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Annual Environment & Social Monitoring Report (April 2010 to March 2011)

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Environmental and Social Performance Report August 2011

IND: Mundra Ultra Mega Power Project

Prepared by SENES Consultants India Pvt Ltd.

Annual Environment & Social Performance Report – Tata Ultra Mega Coal Fired Power Plant, Mundra

Period: April 2010 to March 2011

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 Background ............................................................................................................................. 1

1.2 Objective ................................................................................................................................. 1

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

2.1 ESPR Preparer ........................................................................................................................ 2

2.2 Environmental & Social Responsibility .................................................................................. 2

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

Implementation ................................................................................................................................... 3

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

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

4 Environmental and Social Progress of Project Underway ................................................ 14

5 Summary of Safety Performance and any Corrective Action .......................................... 19

List of Annexure

Annexure 1: EHSS Compliance Details ............................................................................................... 21

Annual Environmental & Social Performance Report (FY 10-11) – CGPL Power Plant, Mundra

August 2011 1 SENES

QUARTERLY ENVIRONMENTAL AND SOCIAL PERFORMANCE

REPORT

(ESPR)

Reporting Period: April 2010 to March 2011

EPSR Completion Date: August 2011

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.

Objective

The purpose of this Annual 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


August 2011 2 SENES

2 Environmental & Social Management

ESPR Preparer

Report prepared by: SENES Consultants India Pvt. Ltd.

Telephone: 022-27576298 / 32986995

E-mail: [email protected] / [email protected] / [email protected]

Signature:

Report Date: August 2011

Environmental & Social Responsibility

For the period 2010-11 in

view of the project

operations and development

and implementation of

Corporate Sustainability

Framework there has been

augmentation in managerial

staffing at both CGPL

corporate and onsite office

through deployment of

Head O&M and CSR, Head

Corporate CR and Chief

Manager – CSR & PR. The

HSE department continues

to successfully operate with

its present staff strength

which was augmented

during the year 2009-10.

The organogram

highlighting the current

staffing of the CSR

department along with

representation of forging

partnership and Community

Resource Facilitator (CRF)

is provided in the chart

below.


August 2011 3 SENES

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

As discussed in the earlier ESPR 2009-10 considerable improvements have been

demonstrated by CGPL towards management of onsite safety risks through effective

engagement with contractors and deployment of qualified HSE personnel. This has been

further supplemented through proper implementation of focused safety initiatives (Safety

Time Out, Parenting Scheme, Safety Bulletin etc), maintaining close communication with the

contractor workers, organizing safety training and awareness programs, incident reporting,

visual aids, etc. CGPL has successfully utilized the expert services of AKAAR – an NGO in

continued improvement of safety awareness onsite through induced behavioral change in

contract workers. Adequate measures have also been taken to monitor worker health including

female workers through health surveillance programs.

With the gradual transition of project from construction to operations stage proactive efforts

being made by CGPL towards management of risks associated with the transition phase

through safety review, implementation of PSUR checklist, carrying out external safety audit

through expert agencies, isolation of operations area and regularization of hand over

approvals. However it is required that CGPL identifies and evaluates the project safety risks

associated particularly with this phase to ensure effective management.

As during construction the Environmental Performance Indicators (EPI) for project

operations to be established and incorporated as part of the EMP developed for operations

stage. Further it is recommended that CGPL develops and implement an Environmental

Action Plan to cater to any deviations observed in the baseline environmental quality as part

of continued environmental monitoring being undertaken. It is also suggested that CGPL

carries out detailed assessment of cumulative environmental risks considering the presence of

Adani Power TPP and related industries in the region.

3 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.


August 2011 4 SENES

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. Further CGPL has also

obtained EC from MoEF for expansion of the proposed project to 4150 MW.

Sl.

No Regulatory Approval Conditions Compliance Status

Applicable EC conditions

1 Preparation of Comprehensive EIA based on full

one year data and submission to MoEF

Done

2 Installation of FGD (Flue Gas Desulphurization)

unit, in case the Sulphur content in coal is to ever

exceed 1% or the CEIA based air quality modeling

indicates a GLC exceeding 80 μg/m3 of SO2 at any

location in the impact zone

Space allocation of FGD and technical

specification is found to be in line with the

project requirement and plans

3 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:

Finalize mode (open/closed channel) of water

withdrawal, intake & outfall locations

Protect sensitive coastal & marine environment

Ensure that the project activity does not affect

the flow, hydraulic and thermal regimes

A plan determining the generation and disposal of

capital & maintenance dredging shall be submitted

to MoEF and abide by directions given on dredging

aspects of the operations

CGPL has undertaken an assessment of it‟s

project‟s impacts on coastal & marine

environment, to represent the changes in

intake & outfall locations and also the

external coal handling & conveyance

systems. CRZ clearance obtained and it‟s

modification is in progress, detailed

provisions will be assessed in further

sections.

Dredging has been primarily assessed to be

beyond CGPL‟s scope and a minor part of

large-scale dredging. However a dredging

plan comprising of dredge material

quantification and disposal details have

been prepared.

4 Reconciliation of land requirement for the project

as part of land acquisition procedure and no

landfilling of the site to be carried out

Reconciliation done and the project have

been preliminarily assessed not to have

included any landfilling from external

sourcing.

