Consultancy Services for Assessment of Contamination ... Services/Khazipally study/Kazipally...

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Consultancy Services for Assessment of Contamination, Design of Remediation Plan & Supervision of Remediation Activities: Kazipally, Telangana, India Task 2 Final Report February 2018 www.erm.com

Telangana State Pollution Control Board

FINAL REPORT

Telangana State Pollution Control Board

Consultancy Services for Assessment of Contamination, Design of Remediation Plan & Supervision of Remediation Activities: Kazipally, Telangana, India

12 February 2018 Reference # I10402/0358611

Reviewed by:

Priya Shivalkar Senior Consultant

Approved by:

Samrat Basak Partner

This report has been prepared by ERM India Private Limited a member of Environmental Resources Management Group of companies, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client.

We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above.

This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

CONTENTS

1 INTRODUCTON 1

1.1 PROJECT BACKGROUND 1 1.2 PROJECT OBJECTIVES 2 1.3 ASSUMPTIONS AND LIMITATIONS 3 1.3.1 Scope of the Assessment 3 1.3.2 Site Specific Limitations 3 1.4 REPORT STRUCTURE 3

2 INVENTORY OF POTENTIAL CONTAMINANT SOURCES 4

2.1 ASSESSMENT METHODOLOGY 5 2.2 POTENTIAL SOURCES OF CONTAMINATION FROM INDUSTRIES 6

3 POTENTIAL HAZARDOUS WASTE DISPOSAL AREAS WITHIN THE CATCHMENT AREA 8

4 RECEPTOR SURVEY 10

5 SAMPLING ACTION PLAN 11

5.1.1 Waste 43 5.2 ANALYSIS PLAN 43

6 APPROACH & METHODOLOGY FOR TASK 3 INVESTIGATIONS 44

6.1 HEALTH AND SAFETY 44 6.1.1 Identification of Drilling Locations and Underground Service Clearance 45 6.1.2 Equipment Decontamination 46 6.2 SURFACE WATER SAMPLING PROTOCOL 47 6.3 SEDIMENT SAMPLING PROTOCOL 48 6.3.1 Collection of surface sediments 48 6.3.2 Collection of sediment from depth 48 6.4 SOIL BORING AND SOIL SAMPLING 49 6.4.1 Soil Boring Protocol 49 6.5 MONITORING WELL DRILLING AND GROUNDWATER SAMPLING PROTOCOL 50 6.5.1 Monitoring Well Drilling Protocol 50 6.5.2 Groundwater Sampling Protocol 51 6.6 QUALITY ASSURANCE / QUALITY CONTROL PROCEDURES FOR FIELD SAMPLING 53 6.7 SAMPLE HANDLING PROTOCOL 53 6.8 ASSISTANCE FROM TSPCB 53

ENVIRONMENTAL RESOURCES MANAGEMENT TASK 2 DRAFT REPORT KAZIPALLY TSPCB PROJECT # 0356611 FEBRUARY 2018

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1 INTRODUCTON

ERM India Private Limited (ERM) was commissioned by the Telangana State Pollution Control Board (hereinafter referred to as ‘TSPCB’ or the ‘Client’) for providing consultancy services for the Assessment of Contamination, Design of Remediation Plan and Supervision of Remediation Activities of Kazipally Tank (hereinafter referred to as the ‘Project’) situated in Medak District, Telangana, India (hereinafter referred to as ‘Kazipally Lake’). Following the award of the contract on 25 June 2016, ERM had a Project Kick-off meeting with TSPCB on 13 July 2016 at TSPCB’s office located in Hyderabad. The Project is divided into five (5) Tasks in order to achieve the Project objective. These Tasks are specified in Section 1.3 below. This Report presents findings from the Task 2 – Inventory of Potential Contaminant Sources of the lake and its catchment area. The field activities for Task – 2 were initiated on 11 April 2017 and were completed on 23 April 2017.

1.1 PROJECT BACKGROUND

The Government of India, through the Ministry of Environment and Forest (MOEF) is implementing a project on Capacity Building and Industrial Pollution Management (CBIPMP) with financial assistance from the World Bank. The objective of the project is aligned with the endeavour of the GOI to establish a National Program for Rehabilitation of Polluted Sites (NPRPS) as a framework for scaling up the cleanup and rehabilitation of polluted sites and facilitate the reduction of environmental and health risks associated with legacy polluted sites, It also aims to build capacity at the State and Central level and develop a framework to address these issues in a comprehensive and systematic manner. Project activities will include demonstrative investments for area-based management of pollution resulting from legacy contamination and ongoing industrial activities through i) remediaton / containment of polluted sites/ hazardous waste hotspots, ii) implementation of enforcement and self-regulatory measures to improve compliance and competitiveness of industries in selected industrial clusters, and iv) upgrading of common environmental infrastructure. The Telangana State Pollution Control Board (TSPCB) is a statutory organisation responsible for the implementation of environmental laws and rules within the jurisdiction of the State of Telangana, India. The current project is being implemented under the World Bank assisted Capacity Building for Industrial Pollution Management Project (CBIPMP).


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The CBIPMP was rolled out to build the environmental management capacity of environmental institutions including state regulatory bodies and to promote investments in integrated pollution management.

1.2 PROJECT OBJECTIVES

The objective of the project is to: To characterize the nature and extent of environmental impact of the lake

body (surface water and sediment), if any; To characterize the nature and extent of environmental impact, if any, of

soil and groundwater from the upstream sources within the lake catchment area;

To develop of feasible and cost-effective intervention measure(s) to mitigate the assessed impact(s) of Soil and/ or groundwater and/ or sediment and/ or Surface water for defined end use;

To prepare the bidding documents for implementation of remedial intervention measures; and

To supervise the implementation of remedial intervention measures. The objectives are to be achieved in the following steps: Task 1 - Reconnaissance and Preliminary Site Assessment

o Background Literature Study and Collation o Visual Inspection o Site Reconnaissance o Drainage Survey o Stakeholder Consultation o Receptor Survey

Task 2 - Inventory of Potential Contaminant Sources (Current Task)

o Evaluate past activities, current on-site operations and related practices at the Site, as appropriate, to establish known or potential sources of material surface water, soil, groundwater impact.

Task 3 - Preliminary Investigation of the Lake

o Topographic Survey o Geotechnical Profiling o Hydrogeological Assessment o Bathymetric Survey o Environmental Screening and Sampling o Develop Preliminary Conceptual Site Model & Qualitative Assessment

of Environmental Risk

Task 4 - Contamination Delineation & Modelling o Additional Investigations o Hydrogeological Investigation & Modelling o Risk Assessment o Environmental, Social and Ecological Survey

Task 5 - Developing Remedial Action Plan


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Task 6 - Preparation of Detailed Project Report This Report presents findings from the Task 2 – Inventory of Potential Contaminant Sources of the lake and its catchment area.

1.3 ASSUMPTIONS AND LIMITATIONS

1.3.1 Scope of the Assessment

This Report is based upon the application of scientific principles and professional judgment to certain facts with resultant subjective interpretations. Professional judgments expressed herein are based on the facts currently available within the limits of the existing data, scope of work, budget and schedule. To the extent that more definitive conclusions are desired by the Client than are warranted by the currently available facts, it is specifically ERM’s intent that the conclusions stated herein will be intended as guidance. ERM makes no warranties, express or implied, including, without limitation, warranties as to merchantability or fitness for a particular purpose. In addition, the information provided to the Client in this report is not to be construed as legal advice

1.3.2 Site Specific Limitations

This Report is based on Site conditions and Site information as detailed by the Site contact(s) on the day on which the individual Site visits were carried out. Only those areas within the Site were covered for which ERM Professionals were given access. Professional judgments expressed herein are based on the facts currently available within the limits of the existing data, scope of work, budget and schedule. Reasonable amount of effort and professional care has been taken to collect, collate and review the documents/records and information, obtained during the course of the assessment.

1.4 REPORT STRUCTURE

The structure of Site Reconnaissance and Preliminary Assessment Report is summarized below: Section 1 Introduction; Section 2 Inventory of Potential Contaminant Sources; Section 3 Sampling Action Plan. Annexes to the Report Annex A Inventory of Potential Contaminant Sources; and Annex B Summary of Site Visits


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2 INVENTORY OF POTENTIAL CONTAMINANT SOURCES

During the Task 1 of the Project (detailed in Section 6 of the Task 1 Report), ERM prepared an industry sector specific inventory of potential waste generators within the catchment. Based on the Task 1Assessment, all the industries within the micro-watershed of the Kazipally Lake were identified as Potential Area of Concern (PAoC). Over 15% of the watershed is covered by industries. The same inventory was updated as a part of Task 2, wherein each of the thirty one (31) industries (as per the list of industries given to ERM by TSPCB) was visited. The maps showing each of these industries are given below in Figure 2.1 and Figure 2.2. The details of the Task are mentioned in the Sections below.

Figure 2.1 Map showing the Pharmaceutical and Chemical Industries within the catchment covered as part of Task 2


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Figure 2.2 Map showing the Manufacturing, Fabrication and Other Industries within the catchment covered as a part of Task 2

2.1 ASSESSMENT METHODOLOGY

A detailed list of all the industries within the micro-watershed was obtained from TSPCB, following which each industry was contacted (details of Site contact person and date of visit mentioned in Annex B Summary of Site Visits) and informed about the Project and Site visit. The Assessment was conducted to identify, evaluate and document the potential areas of concerns with respect to surface water, soil and groundwater contamination, if any, due to the current operations in the various industries visited. The Assessment consists of interviews with Site management and technical staff responsible for Environmental, Health and Safety (EHS) and Production aspects at the Site. On the day of the Site visits, ERM Professionals, along with Site contacts, conducted a Site walkthrough at each of the facility to understand the following: Overall site operations; Raw material storage and handling; Wastewater generation, handling, storage and disposal; Hazardous waste generation, handling, storage and disposal; Surface/ storm water drainage network and final outlet. Photographs were taken where permitted.


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2.2 POTENTIAL SOURCES OF CONTAMINATION FROM INDUSTRIES

The probability of occurrence (i.e. likelihood or potential presence of significant impact associated with surface water, soil and/ or groundwater contamination) has been rated as low, medium or high, based on the known or observed site conditions on the day of the Site visit, potential magnitude of the source and/ or potential release duration (if any), available historical information and, based on the above, the subjective likelihood for potential areas of concern to contribute to significant surface water, soil and/ or groundwater contamination.

Table 2.2 below presents industry wise, and matrix wise, Probability of Impacting Environmental Matrices to identify the Potential Areas of Concerns based on the information obtained from all the industries. The details for the Risk Ratings are attached as Annex A Inventory of Potential Contaminant Sources and Annex B Summary of Site Visits.

Table 2.1 Industry and Matrix wise Rating

Sr. No. #

Industry Name Probability of Impacting Environmental Matrices Raw Material

Wastewater Hazardous Waste

Surface Water

Groundwater

1 Balaji Galvanizing India Limited

Medium High High High Low

2 Divis Pharmaceuticals Pvt Ltd

Medium Low High High Medium

3 Emmenar Pharma Unit 1 Pvt Ltd

Medium Medium High High Low

4 Goldstone Infratech Limited

NA NA NA Low Low

5 KRS Pharmaceuticals Pvt Ltd

Medium Medium Medium Medium Medium

6 Lee Pharma Ltd. High High High High Medium 7 Regent Paints Pvt

Ltd High Medium High High Medium

8 Selma Laboratories Private Limited

NA N.A. NA Low Low

9 TIDC India Pvt Ltd Medium High High High Medium 10 TPS Laboratories

Pvt Ltd High Medium High High Medium

11 Hyderabad Waste Management Project

High High High High High

12 Virchow Chemicals Medium Low Low High Medium 13 Virupaksha

Organics Limited High Medium High High Medium

14 Mylan Labs Unit -1 Low Low Low Medium Low 15 Hetero High Medium Medium High Meduim 16 Arch Pharma Labs

Limited Medium Low Medium Medium Medium


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Sr. No. #

Industry Name Probability of Impacting Environmental Matrices Raw Material

Wastewater Hazardous Waste

Surface Water

Groundwater

17 Benova Labs Pvt Ltd

High Medium High High Low

18 Chemtech Acids and Chemicals

High N.A. NA Medium Low

19 Chemtech Fertilizers

Medium N.A. NA Medium Low

20 Kekule Pharma Limited

High High High High Medium

21 KRR Pharmaceuticals Pvt Ltd

NA N.A. NA NA Low

22 SMS Pharmaceuticals Limited (Unit 1)

High High High High Low

23 Sri Ram Chlorochem

High Low Medium High Medium

24 Vantech Chemicals Limited

Low NA NA Low Low

25 Navodaya Packaging

Low NA NA Low Low

26 Yagmag NA NA NA NA NA


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3 POTENTIAL HAZARDOUS WASTE DISPOSAL AREAS WITHIN THE CATCHMENT AREA

During the Task 1 of the Project (detailed in Section 6 of the Task 1 Report), ERM identified disorganized disposal of potential industrial waste material noted at various locations within the Study Area. Each of these potential waste disposal locations was identified within the Study Area and screened for volatile organic compounds using a Photo Ionisation Detector (PID). The screening results are summarised in the table below.

Table 3.1 Summary of PID values for potential waste disposal areas

Sl.No Waste Disposal Area ID

PID Value (ppm) Area Description

1 D-04 (a)

0 Black amorphous chunks, likely to be coal ash

D-04 (b) 0 Debris mixed black coloured fine to coarse grained waste with yellow amorphous material

2 D-07 (a) 0.1 Greyish coloured, fine grained waste

D-07 (b) 0.6 Orange coloured , fine grained

3 D-12 0.0 Black coarse sand.

4 D-13 0.7 Black colour amorphous coal ash debris.

The details of the above findings are presented in Error! Reference source not found.3.1 below.


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Figure 3.1 Locations of potential waste disposal within the Study Area (does not include private areas/ individual industries)


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4 RECEPTOR SURVEY

During the Task 1 of the Project (detailed in Section 4 of the Task 1 Report), ERM identified water supply systems and groundwater abstraction sources (mainly the bore-wells and hand pumps1) within the Study area and the “Receptors” dependent on each of these identified sources. This data was updated during the current study to include the abstraction wells located in the industries within the Kazipally catchment

Figure 4.1 Map indicating abstraction wells identified by ERM within the Study area

(1) 1 A hand pump is a simple hand operated reciprocating pump which is widely used in the Indian towns and villages where the first water-bearing stratum is within reasonable depth from the ground surface.


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5 SAMPLING ACTION PLAN

The Sampling and Analysis Plan (SAP) has been developed based on the findings from the current Task. The details of the Sampling and Analysis Plan along with the locations are discussed below.


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Table 3.5.1 Surface Water Sampling Plan Details

Sr. No. #

Sample ID Rationale Location Map Location Photograph

1 SW-001 During the Site visit to Virchow, it was noted that historically the surface runoff outlet was located at the southwestern boundary of the Site. This sampling location is intended to evaluate impact to surface water environmental quality, if any.

2 SW-002 During the Site visit to Lee Pharma and

Emmennar, storm water outlets were noted to be leading into TIDC. This sampling location is intended to evaluate impact to surface water environmental quality, if any in the area within TIDC.


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Sr. No. #


3 SW-003 During the Site visit to HWMP, storm water outlet was noted at the south western corner of the Site. This sampling location is intended to evaluate impact to surface water environmental quality, if any, in the area outside the HWMP southwestern boundary. (risk rating for surface water High)

4 SW-004 During the Site visit to the seepage collection sump it was noted that overflows from the sump flows south west towards a low lying area forming a pool. This sampling location is intended to evaluate impact to surface water environmental quality, if any.

5 SW-005 These sampling locations are intended to

evaluate impact to surface water environmental quality downstream of the industrial area, if any.

Photograph not available

6 SW-006

7 SW-007 During the post monsoon season, the Kazipally Lake water was noted to have a reddish yellow color and water was present in various pockets within the lake bed. These sampling locations are intended to evaluate impact to surface water environmental quality.

