................................................................................................................ 13
4.1 Health & Safety Management ............................................................................................... 13
4.2 Safety Performance ............................................................................................................... 15
List of Annexure
Annexure 1: Persons Interviewed ...................................................................................................... 18
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 1 SENES
QUARTERLY ENVIRONMENTAL AND SOCIAL PERFORMANCE
REPORT
(ESPR)
Reporting Period: October to December 2011
Site visit date: 6th – 8th February 2012
1 Introduction
1.1 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 Quarterly Environmental & Social Performance Report (ESPR) is to
report on CGPL’s 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
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 2 SENES
1.3 Project Status
The actual progress for the month has been 0.80% against an early schedule of 0.14% & late
schedule of 1.18%. Overall actual progress stands 92.15% against an early schedule of
99.57% and late schedule of 97.23%. Major engineering is completed and all packages
awarded with materials’ delivery continuing. Major accomplishments for the month includes
Unit#10 & Common – Steam turbine generator was rolled on 28/11/11 and Unit
synchronized on 08/01/12. The second fly ash and bottom ash slurry line completed on
10/12/11. Unit#20 – All system related to BTG and auxiliary are commissioned and ready for
synchronization with Boiler RH tube modification is in progress. With respect to fire
protection Transformer yard HVW spray system works for all transformers flushing
completed on 09/01/12 and systems put in service. Unit#30 – Boiler light up using LDO was
performed on 21/12/11 with draft system test and air balance test completed on 16/12/11.
Restoration work related to boiler light-up completed. Cable laying and earthing works are in
progress with electrical panel commissioning and loop checking work in progress. Unit#40 –
Pass-B duct leak test and burners alignment completed on 16/12/11 and 29/12/11
respectively. ID Fan-A & B lube oil system flushing using flushing oil completed on
13/12/11 and 22/12/11 respectively. Unit#50 - Boiler wall shoot blower installation work
completed 31/12/11. Auxiliary steam piping and atomizing steam line completed on 30/12/11
and 15/12/11 respectively.
Chimney-1: Elevator installed. Stair case, electrical and C&I works are in progress.
Chimney-2: All flue cans erected for U#30 and chimney released for furnace draft test on
13/12/11. U#40 flues can erection commenced on 14/12/11 and 24/48 flue cans erected for
Unit#50. Transformer Yard – The Mundra-Bhachau-Vadavi 400 KV power evacuation line
commissioned by PGCIL on 29/09/2011. The construction of remaining transmission lines
viz. Mundra – Surajbari—Limbdi and Mundra – Surajbari – Jetpur & Gandhar-Navsari line is
likely to completed by PGCIL by Jan’12 and Mar’12 respectively. M/s. ADANI (CW
Intake, ECHP and Coal Jetty): ROW for ECHS and Revised PSA, signed with MPSEZL.
2 Environmental & Social Management
2.1 ESPR Preparer
Report prepared by: SENES Consultants India Pvt. Ltd.
Telephone: 022-27576298 / 32986995
E-mail: [email protected]
Signature:
Report Date: February 2012
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 3 SENES
2.2 Environmental Management Plan (EMP) & Social Management Plan (SMP)
Implementation
The following groups of the Tata Power Corporate Office and CGPL’s 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
The list of individuals contacted during the site visit is given in Annexure 1.
3 Compliance with CGPL Environmental & Social Requirements
This section describes current compliance of the project with IFC/ADB’s environmental &
social policies and guidelines, Environmental & Social Management Plans and presents the
key environmental & social performance indicators. The current project activities have been
assessed with respect to observations and comments offered in the last audit.
3.1 Environmental Aspects
As part of its solid waste management
initiative for the project township CGPL
has commissioned and operating a Biogas
Plant of capacity of 3000 kg/day (Photo
1). Presently with limited occupancy as
the township is under development the
Biogas Plant is presently being operated
at a capacity of 35kg/day. Appreciable
efforts have also been made by CGPL to
utilize renewable energy resources (solar
power) through installation of Tata BP
Solar Plant at the township to cater to the
hot water requirements at the kitchen
facility. However the commissioning of
biogas plant facility to ensure effective management of biodegradable waste generated from
contractor labor camps (as reported during Jan-Mar’11 quarterly audit) is still pending.
