In GOVT MIDC AREA. (LAXMI ORGANIC INDUSTRIES LIMITED) Mahad, Dist: Raigad, Maharashtra. Prefeasibility Report M/s. Laxmi Organic Industries Limited

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PREFEASIBILITY REPORT for PROPOSED Expansion of existing production capacity of Diketene derivatives & Ketene derivatives and Installation of Ethyl acetate, EO derivatives and Cogeneration CPP In GOVT MIDC AREA (LAXMI ORGANIC INDUSTRIES LIMITED) Mahad, Dist: Raigad, Maharashtra 1

Synopsis 1. Introduction 2. Justification 3. Location 4. Recourses 5. Process 6. Pollution Control 7. Background Study 8. Safety 9. Benefits 10. EIA structure 11. Scoping 12. Conclusion 2

1. Introduction M/s.LAXMI ORGANIC INDUSTRIES LIMITED (This Industry, TI) are desirous to expand, diversify and energy integrate the existing specialty chemicals industrial unit for producing green solvents, specialty chemicals and co-generation based captive power plant (CPP), at Plot No. B-2/2, B-3/1/1, B-3/1/2; B-1/1/2, B-1/2/1& B-1/3/2, at Government developed Maharashtra Industrial Development Corporation (MIDC) industrial estate, Mahad, district Raigad, Maharashtra. The existing industrial unit is the only production facility in India to manufacture range of specialty chemicals based on acetic acid to cater to demand of pharmaceutical, colorant and agrochemical industry and substitutes imports by about 40% to 50%. The industry now proposes to expand the capacity and add additional capacity to further substitute imports and enhance exports. Indianand worldwide demand for green solvents and specialty chemicals is increasing steadily. The intermediates and solvent proposed to be manufactured will be used in following industry segments. Printing industry : As a green solvent substituting aromatic solvents. Pharmaceutical industry Colorant industry Agrochemical industry Organic synthesis industry Polymer and coating industry The Notification no. S.O. 1533 promulgated on 14 th September 2006 has covered this type of industries under its entry 5 (f). Synthetic organic chemicals industry located in a notified industrial area/ estate will come under Cat Band come under purview of SEAC/SEIAA, Maharashtra to obtain environment clearance for. The industry submitted the proposal to SEAC, Maharashtra in June 2014. Subsequently, SEAC, Maharashtra have taken up the project in its 86th meeting dated 5 th and 6 th Sept 2014, and classified under Category A as the unit is falling within five km from Ecologically Sensitive Area (ESA) and directed TI to approach to Central EAC, MoEF, New Delhi. In the recent past, the industry was granted Environmental Clearances for the same unit in March 2010 and April 2013 by state SEAC/SEIAA. Now we are seeking expansion in production capacity with addition of new products. This prefeasibility report is prepared for forming a frame work for EIA study, scoping and finalizing terms of reference as may be required. Form I, as is prescribed by the said notification is duly filled up and submitted. The prefeasibility report is an accompaniment to the same. 3

Form I submitted by us generally covered Justification, nearby Land Use, Resources, Process, Pollution Control, Aesthetics, Risk Involved, Consequent Developments and Environmental Sensitive Issues. 2. Justification The Indian pharmaceutical industry is the world's second-largest by volume and is likely to lead the manufacturing sector of India. Several Government and private sector projects with huge amount of investments have been initiated but could not attend the speed of development for the need of good quality material. Over the last decade, there has been a sizeable growth in Pharmaceutical sector both in small, medium and large scale units. This has given rise to many small and medium scale units to manufacture pharma intermediate.the ever growing requirements of India,due to higher population and various diseases indicated the need for the growth of this industry. Thus there is a gap in demand and supply. Our efforts of generating products, by-products, downstream products and recycling - reprocessing are indeed needed. With multinational pharmaceutical companies enhancing their presence in India, the long-term prospects of the pharmaceutical industry seem fairly bright. The printing industry is increasing at robust rate due to globalization and change of life style in India. This calls for availability of green solvents like ethyl acetate which will substitute solvents like toluene, MIK and MIBK. Indian agro sector demand is increasing to improve productivity and to deal with attack of various types of pests etc. The intermediates proposed will substitute imports. The colorant industry demand for intermediates is increasing as multinational companies are shifting manufacturing base in India. But the impact of some factors on the industry's growth remains to be seen. For one, there is the power supply situation. Power accounts for around 10% of the manufacturing cost and availability could be an issue in future. Also, manufacturers need to modernize their processes to reduce energy consumption and become more cost efficient. Due to shortage of power in the country, the company proposes to generate captive power by energy integration by setting a co-generation plant and meets its captive requirements of steam and power. The fate of industrialization depends on the proper and effective conjugation of large and medium/small scale industries each supporting each other in their requirement to bridge the gap between demand and supply. In order to be competitive in the global market this synergy between large & medium/small scale industries is a prerogative. Therefore considering the above, large companies do require the help of small units to support them by giving them quality products at lesser price. 4

