GUJARAT POLLUTION CONTROL BOARDgpcb.gov.in/pdf/Gujarat_Helogen_Petro_Co_PH_MIN_PRO.pdf · REGIONAL OFFICE, NADIAD GUJARAT POLLUTION CONTROL BOARD 201-203, "B" Block, Sardar Patel

REGIO NAL OFFICE, NADI AD

GUJARAT POLLUTION CONTROL BOARD

201-203, " B" Block, Sardar Patel Bhavan, Nadiad. Phone: (0268) 2551427, 2551428

Email: [email protected], Site : www.gpcb.gov.in, Online Application Site : http ://gpcb.guj.nic.in

PUBLIC HEARING PROCEEDINGS

As per the provisions of notifi ation no. S.O.I S33 dated 14/09/2006 and its amendment S.O. 3067 (E) dated 01112/2009, Ministry of Environment and Forests, Government of India, New Delhi Public Hearing is conducted for tbe proposed expan ion project of MIs Gujarat Halogen Petrochem corporation for expansion of Chemical manufactur ing in e isting unit loca ted at Sr. No. 293, ViUage: Lunej, Ta luka- Khambbat, Dist: Anand, Gujarat, which is covered under Category A of the above referred notification.

A copy of the Draft Environment Impact Assessment Report and the Summary of Environment Impact Assessment Report were sent to the fo llowing authorities or offices to make avaiJable the draft ElA Report for the inspection to the publ ic during normal o ffice hours, till the Public Hearing is over :

I . The Distri t Collector Ofllce. Anand. 2. Jllla Panchayat Offic ,Anand. 3. District Industries Centre, Anand . 4. Th Chief Conservator of Forests, Ministry of Environment & Forests, Govt. Of India,

Regional Office (West Zone) Kendriya Paryavaran Bhavan. E - 5, Area Colony,

Link Road - 3, Ravishankar Colony, BHOPAL - 465016

5. Regional O fiice, Gujarat Pollution Control Board 201 -203 B-block, Sardar Patel Bbavan, Nadiad. 6. Chief Officer, Nagar Seva Sadan Anand.

Other concerned persons having plausib le stake in the environmental aspects were requested to send their responses in writing to the concerned regulatory authorities.

The Public H earing was scheduled on date 4th June, 2010 at 11:00 hou rs at Shri BbogilaJ Kuberdas Patel Sabhagruh, BIH Swaminarayan T emple, Chakdol Ground, Metpur Road, Khambhat, Distr ict: Anand.

An advertisement in Englisb was published in "Indian Express" dated 13/04/2010 and in Gujarati in " Sandesh" dated 13/04 /2010. Thougb, after the notification of no t conducting many public bearings on a ingle day, the public notice for the revised dates were pubJished in "Indian Express" and in GujaTati in

"Sandesb" dated 29/04/2010.

Shri R. N. Jo hi, District Magistrate and District Collector, Anand, supervised and presided over the entire public hearing process.

A stat ment showing participants present during the Public Hearing is enclosed herewith as Annexure A.

A statement showing the salient points highlighting issues raised by the participants and responded to by the representative of the applic nt during the Public Hearing in English and Gujarati Languages is enclosed herewith as Annexure Band Bl.

The copies of responses received in writing from other persons having pLausible stake in environmental aspects are enclosed herewith collectively as A.DDe:IUTe C (Cl to C8) and the replies by tb applicants to the same are enclosed herewith collectively as Annexure D (Dl to D3)

(.8. L. Maru)

Regional Officer, GPCB NadiadPlace: Kbam bbat, Di trict Magi trate andAs Representative of the

Dist: Anand District Collector, Anand.Member Secretary, GPCB. Date: 04/06/2010

Encl.: 1. Annexure A, B, Bl, C(CI to C8) and D (D1 to D3) as above. 2. Video C D of Public H earing.

