The proposed project components such as i) expansion and modernization of existing plant at Jhagadia; and ii) de-bottlenecking of existing plant and expansion of new units at Jhagadia and Dahej do not require additional land resources as the project will involve a brownfield expansion within existing premises of the respective facilities. The new MPP that is under construction at Jhagadia (21°37'01.7N 73°08'21.0E) is on a ~ 100 acres of designated industrial use, greenfield plot located inside Jhagadia Industrial Estate promoted by Gujarat Industrial Development Corporation (GIDC). The Company purchased the lease hold rights of the vacant industrial plot in 2017-18.

Given that the company's manufacturing facilities at Jhagadia and Dahej are located inside notified industrial zones, there are no risks and impacts on forest resources, sensitive biodiversity areas, Indigenous People and cultural heritage sites as identified and documented in individual, project level environmental and social impact assessment (ESIA) documents. Hence, it is assessed that no risks and impacts are anticipated for this project which must be managed in accordance with PS5: Land Acquisition and Involuntary Resettlement; PS6: Biodiversity Conservation and Sustainable Management of Living Natural Resources; PS7: Indigenous Peoples and PS8: Cultural Heritage.

This is a Category B project as per IFC’s Policy on Environmental and Social Sustainability. Key E&S risks associated with the project include: (a) corporate and facility level E&S management and monitoring systems to manage E&S risks and impacts from its operations as well as those related to expansion of facilities covered under the project; (b) assurance of fair, safe and healthy labour working conditions in compliance to applicable regulations and PS2 requirements including key risks such as occupational health and safety (OHS), process safety, workers engaged by third parties and supply chain; (c) resource efficiency measures (d) monitoring and management of air emissions, hazardous wastes and wastewater; (e) management of hazardous chemicals and materials including monitoring of soil and groundwater quality ; (f) on-site and off-site emergency preparedness and response; (g) consistence of regular maintenance of production facilities in line with good international industry practices (GIIP); (h) community health and safety risks including hazardous materials transport, life & fire safety risks; and (i) the company’s stakeholder engagement activities related to E&S aspects and the effectiveness  of community grievance mechanism.

Company has established an integrated corporate Aarti Management System (AMS) covering its entire business operations including environmental health and safety issues, which is assessed to be commensurate to the nature and scale of the project and the level of its environmental and social (E&S) risks and impacts. The AMS implemented across all AIL operational facilities are certified to ISO 14001:2015 and ISO 45001:2018 Standards. AIL has corporate E&S related policies which are published on its website: https://www.aarti-industries.com. Under the Health, Safety and Environment Policy updated in September 2022, the Company commits to maintain the excellent standards of health, safety, security, human rights, environment protection, product quality and processes while conducting all its business operations, services, and expansion activities.

Identification of risks and impacts: AIL utilizes a compliance monitoring framework using appropriate software tools to identify and track regulatory requirements and compliances applicable to its sites. AIL has established an ESIA process for identifying & documenting the environmental, biodiversity and social risks and impacts of any capital investment project involving expansion, modernization, change in product mix or new greenfield project. The company identifies and manages E&S risks and impacts associated with its operations through compliance with applicable national standards and E&S regulatory permits and standards. In full compliance with national legal requirements, the company obtains prior consents from State Pollution Control Board (SPCB) each before construction (consent to establish) and operational (consent to operate) phases of the project. For the IFC funded sub-projects, Company has completed the Environmental Impact Assessment (EIA) studies along with quantitative risk assessment (QRA) and hazard operability (HAZOP) studies using Indian National Accreditation Board for Education and Training (NABET) accredited EIA Consultants. The studies were completed based on a regulator approved terms of reference (TOR) that are available at concerned regulator websites (Refer to details below).  Applicable E&S related environmental clearances, consents and permits will be obtained in due course of time based on these EIA and other project documents.

