Point wise compliance of condition of Environmental Clearancegharidetergent.com/EC Compliance_Sagar Unit 2.pdf · plantation, with native species. The photographs of the green area

Point wise compliance of condition of Environmental Clearance With reference to the letter no. 3136/SEIAA/2015 dated 17-03-2015; condition of Environmental Clearance and status of compliance is as below S. No. Conditions of Clearance Compliance Status A Specific Conditions as recommended by SEIAA 1 Once water from AKVN is made available,

use of bore well water will be stopped and there shall be no extraction of ground water.

We had applied to AKVN to provide us the water supply.

In response of our request AKVN had assured us that they will supply us water as and when the water scheme will be completed. The copy of letter is attached as Annexure-IA.

We had regularly followed up with AKVN for this water supply.

On 27.09.2017, we have received a letter from AKVN, which is addressed to President, Industrial Area Sidhguan, illustrating that their water network is completed, and they are ready to provide the water supply to all industrial units. The copy of letter is attached as Annexure-IB.

We are in process to apply for this water connection, and hope that, the water supply will be available to us within 2 to 3 months.

Sooner, we receive the water connection; we will close the bore well.

2 PP should maintain 100% recycling of treated waste water and zero discharge of the treated waste water from the industry

We have installed MEE of 100 KLD & ETP of 40 KLD at the unit.

Our ETP is having Primary, Secondary & Tertiary treatment technology.

The flow chart and ETP design detail & MEE details are attached herewith as Annexure-II.

The ETP is in well functional state, and following the standards of CPCB & MPPCB.

The sample from our ETP is also tested many times from the Madhya Pradesh Pollution Control Board, and every time the results are found well within the prescribed limit.

The treated water achieved from the ETP is used within the plant premises for gardening purpose.

We have sufficient area dedicated to the plantation, with native species. The photographs of the green area is

attached as Annexure-III In this plantation area we use complete

treated waste water is fully utilized. We are not discharging any water out

from our premises

3 PP should ensure handling, disposal and management of hazardous was as per related prescribed rules.

We have received the Hazardous Waste Authorization from Madhya Pradesh Pollution Control Board, which is valid up to 31.07.2020.

The authorization granted us for following wastes: a) Spent acid b) Chemical sludge from waste water

treatment. c) Used spent oil d) Empty barrels/containers/liners

contaminated with hazardous chemicals/wastes

We are regularly generating form 10 during disposal of above mentioned hazardous waste.

We are regularly submitting the Form 4 to MPPCB, well before time. A copy of current Form 4 is attached as Annexure-IV, which is showing the hazardous waste disposed in the entire year.

For TSDF of Hazardous Waste we have agreement with M/s Ramky Enviro Engineers Ltd. For its safe disposal,. The copy of same attached as Annexure-V

4 PP should ensure the norms for stack height and ambient air quality. PP should conduct air quality monitoring as per MPPCB norms.

We have one boiler of capacity of 5 tpd, having stack height of 30 m. The picture of boiler stack is attached as Annexure-VI.

We have 2 DG sets of 750 KVA & 1250 KVA, having chimney height of 6 m above shed and following the CPCB norms. The picture of DG Sets stack are attached as Annexure-VI.

We conduct Environment monitoring on quarterly basis from NABL Certified laboratory. The current Environment Monitoring report is attached as Annexure-VII, with NABL certificate of the laboratory.

We regularly submitting these monitoring reports to MoEF&CC, Bhopal, SEIAA, MP & MPPCB.

5 PP should obtain NOC for firefighting We have obtained the Fire NOC which is

from competent authority. valid up to 01.11.2018. Copy of the Fire NOC is attached as Annexure-VIII.

6 PP should obtain approval of the competent authority for onsite & offsite disaster management plan, Risk management plan.

We have submitted the onsite & offsite disaster management plan along with our application to department of Industrial Health & Safety and after which they have given us the factory license which is valid up to 31.12.2018.

A copy of the license is attached as Annexure-IX

We have also separately ask them to approve our onsite Emergency Plan, which is under process.

