1 April 2013 Compliance Status Report of Environmental Clearance No. J 11011/257/2008 IA II (I) dated 23/11/2010 Sub: Expansion of Organometallic Products/Other Synthetic Organic Chemicals Manufacturing Unit at Village Mujpur, Taluka Padra, District Vadodara, Gujarat by M/s. Gulbrandsen Chemicals Pvt Ltd. Environmental Clearance 2.0 The Ministry of Environment & Forest has examined the application. It is noted that Organometallic Products/Other Synthetic Organic Chemicals Manufacturing unit at Village Mujpur, Taluka Padra, Districe Vadodara, Gujarat. Project Cost is Rs Crores. Total land area of the existing plant is m 2 and an additional area requirement for proposed expansion will be 1903 m 2.
2 COMPLIANCE STATUS REPORT OF ENVIRONMENT CLEARANCE F.NO.:J-11011/257/2008-IAII (I) Condition Description No. 3.0 Venturi caustic scrubber packed column type scrubber shall be provided to anhydrous aluminum chloride (Anhydrous AlCl3) and Tin tetra chloride (TTC) plant to collect un-reacted fumes of anhydrous aluminum chloride, TTC and Chlorine gas. Ammonical stripping system for removal of dissolve Ammonical Nitrogen and packed column with caustic spray system for removal of acidic fumes shall be provided to Organometallic production plant. A flare system will be provided to control accidental release of gaseous system, in which flammable gases will be routed through oil quenching system. Stacks of adequate height will be provided to the proposed units. Total ground water requirement will be increased from 121 m3/day (existing) to 358 m3/day after expansion. Effluent generation will be KLD after expansion. Effluent treatment plant (ETP) is installed for treatment of effluent and will be further augmented to cater the treatment of additional effluent after expansion. Treated effluent will be dispose off into CETP, Umraya through tankers. Domestic sewage will be treated in membrane bioreactor (MBR) based STP (30 KLD). Waste/Residue containing oil, spent solvent and used oil will be sold to the recycler. Distillation residue and oil contaminated waste will be incinerated. Chemical Sludge from wastewater treatment/etp, sludge from scrubber, spill control powder and waste refractory will be disposed off by land filling. 4.0 The Public Hearing of the project was held on 26th May The synthetic organic chemical (Bulk Drugs and Intermediates) manufacturing units located outside the notified industrial areas are listed at S. No. 5 (f) of schedule of EIA Notification, 2006 under A category and apprised at central level. 6.0 The proposal was considered by the Expert Appraisal Committee (Industry-2) in 1 st, 7 th and 14 th meeting held during 24 th -25 th July 2009, 15 th -16 th January 2010 and 16 th - 17 th September 2010 respectively. The Committee recommended the proposal for environmental clearance. 7.0 Based on the information submitted by the project proponent, The Ministry of Environment & Forest herby accords environmental clearance to above project under the provisions of EIA Notification dated 14 th September, Compliance Status. Total water requirement after proposed expansion will not exceed 358 m3/day and total waste water generation after proposed expansion will not exceed KLD.
3 A i ii iii iv v SPECIFIC CONDITIONS Efforts shall be made to reduce RSPM levels in the ambient air and a time bound action plan shall be submitted. At no time, the emission levels shall go beyond the prescribed standards. In the event of failure of any pollution control system adopted by the unit, the respective unit shall not be restarted until the control measures are rectified to achieve the desired efficiency. Ambient air quality data shall be collected as per NAAQES standards issued by the Ministry vide G.S.R. No. 826(E) dated 16 th November, On-line monitoring of Cl2 shall be ensured. Venturi caustic scrubber packed column type scrubber shall be provided to anhydrous aluminum chloride and Tin tetra chloride plant to collect un-reacted fumes of anhydrous aluminum chloride, TTC and Chlorine gas. Ammonical stripping system for removal of dissolve Ammonical Nitrogen and packed column with caustic spray system for removal of acidic fumes shall be provided to Organometallic production plant. Caustic scrubber packed column type scrubber shall be provided to collect un reacted fumes. A dedicated emergency Chlorine scrubber along with proper suction arrangement shall be installed separately to handle emergency situation in case of leakage from Chlorine cylinder. Fugitive emissions shall be controlled by providing closed storage, closed handling & conveyance of chemicals/materials, 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. All the proposed products shall be handled in closed circuit. Fugitive emissions in the work zone environment, product, raw materials storage area etc. shall be regularly monitored. The emissions shall conform to the limits prescribed by the GPCB. A flare system shall be provided to control accidental release of gaseous system and all the flammable gases shall be routed through quenching system. For further control of fugitive emission, following steps shall be followed : a. Closed handling system shall be provided for chemicals. b. Reflux condenser shall be provided over reactor. c. System of leak detection and repair of pump/pipeline based on preventive maintenance. The emission level of all parameters is within the prescribed standard as per National Ambient Air Quality Standards.. Online monitoring system for monitoring of HCl & Cl2 has been installed... On regular basis, work area environmental monitoring is being carried out. Distillation columns are connected with Reflux Condenser.
