1.

Project Description
M/s. Akshar Chem (India) Ltd. is located at Plot No. 166 – 169, Village:
Indrad, Kadi-Kalol Road, Taluka: Kadi, Dist. Mehsana, Gujarat. Unit is
planning to manufacturer of Single Super Phosphate (SSP) with other dye
intermediates products at above location.

Akshar Chem plan to produce Single Super Phosphate (SSP) from the
byproduct of Sulphuric Acid generated from Dye Intermediates resulted to
produce SSP with less cost and enables to provide SSP to farmers with
very competitive rate. Proposed Single Super Phosphate' plant will have
annual capacity of 8350 MT/Month along with other dye Intermediates
products. Details of products are summarized below.

Sr. Product Capacity MT/month

No. Existing Additional Total
1 Vinyl Sulphone 650 00 650
2 Vinyl Sulphones - (PC VS/OA 00 100 100
VS/DMS VS/ M-(Beta Sulfate Ethyl
Sulphone) Aniline)
3 Acetanilide 00 500 500
4 H-Acid 00 450 450
5 SSP (Single Super Phosphate) 00 8350 8350
By Products
1. Acetic Acid 126 15 141
2. Hydrochloric Acid 650 16 666
3. Spent Sulphuric Acid 2275 1105 3380
4. Glauber Salt 510 75 585
5. SBS (Sodium Bi-sulphite) 00 320 320

2. Importance of the Project

SSP is one of the cheapest fertilizers, which farmer can afford to use. The
merits of SSP are given below:
 ¾ It has been proven that SSP is an excellent source of phosphorous over
many years of Agricultural practices. It also contains secondary
nutrients like Sulphur (12%) and the calcium (21%), which are
important for all the crops.
¾ In case of SSP, the capital investment for producing one tone of
Phosphate is lower as compare to Complex Fertilizers Plants and in our
case, it is much more chipper because we are proposed to use Spent
Sulphuric Acid, which is our generation from VS production and save
treatment cost of acidic effluent also.
¾ In case of SSP the project implementation period for plant set-up and
gestation period for production is much lesser as compare to Complex
Fertilizer Plant. Therefore government is encouraging the SSP
production to fulfill the growing demand of fertilizers.
¾ It is useful as phosphoric fertilizer for direct application and as a raw
material for N.P.K Granulated mixed fertilizers as SSP production
requires simple technical steps.
3. Justification of the Project
¾ Dye Intermediates are always required as the demand and supply gap
in local & international market. Akharchem deliver his production of
Vinyl Sulphone in time to the local dyes manufacturer and export which
generate revenue and its by product (Sulphuric acid) can be utilized for
SSP production currently IFFCO-Kandla and proposed to use in the same
unit to set up own SSP plan.
¾ Fertilizers and Micronutrients are always in shortage, as the demand
and supply gap is huge. 65-70% of Indian population is still dependent
mainly on Agriculture business. Majority of them are single crop
cultivators, those are rain feed dependent.
¾ It is observed that during the last two years phosphate fertilizer demand
has gone up by 20% and it will continue to increase considering the
planned target of food grains in next ten years. In fact the whole state
 of Gujarat is facing the shortage of fertilizer and SSP in particular
always in short supply. For such conditions, timely supply of fertilizers is
a must and very essential. Aksharchem can deliver his production of
SSP in time to the farmers of this region with chipper rate of market.
4. Raw Material Requirement/Raw material linkage
For SSP production, mainly rock phosphate (16-20 % P2O5) and Sulphuric
acid (65-70 % Concentration) is main raw materials. Dilute Sulphuric acid
is own waste generated from VS products and concentrated Sulphuric
acid will be made available from Hindustan Zinc Limited located at
Canderi in Chittorgarh. Rock phosphate will be sourced from RSMM
(Rajasthan State Mines). HDPE bags will be procured from local suppliers
available at Ahmedabad.
Required Quantity of Raw materials for manufacturing of SSP:
Sr. Name of Quantity (MT/Month) Source Storage/ Transportation
No. Raw Existing Proposed Total type of
Materials Addition packing
SSP (Single Super Phosphate) - 8350 MT/Month
1 Rock 0 4885 4885 Indigenous Storage by road
Phosphate yard
2 Spent 0 2050 2050 Own Tank Own generation
Sulphuric generation
Acid
3 Fresh 0 2050 2050 Indigenous Tank by road
Sulphuric
Acid

5. Manufacturing process: Single Super Phosphate (SSP):

Single superphosphate (SSP) was the first commercial mineral fertilizer and it
led to the development of the modern plant nutrient industry. This material
was once the most commonly used fertilizer, but other phosphorus (P)
fertilizers have largely replaced SSP because of its relatively low P content.
Chemical Properties:
Following minimum quality of raw materials is requiring for production of SSP.
Phosphorus content: 7 to 9% (16 to 20% P2O5)
Calcium (Ca) content: 18 to 21%
S content: 11 to 12%
Sulphuric Acid: 65% to 70% of Assay value of Sulphuric Acid
Quality of Raw materials:
Rock Phosphate, a natural deposit of Calcium Phosphate containing Fluorine
Carbonate and other impurities in lower concentration (Chemically known as
Fluorpatite) is the basic Rock material used for the manufacture of phosphate
fertilizers. The fertilizer industry gets this Rock phosphate from domestic
mines as well as it is being imported. The high grade Rock phosphate from
Jhamarkotra of Rajasthan contains +30% P2O5 is used for super phosphate
manufacturing. The broad specifications of Rock phosphate from Jhamarkotra
of Rajasthan are as per following:
Sr. Typical quality of rock phosphate
No. (Rajasthan)
Content %
1 P2O5 31.5-33%
2 CaO 42-45%
3 MgO 0.5%
4 Al2O3 0.6%
5 Fe2O3 2.5%
6 Cl 0.10%
7 SIO2 8-12%
8 F 2-3%
9 LOI 1 to 2%
10 H2O 3-6% avg.