Relevant National Regulator Webpage/EIA Link Details

1. Expansion of Ethylation capacities at Dahej - Final Environmental Impact Assessment Report for Proposed Expansion Project of Manufacturing of Synthetic Organic Chemicals at Dahej, Nov 2021

Refer regulator webpage for more details: https://environmentclearance.nic.in/TrackState_proposal.aspx?type=EC&status=EC_new&statename=Gujarat&pno=SIA/GJ/IND3/64482/2021&pid=193148

2. Setting up of Chloro Toluene & derivatives plant at Jhagadia - Environmental Impact Assessment (EIA) & Environmental Management Plan (EMP) for proposed greenfield project of Synthetic Organic Chemicals, Jan 2021

Refer regulator webpage for more details: https://environmentclearance.nic.in/TrackState_proposal.aspx?type=TOR&status=TOR_new&statename=Gujarat&pno=SIA/GJ/IND2/56089/2020&pid=151148

3. Setting up of universal multi-purpose & pilot plants at Jhagadia - Environmental Impact Assessment (EIA) & Environmental Management Plan (EMP) for proposed new project of pesticides and pesticide specific intermediates, Feb 2022

Refer regulator webpage for more details: https://environmentclearance.nic.in/onlinesearchnewrk.aspx?autoid=41764&proposal_no=IA/GJ/IND3/236925/2021&typep=EC

4. Debottlenecking and expansion of existing capacities at Dahej and Jhagadia -

Diamond Division - Final Environmental Impact Assessment Report for proposed expansion project of manufacturing of synthetic organic chemicals, March 2022

Refer regulator webpage for more details:

https://environmentclearance.nic.in/TrackState_proposal.aspx?type=TOR&status=TOR_new&statename=Gujarat&pno=SIA/GJ/IND3/68291/2021&pid=218963

Saffron Division - Environmental Impact Assessment (EIA) & Environmental Management Plan (EMP) for Expansion project, July 2020 https://environmentclearance.nic.in/TrackState_proposal.aspx?type=EC&status=EC_new&statename=Gujarat&pno=SIA/GJ/IND2/55210/2017&pid=121634

Management Program and E&S Organisation: Company has established documented management programs consisting of documented manuals, operational procedures, training management systems, reporting templates, checklists, internal and external audits, monitoring, and reporting mechanisms integrated to its AMS. A Sustainability Council has been established as part of the Board to guide the Company to achieve its short and long -term sustainability goals. The Company manufacturing operations are divided into four Zones based on geographical locations. Each location/site in a zone is further divided into multiple Divisions based on products manufactured or process involved. Each Division has multiple Plants manufacturing different products. Technical and E&S organizational management capacity has been established at Corporate, Zonal, Divisional and Plant levels.  Aligned to AILs management systems, EHS organizational capacity has been instituted at the Manufacturing Pillar with dedicated Environment and Sustainability, Operational safety, and Process safety verticals with competent professionals at corporate, zonal, divisional and plant levels. Besides, for the implementation of sub-projects, organizational capacity is instituted in the form of construction safety and project procurement related supply chain teams at expansion (new projects) pillar.

Emergency preparedness and response: The company has documented emergency preparedness and response plans (EPRP) for each of its facilities and units including Jhagadia and Dahej. EPRPs are reviewed periodically with provisions to review and update after each plan rehearsal or mock drills to take account of any shortcomings. The production zones at Jhagadia and Dahej sites are equipped with appropriate life and fire safety (LFS) passive and active systems, detectors and alarms, emergency control centre (ECC), trained emergency response and management teams in every shift, first aid centre, occupational health centre with in-house ambulance, and multipurpose advanced fire tenders with a dedicated operational team. 

Monitoring & Review: The company has established systems and procedures to monitor and measure the effectiveness of its management program at each plant/unit level, as well as compliance with any related legal/ regulatory requirements on environmental quality and pollution monitoring. Senior management at every level receive periodic performance reviews of the effectiveness of the EHS management system, based on systematic data collection and analysis.

AIL has developed and implemented environmental monitoring program comprising of real-time, continuous pollution/emission monitoring systems that are connected to regulators; in-house environmental lab for monitoring environmental quality; and NABL accredited third party labs as per the EHS monitoring plan. The parameters selected for environmental monitoring are based on the national requirements stipulated in environmental permits granted to the sites. Further, the sites have included risk-based monitoring parameters such as monitoring of chlorine gas and volatile organic compound in the ambient air.

The AMS Manual require internal and external audits of safety systems as an integral part for checking compliance and initiation of improvements. Company has been engaging various national and international level external subject specialists/experts to undertake external process safety audits. Besides the focused thematic audits, Company has also initiated the inter Zonal safety audits and having in plan to hire external auditors to undertake such audits regularly.