http:http://gpcb.guj.nic.inwww.gpcb.gov.in

ANNEXURE B (ENGLISH) As per the provisions of notification No.S.O.1533 dated 14/09/2006 and its amendment S. O. 3067 (E) dated 01/12/2009 issued by Ministry of Environment and Forests, Government of India, New Delhi, Public Hearing issued by Ministry of Environment and Forests, Government of India, New Delhi, Public Hearing is conducted for the project covered under Category A of the said notification for the proposal of expansion of chemical manufacturing unit of M/s Gujarat Halogen Petrochem Corporation located at Sr. No. 293, Village: Lunej, Ta:- Khambhat, Dist: Anand, Gujarat under the supervision of Shri R. N. Joshi, District Magistrate, Anand and Chairman of the Public Hearing Committee. Shri B. L. Maru, Regional Officer, GPCB Nadiad and representative of Member Secretary, GPCB welcomed all present, to the Public Hearing. He then outlined the various provisions of the Notification and briefed the procedural details for conducting this public hearing. He also mentioned actions taken by GPCB for wide publicity of the Public Hearing by news aired on local news channel, announcement via mike mounted autorickshaw on 02nd and 03rd June 2010 and the advertisement given earlier in the local dailies. He announced that as per the provisions of Notification, only locally affected persons will be allowed to make represent also during the Public Hearing while others having plausible stake may give their representation in writing which would be included in the proceedings. He also made it clear to the gathering that making recommendation about the project proposal is outside the purview of the Public Hearing Committee and the Committee is solely responsible for preparation of proceedings of the meeting covering all the concerns raised during the public hearing. He also informed the forum that three written representations were received prior to public hearing. One from Shri Farooq Shaikh, second from Shri Yogesh Pandya Khambhat and the third from Shri Maheshbhai Pandya Paryavaran Mitra Ahmedabad. All of the above would be included in proceedings. The same are enclosed as Annexure C1, C2 and C3 along with the replies submitted by the project proponent as Annexure D1, D2 and D3 respectively. He then opened the Public Hearing after due permission from the District Magistrate He invited the Project Proponent to give their introduction and to give the presentation of their project. Shri Ramanbhai Patel, representative of the industry welcomed the gathering. Thereafter, power point presentation with recorded audio in Gujarati language, covering, introduction of the Company, production data and other details of proposed project, Environmental Management System, its impact on the environment along with proposed mitigation measures and industrys activities regarding Corporate Social Responsibilities was made. After the presentation by the project proponent, Shri B.L. Maru, Regional Officer, GPCB with the due permission of the District Magistrate, opened the forum for representations / suggestions / objections from the locally affected people. The representation submitted during the Public Hearing in written, was read out by the Regional Officer before the verbal representations were made and the same has also been included below.

The statement showing issues / suggestions / objections / opinion raised verbally by the participants and responded to by the representative of the applicant during the Public Hearing is as under: Sr. No.

Name and Address Points written and / represented Replies from Project Proponent

1 Shri Poonambhai Mohanbhai Patel, Vill : Sokhda, Ta : Khambhat, Dist : Anand. (Only Written representation submitted during PH)

He said that this Company contributes towards the social development of the area. He added that there has also never been any crop failure due to pollution from this Company. The expansion in the industry will give rise to further employment opportunities in the village which is a necessity in this underdeveloped area. Hence, he welcomed this Project.

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2 Shri Bhailalbhai Somabhai Makwana, Sarpanch, Vill : Sokhda, Ta : Khambhat, Dist : Anand. (Only Written representation submitted during PH)

He said that there has never been any project was detriment to the crops due to this industry He also mentioned that they get good crops in their fields. He added that there has never been any problem due to pollution from industry in the village also although the Company has been in operation in this area since the last fifteen years. Hence he welcomed the expansion plans of the industry and said that he would fully cooperate with them on this Project.

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3 Shri Manubhai Bhurabhai Bharwad, Deputy Sarpanch, Vill : Lunej, Ta : Khambhat, Dist : Anand. (Only Written representation submitted during PH)

He said that this industry provides employment to the youths of the village and he hoped that they would do so after the expansion also. He added that there has not been any problem of pollution due to this industry. He also mentioned that the industry also contributed to the social development of the village.

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4 Shri Gatorbhai Babarbhai Makwana, Vill : Lunej, Ta: Khambhat, Dist : Anand. (Only Written representation submitted during PH)

He said that his village was located @ 2 kms from this industry and there has never been any pollution problem due to this industry. He said that the expansion of the industry will give rise to further developmental and employment opportunities in the area. Hence he welcomed the project.

Sr. No.

Name and Address Points written and / represented Replies from Project Proponent

5 Shri Yogesh Pandya, Ta : Khambhat, Dist : Anand.

He began by saying that his questions on the Project had already been raised in writing and he had also received the replies from the industry and he was satisfied with the same. He said that since the project was located in the own field/land of the Project Proponent, he would naturally take care to protect and preserve the environment. He also urged the people present to Think Globally and Act Locally. He also added that the Company should do rain water harvesting to conserve and replenish the water supply, and also develop proper Green Belt area, as on date this was unsatisfactory. He asked the industry to comply the conditions issued in the NOC and EC Orders.