The composition of Spent Sulphuric Acid which is available with us is having

following approximate composition.
Sr. Typical quality of Sulphuric Acid
No. Content Concentrated Spent Acid
1 Physical State Liquid Liquid
2 Assay 97±1% 32±2%
3 Colour Colorless Colorless
 4 Organic Impurities - <0.1%
5 Sp. Gravity 1.84 1.29
6 Phosphate 0.5% 0.1%
7 Nitrite 0.2% 0.1%

Chemical Reaction:
The manufacturing process depends on reacting phosphate rock with sulfuric
acid and the fertilizer contains about (16- 20 %) P2O5. The net reaction
proceeds as follows:
CaF2.3Ca3 (PO4)2 + 7H2SO4 + 14H2O 3Ca (H2PO4)2 + 7CaSO4.2H2O + 2HF
M. W. 1008 686 252 702 1204 40

1946 1946

The calcium phosphate remains in the product and forms in the fertilizer SSP.
The other minor reactions which took place are as under:
2CaO+2F2 = 2CaF2 + O2
3CaO+P2O5 = Ca3 (PO4)2
CaO+SO3 = CaSO4
MgO+H2SO4 = MgSO4 + H2
Fe2O3 +3H2SO4 = Fe2 (SO4)3 + 3H2O
The process can be divided into two stages as follows:
¾ The first stage represents the diffusion of sulfuric acid to the rock
particles accompanied by a rapid chemical reaction on the particle
surface, which continues until the acid is completely consumed, and
crystallization of calcium sulphate.
¾ The second stage represents the diffusion of the formed phosphoric acid
into the pores of the rock particles which did not decompose. This stage
is accompanied by a second reaction.
In this process phosphate rock is transported from the storage site to
automatic weight, by a system of belt and screw conveyors and elevators,
which feed the continuous action double conical mixer.
The sulfuric acid is continuously diluted with spent Sulphuric Acid in a batch
mixer to a 70-75 % concentration, and then fed to the mixer to react with
phosphate rock where a first reaction takes place. This reaction ends in the
reaction mixer in 30- 60 minutes, during the period of settling and hardening
of the superphosphate slurry, which is caused by the relatively rapid
crystallization of the low solubility calcium sulphate.
The next stage of the process is ageing of the superphosphate, i.e. the
formation and crystallization of mono-calcium phosphate in the den. The
formed slurry is transported to the continuous-action reaction den which has a
very low travel speed to allow for solidifying, where formation of
superphosphate takes place (settling and hardening of the slurry in the first
stage of ageing). Considerable quantities of fluoride compounds are evolved
from the acidulation, they are sent to the scrubbers.

The superphosphate powder, from the den, is transferred for ageing by a belt
conveyor, located below the den, to the pile storage for curing. The raw
fertilizer is uniformly distributed by a scattering device and in order to
accelerate the ageing operation, the superphosphate is agitated during
storage by means of a grab-bucket crane.

During reaction of the phosphate with sulphuric acid in the den, hydrogen
fluoride evolves and reacts with the silica contained in the phosphates and
forms gaseous silicon-tetrafluoride (SiF4) and fluo slicic acid (H2SiF6). The
continuous den is, therefore, enclosed so that fumes of these compounds do
not escape into the working place. The fluorous gases, containing H2SiF6
vapors, are withdrawn through an opening in the den roof into a ventilation
pipe to an absorption unit (Scrubber) and are utilized for making sodium fluo
silicates.
The SSP manufacturing process consists of the following six stages:

I. Grinding of Rock Phosphate (95 – 98% material passing 100 mesh)

II. Concentrate dilute Sulphuric Acid from 30% to 65–70% by adding

98% concentrated Sulphuric Acid.

III. Acidulation (Mixing of Rock Phosphate & Dilute Acid)

IV. Pollution Control

V. Curing & Shuffling

VI. Bagging & Packing

Step-I: Grinding of Rock Phosphate chips (95–98 % material passing

100 meshes):

Rock Phosphate of + 4 mm to + 15 mm size from either Rajasthan State

Mines of India or from other sources like Jordan, Egypt, Morocco, Togo, Syria,
etc. is unloaded in the covered sheds. The same is fed into Rock Feed hopper
by means of either an overhead crane or loaders. These Rock Phosphate chips
are than conveyed through belt conveyors to the Grinding Mill where, it is
brought to the desired mesh size. The powdered Rock Phosphate is collected
in the storage hopper by air swept system through dust collecting cyclones &
dust collector bags.

Step-II: Concentrate dilute Sulphuric Acid from 30% to 65 – 70% by

adding 98% concentrated Sulphuric Acid.

Dilute Sulphuric Acid from Vinyl Sulphone Plant and other sources are collect
in the tanks. Parallel 98% Sulphuric Acid from various sources is stored in MS
tanks. This acid is than pumped in to the service tank (day tank) where
concentrated and dilute Sulphuric Acid is mixed together by control flow
meters to achieve the required concentration.
Step-III: Acidulation (Mixing of Rock Phosphate & dilute Acid):
Ground Rock Phosphate from storage hoppers is conveyed through rotary
feeder, screw conveyor, bucket elevator, buffer hopper and weigh belt
conveyor to the MS lead & acid heat resistant lined mixer and nickel resist and
hard paddle mixer. The dilute acid through the day tank is fed into the mixer
and is mixed with powder Rock Phosphate in the paddle mixer. The required
1st stage takes place in 2.50 minutes retention time takes place before the
slurry gets in to the slow moving den. In slow moving den conveyor, further
reaction will takes place for 35 to 45 minutes. The gases are now sucked by a
high speed blower into the pollution control system. The cake bed at den
conveyor is than cut into semi powder form by cutter and is flowed into the
crane shed. The crane/loader than shifts/ heaps the material in the green SSP
shed.

Step-IV: Pollution Control:

Particulates: Particulates generates from grinding mill is sucked through ID
fan and emitted after passing through cyclone & bag filter units.

Gaseous: The gases from the den conveyor are sucked through scrubber fan
and is pushed the different stages of scrubbing. Here the gases are scrubbed
by raw water and the scrubbing liquid is collected in tanks. The scrubber
liquor after is then transfer to the acid dilution mixing scrubbed water contain
silica is used as a filler to attain the required quality.

Step-V Curing & Shuffling:

The material from den conveyor is heaped in the green SSP bulk shed. These
heaps are than sliced and re-heaped by crane/ loaders after analytical
procedures by laboratory to attain the required quality. The shuffling of heaps
is required to improve the quality of the product.

Step-VI Bagging & Packing:

Then after standardize quality of product send to bagging unit for bagging &
dispatch.