8 SW-008

9 SW-009


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Sr. No. #


10 SW-010 The surface water from Kazipally flows south through a weir located southwest of the lake. This sampling location is intended to evaluate impact to surface water environmental quality, if any.

Summary of Surface Water Sampling:

Collection of two (02) surface water samples from the lake; Collection of one (01) surface water sample from the lake outlet; Collection of seven (07) surface water samples from the drains; Collection of one (01) duplicate surface water sample for QA/QC purpose. The sampling locations are shown in Figures 3.1 and 3.2 below.


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Figure 5.1 Surface water sampling plan


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Figure 5.2 Surface water sampling plan (view from South – East of Watershed)


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Table 3.2 Sediment Sampling Plan Details

Sr. No. # Sample ID

Rationale Location Map Location Photograph

1 SE-001 Based on historical satellite images, a storm water runoff outlet was noted along the southern boundary of HWMP. This sampling location is intended to evaluate impact to sediment environmental quality, if any, in this area.

2 SE-002 During the Site visit to HWMP, storm water outlet was noted at the south western corner of the Site. This sampling location is intended to evaluate impact to sediment environmental quality, if any, in the area outside the southwestern boundary.

3 SE-003 During the Site visit to Lee Pharma and Emmennar, storm water outlets were noted to be leading into TIDC. This sampling location is intended to evaluate impact to sediment environmental quality, if any, within the TIDC area.


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Sr. No. # Sample ID


4 SE-004 During the Site visit to Virchow, it was noted that a stormwater outlet is located in the southeastern corner of the Site. This sampling location is intended to evaluate impact to sediment environmental quality, if any.


5 SE-005 During the Site visit in the post monsoon season, stagnant pools of water were noted in a vacant area south of Chemtech Fertiliser. The water was noted to be reddish in color. This sampling location is intended to evaluate impact to sediment environmental quality, if any.


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Sr. No. # Sample ID


6 SE-006 During the Site visit to the seepage collection sump area it was noted that overflows from the sump flows south west towards a low lying area forming a pool. This sampling location is intended to evaluate impact to sediment environmental quality, if any.

7 SE-007 These sampling location is intended to evaluate impact to sediment environmental quality, if any, downstream of the industrial areas.


8 SE-008

9 SE-009

10 SE-010

11 SE-011 During the post monsoon season, the Kazipally Lake water was noted to have a reddish yellow color and water was present in various pockets within the lake bed. These sampling locations are intended to evaluate impact to sediment

12 SE-012

13 SE-013


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Sr. No. # Sample ID


14 SE-014 environmental quality, if any.

15 SE-015 The surface water from Kazipally flows south through a weir located southwest of the lake. This sampling location is intended to evaluate impact to sediment environmental quality, if any.

Summary of Sediment Sampling:

Collection of fifteen (15) grab sediment samples; Collection of three (03) core sediment samples. The sampling locations are shown in Figures 3.3 and 3.4 below.


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Figure 5.3 Sediment sampling plan


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Figure 5.4 Sediment sampling plan (view from South - West of Watershed)


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Table 3.3 Details of Soil Sampling Locations

Sr. No. #

Soil ID Rationale Location Map Location Photograph

1 SB-001 Background sample


2 SB-002


3 SB-003 Based on historical satellite images, a storm water runoff outlet was noted along the southern boundary of HWMP. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area.


4 SB-004 This sampling location is located adjacent to the incinerator shed area within the HWMP and is intended to evaluate impact to soil environmental quality, if any.



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Sr. No. #


5 SB-005 During the Site visit to HWMP, storm water outlet was noted at the south western corner of the Site. Stagnant reddish colored water was noted outside the boundary wall. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area.

6 SB-006 Based on historical satellite images, a stagnant pool of water was noted south of Regent Paints and Kekule Pharma. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area.


7 SB-007 During the Site visit to Vantech Chemicals, storm water outlet was noted at the western corner of the Site. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area.



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Sr. No. #


8 SB-008 This sampling location to the west of SMS Pharma is intended to evaluate impact to soil environmental quality, if any, in the area due to surface water discharge along the western boundary.


9 SB-009 In historical satellite images, flooding is noted in the seepage collection sump area. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area.

10 SB-010 During the Site visit to the seepage collection sump area it was noted that overflows from the sump flows south west towards a low lying area forming a pool. The water was noted to be black in color. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area.


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Sr. No. #


11 SB-011 During the Site visit in the post monsoon season, stagnant pools of water were noted in a vacant area south of Chemtech Fertiliser. The water was noted to be reddish in color. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area.

12 SB-012 During the Site visit to hetero, storm water

was noted to flow through the gate located along the western boundary. This sampling location in the vacant area opposite to Hetero gate is is intended to evaluate impact to soil environmental quality, if any.


13 SB-013 During the Site visit, the drain leading to the seepage collection sump located between Hetero and SMS was noted to be stained along the sides. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area


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Sr. No. #


14 SB-014 During the Site visit to Lee Pharma and Emmenar, storm water outlets were noted to be leading into the TIDC area. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the low lying area within TIDC.

15 SB-015 During the Site visit to Lee Pharma, storm

water outlet was noted to be leading into the TIDC area. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area adjacent to Lee Pharma storm water discharge outlet.

16 SB-016 During the Site visit to Emmenar, storm water outlet was noted to be leading into the TIDC area. This sampling location is intended to evaluate impact to soil environmental quality, if any, in the area adjacent to Emmenar storm water discharge outlet.


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Sr. No. #


17 SB-017 In historical satellite images, Solar Evaporation Ponds (SEP) were noted within the Virchow Site. This sampling location is intended to evaluate impact to soil environmental quality, if any in the area.


18 SB-018 During the Site visit to Virchow, it was noted that historically the surface runoff outlet was located at the southwestern boundary of the Site. This sampling location is intended to evaluate impact to soil environmental quality, if any in the area.

19 SB-019 This sampling location is intended to

evaluate impact to soil environmental quality, if any in the vacant land south of Arch Pharma. (risk rating for surface water High)



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Sr. No. #


20 SB-020 This sampling location is adjacent to Cell 1 within the HWMP Site. This location is intended to evaluate impact to soil environmental quality, if any due to landfilling activities in the area.

Summary of Soil Sampling:

Collection of twenty (20) soil samples from twenty (20) soil boring locations The sampling locations are shown in Figures 3.5 and 3.6 below.


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Figure 5.5 Soil sampling plan


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Figure 5.6 Soil sampling plan (view from North - East of Watershed)


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Table 3.4 Details of Groundwater Sampling Locations

Sr. No. #

Monitoring Well ID


1 MW-001 Background sample


2 MW-002 Based on historical satellite images, a storm water runoff outlet was noted along the southern boundary of HWMP. This location is intended to evaluate impact to groundwater environmental quality, if any, in the area.


3 MW-003 During Site visit it was noted that the outlet from HWMP flows southwest and staining was noted in the area. This location is intended to evaluate impact to groundwater environmental quality, if any, in the area downgradient to HWMP.


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Sr. No. #

Monitoring Well ID


4 MW-004 The surface water from Kazipally Lake flows south through a weir located southwest of the lake. This location is intended to evaluate impact to groundwater environmental quality, if any in the area.

5 MW-005 During the post monsoon

season the Kazipally Lake water was noted to have a reddish yellow color and water was present in various pockets within the lake bed. This location is intended to evaluate impact to groundwater environmental quality, if any in the area adjacent to the Kazipally lakebed.

6 MW-006 This location is intended to evaluate impact to groundwater environmental quality, if any, in the area downgradient to the industrial area.



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Sr. No. #

Monitoring Well ID


7 MW-007


8 MW-08


9 MW-009 Based on historical satellite images stagnant pools of water were noted southwest of Sri Ram Chlorochem. This location is intended to evaluate impact to groundwater environmental quality, if any in the area.



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Sr. No. #

Monitoring Well ID


10 MW-010 During the Site visit to HWMP, storm water outlet was noted at the south western corner of the Site. This location is located downgradient of HWMP and is intended to evaluate impact to groundwater environmental quality, if any in the area.

11 MW-011 This location is intended to

evaluate impact to groundwater environmental quality, if any in the area downgradient of Reagent Paints and Kekule (risk rating for groundwater High)


12 MW-012 During the Site visit to the seepage collection sump area it was noted that overflows from the sump flows south west towards a low lying area forming a pool. The water was noted to be black in color. The water flows further south west towards the Kazipally Lake. This location is intended to evaluate impact to groundwater environmental quality, if any in the area.



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Sr. No. #

Monitoring Well ID


13 MW-013 This location is intended to evaluate impact to groundwater environmental quality, if any in the area. To check for groundwater quality downgradient of the Hetero (risk rating for groundwater High)


14 MW-014 During the Site visit in the post monsoon season, stagnant pools of water were noted in a vacant area south of Chemtech Fertilizer. The water was noted to be reddish in color. This location is intended to evaluate impact to groundwater environmental quality, if any.

15 MW-015 In historical satellite images,

flooding is noted in the seepage collection sump area. This location is intended to evaluate impact to groundwater environmental quality, if any.


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Sr. No. #

Monitoring Well ID


16 MW-016 During the Site visit to Lee Pharma and Emmenaar, storm water outlets were noted to be leading into TIDC area. The low lying area within TIDC was noted to be heavily stained. This location is intended to evaluate impact to groundwater environmental quality, if any.

17 MW-017 In historical satellite images, flooding is noted west of Hetero industries. This location is intended to evaluate impact to groundwater environmental quality, if any due to historical flooding in the area.


18 MW-018 During the Site visit to Virchow, it was noted that historically the surface runoff outlet was located at the southwestern boundary of the Site. This location is intended to evaluate impact to groundwater environmental quality, if any


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Sr. No. #

Monitoring Well ID


19 MW-019 During the Site visit to Mylan Unit –I, storm water outlets were noted south of the Site. This location is intended to evaluate impact to groundwater environmental quality, if any..

20 MW-020 During the Site visit to TPS

Laboratories and Virupaksha, the storm water outlet was noted to flow onto the road into Mylan Unit-I. This location is intended to evaluate impact to groundwater environmental quality, if any.

21 MW-021 The vacant area south of Arch Pharma in the vacant land south of Arch Pharma. This location in the open area south of Arch Pharma is intended to evaluate impact to groundwater environmental quality, if any.



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Sr. No. #

Monitoring Well ID


22 MW-022 The northern most parts of the watershed to account for spatial coverage


23 MW-023 The area beyond the northern area of the catchment.


24 EW-001 Existing groundwater monitoring wells within HWMP

25 EW-002

26 EW-03

27 EW-004

28 EW-005

29 EW-006

30 EW-007 To understand the groundwater quality in the settlement area (Dundigal Tanda) up gradient of the water shed.



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Sr. No. #

Monitoring Well ID


31 EW-008 To understand the groundwater quality in the settlement area (Kazipally Village) down gradient of the water shed.


Summary of Groundwater Sampling:

Drilling and installation of twenty three (23) groundwater monitoring wells; Collection of twenty three (23) groundwater samples from the newly installed monitoring wells; Collection of six (06) groundwater samples from existing monitoring wells within HWMP (TSDF); Collection of two (02) groundwater samples from existing abstraction wells within Dundigal Tanda Village and Kazipally Village; Collection of two (02) duplicate groundwater samples for QA/QC purpose. The sampling locations are shown in Figures 3.7 and 3.8 below.


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Figure 5.7 Groundwater Sampling Locations


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Figure 5.8 Groundwater Sampling Locations (view from North –East of Watershed)


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5.1.1 Waste

Five (05) waste samples will be collected from the identified potential waste disposal area(s).

5.2 ANALYSIS PLAN

All soil, sediment, surface water and groundwater samples are to be analysed for the following pre-determined analytical suite: 13 Priority Pollutant Metals 56 Volatile Organic Compounds; 114 Semi Volatile Organic Compounds; Unknown Organics (UO) Scan (library of over a million compounds); and Total Petroleum Hydrocarbons (TPH C6-C36). In addition to the above, part of surface water and groundwater samples are to be analysed for the following pre-determined geochemical suite: Total Iron; Calcium; Magnesium; Sodium; Potassium; Chloride; Sulphate; Sulphide as S - Iodometric Method; Nitrate; Nitrite; Cyanide as CN; Carbonates; Bicarbonates; Alkalinity; Salinity; pH; Total Organic Carbon; COD (Open reflux method); BOD at 27°C for 3 days; Phosphate, Po4; and Fluoride as F. Select waste samples will be characterised for Schedule 2 of the Hazardous Wastes (Management, Handling and Transboundary Movement) Rules, 2016.


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6 APPROACH & METHODOLOGY FOR TASK 3 INVESTIGATIONS

ERM’s standard protocol for drilling, equipment decontamination, sample collection, storage and transportation (based on ASTM Standard E 1903 – 11 Standard Guide for Environmental Site Assessments: Phase II Environmental Site Assessment Process), modified for use in India, shall be adhered to during Task 3 activities. This shall include following from within the respective watersheds, as per the Sampling and Analysis Plan (SAP): Surface water sampling:

o Collection of surface water samples from the lake; o Collection of surface water samples from the drains; o Collection of duplicate surface water sample for QA/QC purpose;

Sediment sampling; o Collection of grab sediment samples; o Collection of core sediment samples.

Soil boring and soil sampling; o Collection of soil samples from twenty (20) soil boring locations;

Monitoring well drilling and groundwater sampling o Drilling and installation of groundwater monitoring wells; o Collection of groundwater samples from the newly installed

monitoring wells; o Collection of groundwater samples from existing wells; o Collection of duplicate groundwater samples for QA/QC purpose.

Hand-held devices used for field screening shall be duly calibrated at all times and used diligently to allow a more targeted investigation to ensue enabling ERM to focus on.

6.1 HEALTH AND SAFETY

A Site-specific Health & Safety Plan (HASP) shall be prepared for the exercise. The HASP shall include an assessment of the potential health risks and physical hazards that may present at the sampling locations, based on Task 1 and Task 2 observations and findings. Prior to start of field work, a safety toolbox meeting, with ERMers and contractors, will be conducted each day to discuss the potential hazards identified and the mitigation health and safety measures for the day’s tasks.


45

Figure 6.1 Safety toolbox meeting

A team of experienced and trained ERM professionals shall be present on Site at all times during the fieldwork. All field personnel shall wear personal protective equipment (PPE) such as gloves, safety glasses, hard hats, dust masks/ half face respirators, tyvek suits, and safety shoes, as directed by ERM and the project HASP.

6.1.1 Identification of Drilling Locations and Underground Service Clearance

As a part of ERM’s health and safety protocol, prior to initiation of the intrusive programme of works, a Site walkover shall be undertaken to mark the sampling locations identified in the SAP proposed by ERM and submitted to the Client as part of Task 2 of the Project. The following steps shall be taken by ERM personnel in accordance with ERM’s global Subsurface Clearance Procedure 3.0 (SSC 3.0), to avoid contact with any subsurface hazards, including buried cables, pipes or other utilities: Discussions with Site personnel (from TSPCB and neighbouring industries

within the Industrial Area) familiar with underground utilities and services;

Use of Ground Penetrating Radar (GPR) and Cable Avoidance Tool (CAT) at the proposed sampling locations to ascertain absence of any subsurface structures/utilities prior to commencing boring/drilling activities; and

Advancing the first 1.5 m of the bore at a slow pace by manual digging and hand auger.


46

Figure 6.2 Subsurface Clearance

During carrying out previous tasks, ERM has observed that certain locations identified for drilling in the SAP might not be accessible due to dense vegetation. Therefore, a back hoe excavator (JCB) shall be used to clear approximately a 6x6 m area of vegetation at few of the identified locations.

6.1.2 Equipment Decontamination

As a part of ERM’s health and safety protocol, all sampling equipment used during the course of the sampling program shall be decontaminated using the following procedure: Manual wash and scrub; Rinse with Alconox, an anionic critical cleaning detergent; Triple rinse with distilled water; and Air drying.

Figure 6.3 Equipment Decontamination

ERM field personnel in charge of decontamination shall wear appropriate level of PPE as defined within the HASP at all time.