5 The following equipment / measures control to be

provided as part of the project:

Flue stacks of 275m height

High efficiency (>99.9%) ESP to ensure

PM<100mg/Nm3

Low NOx burners

Dust extraction & suppression systems (such as

bag filters, water spray systems) in dusty areas

(such as coal & ash handling, transfer areas)

Ash pond with impervious lining, for disposal

Provision of these measures has been

planned and progress documented in the

quarterly audit reports of the project. The

same will continue to be assessed in the

future audits.

First aid provision at the medical centre and

sanitation arrangement at the labor camp

was found to be adequate.


August 2011 5 SENES

Sl.


of unutilized fly ash in the form of HCS

First-aid & sanitation arrangement for drivers

and other contract workers, during construction

phase

6 The following conservation measures to be

provided:

Rain water harvesting (scheme to be prepared &

submitted)

Green-belt around plant, ash pond and township

site covering 1/3rd of total project area

Mangrove development

Green belt development for the project has

been initiated through INTACH and

considerable visible progress has been

documented in this regard. As part of the

plan a total of 20000 saplings have been

planted for the year 2010-11.

Approval of Rain Water Harvesting Plan

from CGWB pending.

The “Mangrove Afforestation Program”

undertaken by CGPL in collaboration with

Gujarat Ecological Commission (GEC) has

been effectively implemented in nearly

about 500 ha land in the coastal village of

Kantiyajal, Bharuch district.

7 Monitoring of ambient air environment A continuous ambient air quality

monitoring station has been commissioned

by CGPL at the site office and is in

operation from April‟10 onwards. Further

monthly monitoring of baseline

environmental is being carried out through

an external agency.

Forest Clearance

7 Overall status In-principle clearance obtained from MoEF,

for diversion of 130 ha of forest land. Non-

forest 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

eventualities that may arise during construction

The Emergency & Disaster Management

Plan (EDMP) prepared by CGPL have been

reviewed and found to be adequate with the

project needs.

9 To meet the water requirements during

construction, groundwater shall not be tapped in

any case

Although assessment did not reveal

groundwater tapping within the project

area, but ground water sourcing from local

community areas is still being practiced. As

recommended earlier CGPL to ensure

controlled sourcing of water from these

areas and identify suitable alternatives viz.


August 2011 6 SENES

Sl.


scheduled operation of Desalination Plant

and securing fast track clearance of Rain

Water Harvesting Plan.

11 Provisions for protection of coastal environment

from:

Construction labour – by locating construction

camps outside CRZ area, and providing

sanitation, water supply & fuel amenities

Disposal of debris, sewage generated during

construction – removed and disposed as per

GPCB guidance

Usage of CRZ areas has been assessed to be

beyond CGPL‟s scope and a minor part of

large-scale CRZ use by a different

developer (Adani). SENES has assessed a

very limited portion nearby CRZ areas but

however recommends due-diligence to be

undertaken as well as a much stricter

control to prevent misuse of adjacent CRZ

area.

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 CGPL‟s 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.

Compliance with Safeguard Requirements including the Environmental Management Plan

and the Social Management Plan

This section intends to describe current compliance of the project with IFC/ADB‟s

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 2010 to March 2011) have been assessed

with respect to IFC/ADB‟s environmental & social policies, guidelines and standards and

EHSS compliance to the same has been provided in Annexure 1.

In line with the recommendation made during earlier audit CGPL has installed and

successfully operating a continuous air quality monitoring system onsite from Apr‟10

onwards.

Review of primary air quality monitoring for the period indicated high SPM and RPM levels

exceeding the National Ambient Air Quality Standards (NAAQS). Day time and night time


August 2011 7 SENES

noise levels recorded at the nearby project villages (Tunda, Vandh etc) also exhibited

exceedance to both day and night time noise standards specified for residential area. Further

with the operation of the project and nearby industrial units (Adani) cumulative impacts on

air and noise quality is quite likely. Hence it is recommended that the operations EMP

prepared be reviewed and upgraded in light of the deviations observed/recorded through

environmental monitoring undertaken during operations. It is also recommended that specific

EPIs be defined and incorporated in the EMP to monitor environmental performance during

operations stage.

The Environmental Monitoring Plan for both construction and operations to be revised in

accordance with NAAQS 2009 to incorporate PM10 and PM2.5 as the air pollutant parameter.

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 needs assessment

1 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.


August 2011 8 SENES

Livelihood opportunities and market linkages

Community Development Program (being formulated)

Stakeholder Engagement Framework

Grievance Redress Procedure

Labor Influx Management Plan

Presently both the labor camps are providing accommodation to approx 6000-7000 nos.

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

however with the gradual transition of the project towards operations a possible decrease in

their numbers is envisaged. Disease exposure, natural resource depletion and increase of

supporting economic activities are the primary anticipated impacts due to labor influx.