7 PP should obtain NOC for firefighting from competent authority.

We have obtained the Fire NOC which is valid up to 01.11.2018. Copy of the Fire NOC is attached as Annexure-VIII.

8 PP should ensure the Rain water harvesting.

We have installed the Rain Water Harvesting system at our unit.

B Specific Conditions as recommended by SEAC 9 PP should ensure the implementation of

CSR and CER activity on regular basis. We are doing regular CSR activities. The

following activities was conducted at site: a) Distributed school bags to under

privileged children on 5th June. b) We did plantation on large scale near

our plant premises. Pictures of CSR & CER activities are

attached as Annexure-X

10 PP should ensure plantation in three rows all along the periphery of the project area, and along the roads with one tree per 100 sq. m. of the plot area subjected to minimum of 33% of total plot area. PP should ensure plantation of the trees of indigenous local varieties like Neem, Peepal, kadam, Kachnaar etc. Every effort should b e mad e t o protect the existing trees on the plot.

We have done 2-3 rows of plantation at the unit.

We have sufficient area dedicated to the plantation, with native species. The photographs of the green area is attached as Annexure-III

We have used all native species to develop green area. Some species used for plantations are Neem, Peepal, Jamun, Mango, Guava, Kadam, Lemon, gulmohar, Seesham, Sagon etc.

11 All chemicals will have to be carefully

transported, handled and processed as per the provisions of MHISC Rules.

The complete list of chemicals used in the production is attached as Annexure-XI.

The chemicals which falls under Hazardous category are attached as Annexure-XII

We are maintaining Material Safety Data Sheet for the chemicals and also included it into onsite emergency plan.

We have conducted HAZOP study and

included study of all the chemicals used within the plant, and included all the chemicals into it. A copy of HAZOP study is attached as Annexure-XIII.

For safe transportation we use authorized vehicles and follow SOP as mentioned under Motor Vehicle Rules, 1989.

12 The chemical formulas- structure and generic names of the optical brightening agent and all other chemicals- have to be indicated in risk management plan.

The chemical formula of OBA is 4’4, Diamino Stilbene-2’2, Disulphonic Acid Solution.

We have prepared Risk Management Plan of the plant, and included all the chemicals into it.

A copy of Risk Management Plan is attached as Annexure-XIV.

C Standard Conditions 1 The company shall install an effluent

treatment plant to treat the effluent generated due to proposed activity. The treated water shall be utilized within the premises to achieve zero discharge.


Our ETP is having Primary, Secondary & Tertiary treatment technology.

The flow chart and ETP design detail & MEE are attached herewith as Annexure-II.

The treated water achieved from the ETP is used within the plant premises for gardening purpose.


In this plantation area we use complete treated waste water is fully utilized.

We are not discharging any water out from our premises

The water balance diagram is attached as Annexure-XV.

Complete treated water is used within the plant for gardening purpose. Hence no treated water is discharged outside the plant.

2 The hazardous wastes and incineration

from the process and treatment should be disposed off as per Hazardous wastes (Management & Handling) Rules, 1989 and subsequent amendments.

Authorization from Madhya Pradesh Pollution Control Board, which is valid up to 31.07.2020.

All the Hazardous waste generating is only from the process.

We are not doing any type of incineration.

The authorization granted us for following wastes: e) Spent acid f) Chemical sludge from waste water

treatment. g) Used spent oil h) Empty barrels/containers/liners



For TSDF of Hazardous Waste we have agreement with M/s Ramky Enviro Engineers Ltd. for its safe disposal. M/s Ramky Enviro Engineers Ltd. Is authorized from MPPCB. The copy of the agreement is attached as Annexure-V

We are regularly submitting the Form 4 to MPPCB, well before time. A copy of current Form 4 is attached as Annexure-IV

3 The project authority shall obtain the membership of CTSDF (Common Treatment Storage & Disposal Facility) for disposal of solid and hazardous waste (if applicable and copy of the same shall be submitted to the regional officer of MoEF, GoI at Bhopal. The company shall maintain the valid membership of CTSDF.