Industry is regularly submitting the EC compliance report to the statutory bodies. In addition, it is also examined whether industry had made compliance as expected in Consent to Operate by MPCB for existing production. S. No. Condition Compliance 1 Address & status Continuous the same no change 2 Validity Valid till 31.03.2016 3 Product size Sr. no. Product Capacity (TPM) 1 Diketene 1350 2 Intermediates for Pharmaceuticals, Pesticides and Pigments a Esters 1000 b Amides 480 c Arylides 535 3 Ketene Derivatives / 1200 Acetic anhydride 4 Isolated storage of 8500 KL/M ethyl alcohol for captive consumption only 4 Waste water 100 m3 permitted. Limited inside quantity 5 Treatment Comprehensive, PCT, Biological & CETP. Found in limit 6 ECE Dust collector / Scrubbers, cyclone, bag filters in place 7 LDAR Leak detection & repair program with monitoring protocol undertaken as consented. No toward incident reported. Work zone ambiance cognizes 8 Hazardous waste Membership of CHWTSDF 5

Proposal: The industry proposed to produce as under : Product Present Additional Proposed, Total I. Diketene 2015 690 2705 Derivatives (TPM) a. Esters / Ester 1000 300 1300 Derivatives b. Amides / 480 145 625 Amide Derivatives c. Arylides / 535 245 780 Arylide Derivatives II. Diketene (TPM) 1350 500 1850 III. Acetic anhydride (TPM) IV. Ketene derivatives (TPM) V. Ethyl acetate (TPM) VI. Ethylene / Propylene oxide derivatives (TPM) VII. Sodium acetate VIII. CPP- Electric Power (MW) 1200 1800 3000 0 1600 1600 0 5000 5000 0 500 500 0 500 500 0 11 11 These are important chemicals and none of them are banned for production in other developed countries, nor is banned for use. The chemicals produced have following merits. Import substitute Export oriented Energy integration by setting up co-generation for steam and power requirements. The reaction product is water Clean production technology adopted by ensuring 6

- Minimize pollutants at source - Maximize recycle - Treat to PCB norms - Use low ash and sulphur coal for Cogen-CPP. 100% recycle of increased effluents for process. No increase in effluent load to CETP Laxmi Organic Industries Limited (TI) is the only producer of Diketene derivatives & Ketene derivatives and major producer of Ethyl acetateand have expertise in Co-gen CPP. TI has proposed to increase capacity in the same products range and has expertise in design, engineering, construction, commissioning and operation of these products and has network of marketing these products in domestic and export markets. 3. Location- The proposed location is at plot number Plot No. B-2/2, B-3/1/1, B-3/1/2, B-1/1/2, B- 1/2/1& B-1/3/2, M.I.D.C, Mahad, District, MIDC at Mahad. This TI site is in premises of MIDC estate which is meant for this type of industries. On all four sides we are surrounded by industries and no nuisance is spread. The surrounding neighbors are, 1. East : MIDC vacant plot 2. West : Local body Road, vacant agricultural land. 3. South : Pearl Polymers 4. North :Lona Industries. Location too is justifiable. Unit size is kept correct for ease of handling and environmental control. Government MIDC at Mahad has provided all infrastructures like assured Electrical power, continuous water supply with purification from water works having, RSF (Rapid Sand Filtration) and disinfection, internal road, network, external approach roads and has networking with Common Hazardous Waste Storage Treatment and Disposal Facility (CHWTSDF). CHWTSDF at Maharashtra Industrial Development Corporation (MIDC), Taloja, in vicinity has been established with support of MIDC and Maharashtra Pollution control Board (MPCB). A Common effluent Treatment Plant (CETP), is also functional at MIDC, Mahad. As there are other industries in the neighborhood with similar nature, there is compatibility. Location can be thus justified. A relevant portion of index map is enclosed. The proposed land plot admeasuring 1,02,789 sq. mts. This is not a Prime Agricultural Land. The land use is already as Industrial. Thus, there is no change in the status. This is a 7