Tata Power Management Team continues to work towards in arriving at a feasible
alternative/solution with respect to project coal availability given the sudden rise in import
coal prices in Indonesia. As earlier recommended CGPL to keep SENES and other
stakeholders (MoEF, GPCB etc) updated on the alternative likely to be chosen and potential
implication (if any) of the same on project design, pollutant characterization and control
equipments.
Photo 1:Biogas Plant at CGPL Township
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 4 SENES
CGPL recognizes fugitive emission from coal conveyors and stockpiles as potential pollution
source leading to possible health related discomfort to nearby communities particularly
Vandh village (considering its location with respect Adani and CGPL coal conveyor). In view
of the above CGPL have identified the following mitigation measures for necessary
implementation:
Development of peripheral green belt (width 100m) along the space between the
boundary wall and coal yard. The purchase order for green belt development
subcontracting work is awaiting finalization.
Wind barrier of height 9m to be set up at the coal yard to control coal dust fugitive
emissions resulting from high wind speed characteristic of Mundra coast region.
Selection of subcontractor for the same is under process with the wind barrier likely to
be installed by end of Feb’12.
CGPL is also in process of using chemical dust suppressants as a dust controlling
agent based on review and evaluation of industry best practices as implemented by
GE in its projects worldwide.
CGPL further has plans of setting up physical barriers (like boards) along the entire
length of coal conveyor, the procurement of which is under process. As
communicated CGPL will also continuously looking ahead to any possible design
related modifications of the coal conveyor to prevent any fugitive emission.
Additionally in this regard CGPL also need to comply with relevant consent conditions viz.
provision of dusting facility, bag filter etc as outlined in the CTO issued by GPCB to control
fugitive emissions from coal conveyor operation. However it is recommended that aforesaid
mitigation measures are adequately supported by source emission modeling study to ensure
effectiveness.
Review of the draft legal EHS register (as discussed during the last quarter audit) being
developed as a part of ISO Integrated Management System (IMS) documentation indicated
the absence of permit/consent conditions including key legislations (EIA Notification, CRZ
Notification etc). In this regard CGPL also need to ensure the inclusion of specific provision
of IFC EHS Guidelines for Thermal Power, IFC General EHS Guidelines, IFC-CGPL
Covenants and IFC Performance Standards (IFC PS) in the register to effectively ensure and
track legal compliance during project operations.
A visit was carried out along with CGPL personnel at West Basin to review the solid and
hazardous waste management practices in accordance with maritime regulations viz.
MARPOL. Reportedly operations at the West Basin is being carried out by Adani and the
waste management of shipping vessels carrying coal to this port is in strict conformance with
the applicable International Maritime Organization (IMO) regulations. As no discussion to
this regard could be arranged with relevant Adani personnel it is requested that specific
policy and/or plans/procedures as being adopted and implemented by Adani with respect port
& vessel waste management practices is shared with SENES by CGPL
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 5 SENES
As suggested earlier liasioning with CGWB to be continued by CGPL in order ensure
approval of the rain water harvesting plan which is still pending. Further the following
actions as recommended in the July-Sep’11 audit report requires active consideration by
CGPL:
Validation study of the thermal dispersion modeling of intake and outfall discharge of
cooling water in relation to the concerns raised by Machimar Society – an NGO
representing fisherfolk and as committed in the marine EMP prepared by NIO.
Establish market linkage for complete utilization of fly ash in nearby industries
(cement) on a fast track basis in accordance to EMP & CTO (dated 21st Oct’11)
requirements. Reportedly only two truckloads have been transported to Binani
Cement for cement preparation.