Disease Exposure

Continued improvement has been demonstrated by CGPL in worker health management

through practice of regular health checkups and proper maintenance of medical records of

contractor workforces. All new workers are subjected to mandatory health check prior to their

operations onsite. Further a medical centre is operational at the labor camp headed by an

experienced doctor and paramedic to cater to the health related ailments of the residing

workforce. Additionally awareness campaigns and programs are being organized on a

periodic basis at the camps by the CGPL medical team to sensitize the workforce on the

vector borne and communicable diseases. Also in view of the female workforce residing at

the camp adequate medical support on child and maternal health care is being provided by a

visiting lady doctor every week.

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. As discussed during earlier audit the ground water is

continued to be sourced (approx 550 KLD) to cater to domestic water requirements of labor

camps given the irregularities associated with Narmada Water Supply Scheme. With gradual

transition of the project towards operations the primary requirement of water is observed at

the labor camps. Hence in anticipation that the labor camps is likely to be operational over

the next 2 years it is imperative that CGPL put in place appropriate management measures

viz. scheduled operation of Desalination Plan and fast track approval of rain water harvesting

plan to regulate ground water sourcing.

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


August 2011 9 SENES

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.

Women as a group were not included as part of the decision making process in the villages

due to prevalent cultural and social practices. They felt that their concerns regarding

employment and development programmmes were largely ignored by the village leaders. As

they were not able to raise their concerns in village meetings or joint meetings with CGPL

officials due to existing social and cultural norms, it has limited their ability to resolve their

concerns effectively. CGPL has attempted to resolve this by organizing separate meetings

with women during visits by senior officials. Such meetings should be continued and any

such resentment from a significant group should be avoided with regard to hiring and local

purchase.

Employing locals in construction activity

The village committee or Sarpanch 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

are working for CGPL. The list is matched with the list provided by Sarpanch according the

skill requirement and the particular persons are contacted for the jobs.

As power is centralized with the Sarpanch to identify persons for list of jobs with CGPL it is

a person or individual centric process which will be largely subjected to the internal dynamics

of the village. Therefore, a more objective system needs to gradually be introduced in order

to make the system more objective so that persons vulnerable or marginalized due to caste,

religion, gender or political affiliation have an equal opportunity to access jobs in CGPL.

Database of PAPs being maintained by CGPL should be used to identify persons for jobs

based on the requirements and availability of such persons from among the PAPs and their

families. This should be prioritized based on income category and the vulnerability of the

family.


August 2011 10 SENES

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.

Temporary shops can also be allocated to SHG groups on a rotational basis for sale prepared

snacks and beverages. This will help the women develop entrepreneurship skills and

experience for income generation. Catering services can also be explored for SHG members

which can be operated from their homes with only a contact point and delivery centre being

available at a decided venue.

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.

PAPs in local hiring and purchase plan

The CSR activity though proactively is targeting many areas, still lacks 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.

A list PAPs has is reported to have now been prepared and database of PAPs socio economic

status being maintained. This would be verified in sub sequent audits, along with inputs from

successive studies to track changes in their socio-economic status.

Community Need Assessment

The Community Need Assessment study based on which CSR interventions were

implemented, identified following components to be addressed. A brief mention of all such

activities carried out is given below:

Water supply – RO plant at Tunda village and school has been set up.

Sanitation –While interacting with women self help group the need for sanitation facility was

felt. The need was addressed by associating with Government of India‟s 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. 200 units were provided

till March 2011 and 90 more units till August 2011. Women reported that the units were in

use, with the only problem being that water requirement was more. Most of the toilets were

kept locked by the families to maintain hygiene.



Community and Reproductive Health – Disease centric health camps were organised - (a)

Vaccination (b) Eye camp (c) Dental camp (d) General Camps (e) Medical Checkup-Cancer

(f) Haemoglobin checkup.

Transportation and Connectivity – One kilometer of village road was concretized.

Education – 3 Learning stations placed in 3 schools, 2 are in process. 625 Kit distribution in "

Kanya Kelavani", English classes initiated. Training of teachers initiated. Promotion of

cultural heritage „lok dayro‟ has also been initiated for community mobilization and

generating awareness. Non Formal education has been commenced in Tragadi for

adolescents.

Water troughs and animal shelters – Daily fodder supply, Boundary wall construction work

has been completed. A Master plan has been developed and shared with community. Cattle

feed sales centre have been planned for Nana Bhadiya and Targadi.

Veterinary Services –Health camps for cattle, training for basic care of cattle for owners,

exposure visit for cattle owners.

Infrastructure Provided, Repair and Renovation of Common property resources – This work is

carried out as and when there is a demand. Community halls for villages, boundary walls for

Cremation grounds, classrooms, boundary wall and sanitation unit for schools, development

of gardens for children, construction of anganwadis, cricket ground and stadium, roads have

been constructed or in the process of being constructed. Villagers are using these community

halls for organizing weddings, meetings, community feasts etc. some of the structures

provided are also used for rain harvesting.

Water Resources – Under Natural Resources Management NRM, the following activities

have been initiated post March 2011. Well Recharging, check dam, pond renovation and farm

bunding for water harvesting. Some of the infrastructure provided also includes rainwater

harvesting.

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. Area Status & activities undertaken by CGPL

1 Entrepreneurship iLead training program initiative needs to be now redefined, as

detailed in the previous annual report

2 Agriculture

Development

Demonstration for Drip irrigation and horticulture has commenced.