flat land where by cutting- filling balances and there will be No Low Borrowing from Nature. Within 10 km influence zone there is no tropical forest, biosphere reserve, national park, wild life sanctuary and coral formation reserve. The river, city Mahad, railway line and national highway are sufficiently at safe distance. The clearance is obtained from local body. Hence, have public acceptability. GEOGRAPHICAL LOCATION OF SITE : Latitude : Approx. 18 6'2.93"N Longitude : Approx. 73 29'4.98"E Terrain : Flat terrain Climate : Semi-Arid 4 Resources TI is desirous to establish in MSI sector unit to expand, diversify and energy integrate the existing specialty chemicals industrial unit for producing green solvents, specialty chemicals and co-generation based captive power plant (CPP). It requires following resources, Area 102789 sq. mts Water Input Assured from MIDC Work force 240 Raw Materials commensurate with product, as also work up Chemicals, solvents & catalysts Effluent Facility high COD and TDS sub stream segregated self-treatment and CETP later. Haz. Waste Facility CSWTSDF at Taloja Process Developed by self Machinery available locally Laboratory maintained sophisticated Attendants Units cooling tower, hot water generations Instrumentation state of art Total Investment Rs. 172.80Crores ( Present + Expansion) Environment Fund 2 % Proponents Law abiding. No litigation pending. Site 1. Existing industrial premises. 2. Climatic condition suitable for finer adjustments of control, making it fit for processing conditions. 3. Well connected for transportation. 4. Leveled ground and load bearing soil 5. TI being in Govt. MIDC Estate, its infrastructure will be used. 8

9

Technology Selection 1. The products proposed are in the same manufacturing range for which the technology is already developed and plants are in operation. 2. The process used is based on raw materials that are available, without anybottleneck. Thus, it is not necessary to store any one of it in excess, with a fear of crossing expiring date. Excess storage also means wastage. Here, we can follow easily the principle of JIT (Just In Time). 3. The process used is developed by TI themselves and hence we are aware about the sensitive points needing careful attention in advance. 4. The process is cost effective, safe and environmentally friendly. 5. There is no elevated pressure condition in processing. 6. Solvents used that are recoverable, and are so recovered. 7. The steam from boilers will be used for process and to produce power in turbine by installing new power plant. Instrumentation 1. Latest electronic instrumentation with high accuracy and reliability 2. DCS control system with 100% redundancy for control and power supply. 3. Emergency Shut Down System for ensuring safety of plant and personnel. 4. Stream flow, feed water flow is measurable (indicating and recording) 5. Water level and liquid material level is measurable (indicating and recording) 6. Multipoint temperature scanner with thermo couple. All points indicating and recording (all for steam, feed water, flue gas and air) 7. Pressure gauges at reactors. 8. DCS based multi-channel data logger to inputs like currents, mv, T/C and recording with columned dot matrix printer. 9. DCS based hooters for trips, low levels, high levels and high temperatures. Machinery &Hardware : 1. Modern pneumatic air handling transfer system is used to avoid any risks in human being handling the production. 2. All processing equipment like reactors material of construction will be compatible to process. Generally, will be of SS316 quality and will be kept validated as per strict international guidelines prescribed. 3. The condensers are in SS316. 4. Wherever water is used, will be specially purified both for process and cleaningwashing. 5. Help of sophisticated configuration may be taken, if necessary. Project proponents Laxmi Organic Industries Ltd. is a producer of green solvents based on alcohols for pharmaceutical and printing industry. It was established in 1988, with a focus on the solvents for Pharmaceuticals and Printing industries. 10