47

6.2 SURFACE WATER SAMPLING PROTOCOL

In addition to the observations reported during Task 2; the surface water SAP is also prepared based on upstream and downstream locations for the lake; the location of outfall or discharge points to the lake, flow patterns within the lake (velocity and agitation) at different locations, and access to sampling locations. Given the above, surface water samples shall be collected from the following locations within the study area: Existing ponds/ stagnated water bodies; Major existing drains and feeder channels that drain directly into the

ponds/ stagnated water bodies; and, Industrial effluent/ wastewater discharges into the ponds (as applicable). Water samples will be collected at each of the proposed locations within the standing water bodies. As the amount of standing water greatly varies seasonally, water levels at the time of sampling will ultimately dictate the methodology for sample collection. Surface water sampling activities shall be carried out by qualified field personnel. Field personnel shall wear all required personal protective equipment at all times. If the water is shallow (< 0.5 m) and slow enough / stagnant, and safe

access is available, the sampler will wade into the surface water to obtain a sample. For shallow streams, the samples will be collected under the water surface while pointing the sample container upstream – the container will be upstream of the collector and all care shall be taken to avoid disturbing the substrate;

In areas with substantial water, surface water sampling from within the lake bodies shall be carried out on a vessel / raft. In such areas, samples shall be collected using a low flow submersible pump and hook mechanism, utilizing low density polyethylene and silicon tubing to pump water into containers;

The pump and hook mechanism shall be lowered from the side of the vessel and designated surface water sample shall be collected;

All samples to be taken at least 100mm below the surface of the water.

Figure 6.4 Surface water sampling


48

Following field parameters will be measured using a duly calibrated multi-parameter probe and a flow through cell. pH; Conductivity; Temperature; Dissolved Oxygen; and ORP. The following information shall be recorded for each sample: Location of sampling point (clearly marked on site plan); Details on lake/ channel cross section and water depth; Field parameters; Flow conditions at time of sampling; Weather conditions (rainfall patterns) during and at the time of sampling;

and Photographs of the sampling point.

6.3 SEDIMENT SAMPLING PROTOCOL

Sampling will commence at downstream locations, proceeding upstream to minimize the impact of sediment disturbance on subsequent sampling locations. In addition to normal site and sample identifiers, field measurements will include: Water quality parameters taken 5-20cm above the sampling site; and Water column conditions during sampling; and Sediment properties (gravel, sand, debris, plants etc.).

Collected samples will be photographed, visually examined and changes in strata recorded.

6.3.1 Collection of surface sediments

Sediment samples will typically be collected from shallow, wade-able streams and ditches using the following techniques: Shovel or other appropriate hand implement will be used if sediments are

collected from areas with exposed lakebed; Hand corers can be used by wading in shallow waters (<0.5 m).

6.3.2 Collection of sediment from depth

Sediment samples from locations with substantial water column will be collected using the following techniques: Grab samplers will be used for collecting grab sediment samples where the

water column is > 0.5 m; Mechanized corers will be used for the collection of deep cores/ compacted

sediment.


49

Figure 6.5 Sediment sampling

6.4 SOIL BORING AND SOIL SAMPLING

Soil sampling will be carried out to obtain representative data and samples that meet project data quality objectives and industry acceptable standards of accuracy, precision, comparability, and completeness.

6.4.1 Soil Boring Protocol

Based on field conditions, access and space limitations, soil samples shall be collected using one of methods mentioned in Table below, as applicable.

Table 6.1 Soil Sampling Techniques

Sr No #

Sampling Technique

Description Typical Photograph

1 Shallow grab sample

Surface/ shallow depth (0.5 feet) samples, if any, will be collected using a decontaminated stainless steel spatula

2 Manual

augering The augers displace the cut materials to the surface. No drilling fluids will be used


50

Sr No #

Sampling Technique

Description Typical Photograph

3

Test pits using an excavator

Trial pit will be excavated using a backhoe excavator. Samples will be collected from the backhoe with no entry to the excavation permitted.

The depth interval will be based upon the following considerations: Depth at which visual or other indications of potential contamination are

first observed; Shallowest and/or deepest depth of potential contamination (dependent

on surface condition and shallow soil profile); Depth above the observed vadose zone; Presence of fill or reworked soil; Changes in lithology; and Potential necessity for collection soil samples near the surface for use of

the data in a risk assessment (e.g., for evaluation of the potential for direct contact with soil).

Field logs will be maintained, with notes and field photographs for observed evidence of contamination (if any) and all site activities. The description will include the following: Sample ID – Location (e.g., boring number), depth, type of sample; Lithology – e.g., sand, silt, clay, silty clay etc.; Colour – general colour descriptions; Moisture Content – use judgment to describe relative amount of moisture

in sample (e.g., dry, damp, moist, wet, or water saturated); Other characteristics – e.g., odours, PID headspace readings, etc.

6.5 MONITORING WELL DRILLING AND GROUNDWATER SAMPLING PROTOCOL

6.5.1 Monitoring Well Drilling Protocol

Based on ERM’s prior site visits and understanding of the local geology, groundwater monitoring wells shall be drilled using rotary percussion drilling (DTH) drilling technique. Wells will be advance to at least 5 m below the water table so adequate water is present in the well for sampling and analysis. Based on ERM’s understanding of the site hydrogeology, all monitoring wells shall be installed up to a maximum depth of fifteen (15) metre below ground


51

surface. In the event that shallow groundwater is not encountered at this depth, the Client will be informed, and drilling will be advanced further upto an extended depth. Hand augers will be used for an initial depth upto 1.5 m bgl and thereafter, rotary-percussion (DTH) drilling method will be used for drilling purpose. Approximately 50 – 63 mm diameter screened monitoring wells will be installed upon reaching the final depth. The monitoring wells will be constructed of uPVC with a section of factory or hand slotted screen. The annular space between the screen and the side of the borehole will be packed with appropriate gravel filter-pack. Well will be completed with plain or blank uPVC piping up to the surface. All pipe joints will be flush threaded and no glues or petroleum-based greases will be used to join pipes. On completion of monitoring well installation, the wells will be developed until the column of water in the well is free of visible sediment, or at a minimum until further improvement in water clarity is not observed with continued groundwater removal. The purpose of the well development is to stabilize the gravel pack and to ensure good hydraulic connectivity between the monitoring well and the aquifer. Once the well has been developed, the well will be sealed and left for a minimum stabilization period of 48 hours before sampling.

Figure 6.6 Typical monitoring well drilling and installation

Geological logs (to ASTM 2488D -06 standards or equivalent) will be completed for each monitoring well, by experienced ERM professional. The completion details of the wells will also be recorded so that the depth of the screen is known (an important consideration during groundwater sampling).

6.5.2 Groundwater Sampling Protocol

Prior to sampling, ERM will measure the static water levels in the new and existing (to the extent practicable and if information regarding lithology is


52

available) wells across study area, so that a synoptic picture of groundwater elevation can later be developed. Each well will be dipped to determine the depth to groundwater and the total depth plumbed. The point from which measurements are made will be permanently marked for future reference. ERM has allowed within its scope of works a professional survey of all wells to a common site datum or to a National datum should one be readily available. ERM’s standard operating method for well sampling is to first purge until well head parameters of pH, conductivity, temperature, oxidation reduction potential (ORP) have stabilized against the following limits: pH 0.1; Conductivity 3%; Temperature 1 ºC; and ORP 10 mV. However, if the yield of the monitoring wells is low to the extent that they readily purge dry, ERM will adapt its methodology to suit site conditions, using best practice in all cases (subject to yield removal of three well volumes). Purging prior to sampling shall be undertaken manually using a bailer. Duly decontaminated bottom-loading Teflon® bailers will be used to collect a groundwater sample from each well. For the groundwater samples, field vacuum (negative pressure) filtration of the water sample(s) shall be undertaken using appropriate filter cartridge and poly-carbonate filtration apparatus as required under ASTM/USEPA/EN standards.

Figure 6.7 Groundwater sampling


53

6.6 QUALITY ASSURANCE / QUALITY CONTROL PROCEDURES FOR FIELD SAMPLING

Quality Assurance/Quality Control (QA/QC) guidelines include documenting all field activities (e.g. drilling & sampling), keeping necessary controls (Chain of Custody - CoC) and using a unique identifier for the identification and tracking of samples. Some guidelines to be followed during sampling include: Collection of duplicate samples; Use of appropriate equipment and materials (including PPE); Measurement of in-situ variables performed only by professional staff; Submittal of samples to the laboratory within specified holding times; Use of appropriate registration forms; and, Identification of samples using unique alphanumeric codes. The following data will be recorded while sampling: Sample ID; Sampling location, date and time; Name of sampler responsible; Number and volume of samples collected; Description of sampling locations; and Direct measurements taken in the field. The CoC is intended to trace and control each of the samples collected in the field to the laboratory. Samples will be couriered to the analytical laboratory on a global priority service to ensure that they reach the laboratory within their respective stipulated holding times.

6.7 SAMPLE HANDLING PROTOCOL

ERM professionals will use fresh nitrile gloves to handle all samples. Portions of samples will be separated from the sampler and placed in sampling containers within the shortest possible time, in order to avoid loss of volatiles to the atmosphere. The samples will be duly packaged, identified and preserved for transportation to the laboratories.

6.8 ASSISTANCE FROM TSPCB

For the Task 3 Investigations, for the soil and groundwater locations for within the watershed, ERM may need permission from the following: State Groundwater Board; Revenue Department;


54

Reserved Forest Department; Local Panchayat Public Works Department; Local Traffic Control Department. ERM would request for assistance from TSPCB for the same.

Annex A

Inventory of Potential Contaminant Sources

1


Annex A:Inventory of Potential Contaminant Sources


Potential Areas of Concern (PAoCs)

2

The probability of occurrence (i.e. likelihood or potential presence of impact associated with surface water, soil and/ or groundwater impact) has been subjectively rated as Low, Medium or High.

Note: In the columns below, historical information is mentioned in Italics.


Hetero

3

Operations Raw Materials Wastewater Treatment Hazardous Waste Storm Water

API and Bulk Drugs Liquid: • Methanol• Toluene• Hexane• IPA• Acids, MDC and caustic• Recovered solvents

Waste water is segregated into Low TDS (135 KLD) and High TDS (110 KLD).

Low TDS is treated in a biological treatment system (200 KLD) and RO (250 KLD).

High TDS along with RO reject is treated in a stripper (300 KLD) followed by MEE (300 KLD) and ATFD (20 KLD)

• Process Organic residue

• Inorganic salts• Spent carbon• ETP , MEE salts• Used oil• Waste drums• spent solvent• Off spec products• date expired

products• Misc- filters etc

Unit I has drainage network, but it is not connected to the north eastern part. Water from collection pit: first cut goes to ETP; after that it goes out of site;

On the day of site visit, there was water in storm water drain (from production areas, leakages from pipes, etc): this goes to sump and from there is goes off site (except for first cut which goes to ETP).

Unit II has not network. And flows offsite through main gate.


Hetero: Raw Material Management

4

Observations Scenario for potential contamination Probability of Impacting Environmental Matrices

Unknown for UST; for AST it is in a paved tankfarm having a secondary containment.

Solid: Stored in roofed warehouse and on paved surface.

During monsoon runoff containing leakage, if any, would go off Site storm water drain.

High

Intermittent storage of raw materials outside the raw material storage area


Hetero: Wastewater Management

5


All WW collected in AG tanks and then sent to the ETP

Seepage of untreated effluent through the flooring can potentially lead to soil and / or groundwater contamination.

Surface runoff in monsoon can lead to untreated effluent mixing with storm water

Medium

Effluent storage tanks adjacent to production block


Hetero: Hazardous Waste Management

6


Stored in closed room; paved surface; with secondary containment and leachate collection system

Overflow in monsoon can lead to hazardous waste mixing with surface run off

Medium

Hazardous waste storage area – Inorganic salts

Hazardous waste storage area – Process organic residue

Hazardous waste storage area – Waste drums


Hetero: Surface Water Management

7


All storm water is collected in a sump which is then sent to ETP for treatment.

In process areas, orange color staining noted in the drains

Any surface contamination will go off-site via surface run off in monsoon

High

Surface runoff collection tank



Surface water drainage network

Surface water drainage network


Divis Pharmaceuticals Pvt Ltd

8


Bulk Drugs and API Liquid• Benzaldehyde;• Mono methyl amine;• Acetophenole;• Para chloro benzo

trifluoride;• Methanol;• Acetone;• Toluene;• Methyl acetyne;

Solid• Caustic soda

pH adjustment and solid separation is carried out. 20 KL per month sent to JETL. Residue sludge is sent to TSDF

• Solvent residues• Inorganic salts/

distillation bottom residue

• Spent carbon• Organic residues

which come from processes

Site has lined storm water drains. During monsoon runoff containing leakage, if any, would flow off Site through boundary wall located on northern corner, into lined drain in between Divis and SMS.


Divis Pharma: Raw Material Management

9


Liquid: Some drums were observed to be stored under tinned roof (no walls). Concrete paved. Some drums are also kept without any secondary containment. These are located in paved and unpaved areas of the Site. Five (5) USTs, Seven (7) ASTs and several day tanks are located on Site. All ASTs were observed in proper condition. Day tanks had minor staining on its walls.

Solid: Stored in drums, within closed room. Paved condition, no cracks and staining observed on the floor.

During monsoon runoff containing leakage, if any, would go off Site through boundary wall located on northern corner, into lined drain in between Divis and SMS.

Medium

Raw Material storage within SiteSolvent storage within Site


Divis Pharma: Wastewater Management

10


pH adjustment and solid separation is carried out. 20KL per month sent to JETL. Residue sludge is sent to TSDF. No PAoC.

Open tanks (3 no) noted in historical image. Site conducted Forced Evaporation till 2016.

Potential for soil and/ or groundwater to be impacted due to the historical wastewater treatment practice.

Low

Effluent storage tank within Site


Divis Pharma: Hazardous Waste Management

11


Stored in closed area, paved flooring. No cracks were observed on the paved flooring. Heavy spillage and staining was observed on the floor. Spent solvent is stored under tinned roof (no wall), paved flooring. Heavy spillage was observed on the floor.

Staining noted outside Hazardous waste storage area. Surface runoff would carry any open to air spillage out of the facility

High

Hazardous waste storage area Spent solvent storage area


Divis Pharma: Surface Water Management

12


All storm water drains are located such that during monsoon, runoff containing leakage if any, would flow offsite and through northern corner of the site boundary, into lined drain between Divisand SMS. This lined drain finally runs off into seepage collection sump. Also at the end of the Site along northern boundary, there is a rain water harvesting pit. All overflow from this trench would run off into the drain in between Divis and SMS.

Overflow in monsoon can lead to hazardous waste and untreated effluent mixing with surface run off

High

Storm water drainage and outlet from Site


Arch Pharma Labs Limited

13


Bulk drugs and API Liquid:• Sodio cyanide• Iso propyl alchohol• Magnesium chloride

Solid: • Ethyl chloro esto

estate• Ethyl acetate• MDC

Segregation and clarification carried out. Then low TDS (5KL) sent to PETL, High TDS (10KL) sent to MEE.

• Spent carbon• MEE Salts• Solvent residues

Storm water drainage network on Site across production blocks, hazardous waste storage area. These drains finally join on to main storm water drain along northern boundary.


Arch Pharma: Raw Material Management

14


Liquid: Solvent storage doesn’t have secondary containment; run off into storm water drain near by

Solid: Stored in closed room. Paved flooring. No cracks were observed. Minor staining all across the floor.


Medium

Raw material storage facility within Arch Pharma


ArchPharma: Wastewater Management

15


Segregation and clarification carried out. Then low TDS (5KL) sent to PETL, High TDS (10KL) sent to MEE.

SEP's noted in 2003 historical image

-Historical soil and / or groundwater contamination issue due to SEP.

Low

Photographs not available


ArchPharma: Hazardous Waste Management

16


Indoor; with paved flooring; no secondary containment. Staining observed on the floor.


Medium

Hazardous waste facility within Arch Pharma


ArchPharma: Surface Water Management

17


Reddish colour stagnant water on storm water drain.