3 Dairy Cooperative Is initiated at Tragadi with 33 members through cooperative,

Convergence support from Kutch Milk Marketing Cooperative



Sl.

No. Area Status & activities undertaken by CGPL

Society (Sarhad Dairy) provided. Initial collection has been more

than 270 litres.

4 SHG Self Help Groups formed within the villages. They are meeting

regularly. Through a tie up with Vivekanad Rural Training

Institute tie and dye training has been initiated. Embroidery

cluster has also commenced.

5 Vermi-compost Has been planned for Nana Bhadiya. This would be largely for

local use.

6 Bio Gas Plant Has been planned for Nana Bhadiya

7 Market linkage

augmentation for

handicrafts

Milk is sent to nearby chilling centre at Bidra from the

collection centre. For Bandhini after the training, it would be

linked with VGS and the labour charge which is normally

Rs.13-14 for Bandhini but now it would be Rs.25/- per piece.

Raw materials will be provided by VGS. Other buyers would

also be contacted

Community Development Plan

One of the promised submittals the Community Development Plan is not ready yet. In the

meantime based on the community needs and demands and the current social and economic

situation as well earlier identified issues discussed with affected communities and people,

activities (mentioned above) have been initiated encompassing health, education, livestock

and CPR.

GRC

The following Grievances Redressal Cell has been formed as mentioned below:

The composition of GRC is

Head of Site

Head (O&M)

Finance (2 members),

HR (2 members),

CSR (2 members),

Admin

Security



The GRC main responsibility is for grievance redressal. Grievances are also addressed by

various departments and officials interaction with affected communities and individuals. The

GRC is for addressing larger issues which cannot be addressed at the field level and which

have the potential for becoming group or collective grievances. Grievances are registered and

maintained currently by the CSR department.

Sustainability Cell

The composition of the Sustainability Cell is as follows:

Head – O&M

DGM - HR

General Manager – Safety

Chief Manager – Security

Chief Manager Admin

Manager Environment

Senior Manager Chemical

Member Operation

Member CSR Sh. S Sharma

The roles of the cell and the channel of communication is currently not assessed and therefore

its importance and contribution to social management, visions for social development its

implementation cannot be ascertained.

Communication and Information Centre CIC

CGPL also proposes to set up a Communication and information centre CIC to disseminate

information and inform the status of grievances, suggestion etc to the people. It proposes to

be the connecting link between affected people and communities and CGPL officials across

all departments.

Interdepartmental Committee

An interdepartmental Committee has been formulated for addressing issues relating to risks

and their mitigation, grievances, communication with affected communities, crisis

management and risk mitigation and other concerns. It is scheduled monthly but is held for

special purposes also apart from routine meeting viz. Meeting HR, Finance, Security,

Purchase and Civil under the chairmanship of Head (O&M and CR).

Stakeholder Engagement Framework

A Stakeholder Engagement framework has been formulated by CGPL that identifies

stakeholder categories, prioritization of stakeholders based on physical proximity, project

impact and criticality. A Participatory Consultation Mechanism has been developed for

continued participation at project stages of planning and implementation. This framework

could not however be yet assessed, and will be done in subsequent audits.



Environmental and Social Progress of Project Underway

It is understood based on discussions, site observations and review of project progress

documents that the actual progress stands 75.26% against an early schedule of 92.59% and

late schedule of 77.80%. Formalities for land acquisition and transfer of land titles to CGPL

continued. Major engineering is completed and all packages awarded with materials‟ delivery

continuing. A summary progress of current project activities is listed herewith:

All 98 packages awarded. Procurement shortfall attributed to deferment of deliveries

due to non-availability of erection fronts.

Boiler Area – Boiler#30 hydrotest activities initiated with Boiler pressure parts‟

erection in Unit# 40 and 50 in progress along with structural erection in ESP Unit#30,

40 & 50. Unit#20 auxiliary steam piping hydrotest completed and CCCW system

hydrotest commenced.

TGB Area - All HP Piping erection and pre-commissioning works completed for

Unit#10, with steam blowing preparations is in progress. TG#10 STG turning gear

operation successfully completed. Generator air leak test completed and CEP#1 & 2

run on recirculation mode. BFP-A & B final alignment completed with U#30, 40 and

50 Deaerator erected.

External Linkages – Jetty is commissioned and first coal shipment unloading

completed on March‟11. 3 charter party contracts signed for supply of coal with 2

super capes vessels ordered on M/s STX, Korea; power evacuation work in progress

by PGCIL along Mundra – Bhachau – Vadavi, Mundra – Surajbari – Limbdi, Mundra

- Surajbari – Jetpur and Gandhar – Navsari transmission routes.

BOP Area – Civil & structural erection works for Internal Coal Handling System

(ICHS) completed except in Tunda-Vandh road area. Reclaimer-A & stacker cum re-

claimer-A erection work in progress. Belt laying & conveyor sheeting work is in

progress. Stacker cum Reclaimer for ECHS powered with work for Ash Handling

System (AHS) is in progress by respective vendors/contractors; concreting work of

CW intake channel completed with concreting of outfall channel is in advance stage

of completion. CW forebay charging completed.

