All the six integrated paint manufacturing plants proposed under the Project in different States of India are located within designated industrial estates that are developed and promoted by respective State government industrial development authorities.

This is a Category B project according to IFC's Policy on Environment and Social Sustainability (2012). Based on information reviewed by IFC, the proposed project will have limited adverse E&S impacts that are few, site specific, largely reversible, and readily addressed through existing mitigation measures and good international industry practices (GIIP). 

Key E&S issues and risks include: (a) corporate and plant level E&S management and monitoring systems to manage E&S risks from construction and operation of six new plants funded under the project; (b) management of labour & working conditions, workers engaged by third-parties, process safety management, occupational health safety (OHS) management, worker exposure to fugitive emissions, and worker’s accommodation; (c) resource efficiency measures; (d) monitoring and management of air emissions, wastewater and hazardous wastes; (e) emergency planning and response including life & fire safety; (f) hazardous material management practices including transport; (g) impacts on nearby community health and safety; and (h) the company's stakeholder engagement and community grievance mechanism.

PS1: Assessment and Management of Environmental and Social Risks and Impacts

E&S Management Systems: Grasim's Paints Division has developed E&S policies which cover Environment, Safety & Occupational Health, and Sustainability aspects. The company's E&S policy objectives and statements such as legal compliance, resource efficiency, reducing safety risks to as low as reasonably practicable (ALARP), and continual improvement are aligned with the objectives of IFC Performance Standards (PSs). The company has established and maintains a construction phase environmental and social management (ESMS) system. The company is in the process of developing an operational phase ESMS and more details are discussed below.

Identification of risks and impacts: The company has finalized the identification of E&S risks and impacts process for the six plants funded under the project in line with national law. The scope of the E&S risk identification process addressed in the Environment Impact Assessment (EIAs) studies are consistent with GIIP and considers E&S risks and impacts including the issues identified in IFC PSs. 

Risk Assessment: The company as part of the EIA process has completed risk assessment studies for each of the six sites and documented the same in publicly disclosed EIA reports. At each plant site, about 11-15 chemicals/solvents, known for their high flammability and toxicity, were identified for detailed consequence analysis of accident scenarios involving storage tanks and pipeline transportation. The consequence analysis reports present a partial risk result of the overall quantitative risk assessment (QRA). As per E&S Action Plan (ESAP)#1, the Company will: (i) complete detailed QRA studies for all the manufacturing sites in line with GIIP and IFC’s Performance Standards, and (ii) implement prevention and mitigation measures resulting from the studies in all the sites to ensure public and workforce safety.

Based on the EIA and risk assessment reports, the company has received Environmental clearance (EC) and the details have been published on the regulator’s website as detailed below. The company also has been publishing half-yearly EC compliance status reports at its website as per the clearance conditions (https://www.grasim.com/sustainability/sustainability-reports):

1. Ludhiana, Punjab (30°56'14.0"N 76°00'04.8"E) –Environmental clearance has been received in Jan 2022 and EIA has been disclosed at: https://environmentclearance.nic.in/state/FB_ECGeneral_Report.aspx?pid=194621
2. Cheyyar, Tamilnadu (12°42'30.6"N 79°39'17.3"E) –Environmental clearance has been received in June 2022 and EIA is disclosed at: https://environmentclearance.nic.in/state/FB_ECGeneral_Report.aspx?pid=190036
3. Chamarajanagara, Karnataka (11°59'22.2"N 76°53'51.2"E) –Environmental clearance has been received in April 2022 and EIA has been disclosed at: https://environmentclearance.nic.in/state/FB_ECGeneral_Report.aspx?pid=198548 
4. Paschim Medinipur, West Bengal (22°21'57.2"N 87°22'25.5"E) –Environmental clearance received in Dec 2022 and EIA has been disclosed at: https://environmentclearance.nic.in/state/FB_ECGeneral_Report.aspx?pid=209922  
5. Mahad, Maharashtra (18°06'15.2"N 73°28'35.0"E) – Environmental clearance has been received in Aug 2022 and EIA has been disclosed at: https://environmentclearance.nic.in/state/FB_ECGeneral_Report.aspx?pid=199182 
6. Panipat, Haryana (29°28'12.9"N 76°54'15.7"E) – Environmental clearance received in December 2021 and EIA has been disclosed at: https://environmentclearance.nic.in/state/FB_ECGeneral_Report.aspx?pid=195163 

All the plants have received E&S related clearances and permits as applicable to their current status. For O&M phase regulatory compliance management, Grasim has set-up a compliance monitoring software to ensure compliance.

