Monitoring the implementation of Environmental Safeguards...

Monitoring the implementation of Environmental Safeguards

Ministry of Environment & Forests Western region, Regional Office, Bhopal

MONITORING REPORT PART-1

DATA SHEET

1. Project type :

River-

Valley/Mining/Industry/Thermal/Nuclear/Other

(Specify)

Industry

2. Name of the Project M/s. TAGROS CHEMICAL INDIA LTD.

3. Clearance letter(s) OM No. and date J-11011/20/2012-IA-II(I) dated 06/03/2014

Location: Plot No. 43/1, GIDC Dahej,

Ta. Vagra

(a) District (s) BHARUCH

(b) State (s) GUJARAT

4.

(c)Location Latitude/Longitude 21043’25.12” N Latitude & 72036’11.10” E Longitude

5. Address for correspondence M/s. TAGROS CHEMICAL INDIA LTD.

Plot No. 43/1, GIDC Dahej,

Ta. Vagra, Dist. Bharuch – 392 130, Gujarat

(a) Address of the correspondence Project Chief

Engineer (with pin Code & telephone/Telex/Fax

numbers)

Mr. Sunish K. Nair –Regional Head

(Chief Engineer)

M/s. TAGROS CHEMICAL INDIA LTD.


Ta. Vagra, Dist. Bharuch – 392 130, Gujarat

Mobile no. 9377687000

Tele:7043999575

(b) Address of the Executive Project

Engineer/Manager

Mr. Rahul Kumar

Manager

M/s. TAGROS CHEMICAL INDIA LTD.


Ta. Vagra, Dist. Bharuch – 392 130, Gujarat Mobile

no. 9426740399

6. Salient Features

(a) Of the Project The technology of this project is that Dicamba

molecule has been developed in house. Moreover,

the technology is much safer compare to

competitors. The High Pressure reactions process

has been such that it is always under controlled

parameters i.e. it’s not a runaway type reactions.

(b) Of the EMP

Water Environment

Water is segregated into High COD/TDS &

Low COD/TDS Streams

High COD/TDS Stream: Treatment ETP

(Primary),

MEE – Condensate is being treated in ETP as

low COD/TDS stream

Concentrated liquid from MEE is being

treated in VTFD. Finally dispose to common

TSDF

Low COD/TDS Stream : Treatment In

ETP(Primary, Secondary & Tertiary) then

Treatment in R.O.

R.O. permeate :After achieving prescribed

norms of SPCB discharge in GIDC Drain

R.O. Reject: is subjected to MEE

Operation of Recovery Plant: Sodium

Sulphate/ Potassium Chloride is recovered

from process waste

Operation & Maintenance & ETP

Operation & Maintenance & MEE & VTFD

Operation & Maintenance & RO

Water Environment Monitoring –

Monthly

By In-house Env. Laboratory

By Third Party

Air Environment

Provided Adequate Air Pollution Control

System for controlling…

Flue Gas Emission: Bag Filter & MCS attached

to Steam Boiler (No 1 & 2 ) & TFH (1 No)

Process Gas Emission:

Two stage Water scrubber for HCL & one

stage Alkali Scrubber for SO2 & CL2 for

controlling PGE.

Operation & Maintenance of APCM

Air Environment Monitoring - Quarterly

Ambient Air Quality Monitoring

Stack/ Process Vent Monitoring

Hazardous Waste Rule

There are Thirteen categories of Hazardous

Wastes.

We got Authorization from SPCB for

management of Hazardous Wastes

Disposal of MEE Salt, ETP Sludge to common

TSDF (M/s. BEIL, Dahej, M/s. SEPPL-

Bhachau, Kutch)

Disposal of Process Waste for co processing

(M/s. RSPL Panoli,)

Disposal of Process Residue to CHWIF (M/s.

SEPPL, GSPL-Palsana, Surat, )

Green Belt Development Continue…..

7. Breakup of the Project area Total Area: 71359 m2

Green Belt Area: 21,359 m2

(a) Submergence area : forest non-forest No forest non-forest area has been used.

Unit is located in Notified Industrial Area.

(b) Others Notified industrial estate

8. Breakup of the project affected population with

enumeration of those losing houses/dwelling units

only agricultural land only both dwelling units &

agricultural land & landless laborers/artisans:

Unit is located in notified industrial area.

GIDC has allotted us this plot.

We do not have such detail.

(a) SC, ST/Adivasi Data is not available

(b) Others -

(Please indicate whether these figures are based

on any scientific and systematic survey carried out

or only provisional figures, if a survey is carried

out give details & year of survey)

Data is not available

9. Financial Details

(a) Project cost as originally planned and

subsequent revised estimates and the year of

price reference

Originally Planned project cost Rs. 150 Crore

(Year:2011 )

Subsequent Revised project cost Rs. 175 (Year:

2012)

(b) Allocation made for EMP with item wise and

year wise break-up

Detail is attached as per Annexure-A

(c) BC ratio/IRR and the year of assessment 0.80

Assessment Financial Year: 2015-2016

(d) Whether © includes the cost of EM as shown in

the above

yes

(e) Actual expenditure incurred on the project so

far

Rs. 198 Crore

(f) Actual expenditure incurred on the EMP so far Total Rs.44.69 Cr

10. Forest land requirement Not applicable as unit is located in notified industrial

estate

(a) The status of approval for diversion of forest

land for non-forestry use Not applicable

(b) The status of clearing felling Not applicable

© The status of CA, if any Not applicable

(d) comments on the viability & sustainability of

CA program in the light of actual field experience

so far

Not applicable

11. The status of clear felling in non-forest areas (such

as submergence area or reservoir, approach

Rods.), if any with quantitative information

required.

Not applicable

12. Status of construction (Actual &/or Planned) Existing Unit

(a) Date of commencement (Actual &/or Planned) March-2013

(b) Date of completion (Actual &/or Planned) March-2014

13. Reason for delay if the project is yet to start. Not applicable

14. Dates of visit sites

a) Date on which the project was

monitored by the MoEF&CC, RO Bhopal

on previous occasion (if any)

b) Date of the site visit for present

monitoring report (if undertaken)

----

07th JULY,2017

15. Details of correspondence with project authorities for obtaining act on plans/information

on status of compliance to safeguards other than the routine letters for logistic support

for site visits. (the monitoring report may contain the details of all the letters issued so

far, but the latter reports may cover only the letter issued so far, but the later reports

may cover only the letter issued subsequently)

Date Letter From RO Date Letter from PA

07.07.2017 During the site visit, the PAs

have been directed to submit a revised

comprehensive compliance report with

documentary evidences.

30.08.2017: CR received vide letter dated

16.08.2017

18.09.2017: Updated CR received vide e-mail

dated 31.08.2017 and letter 31.08.2017

Annexure-A

Year wise Allocation made for EMP

Year Wise Capital Cost Recurring Cost

Water Environment

ETP/MEE/VTFD/RO: 18.0 Crore 2.0 crore

Air Environment

APCM 10.5 Crore 0.50 crore

Haz Waste Rule

Construction of Haz Waste Storage:

0.50 crore

1.0 crore

2014-15

Green Belt Development: 1.0 Crore 0.50 crore

Total = 30 Crore Total =4.0 crore



Water Environment


Air Environment


Haz Waste Rule


0.00 crore

1.20 crore

2015-16


Total = 0.30Crore Total =4.4 crore



Water Environment


Air Environment


Haz Waste Rule


0.12 crore

1.70 crore

2016-17


Total = 0.29 Crore Total = 5.7crore

PART-II & III

DESCRIPTIVE REPORT ON STATUS OF COMPLIANCE TO CONDITIONS OF ENVIONMENTAL CLEARANCE AND ENVIRONMENTAL MANAGEMENT

Compliance Status of Environmental Clearance issued by MoEFCC, New Delhi vide letter No.: J-11011/20/2012-IA.II(I) dated 06.03.2014

(Details of the project: Pesticide Manufacturing unit at Plot No.43/1, Dahej GIDC industrial estate, Taluka Vagra, District Bharuch, Gujarat of M/s. Tagros

Chemical India Ltd.)

A.Specific Condition

1. National Emission

Standards for

Pesticide

Manufacturing and

Formulation

Industry issued by

the Ministry vide

GS.R 46(E) dated

3rd February, 2006

and amended time

to time shall be

followed by the

unit.

The treated water effluents and emissions are complied as

per the standards, mentioned in the table below , and are

regularly monitored for quality of treated waste water and

gases emission by third party i.e. M/s. Vairagya Consultants (Recognized Schedule – II auditor by GPCB no. GPCB/EA-

294/404708/20 Feb 2017) as per National Emission

Standards for Organic Chemicals Manufacturing Industry

issued by the Ministry vide G.S.R. 46(E) dated 3rd February,

2006 and amended.

(Please find Annexure –F)(Attached in hard copy)

Gases emission:-

Month of January 2017 Sr.

No.

National

Emission

Standard

range in

ppm

Result Method

1 HCL 20 0.55 IS 265 : 1993

2 CL2 5 0.36 IS 5182(Part 21) : 1982

3 H2S 5 BDL IS 5182(Part 7) : 1973

4 P2O5 ( H3PO4 ) 10 N/A

5 NH3 30 0.38 IS 265 : 1993

6 CH3Cl 20 N/A

7 HBr 5 N/A

Month of february 2017 Sr.

No.

National

Emission

Standard

range in

ppm

Result Method

1 HCL 20 0.58 IS 265 : 1993

2 CL2 5 0.34 IS 5182(Part 21): 1982

3 H2S 5 BDL IS 5182(Part 7) : 1973

4 P2O5 ( H3PO4 ) 10 N/A

5 NH3 30 0.37 IS 265 : 1993

6 CH3Cl 20 N/A

7 HBr 5 N/A

Month of March 2017 Sr.

No.

National

Emission

Standard

range in

ppm

Result Method

1 HCL 20 0.60 IS 265 : 1993

2 CL2 5 0.40 IS 5182(Part 21): 1982

3 H2S 5 BDL IS 5182(Part 7) : 1973

4 P2O5 ( H3PO4 ) 10 N/A

5 NH3 30 0.38 IS 265 : 1993

6 CH3Cl 20 N/A

7 HBr 5 N/A

Month of April 2017 Sr.

No.

National

Emission

Standard

range in

ppm

Result Method

1 HCL 20 0.58 IS 265 : 1993

2 CL2 5 0.40 IS 5182(Part 21): 1982

3 H2S 5 BDL IS 5182(Part 7) : 1973

4 P2O5 ( H3PO4 ) 10 N/A

5 NH3 30 0.33 IS 265 : 1993

6 CH3Cl 20 N/A

7 HBr 5 N/A

Month of May 2017 Sr.

No.

National

Emission

Standard

range in

ppm

Result Method

1 HCL 20 0.59 IS 265 : 1993

2 CL2 5 0.39 IS 5182(Part 21) : 1982

3 H2S 5 BDL IS 5182(Part 7) : 1973

4 P2O5 ( H3PO4 ) 10 N/A

5 NH3 30 0.31 IS 265 : 1993

6 CH3Cl 20 N/A

7 HBr 5 N/A

Month of June 2017 Sr.

No.

National

Emission

Standard

range in

ppm

Result Method

1 HCL 20 0.60 IS 265 : 1993

2 CL2 5 0.42 IS 5182(Part 21): 1982

3 H2S 5 BDL IS 5182(Part 7) : 1973

4 P2O5 ( H3PO4 ) 10 N/A

5 NH3 30 0..34 IS 265 : 1993

6 CH3Cl 20 N/A

7 HBr 5 N/A

Month of July 2017 Sr.

No.

National

Emission

Standard

range in ppm

Result Method

1 HCL 20 0.61 IS 265 : 1993

2 CL2 5 0.44 IS 5182(Part 21) : 1982

3 H2S 5 BDL IS 5182(Part 7) : 1973

4 P2O5 ( H3PO4 ) 10 N/A

5 NH3 30 0..32 IS 265 : 1993

6 CH3Cl 20 N/A

7 HBr 5 N/A

It is product specific and currently the product

is not in operation for HBr.