AIL monitors soil quality every 6 months in line with national requirements stipulated in environmental permits.  Considering the nature, size and age of site operations involving storage, handling and transport of hazardous chemicals, raw materials and finished products, there is a potential risk of soil contamination. In line with good international industry practices (GIIP), the Company will augment its environmental monitoring program to include soil and groundwater (from existing wells) quality in line with Phase II Environmental Site Assessment (ESA) process as per American Society for Testing and Materials (ASTM) E1903-19 Standards (ESAP #1). The results shall be compared against the national standards or in the absence of such standards, international standards such as the United States Environmental Protection Agency (US EPA) Regional Screening Level (RSLs) and US EPA Regional Removal Management Levels (RMLs). If, based on the soil and groundwater monitoring results, historic pollution is detected, liabilities will be resolved by the company in accordance with the national law, or in the absence of such standards, in accordance with GIIP.  Remediation action plans will be developed, and remedial actions implemented to avoid or minimize significant adverse impacts on human health and the environment. 

As on February 2023, AIL has employed 6200 direct and 7000+ contracted workers across all its operations. Participation of women in AILs workforce increased from less than 1% in FY 2018-19 to approximately 3% during 2022-23. The average employee turnover or attrition rates over the last 3 years is reported around 16%. AIL has formulated and implemented its human resource (HR) People Policy that is applicable to all employees, contractors, suppliers, service providers, and business partners. HR policies and procedures are consistent with the national labour regulations and requirements of IFC PS 2.

AIL has updated and published its HR Codes Manual in Nov 2022 that provides the working conditions and terms of employment covering labour engagement practices and standards which are in line with PS2 requirements and local labour regulations. Company policy and procedures clearly states that: it has zero tolerance towards discrimination and harassment; is an equal opportunity employer; grievance redress mechanism with anonymous provision and accessible to 3rd party contract workers; prevention of sexual harassment (POSH) policy that is applicable to all employees of AIL, including probationer, trainees, apprentices, contract workers, visitors, vendors, and any such person visiting AIL; zero tolerance towards the use of all forms of child labour, forced, trafficked and bonded labour practices; and freedom to associate. Company maintains a harmonious labour relation through constant engagement with staff and workers ensuring no industrial strife or strikes till date. No retrenchment has taken place historically and company follows local regulatory process and directions/standing orders of labour department in the case of “collective dismissals”.

Occupational Health and Safety Management: AIL has established an appropriate Occupational Health and Safety (OHS) and Process Safety Management (PSM) management system. As part of management system, the company has implemented standard operating procedures for each of working position as part of the manufacturing operations and associated ancillary processes which includes providing training to all workers according to the training plan. The Company has also undertaken specialized process safety studies for Jhagadia and Dahej, namely, Hazardous Area Classification; Process Hazard Analysis covering hazard identification (HAZID) and hazard & operability (HAZOP); Layers of protection analysis (LOPA) and Safety integrity levels (SIL) assessment; Fire safe assessments; Quantitative risk assessments (QRA) for hazardous chemicals stored and handled on site including the chemicals that are transported through pipelines from neighbourhood industries at Jhagadia and Dahej; workplace health and hygiene monitoring systems; and combustible dust hazard assessment. The company has also implemented asset integrity management (AIM) system covering inspection, testing and maintenance of safety critical elements. Plant Management has taken appropriate measures to maintain noise levels at the site including enforcement and provision of ear plug/ earmuff in areas with noise levels more than 75 dB (A) to protect worker’s health and safety; preventive maintenance of machineries; acoustic enclosure to diesel generator sets; and monthly monitoring of source noise level for DG set and boiler, and ambient noise level at various locations across the site.

The company’s EHS performance published in the Annual Sustainability Reports indicates an improvement in the Lost Time Injury Frequency Rate (LTIFR) at 0.13 in 2021down from 1.10 in 2019. In the last 5 years, company has reported two fatalities (one direct and one contract worker) at Jhagadia site in FY2020-2021 during coal ash silo maintenance activity and otherwise have maintained zero fatality across all other sites. Expansion Pillar (Projects and new construction activities) operations report zero fatalities and LTIFR in the construction activities. Manufacturing plants at Dahej Zone cumulatively report 20.11 safe million man-hours and there has been zero incidents or fatal accidents since inception.