Management Program: Construction Phase: Largely aligned to IFC PS requirements, the company has established documented EHS management programs and procedures consisting of contractor safety manuals, method statements, EHS training program, monitoring reporting templates and procedures, and audit programs. Each contractor and their subcontractors are contractually obliged to prepare and implement site-specific EHS management plans and procedures throughout the contract period.

Operation and Maintenance Phase: The company is in the process of preparing an operational phase ESMS in line with the national law and permit conditions. The operational ESMS will comprise of EHS/process safety/OHS manuals, incident investigation procedures, standard operational procedures (SOPs), training management, reporting templates, checklists, internal and external EHS audits, EHS monitoring, and reporting mechanisms. The draft SOPs reviewed during IFC appraisal indicates that while some E&S risk aspects are yet to be covered (e.g transport risk management), most of the E&S related SOPs (e.g onsite emergency response plan, industrial hygiene) need to be revised and updated to align with GIIP and industry standards. Therefore, as part of ESAP #2, the company will review, expand the scope and risk coverage of existing SOPs and augment the operational ESMS as per the requirements of IFC PSs, applicable WBG EHS guidelines and GIIP.  The operational ESMS and SOPs shall cover as a minimum: hazardous material management systems; solvent management and monitoring plan; life and fire safety; onsite and offsite emergency response plan; continual EHS/process safety training and capacity building program for E&S staff; occupational health & safety program (including risk assessments), occupational exposure and worker health monitoring, workplace quality and integrated process safety management systems; asset integrity management plan and provision for regular safety audits; GHG estimation; pollution prevention; contaminated stormwater management; hazardous waste including periodical audit of 3rd party treatment, storage and disposal facilities (TSDF) facilities and waste transporter for regulatory compliance; supply chain management; community engagement & grievance mechanism; environmental monitoring including baseline and periodical soil and groundwater quality monitoring program, and auditing & reporting E&S performance. As part of the operational SOPs, Grasim will also develop guidelines/procedures for Company owned paint warehouse operations which will include site screening, selection, risk assessment and mitigation, minimum life & fire safety infrastructure and standards to follow, fire/mock drills, worker training, regulatory compliance, ventilation requirements, fugitive emission monitoring, personal protective equipment's (PPE), accidental leak/spill management, waste management, audits etc. For third party operated warehouses, Company will endeavour to have all relevant and required life and fire prevention measures.

E&S Organisation: Grasim Paints Division has established separate project team along with a central engineering team to co-ordinate and monitor the project planning, design, and construction phase. Grasim retained a technical consultant to support the company in the planning and design phase of the project in line with the national building & fire safety codes and GIIP standards. During the ongoing construction phase, at each site, the project team is supported by plant level operation and maintenance (O&M) teams comprising of the Plant Head and the various department heads/leads covering EHS, Human Resources (HR), mechanical, electrical, and sustainability aspects.  The plant level teams including E&S staff with knowledge, experience and skills who will manage plant’s O&M phase has already been recruited and deployed on site. The plant teams have been made responsible for construction supervision along with the project engineering team. Construction contractor has mobilized EHS supervision team as per the contract requirements.

During operational phase, as stated above, E&S management organization structure established to oversee construction activities will continue to manage the O&M phase. The company has instituted a two-tier E&S organization structure within its Paints Division - Corporate and Manufacturing Plant level EHS teams.  Besides, there are Plant level human resource (HR) management team to manage labor and working conditions. The Administration and Liaison Officer with HR team is responsible for stakeholder engagement and community grievance mechanism. At the Corporate level, EHS Lead along with four (4) staff belonging to process technical team has been appointed to oversee ESMS implementation at plant level. At the plant level, Lead EHS officer reporting to Plant Head has a dedicated E&S team of ten (10) staff who have knowledge, skills, and relevant experience necessary to perform their work.

Emergency Preparedness & Response: As part of the construction phase ESMS and contractor EHS management plan, an emergency response plan is in place which includes probable emergency scenarios, emergency response procedures, periodical training, and monthly fire/mock drills involving all contractor workers. For the O&M phase, company is in the process of preparing site –specific emergency preparedness and response plan (ERP) in line with national law and standards.  The site-specific ERPs for Ludhiana and Panipat Plants have been completed. Review of the available onsite ERPs indicate that this needs to be reviewed and updated to meet the GIIP standards. Some of areas that needs to be integrated include: identification of emergency scenarios; specific emergency response procedures; permanently stationed emergency equipment and facilities; clear identification of evacuation routes and muster points; emergency drills and their periodicity based on assigned emergency levels or tiers; and decontamination procedures and means to proceed with urgent remedial measures to contain, limit and reduce pollution within the physical boundaries of the project property.

