EC COMPLIANCE REPORT

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Derek Lester
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1 EC COMPLIANCE REPORT Monitoring period April 2018 to September 2018 M/s. Om Titanates Plot no. C-1/B-2805, GIDC- Sarigam , Ta.: Umbergaon, Dist.: Valsad, Gujarat EC Granted vide F. No. J-11011/186/2012-IA-II (I), Dated 16/05/2015.

2 Compliance Status of Environmental Clearance of M/s Om Titanates General / Specific Conditions for the period April-2018 to September Ref: F. No. J-11011/186/2012-IA-II (I) and EC granted vide letter dated 16/05/2015. Sr. EC Condition No 2.0 The Ministry of Environment, Forests and Climate Change has examined the application. It is noted that the proposal is for expansion of Synthetic Organic Chemical manufacturing unit at Plot Nos.C- 1-B/2805 & 2806, GIDC, Sarigam, District Valsad, Gujarat by M/s Om Titanates. Total plot area is 1406 m 2. Total cost of project is Rs Lakhs. Damanganga canal, river Darotha and River Damanganga is flowing at a distance of 10 km. Following products will be manufactured.- S. No. Name of the Product 1. Tetra Butyl Titanate 2. Tetra Iso Propyl Titanate 3. TPT 20 B 4. Tetra 2- Ethyl Hexyl Titanate Blendin 5. Titanium Acetyl g Acetonate 6. Ethyl Titanate 7. Di-isopropyl ethyl amine 8. Ammonium Choride 9. Sodium/potassium Total Quantity (MT/M) Existing Propose Scenari d o Scenario Nil Nil 22 Ethyl Sulphate Total Scrubber will be provided to control process emission viz. Ammonia & HCl. Total fresh water requirement from GIDC water supply will be increased from 4 m 3 /day to 13.5 m 3 /day after expansion. Compliance Status We agree with the terms & conditions imposed herein. We have same production capacity as mentioned in EC conditions. Month Production Details Monthly production (T/Month) Titaniu Total Ammoniu m m Acetyl Chloride Aceton ate Tetra Isopropyl Titanate April May June July Aug Sept Total There is no process gas emission from the manufacturing process. Provision of water + Alkali scrubber is made to take care of any accidental release of ammonia & HCl. The water requirement for the project is met by the GIDC supply available at the site. GIDC Water supply bill of September 18 is attached as Annexure-2. Water consumption data for the period of April 18 to September 18 is given below.

3 Sr. No EC Condition Total industrial effluent generation will be 1 m 3 /day after proposed expansion from boiler blow down. Effluent will be treated in the effluent treatment plant (ETP) and treated effluent will be used for toilet flushing. Sewage will be treated in STP and treated sewage will be reused for horticulture purpose. Waste oil and used batteries will be sold to authorized recyclers/re-processors. After proposed expansion project, Ammonium chloride will be added as product in product list & will be sold as product. Public hearing was exempted as per section 7 (i), (iii) Stage (3), Para (i) (b) of EIA Notification, All synthetic organic chemical industries located inside the notified industrial estate/area are listed at S.N. 5(f) under category 'B' and appraised at State level. Due to applicability of general condition (i.e. interstate boundary within 10 Km), project proposal is treated as category 'A' project and appraised at Central Level. The proposal was considered by the Expert Appraisal Committee (Industry) in its 3rd and 34 th meetings held during 3rd - 5th December, 2012 and 1th~ 19thFebruary, 2015 respectively. Proponent and the EIA Consultant namely M/s Precitech Laboratories Pvt. Ltd., have presented EIA / EMP report as per the TOR. EAC has found the EIA/EMP Report and additional information to be satisfactory and in full consonance with the presented TORs. The Committee recommended the proposal for environmental clearance. Based on the information submitted by the project proponent, the Ministry of Environment, Forest and Climate Change hereby accords environmental clearance to above project under the provisions of EIA Notification dated 14 th September 2006, subject to the compliance of the following Specific and General Conditions: Compliance Status Month Monthly Water Consumption Approx. Water consumptio n per Day April May June July Aug Sep TOTAL There is no waste water generation from the manufacturing process. Industrial effluent only generated as cooling tower blow down, and scrubber water which is evaporated in in-house evaporator.the unit is a zero discharge unit. Domestic KLD is being disposed through septic tank/ soak pit. Ammonium chloride is added as product in product list and sold as product