6 Shri Kanubhai M Shah, Social Worker, Ta : Khambhat, Dist : Anand.

He stated that this Company belongs to a group of Companies and there has never been any problem of pollution from this Company in Sokhda and the surrounding areas. He also added that this expansion would create further developmental and employment opportunities in the area. He further added that since this was a water scarce area, he hoped that the industry would take due care to completely avoid wastage of water and would also supply all their own employees with sweet drinking water to satisfy all their needs. He also added that the Company should develop their own water works. Lastly he added that he welcomed the project.

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7. Shri Jayantibhai Jethabhai Patel, President Khambhat Industries Association, Ta : Khambhat, Dist : Anand.

He said that since the land on which the industry was located belonged to the Project Proponent only, hence they would take adequate care to take care to control pollution. He said that this area had no Green Belt although the Government had wanted to develop the same around 15 years Back. He said that industrialization would bring development to the area.

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Sr. No.

Name and Address Points written and 1 represented Replies from Project Proponent

He mentioned that it would be unfair to say that only industries create pollution. He sajd that the pesticides used for development of crops in the fields are sometimes more polluting than the chemicals emitted by the industries, since the industries have to follow the stringent Norms framed for control of pollution and preservation of environment.

The Public Hearing concluded with a vote of thanks to the Chair.

~------~

(B. L. Maru)

Place: Khambhat, Regional Officer, GPCB, Nadiad District Magistrate and Dist: Anand As Representative of Member District Collector, Anand Date : 04/06/2010 Secreta ry, GPCB.

ANNEXURE BI (GUJARATI) pyi#iily Birt srkir , nv) (dh) ni ni[T)(fk[Sn n> a[s.ai[. 1533 ti. 14-9-2006 an[ t[ni s&Firi

a[s.ai[. 3067 {e} ti. 01-12-2009 avy[ k[T[gr) : a[: mi> aivr) l[viy[l m[.g&jrit h[li[j[n p[T^i[k[m ki[pibr - 293, gim l&n[j, K>Bit, aiN>d. an[ pAti(vt n)pji[ni u_pidn miT[n) pAti(vt (vAtZt)krN pi[j[kTn) s&(ct

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FROM G.P.C.B FAX l'U 91 79 23222784 17 2010 11:59AM P2

~~lT ".. . ,,=--={j/",.. Farooq Shaikh (M.L.A.) ...,; )eputy Whi" . Gujarat Leglstlative Assembly

~i rector Gujarat Wakaf Board

-.E!L, 079-:?~rrg767 M. ~,98.?5836046 ~,"",4i1 :;;.:r9 Office. Nagina Pole. lakariya Masjid.

Relief Road. Ahmedabad-3BO 001 3l'l"HIfI '.:J --...--

Ref. : Date. :

., ,,,,- - 1~~r';;,r~'_f!/

GUJARAT HALOGEN PETROCHEM CORPORATION MANUFACTURERS OF : FINECHEMICALS. , r Mfrs of' Benzoyl Chloride. Bevzo-trl-ChlollCle, Acetyl Chloride, Cnloro-Acety: Chloride, Monochloro Acetic Acid.

Works Office Survay No 293. Lune: Village Near Ambika Chemical, Tal Cambay-388620 [Jist Ar.and GUjJial 181 1026981221202.320401 Fax (02698) 220969

Dt: 4thJune 2010.

To.

Shri Farooq Shaikh (1\1L\l Nagina Pole. Zakariya \lasjicl, Ahmedabad - -'so 001 .

Sub.: Replies To Queries Raised.

Dear Sir.

Kindly find herewith the attached replies for the queries raised.

Thanking you.

[

a[n[xr D) - 1

1. ph[li smicirp#imi> jih[rit 13/04/2010 mi> aiv) ht) an[ pC) fr)Y) 29/04/2010 ni ri[j aipvimi> aiv) ht).

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jyi pr r[Dvimi> aivS[ nh). Di[m[(ATk p\d&(Pt piN) Kirk&vimi> mi[klvimi> aivS[.

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ai a[km J.aiE.D).s). (vAtirmi> aivt& nY) miT[ k[T[gr) a[ miT[ arJ kr) C[. E.aiE.a[. ni sT[br

2006 jih[rnimi> an&sir j[ a[km ni[ smiv[S (n(d ni Yti[ hi[y an[ (vAtrN p\i[j[kT an[ nvi

p\i[j[kT miT[ arJ krv) hi[y t[ni[ k[T[gr) a[ mi> smiv[S Yiy C[.