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 project‟s marine

components with that of the adjacent Adani Power facility

External coal conveyance system from railway to conveyor.



Further the Gazette Notification for Tunda –Vandh road closure issued by Gujarat Govt. on

Mar‟11 (already identified earlier as part of project design and planning) is also likely to have

certain social implications.

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:

A. Environment

Taking into account the gradual transition of the project from construction to

operations it is recommended that adequate efforts are made towards developing and

implementing an Environmental Action Plan to address any unprecedented

changes/deviations, if any recorded as part of periodic and continued environment

monitoring. This is considered to be effective in enhancing CGPL preparedness

towards prevention and mitigation of potential significant impacts at an early stage of

project operations.

Continual improvement in project waste management demonstrated by CGPL with

miscellaneous waste (viz. plastic, gloves etc) also now being recycled along with

major recyclables (wood and metal) by selected vendor. In view of potential health

risks associated with indiscriminate disposal of labor camp waste efforts made by

CGPL towards solid waste management through provision of adequate labeled &

colored waste bins at labor camps along with implementation of awareness programs

by AAKAR – an NGO. However waste segregation at source still remains an area of

concern at camps and requires focused efforts by CGPL through frequent

implementation of awareness programs and continued supervision to induce

behavioural change in camp residents. Based on the feasibility study a biogas plant is

also planned to be commissioned and operated at the proposed CGPL colony for

which LoI has been issued to a competent agency.

Efforts are being made towards improvement of STP performance through proper

chemical dosing, sludge drying and recycling, improved housekeeping etc. However

the engagement of competent O&M personnel to be continued along with periodic

supervision by CGPL personnel to ensure effective functioning of STP.

Appreciable efforts have been demonstrated by CGPL with respect to green belt

development and water conservation. In this regard efforts have been made by CGPL

in utilizing the excess treated STP water (to prevent water logging vacant plot near

STP) in developing the pits within the green belt area as “man-made ponds”. The

ponds are being utilized for pisciculture activities and also likely to serve as foraging

and nesting areas for local birds thereby serving as potential eco-restoration zones.

The “Mangrove Afforestation Program” undertaken by CGPL in collaboration with

Gujarat Ecological Commission (GEC) and Kantiyajal Tavar Vikas Samiti (KTVS)



during Oct‟10 has been effectively implemented in nearly about 500 ha land in the

coastal village of Kantiyajal, Bharuch district. Nearly about 600000 nos. saplings of

Avicennia sp encompassing 300 ha of land have been planted by KTVS with a

reported survival rate of 75%.

Continued consumption of ground water to meet domestic water demand (approx 550

KLD) at labor colonies over the next two years coupled with uncertainties

experienced with respect to Narmada water supply may possibly lead to significant

impact on local ground water resources in near future. Although CGPL has planned

initiatives for replenishment of ground water resources in the region through rain

water harvesting/recharge structure, proactive efforts are required to link the ground

water consumption/sourcing to desalination plant operation to address this potential

impact at an early stage. Further necessary efforts need to be made by CGPL to secure

approval of the Rain Water Harvesting Plan from CGWB on a fast tract basis.

Potential safety risks reported during earlier audits on domesticated animals and

nearby villagers from straying within the site restricted area have been effectively

controlled through proper enforcement of onsite security and maintaining adequate

surveillance at all entry and exit point locations.

Focused biodiversity survey is under progress by the Bombay Natural History Society

(BNHS) along the Mandvi-Mundra coast near the project outfall channel to establish

the coastal and marine floral and faunal biodiversity. However based on the aforesaid

study findings it is recommended that CGPL formulate and implements a Coastal

Biodiversity Management Plan to mitigate the identified impacts.

B. Social

Achievements

Some of the remarkable achievements of CGPL‟s social action plan are as follows.

PAP list has been finalized.

Fodder supply: Fodder supply to the villager‟s 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 campaign‟s effectiveness was enhanced

by ensuring CGPL and villager‟s contribution.

Setting up of RO plant and focus on clean drinking water at the village and

community level.

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.



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.

Local Service/business Opportunities: CGPL has continued providing business

opportunities to locals through shops on site and small contracts.

Stakeholder Engagement: Effective stakeholder engagement has continued and some

new stakeholders have been identified with respect to project implementation

progress, which whom consultations are underway.

Risk Mitigation/Crisis Management: CSR department is playing a critical role in

identifying issues and stakeholders related to construction, resolving conflicts, discord

and disagreements with the communities. It is also the key liaisoning and

communication link between the various departments of the company with the

communities and affected villages.

Capacity building of various members to enable them to reach their potential in

activities aimed for their development or livelihood.

Dairy program has been initiated in one village.

Way ahead

Freezing the PAPs list as final and list the entitlements for each family/person as PAP.

A supplementary list also needs to be prepared for families indirectly affected from

loss of common property resources and private & government land, encroachers and

vulnerable groups mainly persons affected due to loss of livelihood /CPR or being

landless. Specific services such as health, education, pension (if unable or incapable

of work) etc including focused CSR activities also need to be extended to the

aforesaid groups.