Inputs Operations Output

Rock Phosphate Cussing, Grinding & Dust to Dust Collector

Screening

Acidulation HF + Acid Mist + SiO2

Acidulation Mixer
(Scrubber)

HF+H2SiF6+SiF2+ SiO2
Reaction Den
(Scrubber)

Belt Conveyer

Bagging

Storage of SSP

6. Details of major Reactors, Vessels and Equipments

Sr. No. Equipments Quantity Capacity

Major Equipments

1 Coarse rock feed Hoper 1 15 Mt

2 Rotary Table feeder 1 05 MT/Hr
 3 Belt Conveyer 1 20 MT/Hr
4 Grinding Mill 1 10 MT/Hr
5 Grit Separator 1 -
6 Ground Rock Hopper 1 15 Mt
7 Rotary Vane Feeder 1 10 MT/Hr
8 Screw Conveyer 1 10 MT/Hr
9 Ground rock bucket elevator 1 10 MT/Hr
10 Feed screw conveyer 1 10 MT/Hr
11 Acid Feeder 1 10 MT/Hr
12 Paddle Mixer 1 12 MT/Hr
13 Reciprocating Den 1 15 MT/Hr
14 Sulphuric Acid storage tank 2 100 Kl
15 Sulphuric Acid day tank 1 10 Kl
Pollution Control Systems
1 Cyclone Separator 1 -
2 Dust Collector-Bag Filter 1 -
3 Venturi Scrubber 1 -
4 Scrubber Tank 1 10 Kl
5 Circulation Pumps 2 5.0 HP
Bagging Plant
1 SSP Feeder Hopper 1 15 MT/hr
2 SSP Feeder Belt Conveyer 1 15 MT/hr
3 Vibratory screen 1 15 MT/hr
4 Hammer Mill 1 12 MT/Hr
5 Bag Filling & Weighting Machine 1 -
6 Stiching Machine 1 -

7. Details of Emission, effluents, hazardous waste generation and

their management
Sr. Components Source EMS
No.
1 Air Emission Dust Emission from rock Cyclone & Bag filter,
Phosphate handling & Close conveyer
grinding unit
2 Waste water Process No waste water
Generation generation
3 Hazardous water ¾ Sulphur residue Use in process
 generation ¾ Wet scrubber solution
¾ Dust from dust collector

8. Resource Requirements–
Water requirements: Water requirement for proposed SSP project for
industrial activity during operation phase will be 10 KLD. The water
requirement will be met through ground water source.

Uses of Water Wastewater Ultimate

water Consumption generation Disposal/Uses
(m3/day) 3
(m /day)
Processing 10 10 Recycle in process
Scrubber because its contain silica
and fluoride compound
which is filler of SSP.

Power/Energy: Power requirement of proposed project will be made

available through State grids (PGVCL - Paschim Gujarat Vij Company
Limited).Total power requirement of proposed SSP plant will be 450 Kwh.
Fuel: No need of fuel for Single Supper Phosphate because we are not
going to produce granular Single Supper Phosphate fertilizer.
9. Details of proposed source-specific pollution control schemes and
equipments to meet the national standards for fertilizer.
Air Pollution Control Measures
Control of Dust pollution in grinding:-
Dust control equipments are the integral part of the plant process design.
Grinding & classifying of rock phosphate is totally enclosed, which consist
of cyclone separators to collect the ground material & for separate out
dust, Bag filters are provided with the mills which works efficiently. After
dust separation clean air is allowed to go out to the atmosphere.
 Chips rock phosphate of 4 to + 15 mm sizes will be ground in the above
mill to 98% passing through 100 mesh. The ground powder will be uplift by
air blower to the Cyclone where it will be collected and pass on to Storage
hopper. The dust coming out of cyclone by suction of blower will be thrown
to Dust collector. Where the equipment will be having cotton bags to
collect the dust and vent the air. The dust collected in the bags will be
conveyed by screw conveyor to the plant.
Pollution Control System for Acidulation
The gases from the Den conveyor will be sucked by Scrubber fan will get in
to the Ventury scrubber, where the gases will be absorbed by raw water
and collected in tank. The scrubber liquid will be pumped from the tanks
for the Acid dilution tank for reuse in process.
Pollution control of fluorine based gases and fine silica particle:
The fluorine-based gases are highly soluble in water. Silicon tetra fluoride
is highly reactive with water and Hydro-fluoroslicic acid. The gases
produced in the den are sucked through the ID fan; these gases are passed
through two venturi scrubber system. The clean air is vented through
Chimney of specified height. The stack will be monitored regularly for
Fluoride content. The scrubber liquid will be pumped from the tanks for the
Acid dilution tank for reuse in process.
Water Environment
There is no wastewater discharged to outside from the plant. All the
wastewater generated in the process i.e. scrubber are collected and is
recycled in the process.
Hazardous waste management:
No waste generation from process. Waste what so ever from any activities
will be handle and manage as per the guideline of Hazardous and other
waste (Management and Handling) Rules-2016.
10. Specification of SSP:
Single super Phosphate is the most important single nutrient Phosphatic
fertilizer containing 16% P2O5 in water-soluble form and has traditionally
been very popular in agriculture sector. Raw material for SSP is rock
phosphate and sulphuric acid, where rock phosphate is a natural deposit of
calcium phosphate containing fluorine and carbonate.
As per FCO (Fertilizer Control Order) Ministry of Agriculture, Government of
India has amended specifications of Single Super Phosphate (Powder) /
G.S.S.P. effective from 10.05.2011

Sr. No. Descriptions Concentration

1 Moisture, percent by weight, maximum 12.0%
2 Free Phosphoric acid (As P2O5), percent 4.00%
by weight maximum
3 Water soluble phosphates (As P2O5) 14.50%
percent by weight minimum
4 Citrate soluble phosphates (As P2O5) % 16.00%
by wt minimum
5 Sulphur (As S), percent by weight, 11.00%
minimum
Layout plan
As per EC no. J-11011/1059/2007-IA-II (I) dated 22.9.2008 and 3.6.2009.
SPECIFIC CONDITIONS
1. The effluent shall not exceed 117 M3/d Not Complied. The average water consumption
after the proposed expansion of which was 199.25 KLPD and average waste water
71 M3/d shall be sold to the textiles generation was 181 KLPD as per environment
mills and 46 M3/d shall be audit report 2014 which is higher than the
concentrated effluent in the multiple prescribed in the ECs of 2009 & 2012. Details of
effect evaporators. The concentrated selling of effluent to textile mills were not
effluent shall be incinerated. The submitted. Two MEE have been installed to treat
condensate from the MEE shall be effluent and concentrated effluent was being
recycled. The dilute stream from the incinerated within the premises. The incinerator
utilities shall be treated in the ETP and was not found in accordance with CPCB
treated effluent shall be sent for solar guidelines and the working was found inefficient
evaporation. The solar evaporation (Photo I). Although PA has claimed that
pond shall be properly lined to prevent condensate of MEE was recycled in the cooling
leaching of effluent. tower and blow down was mixed in the treated
effluent. But, actual water balance was not
submitted. The treated effluent was stored in
solar evaporation ponds. It was observed that
lot of sludge was stored along the pond (Photo
2).
Clarification/Action plan:
Zonal Officer of MoEF & CC has taken the reference of our earlier EC vide EC no. J-
11011/1059/2007-IA-II (I) dated 22.9.2008 and 3.6.2009. Actually we have obtained
second EC vide EC letter no. J-11011/552/2010-IA-II (I) dated 07/12/2012.
Water consumption:
As per our last EC issued in 2012 Total ground water requirement from132 m3/day to
145 m3/day after expansion. Detailed water balance is given below. Water balance
diagram indicate that 40 m3/day recycle water from condensate of MEE. So total water
requirements is tune around 185 m3/day. As per Environmental audit report, its tune
around 199.25 KLPD which is little higher because less water consumption submitted by
us for domestic & greenbelt development in our earlier EC proposal and actual
consumption in both the head is higher. We have modified it in our current proposal.
Wastewater Generation:
There is some calculative mistake. Pl refer water balance diagram for existing set up
which shows that actual wastewater generation is tune around 168 KLD (82 KLD effluent
+ 86 KLD ML) whereas as per the Audit report it is tune around 169 KLD. It is very
marginal difference and we have further reduced it to control excess use of water.
Hazardous waste disposal:
The reason for large quantity of sludge accumulation is saturation of existing TSDF site
operated by M/s. NEPL. Other nearest site is GESCSL-Vatva is also saturated and both
the site operators are trying to develop TSDF site at new location. During this time, we
have get membership from BEIL and it is our interim arrangement because location is
quite far and they are not ready to receive our entire quantity of sludge.
Currently, we have started co-processing activity and generated Gypsum sludge sent to
Ambuja Cement. During period of Apr, 15 to March, 16, we have disposed off around
5428.37 MT of sludge and currently no major accumulation of ETP sludge.
 Water Balance Diagram