As part of operational phase ESMS review and update discussed above and agreed under ESAP#2, the company will review and update the onsite ERP and prepare offsite disaster management plans as a key element of operational ESMS in conjunction with responsible authorities. The ERP will include periodical engagement with sensitive off site social receptors (such as neighbourhood school campus at Ludhiana Plant) and community on safety measures and emergency drills; mandatory establishment and maintenance of buffer zones and green belts around the site restricting activities near the plant; and plan to stop critical operations in case of strong wind towards sensitive receptors (such as neighbourhood school campus) and elevated pollution levels detected on fence line.

Life and fire safety: The fire protection systems and infrastructure at the manufacturing sites have been designed and installed in accordance with the standards outlined by the Indian National Building Code, Bureau of Indian Standards, Tariff Advisory Committee (TAC) Manual and the National Fire Protection Association (NFPA)-72 Code (National Fire Alarm and Signaling Code). A dedicated fire-fighting team overseen by the Fire Safety Officer has been established at each site. This team receives regular training at the sites scheduled for commissioning within FY24. Additionally, to bolster the emergency response capabilities during the operational phase, a minimum of 20% of workforce will be trained on fire-fighting techniques to serve as supplementary fire-fighting team during critical emergency situations. As part of electro-mechanical completion audit, Company will: (i) engage a competent and certified life and fire safety professional to undertake performance testing, commissioning, and certification of all installed fire protection passive and active systems against the nation building and fire safety codes and relevant GIIP requirements before the start of commercial operation; and (ii) the company will engage an approved fire safety engineer to conduct a fire safety audit for all sites to assess compliance of the sites to national regulations and relevant international standards and codes.

Monitoring and Reporting: The company has established systems and procedures to monitor and measure the effectiveness of its ESMS during the ongoing construction phase at each of the six sites, as well as compliance with any related legal/ regulatory requirements on environmental quality, pollution monitoring, compliance reporting and requirements of IFC PSs. At each of the plant sites, the company has been submitting the environmental clearance related compliance monitoring as stated above.

During O&M phase, as part of ESAP#2, the company will develop and implement E&S performance monitoring and reporting management systems as per IFC PS 1 requirements. This will include real-time, continuous ambient air quality and ambient noise monitoring at the fence line of plants and semi-annually monitor ambient noise and ambient air quality at the closest off site sensitive social receptors. The manufacturing facilities will also have continuous monitoring systems for stack and effluent emissions which will also be monitored by a third party monthly. As part of the operational environmental monitoring plan, the company will perform baseline and periodical soil and groundwater quality monitoring program as per GIIP standards such as ASTM Standard Practice for Environmental Site Assessments (Phase I and Phase II) and the results will be compared against the soil (screening and response levels) and groundwater (screening levels) as mentioned in the guidance document for assessment and remediation of contaminated sites in India by Ministry of Environment, Forest, and Climate Change dated December 2015 (1st Edition). The monitoring plan will also cover quality of effluents and efficiency of the onsite wastewater plants.

For O&M phase, the company has deployed software dashboard tool to generate real-time reports, monitor and report E&S performance based on key performance indicators (KPI) discussed under PS3.

PS2: Labor and Working Conditions

The company has deployed about 130 to 177 (women ratio is 15-16%) direct workers during construction phase at each construction site. During O&M phase, it is estimated that Grasim's on-roll, direct staff will be around 149 to 227 (women ratio expected is 15-20%) per plant. The number of contracted workers engaged during peak construction phase at each plant varies between 1220 to 1850 and during O&M phase it is estimated that it will be around 270 to 350 at each plant.

The company has adopted HR Policy Manual in June 2023 based on Grasim’s Corporate and AB Group HR policies. The HR policies and procedures comply with the national law and the requirements of IFC PS2. HR Policies and procedures are documented and accessible to all direct staff and workers and shared with the employees at the time of onboarding and induction training.

Worker Accommodation: During the ongoing construction phase, the main civil construction contractor has set up offsite labor accommodation camps for male workers at each site for accommodating 1000-1200 workers. However, as of February 2024, these camps have been removed at all sites except at Kharagpur site where civil construction is expected to be closed by May 2024. The accommodation blocks have been installed, operated, and maintained by contractors in line with Building and other construction workers (BOCW) regulations. The company on a quarterly basis performs audits of the workers accommodation. As per ESAP#3, the company will update its construction phase ESMS to include labor camp specifications 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. In the sites where labor accommodation camps are still operational, the company will undertake an audit of the labor camp operations. The audit will use IFC worker accommodation guidelines as the framework document and the findings of such audit will be enforced on contractors for compliance within agreed timelines. Workers’ accommodation is not planned within the plant sites during O&M phase.