Replies to Queries by Shri Farooq Shaikh

Queries Replies 1. As per the public notice on 8-04-2010 in

newspaper, as per the provisions of notification No. S.O. 1533 dated 14/09/2006, M/s. Gujarat Halogen Petrochem Corporation has applied for its expansion project under category A. These units discharge their effluent in public and process gas emissions are released in open. Because of this people residing in nearby villages are facing health problems and low yield in their crops production. Hence, such a company should not get a category A certificate.

The first public notice was issued in newspaper on 13-04-2010 and its amendment on 29-04-2010.

These units after adequate treatment, reuses the treated water in its industrial activities. Hence, no water discharge takes place except for the sewage water in the soak pit.

The unit already has multistage scrubbers to scrub the HCl and Cl2 gas emitted during the process. It also proposes to install new scrubbers for its expansion activities.

The unit is applying under category A, as it is not located in GIDC area. As per the EIA notification in September, 2006, the units not falling under the notified area and applying for expansion or new projects fall under the category A.

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6. hyit liTmi> C[li b[ vP aip[l) sgvD, uRpidn n) mi(ht) a[n[xr 1 mi> aip[l) C[. p\d&(Pt piN)ni[ (nkil Yti[ nY) t[ T^)Tm[T kyi< pC) fr)Y) Upyi[gmi> l[vimi> aivS[. Gn kcrini[ (nkil T).a[s.D).a[f.,

a[n.E.s).a[l., n>d[sr)mi> krvimi> aivS[. {sypdn) nkl a[n[xr 2 mi> aip[l) C[.}

7. K>Bit s[m)-k|)T)kl (vAtirmi> aiv[ C[. s).J.Dby&.a[. ni> s&cn ni> aiFir[ 50.5 (k.(l./ (dvs j[Tl& g\iuD vi[Tr viprti uwi[gi[n[ a[n.ai[.s). n) prving) l[vin) j$r nY). p\Ativ)t p\i[j[kT miT[ piN)n)

j$r)yit 34.6 (kli[(lTr/(dvs C[. a[Tl[ t[n[ pN prving) l[vin) j$r nY).

8. p\Ati(vt (vAtZt)krN p\i[j[kT miT[ a[fl&aT T^)Tm[T liTn&> bi>Fkim krvimi> aivS[. T^)Tm[T Yy[l p\d&(Pt piN) s).E.T).p)., E.aiE.s).a[l., Umriyi, pidrimi> mi[klvimi> aivS[. ai a[km[ s).E.T).p).n&> sypd

m[Lv) l)F[l C[ {a[n[xr 3 mi> aipvimi> aiv[l C[}. a[fl&aT s).E.T).p)., E.aiE.s).a[l., pidri ni

a(FkZt T[>kri[ iri mi[klvimi> aivS[.

9. p\Ati(vt p\i[j[kT miT[ Ts aivS[. c)mn) n) U>ciE Ak|br ni> sliyr oiri aipvimi> aivS[. ji[ J.p).s).b). ni ni[m bLtN tr)k[ jliu likDini[ Upyi[g krS[ nh).

11. T).a[s.D).a[f. ni sypdn) nkl a[n[xr 2 mi> aip[l C[.

12. fliy a[Sni[ s>g\h b>F (vAtirmi> krvimi> aivS[. fliy a[S E>Ti[ bnivnirn[ v[cvimi> aivS[.

13. s[fT) m[y&al 68 a[ an[ p) ni (nym p\miN[ bniv[l C[. (nym 41 b) an[ s) p\miN[ s[fT) b&kl[T bniv)n[ aij&bij&ni> (vAtirmi> vh[cvimi> aiv) C[.

14. 2006 mi> k[b[ ai[g[ ai[f-siET D^)l krvimi> aiv) ht) t[mi> ai a[km[ Big l)Fi[ hti[ an[ ai D^)l cir a[km vc[ a[k ki[mn ht) j[ kl[kTr ~) n) hijr)mi> krvimi> aiv[l ht).

15. ni[m vZxiri[pN krvimi> aivS[. ai mi(ht) E.aiE.a[. r)pi[T< ni> pin n> 128 pr (vBig 5.7 mi> aipvimi> aiv) C[. t[ni bj[T (k>mtn) mi(ht) E.aiE.a[. r)pi[T<

ni> pin n> 13 pr (vBig 2.2.1 mi> aipvimi> aiv) C[.

16. vrsid) piN)ni s>g\h miT[ni> bj[T (k>mtn) mi(ht) E.aiE.a[. r)pi[T< ni> pin n> 13 pr (vBig 2.2.1 mi> aipvimi> aiv) C[.