(Please find Annexure –G)(Attached in hard copy)

Treated waste water:-

Sampling Date- 06/07/17

Sr.

No

Parameter Result GPCB

Norms

Unit

1 Ph 6.2 6.5-8.5 -

2 Temperature 32 - .C

3 Colour Colorless - -

4 Suspended solids 96 100 Mg/L

5 Oil & grease BDL 10 Mg/L

6 Fluoride BDL 15 Mg/L

7 Sulphide BDL 2 Mg/L

8 Ammonical nitrogen 2.8 50

9 Nitrate Nitrogen BDL 10 Mg/L

10 Total Kjeldhal Nitrogen 11.2 100 Mg/L

11 Free ammonia BDL 5 Mg/L

12 Copper BDL 3 Mg/L

13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L

16 Total Residue Chlorine BDL 1 Mg/L

17 Arsenic BDL 0.3 Mg/L

18 Hexavalent Chromium BDL 0.1 Mg/L

19 Total chromium BDL 1 Mg/L

20 Mercury BDL 0.01 Mg/L

21 Lead BDL 0.1 Mg/L

22 Cadmium BDL 2 Mg/L

23 Nickel BDL 2 Mg/L

24 Phenolic compound 3.1 5 Mg/L

25 Selenium BDL 0.05 Mg/L

26 Manganese BDL 2 Mg/L

27 Cyanide Absent 0.1 Mg/L

28 Iron BDL 3 Mg/L

29 Vanadium BDL 0.2 Mg/L

Sampling Date- 09/06/17 Sr.

No


Norms

Unit

1 Ph 5.6 6.5-8.5 -












13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L













28 Iron BDL 3 Mg/L



No


Norms

Unit

1 Ph 7.2 6.5-8.5 -









10 Total Kjeldhal Nitrogen 5 100 Mg/L



13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L









24 Phenolic compound 1 5 Mg/L




28 Iron BDL 3 Mg/L



No


Norms

Unit

1 Ph 7.2 6.5-8.5 -







8 Ammonical nitrogen 22 50





13 Zinc BDL 15 Mg/L

14 BOD 15 100 Mg/L

15 COD 48 250 Mg/L













28 Iron BDL 3 Mg/L


Sampling Date- 25/03/17 Sr. No

Parameter Result GPCB Norms

Unit

1 Ph 7.35 6.5-8.5 -












13 Zinc BDL 15 Mg/L

14 BOD 12 100 Mg/L

15 COD 45 250 Mg/L













28 Iron BDL 3 Mg/L




Unit

1 Ph 6.52 6.5-8.5 -












13 Zinc BDL 15 Mg/L

14 BOD 12 100 Mg/L

15 COD 47 250 Mg/L













28 Iron BDL 3 Mg/L


As per the information furnished by the PP and

the fact that the monitoring was not carried out

by NABL/EPA approved laboratory, the

monitoring data generated is considered

authentic subject to acceptance by MoEF&CC,

New Delhi. PP may also compare the analysis

result with the national emission standards for

pesticide industries notified by MoEFCC vide

G.S.R.446 E dated 13th June, 2011. Needful

upgradation of system may be undertaken to

comply with the said norms. Further, it is noted

that the concentrations of phenolic compounds is

exceeding the stipulated national standards (1

mg/l) for treated effluent and as such, necessary

measures should be taken up to comply the

stipulated norms. In view of the above, the

stipulated condition is considered partly

complied.

PARTLY COMPLIED

We are continuously monitoring through GPCB approved (M/s. Vairagya Consultants (Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb 2017).) We will change the Consultants /monitoring agency and will do next monitoring through NABL/EPA approved laboratory/ Consultants. Compliance report will be submitted to your good office.

2. Multi cyclone

followed by bag

filter along with

adequate stack

height shall be

provided to coal

fired boiler to

control particulate

emissions.

We have provided adequate capacity of multi cyclone

separator followed by bag filter to coal waste fired boiler to

control particulate matter as specified by the state board. We

have regular monitoring by third party i.e. M/s. Vairagya

Consultants (Recognized Schedule – II auditor by

GPCB no. GPCB/EA-294/404708/20 Feb 2017).

(Please find Annexure –H)(Attached in hard copy)

Sampling

Date

Stack

attached

to

Height

M

Temp

.C

Param

eter Result

GPCB

Norms

mg/Nm

3

PM 12 150

SOx 9.7 40 14-04-17 Boiler 30 73

NOx 3.3 25

Sampling

Date

Stack

attached

to

Heigh

t M

Temp

.C

Param

eter Result

GPCB

Norms

mg/Nm

3

PM 14 150

SOx 9.3 40 06-07-17 Boiler 30 73

NOx 3.1 25



by NABL/EPA approved laboratory, the

monitoring data generated is considered

authentic subject to acceptance by MoEF&CC,

New Delhi.

COMPLIED SUBJECT TO ACCEPTANCE OF

MONITORED DATA BY MOEF&CC,NEW DELHI


3. Two stage water

scrubber followed

by alkali scrubber

shall be provided to

process vent to

control S02, HCI,

We have provided Two stage Water scrubber for HCL & one

stage Alkali Scrubber for SO2 & CL2 for controlling process

emission.

HBr and Cl2

emissions.

The scrubbed water

shall be sent to ETP

for further

treatment.

Efficiency of

scrubber shall be

monitored regularly

and maintained

properly. Scrubbers

vent shall be

provided with

online detection

and alarm system

to indicate higher

than permissible

value of controlled

parameters. At no

time, the emission

levels shall go

beyond the

prescribed

standards.

The system shall be

interlocked with the

pollution control

equipments so that

in case of any

increase in

pollutants beyond

permissible limits,

plant shall be

automatically

stopped.

Stack monitoring

shall be done

regularly and report

shall be submitted

to Gujarat Pollution

Control Board

(GPCB) and the

The Scrubbed aqueous is dispatched to ETP for treatment.

The scrubbers are monitored on regularly for pH, in case of

abnormality found then drain it and sent to ETP for

treatment. Also we have regular monitoring by third party

i.e. M/s. Vairagya Consultants (Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb

2017). Are maintain emission standard as per PCB norms.(Result file is attached Please find ) (Please find Annexure –I)(Attached in hard copy)

Stack- process gas emission Result

Samplin

g Date

Stack

attache

d to

Paramete

r

Result

GPCB

Norms

mg/Nm3

HCl 13 20

Sox 11.5 40 06-07-

17

Scrubbe

r

Plant-2 Cl2 2.3 5

Samplin

g Date

Stack

attache

d to

Parameter

Result

GPCB

Norms

mg/Nm3

HCl 13 20

Sox 11 40 06-07-

17

Scrubbe

r

Plant-3 Cl2 2.1 5

Samplin

g Date

Stack

attache

d to

Parameter

Result

GPCB Norms

mg/Nm3

HCl 14.2 20

Sox 13 40 14-04-

17

Scrubbe

r

Plant-3 Cl2 2.5 5

We have provided interlock system for chlorine shed along

with instrumentation in case of any increase in pollutants

beyond permissible limits, plant, and the evaporation will get

cutoff automatically stopping chlorine supply to the process

plant. However we will improve instrumentation further if

required.

Stacks are regularly monitored for emissions by third Party

Schedule-II auditor i.e. M/s. Vairagya Consultants (Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb 2017) on quarterly

basis Currently we do not use bromine as a raw material so HBr is not emitted from process. (Result file is attached)

Ministry's regional

office at Bhopal.

(Please find Annexure –I)(Attached in hard copy)

Stack- process gas emission Result

Samplin

g Date

Stack

attache

d to

Paramet

er

Result

GPCB Norms

mg/Nm3

HCl 13 20

Sox 11.5 40 06-07-

17

Scrubb

er

Plant-2 Cl2 2.3 5

Samplin

g Date

Stack

attache

d to

Paramet

er

Result

GPCB Norms

mg/Nm3

HCl 13 20

Sox 11 40 06-07-

17

Scrubb

er

Plant-3 Cl2 2.1 5

Samplin

g Date

Stack

attache

d to

Paramet

er

Result

GPCB Norms

mg/Nm3

HCl 14.2 20

Sox 13 40 14-04-

17

Scrubb

er

Plant-3 Cl2 2.5 5

As per the information furnished by the PP and the fact that the monitoring was not carried out by NABL/EPA approved laboratory, the monitoring data generated is

considered authentic subject to acceptance by MoEF&CC, New Delhi. PP may also compare the analysis result with the national emission standards for pesticide industries notified by MoEFCC vide G.S.R.446 E dated 13th June, 2011. Needful upgradation of system may be undertaken to comply with the said norms.

COMPLIED SUBJECT TO ACCEPTANCE OF MONITORED DATA BY MOEF&CC,NEW DELHI


4. In order to control

odor, outlet of

process vents shall

be connected to the

incinerator.

VOC are monitored regularly checked for levels, Process vent

connect to incinerator which is product specific and currently

the product is not in operation.

In view of the submission by the PP, The

condition is considered complied.

COMPLIED

5. The National

Ambient Air Quality

Emission Standards

issued by the

Ministry vide

G.S.R.No.826 (E)

dated l6th

November, 2009

shall be followed by

the unit.

National Emission Standards are being followed and

accordingly regular monitoring of ambient air , Incinerator &

effluent is being done as per G.S.R No. 826 E, through third

Party analysis i.e. M/s. Vairagya Consultants (Recognized Schedule – II auditor by GPCB no.

GPCB/EA-294/404708/20 Feb 2017)


(MIN. MAX. tabulated based on the data monitoring generation over a period from JAN-2017 to JULY-2017)

Avg. calculated based on the total reading of 7 months)