4 Sr. No EC Condition A. SPECIFIC CONDITIONS i. National Emission Standards for Organic Chemicals Manufacturing Industry issued by the Ministry vide G.S.R. 608(E) dated 21st July, 2010 and amended time to time shall be followed by the unit. Compliance Status The condition is being complied as per laid condition for unit. Stack monitoring is done by NABL accredited M/s Precitech Laboratories Pvt. Ltd. Please find herewith Stack air monitoring report for existing unit attached as Annexure-3. Summary of stack monitoring report is provide below. ii. iii. Scrubber shall be provided to control process emission viz. Ammonia & HCI. The scrubbed water should be sent to ETP for further treatment. Efficiency of scrubber shall be monitored regularly and maintained properly. Scrubbers vent shall be provided with on-line 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 should be interlocked with the pollution control equipments so that in case of any increase in pollutants beyond permissible limits, plant should be automatically stopped. Ambient air quality data shall be collected as per NAAQES standards notified by the Ministry vide G.S.R. No. 826(E) dated 16 th September, The levels of PM10, S02, NOx, CO, HCI and VOC shall be monitored in the ambient air and displayed at a convenient location near the main gate of the company and at important public places. The company shall upload the 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 GPCB. All necessary steps should be taken for monitoring of chlorine and HCI as well as VOCs in the proposed plant. Stack Monitoring Summary No. Parameter Unit Limit Thermopac MIN. MAX. 3 PM mg/nm SOx ppm NOx ppm Monitoring dates: 24/04/2018, 18/07/2018 There is no process gas emission from the manufacturing process. Provision of water + alkali scrubber is made to take care of any accidental release of ammonia & HCl. Hence, on-line detection system is not required. Regular process stack monitoring is being carried out. Please refer Annexure-3 for Stack Monitoring Report. Summary of stack monitoring report is given below. Stack Monitoring Summary No. Parameter Unit Limit Scrubber MIN. MAX. 3 HCl mg/nm NH3 mg/nm Monitoring dates: 24/04/2018, 18/07/2018 Regular Ambient Air quality monitoring is carried out for unit. Natural Gas is used as fuel and hence CO is not monitored. Please find herewith Display board photograph is attached as Annexure-13. Monitoring report of Ambient Air is submitted as a part of six monthly compliance report to Regional office of MOEF, the respective Zonal office of CPCB and GPCB. status on Company s website. HCl and VOC are monitored. Chlorine is not monitored as there is no source of Chlorine generation. Please find herewith ambient air quality monitoring report for existing unit is attached as Annexure-4. Summary of air

5 Sr. No EC Condition Compliance Status monitoring report is provided below. iv. Ambient Air Monitoring Summary No. Parameter Unit Limit Near Security Gate Backside of the Plant MIN. MAX. MIN. MAX. 1 PM10 µg/m PM2.5 µg/m SOx µg/m NOx µg/m NH3 µg/m BDL 6 BDL 4 6 HCl µg/m BDL BDL BDL BDL 7 TVOC ppm -- BDL BDL BDL BDL BDL = Below Detection Limit Monitoring Date: 24/04/2018, 18/07/2018 In plant control measures for checking fugitive emissions from all the vulnerable sources shall be provided. Fugitive emissions from all the vulnerable sources are provided. 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. Fugitive emissions in the work zone environment, product, raw materials storage area etc. shall be regularly monitored. Most of the Raw materials and the products are liquid. Hence, multicyclone separator and water sprinkling system is not required. Closed handling system is provided in plant. Underground Storage tanks are provided for IPA & Hexane. Raw Materials & Products are stored in closed containers and ventilated storage area. Raw-material feeding carried out by vacuum pump. Regular monitoring is done of piping and fittings for checking of any leakages. Good housekeeping maintained in the plant. Please find herewith work place monitoring report for existing unit is attached as Annexure 5. Summary of Workplace monitoring report is provided below. v. For further control of fugitive emissions, 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 Workplace Monitoring Summary No. Parameter Unit Limit Inside Plant Results 1 n- Butanol mg/m NH3 mg/m n-hexane mg/m Ethanol mg/m Monitoring Date: 24/04/2018, 18/07/2018 Complied with. a) Raw-material feeding carried out by vacuum pump. b) Reflux condenser is provided over reactor. c) Regular monitoring is done of piping and