Database prepared for PAPs should be linked to the Purchase and Hiring Plan and the

requirements of CGPL. If requirements are not met from among the PAPs then only

should the requirements be met through the open market. According to the last annual

report submitted by SENES the proportion of benefited PAPs was about 30 percent

which is low considering that direct and indirect employment opportunities in the

construction period tends to be higher. Linking the database to departmental

requirement for manpower creates a pool which assures that first preference is

extended to PAPs thereby increasing the benefitted PAPs.

Earlier prepared documents mainly the Stakeholder Engagement policy, RP (See

GRC in both the documents) needs to be updated and modified to reflect the current

required need and the prevalent practice.

For example the RP suggests a mechanism for GRC at two levels. This can be

implemented or modified and institutionalized in the operation phase. Although

currently a mechanism exists, it needs to be institutionalized to ensure effective



implementation of the grievance management system. A document should be

prepared on current functioning and delegation of responsibilities to address

grievances, along with a consolidated statement of action taken, closure, responsible

officer & department and timeline for resolving grievances received in the last two

years. With documentation of grievances it will be possible to locate, predict and to

address individual and group grievances in a more effective and preventive manner.

Risk Mitigation Plan is required considering the current construction phase. Social,

economic and cultural concerns are likely to come up with the progress in

construction and as plans are modified to accommodate mandatory requirements or

minimize risks. A holistic and integrated Action plan needs to be prepared in the light

of identification of any unanticipated risks that have come up as a result of alteration

of earlier designs and plans. The RMP will include two components. The first one is

basically to mitigate the risks which is likely to be mandatory in the context of

displacement, impact of livelihoods and vulnerable communities etc. The second is

more in the context of extending development programmes under CSR which has

been extended to all affected villages or forming a CDP to meet the development

needs of specific communities. Once a RMP is approved, CSR activities can be

clubbed for execution under CSR.

Strongly recommend planning of CSR activities in close coordination with village

communities in order to finalize on the community demands and to maintain

transparency in the planning and implementation of CSR activities for each village.

Mechanism needs to be established for monitoring, motivating and evaluating

effectiveness of implementation of activities by NGO. The mechanism should also

bring in more clarity to differentiate the role of NGO and the ground level CSR staff,

as there is an obvious overlap of roles especially with respect to dealing with the

intended beneficiaries. While the current roles of the staff are more towards carrying

out or conducting activities some additional inputs from the staff on specific

requirements of programs or individuals need to be captured. For example, under the

Guashala/animal husbandry program additional inputs regarding stall feeding, diary

development, by products that can be used as fodder, supplementary nutrition for

cattle to increase milk production, biogas to meet part of the fuel or energy

requirements of families, etc.

Vermi-compost and bio gas plant have been planned as stand alone programs. These

need to be linked to the current cattle feed program for various villages to enhance

benefits emerging from the fodder program.

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. Documenting is key to estimating the nature of impact of CSR activities and

for enquiring into the nature of change that has occurred within the targeted area. In

the absence of documentation it will also be difficult to showcase successful



initiatives that are handed over to the village, community or group. Therefore there

is requirement that all CSR activities undertaken be documented properly in order to

record, monitor all aspects of planning, implementation and nature of impact.

4 Summary of Safety Performance and any Corrective Action

The project has towards the end of the reporting period, clocked around 42.1 million man-

hours with 5 fatalities and 21 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 2010 to Mar 2011)

Sl.No Performance Indicators

Reporting Period

Apr-Jun

2010

Jul – Sep

2010

Oct-Dec

2010

Jan-Mar

2011

1 Induction Training - Attendees 8260 13061 10132 11454

2 LTIs 5 2 9 5

3 First Aid Cases 345 412 517 770

4 Medical Treatment Cases (MTC) 5 2 11 11

5 Safe Man Hours Worked

(till last fatality) 4080342 7989832 940760

7545716

6 Total Person Hours Worked 8331632 10728992 11367920 11722300

7

LTI Frequency Rate Apr-1.00

May-0.72

June-0.00

Jul-0.00

Aug-0.26

Sep- 0.28

Oct-0.27

Nov-1.10

Dec-0.98

Jan-1.00

Feb-0.00

Mar-0.25

8

Severity Index Apr-2.89

May-3.13

June-3.15

Jul-2.92

Aug-3.12

Sep- 3.08

Oct-3.10

Nov-3.14

Dec-3.24

Jan-2.77

Feb-2.78

Mar-2.73

9 Fire Cases 6 32 39 23

10 Near Misses 168 265 279 243

11 Fatality 3 1 1 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:

CGPL has successfully utilized the expertise of AKAAR – an NGO to drive safety

awareness among site workers through spiritual motivation thereby inducing a

positive behavioural change. Further additional initiatives have been taken by CGPL

in improving safety performance onsite through development and implementation of

various programs viz. Parenting Scheme, Safety Time Out etc and circulation of

periodic safety bulletin viz. Safety Flash. Imposing penalties on contractors on event



of any safety non-conformances being reported was also found to be effective in

managing project safety risks.