Replies to Queries by Shri Yogesh Pandya Queries Replies 1 Accidents in last 3 years and what steps have

been taken to safeguard against future occurrences

No reportable accidents in the last 3 years.

2 What are the likely occupational diseases that may be caused from the raw materials and finished products. Has any case of occupational health disease registered.

Chlorine is the major raw material used in the process. The entire usage is under closed conditions. Even the vents of the reactors are connected to the scrubbers. Flammable liquid like toluene will be stored in designated licensed storage yards and will be taken to the reactors through pumps. There is no direct exposure of chemicals to the workers. Till date no case of occupational disease has been reported.

3 In all the 3 shift how many qualified first aid trained persons are there? Who is looking after safety and environment? Is the person technically qualified?

First aid trained persons are available in all shifts. Maintenance of safe working conditions is the joint responsibility of all the workers and staff. Safety and environment is being looked after by the factory manager. Experts are called monthly for activities like safety training, EHS management and the advice is noted and followed.

4 In the last 3 years how many closure or show cause notice has been issued by GPCB? Is there any court case pending against the unit?

There are no show cause notice or closure notice in the last 3 years.

5 Is there a training centre in the factory? Are the contract workers given basic training?

Training on E H S is imparted to all the workers including the contract workers. They are trained in the use of safety equipment, provided knowledge on chemicals and their hazards, training in handling emergency situations by experts.

6 In the last 3 years what are the production details? Where the effluent, solid waste disposed?

For the existing facilities, production details for the last 2 years is given in Annexure 1. There is no disposal of effluent. The effluent after treatment is reused back. The solid waste is disposed off in the TSDF of NECL, Nandesari. (Membership copy is attached as Annexure 2)

7 Has the permission for extraction of groundwater been taken from central ground water board?

Khambhat falls under semi-critical area. As per the Guidelines for evaluation of proposals/requests for ground water abstraction for drinking and domestic purposes in Notified areas and Industry/Infrastructure project proposals in Non-notified areas issued by Central Ground Water Board, Industries requiring ground water upto 100 m3 /day in semi-critical areas are exempted from obtaining NOC for ground water abstraction from CGWA. Since the water requirement for the proposed project is 50.5 m3/day, the proposed industry falls under the exempted category.

8 For the disposal of treated waste water in ECP has the unit taken necessary

From the proposed expansion, an effluent treatment plant will be constructed. The treated waste water

permission? What are the conditions? will be sent to the Common Effluent Treatment Plant of EICL, Umaraya, Padra. It is not sent to the ECP but to the CETP. The unit has taken the membership of the CETP (Membership copy attached in Annexure-3). The effluent will be sent in the tankers owned and authorized by the CETP of EICL, Padra.

9 Are the proposed scrubbers efficient to scrub the gases generated from the process. Is the stack height sufficient?

In the proposed project, additional tertiary scrubbers are proposed. The height of the stack has been provided by the proposed suppliers of the scrubbers. However, if any change is required as per the norms of GPCB, it will be implemented according to the norms.

10 The unit is advised not to use fire wood as fuel in the boiler? GPCB should stop the use of firewood as fuel for boilers.

The unit will not be using firewood as fuel for the boilers.

11 Provide the membership copy of the TSDF for disposal of solid waste?

Membership copy of the TSDF is attached in Annexure-2

12 Has the unit made proper arrangement for disposal of fly ash?

A separated enclosed and covered area will be provided for storing flyash. Flyash will be sold to brick manufacturers.

13 Has the unit informed the staff and the nearby villages regarding the chemicals used ?

Yes, the safety manual is prepared as per Rule 68 A and P. As per Rule 41 B and C, Safety booklet has been prepared and distributed in the nearby region.

14 In the last 3 years how many onsite emergency plan rehearsal done? In the region, has a offsite emergency plan been conducted in the presence of the collector?

In 2006, Offsite drill was conducted at Cambay Organics Pvt. Ltd. in which this unit had Participated. This drill was a common drill between 4 units which was conducted in the presence of the Collector.

15 At present how much green belt developed by the unit. In future how much area will be covered by the green belt and what is the budget? Which type of trees will be planted?

As per the norms, 33% of the land area (3572 sq mts) will be covered under green belt. Details are given in section 5.7 page 128 of the Draft EIA report. Details on the budgeted cost is given in section 2.2.1 page 13 of the Draft EIA report.