All run off is collected in a pit near northern boundary and sent to onsite MEE

Any surface contamination will go offsite through surface run off in monsoon

Medium

Storm water drain within Arch Pharma


Lee Pharma Ltd

18


API and Intermediates Liquid• Solvents (MDC)• Solvents (Acetone)

Solid• Benzimidazole• Chloro compounds

Existing ETP capacity is 50 KL/ day and upgrading to 100 KL/ day. High TDS sent to MEE followed by ATFT. Low TDS is mixed with condensate from MEE and sent to PETL. New biological treatment plant is being setup on site to treat low TDS as reported by Site representative.

• Process residues• Inorganic waste

(salts) comes from MEE and ATFT

• Spent Carbon + organic salts

Lined storm water drainage network present all around the site. These drains run adjacent to production block, hazardous waste storage area, ETP, MEE and scrap yard. Potential runoff from these areas can lead onto the drains. All drains are finally connected into one main storm water channel.


Lee Pharma: Raw Material Management

19


Liquid: Acetone is stored in six (6) USTs. These tanks are five years old. No integrity testing has been done of these tanks. Several ASTs and day tanks observed on Site. The ASTs had secondary containment in form of dyke walls. No staining observed. Day tanks were observed to be highly stained. Staining was also observed on floor below day tank locations. Storm water drainage systems are present adjacent to such locations.

Solid: Stored in closed rooms, with proper secondary containment. No cracks and staining were observed.


High

Raw material storage within Site


Lee Pharma: Wastewater Management

20


Area open to air; no secondary containment; heavily stained.

Run off will get into storm water drain in monsoon, and go offsite.

High

Effluent storage within Site


Lee Pharma: Hazardous Waste Management

21


Stored in closed room, paved flooring. No secondary containment provided. Waste observed to be overflowing out of the room onto storm water drain running adjacent. Hazardous waste is also stored in sacks in open air, unpaved land, without secondary containment. Heavy spillage observed all around.

Scrap yard is close to drain and on unpaved area where some old drums with left over material noted


High

Hazardous waste storage within Site

Storm water drain


Lee Pharma: Surface Water Management

22


Lined storm water drainage network present all around the site. These drains run adjacent to production block, hazardous waste storage area, ETP, MEE and scrap yard. Potential runoff from these areas can lead onto the drains. All drains are finally connected into one main storm water channel.

Site has an inlet from the common lined drain running parallel to Site.

Heavy staining observed around hazardous waste storage area, ETP and MEE on the drains.

Any surface contamination will go into the storm water drain and off site in monsoon

High

Storm water drainage within Site


Virchow Chemicals

23


Chemical and Intermediate

Liquid:• Ethylyn dichloride• Methanol • Sulphuric acid

Solid:• Sulphur• Acetanalide• Chloro sulphonic acid• Soda ash• Sodium sulphide• Benzene• Chloro sulphonic acid

Neutralization carried out via gypsum addition. High TDS (6.4 KLD, TDS range of 1,50,000 ppm, COD range 100 milligram/ liter) goes to MEE. Low TDS (180 KLD, TDS range 1500 ppm), reused for process without treatment. MEE residues goes to TSDF.

• Spent carbon from ASC and BSA manufacture

• Sulphur sludge• Inorganic salts/

bottom residue • Fe salts

(evaporation salts)• Gypsum

Several lined storm water drainages present on Site.


Virchow Chemicals: Raw Material Management

24


Liquid: Stored in above ground tanks with secondary containment. Staining noted around the tank

DMS has secondary containment but open to sky. Remaining products were kept in stored rooms, some had containments some did not.

Solid: Stored in closed area. Paved, No secondary containment in some areas

During monsoon runoff containing leakage, if any, would go off Site from the storm water drain.

Medium

Raw material storage on Site


Virchow Chemicals: Wastewater Management

25


Low TDS is recycled for process - Low

Effluent storage on Site


Virchow Chemicals: Hazardous Waste Management

26


Stored in closed area; paved flooring; no secondary containment. Minor staining seen

- Low

Hazardous waste storage on Site


Virchow Chemicals: Surface Water Management

27


Spillage and staining observed across unbuilt Site areas. Staining observed on storm water drains.

Site has three (3) collection pits for storm water but are insufficient for run-off collection.

Storm water all across the site has staining; earlier(till 2016) the storm water went off-site to form a pond. Now they cant discharge here since the land owner has objected.

Reportedly, run off from TSDF and ArchPharmacome into this site.

Any surface contamination will go into the storm water drain and off site in monsoon.

Reportedly, run off from TSDF and ArchPharma come into this site

High

Storm water collection pit on Site


Mylan Labs Unit I

28


APIs Liquid: • Acetonitrile• Chloroform• Cyclohexane• Dimethyl formamide

(DMF)• Dimethyl sulfoxide

(DMSO)• Ethyl Acetate• Hexanes• Isopropyl Alcohol (IPA)• Methanol• Methylene Dichloride

(MDC)• n-Butanol• N-Ethylpiperazine• n-Heptane• Pyridine• Toluene• Hydrobromic Acid• Caustic Soda Lye (48%)• Sulfuric Acid (CP)

Solid: on next page

Waste water is segregated into Low TDS (17 KLD) and High TDS (49KLD).



• MEE Salts• ETP Sludge• Spent carbon • Spent solvents • Distillation bottom

residue• Waste oil• Used drums• Off spec / expired

drugs

Production area (east of the site) has drainage network; collection pit near southern boundary. First cut goes to ETP; rest goes off site from gate (they have a release valve).

ETP and solvent tank farm (west of the site) area does not have drainage network.They have one collection sump (small) near gate. Run off goes off site.


Mylan Labs Unit I

29

Raw Materials Raw Materials

Solid:• Activated Carbon

(ENOPC)• Hyflo• Sodium Bicarbonate• Phosphorus

Oxychloride• Potassium Hydroxide

Flakes (CP Flakes)• Caustic Soda (Sodium

Hydroxide Flakes)• Palladium (10% on

charcoal, 50% wet)• CMH Acid• Calcium Chloride

(Anhydrous)

Solid:• Citric Acid

(Monohydrate)• Dipotassium Hydrogen

Orthophosphate• Sodium Borohydride• Sodium Carbonate

(Soda Ash)• Sodium Chloride• Sodium Dihydrogen

Orthophosphate• Sodium Sulfate• Succinic Acid• Boric Acid• CBZ-L-Valine• Cyanoacetamide• D-(-)-Mandelic Acid• Guanine• Potassium Iodide• R(+)-Alpha

Methylbenzylamine• Silica Gel


Mylan Labs Unit I: Raw Material Management

30


Liquid: Stored in ASTs having secondary containment.

Solid: Stored in roofed warehouse and on paved surface.

No PAoC

- Low



Mylan Labs Unit I: Wastewater Management

31


Waste water is segregated into Low TDS (17 KLD) and High TDS (49KLD).



No PAoC

- Low



Mylan Labs Unit I: Hazardous Waste Management

32


In covered room with secondary containment and a leachate collection system.

- Low



Mylan Labs Unit I: Surface Water Management

33


No storm water network in non production area (Western portion). Outlet through southern gate during monsoon after first cut.

A closed public drain provided for the IDA passes through the eastern portion of the Site (runs north to south).

Off-site surface water contamination entering and exiting the site (underground)

Medium


KRS Pharmaceuticals Pvt Ltd

34


Bulk Drug/ Intermediate

Liquid• Methanol• Toluene• Acetone• Methalyine dichloride

Solid• omprezole - sulphate• L cystine

hydrochlorode,• maltol

No ETP. Only pH adjustment and solid separation is carried out. Separate effluent collection tanks present for low (capacity 40 Kl) and high (capacity 20 kl) TDS effluent. 10KL/ month of low and high TDS sent to JETL.

Site conducted Forced Evaporation till 2015.

• Spent carbon • Bottom residues

from different process

Site has a lined storm water drain . Staining observed in drain.


KRS Pharma: Raw Material Management

35


Liquid: Stored in drums. Drums containing acidare stored in open air, without secondary containment. Staining observed on floor. Drums containing solvents are stored in closed, paved room. No cracks and staining were observed within the room.

Solid: Stored in drums, within closed room. Paved condition, no cracks and staining observed on the floor

Storm water drain downgradient to solvent storage area and also runs close by ETP; surface run off in monsoon will go into the storm water drain

Medium



KRS Pharma: Wastewater Management

36


Demineralized (RO) reject water is used for gardening. TDS range is 400 - 500 ppm.

Site conducted Forced Evaporation till 2015.

Potential for soil and/ or groundwater to be impacted due to the historical wastewater treatment practices exists.

Medium



KRS Pharma: Hazardous Waste Management

37


Hazardous waste is stored in closed room without secondary containment. Staining noted on walls.


Medium



KRS Pharma: Surface Water Management

38


Storm water drain runs from ETP area, passes through raw material storage area, and area where solvents are stored open to air, and exitssite through main gate. Staining observed in drain.


Medium

Waste storage within Site

Hazardous waste storagewithin Site


Virupaksha Organics Limited

39


Bulk Drug Intermediate Manufacturer

Liquid: • 1,3 difluro benzene• Chloro acetyl chloride• Alum chloride• 4 amino 1,2, 4 trizol• Methyl dichloride • IPA

Only neutralization process carried out. High TDS (10 Kl/ month) to MEE. Low TDS (60KL/ month) to PETL.

• Spent Carbon• Distillation Bottom

Residue• Forced

Evaporation Salt• Detoxified

containers and liners

• Waste Oil

No surface water drainage system; surface flow goes naturally towards the gate. There is a tank (2 – 3 kl) near the gate which receives TPS surface water as well. The first cut water is sent to PETL via tankers. Any overflow goes out of the site.



Virupaksha: Raw Material Management

40


Liquid: ASTs were observed to be in proper condition.Several day tanks are located in production areas. Staining was observed on the floor.Drums are stored open to air without secondary containments.


High



Virupaksha: Wastewater Management

41


Only neutralization process carried out. High TDS (10 Kl/ month) to MEE. Low TDS (60KL/ month) to PETL.


Medium

High TDS effluent storage on Site


Virupaksha: Hazardous Waste Management

42


Drums stored in closed room. Minor staining observed.Used drums are stored in open area, paved flooring, without secondary containment. No proper drum washing practice.


High



Virupaksha: Surface Water Management

43


No surface water drainage system; surface flow goes naturally towards the gate. There is a tank (2 – 3 kl) near the gate which receives TPS surface water as well. The first cut water is sent to PETL via tankers. Any overflow goes out of the site.


High

Surface runoff on Site

Surface runoff

Haz-waste


TPS Laboratories Pvt Ltd

44


API and Bulk Drug Intermediate Manufacturer (after takeover from Virupaksha they are going to stop producing APIs)

Liquid: • Methylacetate salicylate• Tert butyl ammonium

bromide• Potassium carbonate• Benzyl chloride• Methanol• Hydrochloric acid• 1,4, dioxane• Selenium dioxide• SSP-02• Methanol• Tert butylamine• Diglyme• Sodium borohydride• Lithium bromide• SSP-03• Acetic acid• Activated carbon• EDTA disodium• Caustic soda flakes• SSP-04• Methanol• SSP-05

No ETP. Only pH adjustment and solid separation is carried out. Effluent collection tank present. Low TDS of 60 KL/ month is sent to PETL. High TDS of 10 KL/ month is sent to JETL via Virupaksha.

• Spent Carbon• Distillation Bottom

Residue• Forced Evaporation

Salt• Detoxified containers

and liners (recyclable)• Waste Oil (recyclable)

One storm water drain present on Site which runs into Virupaksha. Discharged offsite from Virupaksha main gate.

Unlined surface run off through main gate.


TPS Labs: Raw Material Management

45


Liquid: Solvents are stored in USTs.Rest are stored in drums, some areas do not have secondary containment.

Spillages observed in drum storage area(s)


High



TPS Labs: Wastewater Management

46


No ETP. Only pH adjustment and solid separation is carried out. Effluent collection tank present. Low TDS of 60 KL/ month is sent to PETL. High TDS of 10 KL/ month is sent to JETL via Virupaksha.


Medium

Surface runoff on Site

Storm water drain

Effluent storage


TPS Labs: Hazardous Waste Management

47


Hazardous waste stored in drums; open to air; on unpaved land; without secondary containment. Staining observed on floor at several places within Site.


High



TPS Labs: Surface Water Management

48


One storm water drain present on Site which runs into Virupaksha. Discharged offsite from Virupaksha main gate.

Unlined surface run off through main gate.

Spillage and staining observed across Site areas.


High

Surface water runoff on Site


Selma Laboratories Private Limited

49


API and Bulk Drug Manufacturing

Site Not Operational since 2015

NA NA NA Strom water drain present. Run off goes through main gate.


Selma Laboratories: Surface Water Management

50


Strom water drain present. Run off goes through main gate.

- Low

Storm water drain within Site


SMS Pharmaceuticals Limited

51


Bulk drugs Liquid• Methanol• toluene• Ipa• DMSO (dimethyl

sylphoxide)

Solid• Furfyrl alchohol• Cystamine

Hydrochloride• NMSM

(intermeddiateproduct)

High TDS (60 KLD0 and low TDS (8KLD) generated. ETP capacity of 100 KLD. High TDS sent to MEE.

• Bottom organic residue

• Spent carbon

Several storm water drainage network on Site. Major storm water drain runs north of site.


SMS Pharma: Raw Material Management

52


Stored in AST and drums. Drums observed without secondary containment; open to air. Staining near day tanks, drums storage and loading and unloading area.

During monsoon runoff containing leakage, if any, would go off Site through storm water drain.

High


Storm water drain

Solvent Storage


SMS Pharma: Wastewater Management

53


High TDS (60 KLD0 and low TDS (8KLD) generated. ETP capacity of 100 KLD. High TDS sent to MEE.


High

Day tank storage within Site


SMS Pharma: Hazardous Waste Management

54


Stored in closed room, paved flooring. Heavy staining observed on the floor. No Secondary containment provided. Spent solvent is also stored in drums, in open air, paved flooring without secondary containment. Waste is also stored in open air, on unpaved land.

Overflow in monsoon can lead to hazardous waste mixing with surface run off.

High

Hazardous waste storage within SiteUsed drum storage within Site


SMS Pharma: Surface Water Management

55


Several storm water drainage network on Site. Major storm water drain runs north of site.

Surface flow out of gate during monsoon to open area south of Site


High

Storm water drainage on Site


TIDC India Pvt Ltd

56


Engineering Liquid: • Methanol

Solid:• Metal steel strip• Wires

Settling tank present. Alum is added and recirculation is carried out and finally used in process.

• ETP sludge (sand, emily and some amount of oil)

• Used oil

Storm water network present on Site. These drains run adjacent to all the production buildings, diesel storage area, hazardous waste storage area. One natural unlined drain runs along the western boundary of Site.


TIDC: Raw Material Management

57


Liquid: Stored in drums, open to air and also within closed room. Paved and secondary containment. Minor staining observed.

Solid: some kept in open some in covered area


High



TIDC: Wastewater Management

58


Settling tank present. Alum is added and recirculation is carried out and finally used in process.

Surface runoff in monsoon can lead to untreated effluent mixing with storm water.


High

Effluent storage tank on Site


TIDC: Hazardous Waste Management

59


Used oil is stored in drums under tinned roof (no wall), in paved flooring. No secondary containment, heavy staining noted on the floor and on storm water drain running adjacent. Sludge is stored in containers, open to air, paved flooring. Heavy staining observed on the floor.


High

Hazardous waste management on Site


TIDC: Surface Water Management

60


Heavy staining observed in drains along diesel storage area and hazardous waste storage area.

Low lying area located along northern boundary that is likely impacted by neighbouring industries (one outlet from Lee and two outlets from Emmenar, One outlet from Granite industry)


Surface water from neighbouring industries enters site.

High

Surface runoff from neighboring industries

Outlet from Emmenar


Kekule Pharma Limited

61


Bulk drug Liquid: • Maltol• Diophenol• Trifluroacetic acid • Toleune• Acetone• Methnoldichloride• Chloroform

Only effluent storage tanks present. Low TDS mixed with High TDS and sent to JETL.