Water Consumption
145 kl

Domestic Process Washing Utilities Greenbelt

4 53 8 70 10

Condensate*
Soak pit
3
RO/DM Cooling
70 40
Ice Reaction Scrubber
100 31+100=131 22

Water from Boiler

RM-7 makeup
HCl SBS
54
12 10
Total
138
Blow Down
6

ML Condense
86 52

ETP
Sale to MEE-1 Condensate* 30
textile Mills 52 40(Cooling)

G-Salt
MEE-2 Solar
12 Evaporation
Concentrated
Organic

Incinerated
2. The company shall adopt cleaner Being Complied: Certain measures like
production technology to minimize the vacuum filtration system, vacuum ejectors
quantity of fresh water equipment and in process, Multi Effect Evaporate (MEE)
process effluent generation. system and recovery of so2in soda ash
solution etc. have been implemented.
Moreover, design of esterification vessel
has been changed to reduce power
consumption.
3. The process emissions from of HCl and Being Complied: Two stage ventury water
so2 shall be scrubber by two stage scrubber followed by two stage alkali
ventury water scrubber followed by scrubber were provided for scrubbing of
two stage alkali scrubber. HCL and so2.
4. Particulate emissions from the steam Not Complied: Cyclone separator was
boiler shall be controlled by installation installed for steam boiler with stack height
of ESP. Adequate height as per CPCB of 30 mtr. Stack height of thermic fluid
standard shall be provided to thermic heater was found less than the prescribed
fluid heater, incinerator and process height as observed during visit. Monthly
gas stack for dispersion of gaseous monitoring reports of steam boiler, thermic
emission. The fugitive emissions shall fluid heater, incinerator process stack 1 and
be controlled by regular maintenance 2 were submitted regularly which do not
of values, pumps and other equipment show any anomaly. Particulate matter,
to prevent leakage. The entire process chlorine and NOx were not monitored in the
shall be carried out in the closed process stacks. RSPM was monitored in the
reactor with proper maintenance of packing area, raw material storage yard
pressure and temperature. and lignite handling area on monthly basis
and reports do not show any anomaly. With
regards to fugitive emissions at the work
place VOCs were not monitored. Although
PA has claimed that adequate measures
have been taken to control fugitive
emissions but it was observed that process
vessels and other associated facilities were
in dilapidated condition (Photo 3-5).
Considering the status at the site and the
information provided, condition is
considered as not complied.
Clarification/Action plan:
1. Regarding installation of ESP
We have never proposed ESP for emission control of boiler because it is techno-
commercially not feasible for such capacity of boiler. We have proposed to install
Cyclone separator before put up the proposal to MoEF for our earlier EC. This
condition was amended by MoEF on 03.06.2009 with word of “Particulate
emissions from the 6 TPH steam boiler shall be controlled by installation of
Cyclone separator” and we have submitted this letter to MoEF office, Bhopal,
chances to oversight this modified condition.
Instead of that, we have installed Cyclone separator & bag filter to control the
emission from the boiler. Bag filter may not be observed by zonal officer, MoEF, but
it is there since beginning. Photographs of same are enclosed in next pages.
2.Regarding visual stack height of Thermic fluid heater
Capacity of thermic fluid heater is only 4 lakhs kcal/hr. and fuel requirement is
maximum 150 kg/hr. of lignite having gross calorific value 3000 kcal/kg. Sulphur
content in lignite is max. 2.4%. Based on the stack height calculation, it is tune
around 12.7 m and we have proposed and install 15 mtr. Stack height.
3. Particulate matter, chlorine and NOx were not monitored in the process
stacks
Above pollutants are not generated from our process and it is not in our proposal and
not in condition of EC. So it is not relevant with our EC condition.
Based on EIA report, we are complying this condition.