4 vi d. 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. e. Cathodic protection shall be provided to the underground solvent storage tanks. Stacks of adequate height shall be provided to the boiler, thermic fluid heaters, DG sets, process vents and flare stack respectively as per CPCB/GPCB standards. Acoustic enclosure shall be provided to the DG sets to mitigate the noise pollution. Acid storage tanks vents are connected with scrubber system.. All stack heights are as per CPCB/GPCB standards. Provision of Acoustic Enclosure has been done to DG sets to mitigate noise pollution. vii 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 State Pollution Control Board. The levels of SPM, RSPM, SO2, NOx, HCl and VOC 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. viii Solvent management shall be as follows : ix a. Reactor shall be connected to chilled brine condenser system b. Reactor and solvent handling pumps shall have mechanical seals to prevent leakages. c. The condensers shall be provided with sufficient HTA and residence time so as to achieve more than 95% recovery d. Solvents shall be stored in a separate space specified with all safety measures. e. Proper earthing shall be provided in all the electrical equipment wherever solvent handling is done. f. Entire plant shall be flame proof. The solvent storage tanks shall be provided with breather valve to prevent losses. Total ground water requirement shall not exceed 358 KLD after expansion and prior permission for the withdrawal of Status of compliance report has been submitted at every six months to Regional Office, MoEF, Zonal office CPCB and State Pollution Control Board. Same will be posted on Company s website. Chilled water condenser system has been provided as and when required... Provision of flameproof fittings has been done in flammable chemicals handling area. Total ground water requirement
5 x xi xii ground water shall be obtained from CGWA/SGWB. Total effluent generation shall not increase KLD after expansion and properly treated in the ETP and shall meet the CETP inlet norms specified by the Gujarat Pollution Control Board. Low volume & high COD/TDS wastewater shall be concentrated in multi-effect evaporator (MEE) followed by incinerator to achieve Zero discharge. However high volume & low COD/TDS effluent shall be treated in ETP and discharged to CETP after confirming to the standards prescribed for inlet norms for the CETP. Treated effluent shall be disposed off into CETP, Umraya only after obtaining prior permission from the GPCB. Membership to M/s Enviro-Infrastructure Co. Ltd. for the disposal of treated effluent shall be obtained and a copy submitted to the Ministry s Regional Office at Bhopal. Domestic sewage shall be treated in membrane bioreactor based sewage treatment plant (STP). Distillation residue and oil contaminated waste shall be incinerated. Chemical sludge from wastewater treatment/etp, sludge from scrubber, spill control powder and waste refractory shall be disposed by land filling. The process product mix shall be reused in process. Membership for the disposal of solid/hazardous waste shall be obtained from M/s Nandesari Environment Control Ltd. and a copy submitted to the Ministry s Regional Office at Bhopal. Waste/residue containing oil, spent solvent and used oil shall be sold to the authorized recyclers only. High calorific organic residues shall be sent to cement industries for burning in the kiln or disposed off to nearby TSDF site. The Company shall obtain Authorization for collection, storage and disposal of hazardous waste under the Hazardous Waste (Management, Handling and Trans boundary Movement) Rules, 2008 as amended time to time shall not exceed 358 KLD after expansion. As per categorization of critical zone, Padra region does not fall in critical zone. Total effluent generation shall not increase KLD after expansion. Gulbrandsen is member of EICL for disposal of treated effluent and copy of membership has been submitted at MoEf, Regional Office, Bhopal. Domestic effluent has been treated in membrane bioreactor based sewage treatment plant.. Copy of membership certificate of M/s. NECL, M/s. BEIL and M/s. GEPIL are enclosed herewith as an Annexure. Our organic residue waste is not meeting the criteria for disposal as co processing purpose and therefore it has been incinerated at common TSDF facility. Company has valid CC & A for disposal of hazardous waste vide CC & A order
6 for management of hazardous wastes and prior permission from GPCB shall be obtained for disposal of solid / hazardous waste in the TSDF. The concerned company shall undertake measures for fire fighting facilities in case of emergency xiii The project authorities shall strictly comply with the rules and guidelines under Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989 as amended in October, 1994 and January, All Transportation of Hazardous Chemicals shall be as per the MVA, xiv Hazardous chemicals shall be stored in tanks, drums, carboys etc. Flame arresters shall be provided on tank farm. Solvent transfer shall be done by pumps. xv During transfer of materials, spillages shall be avoided and garland drains be constructed to avoid mixing of accidental spillages with domestic waste and storm drains. xvi A written commitment regarding safe handling of Cl2 shall be obtained, if transportation of Cl2 from supplier to project premise is done by the supplier. Risk assessment due to handling of Cl2 storage and usage shall be carried out and accordingly mitigation measures shall be adopted. xvii The company shall undertake following waste minimization measures :- xviii xix xx a. Metering and control of quantities of active ingredients to minimize waste. b. Reuse of by-products from the process as raw materials or as raw material substitutes in other processes. c. Use of automated filling to minimize spillage. d. Use of close feed system into batch reactors. e. Venting equipment through vapour recovery system. f. Use of high pressure hoses for equipment clearing to reduce wastewater generation. The unit shall make the arrangement for protection of possible fire hazards during manufacturing process in material handling. Fire fighting system shall be as per the OISD 117 norms. Training shall be imparted to all employees on safety and health aspects of chemical 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. Occupational health surveillance of the workers shall be done on a regular basis and records maintained as per the Factories Act. Green belt shall be developed in 33 % of the plant area. Selection of plant species shall be as per the CPCB guidelines. no which is valid up to Company takes all necessary precautions like reduction of no. of washes in the process, reuse of blow down of cooling tower as scrubber solution etc. to minimize the waste. At present m2 area is covered under green belt.