To improve the OHS and Process safety management in line with Good International Industry Practices (GIIP) and World Bank Group EHS Guidelines, the company will implement the following ESAP actions:

• ESAP#2: AIL will augment the existing industrial hygiene assessment and health surveillance of workers at both Dahej and Jhagadia by implementing a written respiratory protection program with specific worksite procedures and enforce respirator use amongst workers.
• ESAP#3: AIL will augment the existing alarm management guidelines by implementing an alarm rationalization and key performance indicators to achieve effective alarm management program benchmarked to internationally recognized standards and guidelines (such as International Electrotechnical Commission - IEC 62682 Management of alarms in process industries, Engineering Equipment and Materials Users Association  - EEMUA 91 Alarm systems, and International Society of Automation - ISA 18.2 Management of alarm systems).
• ESAP#4: AIL will re-validate and update the Quantitative Risk Assessment (QRA) report for MEA Dahej plant and to ensure it covers the ethylene gas pipeline. Thereafter, to develop a time-based implementation schedule for the recommendations resulting from the study.

Freedom to Associate: Company's People Policy states that AIL respects the employees’ rights to freedom of peaceful association and engage in collective bargaining. There is a functional labour union at Tarapur facility, and no other site has labour unions. Workers committee has been established in compliance to Labour Standing Orders to manage worker welfare issues such as food, canteen service levels, worker clothes and uniforms, and safety issues etc. Both Jhagadia and Dahej sites have formed Worker Committee under Section 3 of the Industrial Dispute Act, 1947 with selected committee members and workmen representatives.

Workers engaged by 3rd Parties: Corporate contract labour management guidelines guide the site HR management which covers key aspects such as: contractor screening and on-boarding process; regulatory compliances and monthly compliance records; recording attendance of contract workmen; training; creation of contract labour cell; and zero tolerance provisions. At Jhagadia and Dahej sites, AIL has instituted a Contract Labour Management Cell that verifies all documents and other regulatory compliance, for which external audits are undertaken by independent labour consultant every month. Company’s grievance mechanism is accessible to workers engaged by 3rd parties as well. AIL maintains monthly attendance of all contract workers, including overtime hours. As part of IFC investment and as per agreed ESAP#5, Company will  review and update HR policies, procedure and management systems and procedures with regards to following aspects: a) Contractor oversight to ensure labour law compliance with regards to daily wage workers and ensure the daily wage and overtime wage requirements comply with the national and state regulations; and b) formulate the onsite or offsite workers accommodation related specifications to meet benchmark standards recommended as per Part II: Standards for and management of workers accommodation, Workers’ accommodation: processes and standards, A guidance note by IFC and the EBRD, August 2009. The worker accommodation specifications shall be updated with regards to sizing of room and dormitory facilities; bed arrangements and storage facilities; canteen, cooking and laundry facilities; standards for nutrition and food safety; medical and first aid facilities; and leisure, social and telecommunication facilities. The provisions of the worker accommodation specifications shall be included in the contract clauses with contractors. Company agrees to audit and enforce the labour camp standards on the construction phase contractors.

Supply Chain: Company procures many hazardous chemicals as raw materials, and the key ones include Ethylene, Toluene, Benzene, Chlorine, Hydrogen and Nitric acid. At Jhagadia, Ethylene, Chlorine and Hydrogen is received through pipelines from neighbourhood industries while at Dahej, neighbourhood industries supply Hydrogen and Ethylene through pipelines. Besides, Company also requires rock phosphate and limestone which is sourced from mines owned and operated by Rajasthan State Mining Company - a State Government entity. Company's Supplier Code of Conduct governs the supply chain management system and is compliant to PS 2 requirements on child and forced labour aspects and occupational health & safety aspects in supply chain. The vendor management procedures include screening, capacity building, training, enforcement, and auditing of code requirements. The company has initiated supply chain sustainability initiative and engaged with 200+ critical suppliers in last 2 years. More than 77% of the raw materials and 98% of engineering goods were sourced locally in FY22. 

Resource Efficiency: The Company has been implementing technically and financially feasible and cost-effective measures for improving efficiency in its consumption of energy, water, raw materials, and other material inputs. Company monitors and reports its resource efficiency programs in its annual sustainability report. AILs energy sources include coal, diesel, natural gas, grid electricity, and purchased steam. At Jhagadia, a coal-based cogeneration (electricity and process steam) plant (CPP) of 8MW installed capacity has been operational and going forward (such as the new 4.5 MW CPP proposed at MPP Jhagadia), Company will install dual-fuel (coal or biomass) or natural gas-based boilers to reduce coal consumption in its energy basket. In addition to these, Plants also use energy generated from waste heat and process systems. In FY 21-22, the total energy consumed was 6.963 million giga joules (GJ) out of which coal alone contributed 84% to energy needs. The energy intensity has been showing a decreasing trend since last 3 years from 10.10 million GJ/ton of product in FY19-20 to 8.68 Million GJ/ton of product in FY21-22.