With project gradually undergoing transition from construction phase to operations

safety accidents viz. flashovers from poor electrical modules, fall during mechanical

erection works etc have been reported. Necessary preventive and corrective

actions/initiatives are being taken by CGPL viz. safety review of electrical modules;

provision of insulated safety coveralls; implementation of pre-start up review (PSUR)

checklist; utilizing the services of ICRA for undertaking electrical audits; isolation of

operations area and regularization of hand over approvals to address such safety

concerns. However it is recommended that CGPL adequate efforts in identifying the

risks associated with the transition and operations stage and enhance the awareness of

contractors/sub-contractor manpower on the same to mediate an effective response.

Potential increase in safety risks are anticipated for CGPL employees resulting from

the heavy vehicular movement along the Mundra-Gandhidham/Bhuj road and increase

in travel frequency of CGPL employees with project progressing towards operations.

CGPL is striving towards addressing the aforesaid risks through construction of

township/colony at Mundra, maintenance of vehicular safety norms, training on

safe/defensive driving etc. In this regard it is essential that CGPL further assess the

mitigation plans/measures being formulated to establish its reassurance and make

adequate efforts towards completion of the onsite CGPL colony on a fast track basis.

With the housekeeping contract being finalized with a third party vendor considerable

visible improvement has been demonstrated by CGPL with respect to workplace

housekeeping. Further CGPL have also constructed an onsite waste management yard

for temporary storage of segregated recyclables to prevent littering and unauthorized

access. It is recommended that CGPL continues with its positive efforts towards

effectively managing the waste generated from work place activities.

Provision of drinking water tanks has been regularized throughout the site and

portable toilets been made functional to cater to the sanitation needs of the onsite

workers.

In accordance with the earlier audit recommendation provision of adequate fire

fighting arrangements have been regularized for both the camps. New labor camp

made operational presently having an occupancy level of approx 2700 nos. workers

with the discontinuation of the make shift camp under progress. Additionally

recreation facilities viz. library, crèche and volleyball grounds have also been

provided at the labor camp as part of the worker recreation initiative by CGPL.

Malaria was found to be prevalent among the labor camp workforce during monsoon.

However necessary malarial control measures have been implemented by CGPL

through distribution of medicines, use of larvicidal sprays in the camps and provision

of mosquito repellants to the camp residents and are being implemented throughout

the year as a preventive measure.


July 2010 21 SENES

Annexure 1: EHSS Compliance Details

Issue

No Description

Status

(New/Old) Assessment Recommendation Priority Compliance Status

Social & Environmental Assessment & Management System

1 Social and Environment

assessment

Old 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 lender‟s queries on the

assessment primarily relating to

additional environmental considerations

(such as cumulative impacts)

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 Adani‟s

environmental performance, it is

now recommended that

sufficient awareness of

regulatory developments and

compliance exists, with

information available in public

domain.

2 Management Program Old The environment and social action plan

prepared in November, 07 has been

assessed to identify actions required to

comply with lender‟s 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.

Need of development of a separate

dredge disposal plan required to be

assessed, as identified in the ESAP

Medium Dredging has been primarily

assessed to be beyond CGPL‟s

scope and a minor part of large-

scale dredging. However a

dredging plan comprising of

dredge material quantification

and disposal details have been

prepared in accordance to the

EC condition.

3 Organizational capacity

Old 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

Reassessment of planned staffing as

well as urgently executing the plans,

particularly for the health and

environment functions

High 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.

Further a Head Corporate – CR

(based at CGPL office) and a



Issue

No Description

Status


Chief Manager – CSR & PR

based onsite has been deployed

to strengthen the CGPL onsite

CSR department.

4 Training Old Assessed to be sufficient in general, with

clear gaps on travel safety, waste

management, spill prevention & control

Fulfill assessed training gaps and

prepare specific training plans on

health, labour hygiene and onsite

environment management

High Specific training plans

developed and presently being

implemented onsite.

5 Community Engagement Old Assessed to be sufficient and effective Sustain with project progress Medium

Labor & Working Conditions

8 Human Resource Policy Old Assessed to be generally in compliance

with all the standards relating working

conditions and worker relationship

management

Sustain with project progress High

Working Relationship

Working conditions and

terms of employment

Worker‟s Organization

Non-discrimination and

equal opportunity

Retrenchment

Grievance mechanism

Child Labour

Forced Labour



Issue

No Description

Status


9 Occupational Health &

Safety

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/defensive driving training

to address travel safety needs.

However it is essential that

CGPL further assess the

mitigation plans/measures being

formulated to establish its

reassurance and make adequate

efforts towards completion of

the onsite CGPL colony on a

fast track basis to minimize

travel requirements of project

staff.

10 Old PPEs, rest rooms, safety induction,

potable drinking water, being provided at

the work site

Provide enhance dust control measures

especially in batching plant, blasting

and paint shop areas

Medium With mechanical and electrical

works currently under progress

potential air quality impacts

from batching plant and blasting

operations appears to be limited.

11 Mobile toilets to be provided at

locations with considerable workers

presence

Medium Provision of drinking water and

mobile sanitation facilities

regularized onsite.

12 Sustain PPE usage in critical areas,

enhance safety awareness and specific

attention on compatible PPE usages on

site

Medium PPE usage among workers has

been observed to be extensive

and satisfactory. Safety signs

and posters have been displayed

in critical project operational

areas.