• Bottom residues• Organic residue+

spent carbon• Inorganic salts

Several storm water drainage network on Site across production blocks, hazardous waste storage area. Major storm water drain runs along eastern boundary and gets collected in a 8kl tank.


Kekule Pharma: Raw Material Management

62


ASTs for solvents; no secondary containment;Day tanks of SS UG, 10 ~12 years old, no integrity testing done. Total of ~25 tanks; per tank of 500 L; Some drums were stored in closed rooms, paved. No cracks were observed within closed rooms. Large number of drums containing solvents were kept in open air, unpaved and paved areas of Site. Staining was observed all across Site premises. Site contained several day tanks and stainless steel UG tanks. These were observed to be in very poor condition. UG tanks contained heavy spillage.


High



Kekule Pharma: Wastewater Management

63


Only effluent storage tanks present. Low TDS mixed with High TDS and sent to JETL.

SEP noted in historical images till 2008.

Seepage of untreated effluent can potentially lead to surface water contamination. Historical soil and / or groundwater contamination issue due to SEP.

High

High TDS Effluent tank area on Site


Kekule Pharma: Hazardous Waste Management

64


Stored in closed room, paved flooring. Heavy staining observed on the floor and outside hazardous waste storage room area. Seepage from waste storage room area was observed outside on the floor. No Secondary containment provided. Spent solvent is also stored in drums, in open air, paved flooring without secondary containment. Heavy staining and seepage observed on floor.


High



Kekule Pharma: Surface Water Management

65


Staining observed across Site areas and on storm water drains. Greenish coloured stagnant water observed on storm water drain on eastern portion of site.

Reportedly runoff collected in tank. Staining noted across the production area indicating run off will carry this offsite.


High

Storm water drainage within Site


Regent Paints Pvt Ltd

66


Paint Manufacture (oil and emulsion based)

Liquid:• Solvents (mineral

turpentine oil)• Solvent (alkyd)

Solid:• Extenders (powder

form)• Additives • Emulsions

No process wastewater generated on Site. Raw water is treated using RO.

Reject RO water used for gardening.

• Waste oil from DG• Used empty

containers

No dedicated storm water network at the Site


Regent Paints: Raw Material Management

67


Liquid: Stored in drums. These were located in paved areas without secondary containment. No cracks were observed within the closed rooms. Minor staining were observed on the paved flooring. Certain drums containing solvents were kept in open area without secondary containment (paved and unpaved areas of site, minor staining observed)

Solid: Stored in drums. Emulsions were stored in drums, open to air, without any secondary containment. These were stored in paved floor. No cracks were observed. Minor staining was observed on the floor areas.

During monsoon runoff containing leakage, if any, would go off Site

High



Regent Paints: Wastewater Management

68


No process wastewater generated on Site. Raw water is treated using RO.

Reject RO water used for gardening.Potential for surface water mixing with RO reject is high.

Potential for soil and groundwater contamination high.

Medium



Regent Paints: Hazardous Waste Management

69


Stored in drums in open air, in several paved and unpaved portions of site. Minor to heavy staining noted all around the Site premises.


High



Regent Paints: Surface Water Management

70


No dedicated storm water network at the Site

Heavy staining observed in DG area. Staining observed in hazardous waste storage area and areas where empty containers were kept open to air.

Any surface contamination will go off site in monsoon

High

Used oil storage within Site

Surface runoff collection pit on Site


Sri Ram Chlorochem

71


Bulk Drug intermediates

Mono methyl ammine gas

Liquid:• Methyl Ethelate• Toluene• Methanol• Diesel

Solid• Sodium methoxide• ECF (Ethyl chloro

formate)

All wastewater goes to onsite MEE.

• MEE Salts (comes from MEE)

• Bottom Residues• Packaging waste

Several storm water drainage networks on Site.


Sri Ram Chlorochem: Raw Material Management

72


Liquid: Total of ten (10 ) USTs on site (25KL capacity each for methyl ethelate, methanol, toluene, diesel). These USTs are 2 to 3 years old (no integrity testing done). Localized, minor staining was observed on ASTs and day tanks. Drums are stored under tinned roof (no walls). Storage area without secondary containment, paved, staining observed. Several drums were located in open air, paved areas with minor staining all across Site. Minor staining near production block.

Solid: Stored in closed room. Paved flooring. Secondary containment present.


High

Raw Material storage on Site


Sri Ram Chlorochem: Wastewater Management

73


All wastewater goes to onsite MEE. No PAoC - Low



Shri Ram Chlorochem: Hazardous Waste Management

74


Drums stored in closed room; paved floor. There is a surface water drain downgradient to hazardous waste storage area; any spill will go into the drain

Medium

Hazardous material storage on Site

Haz-waste storage

Surface runoff


Sri Ram Chlorochem: Surface Water Management

75


There is a surface water drain downgradient to hazardous waste storage area; any spill will go into the drain

Staining observed across Site gradient.


High

Surface runoff from various locations on Site


Chemtech Acids and Chemicals

76


Chemicals Liquid: Methanol

Solid: • Sulphur• Caustic Soda flakes

Not Generated Not Generated Storm water drain along the periphery; water from drain as well as the runoff is collected in a pit on site; overflow goes offsite


Chemtech Acids & Chemicals: Raw Material Management

77


Methanol in AG tank; no secondary containment.

Sulphur store open to air on paved land; caustic soda flake in a room


High

Sulphur Storage within Site

Used open drum storage within Site


Chemtech Acids & Chemicals: Surface Water Management

78


Storm water drain along the periphery; water from drain as well as the runoff is collected in a pit on site; overflow goes offsite


Medium

Storm water drainage and outlet point from Site


Chemtech Fertilizers

79


Fertilizers Liquid: Sulphuric Acid

Solid: Rock Phosphate

Not Generated Not Generated No surface water drainage network on site. Surface run offgoes off site through main gate


Chemtech Fertilizers: Raw Material Management

80


Liquid: No sec containment; open to air. Site paved; flooring cracked almost everywhere.

Solid: Stored in closed room, paved, no secondary containment.

During monsoon runoff containing leakage, if any, would go off Site.

Medium



Chemtech Fertilizers: Surface Water Management

81


No surface water drainage network on site. Surface run off goes off site through main gate

Any surface contamination will go off site in monsoon

Medium

Storm water drainage and outlet point from Site


Benova Labs Pvt Ltd

82


API and Bulk Drugs Liquid:• Ethyl acetate• Methanol

Solid: • 3 4 difluro

notrobenzene• Marfolene

Effluent storage tank of 40 KL capacity. Wastewater generation of 0.9 KLD. No separation of low and high TDS done. Wastewater sent to JETL. TDS range of 10,000 ppm.

No solid waste generated on site. Upto 2016 salts (produced during distillation) used to be sent to TSDF.

Storm water drainage network on Site across production blocks, hazardous waste storage area.


Benova: Raw Material Management

83


Liquid: Solvent storage in drums on unpaved land open to sky; staining seen. No secondary containment.

Solid: Stored in closed room. Paved flooring, no secondary containment. Minor cracks were observed. Heavy staining all across the floor.


High

Spent solvent drum storage area Solvent drum storage area

Storm water drain


Benova: Wastewater Management

84


Effluent storage tank of 40 KL capacity. Wastewater generation of 0.9 KLD. No separation of low and high TDS done. Wastewater sent to JETL. TDS range of 10,000 ppm. No PAoC

Staining observed near the tank; any overflow will mix with storm water

Medium

Effluent storage tank


Benova: Hazardous Waste Management

85


No solid waste generated on site. Upto 2016 salts (produced during distillation) used to be sent to TSDF.

Historically: Spent solvent drums and recovery product; and black polythene bags (organic salts to Ramky); staining observed in storage area. Spent solvent is also stored in drums in open air, on paved land. Heavy staining observed on the floor and on storm water drain running adjacent to it.


High

Hazardous waste stored open to airUsed drums stored open to air


Benova: Surface Water Management

86


Staining observed on drain. Reddish colour stagnant water observed in drains.

Runoff will flow to outlet towards offsite main drain


High

Storm water drain on Site


Emmenar Pharma Unit 1 Pvt Ltd

87


Intermediate Drug Liquid: • Oxygen;• Solvent (MDC);• Mono Methyl Amine; • CS2 (carbon

disulphide)

Primary treatment done by settling process. 10 KL/day sent to JETL.

• Crude Potassium Salts

• Spent Solvent

Site has lined drain. Paved stormwaterdrain runs beside the effluent collection tank and hazardous waste storage areas respectively.


Emmenar Pharma Unit1: Raw Material Management

88


Liquid: Several ASTs and day tanks were observed on Site. ASTs and day tanks had staining on them. These tanks had containment in the form of dyke walls. Several areas along these dyke walls were noted to be stained.

Drain located downgradient to Raw material and finished products room, in a sloping area.

Medium

Solvent ASTs on Site


Emmenar Pharma Unit 1: Wastewater Management

89


Storm water drain located adjacent to Effluent collection tank. Staining observed. Site conducted Forced Evaporation till 2008.

Seepage of untreated effluent can potentially lead to surface water contamination.Historical soil and / or groundwater contamination issue due to FE.

Medium

Effluent tank located adjacent to storm water drainage on Site


Emmenar Pharma Unit 1: Hazardous Waste Management

90


Stored in closed area, paved flooring. No cracks were observed on the paved flooring. Heavy spillage and staining was observed on the floor. Storm water drain runs adjacent to hazardous waste storage area. High potential of spillage runoff into these drains. Spent solvent is stored in open to sky as well as within closed room. Heavy spillage on the paved flooring was observed within the closed room. Further, staining on the paved flooring of the storages in open to sky condition was noted by ERM. No secondary containment.

Hazardous waste area closed however visible staining outside storage area and no secondary containment. Staining also noted inside drain

High


Storm water drain


Emmenar Pharma Unit 1: Surface Water Management

91


Heavy staining observed on the storm water drains


High

Storm water drain and outlet point from Site


Vantech Chemicals Limited

92


Pesticide Formulation Liquid• Solvents (Trimethyl

benzene)

Solid• Talc powder, Sand• Surfactants

Not Generated Not Generated No dedicated storm water drainage network.


Vantech: Raw Material Management

93


Liquid: AG tank for solvents. Have sec containment. RM in closed room. No PAoC

Solid: Stored in closed room. Paved flooring. Secondary containment present.

- Low



Vantech: Surface Water Management

94


Run off goes out from main gate - Low

Surface water runoff on Site Storm water drain

Runoff collection pit


KRR Pharmaceuticals Pvt Ltd

95


Intermediate

Site currently not operational

NA NA NA NA


Hyderabad Waste Management Project

96


TSDF

The Site was an unauthorized waste disposal area prior to 2001 when it was converted to a TSDF

Liquid: • Sulphuric Acid &

miscellaneous stabilization material

Solid:• Lime• Flyash• Ferrous sulphate• Cement

Four (4) SEPs present on site

• Landfilling waste• Incineration waste• Leachate

Several lined storm water drainage network present on Site. These run parallel to waste storage areas, stabilization pit areas, incinerator area, SEPs.

Several natural unlined drain across Site. One major unlined natural drain across the whole Site boundary.


HWMP: Raw Material Management

97


Stored in paved closed room.



High



HWMP: Wastewater Management

98


Four (4) SEPs present on site.

Overflow from SEPs goes to natural surface water drains on site



High

Solar Evaporation Pond located with HWMP


HWMP: Hazardous Waste Management

99


Leachate is collected in tanks, located beside every landfill. This is collected via leachate drains within landfill (as designed). Leachate from these tanks are transferred to SEPs located on Site.


High



HWMP: Surface Water Management

100


Several lined storm water drainage network present on Site. These run parallel to waste storage areas, stabilization pit areas, incinerator area, SEPs.

Several natural unlined drain across Site. One major unlined natural drain along the whole Site boundary.

Spillage and staining observed across Site areas.

Any surface contamination will go into the storm water drain and to SEP. the SEP overflow will go off site in monsoon

High

Storm water drains within HWMP


Balaji Galvanizing India Limited

101


Galvanizing Liquid:Hydrogen Fluoride (1%)Nitric Acid (3%)

Solid: Stainless Steel (SS) wires

Primary treatment done by settling process. Sludge bed present. Sludge is sent to TSDF.

Wastewater generated during washing.

Wastewater sludge;Used oil drums

No lined storm water drainage on Site. Reportedly surface water run off through gate located in northern boundary and through neighbouring industry (YagmagLaboratories)


Balaji Galvanizing: Raw Material Management

102


SS wires: Stored inside a closed, paved room. No cracks observed on flooring.

Spillage and staining observed Medium


Balaji Galvanizing: Wastewater Management

103


Primary treatment done by settling process. Sludge bed present. Sludge is sent to TSDF.


Heavy staining noted around the ETP tank indicating potential spillage.


Surface runoff in monsoon can lead to untreated effluent mixing with storm water.

High

ETP tanks within Balaji Galvanizing Sludge bed for effluent within BalajiGalvanizing


Balaji Galvanizing: Hazardous Waste Management

104


Waste oil is stored in drums, kept in open air, without secondary containment on unpaved land. Heavy spillage observed. Wastewater sludge is stored in sludge drying beds, without secondary containment. Heavy staining was observed along the sludge drying beds.

Overflow in monsoon can lead to hazardous waste mixing with surface run off.

High

Staining adjacent to sludge beds observed within Balaji Galvanizing Waste oil stored storage within Balaji

Galvanizing


Balaji Galvanizing: Surface Water Management

105


No lined storm water drainage on Site. Reportedly surface water run off through gate located in northern boundary and through neighbouring industry (Yagmag Laboratories).

Surface staining observed within surface water drains on site.

Overflow in monsoon can lead to hazardous waste and untreated effluent mixing with surface run off.

High

A & B: Outlet from production block onto ground outsideC : Surface water outlet from Site

A B

C


Goldstone Infratech Limited

106


Was a galvanizing industry; since 2015 used as a warehouse for their own product

NA NA NA One main lined storm water drain runs along the Site.


Goldstone Infratech: Surface Water Management

107


One main lined storm water drain runs along the Site.

- Low

Storm water drain on Site


Navodaya

108


Manufacture HDPE drums and Fibredrums

PaperHDPE granules

Not Generated Not generated No lined drainage network; runoff goes out from main gate.


Navodaya: Raw Material Management

109


Stored under roof in closed room. No PAoC - Low

Finished products: Fiber drums and HDPE drums


Navodaya: Surface Water Management

110


No drainage network; runoff goes out from maingate

- Low


Annex B

Summary of Site Visits

Site Setting

Sr. No# Facility Name Site Details Lattitude Longitude Date of Visit Site Contact Site History1 Balaji Galvanizing India Limited Annealing and Galvanization Unit 17.593826° 78.376424° 14-04-2017 Mr. Ravi Kumar (Production In Charge) (Ph:

+91 9393012470)Operational From: Information not availableHistroy prior to operations: Information not available

2 Divis Pharmaceuticals Pvt Ltd (5 acres) Bulk Drugs and API 17.589503° 78.378137° 14-04-2017 N.V.Nageshwar Rao (Plant Manager) (Ph: 8458277228)

Operational From: 1994Histroy prior to operations: Vacant land

3 Emmenar Pharma Unit 1 Pvt Ltd (7 acres) Intermediate Drug 17.589713° 78.381741° 13-04-2017 Gopikrishna (Plant Manager (Ph: +91 9246541687)

Operational From: 2008Histroy prior to operations: Purchased in 2005 from Reliance Rubber.