Authorization from Madhya Pradesh Pollution Control Board, which is valid up to 31.07.2020. A copy of Hazardous Waste Authorization is attached as Annexure-XVI.

The authorization granted us for following wastes: i) Spent acid j) Chemical sludge from waste water

treatment. k) Used spent oil l) Empty barrels/containers/liners



We are regularly submitting the Form 4 to MPPCB, well before time. A copy of current Form 4 is attached as Annexure-IV

For TSDF of Hazardous Waste we have agreement with M/s Ramky Enviro Engineers Ltd. for its safe disposal. M/s Ramky Enviro Engineers Ltd. Is authorized from MPPCB. The copy of the agreement is attached as Annexure-V

4 The process emissions, VOCs and

particulate matter from various units shall conform to the standards prescribed

There are no VOCs found at our unit. However, we have installed following Air pollution control devices at our unit to

by the concerned authorities from time to time. At no time, the emission level shall go beyond the stipulated standards.

keep check on dust: a) Dust Collector b) Bag filter c) Scrubbers

We are attaching here monitoring reports as Annexure- VII

5 Fugitive emissions in the work zone environment, product, raw materials storage area etc. shall be regularly monitored. The emissions shall conform to the limits imposed by MPPCB.

There is no fugitive emission takes place at our unit.

All machineries are completely intact and covered.

Machineries are operated in automatic manner. Mostly chemicals used in production are in liquid state and all the material directly poured into the reactor, hence no human comes in direct contact of the material.

For detergent powder production we provide mask & safety gears to the workers, however this production process is also in closed manner.

6 The company shall carry out the HAZOP study and the report shall be submitted to regional office of MoEF, GoI at Bhopal.

We have carried out the HAZOP study and the study report is attached as Annexure-XIII

7 The company shall comply with CREP guidelines prepared by MPPCB for Bulk Drug Plants.

We are following all the guidelines of CREP, whichever is related to us.

8 The company shall develop greenbelt in the project area as per the guidelines of CPCB to mitigate the effect of fugitive emission.

We have done three rows of plantation at the unit.


We have used all native species to develop green area. Some species used for plantations are Neem, Peepal, Jamun, Mango, Guava, Kadam, Lemon, gulmohar, Seesham, Sagon etc.

9 During transfer of materials, spillages

shall be avoided and garland drains be constructed to avoid mixings of accidental spillages with domestic waste and storm drains.

We have constructed garland drain around the OBA unit, and it is connected with ETP.

10 Occupational health surveillance of the workers shall be done on a regular basis and records maintained as per the Factories Act.

We have conducted the occupational health check up of workers on regular basis.

The latest check up record is attached as Annexure-XVII.

11 The company shall make the arrangement for protection of possible

We have developed an effective fire protection system to deal with any fire

fire hazards during manufacturing process in material handling.

hazard within the premises. We have also placed 105 fire

extinguishers at various places to deal with small fire situations.

We have 23 no. of hose reels in the fire hydrant system.

We have installed diesel pumps for emergency situations.

The photos of fire hydrant system and fire extinguishers are attached as Annexure-XVIII.


We regularly conduct mock drills and give fire fighting training to or workers and staff to overcome from any fire situations.

12 The DG set will be provided with acoustic arrangements to attenuate the noise pollution. The emission from DG set shall be dispersed as per the CPCB/ MPPCB standards.

We have two DG sets within the premises for emergency backup.

The DG sets are of 750 KVA & 1250 KVA capacity.

We had purchased the inbuilt acoustically enclosed type of DG sets, which are following the CPCB Standards.

Since our LABSA plant is closed, hence now we have discontinued 1250 KVA & 1010 KVA is used at place of 1250 KVA.

The emission from DG set is dispersed as per the CPCB/ MPPCB standards.

13 Industry get the Emergency Disaster Management Plan approved by DTHS and should also comply with the provisions made in Public Liability Insurance Act, 1991

We have submitted the onsite & offsite disaster management plan along with our application to department of Industrial Health & Safety and after which they have given us the factory license which is valid up to 31.12.2018.

