Date: 08/04/2020environmentclearance.nic.in/writereaddata/online/EC/13042020QYE6… · Date: 08/04/2020 To, The Member Secretary, Expert Appraisal Committee,

Date: 08/04/2020

To, The Member Secretary, Expert Appraisal Committee,

(Industrial Project-II) Ministry of Environment, Forest and Climate Change, Indira Paryavaran Bhavan,

Jor Bagh Road, New Delhi-110 003 Subject: Submission of Queries for Environmental Clearance application of M/s. Orgo

Chem (Guj.) Pvt. Ltd. Located at Plot No. 719, Road No. 7, Sachin GIDC, Taluka - Chorasi, District - Surat, Gujarat, INDIA.

Reference: EC Application on dated 21st March 2020 Proposal No.: IA/GJ/IND2/124974/2019 File No.: IA-J-11011/339/2019-IA-II(I)

Dear Sir,

We, Orgo Chem (Guj.) Pvt. Ltd. did online application for persual of Environmental Clearance for our proposed new project of Synthetic Organic Chemical (Dye Intermediates and Specialty Chemicals) proposed at Plot No. 719, Road No. 7, Sachin GIDC, Taluka - Chorasi, District -

Surat, Gujarat, INDIA on dated 21st March 2020. Query was raised by MS on dated 24th March 2020 and with reference to the same you are requested to find the attached reply of queries.

We request you to kindly consider the same and consider our proposal for further proceedings. Thanking you.

Yours Faithfully,

Enclosures:

Enclosure 1: Reply of Queries

Additional Attachments in Enclosures:

Annexure 1: Compliance of MoEF Circular for CPA (Critically Polluted Area) and SPA

(SeverelyPolluted Area) dated 31st October 2019. Annexure 2: Treatabillity Study Report Annexure 3: Plant Layout

Annexure 4: Land Possession Documents Annexure 5: Notification of Sachin GIDC Annexure 6: Revised ToR Complainces

Annexure 7: Revised Form-2

Enslosure 1: Reply of Queries

Sr. No. Query Reply

1

S. no. 23.1 of form 2 (CPA) mentioned

However PP has not submitted the Report as per the Ministry’s office memorandum 31st October, 2019

regarding projects located in Critically Polluted Area

Project site is proposed at Plot No. 719,

Road No. 7, Sachin GIDC, Taluka - Chorasi, District - Surat, Gujarat which is located in Critically Polluted Area as

Notified in Office Memorandum of MoEF dated 31st October, 2019, F. No.22-23/2018-IA.III (Pt).

Compliance of Compliance of Mechanism for Environmental Management ofCritically Polluted Area (CPA) was also

attached as Additional Attachment in EC Application and here as Annexure 1.

Unit has proposed to implement complete ZLD system for effluent. No effluent will be discharged outside plant

premises. Unit has proposed to use natural gas as a fuel with 30 m stack height. As conditioned 40% of the total

area is proposed for the green belt development. Condition wise compliance is attached in Annexure 1.

2

Effluent treatment mechanism with plan for Zero Liquid Discharge needs to be

submitted.

Unit has already proposed ZLD (Zero liquid Discharge) for the proposed project. Total wastewater generation

shall be 34.5 KL/Day (30 KL/Day Industrial + 4.5 KL/Day Domestic).

Entire Industrial effluentwill be treated into in-house MEE plant followed by biological treatment and RO plant. RO

permeate water shall be reusedback within plant premises and RO reject water shall be again sent back to MEE

plant. Domestic wastewater shall be disposed through septic tank/Soak pit system. Details of water consumption

and wastewater generation along with process description of effluent treatment plant (ZLD) are given below.

WATER CONSUMPTION AND WASTEWATER GENERATION

Description Water Consumption Wastewater generation

KL/Day KL/Day

Total Industrial 37 30

Process 13.5 13.5

Boiler 10 5

Cooling 9 7

Washing 3 3

Scrubber 1.5 1.5

Domestic 5 4.5

Gardening 3 0

Grand Total 45 34.5

WATER BALANCE DIAGRAM

Process Description of Effluent Treatment Plant

Effluent generated during manufacturing process and other utility operations shall be sent to inhouse MEE plant followed by biological plant and RO plant. Permeate water from RO plantshall be recycle and reused back within plant premises and RO reject water shall be

againsent back to MEE plant. Captive MEE:

For Captive MEE facility, effluent first will be collected in collection tank. Such two collection tanks are provided. In each collection tank before sending effluent for further treatment,

Limesolution / caustic lye is added for neutralization. Once one batch of collection tank isneutralized effluent is fed to inlet of settling tank. Here precipitated mass is allowed to settleunder gravity. Clear supernatant is collected in MEE feed tank. Sludge from settling tank is

dewatered through filter press. Effluent from MEE feed tank is transferred to multiple effect evaporation system. Hereeffluent is evaporated in forced circulation multiple effect evaporator byconcentrating it from 1% solid

content to 30% solid content. Concentrated mass is further subjected to evaporation in ATFD / Pusher centrifuge system where salt is recovered at thebottom. Evaporated mass obtained as condensate from MEE system is collected in condensate storage tank. It is expected that

evaporated mass will have very less concentration of low volatiles though condensate can have COD/BOD in range of 1500 / 500 mg/lit which needs further polishing treatment for reuse in process.

Condensate such obtained is subjected to biological treatment using Activated Sludge Processin aeration tank. Aeration Tank mixed liquor is fed to secondary settling tank for separation of

biomass. Clean liquor is then collected in treated waste water storage tank. Biomass is recycled back to aeration tank. At regular interval biomass is wasted as side stream and subjected to dewatering along with primary sludge.

Treated wastewater after aeration tank is subjected to treatment through RO plant for providing polishing treatment. Since TDS level of condensate is expected to be in range of 500-1000 mg/l,

RO recovery of more than 90% is achieved in RO plant. RO reject is fed back to MEE feed tank for treatment. RO Permeate is recycled back to plant for reuse mainly as utility water in cooling tower and boiler application.

It is also to note that, lab scale treatability study was carried out for the finalization of

treatment scheme of the effluent and based on that only, the ETP scheme has been proposed.

Stagewise charactristics of the effluent is given in the table below.

CHAPRACTERISTICS OF WASTEWATER

Parame ter

Unit

Concentr ated

Stream Characte

ristics

Effluent Characteri stics After

MEE Treatment

Reduct ion (%)

Effluent Characteri stics After Biological Treatment

Reduct ion (%)

Effluent Characteri stics After

RO Treatment

Reduct ion (%)

pH - 2.5 6.6 - 7.1 - 7.2 -

COD mg/l 34561 3456 90 691 80

BLOCK DIAGRAM FOR EFFLLUENT TREATMENT PLANT

Effluent flow: 30 KL/Day + 4 KL/Day from RO reject

Capacity of ETP: 35 KL/Day

LIST OF EFFLUENT TREATMENT PLANT UNITS (CONCENTRATED STREAM)

Sr. No.

Equipments Nos. of Units Brief Specification

1 Collection Tank 2 Type: Circular Capacity: 25 m3 RCC Tile line

2 Dosing Tank (pH CorrectionSystem)

2 Capacity: 500 Litres MOC: HDPE circular tank

3 Neutralization Tank 2 Type: Rectangular tank Capacity: 25 m3 RCC Tile line

4 Stripper 1

Feed rate: 2 KL/hr (based on 20 hrs operation) Heating medium: Dry saturated steam

at 5 kg/cm2(g) Steam Temperature: as per saturated steam condition

MOC of major parts All HT tubes: Ti (Grade 2) Tube sheet: SS316

Bottom Dish End, Liquid piping, liquid vapor separator (Where liquid is in contact): SS316

Vapor contact part: SS304

5 MEE with ATFD 1

Cap: 3 m3/hr

Treatment Scheme: 1. Tripple stage forced circulation 2. Tripple stage evaporator followed by

ATFD/Centrifuge for removal of salts Utility:

Steam at 5 kg/cm2g Cooling water at 32 deg C

MOC of major parts: All tubes: SS316 L Ti/Ti Vapor line: SS316L

Shell side: SS316L Circulation Line: SS316L

Inlet parameter:

Sr. No.

Equipments Nos. of Units Brief Specification

pH:7-8 (On line pH correction to be provided) Inlet Salts: 15-20 % by wt

6 Biological treatment 1

Aeration Tank: Cap: 2 m3/hr Retention time: 18 Hr

RCC Circular tank with epoxy paint Secondary Lamella: Cap: 2m3/hr MOC: MS Lined

7 Intermittent storage tank 1

Type: RCC Circular tank Diameter: 6 m

Height: 1.5 m + 0.5 m free board Volume: 56.52 m3 MOC : RCC with Epoxy lining

8 Dual Sand Filter 1 Capacity: 2 m3/hr

9 RO Plant 1

Capacity: Feed 34 m3/day Feed Flow rate: 2 m3/hr based on 20

hours/day operation Inlet Parameter

PH: 7 to 7.5 COD: < 250 mg/lit TDS: < 1000 mg/lit

Suspended solids: 70 mg/lit Design Parameter

Pre-treatment: RO plant with spiral tube module, then pre-treatment should consist of PSF, MF and UF for bringing

down SS and Turbidity at the inlet of RO Plant. Acid Dosing, SMBS and Antiscalent

dosing shall be provided in RO Plant. Recovery: 85 % Salt Rejection: 90-92 %

10 Treated water storage tank

1

Type: RCC Circular tank Diameter: 6 m Height: 1.5 m + 0.5 m free board

Volume: 56.52 m3 MOC : RCC with Epoxy lining

Sr. No. Query Reply

3

Proposed Green belt development program along-with time line and budgetary allocation needs to be

provided (40 % Green belt as per Ministry’s office memorandum 31st October, 2019)

Total area of the project site is 2010 m2 (0.201 hac.). Out which 805 m2 area shall be used for green belt development which

is 40 % of the total area.Plant layout is attached as Annexure 3.