6 Sr. No vi. vii. viii. ix. EC Condition pump/pipeline based on preventive maintenance. 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. The gaseous emissions from DG set shall be dispersed through adequate stack height as per CPCB standards. Acoustic enclosure shall be provided to the DG sets to mitigate the noise pollution. Fresh water requirement from GIDC water supply should not exceed 13.5 m3/day. No ground water shall be used. Trade effluent should be treated in ETP. Sewage shall be treated in the STP. 'Zero' effluent discharge should be adopted, and no effluent will be discharged outside the premises. Online monitoring (24x7) for ph and TOC may be conducted within the plant. Process effluent/any wastewater shall not be allowed to mix with storm water. Storm water drain shall be passed through guard pond. Compliance Status fittings for checking of any leakages. d) Only IPA & Hexane are stored in underground tank and other raw materials are stored in drums in designated storage area. Raw-material feeding is carried out through closed pipeline. e) All underground pipe and raw water tanks are provided with Cathodic protection. Complied with. Stack height of DG set as per CPCB standards. Acoustic enclosure is provided to the DG sets to mitigate the noise pollution. We are carrying out the stack monitoring on regular intervals. The stack monitoring report is attached as Annexure-3. Summary of stack monitoring report is provided in specific condition no. i. Complied with. GIDC water bill is provided in condition no. 3. Water consumption detail is given below. Month Monthly Water Consumption Approx. Water consumptio n per Day April May June July Aug Sep TOTAL There is no waste water generation from the manufacturing process. Industrial effluent only generated as cooling tower blow down, and scrubber water which is evaporated in in-house evaporator. The unit is a zero-discharge unit. Hence, online monitoring system not installed. Domestic KLD is being disposed through septic tank/ soak pit Complied with. There is no waste water generation from the manufacturing process. Industrial effluent only generated as cooling tower blow down, and scrubber water which is evaporated in in house evaporator. The unit is a zero-discharge unit. Separate storm water drainage is provided within the plant premises.

7 Sr. EC Condition No x. 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 and amended 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. Compliance Status We have obtained CC&A from GPCB, copy of the same is attached as Annexure-1. xi. Measures shall be taken for firefighting facilities in case of emergency. The Company shall strictly comply with the rules and guidelines under Manufacture, Storage and Import of Hazardous Chemicals (MSIHC) Rules, 1989 as amended time to time. All Transportation of Hazardous Chemicals shall be as per the Motor Vehicle Act (MVA), Adequate measures are taken for firefighting facilities. The firefighting detail is attached as Annexure-6. The storage and handling of the hazardous chemicals is done as per the MSIHC Rules, 1989 as amended time to time. All Transportation of Hazardous Chemicals are as per the Motor Vehicle Act (MVA), xii. Types of Waste Used oil Discarded containers/ Bags Source and Category Maintenance (5.1) Raw material cons. (33.3) Storage Method Stored in closed container Stored at a separate storage area The company shall undertake following waste minimization measures :- a. Metering and control of quantities of active ingredients to minimize waste. Method of Disposal Properly stored & sent to registered recycler. Same practices followed for additional qty. Properly stored & sent to Hindustan Enviro life production services Ltd, Kheda / Sold to authorized reconditioner/ reused for packing. Same practices followed for additional qty. Complied with. a. Metering arrangement for quantities of active ingredients is provided. xiii. 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 b. By-product ammonium chloride is being sold as product. c. Raw-material feeding is carried out by vacuum pump. d. Process is designed to operate with Closed feed system in reactors. e. Venting equipment is provided through vapour recovery system. f. Dedicated reactors are provided and no equipment washing is required. Noted. Complied with. Firefighting system are designed and