Establish an ambient air quality station at Tragdi Bunder/Village to regularly monitor
the air pollutant levels and subsequently assess the potential air quality impacts on
fishing communities, if any during operations. PM2.5 to be integrated as a key
parameter as part of village level ambient air quality monitoring program.
Due-diligence study to be undertaken with the PMU coordinating pilot approaches in
the Gulf of Kutch, under the WB funded Integrated Coastal Zone Management
Project, with respect to the anticipated project’s risks and interactions with marine
resources, conservation needs, and coastal communities.
Development of Environmental Action Plan and Coastal Biodiversity Management
Plan based on deviations observed in the ambient environmental quality and Bombay
Natural History Society (BNHS) survey undertaken on marine and coastal
biodiversity respectively.
3.2 Social Management
The current project activities have been assessed with respect to observations and comments
offered in the last audit.
In compliance towards commitments made by CGPL to IFC in various documents such as
Resettlement Planning, Final Compensation Management Framework, Local Hiring and
Purchase Plan, Final Stakeholder Engagement Policy, CGPL has implemented the following:
For Restoration of Income for Loss of Agricultural Land
The Land sellers/land losers/PAF list/PAPs list has been prepared.
For local procurement and employment, a procedure has been developed by CGPL.
The Procurement Department has identified contracts /work that could be outsourced
to the PAFs or local vendors from the affected villages. The PAFs/PAPs list and a
vendor database have been prepared. The Procurement Department issues vendor
requirement for CGPL to the CSR Department which forwards it to CIC for
translation into Gujarati and display on notice board in the village. The applications
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 6 SENES
received are documented and entered into database and forwarded to the Procurement
Department. The procurement then awards the contract based on negotiation and
fulfillment of criteria. For PAFs and local vendors there is a limited tendering. The
dept. provides guidance and feedback to local vendors in the fulfillment of their
contracts.
For extending employment a similar process is followed by the HR department with
Contractors giving details for manpower requirement. The list is forwarded to the
CSR department for translating and displaying on notice board. Applications and CVs
received from the PAFs/PAP and locals from affected villages are forwarded to the
HR Department. The HR Dept. forwards the same to the concerned Contractor. The
list of applicants employed is given to the HR Dept. by the Contractor which is shared
with the CSR dept. The CSR dept. updates the details in their database.
CGPL had proposed to offer training and education opportunities to enable the PAPs
to fit criteria and has proposed to accommodate PAPs in sectors identified. It has been
suggested in the last audit that a time bound programme needs to be worked out in
terms of positions made available and PAPs completing training. CGPL in this regard
proposes to collaborate with a organization which will identify training and
employment opportunities for affected people and provide training for imporving
employability.
Recommended Actions
1. The entitlement matrix still needs to be prepared for employment of PAPs. For the
preparation of the entitlement matrix
a. Policy for employment under rehabilitation for affected/land sellers families should
be clarified and
b. Definitions for key concepts such as ‘Family’, ‘separate family’ (adult married sons,
unmarried daughters - age to be defined, handicapped/disable family member,
deserted, abandoned and divorced women), ‘PAP’, category of land loser/seller,
eligibility for employment, etc should be formulated.
c. Concerns related to priority, alternatives in case the affected family or person as not
ordinarily residing in the village, death of nominee, absence of legal heirs for affected
families need to be worked out in principle and practice.
2. It has been recommended in the last audit that the PAF/PAP list database finalized
needs to be linked to the HR requirements to enable selection of candidates from the
PAPs list for extending employment, contractual work etc before recruiting from the
open market. Column on benefits needs to be updated in the PAPs list to enable CSR
to monitor the extent of benefits accruing to each PAF (including those through
implementing NGOs) and to ensure the inclusion of all PAFs.
3. The supplementary list also needs to be prepared for families indirectly affected from
loss of common property resources and private & government land, non land based
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 7 SENES
livelihood dependents, encroachers and vulnerable groups. The action taken by CGPL
to mitigate the losses in line with commitments given should be incorporated. For
example payment of Livelihood grant to fishermen from Tragadi village, distribution
of fishing nets to Villagers in Modhva.