However, it is to inform you that,due to some technical error while doing online application, we were not able to change

the detailson portal regarding total plot area.The actual area of the project site is 0.201 hac. (2010 m2) which is mentioned

in EIA report. Moreover, land possession documents are also attached as Annexure 4.

Also Plant layout and land area break up is given as under:

LAND AREA BREAK-UP

Sr. No.

Description Area (m2) % of Land Use

1 Manufacturing Area-1 135.5 6.7

2 Manufacturing Area-2 144.4 7.2

3 Raw Material Storage Area-1 43.2 2.1

4 Raw Material Storage Area-2 48.6 2.4

5 Hazardous Waste Storage Area 40.5 2.0

6 Final Product 49.9 2.5

7 ETP Area 43.2 2.1

8 Utility Area 30.6 1.5

9 Office Area 66.3 3.3

10 Parking Area 20.8 1.0

11 Security 9.0 0.4

12 Green Belt 805 40.0

13 Roads & Other Area 573 28.5

Total Site Area 2010 100.00

PLANT LAYOUT

Green Belt Development Plan and Budgetary Allcation

Unit has proposed to develop green belt in 805 m2 area which is 40 % of the total plot area. The tress shall be planted in three tiers pattern so as to ensure that the entire area

getscovered and ensure effective pollution abatement. For this, management shall ensurethat plantation of trees shall include mixture of lower, higher and middle canopy structure,which shall be mixed appropriately / proportionately / uniformly.

Indigenous species with fast growth are only selected or form the base of selection asGreen Belt can come in view as fast as possible.

The plantation shall also include fruit bearing trees/ species which shall be uniformlydistributed which shall act as dwelling place for Varity of birds and other fauna and

forma breeding ground for them. Care shall be taken to plant ample trees along the road side, boundary wall as well aswithin

the plant premises. It shall enable proper balance of atmosphere both outside thecampus by

absorbing noise and gaseous pollutants of the road side movement of vehiclesand also absorption of noise and emissions within the premises of the plant.

The non-structural actions shall be initiated with inception of commissioning stage andshall be implemented & practiced as routine throughout the project life.

As per the present project activities, it is recommended to raise the following plant species. Thesespecies can be also available near the forest department nurseries.

PLANTATION NEAR WASTE LANDS / RESERVE FORESTED AREAS / ROAD SIDE

Botanical name No.

of Trees Importance

Suggested planting Zone/

Direction

Trees

Ficusbenghalensis 10 Shade, foodfor birds Buffer zone Ficusracemosa 10 Edible fruits Buffer zone

Peltophorumpterocarpum 20 Shade Buffer zone Samaniasaman 100 Avenue tree Buffer zone Cassia fistula 50 Avenue tree Buffer zone Delonixregia 20 Avenue tree Buffer zone

Calophylluminophyllum 50 Shade, Medicinal Buffer zone Casuarina equisetifolia 100 Pulp andconstructionmaterial Core zone

Callistemon citrinus 50 Ornamentaltree Core zone Cocos nucifera 20 Fruits Buffer zone

Dendrocalamusstrictus 10 Bamboo Buffer zone Syzygiumcumini 10 Fruits Buffer zone

Tamarindusindica 10 Shade, fruits Buffer zone Tecomastans 20 Shade Buffer zone

Tectonagrandis 100 Shade, Wood Buffer zone Terminalia bellirica 50 Fruits, Shade Buffer zone Termineliachebula 20 Fruits, Shade Buffer zone

Botanical name No.

of Trees Importance

Suggested planting Zone/

Direction

Thespeciapopulnea 10 Shade Buffer zone Thevetianeriifolia 10 Shade Buffer zone Tremaorientalis 20 Shade Buffer zone Vitex negundo 100 Shade Buffer zone

Wrightiatinctoria 50 Shade Buffer zone Phyllanthus emblica 20 Fruits Buffer zone Pithecellobium dulce 20 Fruits Buffer zone

Plumeria alba 20 Shade Buffer zone

LIST OF TREES RECOMMENDED FOR PLNTATION WITHIN PLANT PREMISES

Sr. No. Botanical Name Site No Space Each Area (m2)

A B D E F G H=E*G

1 Polyalthia longifolia (Sonn.) A1 15 3x3 9 135

2 Azadirachta indica A.Juss A1 4 5x5 25 100

3 Leucaena leucocephala (Lam.) de A1 15 1x1 1 15

4 Terminalia catappa L A1 10 5x5 25 250

5 Thespesia populnea (L.) A1 3 3x3 9 27

6 Tecoma stans (L.) Juss. ex Kunth A2 3 2x2 4 12

7 Vitex negundo L A2 3 2x2 4 12

8 Pongamia pinnata (L.) Pierre A2 10 3x3 9 90

9 Cascabela thevetia (L.) A2 4 2x2 4 16

10 Melaleuca citrina (Curtis) A2 3 2x2 4 12

11 Nerium odoratum Lam A3,B 3 2x2 4 12

12 Bauhinia purpurea L A3 10 2x2 4 40

13 Caryota urens L. B 4 2x2 4 16

14 Roystonea regia (Kunth) O.F.Cook B 4 2x2 4 16

15 Plumeria alba L C 3 2x2 4 12

16 Ixora coccinea L C 10 2x2 4 40

Total 104 805

Preferred site of planting codes: A1: Tall trees towards boundary wall A2: Medium sized trees next row to A1 species

A3: Small trees next row to A2 species B: Near entrance gate and paths C: Garden centre and space provided for plantation

PROPOSED FINANCIAL BUDGET FOR THE GREEN BELT DEVELOPMENT (RS IN LAKHS)

Sr. No.

Component First Year

Second Year

Third Year

Fourth Year

Fifth Year

Total

1 Plant Seeds/Saplings 2.0 2.0 2.0 2.0 2.0 10.0

2 Pits and Watering 0.4 0.4 0.4 0.4 0.4 2.0

3 Regular Maintenance 0.4 0.4 0.4 0.4 0.4 2.0

4 Transportation 0.2 0.2 0.2 0.2 0.2 1.0

Grand Total 3.0 3.0 3.0 3.0 3.0 15.0

Sr. No. Query Reply

4

PP mentioned in-adequate incremental value for PM10 & PM2.5. Air Quality Impact Prediction mentioned (18.1 of form 2) is

inadequate kindly correct it.

Assessment of incremental ground level concentration of PM10, PM2.5, SO2, NOX and NH3 is provided below using

software AERMODCloud Version 18.1 (Build: 36) developed by M/S. Envitrans Consultancy Services.

AERMODCloud is an integrated graphical userinterface of AERMOD, ISCST3, AERMAP and AERMET.

Details of predicted emission from proposed stack are given in following table.

Sr. No.

Operating Parameters

Unit

Source of Emission

Stack Attached To Process Vent Attached To

Boiler (Stack 01)

Thermopack

Unit (Stack 02)

D.G.Set Reactor

(Stack 03)

1 Stack height m 33 12 20

2 Diameter m 0.3 0.1

3 Flue gas

temperature K 423 353 323

4 Air Pollution

Control

Equipment

As Natural Gas is Proposed as a Fuel 33 M Stack Height

Shall be Provided

12 m Stack

Height

Two Stage Ammonia

Scrubber

5 Flue Gas Velocity

m/sec 9.06 - 7

6 Flow Rate Nm3/Hr 1623.90 - 182.50

7 Emission

Concentration

PM10 mg/m3 80* -

PM2.5 mg/m3 40* -

SO2 mg/m3 209.4* -

NOX mg/m3 75.2* -

NH3 mg/m3 - - 140*

8 Emission Rate

PM10 g/sec 0.03609 -

PM2.5 g/sec 0.01804 -

SO2 g/sec 0.09446 -

NOX g/sec 0.03395 -

NH3 g/sec - - 0.00710

(* Permissible Limits for Critically Polluted Area)

MODEL ISOPLETHS AND MAXIMUM INCREMENTAL GROUND LEVEL CONCENTRATIONS

Isopleths plots for the parameters – PM10, PM2.5, SO2 and NOX, NH3 for proposed scenario are given in below figures.

FIGURE 1 – ISOLPLETHS PLOT FOR PM10

Interpretation: Maximum incremental Ground Level Concentration for PM10 is 0.08 μg/m3 at X: 278035 m and Y: 2334129 m at 600 m distance in East direction from source of emissionas

shown in above Figure 1.

FIGURE 2 – ISOPLETHS PLOT FOR PM2.5

Interpretation: Maximum incremental Ground Level Concentration for PM2.5 is 0.03 μg/m3 at X: 278135 m and Y: 2334129 m at 700 m distance in East direction from source of emission as


FIGURE 3 – ISOPLETHS PLOT FOR SO2

Interpretation: Maximum incremental Ground Level Concentration for SO2 is 0.13 μg/m3 at X: 278135 m and Y: 2334129 m as at 700 m distance in East direction from source ofemission


FIGURE 4 – ISOPLETHS PLOT FOR NOX

Interpretation: Maximum incremental Ground Level Concentration for NOX is 0.05 μg/m3 at X: 278135 m and Y: 2334129 m at 700 m distance in East direction from source of emissionas


FIGURE 5 – ISOPLETHS PLOT FOR NH3

Interpretation: Maximum incremental Ground Level Concentration for NH3 is 0.06 μg/m3 at X: 277635 m and Y: 2334129 m at 200 m distance in East direction from source of emission as


MAXIMUM INCREMENTAL GROUND EVEL CONCENRATION

Sr. No. Parameters Maximum GLC (μg/m3) Distance and Direction

1 PM10 0.08 700 m in E

2 PM2.5 0.03 700 m in E

3 SO2 0.13 700 m in E

4 NOX 0.05 700 m in E

5 NH3 0.06 200 m in E

Sr. No. Query Reply

5 In form 2 w.r.t. exemption of PH, copy of notified industrial are document needs to

be uploaded.