4 Goldstone Infratech Limited (2.5 acres) Was a galvanizing industry; since 2015 used as a warehouse for their own product

17.594014° 78.376268° 13-04-2017 Malkit Singh (Plant in Charge) (Ph 9603265256) Operational From: 2012Histroy prior to operations: Information not available

5 KRS Pharmaceuticals Pvt Ltd ( Area - 2 acres) Bulk Drug/ Intermediate 17.594457° 78.379066° 11-04-2017 Mr.Prasad (Plant Manager) 9951929514 Operational From: 2004Histroy prior to operations: Was operated by Vinayak Chemicals

6 Lee Pharma Ltd. (5.6 acres) API and Intermeddiates 17.589992° 78.380228° 14-04-2017 Balwant Reddy (Plant Head) and Virender (ETP in charge) (Ph: +91 7674892999)

Operational From: 1997Histroy prior to operations: Information not available

7 Regent Paints Pvt Ltd Paint Manufacture (oil and emulsion based) 17.583929° 78.379165° 14-04-2017 Umang Kejriwal (Plant Head) Operational From: 2008.Histroy prior to operations: Information not available

8 Selma Laboratories Private Limited API and Bulk Drug Manufacturing 17.594452° 78.382977° 11-04-2017 Mr. Venu Babu (General Manager) Operational From: N.A.Histroy prior to operations: Selma Labs Pvt. Ltd. took over the site from Avalon Chemicals in 2009. From 2006 to 2009 - Avalaon and before that Site belonged to Jupiter Lifesciences. Site has not been functional from 2009.

9 TIDC India Pvt Ltd (Total 30 acres) Engineering 17.586865° 78.381349° 13-04-2017 V.P. Raju (Senior Manager Maintenance) (Ph: +91 9985650070)

Operational From: 1992Histroy prior to operations: Previously occupied by Rollmer Chain Division (also engineering)

10 TPS Laboratories Pvt Ltd API and Bulk Drug Intermediate Manufacturer (After takeover from Virupaksha, Site is going to stop producing APIs)

17.594586° 78.381247° 11-04-2017 G. Chandrasekhar Reddy (Director - Operations)

Operational From: 1989. operations decreased since last 2 years. To be accquired by Virupaksha in 6 months.Histroy prior to operations: Information not available.

11 Hyderabad Waste Management Project (200 acres)

TSDF 17.593731° 78.388590° 15-04-2017 Radha Krishna Sai (Project Manager)/ Mr. Madhu (Business Adminstration)

Operational From: 2001Histroy prior to operations: Previously was an illegal waste dumping area

12 Virchow Chemicals (65 acres. Built area of 25 acres)

Chemical and Intermediate 17.593232° 78.380206° 13-04-2017 Mr. Suresh Babu (Plant Manager) (Ph: +91-7729865536)

Operational From: 1989Histroy prior to operations: Information not available.

13 Virupaksha Organics Limited Bulk Drug Intermediate Manufacturer 17.594439° 78.380274° 11-04-2017 G. Chandrasekhar Reddy (Director - Operations)

Operational From: 2003Histroy prior to operations: Information not available.

14 Mylan Labs Unit -1 APIs 17.594025° 78.379073° 18-04-2017 Mr. Prasanna and Mr. Surya Mohan Operational From: 1989Histroy prior to operations:1989-2001 - Vorin Labs2001-2007 - Matrix Labs2017 - present - Mylan

16 Hetero Bulk drugs and API 17.588489° 78.375323° 17-04-2017 Mr.Malakondaiah (+91 9100700991) Operational From: Purchased in 1997Histroy prior to operations: Prior to 1997 there was another operating site, the Information of which is not available.

17 Arch Pharma Labs Limited (12 acres) Bulk drugs and API 17.593188° 78.381558° 18-04-2017 K.Ravi Babu (VP Operations) (7337455538) Operational From: Operational since 1990's, was shut down for 6 years and restarted work 2017Histroy prior to operations:Information not available

18 Benova Labs Pvt Ltd (1 acre) Bulk drugs and API 17.587153° 78.377363° 17-04-2017 Krishna Reddy (Managing Director) (Ph: 91 8106091393)

Operational From: Information not availableHistroy prior to operations: Information not available

19 Chemtech Acids and Chemicals Chemical 17.585982° 78.372163° Operational From: 1992History prior to operations: Information not available

20 Chemtech Fertilizers (2.7 acres) Fertilizer 17.585919° 78.370591° Operational From: 2001History prior to operations: Information not available

21 Kekule Pharma Limited (6 acres) Bulk drug 17.584658° 78.380533° 17-04-2017 Ramkrishna Gummadi (Plant Manager) (91 9440802667)

Operational From: Operational sine 1989Histroy prior to operations: Information not available

22 KRR Pharmaceuticals Pvt Ltd (2.2 acre) Intermediate 17.586733° 78.372086° 12-04-2017 Satyanarayan Reddy (Manager) 9392765176, V. Murli Krishna

Operational From: Currently not operationalHistroy prior to operations: Information not available

24 SMS Pharmaceuticals Limited (Unit 1) (12 acre) Bulk drugs 17.586058° 78.375489° 17-04-2017 Murali Shekhar ( DGM operations) M.Praveen kemar (EHS Manager)

Operational From: Information not availableHistroy prior to operations: Information not available

25 Sri Ram Chlorochem (5 acres) Bulk Drug Intermediates 17.582610° 78.375286° 12-04-2017 Mr.RaviChandra (Plant Manager) Operational From: 2013History prior to operations: Information not available

26 Vantech Chemicals Limited Pesticide Formulation 17.585011° 78.378482° 12-04-2017 Mr. M.S.Raju (DGM Operations) Operational From: 1993History prior to operations: Vacant Land

27 Navodaya Packaging HDPE / Fibre Drums Manufacture 17.583002° 78.377188° 12-04-2017 Mr Narahari (Plant Manager, +91 9348451166) Operational From: 2010History prior to operations: Granite cutting unit

28 Yagmag Closed (Prviously API) 17.593659° 78.375924° 13-04-2017 No Contact Person was available Operational From: Not operationalHistroy prior to operations: Information not available

V. Chinnarao (GM)/ Mr. Alexander (Production Manager)

12-04-2017

Material Storage

Sl. No. Facility Name Major Raw Materials - Liquid Storage Capacity (for UST/ AST)Storage Quantity (for Drums)

Storage Method Storage Condition Major Raw Materials - Solid Storage Quantity Storage Condition Major Products Quantity Storage Condition of Major Products Any Historical Spillage Rating

1 Balaji Galvanizing India Limited Hydrogen Fluoride (1%)Nitric Acid (3%)

3 KL x 3 AST AST ASTs in open to sky storage, No secondary containment. Spillage and staining observed.

Stainless Steel (SS) wires 40-50 tonnes/month Stored inside a closed, paved room. No cracks observed on flooring.

Stainless steel wire 40 tonnes/month Stored inside a closed, paved room. No cracks observed on flooring.

None reported

2 Divis Pharmaceuticals Pvt Ltd (5 acres)

Benzaldehyde (liquid form)Mono methyl amine (gas)Acetophenole (liquids)Para chloro benzo trifluorideMethanolAcetoneTolueneMethyl acetyne

15 tons5 tons20 tons20 tons20 KL(Solvents stored in 5 USTs and 7 ASTs. These storage tanks are operational since last one year).

DrumsASTDrumsDrumsUSTUSTUSTUST

Some drums were observed to be stored under tinned roof (no walls). Concrete paved. Some drums are also kept without any secondary containment. These are located in paved and unpaved areas of the Site. Five (5) USTs, Seven (7) ASTs and several day tanks are located on Site. All ASTs were observed in proper condition. Day tanks had minor staining on its walls.

Caustic soda (solid) 4 tons Stored in drums, within closed room. Paved condition, no cracks and staining observed on the floor.

Fluoxetine HCLRnD trialsKeterolactro methylamine

4 tons/ month1 kg/ month500 kg/ month

Stored in drums, within closed room. Paved condition, no cracks and staining observed on the floor.

None reported

3 Emmenar Pharma Unit 1 Pvt Ltd (7 acres)

OxygenSolvent (MDC)Mono Methyl Amine CS2 (carbon disulphide)

NA20KL80 tons50 metric tons

ASTASTASTAST

Several ASTs and day tanks were oserved on Site. ASTs and day tanks had staining on them. These tanks had containment in the form of dyke walls. Several areas along these dyke walls were noted to be stained.

NA NA NA MIDC (methyl isothyocyanade) 100 metric tons/ month Stored in drums, within closed room. Paved condition, no cracks and staining observed on the floor.

None reported

4 Goldstone Infratech Limited (2.5 acres)

None Not Applicable Not Applicable Not Applicable None Not Applicable Not Applicable steel ancillary fittings 40 ton/ month Stored in closed , paved room. None reported NA

5 KRS Pharmaceuticals Pvt Ltd ( Area - 2 acres)

MethanolTolueneAcetoneMethalyine dichloride

15 tons (all solvents together) Drums Stored in drums. Drums containing acid are stored in open air, without secondary containment. Staining observed on floor. Drums containing solvent are stored in closed , paved room. No cracks and staining were observed within the room.

omprezole - sulphateL cystine hydrochlorodemaltol

2 - 3 tons10 tons3 - 4 tons

Stored in drums, within closed room. Paved condition, no cracks and staining observed on the floor

omperizonedomperidoneesomeprazole magnesiumdeferiproneother small bulk drugs

30 tons/ year6 - 10 tons/ year12 tons/ year2 tons/ year100 - 200 kgs/ year

Stored in drums and gunny bags, within closed room. Paved condition, no cracks and staining observed on the floor.

None reported

6 Lee Pharma Ltd. (5.6 acres) Solvents (MDC)Solvents (Acetone)

10 tons10 tons

ASTUST

Acetone is stored in six (6) USTs. These tanks are five years old. No integrity testing has been done of these tanks. Several ASTs and day tanks observed on Site. The ASTs had secondary containment in form of dyke walls. No staining observed. Day tanks were observed to be highly stained. Staining was also observed on floor below day tank locations. Storm water drainage systems are present adjacent to such locations.

BenzimidazoleChloro compounds

600 kg600 kg

Stored in closed rooms, with proper secondary containment. No cracks and staining were observed.

Pendoprozol SodiumOmiprezoleItraconzoleLancoprezole

2 tons/ month5 tons/ month15 tons/ month1 ton/ month

Some products were stored in closed room, which were observed to be paved and in proper condition. Some amount of finished goods were also located outside these dedicated rooms, but within a tinned roof (no walls) and paved condition.

None reported

7 Regent Paints Pvt Ltd Solvents (mineral turpentine oil)Solvent (alkyd)

30 KL30 KL

Drums Stored in drums. These were located in paved areas without secondary containment. No cracks were observed within the closed rooms. Minor staining were observed on the paved flooring. Certain drums containing solvents were kept in open area without secondary containment (paved and unpaved areas of site, minor staining observed)

extenders (powder form)additives emulsions

50 tons1 ton20 tons

Stored in drums. Emulsions were stored in drums, open to air, without any secondary containment. These were stored in paved floor. No cracks were observed. Minor staining was observed on the floor areas.

water based paintsolvent based paint

800 KL/ month800 KL/ month

Stored in drums and cans within closed room. Secondary containment present. Paved flooring, no cracks and staining were observed.

None reported

8 Selma Laboratories Private Limited (Not Operational)

Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable

9 TIDC India Pvt Ltd (Total 30 acres)

Methanol 16 KL Drums Stored in open to air and also within closed room. Paved and secondary

Metal steel stripWires

1000 tons/ month Closed and open Chains 800 tons/ month Stored in closed room, paved areas. None reported

10 TPS Laboratories Pvt Ltd Methylacetate salicylateTert butyl ammonium bromidePottasium carbonateBenzyl chlorideMethanolHydrochloric acid1,4, dioxaneSelenium dioxideSSP-02MethanolTert butylamineDiglymeSodium borohydrideLithium bromideSSP-03Acitic acidActivated carbonEDTA disodiumCaustic soda flakesSSP-04MethanolSSP 05

500 kg/ month (All put together) Solvents are stored in USTs.Rest are stored in drums, some areas do not have secondary containment.

Spillages observed in drum storage area(s)

NA NA NA Salbutamol sulphate/ Benzyl salbitamolNaproxen

2 Kgs/ day20 kgs/ day

Stored in closed room, paved areas. None mentioned by the Site contact


Sulphuric Acid; and miscellaneous stabilization material

2 tons AST Miscellaneous stabilization material stored in paved closed room.

LimeFly ash

Ferrous sulphateCement

50 tons100 tons. purchased from local companies.2 tons/ year20 tons

Stored in closed area. Paved. No cracks were observed on floor. Heavy staiining was observed.

Incinerator wasteDirect landfill waste (10 % of waste that they receive)Treated landfill waste (90% of waste that they receive)

200 tons/ month9500 tons/ month (Direct+treated)

Government approved and authorized Landfill



Ethylene dichlorideMethanol Sulphuric acid

25 KL30 KL

DrumsAST (2)

Stored in above ground tanks with secondary ocntainment. Stainng noted around the tank

SulphurAcetanalideChloro sulphonic acidSoda ashSodium sulphide BenzeneChloro sulphonic acid

1500 tons600 tons200 tons50 tons100 tons50 tons200 tons

Stored in closed area. Paved, No secondary containment in some areas

Acetyl Sulphynyl ChlorideBenzene sulphinic acidDi methyl sulphate

600 tons/ month100 tons/ month600 tons/ month

Stored in closed room, paved areas. None reported

13 Virupaksha Organics Limited 1,3 difluro benzenechloro acetyl chloridealum chloride4 amino 1,2, 4 trizolMethyl dichloride IPA

4 to 6 tons/ month1.25 * 4/6 tons0.85 * 4/6 tons

10 tons/ month (each of trizol, MDC & IPA)

AST and drums ASTs were observed to be in proper condition.Several day tanks are located in production areas. Staining was observed on the floor.Drums are stored open to air without secondary containments.

None Not Applicable Not Applicable 2,4, difluro acetophenone2 Amino 5 Bromo pyridineAmino 5 chloro pyridine

432 kg/ day200 kg/ day270 kg/day

Stored in closed room, paved areas. None reported



14 Mylan Labs Unit -1 AcetonitrileChloroformCyclohexaneDimethyl formamide (DMF)Dimethyl sulfoxide (DMSO)Ethyl AcetateHexanesIsopropyl Alcohol (IPA)MethanolMethylene Dichloride (MDC)n-ButanolN-Ethylpiperazinen-HeptanePyridineTolueneHydrobromic AcidCaustic Soda Lye (48%)Sulfuric Acid (CP)

13380.38 Kg494.391 Kg1142.7 Kg2025.1 Kg6506.8 Kg21726.74 Kg34809.24 Kg55043.95 Kg61244.72 Kg33114.63 Kg765.25 Kg3074 Kg15179.71 Kg650.715 Kg30763.75 Kg1634.2 Kg2103.9 Kg3421 Kg

AST Stored in ASTs having secondary containment.

Activated Carbon (ENOPC)HyfloSodium BicarbonatePhosphorus OxychloridePotassium Hydroxide FlakesCaustic Soda Palladium (10% on charcoal, 50% wet)CMH AcidCalcium Chloride (Anhydrous)Citric Acid (Monohydrate)Dipotassium Hydrogen OrthophosphateSodium BorohydrideSodium Carbonate Sodium ChlorideSodium Dihydrogen OrthophosphateSodium SulfateSuccinic AcidBoric AcidCBZ-L-ValineCyanoacetamideD-(-)-Mandelic AcidGuaninePotassium IodideR(+)-Alpha MethylbenzylamineSilica Gel

505.7 Kg1341.9 Kg4714.19 Kg3374.25 Kg6814.33 Kg7075.57 Kg76.806 Kg

1244.61 Kg1334.8 Kg

998.9 Kg1687.9 Kg

919 Kg3967.4 Kg12268.7 Kg325.13 Kg

1987.5 Kg1458.9 Kg23.5 Kg8286.6 Kg768.9 Kg75 Kg10336.9 Kg365.88 Kg2471.56 Kg

321 5 Kg

Stored in roofed warehouse and on paved surface.

LopenavirValganocyclovirQutafin

16 - 17 tonnes/month ( all incl)

All finished goods are stored in FG warehouse with paved flooring.