Water Consumption: AIL operations require water for wide variety of uses such as: chemical processing, heating, and cooling requirements, vacuum generation, steam production, solvent preparation, reaction media, product rinsing, distillation and washing. AIL sites in Jhagadia and Dahej source water from industrial water supply pipeline provided by Gujarat Industrial Development Corporation (GIDC). The water consumption is monitored through flow meters installed at main inlet and multiple areas within a Plant to get process-wise authentic water consumption data and plan & implement water conservation measures based on water auditing. Flow meter readings indicate that Jhagadia sites (Units 1 and 2) cumulatively consumes about 2600 cubic meters while Dahej Neo Division alone consumed about 300 cubic meters in the manufacturing operations, utilities, and domestic purposes. At the Corporate level, Company reports that its operations consumed about 2.3 million cubic meters in FY21-22 and recycled 1.03 million cubic meters of water (44% of total water consumption). AIL has established rooftop rainwater harvesting systems across all manufacturing units and has harvested about 6010 cubic meters of rainwater in FY2022. Water collected through the harvesting system is stored in a raw tank and is used in cooling towers.

To conserve water and increase water recycling opportunities, AIL has installed Zero liquid discharge (ZLD) based effluent treatment plant (ETP) systems in 10 out of its 16 Plants including at Jhagadia and Dahej. Installation of ZLD systems and 60-70% steam condensate recycling in boilers has caused reduction in freshwater consumption and increase in use of recycled water. Company uses advanced tertiary treatment technologies like RO Systems, Multiple effect evaporator (MEE), Agitated Thin Film Dryer (ATFD) and Sewage Treatment Plans (STP). Company monitors the specific water consumption which is around 2.68 cubic meters of water per ton of product.

GHG Emissions: AIL monitors and reports GHG emissions (Scope 1 and 2) as part of annual sustainability report. In FY21-22, the GHG emissions (Scope 1 and 2) reported is 0.704 million tCO2e in which coal contributed almost 80% of the emissions while purchased electricity (13%), process emissions (5%) and purchased steam (2%) are the other major contributors to GHG emission in company operations. GHG emission intensity has come down from 1.00 tCO2e/MT of product manufactured in 2019-2020 to 0.90 tCO2e/MT of product manufactured in 2020-2021 and further down to 0.88 tCO2e/MT of product manufactured in 2021-2022

The Company has signed up with SBTi (https://sciencebasedtargets.org/) in January 2023 for adhering to emissions reduction aligned with science-based targets, which are being developed and finalized. The key actions proposed include the following: partial coal replacement with biomass; increase the share of renewable power in energy mix; increase waste heat utilization and implementation of energy efficiency programs. This plan is expected to reduce total annual GHG emission (Scope 1 & 2) by approximately 0.74 million tCO2e (~16%) by FY27.

Pollution Prevention – Air and Noise: The sources of air emission from AIL operations include: (i) point sources of emission from the stacks attached to air pollution control devices for process reactors and vents attached to the process equipment, coal fired power plant and thermic fluid heater; (ii) fugitive emission from material storage and handling areas (coal, ash, powder charging, ATFD salt dispensing) and (iii) non-point source emissions from fugitive sources (pumps, valves, flanges) and non-routine activities (startup, maintenance, inspection).

For managing point source air emissions, the company has provided appropriate air pollution control devices, along with adequate height of stacks as per the permit conditions. Process scrubbers (acidic or alkali scrubbers, cyclone separators & wet scrubbers, falling film absorber, single stage 10% NaOH scrubbers) are installed to treat emission released from manufacturing processes. Company is in the process of replacing wet to dry scrubbers to eradicate the corrosion problems based on an evaluation and verification of process vent scrubbers for gaseous emission. Three stage, electrostatic precipitator (ESP) is attached as an air pollution control mechanism (APCM) to control particulate matter (PM) emissions from coal fired utilities (boilers and thermic fluid heaters). In the coal, lime is added to reduce SO2 emissions. For managing fugitive dust of coal and fly ash, storage areas is managed through fire water sprinklers. Above & Under Ground Storage Tanks are provided with PESO approved Tank-farms with nitrogen blanketing for controlling fugitive VOC emissions. Green belt has been developed to control fugitive emissions within plant premises.