Location Parameter Result GPCB Norms

MIN Max Avg. Mg/Nm3

PM10 67 74 71.14 100

PM2.5 33 39 35.57 60

Oxide OF Sulphur

7.8 11.8 10.4 80

Oxide OF Nitrogen

1.5 6.8 5.3 80

HCL 1.2 1.5 1.37 200

Cl2 0.58 0.61 0.60 100

Ammonia 0.52 0.58 0.54 400

H2S BDL BDL BDL 500

HC 1.2 1.5 1.4 160

HF BDL BDL BDL 60

CS2 BDL BDL BDL 2000

ETP

CO 1.1 1.3 1.16 5000


MIN Max Avg. Mg/Nm3

PM10 52 66 57.43 100

PM2.5 33.5 37 35.26 60

Oxide OF Sulphur

8.3 14 11.54 80

Oxide OF Nitrogen

0.89 7.9 5.6 80

HCL 0.55 0.61 0.59 200

Cl2 0.34 0.44 0.39 100

Ammonia 0.31 0.38 0.35 400

H2S BDL BDL BDL 500

HC 1.2 1.7 1.41 160

HF BDL BDL BDL 60


Main Gate

CO 0.74 0.78 0.76 5000

Sampling

Date


Mg/Nm3

PM10 67 100

PM2.5 33 60

Oxide OF Sulphur 7.8 80

Oxide OF Nitrogen 1.8 80

HCL 1.5 200

Cl2 0.61 100

Ammonia 0.54 400

H2S BDL 500

HC 1.3 160

HF BDL 60

CS2 BDL 2000

11/01/2017

ETP

CO 1.2 5000

Sampling

Date


Mg/Nm3

PM10 69 100

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

13/02/2017

ETP

CO 1.1 5000

Sampling

Date


Mg/Nm3

PM10 71 100

PM2.5 34 60


Oxide OF Nitrogen 7 80

HCL 1.4 200

Cl2 0.59 100

Ammonia 0.53 400

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

25/03/2017

ETP

CO 1.2 5000

Sampling

Date


Mg/Nm3

PM10 73 100

PM2.5 36 60



HCL 1.5 200

Cl2 0.6 100

Ammonia 0.57 400

H2S BDL 500

HC 1.4 160

HF BDL 60

CS2 BDL 2000

13/04/2017

ETP

CO 1.3 5000

Sampling

Date


Mg/Nm3

PM10 72 100

PM2.5 38 60



HCL 1.4 200

Cl2 0.58 100

Ammonia 0.52 400

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

12/05/2017

ETP

CO 1.1 5000

Sampling

Date


Mg/Nm3

PM10 74 100

HCL 1.3 200

Cl2 0.59 100

Ammonia 0.55 400

H2S BDL 500

HC 1.4 160

HF BDL 60

CS2 BDL 2000

09/06/2017

ETP

CO 1.2 5000

Sampling

Date


Mg/Nm3

PM10 72 100

PM2.5 33 60



HCL 1.2 200

Cl2 0.6 100

Ammonia 0.58 400

H2S BDL 500

HC 1.2 160

HF BDL 60

CS2 BDL 2000

06/07/2

017

ETP

CO 1.1 5000

Sampling

Date


Mg/Nm3

PM10 52 100

PM2.5 33.5 60



HCL 0.55 200

Cl2 0.36 100

Ammonia 0.38 400

H2S BDL 500

HC 1.6 160

HF BDL 60

CS2 BDL 2000

11/01/2017

Main Gate

CO 0.76 5000

Sampling

Date


Mg/Nm3

PM10 53 100

PM2.5 35.3 60



HCL 0.58 200

Cl2 0.34 100

Ammonia 0.37 400

H2S BDL 500

HC 1.3 160

HF BDL 60

CS2 BDL 2000

13/02/2017

Main Gate

CO 0.74 5000

Sampling

Date


Mg/Nm3

PM10 54 100

PM2.5 35 60

Oxide OF Sulphur 11 80


HCL 0.6 200

Cl2 0.4 100

Ammonia 0.38 400

H2S BDL 500

HC 1.2 160

HF BDL 60

CS2 BDL 2000

25/03/2017

Main Gate

CO 0.75 5000

Sampling

Date


Mg/Nm3

PM10 56 100

PM2.5 37 60

Oxide OF Sulphur

13 80

Oxide OF Nitrogen

7.4 80

HCL 0.58 200

Cl2 0.4 100

Ammonia 0.33 400

H2S BDL 500

HC 1.7 160

HF BDL 60

CS2 BDL 2000

13/04/2017

Main Gate

CO 0.77 5000

Sampling

Date


Mg/Nm3

PM10 58 100

PM2.5 35 60

Oxide OF Sulphur

14 80

Oxide OF Nitrogen

7.8 80

HCL 0.59 200

Cl2 0.39 100

Ammonia 0.31 400

H2S BDL 500

HC 1.6 160

HF BDL 60

CS2 BDL 2000

12/05/2017

Main Gate

CO 0.78 5000

Sampling

Date


Mg/Nm3

PM10 63 100

PM2.5 37 60

Oxide OF Sulphur

13.4 80

Oxide OF Nitrogen

7.9 80

HCL 0.6 200

Cl2 0.42 100

Ammonia 0.34 400

H2S BDL 500

09/06/2017

Main Gate

HC 1.3 160

HF BDL 60

CS2 BDL 2000

CO 0.76 5000

Sampling Date

Location Parameter Result GPCB Norms Mg/Nm3

PM10 66 100

PM2.5 34 60

Oxide OF Sulphur

12.5 80

Oxide OF Nitrogen

7.3 80

HCL 0.61 200

Cl2 0.44 100

Ammonia 0.32 400

H2S BDL 500

HC 1.2 160

HF BDL 60

CS2 BDL 2000

06/07/2017

Main Gate

CO 0.77 5000

As per the information furnished by the PP and the fact

that the monitoring was not carried out by NABL/EPA approved laboratory, the condition is considered complied subject to acceptance of monitored data by MoEF&CC, New Delhi. PP shall ensure monitoring of all the parameters prescribed under the said notification of MoEF&CC.



6. In plant control

measures for

checking fugitive

emissions from all

the vulnerable

sources shall be

provided.

Fugitive emissions

shall be controlled

by providing closed

storage, closed

handling &

conveyance of

chemicals/material

s, multi cyclone

separator and

water sprinkling

system.

Dust suppression

system including

water sprinkling

system shall be

provided at loading

and unloading

areas to control

dust emissions.

Fugitive emissions

We have provided closed storage tank for liquid raw

materials and vents provided with condenser system.

From storage tank to reactor raw materials are transfer

through closed pipe line only. For solid raw materials we

have provided closed charging system. We have provided

Water sprinkling arrangement on the coal storage yard.

Water sprinkling arrangement systems has been provided at

loading and unloading areas to control dust emissions.

The work zone environment and product raw material

in the work zone

environment,

product, raw

materials storage

area etc. shall be

regularly monitored

and records

maintained. The

emissions shall

conform to the

limits stipulated by

the GPCB.

storage area and Godown area fugitive emission of

environment regularly monitor by Air monitoring system by

a Schedule –II auditor i.e. M/s. Vairagya Consultants

(Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb 2017) on monthly basis. (Result file is attached)

Work area monitoring Report are attached :

(Please find Annexure –J)(Attached in hard copy)

JANUARY’17

Result Sr.

No.

Parameter Unit Plant-2 Plant-3

1 Xylene ppm 0.001 0.0011

2 Ethylene dichloride ppm 0.0005 0.001

3 Methanol ppm 0.09 0.001

4 Dimethyl formaide ppm 0.009 0.009

5 IPA ppm 0.005 0.002

6 Toluene ppm 0.002 0.001

7 PM 10 ug/m3 1.8 1.2

8 PM 2.5 ug/m3 0.91 0.1

9 Sox ppm 1.1 0.7

10 NOx ppm 0.3 0.21

11 HCl ppm 0.1 BDL

12 Cl2 ppm 0.02 BDL

13 NH3 ppm 0.15 0.01

14 H2s ppm BDL BDL

FEBRUARY’17

Result Sr

No Parameter Unit

Plant-2 Plant-3

1 Xylene ppm 0.0008 0.0001



4 Dimethylformaide ppm 0.007 0.008

5 IPA ppm 0.001 0.002

6 Toluene ppm 0.001 0.0009

7 PM 10 ug/m3 1.0 1.1

8 PM 2.5 ug/m3 0.8 0.35

9 Sox ppm 0.98 0.8

10 NOx ppm 0.21 0.1

11 HCl ppm 0.15 0.12

12 Cl2 ppm 0.01 0.03

13 NH3 ppm 0.11 0.11

14 H2s ppm 0.009 0.001

MARCH’17

Result Sr No


1 Xylene ppm 0.002 0.0021




5 IPA ppm 0.03 0.002


7 PM 10 ug/m3 1.8 1.4

8 PM 2.5 ug/m3 0.7 0.92

9 Sox ppm 1.1 0.98

10 NOx ppm 0.3 0.41

11 HCl ppm 0.1 0.09

12 Cl2 ppm 0.08 0.089

13 NH3 ppm 0.22 0.13

14 H2s ppm 0.001 0.001

APRIL’17

Result Sr No


1 Xylene ppm 0.001 0.001




5 IPA ppm 0.003 0.002


7 PM 10 ug/m3 2.2 1.9

8 PM 2.5 ug/m3 0.6 0.7

9 Sox ppm 0.38 0.99

10 NOx ppm 0.42 0.5

11 HCl ppm 0.19 0.02

12 Cl2 ppm 0.25 0.04

13 NH3 ppm 0.12 0.19

14 H2s ppm 0.002 0.001

MAY’17

Result Sr No


1 Xylene ppm 0.002 0.004




5 IPA ppm 0.001 0.001


7 PM 10 ug/m3 0.9 1.0

8 PM 2.5 ug/m3 0.75 0.43

9 Sox ppm 1.2 0.9

10 NOx ppm 0.33 0.45

11 HCl ppm 0.2 0.19

12 Cl2 ppm 0.02 0.01

13 NH3 ppm 0.03 0.2

14 H2s ppm 0.001 0.001

JUNE’17

Result Sr No


1 Xylene ppm 0.002 0.001




5 IPA ppm 0.003 0.001


7 PM 10 ug/m3 1.1 1.7

8 PM 2.5 ug/m3 0.7 0.3

9 Sox ppm 0.45 0.8

10 NOx ppm 0.61 0.4

11 HCl ppm 0.29 0.12

12 Cl2 ppm 0.15 0.01

13 NH3 ppm 0.2 0.11

14 H2s ppm 0.001 0.001

JULY’17

Result Sr No


1 Xylene ppm 0.001 0.003




5 IPA ppm 0.002 0.001


7 PM 10 ug/m3 1.2 1.3

8 PM 2.5 ug/m3 0.8 0.7

9 Sox ppm 0.61 0.5

10 NOx ppm 0.7 0.43

11 HCl ppm 0.35 0.2

12 Cl2 ppm 0.1 0.02

13 NH3 ppm 0.2 0.2

14 H2s ppm 0.002 0.003

As per the information furnished by the PP and the fact that the monitoring was not carried out by NABL/EPA approved laboratory, the condition is considered complied subject to acceptance of monitored data by MoEF&CC, New Delhi.



7. For further control

of fugitive

emissions,

following steps

shall be followed :

Closed handling

system shall be

provided for

Chemicals.

Reflux condenser

shall be provided

over reactor.

System of leak

detection and

repair of


materials and venting provided with condenser system. From

storage tank to reactor raw materials are transfer through

closed pipe line only.

We have provided primary and secondary reflux condenser

over reactor, where ever solvent recovery and solvent

process based process are carried out.

We carry out regular monitoring leak detection for

pump/pipeline accordingly preventive maintenance is

carrying out. Last six months data of preventive maintenance is attached.

(Please find Annexure –N)(Attached in hard copy)

pump/pipeline

based on

preventive

maintenance.

The acids shall be

taken from storage

tanks to reactors

through closed

pipeline.

Storage tanks shall

be vented through

trap receiver and

condenser operated

on chilled water.

Cathode protection


the underground

solvent storage

tanks.

The Acids and Alkali Raw material used in process are

transferred from Storage tanks through pipelines of suitable

MOC.

We have provided trap receiver and condenser with operating

chilled water on storage tank.

We have already provided earthling pit for Cathode

protection. This is monitored on a regular basis for Earthling

continuity internally by our electrical department.

In view of the information furnished by the PP,

The said stipulation is considered complied.

COMPLIED

8. A proper Leak

Detection And

Repair (LDAR)

Program for

pesticide industry

shall be prepared

and implemented

as per CPCB

guidelines.

Focus shall be

given for

prevention of

fugitive emissions

for which

preventive

maintenance of pumps, valves,

pipelines are

required.

Proper

maintenance of

mechanical seals of

pumps and valves

shall be given.

A preventive

maintenance

schedule for each

unit shall be

prepared and

adhered to.

We carry out regular monitoring leak detection through

online leak detection system on weekly bases.

We carry out regular monitoring and prevention of fugitive

emissions for pump/pipeline accordingly preventive

maintenance is carry out. Last six months data of preventive maintenance is attached. (Please find Annexure –N)(Attached in hard copy)

Last six months data of preventive maintenance is attached.

Last six months data of preventive maintenance is attached.



COMPLIED

9. Continuous

monitoring system

for VOCs and

chlorine shall be

installed at all

important

places/areas.

Effective measures

We regularly monitor level of VOC by third party, i.e. M/s. Vairagya Consultants (Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb

2017) analysis result is attached. Chlorine is continuously

monitored and we have provided interlock system for chlorine

shed along with atomization in case of any increase in

pollutants beyond permissible limits, plant shall be

automatically stopped. Necessary action has to take, while

shall be taken

immediately, when

monitoring results

indicate above the

permissible limits.

monitoring results indicate above the permissible limits.