7 xxi xxii xxiii B i ii iii iv v The company shall comply with the recommendations made in the EIA/EMP/Risk assessment report. Risk assessment shall be included in the safety Manual. Provision shall be made for the housing for the construction labour 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, crèche 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. All the commitments made to the public during the Public Hearing / Public Consultation meeting held on 26 th May, 2009 shall be satisfactorily implemented. GENERAL CONDITIONS The project authorities shall strictly adhere to the stipulations made by the Gujarat Pollution Control Board. No further expansion or modifications in the plant shall be carried out without prior approval of the Ministry of 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. The locations of ambient air quality monitoring stations shall be decided in consultation with the State Pollution Control Board (SPCB) and it shall be ensured that at least one stations is installed in the upwind and downwind direction as well as where maximum ground level concentrations are anticipated. The overall noise levels in and around the plant area shall be kept well within the standards by 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). The Company shall harvest rainwater from the roof tops of the buildings and storm water drains to recharge the Company shall plant more saplings in and around plant area to fulfill the green belt development requirement.. Temporary labours are involved for the construction of project activities and they are hired from nearby villages. Proper sanitation facility has been made available to the labours. Present ambient air quality monitoring stations locations are decided in consultation with GPCB authority.. Being a chemical company, we shall
8 ground water and use the same water for the process activities of the project to conserve fresh water. vi Usage of Personnel Protection Equipments (PPEs) by all employees/ workers shall be ensured. vii Occupational health surveillance of the workers shall be done on a regular basis and records maintained as per the Factories Act. viii The company shall also comply with all the environmental protection measures and safeguards proposed in the documents 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. ix The company shall undertake all relevant measures for improving the socio-economic conditions of the surrounding area. CSR activities shall be undertaken by involving local villages and administration. x The company shall undertake eco-developmental measures including community welfare measures in the project area for the overall improvement of the environment. xi A separate Environmental Management Cell equipped with full fledged laboratory facilities shall be set up to carry out the Environmental Management and Monitoring functions. xii The company shall earmark adequate funds 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. xiii A copy of the clearance letter shall be sent by the project proponent to concerned Panchayat, Zila Parisad/Municipal Corporation, Urban local Body and the local NGO, if any, from who suggestions/ representations, if any, were received while processing the proposal. xiv 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 ) 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 explore to recharge the ground water by rain water harvesting system through third party expert report and based on expert report, it shall be implemented.. Status of compliance report has been submitted at every six months to Regional Office, MoEF, Zonal office CPCB and State Pollution Control
9 website of the company. xv The environmental statement for each financial year ending 31 st March in Form-V as is mandated shall be submitted to the concerned State 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 respective Regional Offices of MoEF by . xvi 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 seen at Website of the Ministry at 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. xvii 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. 8.0 The Ministry may revoke or suspend the clearance, if implementation of any of the above conditions is not satisfactory. 9.0 The Ministry reserves the right to stipulate additional conditions, if found necessary. The company in a time bound manner will implement these conditions Any appeal against this environment clearance shall lie with the National Environment Appellate Authority, if preferred within a period of 30 days as prescribed under Section 11 of the National Environment Appellate Authority Act, The above conditions will enforced, inter alia under the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981 the Environment (Protection) Act, 1986, Hazardous Wastes (Management and Handling) Rules, 1989/2003/2008 and the Public Liability Insurance Act, 1991 along with their amendments and rules. Board. Same will be posted on Company s website. Environmental Statement for each financial year has been submitted to State Pollution Control Board and MoEF, Regional Office, Bhopal. The clearance letter copy was advertised in two local news papers. Not applicable as proposed expansion is related to existing unit.