For managing non-point source emissions, Company has formulated a Leak Detection and Repair (LDAR) Program as per local regulations applicable for the Petroleum Oil industry. As part of IFC investment and as per agreed ESAP#6, the Company will augment the EHS asset integrity management procedures by operationalizing the Leak Detection and Repair (LDAR) program in the Project. The LDAR program will be conducted across the whole of Jhagadia and Dahej plants including in all process units, utilities, storage tanks, ETP, WTPs, and loading/unloading area to control fugitive emissions to the atmosphere.

AIL has developed site specific environmental monitoring plan to monitor identified point sources of emission and workplace environmental quality in line with permit conditions. Air emissions monitoring program comprises of three systems: 1) Permanent ambient air monitoring stations installed to monitor ambient air (weekly twice) inside each facility to monitor ambient air quality twice a week as per national guidelines issued by CPCB in 2009; 2) Online Boiler and Process stack Continuous emission and effluent monitoring systems (OCEMS) has been installed and connected to Central Pollution Control Board (CPCB) portal as per regulator guidelines; and 3) engage external NABL accredited third party labs for monitoring boiler and process stack emission levels as per permit conditions. Ambient air quality monitoring is being conducted for 14 parameters including 12 parameters as per NAAQS, along with additional parameters of chlorine (Cl2) and volatile organic compound. Review of sample monitoring results indicate compliance to national legal requirements stipulated in environmental permits. Among the pollutants specified in Table 1 - Air Emissions in WBG EHS Guidelines for Large Volume Petroleum based Organic Chemicals Manufacturing, dated April 2007, Nitrogen oxide (NOx), Hydrochloric acid (HCl), Sulphur oxide (SOx), Benzene, Ammonia (NH3) and particulate matter (PM) were found applicable to Company operations at Jhagadia and Dahej. Review of air emission monitoring results with regards to above specified pollutants indicate compliance to WBG EHS Guideline values except for Ammonia in one of the plant stacks which was commissioned recently in 2023. As part of agreed ESAP#7, the Company will implement technical process improvements to comply with Ammonia WBG EHS air emission guideline levels and report the compliance annually to IFC through the annual monitoring report.

The sources of noise generation at AIL Jhagadia and Dahej sites include operation of equipment and machineries, such as blowers, pumps, motors etc from manufacturing operation and utilities. A noise pollution monitoring program comprising of fence line ambient noise, equipment operational noise and workplace noise monitoring is in place. The ambient noise levels comply with National Standards for industrial land use.

Pollution Prevention – Wastewater: AIL requires water in various chemical processes resulting in significant wastewater generation. The sources of wastewater from AIL operation consist of domestic wastewater, process wastewater, reject wastewater from scrubber, cooling tower, demineralization plant, and boiler blowdown. Domestic wastewater is treated in on-site sewage treatment plant (STP) and treated wastewater is utilized for gardening purpose.

AIL has installed ETP and MEE systems as part of ZLD at Jhagadia and Dahej sites. The ETP systems use advanced treatment methodologies like Fenton reaction for degradation of organic pollutants in effluent and uses ozonation system to treat recalcitrant chemical oxygen demand (COD) and enhance the biodegradability of the effluent. At Jhagadia and Dahej sites, AIL has also obtained membership of GIDCs Common Effluent Treatment Plant (CETP) for further treatment and deep-sea discharge infrastructure operated by M/s Narmada Clean Tech for discharge of 827 cubic meters treated wastewater. The GIDC CETP and marine outfall system is approved, regulated, and monitored by Gujarat State Pollution Control Board. However, AIL attempts to recycle most of its treated wastewater from its advanced tertiary treatment systems and discharges only the excess treated wastewater to CETP and marine outfall system. At Dahej, the treated wastewater is recycled and not sent to marine outfall for discharge. AIL conducts monthly wastewater monitoring through third party monitoring agency and the treated water quality meets permit conditions, CETP influent quality conditions and IFC EHS Industry Guideline values applicable for Company operations.

Stormwater management: Jhagadia and Dahej sites have provided stormwater drains to the peripheral areas of the site and individual buildings within the site in line with the AIL Corporate guidelines for environment management updated in Jan 2023. The stormwater drains are connected to stormwater retention tank provisioned with valve gates and pumping arrangement for collecting initial runoff. As per AIL standard operating procedure, if stormwater analysis indicates any contamination, the collected water is diverted to ETP for further treatment prior to discharging off-site. In case of no contamination, the collected stormwater is discharged to off-site GIDC stormwater drain, running parallel and adjacent to the Sites.