(Please find Annexure –K)(Attached in hard copy)

Date:- 10/01/17

Sample Location

Parameter

Unit

Result

GPCB Norms

VOC as total 4.1 ETP

VOC as Methanol

µg/m3

1.0

-

VOC as total 4.6 Tank Form

VOC as Methanol µg/m3

1.2

-

VOC as total 6.8 Plant 2 (Ground Floor)


1.1

-

VOC as total 7.1 Plant 2 (first Floor)

VOC as Methanol

µg/m3

1.3

VOC as total 7.2 Plant 2 (Second Floor)

VOC as Methanol

µg/m3

1.2


VOC as Methanol

µg/m3

1.1

VOC as total 7.1

Plant 2 (first Floor)

VOC as Methanol

µg/m3

1.2


VOC as Methanol

µg/m3

1.4

Date:- 16/02/17

Sample Location

Parameter

Unit

Result

GPCB Norms


VOC as Methanol

µg/m3

1.2

-



1.5

-



1.3

-


VOC as Methanol

µg/m3

1.5


VOC as Methanol

µg/m3

1.4


VOC as Methanol

µg/m3

1.3

VOC as total 7.0


VOC as Methanol

µg/m3

1.3


VOC as Methanol

µg/m3

1.4

Date:- 25/03/17

Sample Location

Parameter

Unit

Result

GPCB Norms


VOC as Methanol

µg/m3

1.4

-



1.6

-


VOC as Methanol µg/m3 1.2

-


VOC as Methanol

µg/m3

1.5

VOC as total 7.6 Plant 2 (Second

Floor) VOC as Methanol

µg/m3

1.6


VOC as Methanol

µg/m3

1.2

VOC as total 7.3


VOC as Methanol

µg/m3

1.3


VOC as Methanol

µg/m3

1.3

Date:- 13/04/17

Sample Location

Parameter

Unit

Result

GPCB Norms


VOC as Methanol

µg/m3

2.1

-



1.3

-



1.3

-


VOC as Methanol

µg/m3

1.6


VOC as Methanol

µg/m3

1.5


VOC as Methanol

µg/m3

1.5

VOC as total 7.5


VOC as Methanol

µg/m3

1.4


VOC as Methanol

µg/m3

1.4

Date:- 12/05/17

Sample Location

Parameter

Unit

Result

GPCB Norms


VOC as Methanol

µg/m3

1.9

-



1.4

-



-


VOC as Methanol

µg/m3

1.4


VOC as Methanol

µg/m3

1.5


VOC as Methanol

µg/m3

1.4

All necessary steps

shall be taken for

monitoring of HCI

and HBr in the

proposed plant.

VOC as total 7.6


VOC as Methanol

µg/m3

1.2

VOC as total 7.5 Plant 3 (Ground

Floor) VOC as Methanol

µg/m3

1.5

Date:- 09/06/17

Sample Location

Parameter

Unit

Result

GPCB Norms


VOC as Methanol

µg/m3

2

-



1.2

-



-


VOC as Methanol

µg/m3

1.2


VOC as Methanol

µg/m3

1.7


VOC as Methanol

µg/m3

1.3

VOC as total 7.4


VOC as Methanol

µg/m3

1.1

VOC as total 7.5 Plant 3

(Ground Floor)

VOC as Methanol

µg/m3 1.4

Date:- 06/07/17

Sample Location

Parameter

Unit

Result

GPCB Norms


VOC as Methanol

µg/m3

2.3

-



1.5

-



-


VOC as Methanol

µg/m3

1.7


VOC as Methanol

µg/m3

1.9


VOC as Methanol

µg/m3

1.7

VOC as total 7.9


VOC as Methanol

µg/m3

1.7


VOC as Methanol

µg/m3

1.7

We have regularly monitor level of HCL from the stacks

through third Party analysis i.e. M/s. Vairagya Consultants (Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb 2017) on quarterly basis

Currently we do not use bromine as a raw material so HBr is

not emitted from process.


(MIN. MAX. tabulated based on the data monitoring

generation over a period from JAN-2017 to JULY-2017)



MIN Max Avg. Mg/Nm3

PM10 67 74 71.14 100

PM2.5 33 39 35.57 60

Oxide OF Sulphur 7.8 11.8 10.4 80

Oxide OF Nitrogen 1.5 6.8 5.3 80

HCL 1.2 1.5 1.37 200

Cl2 0.58 0.61 0.60 100

Ammonia 0.52 0.58 0.54 400

H2S BDL BDL BDL 500

HC 1.2 1.5 1.4 160

HF BDL BDL BDL 60


ETP

CO 1.1 1.3 1.16 5000


MIN Max Avg. Mg/Nm3 PM10 52 66 57.43 100 PM2.5 33.5 37 35.26 60

Oxide OF Sulphur 8.3 14 11.54 80 Oxide OF Nitrogen 0.89 7.9 5.6 80

HCL 0.55 0.61 0.59 200 Cl2 0.34 0.44 0.39 100

Ammonia 0.31 0.38 0.35 400 H2S BDL BDL BDL 500

HC 1.2 1.7 1.41 160 HF BDL BDL BDL 60 CS2 BDL BDL BDL 2000

Main Gate

CO 0.74 0.78 0.76 5000

Sampling Date


PM10 67 100

PM2.5 33 60



HCL 1.5 200

Cl2 0.61 100

Ammonia 0.54 400

H2S BDL 500

HC 1.3 160

HF BDL 60

CS2 BDL 2000

11/01/2017

ETP

CO 1.2 5000

Sampling

Date


Mg/Nm3

PM10 69 100


HCL 1.3 200

Cl2 0.6 100

Ammonia 0.52 400

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

13/02/2017

ETP

CO 1.1 5000

Sampling

Date


Mg/Nm3

PM10 71 100

PM2.5 34 60



HCL 1.4 200

Cl2 0.59 100

Ammonia 0.53 400

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

25/03/2017

ETP

CO 1.2 5000

Sampling

Date


Mg/Nm3

PM10 73 100

PM2.5 36 60



HCL 1.5 200

Cl2 0.6 100

Ammonia 0.57 400

H2S BDL 500

HC 1.4 160

HF BDL 60

CS2 BDL 2000

13/04/2017

ETP

CO 1.3 5000

Sampling

Date


Mg/Nm3

PM10 72 100

PM2.5 38 60



HCL 1.4 200

Cl2 0.58 100

Ammonia 0.52 400

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

12/05/2017

ETP

CO 1.1 5000

Sampling

Date


Mg/Nm3

PM10 74 100

PM2.5 39 60



HCL 1.3 200

Cl2 0.59 100

Ammonia 0.55 400

H2S BDL 500

HC 1.4 160

HF BDL 60

CS2 BDL 2000

09/06/2017

ETP

CO 1.2 5000

Sampling

Date


Mg/Nm3

PM10 72 100

PM2.5 33 60



HCL 1.2 200

Cl2 0.6 100

Ammonia 0.58 400

H2S BDL 500

HC 1.2 160

HF BDL 60

CS2 BDL 2000

06/07/2017

ETP

CO 1.1 5000

Sampling Date


PM10 52 100

PM2.5 33.5 60



HCL 0.55 200

Cl2 0.36 100

Ammonia 0.38 400 H2S BDL 500

HC 1.6 160

HF BDL 60

CS2 BDL 2000

11/01/2017

Main Gate

CO 0.76 5000

Sampling

Date


Mg/Nm3

PM10 53 100

PM2.5 35.3 60



HCL 0.58 200

Cl2 0.34 100

Ammonia 0.37 400

H2S BDL 500

HC 1.3 160

HF BDL 60

CS2 BDL 2000

13/02/2017

Main Gate

CO 0.74 5000

Sampling

Date


Mg/Nm3

PM10 54 100

PM2.5 35 60



HCL 0.6 200

Cl2 0.4 100

Ammonia 0.38 400

H2S BDL 500

HC 1.2 160

HF BDL 60

CS2 BDL 2000

25/03/2017

Main Gate

CO 0.75 5000

Sampling

Date


Mg/Nm3

PM10 56 100

PM2.5 37 60



HCL 0.58 200

Cl2 0.4 100

Ammonia 0.33 400

H2S BDL 500

HC 1.7 160

HF BDL 60

CS2 BDL 2000

13/04/2017

Main Gate

CO 0.77 5000

Sampling

Date


Mg/Nm3

PM10 58 100 PM2.5 35 60

Oxide OF Sulphur 14 80 Oxide OF Nitrogen 7.8 80

HCL 0.59 200 Cl2 0.39 100

Ammonia 0.31 400 H2S BDL 500

HC 1.6 160 HF BDL 60 CS2 BDL 2000

12/05/2017

Main Gate

CO 0.78 5000

Sampling

Date


Mg/Nm3

PM10 63 100

PM2.5 37 60



HCL 0.6 200

Cl2 0.42 100

Ammonia 0.34 400

H2S BDL 500

HC 1.3 160

09/06/2017

Main Gate

HF BDL 60

CS2 BDL 2000

CO 0.76 5000

Sampling

Date


Mg/Nm3

PM10 66 100

PM2.5 34 60



HCL 0.61 200

Cl2 0.44 100

Ammonia 0.32 400

H2S BDL 500

HC 1.2 160

HF BDL 60

CS2 BDL 2000

06/07/2017

Main Gate

CO 0.77 5000

As per the information furnished by the PP and the fact that the monitoring was not carried out by NABL/EPA approved laboratory, the condition is considered complied subject to acceptance of monitored data by MoEF&CC, New Delhi.



10. Alarm for chlorine

leakage if any in

the liquid chlorine

storage area shall

be provided along

with automatic

start of the

scrubbing system.

We have provided interlock system for chlorine shed along

with atomization in case of any increase in pollutants beyond

permissible limits; plant shall be automatically start

scrubbing system. However we will implement further action

if required.



COMPLIED

11. The gaseous

emissions from DG

set shall be

dispersed through

adequate stack

height as per CPCB

standards.

Acoustic enclosure


the DG sets to

mitigate the noise

pollution.

We have provided height of chimney to the D G set for

dispersion flue gas emission,

Which is as per formula given by the CPCB.

The offers have been called in for rectification of the existing

DG set with Acoustic enclosures, and will be provided in due

cross after procuring the same.


The said stipulation is considered complied

subject to time bound installation of DG sets with

acoustic enclosures and compliance reported to

this MoEF&CC, Regional Office Bhopal.

COMPLIED SUBJECT TO CONDITION

Please see the attached copy of Quotation & order copy for Sound Proof Acoustic enclosure of DG sets. We are installed shortly.

12. The company shall

upload the status of

compliance of the

stipulated

environmental

clearance

conditions,

including results of

monitored data on

its website and

shall update the

same periodically.

It shall

simultaneously be

sent to the

Regional office of

MOEF, the

respective Zonal

office of CPCB and

the GPCB.

The levels of PM10,

S02, NOx, VOCs,

Cl2, HCI, HBr, CO

and HC (Methane

and Non-methane)

in ambient air and

emissions from the

stacks shall be

monitored and

displayed at a

convenient location

near the main gate

of the company and

at important public

places.

We have not uploaded the data of compliance report. In

future we will be uploading the same on regular basis.

We will regularly sent compliance report to Regional office,

Bhopal office. We haven’t send it earlier.

We are regularly monitor level of PM10, PM2.5, SO2, NOx,

VOC and CO in ambient air and emissions from the stacks

through third party analysis i.e. M/s. Vairagya Consultants

(Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb 2017). On monthly basis

and will display at the main gate of our company.


The said stipulation is considered partly

complied.

PARTLY COMPLIED

We displayed the stack

emission/ambient air

report on board in two

language (local & English)

at main gate of our

company.

We regularly Submitted

compliance report to

Regional office.

At Bhopal office we

haven't sent it earlier,

further we will submit.