A copy of the license is attached as Annexure-IX.

Public Liability Insurance Act, 1991 is not applicable on us, as we have storage less than the prescribed limit.

14 Any enhancement of capacity, change in technology, modernization and scope of working shall again require prior environmental clearance as per EIA Notification, 2006.

We are now enhancing the production capacity of this unit, and therefore applied to MoEF&CC for fresh Environmental Clearance.

A receiving copy of application is attached as Annexure-XIX

15 All activities/ mitigative measures proposed by PP in Environmental impact Assessment must be ensured.

We have installed an ETP of 40 KLD at our unit.

We have installed MEE of 100 KLD capacity at our unit.

We have also installed the Air Pollution Control Devices within the plant premises, like, Dust collector and Bag filters.

For TSDF of Hazardous Waste we have agreement with M/s Ramky Enviro Engineers Ltd. For its safe disposal. The copy of same attached as Annexure-V.

All conditions mentioned under EC are strictly complied.

16 All activities/ mitigative measures proposed by PP in Environmental Management Plan and approved by SEAC must be ensured.

We have followed all mitigation measures which were proposed by SEAC, Madhya Pradesh.

We have installed an ETP of 40 KLD at our unit.

We have installed MEE of 100 KLD capacity at our unit.

We have also installed the Air Pollution Control Devices within the plant premises, like, Dust collector and Bag filters.

For TSDF of Hazardous Waste we have agreement with M/s Ramky Enviro Engineers Ltd. For its safe disposal. The copy of same attached as Annexure-V.

All conditions mentioned under EC are strictly complied.

17 All parameters listed in Environmental Monitoring Plan approved by SEAC must be monitored at approved locations and frequencies.

We use to conduct regular Environment monitoring within our plant remises.

The frequencies of the Environment monitoring are on quarterly basis, which mean we conduct 4 monitoring within a year.

We have 2 monitoring locations at windward and 2 at leeward.

We conduct these monitoring from NABL Certified laboratory. The current Environment Monitoring report is attached as Annexure-VII, with NABL certificate of the laboratory.

18 Vehicular emissions shall be kept under

control and regularly monitored. Vehicles used for transportation of raw material and others shall have valid

We use to keep a check on vehicular emission within the plant premises.

We check the “Pollution under Control”

permissions as prescribed under Central Motor Vehicle Rules, 1989 and its amendments. No overloading of raw materials for transportation shall be committed.

(PUC) Certificate & license of every vehicle entering inside the premises.

We keep record of every vehicle entering inside the premises either personal or logistic vehicles.

We do not allow over loaded vehicles within the plant.

Moreover, we refuse the entry of over loaded trucks.

To keep a check on overloaded trucks we have constructed a way bridge.

19 The company shall develop rain water harvesting structures to harvest the Runoff w a t e r f o r r e c h a r g e o f g r o u n d water.

We have developed the Rain Water Harvesting system within the premises.

20 A separate Environmental Management Cell with suitable qualified personnel shall be set-up under the control of a Senior Executive, who will report directly to the Head of the Organization.

We have an Environment Management Cell, which includes well versed personnel, who keeps the environment and safety condition up to date of the plant premises.

The Environment Management Cell includes the followings: a) General Manager-EHS (Delhi) b) EHS officer-Sagar Unit-II c) 3 ETP operators. d) MEE operators.

21 The funds earmarked for environmental

protection measures shall be kept in separate account and shall not be diverted for other purpose. Year wise expenditure shall be reported to the regional office of the Ministry of Environment and Forest, Bhopal and MPPCB.

The fund spent on various environment protection devices are as follows:

Items 2015-2016 2016-2017

ETP 40 Lakh

ETP Operation &

Maintenance

5 Lakh 5 Lakh

MEE 1.5 Crore 25 Lakh

(upgradation)

Dust Collector 20 Lakh 10 Lakh

(cyclone)

Bag Filter 30 Lakh

Plantation 2 Lakh 2 Lakh

Environment

Monitoring

1 Lakh 1 Lakh

22 Commitment towards CSR has to be followed strictly.

We are doing regular CSR activities. The following activities was conducted at site: c) Distributed school bags to under

privileged children on 5th June. d) We did plantation on large scale near

our plant premises.