Wastes: Hazardous waste generation at AIL sites in Jhagadia and Dahej include ETP sludge, silica, used oil, empty barrels & HDPE bags, discarded containers /bags, process distillation residues & wastes, process residues, spent catalyst, Hydrochloric acid (HCl), Spent Sulphuric acid (H2SO4), Sodium Chloride (NaCl), & Ortho Nitro Phenol (ONP/ Para Nitro Phenol (PNP), Spent Carbon, PPE waste, and off-specification product. AIL has developed site specific hazardous waste management procedures for handling, storage, and disposal of hazardous waste, which includes guideline on segregation of hazardous waste at the source of generation, sending hazardous waste to hazardous waste storage areas, storage and disposal of hazardous waste as per Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. The management of hazardous wastes is assessed to be compliant to regulatory requirements and permit conditions. Company maintains membership in regulator approved Common HW disposal and incineration facility and holds online manifest system during transportation of HW. Like hazardous materials transport discussed below, the company monitors in real time transport of HW vehicles with enabled GPS systems.

As part of the waste management philosophy, AIL aims to reduce incineration of its waste by optimizing the use of the waste resources, reducing energy emissions and consuming raw materials. As a result, the Company reports that it has recycled or reused 85% of hazardous waste generated in FY22 and about 3,400 MT of waste has been sent for co-processing in other industries. Hazardous wastes are converted into valuable products to minimize waste generation and the initiatives includes Hydrochloric acid to Chlorosulfonic acid and Calcium chloride; spent acetic acid to sodium acetate; NOx converted to Nitrosyl sulphuric acid; Waste ammonium chloride to Calcium chloride solution; fly ash for road, brick making and cement industries; and diluted sulfuric acid converted to gypsum, fertilizer, animal feed and to concentrated acid.

Hazardous Material Management: AIL sites manage hazardous chemicals in very large volumes such as Hydrogen & Ethylene via pipeline; Chlorine via pipeline and one tonners; and Sulphur Trioxide, Dimethyl Sulphate, Nitric acid etc. Considering the significant risks and impacts, AIL has developed standard operating procedures for hazardous chemical management at its facilities. Each sites procure, transport, store and handle hazardous chemicals and materials in bulk in mild steel and stainless steel tanks, while non-bulk chemicals are stored in HDPE Carboys, HDPE bags etc. Gaseous raw materials (natural gas, hydrogen, ethylene) are received through overground or underground pipelines from neighbourhood industrial facilities while Chlorine is received through both pipelines and one tonner vehicles.

As part of hazardous chemical management measures every site has implemented control measures including: conduct leak detection and repair (LDAR) program to control emissions from equipment leaks; provided designated storage locations for raw material storage, with impervious layer, RCC roads and flooring to storage areas; dyke walls for bulk storage tanks; closed loops and secondary pellet containment systems to avoid leakage/ spillage; level transmitters/gauges provided to avoid overflow; breather valves/safety valves/flame arrestors installed as appropriate; loading and unloading monitored through the DCS panel; 80% of total capacity is the maximum allowable storage levels; and fencing and access restrictions. Transportation of hazardous chemicals to and from the sites are done in compliance to Motor Vehicle Act & Rules using a specialist third party. More discussions on transportation risks are presented under PS4 below.

Infrastructure and Equipment Design and Safety: Company has established infrastructure and equipment testing regime in compliance to local Factory regulations. Stability of buildings are assessed and independently verified by authorized Chartered Engineers once in 3 years. Multiple industrial equipment’s testing inventory is maintained along with their testing schedule and latest copies of independent certification at each plant. In line with Section 31 (Rule-56) of the Factories Act 1948 and State Factories Rules 1950, the testing and examination of Pressure Vessels are undertaken by competent person approved by Chief Inspector of Factories at specified intervals. The process equipment’s in Steady State Plant Operations are subjected to Cyclic HAZOP, HIRA, Safety Audits, Management of Change, QRA & SIL, SOC Alarm & Interlocks Testing, Pressure Systems Inspection, and Start-up/shutdown/NR checklist & RA. AIL generates Annual, Monthly, Weekly and Daily Mechanical and electrical maintenance and modification plans. These plans are implemented and stringently monitored to comply with GIIP and regulations. 