Photographs of Bag filter installed

5. The PA shall strictly comply with Being Complied. Risk assessment report and
the rules and guidelines under onsite emergency plan has been prepared.
MSIHC rules, 1989 as amended in Necessary permission from CEE was also
Oct., 1994 and January, 2000 and obtained for storage of Ethylene Oxide. An
HWMH Rules, 1989, as amendment authorization under HWMH rules was
from time to time. Authorization obtained. Membership of M/s. NEPL and M/s
from the SPCB shall be obtained BEIL has been obtained. The details of
for collection, treatment, storage, generation and disposal of hazardous waste
and disposal of hazardous wastes. have been provided which show that
All Transportation of Hazardous generation of incineration ash and
Chemicals shall be as per the MVA, hydrochloric acid was higher than the
1989. The GPCB shall ensure that permissible limits whereas other categories
capacity for disposal of waste at were found within the limits. The storage of
Naroda TSDF is available. hazardous waste was found in accordance
with the rules.
6. Hazardous chemicals shall be Not Complied. Hazardous chemicals were
stored in tanks in tank farms, stored in tank farm, drums and carboys etc.
drums, carboys, etc. flame PA has claimed that adequate safety
arresters shall be provided on tank measures were provided in the tank farm
farm. Solvent transfer shall be by area. However, the condition of storage tanks
pumps. were not found in order and lot of emissions
were observed during the visit (Photos 6-7).
Storage tanks were found in dilapidated
condition.
Clarification/Action plan:
Heavy rain was at the time of visit and very difficult situation to visit entire process
plant & storage area. However, they have visited our plant based on our personal
request. Due to heavy rain & high humidity, cloudy atmosphere is observed
because of little fugitive emission. In regular day, there is insignificant fugitive
emission. Regarding storage of Haz. Chemicals, we have obtained PESO permission
for MAH chemicals and store it as per the guideline of PESO.
Action plan:
We have immediate take action and checked the thickness & pressure test of all
storage tanks including EO before scheduled of PESO condition and found adequate
and safe. Due to high humidity, some surface part of color was observed broken
and resulted to notice this point. Recent status of storage tanks are enclosed in
next page.
7. An area of 33% shall be developed Being Complied EC 2008 & EC 2012: few
as green belt. Selection of plants hundred plants have been grown within the
species shall be as per the premises covering an area of 30%.
guideline of CPCB.
8. The company shall seek permission Not Complied. There was two bores within
from the CGWA/SGWA to draw the the premises for which permission for drawl of
ground water. ground water was not obtained from
CGWA/SGWA.
Clarification/Action plan:
We have submitted an application to CGWA for permission which is awaited. We
have taken this matter on top priority & committed to obtained required permission
as early as possible.
10. Occupational health surveillance of Being Complied EC 2008 & EC 2012: All
the workers shall be carried out on the employees have been provided medical
the regular basis & records shall be facilities under Factories Act and records are
maintained as per the Factories Act. maintained.
Photograph of Hazardous chemicals storage tanks
9. The company shall harvest surface as Not Complied. PA has not developed
well as rain water from the rooftops of rainwater harvesting structures even after
the buildings and storm water drains to 7 years of grant of EC.
recharge the ground water and use the
same water for the various activities of
the project to conserve fresh water.
Clarification/Action plan:
GPCB does not favor to develop rain water harvesting structure in factory premises
because there could be probability of contamination of ground water due to industrial
effluent.
Instead of that, we have proposed to improve village lake for increase the storage
capacity of rain water which resulted to recharge groundwater. This matter is also
committed by us in front of District magistrate during public hearing & requested to
grant necessary permission for the same. Representative of company and sarpanch of
village panchayat is regularly followed up this matter and very soon we get the
permission and start the activity.
10. Occupational health surveillance of the Being Complied EC 2008 & EC 2012: All
workers shall be carried out on the the employees have been provided medical
regular basis & records shall be facilities under Factories Act and records
maintained as per the Factories Act. are maintained.
GENERAL CONDIRIONS
1. The project authorities shall strictly EC 2008 & EC 2012: Being Complied.
adhere to the stipulations made by the The CC&A was obtained from GPCB which
State Pollution Control Board. is valid up to 14.2.2019. The production
was found within the permissible limits as
per the details provided. The average
water consumption was 199.25 KLPD and
average waste water generation was 181
KLPD as per the environment audit report
2014 which is higher than the prescribed in
the ECs of 2009 & 2012. It was observed
that process vessels, storage tanks and
other associated facilities were in
dilapidated condition. The details of
generation and disposal of hazardous
waste have been provided which show that
generation of incineration ash and
hydrochloric acid was higher than the
permissible limits where as other
categories were found within the limits.
Online monitoring system not installed.
With regard to the monitoring of steam
boiler, thermic fluid heater, incineration,
process tank 1 & 2, it was noted that
monitoring being carried out on monthly
basis and reports show parameters within
the limits. Gypsum to the tune of 10452.15
MT was supplied to cement manufactures
namely M/S Ambuja cement Ltd., M/S JK
Lakshmi cement Ltd., M/S Sanghi
Industries Ltd., during Jan. 14 to July 15.
Housekeeping in the ETP and hazardous
 waste storage area needs sincere
attention.
2. No further expansion or modification in Being Complied EC 2008 & EC 2012: No
the plant shall be carried out without expansion and modification was carried out
prior approval of the MOEF. In case of so far without prior approval of the
deviations or alteration in the project competent authorities. The area has been
proposal from those submitted to this identified for the proposed expansion
ministry for clearance, a fresh reference (photo 8-9) and no work was started.
shall be made to the Ministry to assess
the adequacy of conditions imposed and
to add additional environmental
protection measures required, if any.
3. At no time, the emissions shall exceed Not Complied. Online monitoring system
the prescribed limits. In the event of not installed for critical parameters to
failure of any pollution control system ensure emissions within limits all the
adopted by the unit, the unit shall be times.
immediately put out of operation and
shall not be restarted until the desired
efficiency has been achieved.
Clarification/Action plan:
Our is small scale unit and now we are going to expand it after obtaining EC from
MoEF & CC. Online monitoring system is not a part of our earlier EC condition hence
we have not installed it. We are regularly checking the emission level by third party
and our environmental auditors are also monitored overall EMS system 3 to 4 times in
a year. GPCB is also monitored emission norms during surveillance visit if they feel
some abnormal emission. No major deviation found.
4. The gaseous emissions (NOx, HCl, SO2, Being Complied. Monthly monitoring
VOC & CO) and Particulate matter along reports of steam boiler, thermic fluid
with RSPM levels from various process heater, incineration, process tank 1 and 2
units shall conform to the standards were submitted which do not show any
prescribed by the concerned authorities anomaly. Particulate matter, Chlorine and
from time to time. At no time, the NOxwere not monitored in the process
emission levels shall go beyond the stacks. RSPM was monitored in the packing
stipulated standards. In the event of area, raw material storage yard and lignite