13. Solvent

management shall

be carried out as

follows:

Chilled brine

circulation system


condensate solvent

vapors and reduce

solvent losses. It

shall be ensured

that solvent

recovery shall not

be less than95%.

Reactor and solvent

handling pump shall

have mechanical

seals to prevent

leakages.

Chilled brine circulation system is provided to condense

solvent vapors and reduces solvent losses and ensured that

solvent recovery is 95-96%. (Data is attached).

We have already provided double mechanical seals to the

pumps & Reactor’s for avoiding leakages.

We have provided adequate condensers. We are achieving

solvent recovery above 95%

The condensers

shall be provided

with sufficient HTA

and residence time

so as to achieve

more than 95%

recovery.

Xylene Recovery :-

Sr. No

Month Total Used

in Kg Recovered

in Kg Percentage

%

1 Jan-17 58405 55508 95.04

2 Feb-17 51364 48842 95.09

3 Mar-17 80096 76115 95.03

4 Apr-17 55078 52379 95.10

5 May-17 67331 63977 95.02

6 Jun-17 58000 55158 95.10

EDC Recovery :- Sr. No

Month Total Used

in Kg Recovered

in Kg Percentage

%

1 Jan-17 118788 112967 95.10

2 Feb-17 86158 81893 95.05

3 Mar-17 108412 103067 95.07

4 Apr-17 106175 100898 95.03

5 May-17 110845 105391 95.08

6 Jun-17 91182 86714 95.10

DMACT EDC Recovery :- Sr. No

Month Total Used

in Kg Recovered

in Kg Percentage

%

1 Jan-17 110422 105650 95.6%

2 Feb-17 79136 75100 95.3%

3 Mar-17 97705 93500 95.7%

4 Apr-17 69645 66523 96.0%

5 May-17 63213 60157 95.6%

6 Jun-17 80625 76387 95.2%

SFT EDC Recovery :-

Sr. No

Month Total Used

in Kg Recovered

in Kg Percentage

%

1 Jan-17 99077 95058 96.0%

2 Feb-17 95851 92851 95.8%

3 Mar-17 89492 85492 95.5%

4 Apr-17 71985 69055 95.9%

5 May-17 73454 70454 95.9%

6 Jun-17 9625 9225 95.8%

DMF Recovery :- Sr. No

Month Total Used

in Kg Recovered

in Kg Percentage

%

1 Jan-17 237577 227577 96%

2 Feb-17 199571 189571 95%

3 Mar-17 93115 89115 96%

4 Apr-17 188741 179841 95%

5 May-17 94555 90055 95%

6 Jun-17 203229 195229 96%

Toluene Recovery :- Sr. No

Month Total Used

in Kg Recovered

in Kg Percentage

%

1 Jan-17 105182 100611 96%

2 Feb-17 104619 100172 96%

3 Mar-17 95349 91021 95%

4 Apr-17 75630 72536 96%

5 May-17 71926 69161 96%

6 Jun-17 81509 77791 95%

Methenol Recovery :-

Process & Washing

129.25 KL Boiler &

Cooling 151.36

KL

Other Use (Gardening

etc.) 10.5 KL

Domestic

28.09 KL

Process & Washing- 127.0 KL + Boiler & Cooling 8.35

KL= Total Industrial

Effluent 135.35 KL

Domestic

24.97 KL

Total Effluen

t 160.32

KL

10.5 KL use in Gardening etc. Loss

143.01 KL 2.25KL

Loss

3.12 KL

Loss

GIDC Water 313.11 KL

Solvents shall be

stored in a separate

space specified with

all safety ensures.

Proper earthing

shall be provided in

all the electrical

equipment

wherever solvent

handling is done.

Entire plant shall

be flame proof.

The solvent

storage tanks shall

be provided with

breather valve to

prevent losses.

Sr. No

Month Total Used

in Kg Recovered

in Kg Percentage

%

1 Jan-17 162600 156330 96%

2 Feb-17 88200 84150 95%

3 Mar-17 90500 86669 96%

4 Apr-17 117400 112748 96%

5 May-17 N/A N/A N/A

6 Jun-17 N/A N/A N/A

IPA Recovery :- Sr. No

Month Total Used

in Kg Recovered

in Kg Percentage

%

1 Jan-17 243000 231945 95%

2 Feb-17 163400 156161 96%

3 Mar-17 N/A N/A N/A

4 Apr-17 N/A N/A N/A

5 May-17 N/A N/A N/A

6 Jun-17 N/A N/A N/A

We store solvent at its designated area. Storage tanks are

equipped with all safety measures (Level Indicator, Pressure

gauge, Vent, PRV, Dyke wall etc…)

All electrical equipment ‘sand solvent tank/transfer line are

protected by earthling and connected to a Earthing Pit with

Charcoal.

All electric fittings are flame proof in the plant. Breather

Valves are installed on solvent storage tanks.



COMPLIED 14. Total water

requirement from

GIDC water supply

shall not exceed

1383 m3/day and

prior permission

shall be obtained

from the

Competent

Authority.

Our water consumption is never limit.

Please see mention water and waste water balance :-

Please see the attached data of water consumption last year-2016-17 also. Attached addl. information of copy of

agreement with GIDC form

water supply.

Month

Water Consumption (KL)

Apr - 16 8507

May -16 5697

June -16 6459

July -16 8860

Aug -16 10570

Sept -16 9026

Oct -16 11954

Nov -16 12149

Dec -16 10665

Jan -17 11024

Process &

Washing

126.76 KL

Boiler & Cooling 148.49

KL

Other Use (Gardening etc.) 16.5 KL

Domestic

21.36 KL

Process & Washing- 124.55 KL + Boiler &

Cooling 7.49 KL= Total Industrial Effluent 132.04

KL

Domestic

18.99 KL

Total Effluent 151.03

KL


2.21 KL Loss

WATER BALANCE-2016-17

2.37 KL

Loss


No ground water

shall be used.

We are not using the ground water. Our source of water is

GIDC Water only.


The said stipulation is considered partly complied

subject to submission of addl. information of

copy of agreement with GIDC for water supply,

details of water consumption (month-wise max.

min) over the compliance period.etc.


Feb -17 9484

Mar -17 12117

Total 116512

Min. Kl/Day 183.77

Max. Kl/Day 404.97

Ave. Kl/Day 319.21


Process & Washing

129.25 KL Boiler &

Cooling 151.36

KL

Other Use (Gardening

etc.) 10.5 KL

Domestic

28.09 KL


Cooling 8.35 KL= Total Industrial Effluent

135.35 KL

Domestic

24.97 KL


KL


143.01 KL 2.25KL

Loss


3.12 KL

Loss


Process &

Washing

126.76 KL

Boiler & Cooling 148.49

KL

Other Use (Gardening etc.) 16.5 KL

Domestic

21.36 KL


Cooling 7.49 KL= Total Industrial Effluent 132.04

KL

Domestic

18.99 KL


KL


2.21 KL Loss


2.37 KL

Loss

15 Industrial effluent

generation shall not

exceed 904

m3/day.

Effluent shall be

segregated into

High COD, High

TDS and low

COD/TDS effluent

streams.

High COD effluent

mother liquor shall

be incinerated.

High TDS effluent

shall be treated

We are not generating more than permissible limit of

Industrial effluent. Please see mention water and waste

water balance:-We have segregated High COD, High

TDS and low COD/TDS effluent streams.

We treat our High COD/TDS effluent in MEE.

We treat LOW COD/TDS consisting of primary, secondary

treatment units in ETP.

through stripper

followed by MEE.

Low COD/TDS

effluent shall be

treated in ETP.

Industrial effluent

shall be treated in

ETP and treated

effluent shall be

discharged to the

GIDC Effluent

drainage line after

conforming the

norms prescribed

by GPCB.

We discharge our effluent after giving proper treatment and

after conforming to the norms prescribed by GPCB. Through

underground effluent drainage line to GIDC. Please see the

analysis report of third party i.e. M/s. Vairagya

Consultants (Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb 2017)



Sr.

No

Parameter Result GPCB Norms Unit

1 Ph 6.2 6.5-8.5 -


3 Colour Colorles

s - -










13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L













28 Iron BDL 3 Mg/L



No


1 Ph 5.6 6.5-8.5 -


3 Colour Colorles

s - -










13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L













28 Iron BDL 3 Mg/L




Unit

1 Ph 7.2 6.5-8.5 -


3 Colour Colorles

s - -










13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L













28 Iron BDL 3 Mg/L




Unit

1 Ph 7.2 6.5-8.5 -




5 Oil & grease

BDL 10 Mg/L








13 Zinc BDL 15 Mg/L

14 BOD 15 100 Mg/L

15 COD 48 250 Mg/L













28 Iron BDL 3 Mg/L




Unit

1 Ph 7.35 6.5-8.5 -









10 Total Kjeldhal Nitrogen

47 100 Mg/L



13 Zinc BDL 15 Mg/L

14 BOD 12 100 Mg/L

Cyanide effluent

stream shall be

segregated and

treated.

Water quality of

treated effluent

shall meet the

norms prescribed

15 COD 45 250 Mg/L













28 Iron BDL 3 Mg/L




Unit

1 Ph 6.52 6.5-8.5 -












13 Zinc BDL 15 Mg/L

14 BOD 12 100 Mg/L

15 COD 47 250 Mg/L













28 Iron BDL 3 Mg/L


Yes we have a facility to segregate Cyanide effluent stream

separately and give the hypo treatment first and conform nil

cyanide then transfer it to HIGH COD stream.

Yes our discharge quality of treated effluent shall meet the

norms prescribed by CPCB/SPCB.

(Please find Annexure –G)(Attached in hard copy)


by CPCB/SPCB. Sr.

No


Norms

Unit

1 Ph 6.2 6.5-8.5 -


3 Colour Colorles

s - -








11.2 100 Mg/L



13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L

16 Total Residue Chlorine

BDL 1 Mg/L


18 Hexavalent Chromium

BDL 0.1 Mg/L










28 Iron BDL 3 Mg/L



No


Norms

Unit

1 Ph 5.6 6.5-8.5 -


3 Colour Colorles

s - -








9.24 100 Mg/L



13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L


BDL 1 Mg/L



BDL 0.1 Mg/L










28 Iron BDL 3 Mg/L




Unit

1 Ph 7.2 6.5-8.5 -


3 Colour Colorles

s - -








5 100 Mg/L



13 Zinc BDL 15 Mg/L

14 BOD BDL 100 Mg/L

15 COD BDL 250 Mg/L


BDL 1 Mg/L



BDL 0.1 Mg/L










28 Iron BDL 3 Mg/L



Sr.

No


Norms

Unit

1 Ph 7.2 6.5-8.5 -


3 Colour Colorle

ss - -








52 100 Mg/L



13 Zinc BDL 15 Mg/L

14 BOD 15 100 Mg/L

15 COD 48 250 Mg/L


BDL 1 Mg/L



BDL 0.1 Mg/L










28 Iron BDL 3 Mg/L



No


Norms

Unit

1 Ph 7.35 6.5-8.5 -


3 Colour Colorles

s - -








47 100 Mg/L



13 Zinc BDL 15 Mg/L

14 BOD 12 100 Mg/L

15 COD 45 250 Mg/L


BDL 1 Mg/L



BDL 0.1 Mg/L










28 Iron BDL 3 Mg/L



No


1 Ph 6.52 6.5-8.5 -












13 Zinc BDL 15 Mg/L

14 BOD 12 100 Mg/L

15 COD 47 250 Mg/L













28 Iron BDL 3 Mg/L




by NABL/EPA approved laboratory, the condition

is considered complied subject to acceptance of

monitored data by MoEF&CC, New Delhi.

COMPLIED SUBJECT TO ACCEPTANCE OF

MONITORED DATA BY MOEF&CC,NEW DELHI


16. Treated effluent

shall be passed

through guard

pond.

Online continuous

pH meter, TOC

analyzer and flow

meter shall be

Installed to monitor

the treated water

quality.