The company's Human Rights Policy recognizes workers’ rights to form and join a trade union of their choice without fear of intimidation or reprisal, in accordance with national law. Safety and various worker welfare committee systems are in place in the ongoing construction phase and the same system will be replicated during operational phase as well.  The company's Human Rights Policy commits to valuing diversity, equal opportunity, and the need to consider the rights of vulnerable groups such as indigenous peoples, women, migrant workers, and other minorities as a key policy objective. The HR policies prohibit all forms of child labor, forced labor, discrimination, and harassment and the same has been articulated in its Human Rights Policy.

Grievance Mechanism: During the ongoing construction phase, grievance mechanism for contractor workers and for Grasim direct staff have been instituted and operated by Industrial Relations (IR) Manager in respective HR teams. During operational phase, the company will adopt GRM policy and procedures covering direct and contracted workers. At the Grasim company level, an internal grievance policy and procedure is in place and Paints Division will institute a similar mechanism augmented to comply with the requirements of IFC PS2. Therefore, as part of ESAP#4, the company will formulate and provide a grievance mechanism for workers which will be aligned with the national law and the requirements of IFC PS 2.

Prevention of Sexual Harassment (POSH) Policy: The company has formulated and published a zero-tolerance policy to prevent and redress sexual harassment at workplace as part of its HR Manual published in June 2023. This policy is made applicable to all direct and contracted workers as well as workers engaged by third parties, customers, vendors, and suppliers.

Occupational Health and Safety: Grasim has established an occupational health and safety (OHS) management system for the ongoing construction phase as discussed under PS1. The construction contracts integrate the compliance requirements of company’s contractor environment, health & safety manual. Construction HSE statistics is maintained at site level and consolidated at Paints Division corporate level. Since the start of construction activities in FY22-23, Grasim reports 21 million safe manhours have been achieved without any fatality across all six sites as of December 2023.

Grasim has conducted hazard and operability (HAZOP) studies during the design phase for its paints manufacturing facilities. To ensure process safety risks are controlled, as part of ESAP#5, the company will ensure all HAZOP recommendations and mitigation measures are appropriately implemented at each site and will undertake validation of the as-built HAZOP during the operations phase. The company will also complete a Layer of Protection Analysis (LOPA) and Safety Integrity Level (SIL) classification study for all instrumented protective functions (automated trips) to be evaluated in accordance with IEC 61508/61511 Standards. In addition, Grasim will augment the alarm management system by implementing an alarm rationalization and key performance indicators to ensure effective alarm management program compliant to EMMUA 191 and ISA18.2 standards on management of alarm systems for the operations phase at each facility. 

Grasim has prepared OHS-related safe work standards and procedures for confined space entry, chemical handling, manual handling, work at height, and stacking and storage. To ensure adequate control of occupational health and safety risks, the Company will prepare site-specific OHS risk assessments as part of ESAP#2 operational ESMS development, for paint and resin manufacturing activities and implement risk control measures, including a permit-to-work system and updating the safe work standards and procedures to ensure alignment with the requirements of the World Bank Group EHS Guidelines and good international industry practice.

The company, as part of the design of the manufacturing facilities, has integrated pollution control measures for dust and volatile organic compounds (VOCs) such as dust collectors, scrubbers, and online monitoring systems. The dust extraction system of down flow evolution (DFE) technology has been selected as per “American Conference of Governmental Industrial Hygienists” (ACGIH) standards. As per agreed ESAP#6, the company will implement an industrial hygiene program applicable to direct and third-party (contractor) workers covering industrial hygiene risk assessment, workplace air quality monitoring (at higher frequency during early commissioning stages, if needed), employee exposure assessment, and medical surveillance to cover pre-employment and periodic medical evaluation, including establishing baseline medical records of workers. The Company will also complete a dust hazard assessment per the requirements of NFPA 652 Standard on the Fundamentals of combustible dust.

Workers engaged by Third Parties: During construction phase, required clearances and permits relating to contract labor engagement including inter-state migrant workmen through various type of construction contractors has been maintained and complied. Each contractor is audited and inspected monthly for regulatory compliance and for maintaining appropriate regulatory compliance documents.

During the operational phase, approximately 60% of the total workforce across all six plants will be contracted workers engaged through licensed contractors. The company is in the process of formulating a standard operating procedures for contractor management.  As part of the ESAP #3 discussed above, the company will develop and implement a contractor management procedure and contractor management plan to comply with local regulations, IFC PS 2 requirements and IFCs Good Practice Note on Managing Contractors’ Environmental and Social Performance (2017).