16 What is the budget allocated for rainwater harvesting and development of check dam / ponds in the nearby areas.

Details on the budgeted cost is given in section 2.2.1 page 13 of the Draft EIA report.

Annexure 1

Production Data for last 2 years

2008-09 ACETYL CHLORIDE

BENZOYL CHLORIDE

HYDRO CHLORIC ACID

APRIL 14.54 23.86 26.23 MAY 13.94 24.64 28.23 JUNE 13.30 23.95 28.56 JULY 14.31 24.00 29.02 AUG 14.23 23.96 28.47 SEP 13.82 20.73 28.69 OCT 13.16 17.68 26.72 NOV 14.12 20.61 25.02 DEC 14.81 24.16 28.66 JAN 14.10 24.35 28.32 FEB 13.70 24.37 29.62

MARCH 14.47 24.09 29.51

2009-10 ACETYL CHLORIDE

BENZOYL CHLORIDE

HYDRO CHLORIC ACID

APRIL 14.74 24.28 29.08 MAY 14.54 24.85 29.63 JUNE 13.40 23.70 28.22 JULY 13.55 23.68 28.98 AUG 13.99 23.08 28.23 SEP 14.04 24.92 29.44 OCT 14.61 24.09 29.53 NOV 14.61 24.36 29.50 DEC 14.25 24.10 28.20 JAN 13.51 23.34 28.77 FEB 13.67 23.49 28.97

MARCH 13.90 23.95 27.19

Annexure 2

Annexure 3

PA A (CENTRE FOR SOCIAL JUSTICE - J NVIKAS)

502, Raj Avenue Bhalkaka Nagar Road. Nr. Thaltej Cross Road, Thaltej, Ahrnedat)ad . 380 059 . . Teiefax: (079) 26851321, Fax: (079) 26857443

Email: paryavaranmltra@yahoo,com, [email protected] 'Website: http://paryavaranrnitra.org.in

Ref: #PMIMP 1526/2010 Date: 21 May 2010

To Shri RG Shah Member Secretarj Gujarat Pollution Control Board Gandhinagar

Sub. : Environmental Public Hearing of Gujarat Halogen Petrochem Corporation for expansion at Khambbat, Anand on 4.06.2010.

Sir,

We have reviewed EIA report of above mentioned project. Following are our comments/suggestions/observations regarding project and EIA report.

10 Please give details of GPCB visit report and air/water/solid waste sample analysis report for existing unit in last two years.

2. Please give details ofMoEF regional office visit report in last two years, if any. 3. Whether company had been issued show cause notice / closure order/notice under

Water Act 1974 or Air Act 1981 or Environment Protection Act 1986 since starting of existing unit? If yes give details of it. Also what remedies had been taken for restarting operation?

4. Whether unit has submitted Environmental Audit Reports regularly to GPCB for existing plant? What were suggestions of Auditor in last two years report?

5. Whether permission of Central Ground Water Board has been obtained for withdrawal of water from bore well for existing plant and for proposed expansion? If yes give deails of it.

6. Why freshwater from bore well should be used for scrubbing? 7. What would happen to scrubbed water with solvent? 8. How many employees are currently working in the factory and after expansion? 9. Please justify water to wastewater ratio from 1.2 to 7.7 after expansion. 10. Which type ofbiofue1s are used in boiler and heater? 11. Why there is no greenbelt in existing factory premises? 12. Please justify 2000 L per day of water for developing greenbelt in 3572 sqm area. 13. There was no ambient air measurement location beyond radius of 4 km from factory.

It is violation of ToR of MoEF of 10 km radius air quality measurement

dbY

f\ rYv,,~~8

w ~

(f\

http://paryavaranrnitra.org.inmailto:[email protected] TextAnnexure C3

PARY VARA ITRA

I CENTRE FOR SOCIAL JUSTICE - JANVIKAS)

502, Raj Avenue, Bhalkaka Nagar Road, Nr. Thaltel Cl'OSS Road, Thaltei, ,"Ihmedc1bad 380 059

Telefax : (079) 26851321, Fax: (079) 26857443

Email: [email protected], [email protected] .Website : http://paryavaranmitra.org.in

14. Whether TSDF site will be of Nandesari or Surat? Both have different impacts on environment for receiving solid waste from factory.

15. Please give name of CPCB authorized recycler/trader to whom discarded drums and other solid hazardous waste is given for existing unit.

16. To whom 30% HCI is sold in existing plant? 17.Please show membership certificate of CETP and TSDF for disposal of effluent and

solid waste. 18. There are many similar factories in near by premises. Any common facility has been

sought for pollution reduction? 19. Any carrying capacity study or cumulative pollution load have been studied for this

area?