The company has adopted following certifications 1. ISO 9001 2. ISO 14001 3. ISO 18001 4. ISO 50001 (Under implementation) 5. Kosher 6. Responsible Care Today, Laxmi Organic Industries Ltd manufactures a wide range of intermediates and solvents and has forged enduring relationships with large and small companies all over the world. Laxmi Organic Industries Ltd. has established reputation for providing quality products in manufacturing plants that meet global standards. The proponents are, S. No. Name Designation 1. Ravi V. Goenka Managing Director Chemical Engineer 2. A. K. Dudhane Chemical Engineer Executive Director & COO 3. N. K. Rao Vice President B.Sc.with Diploma in Marketing Marketing Management 4. V. B. Borse Chemical Engineer Sr. Vice-President (Operations& Projects) 5. B. K. Kabra Graduate in Commerce with Masters in Marketing Management 6. K.D. Das ACMA, MBA (Finance) 5 Process General Manager Exports C.F.O. Products TI proposes to establish a plant to produce green solvents. The products serve as green solvents for Pharmaceuticals and Printing. As season changes or as immunity changes, demand for particular chemical changes, the industry has thus to be in readiness to change the product suitability and be prepared to mitigate the corresponding environmental challenges. The utilities are normally the same, but the reactors are used by different combination and sequence. The product mix is as given below. Product Present Additional Proposed Total 1. Diketene Derivatives (TPM) 2015 690 2705 11

Esters / Ester 1000 300 1300 Derivatives Amides / Amide 480 145 625 Derivatives Arylides / Arylide 535 245 780 Derivatives 2. Diketene (TPM) 1350 500 1850 3. Acetic anhydride (TPM) 1200 1800 3000 4. Ketene derivatives 0 1600 1600 (TPM) 5. Ethyl acetate 0 5000 5000 (TPM) 6. Ethylene / Propylene 0 500 500 oxide derivatives (TPM) 7. Sodium acetate 0 500 500 8. CPP- Electric Power (MW) 0 11 11 It may be seen that, There is a capability of making these products Production process is continuous with Cleaner Production strategy with effluents recycle Machineries, utilities will be installed according to the expansion requirement. Process The details of manufacturing process is submitted as annexures. Overall Environmental Significance: Unit Operation/ process 1. Incoming raw material 2. Weighing and strict quality control Peculiarities Selected from known vendors Transportation in closed tankers Load Cell based weighing system provided Environmental significance Prompt use and storage in closed containers prevent spillages and loss of strength. Less HC emissions. Better check on mass balance, purer material and less rejections. 3. In process Solvents Recovered and reused By products Recovered and sold to parties, when in demand Gaseous emissions Scrubbed and detoxified Process waste residue To be sent on common facility for disposal 12

4. Instrumentation DCS Control system for accurate process controls 5. Control Excellent system of documentation and control of critical stages in production process 6. Solvent recovery No solvents are used in the process Facilitates monitoring of quality of the product and safety aspects. Better operation and retrievable records for better checks. Not applicable 6 Pollution control Clean production technology adopted by ensuring following at design and engineering stage. - All reactions selected are producing water as by product. - Minimise pollutants at source - Maximise recycle - Treat to PCB norms - 100% recycle of increased effluents for process. - No increase in effluent load to CETP - Treatability data available from existing ETPs - Reduction of VOC at every processing stage by vent condensers and scrubbers. - Use low sulphur and ash coal for Cogen CPP for reducing emissions The process adopted is based on esterification of organic acid and alcohol producing water as an effluent. The recovery system will be designed in such a way that entire water is used for process application thereby replacing fresh water input. The boiler is provided with cyclone separator, bag filter/esp, to control emission within prescribed limits. The stack height is upto 60 meters to control ground level clearance within limits. Process vents are controlled by condensers followed by water scrubber and organics are recovered and recycled. (a) Water & waste water: The water and waste water generated in the factory will be as follows; a. Water requirement : # Use Station Existing Proposed Total 1 Domestic 22 8 30 2 Cooling water 916 1891 2807 13

