To The Member Secretary State Expert Appraisal Committee Paryavaran Bhavan Sector 10 A Gandhinagar

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1 March 18, 2019 BY HAND DELIVERY/RPAD To The Member Secretary State Expert Appraisal Committee Paryavaran Bhavan Sector 10 A Gandhinagar SUB.: APPLICATION FOR SUBMISSION OF ESSENTIAL DETAIL SOUGHT BY SEAC FOR UNIT LOCATED AT PLOT NO. D 2/CH/146, GIDC DAHEJ, TAL. VAGARA, DISTRICT: BHARUCH, GUJARAT OF M/S. ICON PHARMA CHEM REF.: 1. EDS BY SEAC Dated: 16/03/ PROPOSAL NO. SIA/GJ/IND2/32683/2014 Dated: 09/03/ File No. SEIAA/GUJ/EC/5(f)/216/2014 Dated: 11/09/2014 Dear Sir, This has reference to above mentioned subject matter. We got Environment Clearance issued by SEIAA, Gandhinagar, for the proposed project of M/s. ICON PHARMA CHEM Vide Letter No SEIAA/GUJ/EC/5(f)/216/2014 Dated: 11/09/2014. In this connection we are seeking amendment in above said Environment Clearance vide Proposal No. SIA/GJ/IND2/32683/2014 dated: 09/03/2019. EDS required by SEAC dated: 16/03/2019 Query: MoU for Sodium Sulphite & Spent HCl is not uploaded please upload and submit revised application. Reply: MoU for Sodium Sulphite & Spent HCl are attached as Annexure 8 in Form 1. We hope you would find the same in order and request your kind self to grant us amendment in EC Letter and oblige. Thanking you. Yours faithfully, Encl: 1. Form I & MoU as annexure 8

2 MoU for Sodium Sulphite

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5 MoU for HCl

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7 March 09, 2019 BY HAND DELIVERY/RPAD To The Member Secretary State Expert Appraisal Committee Paryavaran Bhavan Sector 10 A Gandhinagar SUB.: APPLICATION FOR AMENDMENT IN EC LETTER FOR CHANGE IN MODE OF DISPOSAL OF INDUSTRIAL EFFLUENT, CHANGES IN AIR EMISSION & CHANGES IN HAZARDOUS WASTE IN EXISTING ENVIRONMENT CLEARANCE FOR UNIT LOCATED AT PLOT NO. D 2/CH/146, GIDC DAHEJ, TAL. VAGARA, DISTRICT: BHARUCH, GUJARAT OF M/S. ICON PHARMA CHEM REF.: File No. SEIAA/GUJ/EC/5(f)/216/2014 Dated: 11/09/2014 Dear Sir, This has reference to above mentioned subject matter. We got Environment Clearance issued by SEIAA, Gandhinagar, for the proposed project of M/s. ICON PHARMA CHEM Vide Letter No SEIAA/GUJ/EC/5(f)/216/2014 Dated: 11/09/2014. (Please refer Annexure I). In this connection we are seeking amendment in above said Environment Clearance for following conditions Under Water Act As per EC Condition No. A2. WATER As per Condition No. 5: Entire quantity of effluent shall be evaporated with the help of Multiple Effect Evaporator after primary treatment. Condensate water will be reused back in scrubber, cooling tower & boiler. As per Condition No. 7: No effluent from the plant shall be discharged outside the factory premises and Zero effluent discharge concept shall be followed. As per Amendment We are applying for EC Amendment to obtain discharge permission from SEAC i.e. change in mode of disposal of Industrial effluent, In this regard we already have booked hydraulic KLD of CETP. (M/s. GIDC Dahej) (Membership Certificate is given below )

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9 DETAILS REGARDING PROPOSED CHANGES ARE FURNISHED AS UNDER Sr. Condition no. no. in which Amendment is proposed. As per EC As per proposed amendment Justification 1 A.2 WATER Effluent will be treated in Solvent Stripper & ETP CONDITION within premises. & treated waste water will be sent Entire quantity of effluent shall be evaporated 5.0 to CETP (GIDC Dahej) with the help of Multiple Effect Evaporator after primary treatment. Condensate water will be reused back in scrubber, cooling tower & boiler. Total Industrial waste water: 9.0 KLD (Process 7.0 KLD + Utility 2.0 KLD ) 2 CONDITION NO. 7 No effluent from the plant shall be discharged outside the factory premises and Zero effluent discharge concept shall be followed. Process effluent: Concentrated effluent from process 7.0 KLD will be subjected to in house Solvent Stripper KLD recovered solvent reuse in process. Unit is having booked hydraulic KLD of CETP (GIDC Dahej) Total waste water from 7.0 KLD will be subjected to Solvent Stripper for removal of organic load. Unit will be having Adequate ETP for treatment of combined effluent. ETP will be having primary, Secondary units for condensate & utility section that will be discharged in CETP (M/s. GIDC Dahej) KLD Organic Residue will be sent to cement industry for co processing or send to CHWIF. 6.8 KLD from steam stripper along with dilute stream (Washing & Boiler/cooling blow 2.0 KLD) total 8.8 KLD will be allowed in ETP comprising of primary & secondary units finally sent to CETP (M/s. GIDC Dahej) after achieving CETP inlet norms. For Characteristics of effluent & Treatment Facility Please refer Annexure 4