4. Procurement and HR Department to prepare and maintain monthly reports on the
number and details of the locals employed directly and indirectly with CGPL.
5. To address the above issues related to procurement, training and employment, CGPL
will formulate a Local Procurement and Employment Policy.
Provision of Employment and Livelihood Opportunities
Employment is covered in the previous section; therefore in this section other livelihood or
income generating activities have been discussed.
Dairy development programme has been initiated in three villages Tragadi, Vandh and Nana
Kandagra.
Farm bunding has been done for the agricultural lands of one of the farmers in Nana Bhadiya.
Drip irrigation has also been implemented in the village and farmers who have implemented
the scheme in their farms have found these to be sustainable. For drip irrigation they expect
that the water consumption will be less. The farmer is cultivating papaya trees to increase
their profits in the current year. Part of the land is under sugarcane.
Provision of Alternative Grazing Land
On experimental trial fodder cultivation has been initiated on 4 hectares of land
owned by company. First harvesting has been done in the month of November 2011
(total yield 650 kgs). The company has paid 30% additional amount to the district
administration in lieu of acquired grazing land for gauchar development purpose. The
district administration will transfer the said 30% to the gram panchayat with a
directive for using the same only for gauchar purpose. The process for development
and liasioning with government rests with gram panchayat.
Gaushala trusts have been set up for Vandh-Tunda and Mota Kandagrah for procuring
and distribution of fodder for livestock. A Gaushala has been constructed near the
main gate of CGPL.
On the whole most of the livestock owners have articulated the distribution of fodder
and the activities initiated for the /Gaushala as a good practice as large number of
households who have livestock have experienced land loss of loss of grazing land
which was acquired by CGPL.
Gobar Gas plant has been installed at village Nanabhadiya and managed by the
Primary school and is used to cook the Mid- Day meal in the school.
Recommended Actions:
1. Promote fodder cultivation by marginal and small farmers in the affected villages that
can be purchased by the Trust.
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 8 SENES
2. Improvement in the livestock by promoting breeds which have comparatively higher
milk production than the native breeds currently reared.
3. A cement or stone platform should be provided in the kitchen of the Primary school at
Nanabhadiya to prevent any accidents or fire as currently the cooking is done on a gas
stove on a wooden bench.
Restoration of Other Common Property Resources
Under Natural Resource Management, CGPL has initiated activities to recharge ground water
through check dams, pond renovation, well recharge and farm bunds.
Women’s Needs and Participation
Women Self Help Groups have been promoted by CGPL and training has been imparted for
SHG members. Skill training for tie and dye as well as embroidery which are prevalent in the
area has also been imparted. Piece work has been provided to the women in the village
although there are some issues relating to the groups member ability to get the raw material
from the organization and returning the cloth after tying. Individual groups member are not
willing to take up the responsibility.
Recommended Actions:
1. As the work has been outsourced to an NGO, Vivekananda Research and Training
Institute (VRTI), CGPL should conduct a review of the number of women trained,
number involved in the piece rate and the average earning per month and access
whether the income has increased from pre training period.
Corporate Social Responsibility (CSR) Initiatives
The development activities undertaken in the villages have been reported to be effective and
in use by the people. There was some feedback from the village (Mukhia and beneficiaries)
on the slow pace of implementation of activities (related to construction and infrastructure
and SHG activities).
The development activities undertaken in the villages have been reported to be effective and
in use by the people. There was some feedback from the villages (Mukhia and beneficiaries)
on the slow pace of implementation of activities (related to construction and infrastructure
and SHG activities).
Drinking water is a key issue for some of the villages in the area. Direct linkage to
government programme has been created through WASMOS and RO plants have been
provided in 12 schools for drinking water. In Tunda and Tragadi villages RO plant has been
provided.
Most of the activities related to the schools were appreciated by the people and teachers.