Supply Chain: The paint plants will require about 16 raw material inputs comprising of resins, solvents, pigments, additives, monomers, oil, and extenders which will be procured from domestic market or sourced globally. Primary suppliers to the company include established business houses/ companies. The company will as part of the ESAP #2 develop its procurement policy, supplier code of conduct including a clear prohibition of child labour, and forced labour in all purchasing procedures, consistently with the requirements of IFC PS 2 and include contractual requirements to ensure suppliers abide by them. 

PS3: Resource Efficiency and Pollution Prevention

Resource Efficiency: Grasim has integrated technically feasible and cost-effective resource efficiency measures in the design of the six new plants.  As part of the E&S performance monitoring and reporting system, the company will set the key sustainability performance indicators (KPI) such as specific electricity consumption, specific water consumption, and other resources and material inputs to monitor effectiveness of resource efficiency measures with the objective of conserving raw material, water, and energy.

Greenhouse Gases: The project is expected to generate annually 76,750 tons of CO2eq on an average over the next 10 years. Therefore, as part of the operational phase ESMS (ESAP#2), the company will annually quantify Scope 1 and Scope 2 emissions in accordance with internationally recognized methodologies and good practice and report to IFC.  

Water Consumption: Water will be sourced from respective industrial authorities and all plants have signed water supply agreements with the industrial estate authorities. As per EIAs, daily process water consumption per plant will be in the range between 1000 to 1200 kilolitres (KL). The company has integrated water conservation measures into technical design including process wash water reuse system; superior mixer cleaning system; maximum condensate recovery from the boiler by having a closed loop system; and 100% treated effluent recycling through reverse osmosis (RO), Multiple effect evaporator (MEE) and Agitated thin film dryer (ATFD) technology based zero liquid discharge (ZLD) systems for cooling tower use. During the monsoon season, the rainwater harvested will be used as a raw water source reducing the water demand. The use of rain-harvested water in process use is expected to meet approximately 15% of daily process and utility water demand during monsoon months.

Air emissions and ambient air quality: During operational phase, point source air emissions are expected from utility equipment stacks and process vents from paint manufacturing blocks. The point source air emissions from utilities such as diesel generators, steam boilers, and thermic fluid heaters are controlled through adequate stack heights for achieving maximum dispersion and as per permit conditions. The company will install the continuous online emission monitoring system (CEMS) in the utility/boiler stacks as per permit conditions and the real-time emission data will be shared with regulator. The utility air emissions will be regularly monitored in line with national regulatory requirements and applicable WBG EHS guidelines using third party specialized and accredited laboratories.

As per EIA reports, the point source air emissions from process vents will be managed by specific air pollution control measures as listed below and the air pollution control equipment’s designed to control ammonia, monomers, and hydrocarbon emissions to less than 10 ppm at stack outlet:

• In water-based paint manufacturing process, ammonia emissions are anticipated, and counter current wet scrubber designed to reduce ammonia emissions has been installed in line with the design.
• In solvent paint block, volatile organic compounds (VOC)/hydrocarbon emissions are envisaged. A two-stage activated carbon bed scrubber designed to reduce Methylcyclohexane-Toluene-Octane (MTO)/Xylene emissions has been installed.
• In emulsion block, ammonia (NH3), monomers/ hydrocarbon emissions are envisaged by design and a counter current wet scrubber cum two stage carbon bed has been designed & installed to reduce NH3 levels to less than 10 ppm; monomers such as methyl methacrylate (MMA), butyl acrylate (BA) and styrene levels less than 10 ppm; and Xylene (hydrocarbon) levels to less than 10 ppm in the vent outlet.
• In resin bock of plants, to control hydrocarbon emissions, a vent condenser with two stage carbon bed designed to reduce hydrocarbons (MTO and Xylene) to less than 10ppm at outlet vent has been installed.

As part of the EIA studies, for each Plant, predicted air emissions and cumulative impact assessment on regional air shed quality during operational phase was analysed using regulator recommended air modelling tools (such as AERMET and AERMOD). Air quality modelling analysis indicate that operation of plants will not have significant impact on local and regional airshed quality across all sites. The resultant maximum pollutant ground level concentrations (of PM10, SO2, NOx, VOC emanating from project operations) and the background ambient air quality levels are observed to be within India's National Ambient Air Quality Standards (NAAQS) prescribed for ambient air environment except at Panipat site where the background levels for particulate matter exceed national standards especially during post monsoon season (Oct-Dec period).

As per agreed ESAP#2, the company will develop and implement an environmental monitoring plan as part of the standard operating procedures. Under the plan, point source emissions from utility stacks will be monitored for particulate matter emissions, NOx, and SOx parameters. The emission standards recommended by India’s Central Pollution Control Board for integrated paints industry and Plant specific permit conditions are aligned to emission guidelines recommended for small combustion facilities in WBGs General EHS guidelines (Refer to Table 1.1.2 - Small Combustion Facilities Emissions Guidelines (3MWth – 50MWth), WBG General EHS Guidelines).