Proposed new project is proposed at Plot No. 719, Road No. 7, Sachin GIDC,

Taluka - Chorasi, District - Surat, Gujarat which is located in Notified Industrial Estate (Sachin GIDC). Thus,

Public Hearing is not applicable. Notification documents for Notified Industrial Estate is attached as

Annexure 5.

6

Details of Raw material and its linkage and its mitigation measure during

transportation needs to be submitted (13.1 of form 2).

Details of Raw materials and its linkage along with mitigation measusres during transportation are mentioned below.

Sr. No.

Name of Raw Material Physical

State Consumption

(MT/Year) Suggested Source Storage

Mode of Transportation

BP °C MP °C

1 Acetic Acid Liquid 104.8 Pioneer Chemicals,

Surat Tanks Road 118.1 16.6

2 Ammonia Liquid 3736.6 Ganesh Traders,

Surat Tanks Road - -

3 Benzoic Acid Solid 822.2 Imported from

abroad HDPE Bags

Road 249.2 122.4

4 Benzoyl Chloride Liquid 423.5 Open Market,

Sachin Tanks Road 198 -1

5 Dilute Nitric Acid Liquid 4206 Shivam Products,

Ankleshwar Tanks Road 82.6 (-41.6)

6 Dilute Sulphuric Acid Liquid 832.6 Niken Traders,

Pandesara Tanks Road 119 10.49

7 Hydrochloric Acid Liquid 11024.2 A B Chemicals, Vapi Harsidhi Chemicals,

Vadodara Tanks Road 108.58 (-62.2)

8 Iron Powder Solid 6860.6

Texchem Industries, Ahemedabad

Thacker Pulverizing

Co., Rajkot

HDPE Bags

Road 3000 1535

9 Meta Phenylene Diamine 4 Sulfonic

Acid (MPDSA) Solid 300

Imported from abroad

HDPE Bags

Road 284 62

10 Methanol Liquid 205.7 Open Market,

Sachin Tanks Road 64.7 -97.8

11

NaOH (Caustic Lye)

Liquid 205.9

A B Chemicals, Vapi Shivam Products,

Ankleshwar

Tanks

Road

1388

323

12 Nitric Acid Liquid 2422.7 Shivam Products,

Ankleshwar Tanks Road 121 (-41.6)

13 Ortho Amino Phenol (OAP) Solid 180 Imported from

abroad HDPE Bags

Waterways NA 172

Sr. No.


State Consumption



BP °C MP °C

14 Ortho Di Chloro Benzene (ODCB) Liquid 2800.8 Panoli

Intermediates, Panoli

Tanks Road 180 (-17.6)

15 Ortho Nitro Chloro Benzene Para

Sulfonic Acid (ONCBPSA) Solid 727.2

Shri Arihant Dye-Chem, Sachin

HDPE Bags

Road NA NA

16 p- Nitrobenzoyl chloride (PNBC) Solid 840 Transpek Industries, Vadodara

HDPE Bags

Road 202 70

17 p- Nitrobenzoyl chloride (PNBC) Solid 840 Jainik Industries,

Ahemedabad HDPE Bags

Road 205 74

18 Para Nitro

Toluene Ortho Sulphonic Acid (PNTOSA)

Solid

840 Imported from

abroad HDPE Bags

Waterways

500

92

19 p-Nitro Toluene (PNT) Liquid 727.2 Aarti Industries

Ltd., Vapi Tanks Road 240 53

20 p-Nitrobenzoic acid (PNBA) Solid 840 Chemcrux

Enterprises Ltd., Ankleshwar

HDPE Bags

Road 270 221

21 Polycyclohexylenedimethylene

terephthalate (PCT) Solid 1522.9

Imported from

abroad

HDPE

Bags Waterways NA 285

22 p-Phenylenediamine (PPD) Solid 476.5 Imported from

abroad HDPE Bags

Waterways 267 146

23 Soda Ash Solid 4972.8 Ramesh Trading

Co., Surat HDPE Bags

Road 1600 851

24 Sodium Methoxide Liquid 36 Open Market,

Sachin Tanks Road 5 93

25 Sulphuric Acid Liquid 120 Niken Chemicals,

Pandesara Tanks Road 270 (-35)

26 Urea Solid 606 Amos Corporations,

Ahemedabad HDPE Bags

Road NA 132.7

Sr. No.


State Consumption



BP °C MP °C

27 2- Chloro 5- Nitro Benzene Sulfonic

Acid (PNCBOSA) Solid 300

Open Market, Sachin

HDPE Bags

Road NA NA

28 2-Acrylamido-2-methylpropane

sulfonic acid (APMS) Solid 270

Open Market, Sachin

HDPE Bags

Road NA NA

29 2-Chloro-5-Nitrobenzoic Acid Solid 105.2 Chemcrux

Enterprises Ltd., Ankleshwar

HDPE Bags

Road NA 142

30 2-Methyl-2,4-pentanediol (MPD) Liquid 176.5 Open Market,

Sachin Tanks Road 197 -40

31 2-Methyl-6-nitrobenzoic anhydride

(MNBA) Solid 840

Chemcrux Enterprises Ltd.,

Ankleshwar

HDPE Bags

Road NA 108

32 3,5-Dinitrobenzoic Acid (DNBA) Solid 412.6 Ankur Chemicals,

Rajasthan HDPE Bags

Road NA 206

33 3-Nitro Benzoic Acid Solid 412.6 Shree

Chemopharma, Ankleshwar

HDPE Bags

Road NA 140

MITIGATION MEASURES DURING TRANSPORTATION

It is proposed to use plastic cover sheet while transporting raw materials. All safety & control measures shall be provided to prevent spill, leakand accident during transportation.

Safety Precautions during Transportation of Raw Materials by Road

Training shall be given to driver and cleaner regarding the safe driving, hazards of chemicals, emergency handling, and use of Self contained breathing apparatus (SCBA) sets.

TREM card shall be kept with Tanker/Lorry. SCBA set shall be kept with Tanker/Lorry. Fire extinguishers shall be kept with Tanker/Lorry. Flame arrestor shall be provided to Tanker/Lorry exhaust. Hazard Identification symbol and emergency telephone number shall be displayed as per

HAZCHEM CODE. Appropriate PPEs are kept with Tanker/Lorry.

In case of leak or spill:

Source of leakage shall be checked. Damaged containers or spilled material shall not attended without wearing appropriate

protective clothing. Leak shall be stopped, if possible to do so without risk. Combustibles (wood, paper, oil, etc.) shall be kept away from spilled material.

Safety Precautions during Unloading of Chemicals from Tanker/Truck

Priority shall be given to Tanker/truck to immediately enter the storage premises at site and shall not be kept waiting near the gate or the main road.

Security person checks License, TREM CARD, Fire extinguisher condition; SCBA set condition, Antidote Kit, required PPEs as per Standard Operating Procedure (SOP) laid down.

Following precautions are taken during unloading:

Wheel stopper shall be provided to Tanker/Lorry at unloading platform. Static Earthing shall be provided to road tanker. Tanker unloading procedure shall be followed according to check list and implemented

strictly. Flexible SS hose connection shall be done at Tanker/Lorry outlet line. Only day time unloading shall be permitted.

Safety Precautions during Chemical Trasfer from Storage Areas to Process Plant

Double mechanical seal type FLP type pump shall be provided. Flame arrestor with breather valve shall be provided on vent line. Lightening arrestor is provided on the top of tallest structure.

Over flow system shall be provided for additional safety and it is connected to main storage tank.

NRV’s shall be provided on pump discharge line. Double Jumper clip shall be provided to all solvent handling pipelines.

WAYS TO MINIMIZE THE MANUAL HANDLING OF THE HAZARDOUS CHEMICALS

1. Fork liftswill be used for unloading chemical barrels/carboys, their movements within

plant, handling carboys, bulk chemical bags, etc.

2. Cranes, hoists, pallet trucks, conveyors, etc. are used as per the requirement, to eliminate manual handling.

3. Lifting tools & tackles are used, wherever required. 4. SOPs, work instructions are prepared and followed. 5. Trainings are provided to relevant staff, operators, workers for the risk associated with

manual handling of hazardous chemicals, ways to overcome those risk, etc.

Sr. No. Query Reply

7

TOR compliance is not adequate in

EIA/EMP report and need to revise as per the terms of reference granted for the project, and shall conform to Appendix III

of the EIA Notification, 2006.

Noted. Revised ToR compliance has been attached to EIA/EMP report. Same is attached in Annexure 6.

8

In form 2 Sr. No. 33, the benefit of project mentioned by PP, “Amendment in EC of

Mineral Addition & Amendment in EC Production & EC Transfer for Quartz, Feldspar and Granite mining project of M/s.

Shri Shyam Minerals is situated at near village - Ratanpura, Tehsil – Masuda, District – Ajmer, Rajasthan is of utmost

importance to the area for interest of mineral development and improves the socio-economic conditions of the local

habitants. The operation of the proposed project of Quartz, Feldspar and Granite mining will pass on various social and

economic ben“. Consultant has copied and paste the details for some other project and even do not consider to recheck before

submitting the documents in parivesh portal.