We have provided guard pond and discharge our waste water

into underground effluent drainage line to GIDC.

We have provided online pH meter, flow meter and TOC

analyzer at the final out let of GIDC and running

continuously.


and as per The site observation, the stipulation


COMPLIED

17. Process effluent/any

wastewater shall

not be allowed to

mix with storm

water. Storm water

drain shall be

passed through

guard pond.

We have provided separate storm water system and separate

industrial waste water collection system. We ensure that,

both the streams are not mixed in any case.



COMPLIED

18. Incinerator

comprising primary

and secondary

chamber shall be

designed as per

CPCB guidelines.

S02, NOx, HCI and

CO emissions shall

be monitored in the

stack regularly.

We have installed Incinerator comprising primary and

secondary chamber shall be designed as per CPCB guidelines

The incinerator installed is meant for off gases & is product

specific. Presently the off gases related to the specific

production are out of production line. Hence, the incinerator

hasn’t been operated yet. However, we ensure the

equipment’s is well maintained and operatable at any

moment of time.



COMPLIED

19. Hazardous

chemicals shall be

stored in tanks in

tank farms, drums,

carboys etc.

Flame arresters

shall be provided

on tank farm.

Solvent transfer

shall be by pumps.

We have provided separate tank yard for liquid raw materials

as per factory act rules.

We have already provided flame arrester and heat exchanger

on tank farm.

We have provided close pipe line and pump for transferring

the solvents from storage tank to reactors.



COMPLIED


obtain

Authorization for

collection, storage

and disposal of

hazardous waste

under the

Hazardous Waste

(Management,

Handling and

Trans-Boundary

Movement) Rules,

2008 and amended

We have already obtained authorization in the form of CCA

from GPCB for the generation; storage and disposal of

hazardous waste under the hazardous waste rules 2008.We

have already obtained membership of TSDF.

as on date for

management of

Hazardous wastes

and prior

permission from

GPCB shall be

obtained for

disposal of solid /

hazardous waste in

the TSDF.

Measures shall be

taken for

firefighting facilities

in case of

emergency.

Membership of

TSDF for hazardous

waste disposal shall

be obtained.

We have provided adequate firefighting system in entire plant

area. We have already obtained membership of TSDF. Please find the membership certificate. Annexure –P (Attached in hard copy)

In view of the information furnished by the PP

and the CCA submitted by the PP, The stipulation


COMPLIED

21. As proposed, ETP

sludge, incineration

ash and

evaporation residue

shall be sent to

TSDF site.

High calorific value

waste such as

spent organic shall

be sent to cement

factory/incinerated.

The fly ash from

boiler shall be sold

to brick manufacturers/cem

ent industry.

We dispose our ETP sludge, incineration ash sent to the TSDF

site time to time. And evaporation/distillation residue sent to

RSPL for co processing.

High calorific value waste such as spent organic sent to

GSPL/SEPPL for incinerated. Distillation residue sent to RSPL

for co processing.

The fly ash from boiler sent to brick manufacturers.


the stipulated condition is considered complied

subject to submission of documentary evidences

in support of the compliance reported.


Please see the attached

membership certificate for

your reference.

22. The Company shall

strictly comply with

the rules and

guidelines under

Manufacture,

Storage and Import

of Hazardous

Chemicals (MSIHC)

Rules, 11989 as

amended in

October, 1994 and

January, 2000.

All Transportation

of Hazardous

Chemicals shall be

as per the Motor

Vehicle Act (MVA),

1989.

We are complying with all the rules regulations and guide

lines under Manufacture, Storage and Import of Hazardous

Chemicals (MSIHC) Rules, 1989 as amended in October,

1994 and January, 2000.

We are transporting all the hazardous chemicals as per the

Motor Vehicle Act (MVA), 1989.


the stipulated condition is considered complied.

COMPLIED


undertake following

waste minimization

measures :-

Complied

Metering and

control of quantities

of active ingredients

to minimize waste.

Reuse of by-

products from the

process as raw

materials or as raw

material substitutes

in other processes.

Use of automated

filling to minimize

spillage.

Use of Close Feed

system into batch

reactors.

Venting equipment

through vapor

recovery system.

Use of high

pressure hoses for

equipment clearing

to reduce

wastewater

generation.

We have provided magnetic flow meter for minimize waste.

We reuse our byproduct in process.


materials. From storage tank to reactor raw materials are

transfer through closed pipe line for minimize spillage.

We have charging solid/liquid raw material in close system

batch reactor.

Venting provided with condenser system and recover it.

We use jet pump for cleaning our equipment and reduce

waste water generation.



COMPLIED

24. The unit shall make

the arrangement for

protection of

possible fire

hazards during

manufacturing

process in material

handling.

Firefighting system

shall be as per the

norms.

We have provided separate isolated storage yard for all the

raw materials and also closed raw material handling system

and ensure that; there is no fire hazard occur during the

manufacturing process.

We have provided adequate firefighting system, with stand

by diesel operated Firefighting pump, in entire plant area as

per the safety norms.



COMPLIED

25. Occupational health

surveillance of the

workers shall be

done on a regular

basis and records

maintained as per

the Factories Act.

We are regularly carried out medical checkup of each

employee through authorized medical officer and maintain

the records as per the factory act rules. ( health register Attached in hard copy) Annexure-O.



COMPLIED

26. As proposed, green

belt over 33 % of

the total project

area shall be

developed within

plant premises with

at least 10 meter

wide green belt on

all sides along the

Our total plot area is 71722.05 m2 and we have already

developed green belt in 21, 000m2 of area in and around the

factory premises to mitigate the effects of fugitive emissions

all around the plant as per the guideline GPCB.

periphery of the

project area, in

downward

direction, and along

road sides etc.

Selection of plant

species shall be as

per the CPCB

guidelines in

consultation with

the DFO.

We have selected plant species as per GPCB guide lines only.

In view of the information furnished by the PP

and the site observation that greenbelt is found

in patches along the periphery and stipulated

greencover not met the stipulated condition is

considered partly complied.

PARTLY COMPLIED

We assure that, we will

develop the green belt in

the factory premises, also

the green belt area of

factory boundary has

improved better than past.


make the

arrangement for

protection of

possible fire and

explosion hazards

during

manufacturing

process in material

handling.

We have installed jockey pump along with surrounding water

hydrant line. And install fire extinguisher form every plant as

per fire load.



COMPLIED

28

.

All the

commitments made

during the Public

Hearing / Public

Consultation

meeting held on

l7th April, 2013

shall be

satisfactorily

implemented and

adequate budget

provision shall be

made accordingly.

Sr.

No. Name and

Address

Points

Represente

d and/or

written

submission

Replies from

Project

Proponent

Compliance status

1 Shree Ranjeet

Gohil, Village: Dahej,

Taluka: Vagra,

District:

Bharuch

He had informed

during the public hearing that

large nos. of

plants developed

on the sea-shore

which had blocked the

approach roads.

He also informed

that employment is

given to the

local people at

lower level and top

management

persons are

from outside

areas. Presently in

Gujarat various

collages /

institutes are available and

students from

outside Gujarat

also candidates of Gujarat are

not given

preference for

selection in jobs.

Shri Rakeshbhai C.

Shah (EIA consultant) had replied that the

said statement is true

as the people of

Gujarat are more

attracted towards business activities

rather than technical

education and

services.

For recruitment in top

management technical education and skilled

man power are

required. He further

added that if a person from local area having

the desires

qualification is

available they will be preferred for

employment in the top

management.

Our plant is located in

GIDC with well laid infrastructure. The internal

plant roads are well laid

for easy accessibility to

operational plants.

The top managements

heading the Key areas are

locals and from within the

state.

The workers and skilled

technicians are sourced

from the local areas based

on there their trade are employed and currently

serving the organization.

2 Shree Rajendrasinh

Fatehsin

Parmar,

Village: Vav,

Taluka: Vagra, District:

Bharuch

He had informed that level of

education in the

area is poor

therefore; the

opportunities to get the job are

very less. If

proper training

is imparted by Government,

they may get

selected.

No comments were given by the project

proponent

No Comments: it’s related to Govt policy matter.

He also informed

people of the

nearby areas are aware of the

chemicals and

their reaction.

They should be made aware

regarding the

same.

3 Shree Yogesh

Pandiya (Founder

Trustee, Dahej

Eco-Friendly

Society), Village: Dahej,

Taluka: Vagra,

District:

Bharuch

He had given

details of Dahej Eco-Friendly

Society and it’s

registration as

charitable trust he furthered

informed that

they are

engaged in environmental

conservation

and safety.

He informed

that company

is going to

manufacture organ

phosphorus

compounds,

pesticides, herbicides etc

which require

special care

regarding

safety & environment.

The company is going to

manufacture

D.V. acid

product for

which no specific safe

chemistry is

available.

Considering the past records of

this products

number of

accidents had occurred in

these plants.

He had given

examples of incidents in

these types of

plants at

various location

of Gujarat and Maharashtra.

Considering the

same he had

advised the industry to find

out safe

chemistry for

the product.

He stated that

people working

in the plant have

knowledge

about the risk

of chemicals but other local

people do not

know about

this.

Regarding EIA

he had pointed

out the scheme of rainwater

The company at present is

engaged in manufacture of Herbicides, the technology

and the chemistry is

developed in In house.

The Hazop has been carried out on the entire

process a aspects have

been understood very well

and safety measures have been adequately

established and adopted to

prevent any untoward

incidents and accidents.

The company has a full-fledged Safety team

including Head Safety and

safety executives in

shifts, including fire fighting personnel. The

Team imparts training to

all plant personnel on the

chemicals handled in process and safe

practices to be followed.

The solvent recoveries at present are at 96%,

which is ensured by way

secondary and tertiary

HE’s. With Brine

Circulations of minus 10 degree.

The plant personnel are

trained regularly on fire

fighting methods and

exposed to all firefighting equipment's and how to

use the same in exigency

situations.

The Safety department

has well equipped occupational health

Centre with oxygen

cylinders, First aid Kit,

Medicines, Stretcher and Nurse on a 24 hrs basis,

with emergency vehicle

to cater to any

emergency. A doctor is statione d during the day

time and we have tied

with an local Hospital

Located within 3 Km from the factory premises.

harvesting.

Considering the

pesticide manufacturing

plant he advise

the industry

not to go for rainwater

harvesting. The

company is

going to invest about Rs. 200

crores in Dahej

plant

considering the effluent

disposal

infrastructures

available. He

warned the industry that

the available

common

infrastructure is constantly

monitored by

the

Government Authorities as

well as by

NGOs. He

advised the

industry not to go for wrong

practices. The

industry is

going to use large amount

of solvents in

the plant and

they have shown 90%

solvent

recovery. But

he advised the industry to go

for solvent

recovery more

than 95% due

to which emission of

Volatile organic

Compounds

(VOC) will be minimized and

adverse impact

on the

environment will be avoided.

Regarding

occupation

health, he had

advised the industry to

keep and

availability of

antidotes of all the chemicals

in their

premises. He

further advised the industry to

develop well

equipped

occupational health center in

the industry

with an export

and male

nurse.



COMPLIED 29. At /east 5 % of the We are providing skill development for local people. We have

total cost of the

project shall be

earmarked towards

the Enterprise

Social Commitment

(ESC) based on

public hearing

issues and item-

wise details along

with time bound

action plan shall be

prepared and

submitted to the

Ministry's Regional

Office at Bhopal.

Implementation of

such program shall

be ensured

accordingly in a

time bound

manner.

started to “beti Bachao beti padhao” scheme through local

government school. (Please find Annexure –M)(Attached in hard copy)



subject to submission documentary evidences in

support of the PP submitting a time bound action

plant alongwith amount spent so far to towards

ESC.

COMPLIED

30

.

Provision shall be

made for the

housing for the

construction labor

within the site with

all necessary

infrastructure and

facilities such as

fuel for cooking,

mobile toilets,

mobile sewage

treatment plant,

safe drinking water,

medical health

care, etc.