As per agreed ESAP#2, under environmental monitoring plan discussed above, the company will monitor point source emissions from process stacks for ammonia, monomers, and hydrocarbon emissions. As per project technical design documented in the EIA reports, the process emissions of these gaseous pollutants will be reduced to less than 10ppm at the process stack outlet. As per agreed ESAP#7, the company will perform monitoring of point source air (process and utility stacks) emissions and monitoring of ambient air quality at Ludhiana, Panipat, and Cheyyar plants (March – April 2024) to confirm compliance with India's National ambient air quality standards and in particularly ammonia and volatile organic compound (VOC). If the monitoring results indicate non-compliance with the national ambient air quality standards, the company will augment the pollution abatement measures in line with GIIP. The company will apply such improved emission abatement measures in Mahad, Chamarajnagar and Kharagpur plants that are to be commissioned before FY25.

Ambient Noise Environment: The noise generating equipment’s in the plant includes diesel generator (DG) sets, mixers, grinding mills, pumps, boilers, reactors, blowers, scrubbers, and dust collectors. Plant design includes provision of acoustic enclosures for major noise generating equipment like DG sets, boiler, feed water pumps; selection of low vibration generating machines/equipment; equipment foundations designed to minimize vibrations and noise; and provision of silencers to other equipment’s. Acoustic design with sound-proof glass panelling has been provided for critical operator cabins/control rooms. Use of personal protective equipment’s/devices such as ear-muffs, ear plugs will be enforced for the workers engaged in high noise areas. Every plant has earmarked 33% of plot area for dense greenbelt development as per permit conditions specifically along the plant boundaries to protect nearby communities.

As per EIA reports, maximum design noise levels of the equipment’s in the range of 85 dB(A) to 95 dB(A) were considered for noise modelling purpose and using modelling tools, the predicted ambient noise level contours were generated. Ambient noise level modelling analysis indicate that background noise levels within and outside the project site could increase by 0.4 to 1dB (A) during operational phase and will meet the NAAQS with respect to noise levels and WBG General EHS Guideline levels (Refer: Table 1.7.1- Noise Level Guidelines)

Wastewater Treatment Systems

Effluent Treatment in Zero Liquid Discharge (ZLD) System: The process wastewater will be generated from paint process blocks, emulsion process block, boiler blowdown, water treatment plant (WTP) backwash, process wash water (only 8.7% is estimated as effluent as other 92% will be reused in process), RO reject, air pollution control (APC) scrubber and cooling towers. The plants will have onsite industrial wastewater treatment plants (WWTP)/effluent treatment plant (ETP) of about 150 KLD capacity at each plant.  The wastewater management system is designed for achieving ZLD and will have four stages or levels of treatment comprising of primary physico -chemical treatment, two stage biological treatment based on activated sludge process, tertiary treatment comprising of pressure sand filter and activated carbon filter, followed with advanced tertiary treatment systems (like disc tubular reverse osmosis (DT-RO), MEE and ATFD. Treated effluent will be used in cooling towers and the salts generated from ATFD will be disposed to regulator authorized hazardous waste disposal facility as per permit conditions.

Domestic Sewage Treatment: During the ongoing construction phase, about 80 KLD of sanitary wastewater has been generated at peak construction phase which are treated in three (3) mobile sewage treatment plants (STPs) of 30KLD capacity each at every offsite worker accommodation and Plant sites. Treated wastewater is being reused for green belt development and fugitive dust control in construction areas. 

During the operation phase, sewage generated from domestic use, kitchen, washrooms, and pantries will be treated in a 30KLD capacity activated sludge process (ASP) based STP using membrane bioreactor (MBR) technology. As per EIA reports, the treated effluent quality will be suitable for irrigation purposes and complies with permit conditions and IFC General EHS Guideline values for discharging to surface water (Table 1.3.1 Indicative Values for Treated Sanitary Sewage Discharges, WBG General EHS Guidelines, April 2007).

Diverting Initial Stormwater Runoff: According to the technical design, each plant will have appropriate constructed stormwater catchment area, pipeline, and tank infrastructure to collect, store, and transfer to ETP for treatment the initial polluted stormwater runoff (15-20 minutes of initial rainwater).  The tank farms will have dike wall systems with a volume of 110 percent of maximum tank capacity, designed to contain liquid eventual spills.  Quality of storm water collected in dike systems will be regularly monitored as part of the operational environment monitoring plan discussed under ESAP#2. A dike wall area will be cleaned before every monsoon season as part of tank farm maintenance procedures. Tanks farms are also provided with collection pits along with transfer pumps to ETP.