3 Process water 170 75 245 4 Boiler feed 10 32 42 5 Greening 5 52 7 Total 1123 2008 3131 b. Waste Water generation: # Use Station Existing Proposed Total 1 Domestic 18 7 25 2 Cooling water 37 152 189 3 Process water 170 173 343 4 Boiler Blow down 3 39 42 Total 228 371 599 There is no increase in effluent load to CETP. The industry has membership of CETP, letter is attached ESTIMATED QUALITY OF RAW & TREATED EFFLUENT : SR. NO. PARAMETER RAW EFFLUENT TREATED EFF. QUALITY (MPCB LIMITS) UNITS 1. ph 6 7 5.5 9.0 -- 2. B.O.D 300 Max. 100 Mg/lit. 3. C.O.D 800 Max. 250 Mg/lit. 4. T.S.S. 200 Max. 100 Mg/lit. 5. Oil & grease 8 Max. 10 Mg/lit. 6. Ammonical Nitrogen <50 <50 Mg/lit. 14

Proposed ETP Flow Sheet: 15

(b) Air pollution: The proposed plant will not produce any significant air pollution load. The major sources of air pollution are: Boiler D.G. Set Emissions Fugitive emissions Process emissions The efforts taken by the proposed plant to tackle these issues are also given below. Emission Control Equipment: The fuel used here is coal & electricity. Stack of 60 m shall be provided. DG set of capacity 1010 KVA will be on low sulphur diesel and will be provided stack and acoustic enclosure as per MoEF standards. # Source Pollutant In-plant Measures 1 Proposed SPM, CO,SO2, Dust Collectors,, Boiler NOx ESP, Dust extraction with Bag filters, fogging. 3 In process HC, VOC Closed loop transfer Control Equipment Tall stack of 60 m. Vent condensers, Extraction and scrubbing 4 In process SO2 &HCl SO2 and HCl gas Scrubbing and detoxification 5 ETP CO2, H2S Covered transfer Fully aerobic In addition, other attendant efforts like water spraying, tree plantations and covered storage,etc shall be adopted, wherever feasible and needed. 16

Stack Details: Stack numbers 1 2 3a 3b 3c 4 5 6 7 Present Present Additional Present Present Additional Additional Attached to Boiler No 1 & 2 (No Air exhaust from Ketene Furnace (Additional Stack details as given below) Acid Recovery DG Set (No change) DG Set Cogen CPP change) Pneumatic conveying (No change) Capacity ----- ------ 3.4 MM 5 MM 5 MM ------ 1010 KVA 1010 KVA 75 MT/Hr Kcal/Hr Kcal/Hr Kcal/Hr Steam Fuel Type Boiler No. 1 : Coal Boiler No. 2 : Furnace Oil Fuel quantity (Kg/hr) Boiler No. 1 : 27 TPD Boiler No. 2 : 8.3 TPD Material of Construction ------ Coal is gasified to produce Producer gas and used as Gas in the Furnace C-9 as alternative / support fuel ------ Coal : 500 kg/hr C-9 : 2 KL/day Coal : 1100 kg/hr C-9 : 4 KL/day Coal : 1100 kg/hr C-9 : 4 KL/day ------ Diesel Diesel Coal ------ No continuous requirement. Used only during failure for critical areas. Not used for Plant No continuous requirement. Used only during failure for critical areas. Not used for Plant Coal : 11000 kg/hr MS MS MS MS MS MS MS MS RCC 17

Shape Round Round Round Round Round Round Round Round Round Height, mtrs 40 30 30 30 40 30 6.3 (above 6.3 (above 60 roof) (2 nos) roof) (2 nos) Diameter, mtrs 1.2 0.6 0.674 1.1 1.1 0.2 0.25 * 2 nos 0.25 * 2 nos 3 Gas Quantity Nm3/hr 13500 6000 5000 8700 8700 650 3000 3000 111450 Gas Temperature o C 140 35 140 140 140 35 160 160 140 Exit Gas Velocity (m/sec) 3 6 Control equipment preceeding the Stack Nature of pollutants likely to be present in the stack gases such as Cl2, NOx, Sox, TPM etc Emission Control System provided Incase of DG set Power generation capacity in KVA (Attach specifications including residue management systems of each of the Control equipment including inlet/outlet Dust collector & Bag filters SOx, TPM Dust collector & Bag filters Scrubber of diameter 1200mm 4 4 4 6 N.A. since Gas fired Scrubber of diameter 600mm SOx, TPM SOx, TPM SOx, TPM Scrubber of diameter 1200mm N.A. since Gas fired Scrubber of diameter 600mm 7 As per air pollution prevention norms for DG SOx, TPM As per air pollution prevention norms for DG 7 5 As per air pollution prevention norms for DG Dust separators followed by ESP SOx, TPM CO2, SOx, NOX, SPM As per air pollution prevention norms for DG NA NA NA NA 1010 KVA. Plant will not be operated on the DG. DG shall be used only for Critical Consumers. The fuel used is high speed deisel available from Petrol / Diesel pumps. Residue management system is not applicable. Dust separators followed by ESP NA 18