The housing may

be in the form of

temporary structure

to be removed after

the completion of

the project. All the

construction wastes

shall be managed

so that there is no

impact on the

surrounding

environment.

We have provided all necessary infrastructure and facilities

such as fuel for cooking, toilets, sewage treatment plant, safe

drinking water, medical health care, etc. for the labor.

We have removed all temporary structure after completion of

the project. And All the construction wastes is removed for

project location so there is no impact on the surrounding

environment.



COMPLIED

B. General condition

1 The project

proponent shall

strictly adhere to

the stipulations

made by the

Gujarat Pollution

Control Board

(GPCB), State

Government and

We are strictly adhering to the stipulations made by the

Gujarat Pollution Control Board (GPCB), State Government

and any other statutory authority.



subject to submission of detailed compliance of

all the stipulation made by GPCB.


compliance report of

environmental auditor

(recommended by GPCB for

audit) for your reference.

any other statutory

authority. COMPLIED SUBJECT TO CONDITION

2 No further

expansion or

modifications in the

plant shall be

carried out without

prior approval of

the Ministry of

We undertake that; we will not carry out further expansion or

modifications in plant without approval of the Ministry of

Environment, Forest and climate change.

Environment and

Forests.

In case of

deviations or

alterations in the

project proposal

from those

submitted to this

Ministry for

clearance, a fresh

reference shall be

made to the

Ministry to assess

the adequacy of

conditions imposed

and to add

additional

environmental

protection

measures required,

if any.

There is no deviation or alternations in the project. The

expansion project is carried out as per EC issued by MoEF&

CC.



COMPLIED

3 The locations of

ambient air quality

monitoring stations

shall be decided in

consultation with

the Gujarat

Pollution Control

Board (GPCB) and

it shall be ensured

that at least one

station is installed

in the upwind and

downwind direction

as well as where

maximum ground

level concentrations

are anticipated.

We regularly monitor ambient air quality within the premises

through third party analysis i.e. M/s. Vairagya Consultants

(Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb 2017) on monthly basis.

The reports of ambient air quality monitoring is enclosed

herewith as We have selected ambient air monitoring station

in consultation with the Gujarat Pollution Control Board

(GPCB) and ensured that at least one station is installed in

the upwind and downwind direction as well as where

maximum ground level concentrations are anticipated.

(Please find Annexure –E)(Attached in hard copy)

(MIN. MAX. tabulated based on the data monitoring generation over a period from JAN-2017 to JULY-2017)


Location Parameter Result GPCB

Norms

MIN Max Avg. Mg/Nm3

PM10 67 74 71.14 100

PM2.5 33 39 35.57 60

Oxide OF Sulphur 7.8 11.8 10.4 80


HCL 1.2 1.5 1.37 200

Cl2 0.58 0.61 0.60 100

Ammonia 0.52 0.58 0.54 400

H2S BDL BDL BDL 500

HC 1.2 1.5 1.4 160

HF BDL BDL BDL 60


ETP

CO 1.1 1.3 1.16 5000

Location Parameter Result GPCB

Norms

MIN Max Avg. Mg/Nm3

PM10 52 66 57.43 100

PM2.5 33.5 37 35.26 60

Oxide OF Sulphur 8.3 14 11.54 80


HCL 0.55 0.61 0.59 200

Cl2 0.34 0.44 0.39 100

Ammonia 0.31 0.38 0.35 400

H2S BDL BDL BDL 500

HC 1.2 1.7 1.41 160

HF BDL BDL BDL 60


Main Gate

CO 0.74 0.78 0.76 5000

Sampling

Date


Mg/Nm3

PM10 67 100

PM2.5 33 60



HCL 1.5 200

Cl2 0.61 100

Ammonia 0.54 400

H2S BDL 500

HC 1.3 160

HF BDL 60

CS2 BDL 2000

11/01/2017

ETP

CO 1.2 5000

Sampling Date


PM10 69 100

PM2.5 36 60



HCL 1.3 200

Cl2 0.6 100

Ammonia 0.52 400

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

13/02/2017

ETP

CO 1.1 5000

Sampling

Date


Mg/Nm3

PM10 71 100

PM2.5 34 60



HCL 1.4 200

Cl2 0.59 100

Ammonia 0.53 400

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

25/03/2017

ETP

CO 1.2 5000

Sampling

Date


Mg/Nm3

PM10 73 100

PM2.5 36 60



HCL 1.5 200

Cl2 0.6 100

Ammonia 0.57 400

H2S BDL 500

HC 1.4 160

HF BDL 60

CS2 BDL 2000

13/04/2017

ETP

CO 1.3 5000

Sampling

Date


Mg/Nm3

PM10 72 100

PM2.5 38 60



HCL 1.4 200

Cl2 0.58 100

Ammonia 0.52 400

H2S BDL 500

HC 1.5 160

HF BDL 60

CS2 BDL 2000

12/05/2017

ETP

CO 1.1 5000

Sampling

Date


Mg/Nm3

PM10 74 100

PM2.5 39 60



HCL 1.3 200

Cl2 0.59 100

Ammonia 0.55 400

H2S BDL 500

HC 1.4 160

HF BDL 60

CS2 BDL 2000

09/06/2017

ETP

CO 1.2 5000

Sampling

Date


Mg/Nm3

PM10 72 100

PM2.5 33 60



HCL 1.2 200

Cl2 0.6 100

Ammonia 0.58 400

H2S BDL 500

HC 1.2 160

06/07/2017

ETP

HF BDL 60

CS2 BDL 2000

CO 1.1 5000

Sampling

Date


Mg/Nm3

PM10 52 100

PM2.5 33.5 60



HCL 0.55 200

Cl2 0.36 100

Ammonia 0.38 400

H2S BDL 500

HC 1.6 160

HF BDL 60

CS2 BDL 2000

11/01/2017

Main Gate

CO 0.76 5000

Sampling

Date


Mg/Nm3

PM10 53 100

PM2.5 35.3 60



HCL 0.58 200

Cl2 0.34 100

Ammonia 0.37 400

H2S BDL 500

HC 1.3 160

HF BDL 60

CS2 BDL 2000

13/02/2017

Main Gate

CO 0.74 5000

Sampling

Date


Mg/Nm3

PM10 54 100

PM2.5 35 60



HCL 0.6 200

Cl2 0.4 100

Ammonia 0.38 400

H2S BDL 500

HC 1.2 160

HF BDL 60

CS2 BDL 2000

25/03/2017

Main Gate

CO 0.75 5000

Sampling

Date


Mg/Nm3

PM10 56 100

HC 1.7 160

HF BDL 60

CS2 BDL 2000

Gate

CO 0.77 5000

Sampling

Date


Mg/Nm3

PM10 58 100

PM2.5 35 60



HCL 0.59 200

Cl2 0.39 100

Ammonia 0.31 400

H2S BDL 500

HC 1.6 160

HF BDL 60

CS2 BDL 2000

12/05/2017

Main Gate

CO 0.78 5000

Sampling

Date


Mg/Nm3

PM10 63 100

PM2.5 37 60



HCL 0.6 200

Cl2 0.42 100

Ammonia 0.34 400

H2S BDL 500

HC 1.3 160

HF BDL 60

CS2 BDL 2000

09/06/2017

Main Gate

CO 0.76 5000

Sampling

Date


Mg/Nm3

PM10 66 100

PM2.5 34 60



HCL 0.61 200

Cl2 0.44 100

Ammonia 0.32 400

H2S BDL 500

HC 1.2 160

HF BDL 60

CS2 BDL 2000

06/07/2017

Main Gate

CO 0.77 5000



COMPLIED

4 The overall noise

levels in and around

the plant area shall

be kept well within

the standards by

We are maintaining the noise level within the plant area as

prescribed by the board. To control noise level within the

premises we are regularly carried out maintenance stirrers,

pumps machineries etc.

providing noise

control measures

including acoustic

hoods, silencers,

enclosures etc. on

all sources of noise

generation.

The ambient noise

levels shall conform

to the standards

prescribed under

Environment

(Protection) Act,

1986 Rules, 1989

viz. 75 dBA (day

time)and 70 dBA

(night time).

We regularly monitor noise level within the premises through

third party analysis i.e. M/s. Vairagya Consultants (Recognized Schedule – II auditor by GPCB no. GPCB/EA-294/404708/20 Feb 2017) on monthly basis.

(Please find Annexure –L)(Attached in hard copy)

Sr

NO

Location Min.

Noise

Level

dB(A)

Mex.

Noise

Level

Db(A)

Avg.

Noise

Level

Db(A)

1 Main Gate 44.8 64.2 54.3

2 Material Gate 54.8 74.1 64.45

3 Near Boiler Boundary 64.2 77.0 70.6

4 Way Bridge 49.9 67.7 58.8

5 Hydrogen plant Boundary 55.6 65.6 60.6

6 Empty storage area 43.1 67.0 55.05

7 Sludge storage area 52.0 67.3 59.65

8 Plant-3 boundary area 61.7 65.0 63.35

9 Canteen 49.9 63.8 56.85

10 Green Belt area 47.5 64.0 55.75

In view of the information furnished by the PP and the fact that the monitoring was not carried out by NABL/EPA approved laboratory, the condition is considered complied subject to acceptance of monitored data by MOEF&CC, New Delhi. PP shall

ensure monitoring by an NABL/EPA approved laboratory for the environmental quality monitoring purpose.



5 The Company shall

harvest rainwater

from the roof-tops

of the buildings and

storm water drains

to recharge the

ground water and

use the same water

for the process

activities of the

project to conserve

fresh water.

Not Applicable as this is a Pesticide manufacturing Unit.


the stipulated condition is considered not

applicable to PP.

COMPLIANCE NOT APPLICABLE TO PP

6 During transfer of

materials, spillages

shall be avoided

and garland drains

be constructed to

avoid mixing of

accidental spillages

with domestic

wastewater and

storm water drains.

We have provided double mechanical type seal pump for

avoided spillages, leakages during transfer of raw materials

to avoid mixing with domestic waste water as well as storm

water drains.



COMPLIED

7 Usage of Personnel

Protection

Equipment’s by all

employees/ workers

shall be ensured.

We have provided adequate PPE’s like helmet, hand gloves,

gum boots, aprons to each employees. We ensure that;

without PPE’s employee is not entered in the plant area.



COMPLIED

8 Training shall be

imparted to all

employees on

safety and health

aspects of

chemicals handling.

Pre-employment

and routine

periodical medical

examinations for all

employees shall be

undertaken on

regular basis.

Training to all

employees on

handling of

chemicals shall be

imparted.

We are regularly carried out training regarding safety, health

and chemical handling within the premises once in a month.

This mandatory administrative procedure which is carried out

for each employee through authorized medical officer, and

maintains the records as per the factory act rules.

We are regularly carried out training on handling of

chemicals.




in support of the same.



training attendance sheet

for your reference.

9 The company shall

also comply with all

the environmental

protection measures

and safeguards

proposed in the

project report

submitted to the

Ministry.

All the

recommendations

made in the

EIA/EMP in respect

of environmental

management, risk

mitigation measures

and public hearing

relating to the

project shall be

implemented.

We are complying with all the environmental protection

measures and safeguards submitted to the Ministry.

We have already implemented recommendations/suggestions

mentioned in EIA/EMP and risk assessment report.



COMPLIED

10 The company shall

undertake CSR

activities and all

relevant measures

for improving the

socio-economic

conditions of the

surrounding area.

We have regularly carried out CSR activities and all relevant

measures for improving the socioeconomic conditions of the

surrounding area.






Please see the attached our

CSR activities participation for

your reference.

11 The company shall

undertake eco-

developmental

measures including

community welfare

measures in the

project area for the

overall

improvement of the

environment.

We are regularly taken part for eco development including

community welfare measures in the project area for overall

improvement of the environment through Dahej industrial

association.