None reported

16 Hetero MethanolTouleneHexaneIPAAcids, MDC and causticRecovered solvents

28 KL65 KL24 KL28 KL25 KL, 30 KL, 20 KLInformation not available

USTUSTUSTUSTAST AST

Unkown for UST; for AST it is in a paved tankfarm having a secondary containment.

* as per annex * as per annex Stored in roofed warehouse and on paved surface.

As attached (72 nos.) All finished goods are stored in FG warehouse having paved flooring.

None reported

17 Arch Pharma Labs Limited (12 acres)

Sodio cyanideIso propyl alchoholMagnesium chloride

Information not available AST 9 AST for solvents. No PAoCs.Solvent storage doesn’t have secondary containment; run off into storm water drain nearby

Ethyl chloro esto estateEthyl acetateMDC

5 metric ton20 metric ton40 metric ton

Stored in closed room. Paved flooring. No cracks were observed. Minor staining all across the floor.

EatorovostatinZudovadine

20 metric ton/ month (combined)

Stored in closed room. Paved flooring. None reported

18 Benova Labs Pvt Ltd (1 acre) Ethyl acetateMethanol

10 tons all solvents Drums Solvent storage in drums on unpaved land open to sky; staining seen. No secondary containment.

3 4 difluro notrobenzeneMarfolene

5 tons all solids Stored in closed room. Paved flooring, no secondary containment. Minor cracks were observed. Heavy staining all across the floor.

3 3 fluro 4 marpholiritePhenylOxazolidinyl methyln methyl opda

150 kg/ month (combined) Stored in closed room. Paved flooring. Staining observed. No secondary containment.

None reported

19 Chemtech Acids and Chemicals Methanol 50 tonnes Methanol in AG tank Methanol in AG tank; no secondary containment.

SulphurCaustic Soda flakes

600 to 1000 tons Sulphur stored in open to sky on paved land; caustic soda flake in a room.

Sulphuric acidOleum

70 tons/ day (combined) Stored in closed room. Paved flooring. No secondary containment.

None reported

20 Chemtech Fertilizers (2.7 acres) Sulphuric Acid 100 tons AST No sec containment; open to air. Site paved; flooring cracked almost everywhere.

Rock Phosphate 2000 tons Stored in closed room, paved, no secondary containment.

SST ( Single Super Phosphate)NPK mixture

1500 tons/ month1200 tons/ month

Stored in closed room. Paved flooring. No secondary containment.

None reported

21 Kekule Pharma Limited (6 acres) maltoldiophenoltrifluroacetic acid tolueneacetonemethnoldichloridechloroform

50 to 70 tons (Combined) AST, Drums. ASTs for solvents; no secondary containment;Day tanks of SS UG, 10 ~12 years old, no integrity testing done. Total of ~25 tanks; per tank of 500 L; Some drums were stored in closed rooms, paved. No cracks were observed within closed rooms. Large number of drums containing solvents were kept in open to sky condition, unpaved and paved areas of Site. Staining was observed all across Site premises. Site contained several day tanks and stainles steel UG tanks. These were observed to be in very poor condition. heavy spillage observed on UG tanks

Not Applicable Not Applicable Not Applicable pentaprozolcelecaxidhetericaxidbicaldamide

2.5 ton/ month3 ton/ month3 to / month4 ton/ month

Stored in closed room. Paved flooring. Secondary containment present.

None reported

22 KRR Pharmaceuticals Pvt Ltd (2.2 acre)

Sick Industry (Not Applicable) Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable PiperazinePREG 3Mannich HydrochlorideBis- Fosfomcintrometamol disaltMethyl sulphonate ammonia piraminePAVEST2 Ethoxy Benzoic AcidPADA

200 kg/ day200 kg/ day200 kg/ day200 kg/ day102.47 kg/ day102.47 kg/ day102.47 kg/ day102.47 kg/ day

Currently no storage NA NA

24 SMS Pharmaceuticals Limited (Unit 1) (12 acre)

MethanolTolueneIpaDMSO (dimethyl sylphoxide)

30 KL (2 tanks AST)Not available50 KL (2 tanks)Not Available

AST (2)DrumsAST (2)Drums

Stored in ASTs and Drums without secondary containament, open to air. Staining near day tanks, drums storage and loading and unloading areas.

Furfyrl alchoholCystamine HydrochlorideNMSM (intermeddiate product)

200 tons/ month Stored in closed room. Paved flooring. Secondary containment present.

FamotidineSildenafil CirateCystoferNMSMRantaditine Hydrochloride

5 tons/ month5 tons/ monthNot AvailableNot Available100 tons/ month


None reported



25 Sri Ram Chlorochem (5 acres) Mono methyl ammine gasMethyl EthelateTolueneMethanolDiesel

4 KL25 KL25 KL25 KL25 KL

UST, AST, Drums Total of ten (10 ) USTs on site (25KL capacity each for methyl ethelate, methanol, toluene, diesel). These USTs are 2 to 3 years old (no integrity testing done). Localized, minor staining was observed on ASTs and day tanks. Drums are stored under tinned roof (no walls). Storage area without secondary containment, paved, staining observed. Several drums were located in open air, paved areas with minor staining all across Site. Minor staining near production block.

Sodium methoxideECF (Ethyl chloro formate)

1000 kgs8 tons


NMPNCP4 ANCP

5 tons/ month (combined) Stored in closed room. Paved flooring. Secondary containment present.

None reported

Talc powder, Sand Brand Name Ryanxpr/ Fittera, Chemical name hlorantraniliprole

400 tons

Surfactants Carbofuoron 10 - 15 tons

27 Navodaya Packaging None Not Applicable Not Applicable Not Applicable PaperHDPE granules

20-35 tons/ month50 tons/ month

Stored in closed room, on paved floor.

Fiber drumsHDPE Drums

40,000 nos. per month20,000 nos. per month

Stored within closed room, on paved floor. None reported

28 Yagmag Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable None reported NA

AST, Drums Max 5 tons Stored in closed room. Paved flooring. Secondary containment present.


None reported60 to 90 KLSolvents (Trimethyl benzene) Solvent, surfactans. AG tank for solvents. Have sec containment. RM in closed room. No PAoC

Vantech Chemicals Limited26

Waste Water Management

1 Balaji Galvanizing India Limited Primary treatment done by settling process. Sludge bed present. Sludge is sent to TSDF.


No Heavy staining noted around the ETP tank indicating potential spillage.

2 Divis Pharmaceuticals Pvt Ltd (5 acres) pH adjustment and solid separation is carried out. 20KL per month sent to JETL. Residue sludge is sent to TSDF

No discharge of wastewater No Open tanks (3 nos ) noted in historical image. Site conducted Forced Evaporation till 2016.

3 Emmenar Pharma Unit 1 Pvt Ltd (7 acres) Primary treatment done by settling process. 10 KL/day sent to JETL.

No discharge of wastewater No Storm water drain located adjacent to Effluent collection tank. Staining observed. Site conducted Forced Evaporation till 2008.

4 Goldstone Infratech Limited (2.5 acres) Not Applicable Not Applicable Not Applicable Not Applicable

5 KRS Pharmaceuticals Pvt Ltd ( Area - 2 acres) No ETP. Only pH adjustement and solid separation is carried out. Effluent collection tank present separate for low (capacity 40 Kl) and high (capacity 20 kl)TDS. 10KL/ month of low and high TDS sent to JETL

Demineralized reject water is used for gardening. TDS range is 400 - 500 ppm

No Site conducted Forced Evaporation till 2015.

6 Lee Pharma Ltd. (5.6 acres) Existing ETP capacity is 50 KL/ day and upgrading to 100 KL/ day. High TDS sent to MEE followed by ATFT. Low TDS is mixed with condensate from MEE and sent to PETL. New biological treatment plant is being setup on site to treat low TDS as reported by Site representative.

No discharge of wastewater No Area open to sky; no secondary containment; heavily stained. Run off discharged into stormwater drain in monsoon and go offisite.

7 Regent Paints Pvt Ltd No process wastewater generated on Site. Raw water is treated using RO.

Reject RO water used for gardening. Potential for surface water mixing with RO reject is high.

No

8 Selma Laboratories Private Limited Not Operational Not Operational No Not Applicable

Sl. No. Facility Name Wastewater Treatment Remarks RatingAny Discharge of Treated/ Untreated Wastewater On-site or Off-site

Any Analytical Testing of Wastewater for Raw Material and Products (including API)



9 TIDC India Pvt Ltd (Total 30 acres) Settling tank present. Alum is added and recirculation is carried out and finally used in process.

No discharge of wastewater No

10 TPS Laboratories Pvt Ltd No ETP. Only pH adjustment and solid separation is carried out. Effluent collection tank present. Low TDS of 60 KL/ month is sent to PETL. High TDS of 10 KL/ month is sent to JETL via Virupaksha.



Four (4) SEPs present on site Overflow from SEPs goes to natural surface water drains on site


Neutralization carried out via gypsum addition. High TDS (6.4 KLD, TDS range of 1,50,000 ppm, COD range 100 milligram/ liter) goes to MEE. Low TDS (180 KLD, TDS range 1500 ppm), reused for process without treatment. MEE residues goes to TSDF.

Low TDS is recycled for process No

13 Virupaksha Organics Limited Only neutralization process carried out. High TDS (10 Kl/ month) to MEE. Low TDS (60KL/ month) to PETL.

No discharge of wastewater

14 Mylan Labs Unit -1 Waste water is seggregated into Low TDS (17 KLD) and High TDS (49KLD).




16 Hetero Waste water is seggregated into Low TDS (135 KLD) and High TDS (110 KLD).



Yes No All WW collected in AG tanks and then transferred to ETP



17 Arch Pharma Labs Limited (12 acres) Segregation and clarification carried out. Then low TDS (5KL) sent to PETL, High TDS (10KL) sent to MEE.

No discharge of wastewater No SEP's noted in 2003 historical image

18 Benova Labs Pvt Ltd (1 acre) Yes. Only effluent storage tank of 40 KL capacity. Wastewater generation of 0.9 KLD. No separation of low and high TDS done. Wastewater sent to JETL. TDS range of 10,000 ppm.


19 Chemtech Acids and Chemicals No waste water generation No discharge of wastewater NA Not Applicable

20 Chemtech Fertilizers (2.7 acres) No waste water generation No discharge of wastewater NA Not Applicable

21 Kekule Pharma Limited (6 acres) Only effluent storage tanks present. Low TDS mixed with High TDS and sent to JETL.

No discharge of wastewater No SEP noted in historical images till 2008.

22 KRR Pharmaceuticals Pvt Ltd (2.2 acre) Only effluent storage tanks. Not Operational. Not Operational. No Historical image shows SEP in 2003

Not Applicable


High TDS (60 KLD) and low TDS (8KLD) generated. ETP capacity of 100 KLD. High TDS sent to MEE.

No discharge of wastewater No Heavy spillage and staining observed in the ETP area

25 Sri Ram Chlorochem (5 acres) All wastewater goes to onsite MEE. No PAoCs. No discharge of wastewater No

26 Vantech Chemicals Limited No waste water generation No discharge of wastewater No Not Applicable

27 Navodaya Packaging No waste water generation No discharge of wastewater No 5 - 6 tankers water used per month for cooling tower.

Not Applicable

28 Yagmag Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable

Waste Management

1 Balaji Galvanizing India Limited Wastewater sludgeUsed oil drums

200 - 300 Kg 20 drums

Waste oil is stored in drums, kept in open air, without secondary containment on unpaved land. Heavy spillage observed. Wastewater sludge is stored in sludge drying beds, without secondary containment. Heavy staining was observed along the sludge drying beds.

Open drums for waste oil storage, Open storage of hazardous waste.


solvent residuesinorganic salts/ distillation bottom residuespent carbonOrganic Process rejects

13 tons/ year Stored in closed area, paved flooring. No cracks were observed on the paved flooring. Heavy spillage and staining was observed on the floor. Spent solvent is stored under tinned roof (no wall), paved flooring. Heavy spillage was observed on the floor.

Staining noted outside Hazardous waste storage area. Surface runoff would carry any open to air spillage out of the facility.


Crude Pottasium SaltsSpent Solvent

40 tons/ monthNot Available

Stored in closed area, paved flooring. No cracks were observed on the paved flooring. Heavy spillage and staining was observed on the floor. Storm water drain runs adjacent to hazardous waste storage area. High potential of spillage runoff into these drains. Spent solvent is stored in open to sky as well as within closed room. Heavy spillage on the paved flooring was observed within the closed room. Further, staining on the paved flooring of the storages in open to sky condition was noted by ERM. No secondary containment.

HW area closed however visible staining outside storage area and no secondary containment. Staining also noted inside drain


None Not Applicable Not Applicable Not Applicable Not Applicable


spent carbon bottom residues from different process

together 30 tons/ year No hazardous waste in the open area. Hazardous waste is stored in closed room without secondary containment. Staining noted on walls.

-

RatingRemarksQuantity storedSl. No. Facility Name Hazardous Waste Produced On-site Storage Condition


6 Lee Pharma Ltd. (5.6 acres) Process residuesInorganic waste (salts) comes from MEE and ATFTSpent Carbon + organic salts

60 kg/ month150kg/ day500 kg/day

Stored in closed room, paved flooring. No secondary containment provided. Waste observed to be overflowing out of the room onto storm water drain running adjacent. Hazardous waste is also stored in sacks in open to sky condition, unpaved land, without secondary containment. Heavy spillage observed across the Site.

-

7 Regent Paints Pvt Ltd waste oil from DGused empty containers

6 l/ month~100 as observed on Site

Stored in drums in open to sky condition, in several paved and unpaved portions of site. Minor to heavy staining noted all around the Site premises.

-

8 Selma Laboratories Private Limited No. As not operational NA NA - Not Applicable

9 TIDC India Pvt Ltd (Total 30 acres) ETP sludge (sand, emily and some amount of oil) (PID - 2.8 ppm)Used oil

400 tons/ month

400 L/ month

Used oil is stored in drums under tinned roof (no wall), in paved flooring. No secondary containment, heavy staining noted on the floor and on stormwater drain running adjacent. Sludge is stored in containers, open to air, paved flooring. Heavy staining observed on the floor.

-

10 TPS Laboratories Pvt Ltd Spent CarbonDistillation Bottom ResidueForced Evaporation SaltDetoxified containers and liners (recyclable)Waste Oil (recyclable)

50 kg/ month150 kgs/ month400 kgs/day10 nos/ month

2 lt/ month

Hazardous waste stored in drums; open to sky; on unpaved land; without secondary containment. Staining observed on floor at several places within Site.

-

Landfilling waste 0.5 tons/ dayIncineration wasteLeachate


Spent carbon from ASC and BSA manufactureSulphur sludgeInorganic salts/ bottom residue Fe salts (evaporation salts)Gypsum

3 tons/ month

2 tons/ month55 tons/ month40 tons/ month43 tons/ month

Stored in closed area; paved flooring; no secondary containment. Minor staining seen

-

-100 KL/ month


Collected in leachate tanks, located beside every landfill. This is collected via leachate drains within landfill (as designed). Leachate from these tanks are transferred to SEPs located on Site.


13 Virupaksha Organics Limited Spent CarbonDistillation Bottom ResidueForced Evaporation SaltDetoxified containers and linersWaste Oil

50 kg/ month150 kgs/ month400 kgs/day10 nos/ month2 lt/ month

Drums stored in closed room. Minor staining observed.Used drums are stored in open area, paved flooring, without secondary containment. No proper drum washing practice.

-

14 Mylan Labs Unit -1 MEE SaltsETP SludgeSpent carbon Spent solvents Distillation bottom residueWaste oilUsed drumsOff spec / expired drugs

70 tonnes/ month35 tonnes/month6 tonnes/ month400 KL/m10 tpm150 Lpm500 nos per monthNot Available

In covered room with secondary containment and a leachate collection system.

-

16 Hetero Process Organic residueInorganic saltsSpent carbonETP , MEE saltsUsed oilWaste drumsspent solventOff spec productsdate expired productsMisc- filters etc

together 30 tons/ year In closed room with paved surface. -

17 Arch Pharma Labs Limited (12 acres) Spent carbonMEE SaltsSolvent residues

Not Available Indoor; with paved flooring; no secondary containment. Staining observed on the floor.