Benefits due to project activities are

mentioned as under: Social: Proposed proect will generate

direct/indirect employments to the local/near by area/villages. CER activities will improve the quality of

nearby villagers as their need will be fulfilled.

Financial: As products will also be exported to other countries, there will be benefit to

the country due to taxation. No. of Employments to be

generated: 45 (7 Skilled, 10 Semi-skilled and 28 un-skilled)

Sir, it is to inform that, technical error is happening during online submission

of proposal. Due to technical error, while uloading EIA/EMP report we were not able to change some details. Online

portal was not allowing to modify the same.

9

In view of the above, PP/Consultant are

requested to revise the application for grant of EC and accordingly revise the Form 2 along with EIA/EMP Report. The EIA/EMP

Report shall match with the information as filled in Form 2. On examination it is observed that the Consultant has not

adequately submitted the application as per the provisions of the EIA Notification, 2006. Consultant has to read the documents

before uploading the information in Form 2/EIA/EMP report.

With above changed, application has been revised. Revised Form-2 with

updated details are mentioned in Annexure 7.

Also EIA report has been revised considering the above changes and uploaded online.

Annexure 1

Compliance of MoEF Circular for CPA

(Critically Polluted Area) and SPA (Severely

Polluted Area) dated 31st October 2019.

Compliance of Mechanism for Environmental Management of

Critically Polluted Area (CPA) and Severally Polluted Area (SPA)

Reference: OM F. No. 22-23/2018-IA.III (Pt.) dated: 31st October, 2019

Environm

ent Mitigation Measures Compliance

Air Stipulation of Conditions Such as:

i. Stack emission levels should be

stringent than the existing

standards in terms of the identified

critical pollutants.

Noted and shall be complied. Unit

has proposed to provide adequate

Air Pollution Control Measures for

flue gas and process gas emission to

achieve the norms as mentioned and

revised in CPA.

Flue gas emission and its proposed

air pollution control measures are

mentioned below:

⚫ Unit has proposed to use

natural gas as a fuel for Boiler

(2 MT/Hr) and Thermopack

(200 U). Unit will provide 33 m

common stack for Boiler &

Thermopack as natural gas is

proposed as fuel.

⚫ LDO shall be used for D.G. Set

having capacity of 125 KVA.

However, it will be used only

during the emergency power

cutoff.

Process gas emission and its

proposed air pollution control

measures are mentioned below.

⚫ Two stage ammonia scrubbers

shall be provided to control

emission of VOCs and NH3.

More details are provided in EIA

report Chapter – 2.

ii. CEMS may be installed in all Continuous Emission Monitoring

large/medium red category

industries (air polluting) and

connected to SPCB and CPCB

server.

System will be installed and

connected with GPCB/CPCB Server.

iii. Effective fugitive emission control

measures should be imposed in the

process, transportation, packaging

etc.

Complied.

Unit has proposed to use natural gas

a fuel for boiler (2 MT/Hr) and

Thermopack (200 U).

iv. Transportation of materials by

rail/conveyor belt, wherever

feasible.

Unit will prefer the transportation of

the materials through rail whenever

it is possible. Manual handling will

be utilized in minimum activities.

v. Encourage use of cleaner fuels (pet

coke/ furnace oils/ LSHS may be

avoided.)

Noted. Unit has proposed to use

natural gas a fuel. LDO will be used

in DG Set and which shall be used

only during emergency power cutoff.

vi. Best Available Technology may be

used. For example, usage of

EAF/SAF/IF in place of cupola

furnace. Usage of supercritical

technology in place of sub-critical

technology.

Unit will comply the condition and

use best available technology to

increase yield and minimize quantity

of waste. Unit has also explored the

technology of continuous reactor

process in place of batch process for

their some of the products to

maximize the yield and minimize the

pollution.

vii. Increase of Green belt cover by

40% of the total land area beyond

the permissible requirement of

33%, wherever feasible.

Complied. Unit has proposed to

develop 40 % green belt within the

plant premises. However, there is

existing structure available at the

project site. Unit will modify it

according to the need.

viii. Stipulation of greenbelt outside the

project premises such as avenue

plantation, plantation in vacant

areas, social forestry, etc.

Unit has proposed to develop 40 %

green belt within the plant premises.

Total area of the project site is 2010

m2. And area proposed for the

green belt development is 805 m2.

ix. Assessment of carrying capacity of

transportation load on roads inside

the industrial premises. If roads

required to be widened, shall be

prescribed as a condition.

Project location is in well-established

GIDC of Sachin having adequate

infrastructure facilities. Unit has also

proposed to provide 4 m wide road

within the plant area.

Water Stipulation of Conditions Such as:

i. Reuse/Recycle of treated

wastewater, wherever feasible.

Unit has proposed ZLD system for

wastewater management. Entire

effluent generated from industrial

activity shall be send to inhouse MEE

plant followed by biological

treatment and RO plant. RO

permeate water shall be reused

within plant premises itself. And RO

reject water shall be again sent back

to MEE plant.

ii. Continuous Monitoring of effluent

quality/ quantity in large and

medium red category industries

(water polluting).

Noted and unit will comply the

condition as per standards.

Unit will install flow meters as inlet

and out of ETP. Regular monitoring

will be carried out to check the

quality of effluent. Unit will provide

COD, pH sensor at final outlet for

continuous analysis.

iii. A detailed water harvesting plan

may be submitted by the project

proponent.

Water Harvesting plan is provided in

EIA report Chapter – 2.

iv. Zero Liquid Discharge wherever

techno-economically feasible.

Unit has proposed Zero Liquid

Discharge for wastewater

management.

Total water requirement is 45

KL/Day. Out of which unit will

recycle and reuse 23 KL/Day water

through MEE plant followed by

biological treatment and RO plant.

Thus, fresh water demand shall be

reduced to 22 KL/Day.

Domestic wastewater shall be

disposed through septic tank/soak

pit system.

v. In case, domestic waste water

generation is more than 10 KLD,

Industry may install STP.

Domestic waste water generation

shall be 4.5 KLD and shall disposed

through septic tank/soak pit.

Land Stipulation of Conditions Such as:

i. Increase of Green belt cover by

40% of the total land area beyond

the permissible requirement of




33%, wherever feasible. m2. And area proposed for the


ii. Stipulation of greenbelt outside the

project premises such as avenue

plantation, plantation in vacant

areas, social forestry, etc.




m2. And area proposed for the


iii. Dumping of waste (fly ash, slag,

red mud, etc.) may be permitted

only at designated locations

approved by SPCBs/CPCBs.

Unit will send Hazardous waste to

approved TSDF site only.

All the waste will be disposed of as

per Solid and hazardous waste

management.



iv. More stringent norms for

management of hazardous waste.

The waste generated should be

preferably utilized in co-processing.

Noted.

The details for management of

hazardous waste are provided in EIA


Other

Condition

(Additional)

Stipulation of Conditions Such as:

i. Monitoring of compliance of EC

conditions may be submitted with

third party audit every year.

Noted. Unit shall Comply the

condition.

ii. The % of CER may be at least 1.5

times the slabs given in OM dated

01.05.2018 for SPA and 2 times for

CPA in case of Environment

Clearance.

The unit has proposed to spend

nearly ₹ 37,00,000/- Budget (4 %

of the total cost ₹ 9.25 Crores) for

social development programs under

CER activities for the next 5 years.



Annexure 2

Treatability Study Report

ENPRO Enviro Tech and Engineers Pvt. Ltd.

Treatability Study Report for M/s. Orgo Chem (Guj.) Pvt. Ltd.

INTRODUCTION

Orgo Chem (Guj) Pvt. Ltd. is proposing to set up a new manufacturing unit of dye intermediate and specialty chemical products @ 170.5 MT/Month at Block No. 719, Road No. 7, Sachin GIDC, Surat, Gujarat. Unit has purchased entire plot with existing infrastructure having constructed building and other utilities. Total generated industrial waste water 30 KL/Day shall be treated in proposed MEE plant. Industrial effluent shall be sent to inhouse MEE plant followed by biological treatment and RO plant. RO permeate water shall be reused within plant premises itself and RO reject water shall be again sent back to MEE plant. 1) Concentrated effluent stream – 30 KL/Day A detailed treatability study is carried out to identify optimum dosing of various treatment chemicals.

1. FOR CONCENTRATED EFFLUENT STREAM Effluent generated during manufacturing process and other utility operations shall be sent to inhouse MEE plant followed by biological plant and RO plant. Permeate water from RO plant shall be recycle and reused back within plant premises and RO reject water shall be again sent back to MEE plant. Characteristic of composite sample is given below:

TABLE 1 – EFFLUENT CHARACTERISTICS (CONCENTRATED STREAM)

No. Parameter

Composite Sample (Considering Worst Case

Scenario)

1 pH 2.5

2 COD, mg/l 34561

3 BOD, mg/l 11234

4 Total Dissolved Solids, mg/l 44895

5 Suspended Solids, mg/l 986

LABORATORY TREATABILITY STUDIES Laboratory scale pilot study was carried out on the composite effluent having characteristics as mentioned in Table 4. A summarized result of study is reported in this section. Distillation Initially sample was neutralized using caustic for further distillation treatment. Lab scale analysis was done for distillation process. Initially 500 ml of sample was treated through distillation at control temperature in the range from 50 ℃ to 80 ℃. Further to this, the same flask was further heated at 105 ℃ and distillate was collected and analysed to check the parameters of the sample. Summary of the result is tabulated herewith in Table 2.