Yes sir, please see the

attached sheet.

Social Activities.

Skill development

Activities

12 A separate

Environmental

Management Cell

equipped with full-

fledged laboratory

facilities shall be

set up to carry out

the Environmental

Management and

Monitoring

functions.

We have establish our own environmental management cell

with full-fledge environmental laboratory. We have appointed

one number of chemical engineer, 4 numbers of chemists

(M.Sc.) for the operation and maintenance of environmental

management system. We are regularly carried out waste

water analysis in our own laboratory on daily basis.



subject to recruitment of manpower with

Env.Engg/Env.SC background.


Yes we have already recruited

BE Environment engineer in

our Environment management

cell. Attach the sheet for your

reference.

13 Company shall

earmark sufficient

funds for recurring

cost per annum to

implement the

conditions

stipulated by the

Ministry of

Environment and

Forests as well as

the State

Government along

with the

implementation

schedule for all the

conditions

stipulated

herein.

The funds so

earmarked for

environment

management/

pollution control

measures shall not

be diverted for any

other purpose.

We have earmarked sufficient funds for recurring cost as per

requirement and mentioned in EIA/EMP for the operation of

EMS.

We ensure that; the funds earmarks for EMS will not divert

for any other purposes.




in support of the same like total CAPEX incurred

for environment management do far and sub-

head wise recurring expenditure incurred over

the last 3 years.


Please see the attached our TOTAL BUDUGT FOR environment management for your reference.

14 Copy of the

clearance letter

shall be sent by the

project proponent

to concerned

Panchayat,

ZilaParisad/Municip

al Corporation,

Yes we have distributed Copy of the clearance letter to all.




Please see the attached distributed Copy of the clearance letter to all for your reference.

Urban local Body

and the local NGO,

if any, from who

suggestions/

representations, if

any, were received

while processing the

proposal.



15 The project

proponent shall also

submit six monthly

reports on the

status of

compliance of the

stipulated

Environmental

Clearance

conditions including

results of

monitored data

(both in hard copies

as well as by e-

mail) to the

respective Regional

Office of MoEF, the

respective Zonal

Office of CPCB and

the Gujarat

Pollution Control

Board.

A copy of

Environmental

Clearance and six

monthly compliance

status reports shall

be posted on the

website of the

company.

We have submitted status of compliance report to

GPCB and upload to XGN web site.

We will post six monthly compliance reports on XGN

web site.


the stipulated condition is considered partly

complied.

PARTLY COMPLIED

We hereby attached copy

of third party compliance

report submitted to GPCB.

16 The environmental

statement for each

financial year

ending 3lst March

in Form.-V as is

mandated shall be

submitted to the

Gujarat Pollution

Control Board as

prescribed under

the Environment

(Protection) Rules,

1986, as amended

subsequently, shall

also be put on the

website of the

company along with

the status of

compliance of

environmental

clearance

conditions and shall

also be sent to the

Bhopal Regional

Offices of MOEF by

e-mail.

We are regularly submitting Environmental statement From V

to GPCB every year through online XGN of GPCB and will also

uploaded on web site of the company.



complied.

PARTLY COMPLIED

We hereby attached copy

submitting Environmental

statement From V to GPCB

every year through online

XGN web site.

17 The project

proponent shall

inform the public

that the project has

been accorded

environmental

clearance by the

Ministry and copies

of the clearance

letter are available

with the

SPCB/Committee

and may also be

Advertisement for the environment clearance for the project

proponent has been circulated in the vernacular language of

the locality concerned and the copy of the same

has been forwarded to the Ministry’s Regional office. (Please

find Annexure –Q)(Attached in hard copy)



COMPLIED

seen at Website of

the Ministry at http://envfor.nic.in.This

shall be advertised

within seven days

from the date of

issue of the

clearance letter, at

least in two local

newspapers that

are widely

circulated in the

region of which one

shall be in the

vernacular language

of the locality

concerned and a

copy of the same

shall be forwarded

to the concerned

Regional Office of

the Ministry.

18 The project

authorities shall

inform the Regional

Office as well as the

Ministry, the date of

financial closure

and final approval

of the project by

the concerned

authorities and the

date of start of the

project.

We have completed and commissioned our expansion project

in the month of March 2015 and informed to the GPCB.



complied.

PARTLY COMPLIED


copy of online application

for CCA on GPCB XGN site

after commissioned our

expansion project.

SUMMARY NOTE:

i. Implementation of Conditions:

Out of 48 total conditions, it may be seen that 24 are complied, 7 are compiled

subject to acceptance of monitored data by MoEF & CC, New Delhi, 10 are

compiled subject to condition, 6 are partly complied, 1 is compliance not

applicable to PP. These have been explained in the foregoing compliance report

against each of the condition, and the PP needs to take necessary and time

bound action for early compliance in respect of the relevant conditions and the

general observations mentioned below.

ii. General observations:

During the site visit, it is observed that housekeeping is poor in the hazardous

waste storage area and adequate steps shall be taken to improve the same.

Greenbelt is found in patches along the plant periphery and is inadequate.

PP shall install online effluent monitoring system to monitor the treated effluent

reaching GIDC effluent discharge pipeline in accordance with recent directions

of CPCB to similar industries.

iii. Court Cases and show cause/ closer notices:

PP vide e-mail dated 31.08.2017 submitted that there are no court case

pending against the project.

PP also submitted that 4 show cause notices have been issued by GPCB over the

past 03 years, the details of which are as furnished below:

Sr.

No.

Show cause Date SCN/DIR notice query SCN/DIR Compliance Reply

Storm water drainage is used for

industrial waste water (Various plant

to ETP).

Storm water drainage will be used for

storm water only.

Incinerator – not in use. Specific product is not produced.

Approx 200 drums for in process

material are kept at different open

places. Contaminated liners are kept

in open space.

The plant was under stabilization. The

non-conforming process material was

kept outside for reprocessing. The said

drums has been shifted back to plant &

processed. The area has been cleared.

Contaminated liners have been off as

per GPCB guidelines.

Hazy small felt near plant-2 from

drums stored in open space.

We will float inquiries; offer the same

for installing deodorant system in due

course.

1. BRCH-B-CCA-

109(3)/ID-

35422/357083/25-

05-2016

Vent line found on the floor at

ground level of chlorination scrubber

for sulphentrazone reactor.

Modification work has been completed &

installed as desired.

Online monitoring system, not

installed on scrubber and boiler

stack.

We will float inquiries and offer for the

same for installation in due course.

Approx 100 MT of MEE and ETP salt,

stored in Hazardous waste yard and

approx 100 MT of MEE salt filled in

open bag are kept in open space.

We have disposed MEE and ETP salt

approx 150 MT in BEIL Dahej. And

further generated solid waste is being

regularly disposed off to BEIL.

Poor housekeeping found in plant

premises.

Housekeeping improved.

(Please find Annexure –B)(Attached

in hard copy)

MEE &

Incinerator are

not Running.

The plant is operating at low

capacity as it is under

stabilization. The effluent

from plant is collected and

once it around 300 kl. We

start MEE and treat it.

Specific product is not

produced to running

Incinerator.

We have started operating

the plant on daily basis as

per the quantity of effluent

received, from the plant. The

MEE condensate effluent is

further taken to biological

system for further treatment.

Complied with immediate

effect. MEE operational data

is attached herewith.

Color water is

observed back

site of ETP,

Incinerator and

hazardous

waste storage

area. .

The water collected in the low

lying area is rain water, which

has been collected and

returned to ETP will be

completed and is being

monitored on regular basis.

The low lying area and

depressed open land area is

being levelled to stop rain

water accumulation. We will

be overcoming the problem.

Completion time 25th of

OCT.

Smell of VOC is

felt.

The environment monitoring

is scheduled and has started

based on the frequency of the

monitoring. The report of

VOC analysis at various

location is attached.

Further to this we are

installing heat exchanger at

places of solvent recovery

with potential losses so that

we can minimize loses and

getting the VOC to a

minimum. Completion by

10th NOV.

Hazardous

waste storage

area wall is

found cracked

and leachate is

spillage on

ground.

Hazardous waste storage

area wall is repaired and

leachates are collect and treat

it on regular basis.

The repairing work of the

wall and leachate collection

pit has been further

improved upon to ensure

zero seepage and leakage.

Completed.

2. BRCH-B-CCA-

109(3)/ID-

35422/371747/01-

10-2016

Modify vent line

of D V Acid

chloride

scrubber in

plant which are

not proper

height, and SMF

SMF will take place and

modify vent line of D V Acid

chloride scrubber as per

GPCB guideline.

The system of SMF has

installed and completed.

Ready for sampling purpose.

Completed.

is not installed.

Huge amount of

in process

drums &

residue drums

are found on

open land near

Incinerator

area.

We have already started

shifting the in process drums

for processing & residue are

disposed in RSPL/ GSPL as

per PCB guideline.

As communicated earlier the

in process material has been

generated during process

stabilization. The material

has salvage value, hence

stored in the yard. We have

made a temporary closed

shed to store the material,

will be completed by 17th of

Oct. Meanwhile at the same

time we have are taking back

the material for

reprocessing. We will clear

by November 2016.

Approximately

200 MT of acidic

salt is stored in

storage yard

behind

hydrogenation

unit. Acidic

leachate is

found inside of

storage yard.

The salt stored in the yard is

of sodium sulphate. The same

will be processed and sold to

end user. The leachate is rain

water ingression due to

leakage roof, which has been

collected and returned to ETP

and is being monitored on

regular basis.

We are ensuring the leachate

is collected neutralized and

taken to ETP for further

treatment. The salt will be

reprocessed and sold to end

user. We request the board

to give us time December

2016.

(Please find Annexure –

C)(Attached in hard copy)

VOC odor felt within premises. We have ensured corrective measures on

recoveries of solvent as part of reduction of

VOC. Please find attached the report of the

routine third party monitoring for your kind

perusal.

Incinerator observed not in

operation.

The incinerator installed is meant for off

gases & is product specific.

Presently the off gases related to the specific

production is out of production line. Hence,

the incinerator was not under operation.

However, we ensure the equipments is well

maintained and operatable at any moment

of time.

Housekeeping observed poor

near Incinerator and

Hydrogenation plant.

Please find the attached snaps of the site

mentioned.

3. BRCH-B-CCA-

109(3)/ID-

35422/401395/17-

01-2017

@ 150 MT to 200 MT MEE salt

observed stored in Hazardous

waste storage area.

Disposal of MEE salt to BEIL Dahej& SEPPL

Bhachau is going on. Please find the

attached manifest copy.

(Please find Annexure –D)(Attached in

hard copy)

4. BRCH-B-CCA-

109(3)/ID-

Large number of In process

filled material and contaminated

At present not any contaminated drum

stored on open land and Filled drums are our

35422/405027/22-

02-2017

drums stored on the open land. process material, and its shifting in plant for

processing will be completed.

Acid proof break line was found

crake in High COD waste water

underground drainage line.

Acid proof brick line chamber repairing work

is in progress.

Online pollution monitoring

system for process stack & Fuel

gas stack is not installed.

We have initiated the process of calling in

the offers, will be finalized.

Height of the process vent line

of Plant 2 to be increased and

arrangement for sample

collection platform to be done.

Modification work is completed.

Sample point is not given at

outside of the premises in GIDC

drainage line.

GIDC drainage chamber has not been

provided outside our factory premises; the

only drainage chamber available outside

BEIL premises, GIDC has connection of

effluent discharge line to the chamber

provided at BEIL. Therefore we can not to

discharge effluent by space gravity & install

sample point.

Further to this we would like to keep you

posted that we have requested to GIDC vide

letter dtd. 12/10/2015 and 31/01/2017

&27/02/2017 to provide a drainage chamber

outside our premises. & been regularly

following up with GIDC officer for the same.

(Please find Annexure –E)(Attached in

hard copy)

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