8 Sr. No xiv. EC Condition manufacturing process in material handling. Firefighting system shall be as per the norms. 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 should be undertaken on regular basis. Training to all employees on handling of chemicals should be imparted. Occupational health surveillance of the workers should be done on a regular basis and records maintained as per the Factories Act. xv. As proposed, green belt should be developed at least 160 m 2 area in and around the plant premises to mitigate the effects of fugitive emissions all around the plant as per the CPCB guidelines in consultation with DFO. xvi. AII the recommendations made in the risk assessment report should be satisfactorily implemented. xvii The Company shall submit within three months their policy towards Corporate Environment Responsibility which should inter-alia address (i) Standard operating process/procedure to being into focus any infringement/deviation/ violation of environmental or forest norms/conditions, (ii) Hierarchical system or Administrative order of the Company to deal with environmental issues and ensuring compliance to the environmental clearance conditions and (iii) System of reporting of non-compliance/violation environmental norms to the Board of Directors of the company and/or stakeholders or shareholders. B. GENERAL CONDITIONS i. The project authorities shall strictly adhere to the stipulations made by the Gujarat Pollution Control Board. ii. 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. Compliance Status installed as per prevailing rules & regulations List of Fire Extinguishers are attached as Annexure-6. Complied with. The training has been provided to employees. We are carrying out Occupational health surveillance of the workers on a regular basis and records of the same are maintained as per Factories Act. Please refer Annexure-7 for Medical Report. Please refer Annexure-8 for Safety Training Report. Plantation work has been gradually upgraded and plantation is done as per the CPCB guidelines. Photographs of existing Green belt is attached as Annexure-9. We have implemented all the recommendations made in the risk assessment report. An Environment management cell is in place & functioning well. Organogram of Environment management cell is attached as Annexure-10. We have obtained CC&A from the Gujarat Pollution Control Board and the copy of the same is attached as Annexure-1. We assure that no further expansion or modifications in the plant shall be carried out without prior approval of the Ministry of Environment and Forests

9 Sr. EC Condition No iii. 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.. iv. No. Paramete r Compliance Status Ambient air quality monitoring stations are identified within the company premises as per the State Pollution Control Board (SPCB) guidelines. AAQM is also carried out by GPCB & VIA in GIDC estate. Please refer Annexure-4 for Ambient Air Quality monitoring quarterly reports. Summary of Ambient Air monitoring is given below. Ambient Air Monitoring Summary Unit Limit Near Security Gate Backside of the Plant MIN. MAX. MIN. MAX. 1 PM 10 µg/m PM 2.5 µg/m SOx µg/m NOx µg/m NH 3 µg/m BDL 6 BDL 4 6 HCl µg/m BDL BDL BDL BDL 7 TVOC ppm -- BDL BDL BDL BDL BDL = Below Detection Limit Monitoring Date: 24/04/2018, 18/07/2018 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. 75dBA (daytime) and 70 dba (nighttime). Noise Monitoring Summary No. Parameter Day Time (75 db(a)) MIN. MAX. 1 Nr. Security Gate Nr. Cooling Tower Administration office Nr. Boiler House Plant Center East Side West Side South Side North Side Monitoring Dates: 24/04/2018, 18/07/2018 v. The Company shall harvest rain water from the rooftops of the buildings and storm water drain store charge the ground water and use the same water for the process activities of the project to conserve fresh water. Necessary mitigation measures has been implemented e.g. compressors are provided with silencers and kept in a closed building. The ambient noise levels conforms to the CPCB standards. The noise monitoring report is attached as Annexure-11. Summary of Noise monitoring is provided below. Since there is no permission of Bore well in GIDC we are not recharging the ground water. vi. Training shall be imparted to all employees The training is being provided to employees.