ENPRO Enviro Tech and Engineers Pvt. Ltd.

Treatability Study Report for M/s. Orgo Chem (Guj.) Pvt. Ltd.

TABLE 2 – SUMMARY OF DISTILLATION PROCESS

Parameters Run 1 Run 2

Volume of sample, ml 500 500

TDS (mg/lit)

Influent (KL) 44895 44895

Effluent (KL) 1347 449

% removal 97 99

BOD (mg/lit)



% removal 91 94.3

COD (mg/lit)



% removal 85.3 90

OBSERVATION: Based on laboratory scale pilot plant study, following observations can be made, 1. Analysis of effluent sample from individual industries and composite sample suggest following ranges: a. pH – < 4 b. COD – 30000-35000 mg/l c. BOD – 75000-8750 mg/l d. TDS – 40000-45000 mg/l e. SS – 100-1000 mg/l 2. Initially neutralization was done to get pH in the range from 6.5 to 8.5 and further distillation was provided. After distillation at lab scale, it is observed that, Total dissolved solids level is reduced upto 99%, COD level is reduced up to 90 % and BOD level is reduced up to 94.3 %.

Annexure 3

Plant Layout

STATEMENT OF AREAS

S.N DESCRIPTION AREA (sq.m)

1

2

3

4

5

6

144.4

7

8

9

10

11

12

13

SECURITY 9.0

2010TOTAL SITE AREA

% OF LAND USE

MANUFACTURING AREA-1 135.5 6.7

7.2

43.2RAW MATERIAL STORAGE AREA-1 2.1

48.6

HAZARDOUS WASTE STORAGE AREA 2.0

2.4

40.5

FINAL PRODUCT 2.549.9

UTILITY AREA 1.530.6

28.5573

GREEN BELT 40.0805

0.4

PARKING AREA 20.8 1.0

ROADS & OTHER AREA

100.00SECURITY

3 m x 3 m

GATE

PARKING AREA

7.7 m x 2.7 m

MANUFACTURING AREA - 1

13.5m x 10m

OFFICE AREA

8.5 m x 7.8 m

MANUFACTURING AREA - 2

19 m x 7.6 m

UTILITY

AREA

9.3 m x

3.3 m

ETP

AREA

13.1 m x

3.3 mRAW MATERIAL

STORAGE AREA-1

9 m x 4.8 m

RAW MATERIAL

AREA-2

10.8 m x 4.5 m

HAZ. WASTE

STORAGE AREA

9.0 m x 4.5 m

FINAL PRODUCT

STORAGE AREA

11.1 m x 4.5 m

4 m WIDE ROAD

4 m

WID

E R

OA

D

4 m

WID

E R

OA

D4 m

WID

E R

OA

D

MANUFACTURING AREA-2

RAW MATERIAL STORAGE AREA-2

ETP AREA 2.143.2

OFFICE AREA 3.366.3

GATE

RAIN WATER

HARVESTING

Annexure 4

Land Possession Documents

Scanned by CamScanner

Annexure 5

Notification of Sachin GIDC

Date: 08/04/2020 To,

The Member Secretary, Expert Appraisal Committee, (Industrial Projects - II), Ministry of Environment, Forest and Climate Change, Indira Paryavaran Bhavan,

Jor Bagh Road, New Delhi - 110 003

Subject: Public hearing is exempted for Orgo Chem (Guj.) Pvt. Ltd. located at Plot No. 719,

Road No. 7, Sachin GIDC, Surat, Gujarat.

Dear Sir,

With reference to above subject, proposed new project location for Orgo Chem (Guj.) Pvt.

Ltd. is in Notified Industrial estate, Sachin GIDC. Due to the same public hearing is not applicable for this project.

Thanking You.

Enclosure:

Notification of Sachin GIDC

Annexure 6

Revised ToR Compliances

Sr. No.

Standard Terms of References Compliances

1 Executive Summary Orgo Chem (Guj) Pvt. Ltd. is proposing to

set up a new manufacturing unit of dye intermediate and specialty chemical products @ 170.5 MT/Month at Plot No. 719, Road No. 7, Sachin GIDC, Surat, Gujarat.

Proposed project shall be located in 2010 m2 area. In which, 805 m2 (40 % of the total plot area) shall be allotted to green belt

development. Total water requirement for the proposed project is 45 KL/Day which shall be sourced from Sachin GIDC. Total wastewater

generation shall be 34.5 KL/Day. Unit will recycle and reuse 23 KL/Day water from MEE plant.

Total power requirement shall be 200 KVA

which shall be sourced from DGVCL. Total employment generation due to

proposed project shall be 45. Capital cost for the Environmental Management Plan (EMP) will be Rs. 288 Lakhs.

Recurring cost for the Environmental Management Plan (EMP) will be 146.1 Lakhs.

Funds for the Corporate Environment Responsibility (CER) will be Rs. 37 Lakhs. Total capital cost of the project is Rs. 9.25 Crores.

2 Introduction

I. Details of the EIA Consultant including NABET accreditation

EIA Consultant Name:

ENPRO Enviro Tech and Engineers Pvt. Ltd. Certificate No.:

Sr. No.


NABET/EIA/1922/RA 0122 valid till 12th

January, 2022 Approved Sectors and Category:

1. Metallurgical industries (ferrous & non-

ferrous) - Cat. A 2. Synthetic organic chemicals industry

(dye & dye intermediates; bulk drugs and intermediates excluding drug formulations; synthetic rubber; basic organic chemicals, other synthetic organic chemicals and chemical

intermediates) - Cat. A 3. Common hazardous waste treatment,

storage and disposal facilities (TSDFs) -

Cat. A

4. Common Effluent Treatment Plant

(CETPs) - Cat. B 5. Common Municipal Solid Waste

Management Facility (CMSWMF) - Cat. B

6. Bio Medical Waste Treatment Facilities -

Cat. B

7. Chlor alkali Industry - Cat. B

8. Isolated Storage and Handling of

hazardous chemicals - Cat. B 9. Cement Plants – Cat A

10. Power Plants – Cat. A

Contact Details: Email id: [email protected]

Contact: +91-81604-83760

mailto:[email protected]

Sr. No.


Address: 306, Royal Park, Nr. Deepa

Complex, Adajan Road, Surat, Gujarat – 395 009

II. Information about the project proponent

Orgo Chem (Guj.) Pvt. Ltd. is promoted by Mr. Paras Mehta who is having more than 25

years of experience in the field of chemical industry especially in Dye intermediate products. The promoter is already having a unit of dye intermediate products in Sachin GIDC which is under operation for more

than two decades. List of directors for the proposed project is given in Section 1.4 on page no. 1.2 in

chapter 1.

III. Importance and benefits of the project The global and local market for dye intermediates has been witnessing significant growth due to rising demand

from end-user industries. Based on this requirement, the company proposes to install a new plant which will benefit the country and region. Also, based on informal survey of the market with their existing

customers and various traders, company has found that there is a big potential for the range of the proposed products which will directly help to grow the market of Indian products worldwide.

More details are given in Section 1.5.1 on page no. 1.4 in chapter 1.

3 Project Description

I. Cost of project and time of completion. Total cost for the proposed project is Rs. 9.25 Crores. CA Certificate is attached as Annexure V. Proposed Project activities are

likely to start after getting Environmental Clearance from EAC, Delhi and NOC/CTE from GPCB.

Proposed schedule for approval and implementation is given in Section 2.5 on page no. 2.11 in chapter 2.

II. Products with proposed project. Production capacity of the proposed project will be 170.5 MT/Month.

Sr. No.


List of proposed products with their manufacturing capacity per month is given in Table 2.3 in Section 2.4 on page no. 2.4 in chapter 2.

III. If expansion project, details of existing products with capacities and whether adequate land is available for expansion,

reference of earlier EC if any.

Proposed project is new project. However, Company has purchased a land

with existing construction available within plot and they have proposed to modify the same as per requirement.

IV. List of raw materials required and their

source along with mode of transportation.

List of raw material required with quantity

and their source along with mode of transportation is given in Table 2.8 on page no. 2.19 in Section 2.6.1 in chapter 2.

V. Other chemicals and materials required with quantities and storage capacities

Other chemicals required for dosing in effluent treatment plant will be sourced from

local market and will be stored in raw material storage area. Unit has proposed to provide 71.8 m2 area for raw material storage.

VI. Details of Emission, effluents, hazardous waste generation and their management.

Air Pollution: Unit has proposed to install Boiler having capacity of 2 MT/Hr and Thermopack having capacity of 200 U. Unit has proposed natural

gas as a fuel for both utilities. Common stack with 33 m shall be provided to Boiler and Thermopack. D.G. Set having capacity of 125 KVA shall be

kept for emergency power back up. LDO (600 Liters/Day) will be used as a fuel for D.G. Set. Details for the same are given in Section 2.7

on page no. 2.22 in chapter 2. Wastewater Management:

Unit has proposed ZLD system for wastewater management. Total water requirement for the proposed project is 45 KL/Day (37 KL/Day for

Sr. No.


Industrial + 5 KL/Day for Domestic + 3

KL/Day for Gardening). Total wastewater generation is 34.5 KL/Day (30 KL/Day + 4.5 KL/Day Domestic).

Entire industrial wastewater (30 KL/Day) shall be send to stripper followed by MEE plant, biological treatment and RO plant. 23 KL/Day RO permeate water shall be reused

within the plant premises itself and RO reject water shall be again sent back to MEE plant. This way, fresh water demand for the proposed project shall be reduced to 22 KL/Day from 45 KL/Day.