failure of pollution control system (s) handling area on monthly basis.
adopted by the unit, the respective unit
shall not be restarted unit the control
measures are rectified to achieve the
desired efficiency. Stack monitoring for
SO2, NOX and SPM shall be carried.
5. The locations of AAQ monitoring stains Being Complied EC 2008 & EC 2012:
shall be decided in consultation with the AAQ has been monitored at two stations
SPCB and it shall be ensured that at on monthly basis with parameters of SO2,
least one stations is installed in the up NOX, PM10 and PM2.5. Monitoring reports do
wind and downwind direction as well as not show any anomaly.
where maximum ground level
concentrations are anticipated.
6. Dedicated scrubbers and stacks of Being Complied. Dedicated scrubbers
 appropriate height as per the CPCB were to control emissions and scrubbed
guidelines shall be provided to control water was being treated in the ETP.
the emissions from various vents. The
scrubbed water shall be sent to ETP for
further treatment.
7. The company shall undertake following Being Complied EC 2008 & EC 2012: It
waste Minimization measures. was observed that waste minimization
Metering and control of quantities of measures like close feed system, recovery
active ingredients to minimize waste. of SO2 as sodium bio Sulphate, closed feed
Re use of by products from the system & high pressure jet nozzles for
process as raw materials or as raw cleaning have been implemented.
material substitutes in other processes.
Use of automated filling to minimize
spillage.
Use of “close feed” system into batch
reactors.
Venting equipment through vapour
recovery system.
Use of high pressure hoses for
equipment cleaning to reduce
wastewater generation.
8. Fugitive emissions in the work zone Not complies. Although PA has claimed
environment, product, and raw materials that adequate measures have been taken
storage area shall be regularly to control fugitive emissions but it was
monitored. The emissions shall conform observed that process vessels and other
to the limits imposed by the SPCB/CPCB. associated facilities were in dilapidated
condition. With regards to fugitive
emissions at the work place, VOCs no
monitored. Considering the status at the
site & the information provided, condition
is considered as not complied.
Clarification/Action plan:
We have taken best effort to minimize the fugitive emission by way of transfer the
liquid materials pneumatically and solid materials are charged in closed manner from
bottom of the vessels through charging silo. Little vacuum is maintain in reactor to
minimize fugitive emission in work zone. All the reactions are taken in closed reactors.
Visit was made during rainy days and resulted to observed foggy atmosphere in work
area.
9. The overall noise level in and around the Being Complied EC 2008 & EC 2012:
area plant shall be kept well within the Noise levels have been monitored at nine
standards by providing noise control locations on monthly basis and reports do
measures including acoustic hoods, not show any anomaly.
silencers, enclosures etc. on all source of
noise generation. The ambient noise
levels shall conform to the standards
prescribed under EP Act, 1986 Rules,
1989 viz. 75 dB A (daytime) and 70 dB
A (nighttime).
10. Training shall be imparted to all Being Complied EC 2008 & EC 2012:
employees on safety and health aspects Safety training was provided by outside
of chemicals handling. Pre-employment safety experts on six monthly bases. Fire
and routine periodical medical mock drills were also conducted
examinations for all employees shall be periodically. Workers have been provided
undertaken on regular basis. medical facilities as per Factories Act.
11. Usage of PPEs by all employees/ workers Being Complied. EC 2008& EC 2012:
shall be ensured. Usage of PPE'S by entire employee was
ensured. Workers have been provided
PPE’S like Helmets / Goggles / Hand gloves
/ Gumboots.
12. The PP shall also comply with all the Being Complied. EC 2008& EC 2012:
environmental protection measures and Major recommendations made in EIA
safeguards proposed in the project report have been implemented per details
report submitted to the Ministry. All the provided.
recommendations made in respect of
EMS and risk mitigation measures
relating to the project shall be
implemented.
13. The company will undertake all relevant Not Complied. EC 2008& EC 2012: CSR
measure for improving the Socio- activities have also not been undertaken as
economic conditions of the surrounding per the condition.
area. CSR activities will be undertaken
by involving local villages and
administration.
Clarification/Action plan:
It is gray area and we will focus in this matter.
We committed to strengthen our CSR activities as per the CSR plan of EIA report.
Summary of fund allocation are given in next slide.
Budgetary provisions for the next five years (Every Year)
Sr. No. Activities Budgetary provision (Lakhs)
1. Educational activities 15
2. Preservation of the Environment 7
and Sustainable Development
3. Health and family welfare 5
4. Drinking water and sanitation 10
facilities
5. Miscellaneous as per the demand 13
of surrounding villages
Total 50
14. The company shall undertake eco- Not Complied. EC 2008 & EC 2012:
developmental measures including Eco- development measures including
community welfare measures in the community welfare measures have not
project area for the overall improvement been taken up.
of the environment.
Clarification/Action plan: Committed to fulfill Eco- development measures including
community welfare measures nearby project area to improve the environment.
15. A separate EMC equipped with full- Being Complied. EC 2008 & EC 2012:
fledged laboratory facilities shall be set The EMC at site was established under Sr.
up to carry out the Environmental Vice President- Project who is supported by
Management and Monitoring functions. ETP cell-in-charge and supporting staff.
16. The PA shall earmark adequate funds to Being Complied. EC 2008 & EC 2012:
implement the conditions stipulated by Rs.3.50 Cr. Was incurred during 2014-15
the MOEF as well as the State Govt. on EMP (for ETP operation and waste water
along with the implementation schedule Recycling/Hazardous waste management).
for all the conditions stipulated herein.
The funds so provided shall not be
diverted for any other purpose.
17. The implementation of the project vis-à- Not Complied. EC 2008 & 2012: Half
vis environmental action plans shall be yearly compliance with analytical reports
monitored by the concerned RO of has been submitted. RO Bhopal has
Ministry/SPCB/ CPCB. monitored the project. PA has not
A six monthly compliance status report uploaded EC. Compliance status, analytical
shall be submitted 10 monitoring data, ES Form-V, consent the website of
agencies and shall be posted on the the company.
website of the Company.
Clarification/Action plan: Our is small scale unit and IT expert is not appointed.
However, we will hire this service and start uploading of compliance report, analytical
data, ES Form-V on our website and will update it regularly.
18. The PP shall inform the public that the Not Complied. EC 2008: PA had informed
project has been accorded EC by the the public about grant of EC by means of
Ministry and copies of the clearance advertisement in only one newspaper
letter are available with the namely "The Indian Express" dated
SPCB/Committee and may also be seen 03.05.2008, but clause of seven days was
at website the Ministry at not followed.
http://envfor.nic.in. This shall be Being Complied. EC 2012: PA had
advertised within seven days from the informed the public about grant of EC by
date of issue of the clearance letter, means of advertisement in two widely
atleast in two local newspapers that are circulated local newspapers namely "The
widely circulated in the region of which Indian Express" and "Jansatta" dated
one shall be in the vernacular long age 22.12.2012 i.e. within fifteen days. Thus,
of the locality concerned and a copy of condition was considered as complied.
the same shall be forwarded to the
concerned RO of the Ministry.
19. The PA shall inform the Regional Once as Not Complied. EC 2008 & EC 2012: The