Hazardous Waste Management: As per EIA reports, the plants will generate about 17 streams of hazardous waste annually during operation. The off-specification product will be worked off and reused in paint processing. The company will comply with permit conditions and dispose of hazardous waste through authorized TSDF. Wastes having high calorific value will be sent to authorized industries that are permitted by regulator to use them as fuel. Each plant has a designated hazardous waste storage building and dedicated scrap yard to store hazardous and non-hazardous waste streams respectively in line with permit conditions.  As per agreed ESAP#2, the company will include procedures to periodically audit the TSDF facilities and waste transporter for regulatory compliance.

Legacy Soil and Groundwater Contamination: All Plant sites are greenfield and located inside industrial areas except for Mahad Plant in Maharashtra where a small textile unit was functioning in a part of the land parcel and remained closed since 1985. The legacy soil and groundwater contamination risk is assessed to be low. However, as discussed under monitoring & reporting section in PS1, as part of the operational phase ESMS and ESAP#2, Company will institute a soil and groundwater contamination monitoring program establishing the baseline quality levels within the first year of operations and periodical monitoring to generate and maintain a database on soil and groundwater contamination levels within the plant premises.

Hazardous Materials Management: The new plants will manage hazardous chemicals and solvents in large volumes such as butanol, butyl acetate, diethylene, glycol, HSD (High speed diesel), iso butanol, liquor ammonia, MEG (mono ethylene glycol), O-xylene, styrene, vinyl acetate, ethyl acetate, MMA (Methyl Methacrylate), iso octane, butyl acrylate, and mineral turpentine. As per EIA reports, typically, total chemicals and solvents consumed in a month at every plant will be around 48,000 tons out of which chemicals with moderate health hazards and solvents that are flammable constitute around 21,200 tons per month.

All the hazardous chemicals and powder chemicals will be stored in small bags (25 kg) or jumbo bags (500 kg, 1 MT), silos, hopper, tank farms (for storing emulsion, monomer, oil, polymer additives, resin, solvent-additives, solvents, and water-based additives), and barrels. The tank farms are designed as per national law and standards, national building & fire safety codes, Bureau of Indian Standards, and according to applicable GIIP standards (such as American Petroleum Institute and NFPA). Design of the tank farms is approved by the national agency for regulating the safety of hazardous substances - Petroleum and Explosives Safety Organization (PESO). The positioning of the tank farms within the plant’s footprint was selected considering the consequence analysis outcomes of the risk assessment studies referred under PS1.

Considering the significant risks and impacts associated with transport, storage, use and handling of these hazardous chemicals, as per agreed ESAP#2 and as part of the documented operational ESMS, Grasim Paints Division will develop hazardous material management plan and standard operating procedures that are commensurate to the risks and impacts identified in QRA, hazard identification (HAZID), hazard operability (HAZOP), process safety management (PSM) and other related safety studies.

Solvent Recovery Plant: At each Plant, as per the solvent mass balance estimates documented in the EIA reports, solvent evaporation loss during process of paint mixing and blending operations is estimated at 6.25 kiloliter (KL)/ annum which will be passed through activated carbon filter (ACF) filter and about 0.125 KL/annum is expected to be released into ambient air while the solvent containing filtrate of ACF will be used as fuel source in other, regulator approved, industrial plants as per permit conditions.

As per EIA reports, typically in a Plant, the estimated spent solvent waste generation is around 52.8 KL/Annum, which will be processed in dedicated solvent recovery plant with an efficiency of 87 %. About ~6.6 KL/Annum (which is 0.01% of total solvent consumed per annum) will go along with distillation residue as hazardous waste or co-processed as fuel in other regulator approved industries as per permit conditions.

As per EIA reports, each plant will implement a Solvent Management Plan as part of the operational phase management systems which comprise of monitoring of solvent losses; preventive maintenance to prevent leakages; and recovery of spent solvent. Storage and consumption of solvents in various products is measured through load cells weighing systems. The quantity at each stage is reconciled periodically to arrive at losses. Batch outputs are monitored and reconciled with quantity of input raw materials added. Workplace VOC monitoring through hand-held VOC meter will be carried out at the shop floor to detect solvent leakages. Considering the significant risks and impacts associated with solvent handling and disposal, as per agreed ESAP#2 and as part of the documented operational ESMS, Grasim Paints Division will develop and implement solvent management plan and standard operating procedures as per applicable GIIP standards.