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 9 SENES
Tunda Vandh road issue has been resolved through a mutual agreement between CGPL and
the villagers by providing access through a gate for the labourers in the village for two hours
in the morning and two hours in the evening. A security guard has also been made available.
The Annual Business Plan of CGPL reflects activities undertaken in the fulfillment of
commitments given during land acquisition and purchase. Under income generation and
livelihood the pool of activities cover various target groups. The PAPs need for employment
and employability are proposed to be addressed though training programmes implemented
through specialized organizations.
Recommended Actions
1. One of the feedback of the teachers is that there are some students who are illiterate or
have borderline literacy. Teachers are unable to give the required time to such
students. Therefore, CGPL should take up activities to address the needs of such
students through volunteerism from CGPL Staff or through any agency to improve
their level and bring them on par with others of their age.
Review of Implementation of Mechanisms for Community Development
Mechanisms have been developed mainly the Village Development Committees,
Grievance Redressal Mechanism, Community Information Centre are in place in the
village Tunda-Vandh and villagers have found it to be a good practice as they are now
informed about the availability of opportunities for vendors and for employment in
three villages.
Notices, detailing work availability and for procurement is translated into Gujarati and
put up in three villages. Applications are received by CIC and forwarded to the
concerned department. The affected villagers have found this practice to be effective.
The PAPs had reported in earlier audits that they were not able to access information
from CGPL. This concern has been addressed partially through the CIC. The CIC
maintains the Grievance Register and the suggestion box, both are common for all
affected villages. This mechanism should not be confined to one village and extended
to other villages as well.
Meetings are being held in Tunda Vandh and people have been positive about the
process.
In Nana Bhaidya, meetings have not been held.
One of the common concerns raised in the villages was that they did not know the
activities being carried out in the village by the NGO, (Vivekananda Research and
Training Institute) VRTI which is implementing select CSR activities on behalf of
CGPL. VRTI submits regular reports to CGPL. Joint Monthly meetings are held
between Staff of CGPL, VRTI and TPCDT and Quarterly meetings are held between
CSR team CGPL, Management Board members and staff members of VRTI.
In Tunda the villagers want village meetings instead of VDC meetings as they would
be informed instead of having only few influential villagers being informed.
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 10 SENES
Villagers across villages reported not having received any receipts for grievances and
applications made for any purpose to the company. Minutes of meetings or
discussions held with VDC and or village meetings were not circulated.
Recommended Actions
1. IFC requires that under the Performance Standard 1 (Social and Environmental
Assessment and Management Systems) Disclosure, Consultation and Grievance
mechanism must be undertaken for community engagement. Community engagement
is an on-going process involving the client’s disclosure of information. When local
communities may be affected by risks or adverse impacts from a project, the
engagement process will include consultation with them. Informed participation
involves organized and iterative consultation, leading to the client’s incorporating into
their decision-making process the views of the affected communities on matters that
affect them directly, such as proposed mitigation measures, the sharing of
development benefits and opportunities, and implementation issues. In line with IFC’s
requirements minutes of meetings will be prepared and circulated to the participants.
For grievances/application, an acknowledgement of the grievance/application
received with unique code/ number should be generated and given to the applicant.
2. CGPL to inform or put up on notice board the activities being implemented though
VRTI and the implementers contact details and by putting up a list of planned,
ongoing and completed activities in each village month wise.
3. Minutes of Meetings to be shared with SENES before the next audit.
CSR Department
It had been recommended in the earlier audit that risk mitigation and CSR development
activities should be separated as both aspects are crucial for stakeholder engagement and
implementation of CSR activities to fulfill CGPL’s commitments to stakeholders and IFC. In
this regard CGPL proposes to appoint staff in the department to fulfill their requirements in
the coming financial year. Details should be made available to SENES regarding the role and
responsibilities.
Other Issues
CAO, Ombudsman Assessment Report Regarding Community and Civil Society Concerns in
Relation to IFC‘s Tata Ultra Mega Project has concluded that a dispute resolution process is
voluntary both for affected communities and for the company. It is CAO‘s view that a
collaborative process may have been helpful in this case to address many of the concerns of
the fisher folk. Both parties understand that part of the threat to the livelihoods of the wider
Mundra coast‘s fisher folk stems from sources beyond Tata Power in the wider
industrialization of the coast, and thus cannot be resolved by the company and community
alone.