well as the Ministry, the date of financial term loan of RS. 4.50 Cr. was sanctioned
closure and final approval of the project by State Bank of India vide letter dated
by the concerned authorities and the 8.10.08 for EC 2008. With regard to EC
date of start of the project. 2012, details of financial closure were not
submitted either.
20. The Ministry may revoke or suspend the EC 2008 & EC 2012: Agreed to Comply.
clearance, if implementation of any other
above conditions is not satisfactory.
21. The Ministry reserves the right to EC 2008 & EC 2012: Agreed to Comply.
stipulate additional conditions, if found
 necessary. The company in a time bound
manner will implement these conditions.
22. Any appeal against this EC shall lie with Noted & Agreed as submitted by PA.
the National Appellate Authority, if
preferred, within a period of 30 days as
prescribed under section 11 of the NEAA
Act. 1997.
23. The above conditions will be enforced. EC 2008 & EC 2012: Being Complied. It
Inter-alia under the provisions of the is inferred from the above that the CC&A
Water (P & CP) Act, 1974, Air (P & CP) was obtained from CPCB which is valid up
Act. 1981, the EP Act.1986 HWMH Rules, to 14.2.2019. The production was found
2003 and the PLI Act, 1991 along with within the permissible limits as per the
their amendments and rules. details provided. The average water
consumption was199.25 KLPD and average
waste water generation was 181 KLPD as
per environment audit report 2014 which is
higher than the prescribed in the ECs of
2009 & 2012. It has observed that process
vessels, storage tanks and other
associated facilities were in dilapidated
condition. The details of generation and
disposal of hazardous waste have been
provided which show that generation of
incineration ash and hydrochloric acid was
higher than the permissible limits whereas
other categories were found within the
limits. Online monitoring system was not
installed. With regard to the monitoring of
steam boiler, thermic fluid heater,
incinerator, process stack 1& 2, it was
noted that monitoring was being carried
out on monthly basis and reports show
parameters within the limits. Gypsum to
the tune of 10452.15 MT was supplied to
cement manufacture namely M/s. Ambuja
Cement Ltd., M/s. J.K. Lakshmi Cement
Ltd., M/s. Orient Cement Ltd., M/s. Sanghi
Industries Ltd. during Jan. 14 to July 15.
Housekeeping in the ETP and hazardous
waste storage area needs sincere
attention. Copy of PLI was submitted which
was valid up to 24.3.2015.
AS per EC no. J-11011/552/2010-IA. II (I) dated 7.12.2012.
SPECIFICATION CONDITIONS
1. All the specific conditions and general Being Complied. It has been inferred
conditions specified in the earlier EC from the above mentioned review that
letters accorded vide Ministry's letter no. majority of conditions have been complied
J-11011/1059/2007-IA.II (I) dated where as conditions pertaining to
22.9.2008 shall be implemented. generation of HW and its storage &
disposal, installation of online monitors.
Monitoring of fugitive emissions etc.,
needs sincere efforts.
2. The national emission standards for Being Complied. Analytical reports of
organic chemicals manufacturing AAQ and stacks show parameters within
industry issued by the Ministry vide GSR the stipulated norms.
608 (E) dated 21.7.2010 and amended
time to time shall be followed by the
unit.
3. As proposed, production capacity shall Being Complied. The production was
be increased from 500 TPM to 600 TPM found within the permissible limits as per
by debottlenecking in the process the details provided.
without adding any equipments/utilities.
4. Bag filter along with stack of adequate Being Complied. Bag filters have been
height will be provided to proposed coal/ provided to boiler stack and monthly
lignite fired Boiler. Two stage chilled monitoring reports do no1 show any
water/caustic scrubber should be anomaly. Besides three stage scrubbing
provided to process vents to control HCl. system with chilling water circulation
Two stage scrubbers with caustic lye system was installed (Photo 10). Caustic
media solution should be provided to lye solution was being circulated in third
process vents to control SO2. The stage scrubber to control SO2 emissions.
scrubbing media should be sent to ETP The scrubbed solution was being treated
for treatment. The scrubbing solution in the ETP. Interlocking system was
shall be sent to ETP for treatment. provided. However, online monitors have
Efficiency of scrubber shall be monitored not been installed.
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 be
submitted to the Ministry's RO at Bhopal.
5. The National AAQ emission standards Same as above mentioned specific
issued by the Ministry vide GSR No. condition No. 2 of EC 2012.
826(E) dated 16.11.2009 shall be
followed.
6. In plant control measures of checking Being Complied. PA has submitted the
fugitive emissions from all the vulnerable following:
sources shall be provided. All the ● All the reactors have been provided with
 reactors shall be connected to an cooling chilling condenser;
efficient condenser system with ●All the liquid raw materials were being
cooling/chilling brine circulation. Fugitive transferred pneumatically and entire
emission shall be controlled by providing process was being taken in close vessel;
closed storage, closed handling & ● Mostly liquid raw materials have been
conveyance of chemicals/materials, used and transfer pneumatically with
multi cyclone separator and water taken care to zero laminated bags hence
sprinkling system. Dust suppression sprinkling system in material handling
system including water sprinkling system area may not require;
shall be provided at loading and ● Work zone monitoring has been carried
unloading areas to control dust out regularly and analysis report was
emissions. Fugitive emission in the work being submitted regularly.
zone environment, product, raw But, it was observed that process vessels
materials storage area eta. Fugitive and other associated facilities including
emission in the work zone environment, incinerator were in dilapidated condition
product, raw materials storage area etc. and lots of emissions were observed
shall be regularly monitored and records during the visit. PA was directed to rectify
maintained. The emissions shall conform the same.
to the limits stipulated by the GPCB.
7. For further control of fugitive emissions, Being Complied. PA has submitted the
following steps shall be followed: following:
1. Closed handling system shall be ● Closed pneumatic system has been
provided for chemicals. already provided with pump of mechanical
2. Reflux condenser shall be provided seal to avoid any leakages.
over reactor. ● There was no need of any reflux
3. System of leak detection and repair of condenser, since solvents were not being
pump/pipeline based on preventive used.
maintenance. ● Leak detection system was not found
4. The acids shall be taken from storage although PA has claimed that they are
tanks to reactors through closed having an elaborative preventive
pipeline. Storage tanks shall be vented maintenance schedule.
through trap receiver and condenser ● Acid handling transfer through closed
operated on chilled water. pipeline was in practice.
5. Cathodic protection shall be provided ● Overhead tanks were provided with
to the underground solvent storage proper earthing facility.
tanks.
8. The gaseous emissions from DG set shall Being Complied. DG sets were installed
be dispersed through adequate stack in closed rooms with adequate stack
height as per CPCB guideline. Acoustic height.
enclosure shall be provided to the DG
sets to mitigate the noise pollution.
9. The company shall upload the status of Not Complied. PA has not uploaded
compliance of the stipulated EC compliance report including results of
conditions, including results of monitored monitored data on company's website.
data on its website and shall update the Half yearly reports were being submitted
same periodically. It shall simultaneously to MoEF, Bhopal, CPCB and GPCB. Sign
be sent to the RO of MOEF, the board has been provided as per condition.
respective Zonal Office of CPCB and the
 GPCB. The levels of PM10, SO2, NOx, CO,
VOC and HC in ambient air shall be
monitored & displayed at a convenient