Domestic wastewater (4.5 KL/Day) shall be disposed through septic tank / soak pit system.

Details for the same are given in section on page no. 2.23 in chapter 2. Hazardous waste management

Hazardous waste shall be disposed of to TSDF site / recyclable waste shall be sent to authorized recycler as per Hazardous Waste (Management, Handling and Transboundary Movement) Rules, 2016.

Details for the same are given in section on page no. 2.32 in chapter 2.

VII. Requirement of water, power, with

source of supply, status of approval, water balance diagram, man-power requirement (regular and contract)

Water Requirement:

Total water requirement for the proposed project is 45 KL/Day (37 KL/Day for

Industrial + 5 KL/Day for Domestic + 3 KL/Day for Gardening). Details for the same are given in section 2.8 on page no. 2.23 in chapter 2.

Water balance diagram is presented as Figure 2.2 on page no. 2.25 in chapter 2.

Sr. No.


Power Requirement: Total power requirement for proposed

project will be 200 KVA and shall be sourced from Dakshin Gujarat Vij Company Limited (DGVCL). To meet the emergency power requirement for critical operations

for ensuring safety, 01 D.G. Set having capacity 125 KVA will be kept as standby power back up.

Details of the same are given in Section 2.4.1.3 on page no. 2.8 in chapter 2.

VIII. Process description along with major equipments and machineries, process

flow sheet (quantitative) from raw material to products to be provided

Details of manufacturing process along with chemical reaction and mass balance is given

in Annexure I.

Details of major equipments are given in Table 2.5 in section 2.4.1.5 on page no. 2.9 in chapter 2. Unit will install Boiler (2 MT/Hr),

Thermopack (200 U) and D.G. Set (Stand By) (125 KVA). There shall be installation of RO plant, Stripper, MEE plant, biological treatment units in ETP.

IX. Hazard identification and details of

proposed safety systems.

Details of hazardous identification are given

in Section 7.2 on page no. 7.6 in chapter 7. Qualitative Risk Assessment has been carried out for the proposed project. In this,

risk has been analyzed using methodology called HIRA-Hazard Identification & Risk Assessment. In HIRA, major manual activities carried out by plant personnel as well as contract labors have been

considered. Qualitative risk assessment is given in section 7.2.1 on page no. 7.6 in chapter 7.

X. Expansion/modernization proposals:

Copy of all the Environmental Clearance(s) including Amendments

Not applicable as proposed project is new project.

Sr. No.


thereto obtained for the project from

MOEF/SEIAA shall be attached as an Annexure. A certified copy of the latest Monitoring Report of the Regional Office of the Ministry of Environment and Forests as per circular dated 30th

May, 2012 on the status of compliance of conditions stipulated in all the existing environmental clearances including Amendments shall be

provided. In addition, status of compliance of Consent to Operate for the ongoing existing operation of the project from

SPCB shall be attached with the EIA-

EMP report.

In case the existing project has not obtained environmental clearance, reasons for not taking EC under the

provisions of the EIA Notification 1994 and/or EIA Notification 2006 shall be provided. Copies of Consent to Establish/No Objection Certificate and Consent to Operate (in case of

units operating prior to EIA Notification 2006, CTE and CTO of FY 2005-2006) obtained from the SPCB shall be submitted. Further, compliance report to the conditions of consents from the

SPCB shall be submitted.

Not applicable as proposed project is new project.

4 Site Details

I. Location of the project site covering village, Taluka/Tehsil, District and

State, Justification for selecting the site, whether other sites were considered.

Proposed project shall be located at Plot no. 719, Road No. 7, Sachin GIDC, Surat,

Gujarat. Nearest town: Sachin (approx. 3 km) District: Surat

Nearest water body: Mindhola River (approx. 5.45 km (S))

Nearest High way: National Highway No. 53 (Old NH 6) (approx. 1.08 km (NE)) State Highway No. 6 (approx. 1.18 km (NE))

Sr. No.


Nearest railway station: Sachin railway station (approx. 2.45 km (SE)) Nearest airport: Surat airport (approx. 12.76 km (NW))

Note: Above distances are aerial distances.

More details are provided in Section 2.3 on page no. 2.1 in chapter 2. Justification for selecting the site:

The main reason behind selection of this site is availability of existing construction facility in the well-established in Sachin GIDC. So, there is no alternative site was examined for the proposed project.

More details are provided in section 5.1 on page no. 5.1 in chapter 5.

II. A toposheet of the study area of radius of 10 km and site location on 1:50,000/1:25,000 scale on an A3/A2

sheet. (including all eco-sensitive areas and environmentally sensitive places)

A toposheet of the study area of radius of 10 km and site location on 1:50,000/1:25,000 scale on an A3/A2 sheet is presented in Map

3.2 on page no. 3.37 in chapter 3.

III. Details w.r.t. option analysis for selection of site

Details about analysis of alternative site are given in section 5.1 on page no. 5.1 in

chapter 5.

IV. Co-ordinates (lat-long) of all four corners of the site.

Geographical location of the project site: Latitude: 21°5'41.00"N Longitude: 72°51'27.00"E

Coordinates of the boundary:

Point Latitude Longitude

A 21° 5'42.11"N 72°51'25.19"E

B 21° 5'41.69"N 72°51'27.56"E

C 21° 5'40.70"N 72°51'27.38"E

D 21° 5'41.05"N 72°51'25.07"E

- Specific Location of Site with Project

Sr. No.


Boundary is given in section 2.3.2 in on

page no. 2.3 in chapter 2.

V. Google map-Earth downloaded of the project site.

Specific location of the project site on google earth is given as Map 2.2 on page no. 2.3 in chapter 2.

VI. Layout maps indicating existing unit as well as proposed unit indicating storage area, plant area, greenbelt area, utilities etc. If located within an Industrial area/Estate/Complex, layout

of Industrial Area indicating location of unit within the Industrial area/Estate.

Total plot area of the project site is 2010 m2. Company has purchased a land with existing construction available within plot and they have proposed to modify the same as per requirement.

Area proposed for Green belt development is 805 m2 (40 m2 of the total plot area)

Manufacturing area shall be located in 279.9 m2, Raw material storage area shall be located in 71.8 m2, hazardous waste storage area shall be located in 40.5 m2,

final product storage area shall be located in 49.9 m2, ETP/MEE area shall be located in 43.2 m2, remaining area will covered utility area, office area, security, parking etc.

Plant layout is presented in Figure 2.2 and Annexure III. Area break up is presented in

Table 2.4 on page no. 2.8 in chapter 2.

VII. Photographs of the proposed and existing (if applicable) plant site. If existing, show photographs of plantation/greenbelt, in particular.

Photographs of the project site are showing in Figure 2.1 on page no. 2.6 in chapter 2.

VIII. Landuse break-up of total land of the project site (identified and acquired), government/private - agricultural, forest, wasteland, water bodies,

settlements, etc shall be included. (not required for industrial area)

Mostly area is covered with fallow land 33 %, water bodies are located in 10 %, mud area is located in 19 %, plantation is located in 4%.

Land use break up is presented in Table 3.14 in section 3.7.5.4 on page no. 3.54 in chapter 3.

IX. A list of major industries with name and type within study area (10km radius) shall be incorporated. Land use details of the study area

Project site is proposed within notified industrial area of Sachin GIDC, District: Surat. Sachin GIDC consist of approximately 65 textile processing industries,

approximately 45 different chemical manufacturing units and many numbers of textile weaving units. Most of the industries

Sr. No.


located within Sachin GIDC are small and

medium scale industries. Land use break up for the study area is presented in Table 3.14 in section 3.7.5.4 on page no. 3.54 in chapter 3.

X. Geological features and Geo- hydrological status of the study area shall be included.

Geographically, the Surat district belongs to the western coastlands of the Deccan peninsula. The area is mainly characterized by the alluvial plains comprising the flood

plains of the Tapi and Mindhola rivers. Geology The geological formations encountered in

the Surat district are of Quaternary alluvium, Tertiary limestone and sandstone, and Deccan Trap basalt.

Details of the same are given in section 3.9.5 on page no. 3.68 in chapter 3. Hydrology

The major aquifers in the study area are mainly formed by alluvium and Tertiary formations. The common ground water

abstraction structures are dug wells, dug- cum-bore wells and tube wells. The yields mainly depend on the recharge conditions. The depths of the wells in alluvium generally range from 3.0 to 20.0 and some even 25.0

m. Some of the dug wells have in-well bores down to >30 m. Depths to water levels in the area range from 0.5 to 15 m bgl about 90% wells shows water levels less than 10m bgl.

More details regarding the same is given in section 3.9.6 on page no. 3.70 in chapter 3.

XI. Details of Drainage of the project upto 5 km radius of study area. If the site is within 1 km radius of any major river, peak and lean season river discharge as well as flood occurrence frequency

The area is regionally dissected by perennial and intermittent rivers, streams and streamlets, and forming part of either Tapi or Mindhola River Systems comprising the flood plains deposits. The drainage pattern

Sr. No.


based on peak rainfall data of the past

30 years. Details of Flood Level of the project site and maximum Flood Level of the river shall also be provided. (mega green field projects)

in general is sub- dendritic. Both the rivers

merge west of the study area before culminating into the Arabian Sea. The Tapi is the major river which passes through the central parts of the district and flows towards the west. The river is perennial in

nature.

More details area given in section 3.9.4 on page no. 3.67 in chapter 3.

XII. Status of acquisition of land. If

acquisition is not complete, stage of the acquisition process and expected time of complete possession of the land.