concentration of relevant pollutants) Whether any release of Odiferous compounds such as Mercaptans, Phorate etc. are coming out from any storages or process house Do you have adequate facility for collection of platform, ladder etc. as per Central Board Publication Emission regulations Part - III Quality of treated flue gas emissions and process emissions. Quantity of treated flue gas emissions and process emissions (Specify concentration of criteria pollutants and industry/processspecific pollutants stack-wise. Enclose copy of latest report of analysis from the laboratory approved by State Board/Central No Yes Refer Annexure 19

Board/Central Govt. in the MoEF. For proposed unit funish expected characteristics of the emissions 20

Dispersion: Point Emissions are coming from six boilers, and a proper stacks are provided for the same. Refer enclosed of stack details The stack will be fitted with port-holes, ladder and platform for facility of taking samples. Fugitive: A number of mitigation measures are taken to control fugitive emissions Engineering the plant layout in such a way so as to virtually eliminate need of using heavy equipment for material handling in the main plant Internal roads paved, leveled, no undulations, no sharp curves, slow speed No open storage of materials involved Fumes extraction and scrubbing system provided for extraction of fumes from the reactors and the process plant areas. 8. SOLID WASTE Introduction: Following mitigation practice is the policy for future: Minimization at all levels will be attempted for discarded products, empty containers, packing surpluses, incoming raw material unloading spillages and fugitives. The plant will produce very less amount of scrap materials. All these, however, be carefully stored on raised platform with dwarf toe walls all around, and a roof over-head. The contents will not be held in the premises for more than a fortnight. The main solid waste from factory will be in form of and residues form catalyst recovery. This waste will be transported to the Common Hazardous Waste Treatment and Disposal site for proper treatment and disposal. We buy raw materials in tankers and chemicals in bags. The bags are recycled. The ETP sludge will be sent to CHWTSDF. (A) Non Hazardous solid waste: Based on above working, the summary of Non Hazardous solid waste is given below Non hazardous solid waste Type of Total Management generation waste From Domestic Activities Dry garbage 18 Kg/day Wet garbage 42 Kg/day Garbage sent to Muncipal collection centre Garbage sent to Muncipal collection centre 21

From Process Coal Ash 28 MT/day To Brick Manufacturers Plastic Drums / Containers 15 Nos./ Day Handed over to the authorized recyclers (B) Hazardous Waste: The unit is member of CHWTSDF Taloja the copy of membership is attached The relevant summary is given below: Sr. Schedule I No. Category No. Type 1 34.3 (ETP Sludge) Chemical sludge from waste water treatment Qty (kgs/day) 6 (Present) 3 MT/month (Proposed Additional) Method of Disposal CHWTSDF 2 26.1 Process waste sludge / residue containing acid or other toxic metals or organic complexes. D-7 Organic nitrogen containing compounds expressed as nitrogen 9 MT/month (Total) 55 MT/month (Present) 29 MT/month (Proposed) 84 MT/month (Total) Used as fuel in furnace along with other fuels, after reprocessing Aesthetics: There will be no nuisance from noise. DG set only run occasionally during power failures to keep plant under safe conditions. There are crushing and pulverizing operations for coal handling. Dust suppression system is provided. Dust extraction with dust collection is provided. Labor strength is also limited in this MSI unit. Odour however can be of some sensitivity in chemical industries. However, in this case majority input is odourless, and only few with mild or characteristic odour. This will be handled carefully. No nuisance will go to surrounding chemical industries. 22