Hazardous Materials Management and Safety: Jhagadia and Dahej sites are located inside industrial zoned land for hazardous chemical industries. At Dahej, there are no residential settlements within the 4 km radius as it is surrounded by other industries in the industrial zone. At Jhagadia, nearest residential settlement is located at 1 km distance and two more settlements - Sardarpura (1.5km) and Unita (2.5km) are the other villages close by. Based on review of the QRA’s undertaken for sections of both Jhagadia and Dahej plants, it is summarized that the risks of accidents and its impacts are limited within the respective plant boundaries.

Transport and Traffic Management: Company has established and operating Aarti Logistics Control Centre (ALC) at Vadodara using independent HAZCHEM transport specialist third party service provider. ALC monitors all the HAZHEM including hazardous waste transport vehicles to & from AIL sites round the clock using state of the art technology and tools. For emergency management, ALC operator has established quick response team (QRT) at every 70-80 kms across 4 States of India and in other States the operator takes help of other service providers or government emergency services. Crisis Support Team (CST) has been identified at AIL Plants as well at Corporate/Zonal/Divisional and Plant levels which can help ALC QRTs on a real-time basis at the accident or emergency site.

The QRT team members are well trained and experienced in handling any kind of HAZCHEM accidents/incidents. The transport fleet service vendors are selected by AIL based on a stringent screening and selection criteria and are periodically trained by ALC Team on traffic and transport safety issues associated with HAZCHEM transport. Each driver of the fleet has to possess hazardous chemical driving license issued by transport regulator (RTO) and AIL subjects the drivers to a 3-day course on HAZCHEM Transport for Drivers at a Government Institute in Vapi or AIL Vapi. There is a 1-day refresher training to be completed every year by AIL fleet operators. Transport or journey risk assessment is undertaken by the ALC operator before initiating the fleet operations in a new route. ALC deploys security vehicles for escort and in some cases security guards are deployed to travel in each vehicle depending on the risk profile. All export or port bound fleets move together in an organised convoy escorted by security vehicles

Emergency Preparedness and Response: District authorities have developed Off-site emergency plan which includes a Mutual Aid Scheme agreed amidst neighbourhood industries, regulatory and emergency service agencies in Surat District. As part of the plan, periodic off-site mock drills are conducted in presence of Jhagadia & Dahej – District’s Disaster Control Management Team and District Magistrate.

Security Personnel: Unarmed security personnel have been deployed across all Plants through third party security vendors authorized by government. The company briefs security personnel about policies on child labor and provides training on basic safety, first-aid, fire safety and emergency response. The security team is led by company chief security officers who are on-roll staff. Security team members is made part of the emergency response team with recurrent training on emergency situations as per on-site emergency management plan. Company reports no security incident in the past involving armed/unarmed security guards and local community members. 

Company has instituted stakeholder engagement process in line with its vision to have amiable social license to operate with the neighbourhood communities and considers stakeholder engagement as a key process for a robust collaboration with the communities and regulatory authorities. AIL aspires to lead the dialogue with stakeholders and in its agility to respond and consistent engagement with key stakeholders is a step-up to lead the dialogue with stakeholders beyond compliance. AILs key stakeholder groups identified by the Stakeholder engagement mechanism includes and government agencies; local communities; suppliers and contractors. With local communities, AIL engages through regular engagement activities and programs to understand their concerns & requirements and through community engagement programs during corporate social responsibility (CSR) initiatives.

AIL has been publishing sustainability reports for past 3 years which are available on its website (Refer:  https://www.aarti-industries.com/sustainability/sustainability-reports). AIL also publishes its regulatory compliance statements in public and hosts the same on its webpage (Refer: https://www.aarti-industries.com/sustainability/compliance). At the site level, as per permit conditions, a real-time digital display board on environmental pollution levels using the data generated by continuous emission monitoring systems has been installed across all AIL sites.

Informal community grievance mechanism is in place that is managed by community contact persons under HR vertical who regularly meet and engage with the local community members especially gram panchayat (local government), local government head (Sarpanch) and local regulatory & administrative authorities (GIDC, GSPCB, District Administration, DISH). However, as part of ESAP #8, the Company will develop a stakeholder engagement plan (SEP), including (i) stakeholder identification, profiling, and analysis, (ii) disclosure and dissemination of information including engagement methods and frequency of engagement, (iii) development of an effective community grievance mechanism, and (iv) ongoing reporting to affected communities and stakeholders; and (v) documentation of stakeholder engagement records, in a manner aligned with IFC PS1 requirements.