In view of the aforesaid findings and as part of its CSR program CGPL has undertaken the
following initiatives in response to the people needs and requirements.
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 11 SENES
a. Drinking water is being supplied to Tragadi Bandar.
b. Construction of access road as alternate road for Tragadi harbor from Balaji Salt pan
Bund.
c. Three health camps have been organized at Targadi Bandar.
d. Regular meetings are being held with the people Targadi Bandar and meetings with
women are also being organized separately.
Other initiatives are being planned by CGPL and will be implemented in the coming financial
year after agreement by stakeholders.
The Stakeholder and Benefit Sharing Report submitted by Karma regarding the fishermen at
Tragadi Bandar has internal inconsistencies such as
Migration both in and out is reported to be nil (but large number of families live in
rented premises, there is also a case of HIV for which details have not been given)
Families reported that they had no savings elsewhere it was reported that fishing
equipments had been bought with savings not on loans, or through other means.
Expenditure pattern of the families not available.
Census seems to have been conducted for very few families. The reason for the same
has not been ascertained.
Consolidated list of fishermen who have received livelihood grant has not been
attached.
Specific Government schemes/programmes and self employment opportunities viable
in the area not discussed.
The Report on Modhva is good and can be used for development interventions for the village.
Major issues related to poverty levels, health and illiteracy with lack of access to anganwadi
services is reflected in large families, lack of options for livelihood other than fishing, few
self employment opportunities and failure to access government programmes by individuals
and the community. Informal source for credit are more prevalent leading to chronic
indebtedness. Extent of indebtedness has not been discussed.
Recommended Actions
1. CGPL to finalize the activities from those suggested in the report and the time line for
implementation of the activities.
2. Some of the activities already undertaken by VRTI in other villages can be
implemented in Modhva especially those related to SHG, Education and Health.
3. Both the reports should be revised and finalized after addressing the inconsistencies
and gaps discussed above.
‘Volunteerism’ With Respect to CSR Activities
Tata Power has an employee volunteering guideline for encouraging employees to give
their time, skill and other resources voluntarily for community welfare.
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 12 SENES
Recommended Action
1. Plan of action for ‘Volunteerism’ for specific CSR activities will be prepared by
CGPL including the time and manpower to be invested and the anticipated outcome
of the activity.
2. The ABP should reflect the activities or sub activities which will be undertaken only
through Volunteers.
Documentation and Reporting
It had been suggested in the last audit that case studies need to be documented along with
photographs to enable more people in other villages to get involved with the on-going
programmes. Each of the past and current (with a continuation of the same for future)
development projects undertaken as part of CSR, should be documented in the form of a
complete report. The reports should also include photographs and handing over of the project
to the Panchayat or the applicable group.
Recommended Actions
1. CGPL to appoint staff, individual/NGO for undertaking reporting and documentation
of CSR activities.
2. Under the GRM a consolidated report with status of grievances to be prepared on a
monthly and quarterly basis. Grievances addressed should be closed.
3. Information dissemination to the villagers should be improved. There seems to be
gaps with regard to the information provided on initiation of activities and the
progress made.
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 13 SENES
4 Health & Safety
CGPL has adopted the health and safety system (with guidance form Dupont) that includes
well defined performance standards, procedures and guidelines (HIRA, SCAR, etc), safety
awareness programs (Safety Time Out) and key performance indicators (e.g. lost time
incidents, severity rate, near miss etc.), which are used to track compliance with Health and
Safety (H&S) targets. Specific health and safety plans and onsite emergency plan have been
developed & augmented on regular basis by CGPL and communicated to contractors. The
plans outline the policies and strategies, the organization, resources and documentation
required, the HS risk management principles, and reporting requirements.