10 Sr. No vii. viii. ix. EC Condition 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. Usage of Personnel Protection Equipments (PPEs) by all employees/ workers shall be ensured. The company shall also comply with all the environmental protection measures and safe guards 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. The company shall under take 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 ecodevelopmental measures including community welfare measures in the project area for the overall improvement of the environment. xi. xii. xiii. A separate Environmental Management Cell equipped with full-fledged laboratory facilities shall be setup to carry out the Environmental Management and Monitoring functions. As proposed, the company shall earmark sufficient funds towards capital cost and 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. A copy of the clearance letter shall be sent by the project proponent to concerned Panchayat, ZilaParisad/ Municipal Corporation, Urban local Body and the local NGO, if any, from who suggestions/ representations, if any, were received While processing the proposal. Compliance Status We are carrying out Occupational health surveillance of the workers on a regular basis and records of the same are maintained as per Factories Act. Please refer Annexure-7 for Medical Report Please refer Annexure-8 for Safety Training Report The following PPE s are provided to the employees/workers: Safety Helmet Safety Shoes Hand gloves (cotton, leather, rubber) Safety Goggles Use of PPE s. The recommendations made in the EIA/EMP were included in the design and implemented for all plants which have been established. These include adequate stack height, ETP, zero liquid discharge etc. Complied with. Complied with. An Environment management cell is in place & functioning well. Organogram of Environment management cell is attached as Annexure-10. Funds earmarked towards capital cost was Rs Lakh and at present our recurring cost is around Rs Lakh for Oct 17 to March 18 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. Not Applicable, as our plant is located in GIDC Estate.

11 Sr. No xiv xv xvi EC Condition 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 report shall be posted on the website of the company. 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 . 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 SPCS/ 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. Compliance Status We are regularly submitted six monthly EC compliance report to the respective Regional Office of MoEF, the respective Zonal Office of CPCB and the Gujarat Pollution Control Board. Year Report Month Submission Date 2015 June-15 to Sept Oct-15 to March April-16 to Sept Oct-16 to March April-17 to Sept Oct-18 to March The environmental statement in Form-V is being submitted to the Regional Office of MoEF and GPCB. The Form V along with the status of compliance will be uploaded on company s website. Form V is attached as Annexure-12. We have already informed to the public through advertisement given in the local newspaper (Sandesh and Gujarat Samachar) dated 11/07/2015 that we have accorded environmental clearance by the Ministry and copies of clearance letter are available with the state Pollutions Control Board and may also be seen at website of the Ministry of Environmental and Forests at website of the Ministry of Environmental and Forests at The copy of advertisement is given below.

Sr. No EC Condition Compliance Status xvii The project authorities shall inform the Regional Office as well as the Ministry, the date of financial

0 The Ministry may revoke or suspend the clearance, if implementation of any of the above conditions is not satisfactory. 9.

The company in a time bound manner will implement these conditions. 10.

12 Sr. No EC Condition Compliance Status 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 The above conditions will be enforced, interalia under the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention &. Control of Water Pollution) Act, 1981, the Environment The project was started at 20/06/2015. We have obtained CC&A for the existing project. Please refer Annexure-1 for the CC&A

13 Sr. EC Condition No (Protection) Act, 1986, Hazardous Waste (Management, Handling and Transboundary Movement) Rules, 2008 and the Public Liability Insurance Act, 1991 along with their amendment sand rules Environment Clearance is issued to M/s OM Titanates for expansion of synthetic organic chemical manufacturing unit at Plot Nos. C- 1- B/280S&2806, GIDC, Sarigam, District Valsad, Gujarat. Compliance Status --

14 Annexure

15 Annexure- 1: CC&A Copy

18 CC&A Amendment