Orgo Chem (Guj) Pvt. Ltd. has purchased a

land from M/s. Siddhnath Tradelink Pvt. Ltd. This was manufacturing different type of yarns and threads. However, units has shut down its facility and sell the plot having total area of 2010 m2 with existing building

constructed on 1300 m2 area to Orgo Chem (Guj.) Pvt. Ltd. Land documents mentioning the same is enclosed as Annexure II.

XIII. R&R details in respect of land in line

with state Government policy.

R&R is not applicable as proposed project

site is located in Notified Industrial Area (Sachin GIDC).

5 Forest and wildlife related issues (if applicable):

I. Permission and approval for the use of forest land (forestry clearance), if any, and recommendations of the State Forest Department. (if applicable)

Not applicable as proposed project site is located in notified industrial area (sachin GIDC). So, no forest or wildlife clearance is required as, wildlife sanctuary and national parks are not found within 10 km radius

from the project site.

II. Landuse map based on High resolution satellite imagery (GPS) of the proposed site delineating the forestland (in case

of projects involving forest land more than 40 ha)

Not applicable as there is no forest land is located within 10 km radius of the project site.

III. Status of Application submitted for obtaining the stage I forestry clearance

along with latest status shall be submitted.

Not applicable as there is no forest land is located within study area.

IV. The projects to be located within 10 km of the National Parks, Sanctuaries, Biosphere Reserves, Migratory Corridors of Wild Animals, the project

Not applicable. No National Parks, Sanctuaries, Biosphere Reserves, Migratory Corridors of Wild

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proponent shall submit the map duly

authenticated by Chief Wildlife Warden showing these features vis-à-vis the project location and the recommendations or comments of the Chief Wildlife Warden-thereon.

Animals are located in the study area.

V. Wildlife Conservation Plan duly authenticated by the Chief Wildlife Warden of the State Government for conservation of Schedule I fauna, if

any exists in the study area.

Not applicable

VI. Copy of application submitted for clearance under the Wildlife (Protection) Act, 1972, to the Standing

Committee of the National Board for Wildlife.

Not applicable

6 Environmental Status

I. Determination of atmospheric inversion

level at the project site and site-specific micrometeorological data using temperature, relative humidity, hourly wind speed and direction and rainfall.

Baseline motoring was carried out for the

period of 1st March, 2019 to 31st May, 2019 by NABL approved laboratory ENPRO Enviro Tech and Engineers Pvt. Ltd. (Environmental Laboratories).

Interpretation of micrometeorological data:

Wind Pattern: 24 hourly wind rose diagram for March to May and resultant vector of wind rose diagram indicates that the

predominant winds are from South – West to North - East direction with 36.75 % calm condition. Average wind speed is 1.06 m/s.

Temperature: During the month of March to May, temperature has varied in the range from 16 °C to 44 °C.

Relative Humidity: During the month of March to May, relative humidity has varied in the range from 16% to 89 %.

Details regarding the same are given in Section 3.4 on page no. 3.13 in chapter 3.

II. AAQ data (except monsoon) at 8 Ambient air quality monitoring was carried

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locations for PM10, PM2.5, SO2, NOX,

CO and other parameters relevant to the project shall be collected. The monitoring stations shall be based CPCB guidelines and take into account the predominant wind direction,

population zone and sensitive receptors including reserved forests.

out at eight monitoring locations during 1st

March, 2019 to 31st May, 2019.

Interpretation of the results:

Average concentration of PM10, PM2.5, Sox, NOx, CO and NH3 remains within the

stipulated standards of NAAQS [24 hrs.] at all the monitoring locations. While HC, VOC and PAH were not detectable at any monitoring locations.

Details regarding ambient air quality monitoring is given in section 3.5 on page no. 3.18 in chapter 3.

III. Raw data of all AAQ measurement for 12 weeks of all stations as per frequency given in the NAQQM Notification of Nov. 2009 along with -

min., max., average and 98% values for each of the AAQ parameters from data of all AAQ stations

should be provided as an annexure to the EIA Report.

Results of Ambient air quality is presented in Table 3.8 in section 3.5 on page no. 3.22 in chapter 3 along with min, max, average and 98 %. Hard copy of the same shall be made

available at the time of presentation.

IV. Surface water quality of nearby River (100m upstream and downstream of discharge point) and other surface drains at eight locations as per CPCB/MoEF&CC guidelines.

Surface water monitoring was carried out at six different location. In which, 5 were lake water samples and 1 is river sample.

Interpretation of the results: Surface water sources i.e. only Lakes and river water needs water treatment plant

before it is used as domestic purposes.

Details of surface water monitoring and its results is presented in section 3.3 on page no. 3.2 in chapter 3.

V. Whether the site falls near to polluted

stretch of river identified by the CPCB/MoEF&CC, if yes give details.

Not applicable.

VI. Ground water monitoring at minimum at 8 locations shall be included.

Ground water monitoring was carried out at seven different locations. Six samples were

collected from bore well and one sample is collected from hand pump.

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Interpretation of the results: Ground water can be used as drinking water as well as industrial water after obtaining

permission from CGWA and after relevant treatment.

Details of ground water monitoring and its results is presented in section 3.3 on page no. 3.2 in chapter 3.

VII. Noise levels monitoring at 8 locations within the study area.

Noise level monitoring was carried out at eight different location. One is at project site and others are village area. Interpretation of the results:

Noise level in the industrial area as well as residential area found within the stipulated norms of GPCB/CPCB/MoEF.

More details regarding the same is presented in Section 3.6 on page no. 3.25 in

chapter 3.

VIII. Soil Characteristic as per CPCB guidelines.

Soil quality monitoring was carried out at seven different locations.

Interpretation of the results: The pH of soil samples ranges from

Moderately alkaline to strongly alkaline. The cation exchange capacity of the soils is moderately contributed mainly by potassium exchangeable ions. The soil texture is predominantly clay loam.

More details are presented in section 3.7 on page no. 3.28 in chapter 3.

IX. Traffic study of the area, type of vehicles, frequency of vehicles for transportation of materials, additional traffic due to proposed project, parking arrangement etc.

It is predicted that, there are nearly 3 vehicles visits per day at project site due to proposed production activity. Detail regarding the transportation of the vehicles is presented in section 4.7.3 on page no.

4.22 in chapter 4.

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Unit has provided 20.8 m2 area for parking within the plant premises. And unit has also provided 4 m wide road within the plant with separate entry and exit for better movement of vehicles as shown in plant layout attached

as Annexure III.

X. Detailed description of flora and fauna (terrestrial and aquatic) existing in the study area shall be given with special

reference to rare, endemic and endangered species. If Schedule-I fauna are found within the study area, a Wildlife Conservation Plan shall be prepared and furnished.

The trees in the study area; were generally planted either as farmland plantation or homestead plantation or along the road

sides. Otherwise natural tree cover is very less in this part of Surat District. Homestead plantation was dominated by Tamarindus indica (Amali), Mangifera indica (Keri), Moringa oleifera (Sargavo), Ficus benghalensis (Vad), and Cocos nucifera (Narial). There is no notified/protected ecologically sensitive area including national park, sanctuary, Elephant/Tiger reserves or Schedule-I fauna existing in the study area

covering 10 km radial distance. Details on ecology and biodiversity are given in section 3.8 on page no. 3.45 in chapter 3.

XI. Socio-economic status of the study area.

The project area having a total of 24 villages and seven cities/towns in the radial distance of 10 km from the project site. The demographic profiles show huge deviation of the value from the average value of each

demographic variables and are largely concentrated among 14 villages only in the project area having radial distance of 10 km from the project sites.

The villages/towns within the 10 km from the project sites shows Public amenities like presence of Anganwadi center, Self Help

Group, Public/Private Transportation, Telephone/mobile, black toppled metal road, Govt. PHC/SC; Govt. Primary School; untreated tap water and regular power supply are present in almost 90%-100% of

villages. While other public amentias like presence of river and canal in 52% of the villages, and presence of Community

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Centers; existence of commercial bank,

presence of agriculture credit society, Total Sanitation Campaign and Govt. vocational training center – ITI ranges from 45% to 10% to the villages in the radial distance of 10 km from the project site.

More details are presented in section 3.10 on page no. 3.73 in chapter 3.

7 Impact and Environment Management

Plan

I. Assessment of ground level concentration of pollutants from the stack emission based on site-specific

meteorological features. In case the project is located on a hilly terrain, the AQIP Modelling shall be done using inputs of the specific terrain characteristics for determining the

potential impacts of the project on the AAQ. Cumulative impact of all sources of emissions (including transportation) on the AAQ of the area shall be assessed. Details of the model used

and the input data used for modelling shall also be provided. The air quality contours shall be plotted on a location map showing

the location of project site, habitation nearby, sensitive receptors, if any.

Assessment of incremental ground level concentration of PM10, PM2.5, SO2, NOX and NH3 is provided in this Section 4.7 using

software AERMODCloud Version 18.1 (Build: 36) developed by M/s. Envitrans Consultancy Services.

Results for Air Modelling:

PM10: 0.08 µg/m3

PM2.5: 0.03 µg/m3

SO2: 0.13 µg/m3

NOx: 0.05 µg/m3

NH3: 0.06 µg/m3

Details of Predicted Emission from Stacks

are given in Table 4.9 on page no. 4.14 in chapter 4.

Isopleths for the PM10, PM2.5, SO2, NOX and NH3 are presented in section 4.701 on page no. 4.15 in chapter 4.

II. Water Quality modelling - in case of

discharge in water body

Not applicable.

III. Impact of the transport of the raw materials and end products on the surrounding environment hall be

assessed and provided. In this regard, options for transport of raw materials and finished products and wastes (large quantities) by rail or rail-cum road transport or conveyor cum-rail

transport

Incremental emission due to proposed transportation of vehicles is presented in section 4.7.4 on page no. 4.23 in chapter 4.