7. Background Study: This is important part of study. (A)Natural Environment : We propose to do sampling as Surface Water: 2 Locations, 11 Parameters. Ground Water: 5 Locations, 9 Parameters. Includes 1 up gradient and 2 down gradient source. Air Quality: 3 Months, For PM10, PM2.5, SO2 and NOx. Noise: 5 Locations. Soil: 5 locations The stations will be selected in all the eight directions from the factory and in 10 km radius. (B) Manmade Environment This includes existing land-use, demography, employment, socio-economic aspects and community development needed and proposed. This is for entire area both rural and urban in this study zone. Socio-Economic Status in Influence Zone explained in the study of Non-Workers percentage whether high, from the percentage employed population on Agricultural, how far is the scope for other avenues of livelihood like Live Stock, Forestry, Fishing, Hunting, Orchards, Mining, Trade Commerce. Further Out of Total Land what percentage is already under Cultivation and Out of Total Land what percentage is already under Irrigation. If the land is not likely to support more people, then whether Industrialization is necessary to improve the situation. All this will be studied as cost benefit ratio. 8. Safety Safety and Occupational Health will be dealt carefully. A disciplined approach is natural to this industry. Safety policy will be in place. The unit is registered under Factory Act and is bound by State Factory Rules. A complete exercise of risk assessment & characterization is scientifically done. Mitigation plan is drawn as follows: Mitigation measures Sprinkling on excavation Scrubbers on process vents Bag filters for steam boilers Stack height per MPCB Trees Barrier walls as shielding technology to suppress blast pressures, fragments, fireballs 23

Chemical storage area ventilation, store-rooms, fuel dyked For Hazardous chemicals Flame-proof motors, No smoking, Thermal insulations. First aid trained and Fire-fighting trained person will be available in every shift. Safety Officer will be appointed, as also the competent person retained. Where necessary, provisions of other Acts, where required like Petroleum act, Explosive Act, etc. will be obeyed. Fire fighting system is kept as per norms of Insurance Company. DMP (Disaster Management Plan) and off-site emergency plan will be in place. Accordingly, Personal protection equipment will be given and use will be insisted. Consulting Physician is available to attain the factory. 9. Benefits The expanded capacity will meet the growing demand for green solvents locally and internationally. 40% of the products will be exported to EU and other countries. 10. EIA study report: This will be finally prepared and submitted as per guidelines given by MoEF as -- Chapters Contents I Proponents, ToR, Purpose II Project explained. Why this, Why needed, Why here, What priorities, What options III Environment Setting Natural & Man-made Material, Method, Delphi technique Approach IV High Significant Impact Low Insignificant Impact & Shield Proper Site Prevention Abatement Treatment Mitigation Smooth Disposal V Alternate Analysis Selection of Raw Materials, Site, Process, Machinery- Hardware, Collaborators, Staff & Team VI Monitoring = Stations, Parameters, Frequency, Statistics, Rectify VII Risk = To Environment, To Health, To Bankers Public Consultation Reporting Community = Other Assistance VIII Benefits = Physical, Social, Employment, Other Tangible. Sustainable considerations IX Cost-Benefit. If Project Done? If No-Project?? X EMP = Plan, Cell, Schedule, Watch-dog, Monitoring, Documentation, Reporting. XI Summary, Conclusion, Justification, Mitigation. XII EIA Team = Proponent, Consultant, Associates, Future 24

11. Scoping We shall propose in Scoping the details of all above, as also the following; The study area of 314 sq. km, the land under the unit is very small. Thus, there will not be change in land use pattern. The present land is already non agricultural and under the industrial use. Raw material requirement, water requirement, water balance, process details, technology, product details etc. Ambient Air Quality monitoring, for 3 months except monsoon covering 10 km radius around industry and its impact. Ground water quality around plant 10 km radius. Treatment scheme to achieve low discharged from premises. Scheme of treatment, mode of treatment Many other medium and large scale industries are present within 10 km radius in general and in this estate in particular. Information of solid waste, number of working days, CO2 emission from stack and process, etc. Employment generation, benefits of project The raw materials used are enlisted and their MSDS will be presented. Some of them will be covered under MIS rules. However there use in process is small below regulatory quantity. Risk assessment will be done and submitted. 12. Conclusion This project is very necessary to supply green solvents for printing industry and meet solvent demand of pharmaceutical industry both domestic and worldwide and also in view of : The local people desire that this industry will be welcome in their area. The candidate site is suitable from general MoEF expectations. Water, power, raw material, Filler Material and Market is assured and found available with ease. Full precautions will be taken for Pollution Control, Resource Conservation and Environmental Protection. This is cost effective and Sustainable Development. 25