Yours truly

Mahesh Pandya

Cc

1. Shri R.N. Joshi, Collector, Anand

Y Regional officer, GPCB, Nadiad

http://paryavaranmitra.org.inmailto:[email protected]:[email protected]

Sr. No.

Query Reply

1. Please give details of GPCB visit report and air/water/solid waste sample analysis report for the existing unit in last two years.

Visit reports attached as Annexure 1.

2. Please give details of MOEF regional office visit report in last two years if any.

No visits from MOEF in last two years.

3. Whether company had been issued show cause notice / closure order/ notice under water Act 1974 or Air Act 1981 or Environment Protection Act 1986 since starting of existing unit ? If yes give details of it. Also what remedies had been taken for restarting operation ?

No show cause notice /closure order / / notice under water Act 1974 or Air Act 1981 or Environment Protection Act 1986 is issued to the unit since starting of existing unit.

4. Whether unit has submitted Environmental Audit Reports regularly to GPCB for existing plant? What were suggestions of Auditors in last two years report ?

The industry does not fall under Environment Audit scheme.

5. Whether permission of Central Ground Water Board has been obtained for withdrawal of water from bore well for existing plant and for proposed expansion? If yes, give details of it.

Khambhat falls under semi-critical area. The total water consumption after proposed plant expansion will be 50.5 KL/day. As per the Guidelines for evaluation of proposals/requests for ground water abstraction for drinking and domestic purposes in Notified areas and Industry/Infrastructure project proposals in Non-notified areas issued by Central Ground Water Board, Industries requiring ground water upto 100 m3 /day in semi-critical areas are exempted from obtaining NOC for ground water abstraction from CGWA. Since the water requirement for the proposed project is 50.5 m3/day, the proposed industry falls under the exempted category.

6. Why freshwater from bore well should be used for scrubbing?

The unit will require total 25 KL/Day of water for scrubbing activities at its full plant capacity. It will reuse its R.O. water reject 14 KL/Day for scrubbing activities and the rest 11 KL/Day will be acquired from borewell.

7. What would happen to scrubbed water with solvent?

Water Scrubbers will be used only for scrubbing HCl. Solvents will not be scrubbed with water.

8. How many employees are currently working in the factory and after expansion?

Out of the total workforce of 30 employees, employees from the village Lunej are maximum (14 no.s), followed by Ambavadi, Cambay and Bhimtalav. The village wise employment details are as given in chapter 3, pg. 111 of the draft EIA report. About 5-10 personnel will get employment for the

proposed expansion project. All the personnel will be taken from nearby villages.

9. Please Justify water to wastewater ratio from 1.2 to 7.7 after expansion.

Water consumption is increasing due to utilization of R. O. use of water in boiler & cooling tower. Hence increase in water to wastewater ratio.

10. Which type of biofuels are used in boiler and heater?

In the existing unit, wood / lignite is used in the boiler and thermic fluid as fuel as per the valid Consolidated Consent & Authorization from GPCB.

11. Why there is no greenbelt in existing factory premises?

There is a greenbelt in the existing factory premises, which is 22 % and it shall be increased to 3572 sq. mts (33% of the total plot area) for the proposed expansion project.

12. Please justify 2000 L per day of water for developing greenbelt in 3572 sq.mt. area.

The plantation activity will be carried out in phases over a period of 4 years. In the initial phases the water requirement will be less being the sapling or initial stage of the plants growth. On attaining the growth, the water requirement by trees reduces.

13. There was no ambient air measurement location beyond radius of 4 km from factory. It is violation of TOR of MOEF of 10 km radius air quality measurement.

As per the ISCST3 model run for finalizing the monitoring station using previous years meteorological data, the GLC drops drastically after only 1 Km. the same was verified with the meteorological data for the monitoring season. Moreover in the downwind direction, the mudflats of Gulf of Khambhat starts at a distance of about 2 km.

14. Whether TSDF site will be of Nandesari or Surat? Both have different impacts on environment for receiving solid waste from factory.

Generally the TSDF site of Nandesari site is utilized. However Surat TSDF site will be used only in case of emergencies.

15. Please give name of CPCB authorized recycler / trader to whom discarded drums and other hazardous solid waste is given for existing unit.

Bhagwati traders, Rajpipla chowkdi, Ankleshwar.