Unit will prefer the transportation of the materials through rail whenever it is possible. Manual handling will be utilized in minimum activities.

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shall be examined.

IV. A note on treatment of wastewater from different plant operations, extent recycled and reused for different purposes shall be included. Complete

scheme of effluent treatment. Characteristics of untreated and treated effluent to meet the prescribed standards of discharge under E(P) Rules.

Total wastewater generation is 34.5 KL/Day (30 KL/Day + 4.5 KL/Day Domestic). Entire industrial wastewater (30 KL/Day)

shall be send to stripper followed by MEE plant, biological treatment and RO plant. 23 KL/Day RO permeate water shall be reused within the plant premises itself and RO reject water shall be again sent back to MEE

plant. This way, fresh water demand for the proposed project shall be reduced to 22 KL/Day from 45 KL/Day. Domestic wastewater (4.5 KL/Day) shall be

disposed through septic tank / soak pit system. A detail for the same is given in section 2.8 on page no. 2.23 in chapter 2.

V. Details of stack emission and action plan for control of emissions to meet standards.

Details of gaseous emission and its control is presented in section 2.7 o page no. 2.22 in chapter 2.

VI. Measures for fugitive emission control Unit has proposed natural as a fuel for boiler

and Thermopack. Common stack with height of 33 m shall be provided to control emission. In addition to this, Only PUC vehicle will be used for the transportation of

materials and equipment. Vehicles shall use plastic cover sheet while transporting Hazardous waste/products from project site. Paved roads shall be made available within the plant premises to minimize the dust

emission.

VII. Details of hazardous waste generation and their storage, utilization and management. Copies of MOU regarding utilization of solid and

hazardous waste in cement plant shall also be included. EMP shall include the concept of waste- minimization, recycle/reuse/recover techniques,

Energy conservation, and natural resource conservation.

Details of hazardous waste management are given in section 2.9 on page no. 2.32 in chapter 2.

Hazardous waste shall be disposed of to TSDF site / recyclable waste shall be sent to authorized recycler as per Hazardous Waste (Management, Handling and Transboundary

Movement) Rules, 2016. NOC from M/s. BEIL for landfilling of haz.

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waste is attached as Annexure VI.

NOC from M/s. BEIL for incineration and co-processing of haz. Waste is attached as Annexure VII.

NOC from M/s. Rhythm Chemical for spent

solvent is attached as Annexure VIII. Details on cleaner production technology are

given in section 10.8 on page no. 10.13 in chapter 10.

VIII. Proper utilization of fly ash shall be ensured as per Fly Ash Notification, 2009. A detailed plan of action shall be

provided.

Not applicable as there is no generation of fly ash during the operation of plant.

IX. Action plan for the green belt development plan in 33 % area i.e. land with not less than 1,500 trees per

ha. Giving details of species, width of plantation, planning schedule etc. shall be included. The green belt shall be around the project boundary and a scheme for greening of the roads used

for the project shall also be incorporated.

Total area of the project site is 2010 m2 as shown in plant lay out attached as Annexure III.

Unit will develop green belt in 805 m2 area (40 % of the total plot area).

Details for green belt development management are presented in section 10.6 on page no. 10.9 in chapter 10.

X. Action plan for rainwater harvesting

measures at plant site shall be submitted to harvest rainwater from the roof tops and storm water drains to recharge the ground water and also to use for the various activities at the

project site to conserve fresh water and reduce the water requirement from other sources.

Unit has proposed to recharge 994.7 m3

water annually for rain water harvesting facility. Details regarding rain water harvesting is given in section 2.11 on page no. 2.37 in

chapter 2.

XI. Total capital cost and recurring

cost/annum for environmental pollution control measures shall be included.

Total capital cost towards the environmental

pollution control measures shall be Rs. 288 Lakhs and recurring cost shall be Rs. 146.1 Lakhs.

Detail break up is given in section 10.7.1 on page no. 10.12 in chapter 10.

XII. Action plan for post-project environmental monitoring shall be

Details regarding post project environmental monitoring plan is given in section 6.2 on

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submitted. page no. 6.1 in chapter 6.

Unit has allocated Rs. 5,45,900/- for environmental monitoring plan. Same is presented in table 6.2 on page no. 6.5 in chapter 6.

XIII. Onsite and Offsite Disaster (natural and Man-made) Preparedness and Emergency Management Plan including Risk Assessment and damage control.

Disaster management plan should be linked with District Disaster Management Plan.

On site / off site emergency management plan which defines the level of emergency, objective of emergency management system, structure of emergency

management system is given in section 7.5 on page no. 7.30 in chapter 7.

8 Occupational health

I. Plan and fund allocation to ensure the occupational health & safety of all contract and casual workers

Unit has allocated Rs. 22,500/- for health monitoring of workers. Details on occupational health & safety

program are given in section 7.6 on page no. 7.40 in chapter 7.

II. Details of exposure specific health status evaluation of worker. If the

workers' health is being evaluated by pre designed format, chest x rays, Audiometry, Spirometry, Vision testing (Far & Near vision, colour vision and any other ocular defect) ECG, during

pre placement and periodical examinations give the details of the same. Details regarding last month analysed data of above mentioned parameters as per age, sex, duration

of exposure and department wise.

Details of provision of industrial hygienist & health evaluation of workers are presented

in section 7.6.8 on page no. 7.42 in chapter 7.

Details on safety trainings and mock drill are presented in section 7.6.9 on page no. 7.42

in chapter 7.

III. Details of existing Occupational & Safety Hazards. What are the exposure levels of hazards and whether they are

within Permissible Exposure level (PEL). If these are not within PEL, what measures the company has adopted to keep them within PEL so that health of the workers can be

preserved

Details of occupational health impacts and safety hazards which describe the occupational hazard identification and

occupational health impacts are given in section 7.6.5 on page no. 7.41 in chapter 7.

IV. Annual report of heath status of workers with special reference to

Details on safety trainings and mock drill are presented in section 7.6.9 on page no. 7.42

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Occupational Health and Safety. in chapter 7.

9 Corporate Environment Policy

I. Does the company have a well laid down Environment Policy approved by its Board of Directors? If so, it may be

detailed in the EIA report.

Since the project is new, unit will comply the said condition after establishment of proposed project.

II. Does the Environment Policy prescribe for standard operating process / procedures to bring into focus any

infringement / deviation / violation of the environmental or forest norms

/conditions? If so, it may be detailed in the EIA.

Since the project is new, unit will comply the said condition after establishment of proposed project.

III. What is the hierarchical system or Administrative order of the company to deal with the environmental issues and

for ensuring compliance with the environmental clearance conditions? Details of this system may be given.

Orgo Chem (Guj.) Pvt. Ltd. will formulate the Environmental Management Cell for its proposed unit. The company will have a

well-defined hierarchical system or administrative order to deal with the environmental issues. EMC will involve personnel of plant level as well as corporate level for interaction with technical and

statutory bodies to deal with environmental requirements/issues at all level.

Details of the same is attached in section 10.3.3 on page no. 10.2 in chapter 10

IV. Does the company have system of

reporting of non-compliances / violations of environmental norms to the Board of Directors of the company and / or shareholders or stakeholders at large? This reporting mechanism

shall be detailed in the EIA report

Since the project is new, unit will comply the

said condition after establishment of proposed project.

10 Details regarding infrastructure

facilities such as sanitation, fuel, restroom etc. to be provided to the labour force during construction as well as to the casual workers including truck drivers during

operation phase.

Workers and truck drivers will use sanitation

facility available in admin building during operation phase. Unit will made availability of rest room for worker and others at the time of construction/modification of building.

11 Enterprise Social Commitment (ESC)

Adequate funds (at least 2.5 % of the

project cost) shall be earmarked

The unit has proposed to spend nearly Rs.

37,00,000/- Budget (4 % of the total cost

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towards the Enterprise Social

Commitment based on Public Hearing issues and item-wise details along with time bound action plan shall be included. Socio-economic development activities need to be elaborated upon.

Rs. 9.25 Crores) for social development

programs under CER activities for the next 5 years.

More details are provided in section 8.4 on page no. 8.1 in chapter 8.

12 Any litigation pending against the

project and/or any direction/order passed by any Court of Law against the project, if so, details thereof shall also be included. Has the unit received any notice under the Section 5 of

Environment (Protection) Act, 1986 or relevant Sections of Air and Water Acts? If so, details thereof and

compliance/ATR to the notice(s) and present status of the case.

Not applicable as proposed project is new.

13 'A tabular chart with index for points wise compliance of above TOR.

Complied.

Specific Terms of References

1 Details on solvents to be used, measures for solvent recovery and for emissions control.

Unit will provide three stage condensations with distillation column for the maximum recovery of solvents used during the

operation phase. Unit has also proposed to install VOC detectors at various places to identify any fugitive emission.

Solvent management plan is given in section 2.10 on page no. 2.34 in chapter 2. Unit will try to recover up to 99 % solvents.

2 Details of process emissions from the proposed unit and its arrangement to control.

There shall be emission of VOCs and NH3 during manufacturing process. Unit has proposed tow stage ammonia scrubbers to control the same.

Details are given in the section 2.7 on page no. 2.22 in chapter 2.

3 Ambient air quality data should include

VOC, other process – specific pollutants* like NH3*, chlorine*, HCl*,

Details of ambient air quality monitoring are

given in section 3.5 on page no. 3.18 in chapter 3.

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HBr*, H2S*, HF*, etc., (*- as

applicable)