10 A.3 AIR CONDITION NO Unit shall provide adequate APCM with process gas generation sources as mentioned below Sr. no. 1 2 Specific Source of emission (Name of the Product & Process) Reaction vessel 1 Process Vent 2 Type of emiss ion SO 2 Stack/ Vent Height/ Dia (meter) 10 m/0.3 m HCl 11 m/0.3 m Air Pollution Control Measures (APCM) Alkali Scrubber & Water Scrubber Alkali Scrubber & Water Scrubber To be amended as Unit shall provide adequate APCM with process gas generation sources as mentioned below Sr. no. Specific Source of emission (Name of the Product & Process) 1 Reaction vessel 1 2 Process Vent 2 3 Solvent Stripper Type of emiss ion Stack /Vent Heigh t/dia (met er) SO 2 10 m/ 0.3 m HCl 11 m/ 0.3 m VOCs 15 m/ Air Pollution Control Measure s (APCM) Alkali Scrubber & Water Scrubber Alkali Scrubber & Water Scrubber Primary & Secondary Condenser & Carbon absorber During proposed amendment 7.0 KLD effluent is subjected to solvent stripper. Accordingly, there will be addition of vent attached to Solvent stripper. There will be provision of primary & secondary condenser to trap the VOCs. Finally passing through carbon absorber before venting out in atmosphere.

11 A.4 SOLID HAZARDOUS WASTE Condition No. 24, 25,26,27 & 28 Management of Hazardous Waste Sr. No. 1 Hazardous waste Source of generation Category Discarded Containers Storage & handling of Raw Materials Sch I/ 33.1 EC Bag: 250 Drums: 500 Quantity (MT/Month) Proposed Amend nt After Amend nt Bag: 250 Drums: 500 Disposal Mode Collection, Storage, Transportation, Decontamination & Disposal By Selling To Registered Recycler 2 Used/ Spent Oil Equipment & Machineries Sch I/ Collection, Storage, Transportation & Disposal By Selling To Registered Recycler 3 ETP Sludge Inhouse ETP 4 Spent Carbon 5 Spent Solvent 6 Distillation Residue Mfg. Process of Intraconazole Mfg. Process + Solvent Stripper Solvent Recovery 7 MEE Salt MEE Sch I/ 35.3 Sch I/ 28.1 Sch I/ 28.6 SCH I/ 28.1 Sch I/ HCl Mfg. Process Sodium Sulphite Mfg. Process 5 5 Collection, Storage, Transportation and Disposal in Common TSDF Site Of BEIL, Ankleshwar Collection, Storage, Transportation & Sent To Cement Industries for Co Processing or Incineration In CHWIF of BEIL, Ankleshwar. Collection, Storage, Management & Recovery Within the Premises. Collection, Storage, Transportation & Sent To Cement Industries for Co Processing or Incineration In CHWIF of BEIL, Ankleshwar Nil As total effluent will be sent to CETP(GIDC Dahej) Collection, Storage, Transportation and Disposal by selling to authorized end user registered under Rule 9. Collection, Storage, Transportation and Disposal by selling to authorized end user registered under Rule 9.

12 Justification for Haz. Waste Generation: ETP Sludge (1 to 1.7 MT/Month): Unit will be having Primary & Secondary units for treatment of dilute stream. In order to maintain MLSS to MLVSS ration between 1:3 to 1: 2 activated sludge will be added (approx. 0.2 MT/Month). Moreover, there will be sludge generation from Secondary units (approx. 0.5 MT/Month). Hence, quantity of ETP Sludge will be increased in addition to existing EC. Spent Carbon (1.0 to 1.2 MT/Month): Generates from absorber for VOC control in Solvent Stripper. Hence, we have added the same during this application (EC Amendment). Spent Solvent (170 to 176 MT/Month): Spent Solvent from Manufacturing Process 170 MT/Month & and Generation of Spent Solvent from Solvent Stripper MT/day (6.0 MT/Month) during treatment of effluent. MEE (20.0 to Nil MT/Month) salt is removed as effluent will be sent to CETP after achieving inlet norms of CETP Distillation Residue (7.5 to 8.0 MT/Month): from Solvent Distillation 7.5 MT/Month & and Generation of additional distillation residue from Solvent Stripper MT/Day (0.5 MT/Month during treatment of effluent. HCl (15 MT/Month): generated from manufacturing process will be sold to authorized end user registered under Rule 9. Sodium Sulphite (5 MT/Month): generated from manufacturing process will be sold to authorized end user registered under Rule 9. We hope you would find the same in order and request your kind self to grant us amendment in EC Letter and oblige. Thanking you. Yours faithfully, Encl: 1. Details & Justification of Proposed changes, 2. EC Letter & 3. Form I