16. To whom 30% HCl is sold in existing plant ?

30% HCl is sold to : 1. S. V. Dyechem Pvt. Ltd., Neja. 2. Tulsi Intermediates Pvt. Ltd., Sokhada. 3. Asiatic Colorchem Ind. Ltd., Neja 4. S. M. Industries, Sokhada.

17. Please show membership certificate of CETP and TSDF for disposal of effluent and solid waste.

CETP & TSDF Membership copies are attached as Annexure 2.

18. There are many similar factories in near by premises. Any common facility has been sought for pollution reduction?

Yes, the plannings for installation of CETP is in progress as declared by the authorities.

19. Any carrying capacity study or cumulative pollution load have been studied for this area?

Cumulative Impact Of All Four Projects on Ambient Air Quality was studied using ISCST3 modeling. The details of the study is covered in chapter 4, section 4.2.2.1, pg. 116 of the draft EIA report.

Sample ID:21679 - Analysis Completion:05/07/2008

Gujarat Pollution Control Board

Vadodara

GERI Compound

Race Course Road

Vadodara - 390007

Tele:0265-2354850 Chemicals & Products / LAB Inward : 2077

ANALYSIS REPORT for AIR

TYPE : STACK

: 28/06/2008, (1725 to 1750) Start Date : 01/07/2008

: REP-Representative , (Insp Type : ROU-Routine Visit)

: vent attached toreactors through apc system.

: Process

: HCl,Cl2

: -

: 30 9. Volume-Absord Media : -

: 19.67-each

: 2 12.Oper Time(Min) : 0

: 14. Carboys Marks : B

1. Name &

Address of the Unit

Gujarat Halogen Petrochem Coporation - 17416

293,VILL :LUNEJ,KHAMBHAT.388620,-

-LUNEJ - -388620,Taluka : Khambhat, District : Anand, GIDC : Not In Gidc

Sr. ResultUnitParameter

HCL-Stack MG/NM3 1 7.83

Cl2-Stack MG/NM3 2 0.009

2. Date & Time of Collection

3. Type of Sample

4. Sampling Point

5. Fuel

6. APCM

7.Thimble & Weight (gm)

8. Temperature on Collection

10. Volume-Gas Passed

11. Parameters

13. Cap No & Weight

Signature_________________

L. K. VANDRA,SO

Laboratory Remarks : ~------

N I C 01/06/2010



Vadodara

GERI Compound

Race Course Road

Vadodara - 390007



TYPE : STACK

: 08/09/2009, (1440 to 1450) Start Date : 10/09/2009

: REP-Representative , (Insp Type : HOR-H.O.Reference)

: Vent attached to various reactors through Apcm

: --

: Two stage water scrubber followed by alkali scrubber

: --

: 29 9. Volume-Absord Media : Gas passed for HCl & Cl2-20 lts each

:


: 14. Carboys Marks : B

1. Name &

Address of the Unit








3. Type of Sample

4. Sampling Point

5. Fuel

6. APCM




11. Parameters

13. Cap No & Weight

Signature_________________

H.C. Solanki,SSO

Laboratory Remarks : .

N I C 01/06/2010



Vadodara

GERI Compound

Race Course Road

Vadodara - 390007



TYPE : STACK

: 07/04/2010, (1450 to 1610) Start Date : 13/04/2010

: REP-Representative , (Insp Type : ROU-Routine Visit)

: vent attached to verious reactors

: -

: two stage water scrubber followed by alkali scrubber

: -

: - 9. Volume-Absord Media : 50ML/EACH-DW for HCL,MO for CL2

: 40 LITER


: - 14. Carboys Marks : 2

1. Name &

Address of the Unit








3. Type of Sample

4. Sampling Point

5. Fuel

6. APCM




11. Parameters

13. Cap No & Weight

Signature_________________

H.C. Solanki,SSO

Laboratory Remarks : freeze By:436-lab_436 Dt.: 16/04/2010

N I C 01/06/2010

Annexure 2

aTypewritten TextAnnexure C4


A 1A 2A 3A 4A 5A 6A 7A 8A 9Ann-B_points raised English - GHPC Annexure C1f1Annexure D1 - gujAnnexure D1Annexure C2f2Annexure D2 - gujAnnexure D2Annexure C3f3Annexure D3Binder1.pdf05072008.pdf2309200916042010

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Documents

GUJARAT POLLUTION CONTROL BOARDgpcb.gov.in/pdf/Gujarat_Helogen_Petro_Co_PH_MIN_PRO.pdf · REGIONAL OFFICE, NADIAD GUJARAT POLLUTION CONTROL BOARD 201-203, "B" Block, Sardar Patel