4.1 Health & Safety Management
With the augmentation in safety staffing by CGPL, proper implementation of specific plan
and procedures, communication between the contractor workers, safety training and
awareness, incident reporting, visual aids etc the onsite Health & Safety Management of
CGPL continues to demonstrate considerable improvement.
As discussed during the last quarter audit CGPL has drafted the IMS Legal Register
incorporating the specific provision of applicable health and safety regulations for the
purpose of OHSAS, EMS and QMS certification. However as pointed out in the earlier
section, permit/consent conditions and specific provisions of IFC EHS Guidelines (Thermal
Power Plants) & Performance Standards (PS) referring to occupational health and safety
aspects during operations stage need to feature in the IMS legal register to ensure legal
compliance.
Appreciable efforts have been made by CGPL in the management of health and safety risks
viz. confined space entry, noise and heat exposure, fire & explosion hazard etc identified for
project operations. However with Unit#1 currently under operation and remaining units to
follow it is anticipated that the project facility workers is likely to have a higher exposure to
electric and magnetic fields (EMF) due to working in close proximity to electric power
generators, and connecting high-voltage transmission lines. Hence it is recommended that
occupational EMF exposure be prevented and minimized through implementation of an EMF
safety program by CGPL encompassing relevant aspects as identified in the IFC EHS
Guidelines for Thermal Power Plants viz. identification of potential exposure levels in
workplace, training of worker on EMF, establishment and identification of safety zones,
personnel exposure monitoring etc.
In anticipation of potential fire hazard at open coal yard necessary safety measures have
already being adopted and implemented by CGPL viz. compaction coal stock piles, regular
water sprinkling etc. However in this regard it is suggested that CGPL also evaluates the
option of use of automated systems such as temperature gauges and/or carbon monoxide
sensors to survey solid fuel storage areas to detect fires caused by self-ignition and to identify
risk points.
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 14 SENES
However the following safety related observations were made with respect to CGPL onsite
activities which require focused efforts to ensure necessary compliance:
Gas cylinders were observed to be
stacked in the open near Unit#1 without
proper securing (Photo 2). In accordance
to relevant provision of Gas Cylinder
Rules the cylinders kept in an upright
position need to be properly secured and
so placed to prevent any possibility of
knock over.
Transformer oil drums (approx 60-80
nos) continue to be indiscriminately
stored at BHEL storage yard without
adequate secondary containment and spill
prevention & control equipments (Photo
3).
Development and implementation of
process/mechanism to cater to the
grievances related to basic labor
requirements of the workforce residing
outside the project boundary is still
pending. In this regard CGPL also need to
develop a monitoring program to
periodically check and report for the
presence and/or adequacy of the
amenities/facilities being provided to such
workforce by the contractor in accordance
to applicable labor laws.
Although Desalination Plant is under operation CGPL still continues to source approx 150
KLD of fresh water from local contractors to meet labor camp potable water requirements.
Reportedly this is primarily caused by operational problems faced resulting from water
supply pipeline leaks and corrosion. This assumes significance given the project CTO
imposing restrictions on ground water usage at the project site coming under dark zone even
in lean season without permission from competent authorities. Hence necessary efforts need
to be made by CGPL to discontinue ground water sourcing by regularizing Desalination Plant
water supply through effective redressal of O&M problems as discussed above.
Photo 2:Stacked gas cylinders near Unit#1
Photo 3:Indiscriminate storage of transformer oil drums
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 15 SENES
CGPL township is in the advance stage of
development and likely to support a
residing population of approx 2000 nos
(Photo 4). The allotment of rooms/houses
to CGPL employees is being carried out
in a phased manner in commensurate with
the development of the township building
blocks. Presently only few families has
shifted in the township with full
occupancy expected by next two years.
This is likely to significantly contribute in
the reduction of travel related safety risks.
4.2 Safety Performance
The health and safety performance of the project monitored with respect to safety
performance indicators for the period Oct-Dec 2011 is presented in the Table-1 below.