-

18 Benova Labs Pvt Ltd (1 acre) Process Salts (upto 2016);Spent solvents;

Not Available Spent solvent drums and recovery product; and black polythene bags (organic salts to ramky); staining observed in storage area. Spent solvent is also stored in drums in open to sky condition, on paved land. Heavy staining observed on the floor and on stormwater drain running adjacent to the storage area.

-

19 Chemtech Acids and Chemicals No Not Applicable Not Applicable - Not Applicable20 Chemtech Fertilizers (2.7 acres) No Not Applicable Not Applicable - Not Applicable


21 Kekule Pharma Limited (6 acres) bottom residuesorganic residue+ spent carboninorganic salts

500 kg/ month600 - 700 kg/ month1.5 / 2 tons/ day

Stored in closed room, paved flooring. Heavy staining observed on the floor and outside hazardous waste storage room area. Seepage from waste storage room area was observed outside on the floor. No Secondary containment provided. Spent solvent is also stored in drums, in open air, paved flooring without secondary containment. Heavy staining and seepage observed on floor.

Hazardous waste noted outdoors in open condition


sodium chloride average 90 tons/ month Not Applicable. Currently in non operational state.

- Not Applicable


bottom organic residuespent carbon

Not Available Stored in closed room, paved flooring. Heavy staining observed on the floor. No

Spent solvent in drums in open areas

25 Sri Ram Chlorochem (5 acres) Fe Salts (from MEE)Bottom ResiduesPackaging waste

400 kg/ day160 kg/ dayNot Available

Drums stored in closed room; paved floor. Any surface water drain downgradient to hazardous waste area, any storm water will flow from the HW area into the drain.

-

26 Vantech Chemicals Limited NA NA NA - Not Applicable27 Navodaya Packaging No NA NA - Not Applicable28 Yagmag Not Applicable Not Applicable Not Applicable - Not Applicable

Surface Water Management


Yes (waste oil, ETP sludge bed)

No No stormwater drainage on Site. None. Reportedly surface water run off via northern corner and also towards Yagmag (located NE of the Site)

Yes Yes, staining observed along the gradient of the Site.

No One, through gate located in northern boundary and through neighbouring industry (Yagmag Laboratories)

No The outlet is towards YagMag and sludge bed can overflow during monsoon


No No All storm water drains are located such that during monsoon, runoff containing leakage if any, would flow offsite and through northern corner of the site boundary, into lined drain between Divis and SMS. This lined drain finally runs off into seepage collection sump. Also at the end of the Site along northern boundary, there is a rain water harvesting pit. All overflow from this trench would run off into the drain in between Divis and SMS.

No Yes No No One. Through north eastern boundary wall.

No Additional to one outlet, openings were noted in the north eastern boundary wall. During Site visit the facility was not operational


Yes (spent solvents)

No for Hazardous waste. Yes for raw materials and products.

Yes. Lined and unlined stormwater drainage on Site. Paved stormwater drain runs beside the effluent collection tank and hazardous waste storage areas respectively.

No Yes. Yes, heavy staining observed on the stormwater drains

No Two. Through the western portion of Site. Discharged into TIDC.

No The SW drain is newly built.


No Not Applicable Yes. One main lined stormwater drain runs along the Site.

No Not Applicable No No One. Through Main Gate. No -


Yes (solvents) Partial areas have secondary containment. Many areas stored solvents open to air without secondary containment.

Yes. Stormwater drain runs from ETP area, passes through raw material storage area and area where solvents are stored open to air and exits site through main gate. Staining is observed in drain.

No Yes Yes. Staining observed in drain. No One. Through Main Gate. No -

6 Lee Pharma Ltd. (5.6 acres) Yes (solvent, hazardous waste)

No Yes. Lined stormwater drainage network present all around the site. These drains run adjacent to production block, hazardous waste storage area, ETP, MEE and scrap yard. Potential runoff from these areas can lead onto the drains. All drains are finally connected into one main stormwater channel.

No. Site has an inlet from the common lined drain running parallel to Site.

Yes Yes. Heavy staining observed around hazardous waste storage area, ETP and MEE on the drains.

No One. Stormwater drain outlet into TIDC.

No -

7 Regent Paints Pvt Ltd Yes (emulsions, diesel, used empty containers)

No No stormwater drainage on Site. No Yes Heavy staining observed in DG area. Staining observed in hazardous waste storage area and areas where empty containers were kept open to air. Any surface contamination will go off site in monsoon.

No One. Through Main Gate. No -


NA NA One stormwater drain present on Site. No NA No No One. Through Main Gate. No -


Yes (Sludge) Only for Methanol. Yes. Stormwater network present on Site. These drains run adjacent to all the production buildings, hazardous waste storage area.

Yes. One natural unlined drain runs along the western boundary of Site.

Yes Yes. Heavy staining observed in drains along diesel storage area and hazardous waste storage area.

No One. Outlet from northern boundary wall.

No Due to low lying area that is likely impacted by neighbouring industries (one outlet from Lee and two outlets from Emmenar, One outlet from Granite industry.

10 TPS Laboratories Pvt Ltd Yes (solvents) Not for all storages One stormwater drain present on Site which runs into Virupaksha. Discharged offsite from Virupaksha main gate.

No Yes Yes. Spillage and staining observed across Site areas.

No One. Unlined surface run off through main gate.

No -


Yes Not for all storages Yes. Several lined stormwater drainage network present on Site. These run parallel to waste storage areas, stabilization pit areas, incinerator area, SEPs.

Yes. Several natural unlined drain across Site. One major unlined natural drain along the whole Site boundary.

Yes Yes. Spillage and staining observed across Site areas.

No One. Southwestern boundary.

No -

Sl. No. Remarks RatingAny Treatment prior to Offsite Discharge (Y/ N)

Probablity of Raw Material, Product, Waste and WW flowing into the

Any Organoleptic Findings within SW Channel

Any SW Quality Monitoring

How Many Offsite Discharge Points

Does Site have lined stormwater drainage network

Any Natural Drain Flowing through the SiteSecondary Containment of Storage Areas

Any Open to Sky Storage

Facility Name









Facility Name


Yes (DMS) No Yes. Several lined stormwater drainage network present on Site.

Yes. Several unlined natural drainage across Site area.

Yes Yes. Spillage and staining observed across unbuilt Site areas. Staining observed on stormwater drains.

No Three. One through main gate. One from southwest portion on to drain near Hetero. One from western boundary into vacant plot.

N Storm water all across the site has staining; no unpaved drains; earlier (till 2016) the storm water went off-site to form a pond. Now they cant discharge here since the land owner has objected.

Site has collection pits for stormwater but are insufficient for run-off collection. Reportedly, run off from TSDF and ArchPharma come into this site.

13 Virupaksha Organics Limited Yes No No.Surface flow goes towards the gate. There is a tank (2 – 3 kl) near the gate which receives TPS surface water as well. The first cut water is sent to PETL via tankers. Any overflow goes out of the site.

No Yes No No One. Through main gate. No Cracks on the paved surface

14 Mylan Labs Unit -1 Yes, only tank farms.

Yes Yes. Production area (east of the site) has drainage network; collection pit near southern boundary. First flush goes to ETP; rest goes off site from gate (the Site has a release valve).

ETP and solvent tank farm (west of the site) area does not have drainage network.The Site has one collection sump (small) near gate. Run off goes off site.

Yes. A closed public drain provided for the IDA passes through the eastern portion of the Site (runs north to south).

No No Yes (pH, COD, TDS) for the first flush storm water.

Four. Y (first flush is treated in ETP)

No Stormwater network in non production area ( Western portion). Outlet through southern gate during monsoon after first flush.

16 Hetero Yes, only tank farms.

Available except for organic waste residue storage area.

Unit I has drainage network, but it is not adequate: surface water drain is not connected to the north eastern part. Water from collection pit: first flush goes to ETP; after that it goes out of site;

On the day of site visit, there was water in storm water drain (from production areas, leakages from pipes, etc): this goes to sump and from there is goes off site (except for first flush which goes to ETP).

Unit II: no network; runnoff goes offsite from gate (located SW corner; downgradient point).

No Yes In process areas, orange color staining noted in the drains

No One. Drainage boundary from western boundary

NA Unit I has drainage network, but it is not connect to the north eastern part. The first flush storm water goes to the ETP.

In process areas, orange color staining noted in the drains.


No No Yes. Several stormwater drainage network on Site across production blocks, hazardous waste storage area. These drains finally join on to main storm water drain along northern boundary.

No Yes Yes. Reddish colour stagnant water observed in stormwater drain.

No One. Through Main gate. No All run off is collected in a pit near northern boundary and sent to onsite MEE

18 Benova Labs Pvt Ltd (1 acre) Yes (spent solvents)

No Yes. Several stormwater drainage network on Site across production blocks, hazardous waste storage area.

No Yes Yes. Staining observed on drain. Reddish colour stagnant water observed in drains.

No One. Through southern boundary onto drain between Mylan and SMS.

No Runoff will flow to outlet towards offsite main drain

19 Chemtech Acids and Chemicals Yes No Yes. Storm water drain along the periphery; water from drain as well as the runoff is collected in a pit on site; overflow goes offsite.

No Yes No No Two. Through the southern boundary.

No -

20 Chemtech Fertilizers (2.7 acres) Yes No No stormwater drainage on Site. No Yes No No One. Through main gate No -

21 Kekule Pharma Limited (6 acres)

Yes (solvents) No Yes. Several stormwater drainage network on Site across production blocks, hazardous waste storage area. Major stormwater drain runs along eastern boundary and gets collected in a 8kl tank.

No Yes Yes. Staining observed across Site areas and on storm water drains. Greenish coloured stagnant water observed on storm water drain on eastern portion of site.

No One. Through main gate No Reportedly runoff collected in tank. Staining noted across the production area indicating run off will carry this offsite.


Yes No Yes. Several stormwater drainage network on Site.

No No No No One. Through main gate No - Not Applicable









Facility Name


Yes No Yes. Several stormwater drainage network on Site. Major stormwater drain located to the north of site.

No Yes No No One. Through main gate. No Surface flow out of gate during monsoon to open area south of Site

25 Sri Ram Chlorochem (5 acres) Yes No Yes. Several stormwater drainage networks on Site.

No Yes Yes. Staining observed across Site gradient.

No One. Through southern boundary.

No There is a surface water drain downgradient to hazardous waste storage area; any spill will lead into the drain

26 Vantech Chemicals Limited Yes Yes Yes. One major storm water drain across the northern boundary of Site. These gets collected in a pit.

No No No No One. Through main gate. No -

27 Navodaya Packaging No Not Applicable No No No No No One. Through main gate. No -

28 Yagmag Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable Not Applicable

Groundwater Monitoring


No NA NA NA NA Tanker water (100 KL/day)

-



Potential for ground water impact due to presence of USTs on site.

3 Emmenar Pharma Unit 1 Pvt No NA NA NA NA Tanker water (100 -4 Goldstone Infratech Limited

(2.5 acres)No NA NA NA NA Tanker water (20

KL/month)-


No NA NA NA NA Tanker water Potential for ground water impact due to Forced evaporation, that is being carried out since 2015. RO reject is also used for gardening.

6 Lee Pharma Ltd. (5.6 acres) No NA NA NA NA Tanker water (60 KL/day)

Potential for ground water impact due to presence of USTs on site, for which no intergrity testing has been done.

7 Regent Paints Pvt Ltd No NA NA NA NA Tanker water (36 KL/day)

Potential for ground water impact due to the use of RO reject for gardening.


No NA NA NA NA NA -



Potential for ground water impact due to presence of USTs on site.

10 TPS Laboratories Pvt Ltd No NA NA NA NA Tanker water Potential for ground water impact due to presence of USTs on site.


Yes 17 Monitoring Wells

No No 3 Abstraction wells Potential for ground water impact due to presence of SEPs and landfill on site.



Potential for ground water impact due to presence of partially underground collection pit on site.

Sl. No. Site Details Any GW Monitoring Well On-site

How Many What Kind of Analytical Monitoring

Remarks RatingAny ExceedancesAny Analytical Testing of GW for Raw Material and Products (including API)

Water Source Onsite

Sl. No. Site Details Any GW Monitoring Well On-site

How Many What Kind of Analytical Monitoring

Remarks RatingAny ExceedancesAny Analytical Testing of GW for Raw Material and Products (including API)

Water Source Onsite

13 Virupaksha Organics Limited No NA NA NA NA NA Potential for ground water impact due to presence of three partially underground collection pits onsite.

14 Mylan Labs Unit -1 No NA NA NA NA Tanker water (150 -16 Hetero No NA NA NA NA Tanker water (280

KL/day)Potential for ground water impact due to presence of partially underground collection pit on site.


No NA NA NA NA NA Potential for ground water impact due to presence of SEPs that are visible on historical images.

18 Benova Labs Pvt Ltd (1 acre) No NA NA NA NA Tanker water (1.2 KL/day)

-

19 Chemtech Acids and Chemicals No NA NA NA NA Tanker water -

20 Chemtech Fertilizers (2.7 acres) No NA NA NA NA Tanker water (300-400 L/day)

-

21 Kekule Pharma Limited (6 acres)

No NA NA NA NA Tanker water (70 L/day)

Potential for ground water impact due to presence of USTs on site and SEPs that are visible on historical images.


No NA NA NA NA Tanker Water -



-

25 Sri Ram Chlorochem (5 acres) No NA NA NA NA Tanker Water Potential for ground water impact due to presence of USTs on site.

26 Vantech Chemicals Limited No NA NA NA NA NA -27 Navodaya Packaging No NA NA NA NA NA -28 Yagmag No NA NA NA NA NA - Not Applicable

Summary of Ratings

Raw Material Wastewater Hazardous Waste Surface Water GroundwaterBalaji Galvanizing India LimitedDivis Pharmaceuticals Pvt LtdEmmenar Pharma Unit 1 Pvt Ltd Goldstone Infratech Limited NA NA NAKRS Pharmaceuticals Pvt LtdLee Pharma Ltd. Regent Paints Pvt LtdSelma Laboratories Private Limited NA NA NATIDC India Pvt Ltd TPS Laboratories Pvt LtdHyderabad Waste Management ProjectVirchow Chemicals Virupaksha Organics LimitedMylan Labs Unit -1 HeteroArch Pharma Labs Limited Benova Labs Pvt Ltd Chemtech Acids and Chemicals NA NAChemtech Fertilizers NA NAKekule Pharma Limited KRR Pharmaceuticals Pvt Ltd NA NA NA NASMS Pharmaceuticals Limited (Unit 1) Sri Ram ChlorochemVantech Chemicals Limited NA NANavodaya Packaging NA NAYagmag NA NA NA NA NA

HighMediumLow

Industry Name Risk Rating

Legend


ERM has over 160 offices Across the following countries worldwide Argentina Netherlands Australia Peru Belgium Poland Brazil Portugal China Puerto Rico France Singapore Germany Spain Hong Kong Sweden Hungary Taiwan India Thailand Indonesia UK Ireland USA Italy Venezuela Japan Vietnam Korea Malaysia Mexico ERM India Private Limited Building 10, 4th Floor Tower A, DLF Cyber City Gurgaon – 122 002, NCR , India Tel: 91 124 417 0300 Fax: 91 124 417 0301 Regional Office – West 801, 8th Floor, Windfall, Sahar Plaza, J B Nagar, Andheri (East), Mumbai – 400 059 Tel : 022 42107373 Fax: 91- 022- 4210 7474 Regional Office – West 702 Abhishree Avenue, Near Nehru Nagar Circle, Ambawadi Ahmedabad -380006 India Tel: +91 79 66214300 Fax: +91 79 66214301

Regional Office -South Ground Floor, Delta Block Sigma Soft Tech Park Whitefield, Main Road Bangalore- 560 066, India Tel: +91 80 49366 300 (Board) Regional Office –East 4th Floor, Asyst Park, GN-37/1, Sector-V, Salt Lake City, Kolkata 700 091 Tel : 033-40450300

HS.Rawat

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