13 Current man power allocation to drive

basic safety provision and monitor

Medium Augmentation of HSE staff

initiated by CGPL through



Issue

No Description

Status


occupational health concerns requires

staff strengthening on priority basis and

as already identified by CGPL

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.

14 Old 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 Integration of CGPL‟s safety

plans; procedures and

performance indicators with that

of the project contractor (M/s

DOOSAN) have been complied

with and to be sustained along

with project progress.

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 New labor camp made

operational presently having an

occupancy level of approx 2700

nos. workers with the

discontinuation of the make

shift camp under progress.

Additionally recreation facilities

viz. library, crèche and

volleyball grounds have also

been provided at the labor camp

as part of the worker recreation

initiative by CGPL.

16 Supply Chain Old No specific need assessed - - -



Issue

No Description

Status


Pollution Prevention and Abatement

17 General Requirements Old Design stage pollution prevention &

abatement measures shall be assessed

during subsequent audits

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.

High -

18 Pollution prevention,

resource conservation

and energy efficiency

Old No specific water resource conservation

practices or procedures are evident

during the current construction stage

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

High Reuse of treated STP water for

green belt development has

been put in practice by CGPL.

Further the excess treated water

is being reused in the

development of “man-made

ponds” within the green belt

area – an eco-restoration

initiative of CGPL.

19 New Review of data obtained through periodic

air quality monitoring revealed

inconsistencies

Continuous ambient air quality

monitoring station to be installed and

operated onsite in view of robust data

needs

Medium Continuous air quality

monitoring station is being

operated by CGPL from Apr‟10

onwards.



Issue

No Description

Status


20 Wastes Old 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

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

waste water

High Contracting of housekeeping

services has led to considerable

improvement in workplace solid

waste management. Further an

onsite waste management yard

has been constructed for

temporary storage of segregated

recyclables to prevent littering

and unauthorized access.

However management of food

waste generated from camps

still remains an area of concern

and requires focused efforts by

CGPL through frequent

implementation of awareness

programs and continued

supervision. Based on the

feasibility study a biogas plant

is also planned to be

commissioned and operated at

the proposed CGPL colony for

which LoI has been issued to a

competent agency.

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 Measures taken with respect to

spill prevention and control at

fuel and lubricant storage areas

were found to be insignificant.

However CGPL need to

continue with the specific

worker training programs

developed on spill prevention

and control.



Issue

No Description

Status


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 The Emergency Response &

Disaster Management Plan has

been reviewed and was found to

be in commensurate with the

project associated health and

safety risks. However the

contact details of Emergency

Response Team need to be

periodically updated.

Community Health, Safety & Security

23 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 Continued ground water

sourcing from nearby villages

still remains an area of concern.

Additional thrust required from

CGPL in addressing the same

through scheduled operation of

Desalination Plan and obtaining

fast track approval of Rain

Water Harvesting Plan by

CGWB.

Local xerophytic shrubs and

undergrowth is being utilized by

labors as fuelwood to avoid

pressure on natural resources.

24 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



Issue

No Description

Status


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. Further regular

medical check-ups are

undertaken and records being

maintained by CGPL Medical

team for all onsite contractor

workforce.

Land Acquisition & Involuntary Displacement

25 Project design Old No such change in design inducing

involuntary displacement

- - -

26 Consultation Old Regular community consultation being

carried out, method of compensation for

grazing land and related CSR activities

were decided after consultation.

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.

New Risk identification and Mitigation has

become critical due to some components

of design affecting long term CSR

activities. Risk identification and

mitigation requires focused work and

shared responsibilities with various

departments. Risks if addressed only by

CSR is likely to affect long term work.

Involvement of key departments in

identifying risks or potential concerns

likely to result in risks and planning

measures to mitigate risks.

Training of key team consisting of

officials from various departments for

negotiating with communities.

High

27 Grievance Mechanism Old No significant improvement in

documentation on grievance mechanism

The grievance redressal mechanism to

be streamlined and documented, to

avoid potential conflict in future

Medium

28 Economic displacement

Old CGPL provide employment opportunities

through training, site jobs and allotting

Focus on providing such opportunities

to the project affected people

Medium Although CGPL has provided

employment opportunities to



Issue

No Description

Status


shops to the local communities.Income

generation programs initiated including

dairy program, training for self

employment for women and farm

development

recommended

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.

Biodiversity Conservation and Sustainable Natural Resource Management

29 Protection and

conservation of

biodiversity

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 Visible progress has been

witnessed in the green belt

development program (utilizing

indigenous species) being

implemented by INTACH. With

nearly 20000 nos. saplings

being planted for the year 2010-

11. Further efforts being made

by CGPL in developing “man-

made ponds” in the green belt

area through reuse of the excess

treated STP water. The ponds

are to serve as potential eco-

restoration zone providing

habitat for local and migratory

bird species. CGPL is also

implementing a “Mangrove

Afforestation Program”

encompassing approx 1000 ha

area of the coastal village of

Kantiyajal, Bharuch district in

collaboration with Gujarat

Ecological Commission (GEC).

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



Issue

No Description

Status


Cultural Heritage

30 Chance find procedure Old CGPL to formulate and implement

Chance find procedure as part of

construction activities on site to avoid

damage to cultural heritage

Medium