23 All other statutory clearance such as the approvals for storage of diesel from Chief Controller of Explosives, Fire Department, Civil Aviation Department, Forest Conservation Act 1980 and Wildlife (Protection) Act, 1972 etc. shall be obtained (as and when applicable), by the project proponent from the respective competent authorities.

We have obtained various statutory clearance from various departments, like:

Fire NOC : Obtained

Civil Aviation Department

NOC

: Not Applicable

Forest NOC : Not Applicable

Factory License : Obtained

M.P. Pollution Control Board

(CTO)

: Obtained

(Annexure-XX)

24 The regional office, MoEF, GoI, Bhopal and MPPCB shall monitor compliance of the stipulated conditions, A complete set of documents including Environment Impact Assessment Report, Environmental Management Plan, should be give to Regional Office, MoEF, GoI, Bhopal and MPPCB.

We had submitted the EIA Report, Environment Management Plan to MoEF&CC, Bhopal and MPPCB along with first compliance report.

25 The Project Proponent has to submit half yearly compliance report of the stipulated prior environmental clearance Terms and conditions in hard and soft copy to the Regulatory Authority on1st

June and 1st December of each

calendar year.

We use to submit regular EC compliance to MoEF&CC, Bhopal and MPPCB, on six monthly bases.

The EC compliance report includes the progress report, Environmental Management Plan & Environment Monitoring reports.

A copy of recent EC compliance (June 2017) is attached as Annexure-XXI.

26 A copy of the environmental clearance shall be submitted by the Project Proponent to the Heads of the Local Bodies, Panchayat and Municipal Bodies as applicable in addition to the concerned Government Departments/ Organization responsible for controlling the proposed projects who in turn has to display the same for 30 days from the date of receipt.

We had submitted the copy of Environmental Clearance to local bodies.

27 The project proponent has to strictly follow directions/guidelines issued by the MoEF, GoI, CPCB and other Govt. agencies from time to time.

We are following the MoEF&CC, CPCB, and other applicable agencies guidelines.


The ETP is in well functional state, and following the standards of CPCB.

To mitigate with air pollution we have installed dust collector, bag filter at the project site.

Also we have raised the chimney height of DG sets and boiler, as per the CPCB standards.

We conduct a quarterly basis

Environment monitoring at the project site, and the test reports ensure that all the discharge and emission follows the CPCB and MoEF&CC norms.

The current Environment Monitoring report is attached as Annexure-VII, with NABL certificate of the laboratory.

28 The Project Proponent shall advertise at

least in two local newspapers widely circulated, one of which shall be in the vernacular languages of the locality concerned, within 7 days of the issue of the clearance letter informing that the project has been accorded environmental clearance and a copy of the clearance letter is available with the State Pollution Control Board and also at web site of the State Level Environment Impact Assessment Authority (SEIAA) website at www.mpseiaa.nic.in and a copy of the same shall be forwarded to the regional office, MoEF, GoI, Bhopal and MPPCB.

As suggested, we had published the advertisement in two local newspapers.

A copy of same is attached as Annexure-XXII.

29 The company shall make the arrangement for protection of possible fire hazards during manufacturing process in material handling.

We have developed an effective fire protection system to deal with any fire hazard within the premises.

We have also placed 105 fire extinguishers at various places to deal with small fire situations.

We have 23 no. of hose reels in the fire hydrant system.

We have installed diesel pumps for emergency situations.

The photos of fire hydrant system and fire extinguishers are attached as Annexure-XVIII.


We regularly conduct mock drills and give fire fighting training to or workers and staff to overcome from any fire situations.