PS4: Community Health, Safety and Security

Infrastructure and Equipment Safety: All the new plants funded under the Project are located within the designated industrial zone.  None of the plants will be accessed by members of the public. Each plant layout has allocated 33% of the plot area for green vegetation development all around the perimeter of the plants to act as a natural green barrier between plant operations and neighborhood communities which are located within 500-1000m distance from each of the six plants. Structural and civil construction, pre-engineered buildings, process machinery, hazardous material storage tanks and piping & instrumentation elements of the plants are designed and constructed and as per national building codes and local regulations. 

During operational phase, the structural stability of industrial buildings; fitness of critical process equipment’s that operate at high pressure and or temperature; testing of lifting equipment’s, tools, and tackles; fitness of hazardous material storage tanks and piping in tank farms; and boilers etc will be tested periodically in compliance to Factory regulations and other applicable local regulations. As per agreed ESAP#2 and as part of operational phase ESMS, the company will develop and implement an asset integrity management plan and undertake regular safety audits of production facilities and critical equipment in line with GIIP, national codes and standards.

Road Traffic and Transport Safety: All the raw materials, hazardous chemicals, solvents as well as finished goods (paints) will be transported by road in trucks and tanker lorries. As per EIA reports, during the operation phase, about 120 trucks are expected to access each of the plants daily.  All the manufacturing sites are in notified industrial zones with good access road networks to the nearest National or State Highways. All the raw material transport and delivery will be the responsibility of the suppliers and the finished goods transport will be the responsibility of the company. Considering the risks and impacts associated with transporting hazardous materials, as per ESAP #8, the company will complete road transportation safety risk assessments covering raw material and finished good transport and develop a road safety and transport management plan and procedures aligned to requirements of Para 3.5 in IFC General EHS Guidelines, April 2007 on transport of hazardous materials. The procedures should include transport fleet operator screening, selection, periodical audit for regulatory compliance and evaluation of safe performance; minimum basic qualification/certification of drivers, driver training on emergency preparedness in case of road accidents and safe driving behavior; conducting periodical community awareness programs on road safety accidents involving chemicals and preparedness; and gender based violence and harassment (GBVH) related training cum awareness for local communities and fleet operators.

Hazardous Materials Management and Safety: The risk assessment focusing on consequence analysis indicates that the consequence zones are not expected to result in offsite impacts and on nearby community settlements or sensitive receptors (such as school campus near Ludhiana Plant). Location of storage tanks and process building layout in each of the sites has been designed based on consequence analysis outcomes of risk assessment done as part of EIA study. Fire-fighting facilities and fire tender with dedicated fire-fighting team will be deployed round the clock. As all the manufacturing sites are located inside notified industrial zone off-site disaster management plan is managed by the Industrial authority as per the published District Disaster Management Plans. However, as discussed under emergency response section in PS 1, as per agreed ESAP#2, Company will review and update the onsite ERP and prepare offsite disaster management plans in co-ordination with the responsible authority as a key element of operational ESMS.

Security Personnel: Unarmed security personnel have been deployed across all manufacturing plants through third party security vendors authorized by the 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 Plant security team is led by Chief Security Officer - a direct staff of the Company. Security team members are 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 security guards and local community members during the ongoing construction phase. 

As part of the EIA process and regulator led community consultation (public hearing) process, the local communities in the vicinity of the project sites were engaged. The environmental clearance issued to all six plants were disclosed by the company through newspaper advertisements in the local and regional media and the copies of the same were disclosed on regulator website.

Grasim Industries Limited publishes the Corporate Sustainability Report, ESG Data Book and Division-wise/Plant-wise Regulatory Compliance Reports on its website (Refer: https://www.grasim.com/sustainability/sustainability-reports). In line with its Group level policies, Grasim Industries has published a stakeholder grievance handling policy in 2021. Grasim Paints Division has started implementing the policy requirements at each of its six plants and has started engaging with local communities through its corporate environmental responsibility (CER) and corporate social responsibility (CSR) programs being rolled out through third party non-governmental organization (NGOs). While documented consultation process was implemented as part of ESIAs preparation, knowledge of the project, their impact and mitigations need to be strengthened in the neighbourhood communities.  As per agreed ESAP#2, the Company will develop and implement stakeholder engagement procedures covering disclosure of information on offsite emergency response, general plant activities, transport impacts, community grievance mechanism and GBVH. 

Contact Person:          Mr Purushotham S, Sustainability Officer

Company Name:        Paints Business Division, Grasim Industries Limited

Address:                     9th Floor, Birla Centurion, Worli, Mumbai - 400 030. Maharashtra, India

Email:                         opuscare@adityabirla.com,

Phone:                         022 6854 0444