Table 1: Safety Performance Indicator Status (October to December 2011)
Sl.No Performance Indicators Reporting Period
Oct-11 Nov-11 Dec-11
1 Induction Training Attendees 2187 3500 3173
2 LTIs 0 0 2
3 First Aid Cases 62 90 106
4 Medical Treatment Cases (MTC) 0 0 2
5 Safe Man Hours Worked till last fatality/LWDC 6264560 3345824 222240
6 Total Person Hours Worked 6264560 3345824 3098040
7 LTI Frequency Rate 0.0 0.0 0.65
8 Severity Index 3.0 3.05 2.91
9 Fire Cases 12 11 19
10 Near Misses 100 57 74
11 Fatality 0 0 0
* Last LWDC recorded on 31.08.2011
Photo 4:CGPL Township under construction
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 16 SENES
Table 2: Safety Action Plan
Sl.No Items
Targets Oct Nov Dec
Tar Act Tar Act Tar Act
1 Safety Sub-Committee meeting (Dates)
a) CSC 12 1 1 1 1 1 1
b) Incident Investigation 12 1 1 1 1 1 1
c) Contractor Safety management 12 1 1 1 1 1 1
2 STOP Observation
a) Nos. of observers 98
b) Nos. of observations 392 380 340 360 300 359 289
3 C F S A (as applicable) 4 4 4 4 4 4 4
4 HIRA / JSA (as applicable to SBU) Yet to Finalized
a) New 40 26 24
b) Review in 5 working days 33 4 4
5 Site Specific safety Procedures As and when
a) New additions - - -
b) Review / Updation of existing procedures
6 External / Statutory audits -Safety Audit(as applicable to SBU) 1 in Year
7 Emergency Preparedness drill 12 1 1 1 1 1 1
a) Scenerio / periodicity
8 Audits plan by site safety officers- 1 in year
( System Audit) -For major contractors
(Cross function team to be made- )
9 Safety inspections schedule - ( By safety stewards) 4 Inspection/ month
a) Lifting equipment & accessories -6 monthly 1 1
b) Housekeeping- Monthly 1 1
c) PPE usage -(PPE Inspection - Safety harness,helmet ) 1 1
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 17 SENES
Sl.No Items
Targets Oct Nov Dec
Tar Act Tar Act Tar Act
d) Handtools- Power tools- 1 1 1 1
e) Access & work platform- NA
f) Pressure vessels & gas cylinders - NA
g) Portable electrical equipment- (Welding and cutting - Quaterly 1 1 1 1
h) Fire fighting equipment ( Fixed Systems/ Fire extinguishers) 1 1 1 1 1 1
i) Fire alarm system
j) Fire exits, escape routes marking. Office area.
k) Buildings, plant structures NA
l) Plant lighting
(m) Safety signages -
(n) Conveyors NA
(o) Moving machinery NA
Vehicle Inspection - 1 1 1 1
10 "On-The-Job" Safety events
a) Environment day celebration- 1
b) Electrical Safety week 1
c) Housekeeping week 1 1 1
d) Road safety week- 1
e) Safety week celebration HSE department -Mar 2012 1
f) Fire awareness week 1
11 "Off-The-Job" Safety events 3
a) Home safety- 1
b) Defensive driving-(Traffic safety awarness) 1
c) Environment & Hygiene 1
d) Electrical Safety
Quarterly Environmental & Social Performance Report – CGPL Power Plant, Mundra
February 2012 18 SENES
Annexure 1: Persons Interviewed
Sl. No. Name Position
CGPL
1 Mr. Sharad Baijal Head - Operations
2 Mr. Sanjeev Gupta Associate Group Head - Finance
3 Mr. Ramesh K Dhawan Chief – SHE
4 Mr. Vishal C. Shah Senior Manager - Environment
5 Mr. Himanshu Shrivastav Member, HR
6 Mr. Pradeep Ghosal Associate Group Head – CSR
7 Mr. Amit Ganguli Chief Manager - Procurement