30 The SEIAA of M.P. reserves the right to add additional safeguard measures subsequently, if found necessary, and to take action including revoking of the environment clearance under the provisions of the Environmental (Protection) Act, 1986, to ensure effective implementation of the

We agree with this point. We are following all the guidelines and

never violate any condition mention under Environment Impact Assessment & Environment Clearance.

http://www.mpseiaa.nic.in/

suggested safeguard measures in a time bound and satisfactory manner.

31 Action plan with respect to suggestion/ improvement and recommendations made and agreed during public hearing consultation shall be submitted to the Regional Office, MoEF, GoI, Bhopal, MPPCB within Six months.

We have followed all the recommendations suggested in the public hearing.

a) Local Employment: Mostly workers which are employed in our plant are local.

b) No discharge from plant: We have installed ETP & MEE within the plant to treat all the waste water generating from the plant. We are using all treated water within the plant for gardening purpose.

c) Plantation: We have done plantation inside and around the factory.

32 These stipulations would be enforced among others under the provisions of Water (Prevention and Control of Pollution) Act, 1974, the Air (Prevention and Control of Pollution) Act 1981, the Environment (Protection) Act, 1986, the Public Liability (Insurance) Act, 1991 and EIA Notification, 2006.

We have obtained Consent to operate from Madhya Pradesh Pollution Control Board under Air & Water Act, which is valid up to 31.07.2018.

We are strictly complying with the consent condition at our plant.

Public Liability Insurance Act, 1991 is not applicable on us, as we have storage less than the prescribed limit.

33 The Ministry or any other competent authority may alter/modify the above conditions or stipulated any further condition in the interest of environment protection.

We are agreed with this point. We ensure that whatever amendment

will be done, it will be strictly followed by us.

34 Concealing factual data or submission of false/fabricated data and failure to comply with any of the conditions mentioned above may result in withdrawal of this clearance and attract action under the provisions of environment (Protection) Act, 1986.

We have not concealed any fact or data from SEIAA, MoEF&CC and MPPCB.

Hence there is no question of withdrawal of our Environmental Clearance.

35 Any appeal against this prior environmental clearance shall lie with the Green Tribunal, if necessary, within a period of 30 days as prescribed under Section 16 of the National Green Tribunal Act, 2010.

We have not made any appeal against EC obtained by us.

36 The prior Environmental Clearance granted for the project is valid for a period of five years as per EIA notification dated. 14-09-2006.

We had received Environmental Clearance from SEIAA, MP before starting the project.

This EC was granted on 17.03.2015. This EC is valid up to 16.03.2020. We are now enhancing the production

capacity of this unit, and therefore applied to MoEF&CC for fresh prior Environmental Clearance.

A receiving copy of application is attached as Annexure-XIX.

37 The proponent shall upload the status of compliance of the stipulated EC conditions, including results of monitored data on their website and shall update the same periodically. It shall simultaneously be sent to the Regional Office of MoEF, the respective Zonal Office of CPCB and the SPCB. The criteria pollutant levels namely; SPM, RSPM, SO2, NOx, (ambient level as well as stack emissions) or critical sectoral parameters, indicated for the project shall be monitored and displayed at a convenient location near the main gate of the company in the public domain.

We use to submit regular EC compliance to MoEF&CC, Bhopal and MPPCB, on six monthly bases.

The EC compliance report includes the progress report, Environmental Management Plan & Environment Monitoring reports.

A copy of recent EC compliance (June 2017) is attached as Annexure-XXI.

We have uploaded the EC compliance along with monitoring data at our website.

38 The environmental statement for each

financial year ending 31st March in

Form-V as is mandated to be submitted by the project proponent to the concerned State Pollution Control Board as prescribed under the Environment (Protection) Rules, 1986, as amended subsequently, shall also be put on the wesite of the company along with the status of compliance of EC conditions and shall also be sent to the Regional Office of MoEF.

We use to submit Environment Statement regularly to MPPCB for each financial y e a r e n d i n g 3 1 s t March i n Form-V.

A copy of recent submission is attached as Annexure-XXIII.

Documents

Point wise compliance of condition of Environmental Clearancegharidetergent.com/EC Compliance_Sagar Unit 2.pdf · plantation, with native species. The photographs of the green area