location near the main gate of the
company and at important public places.
10. Solvent management shall be carried out Not pertains to project. As mentioned
as follows: above solvent has not been used in the
a) Reactor shall be connected to chilled process, the condition may not be
ne condenser system. applicable to the project as argued by PA.
b) Reactor and solvent handling pump However, earthing was provided to EO
shall have mechanical seals to prevent storage tanks.
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 should be provided
with breather valve to prevent losses.
g) All the solvent storage tanks should
be connected with vent condensers with
chilled brine circulation.
11. Total fresh water requirement from Not Complied. The average water
groundwater source shall not exceed consumption was 199.25 KLPD and
145 m3/day and prior permission shall average waste water generation was 181
be obtained from the CGWA/SCWA. A KLPD as per environment audit report
copy of permission to the Ministry's RO 2014 which is higher than the prescribed
at Bhopal. limits. There were two bore within the
premises for which permission for drawl of
ground water was not obtained from
CGWA/ SGWA.
Water consumption
As per our last EC issued in 2012, total ground water requirement from 132 m3/day
to 145 m3/day after expansion. Detailed water balance is given on page no. 2 of this
document. Water balance diagram indicate that 40 m3/day recycle water from
condensate of MEE. So total water requirements is tune around 185 m3/day. As per
Environmental audit report its tune around 199.25 KLPD which is little higher
because less water consumption submitted by us for domestic & greenbelt
development in our earlier EC proposal and actual consumption in both the head is
high. We have modified it in our current proposal.
12. Industrial effluent generation shall not Same as above mentioned specific
exceed 82m3/day. Industrial effluent will condition no. I of EC 2008.
be segregated into high TDS/high COD &
low TDS/low COD streams. High
 TDS/high COD effluent streams will be
treated in stripper, MEE and incinerator.
Low TDS/low COD effluent stream will be
treated in the ETP. Condensate from
evaporation will be reused/recycled for
cooling tower make up water.
Wastewater Generation
Pl. refer water balance diagram for existing set up which shows that actual
wastewater generation is tune around 168 KLD (82 m3/day Effluent + 86 m3/day ML)
whereas as per the Audit report it is tune around 169 KLD. It is very marginal
difference and we have further reduced it to control excess use of water.
13. No effluent shall be discharged outside Not Complied. Although PA has claimed
the premises and 'Zero' discharge that the effluent was not being discharged
concept shall be adopted. outside the premises, but it was observed
that solar evaporation pond does not have
adequate capacity with regard to
generation of effluent. Since detailed
water balance was not submitted, zero
discharge could not be ensured. Thus,
condition is considered as not complied.
Clarification/Action plan: Currently our solar evaporation pond is used for storage
of treated effluent before evaporate it in our evaporator. We have one solar
evaporation pond of average 410 sqm area. We wish to inform you that, this pond is
intermediate storage before evaporate it in our evaporator and has capacity of 820
m3 and retention is tune around 5.0 days and it is adequate as per our requirement.
14. Process effluent/any wastewater shall Being Complied. It was observed that
not be allowed to mix with storm water. storm water channel was developed but
Storm water drain shall be passed mixing from the washing area/ETP could
through guard pond. not be avoided during monsoon as evident
from the Photo 11.
15. Incinerator comprising primary and Not Complied. Incinerator was not
secondary chamber shall be designed as designed as per CPCB guidelines. Photo 1
per CPCB guidelines. shows the status of the incinerator which
has only one chamber.
Clarification/Action plan: Our Incinerator is too old and installed in the year of
1998 at that time mechanical evaporator (MEE) was not so popular and industries
were installed and operate Incinerator for evaporation of effluent rather than
incinerator for decomposed of toxic compound. In the same philosophy, we have
installed it and operate as evaporator. So practically, installed incinerator with single
chamber is not incinerator but evaporator/dryer to dry concentrated slurry/ML of
MEE.
16. As proposed, gypsum shall be sent to Being Complied. Gypsum to the tune of
cement industries. ETP sludge, 10452.15 MT was supplied to cement
evaporated residue and incinerated ash manufacturers namely M/s Ambuja
shall be disposed off to the TSDF. Cement Ltd., M/s J.K. Lakshmi Cement
Ltd. M/s Orient Cement Ltd., M/s Sanghi
Industries Ltd. during Jan. 14 to July 15.
Incinerator ash/salt was being is disposed
 off to TSDF site of M/s BEIL, Ankleshwar.
17. The company shall obtain authorization Same as above mentioned specific
for collection, storage and disposal of condition no. 5 of EC 2008.
hazardous waste under the HWMH and
Trans-Boundary Movement Rules. 2008 Being Complied.
and amended as on date for
management of hazardous wastes and
prior permission from CPCB shall be
obtained for disposal of solid/hazardous
waste in the TSDF. Measures shall be
taken for firefighting facilities in case of
emergency.
18. The company shall strictly comply with Same as above mentioned specific
the rules and guidelines under MSIHC condition no. 5 of EC 2008.
Rules, 1989as amended in Oct., 1994 &
January, 2000. All transportation of Being Complied.
hazardous chemicals shall be as per the
Motor Vehicle Act (MVA), 1989.
19. Necessary precaution should be taken Being Complied. PA has argued that
during transportation of ethylene oxide. supply of ethylene oxide is in the scope of
Entire risk should lie with the authorized manufacturer of EO till delivery at the
supplier till the delivery at project site. It project sire. This has been included as
should be mentioned clearly in the part of purchase order issued to EO
contract documents. For bulk supplied. Thus, condition is considered as
transportation of Ethylene Oxide & the complied.
traders
carrying them must follow:
a) A fixed route after conducting a route
survey, from the EO/Acrylonitrile
suppliers/ storage premises to plan.
b) GPS system for constant monitoring
of the truck movement.
20. The unit shall make the arrangement for Being Complied. Fire-fighting system at
protection of possible fire hazards during EO storage area and foam/CO2
manufacturing process in material extinguishers has been provided in the
handling. Fire-fighting system shall be as process area to control the fires. PA was
per the norms directed to install adequate no. of sensors
at the strategic locations 10 make system
more effective.
21. Fire hydrant system shall be provided Not Complied. Fire monitor and flame
along with fire monitor and flame detector system was not provided.
detection system in the process as well
as storage areas.
Clarification/Action plan: Fire monitor and flame detector system will be installed.
22. Provision shall be made for the housing Being Complied. Since project was
for the construction labour within the commissioned long back and expansion
site with all necessary infrastructure and was implemented by means of
facilities such as fuel for cooking, mobile "debottlenecking of the process system",
 toilets, mobile sewage treatment plant, thus, condition could not be verified. PA
safe drinking water, medical health care, has intimated during the discussion that
crèche etc. The housing may be in the construction labours were coming from
form of temporary structure to be nearby villages. Therefore, condition is
removed after the completion of the considered as complied.
project. All the construction wastes shall
be managed so that there is no impact
on surrounding environment.
GENERAL CONDITIONS
1. A copy of the clearance letter shall be Not Complied. Although PA has
sent by the PP to concerned Panchayat, submitted that condition is compiled but
Zila Parisad/ Municipal Corporation. no documentary evidence was submitted.
Urban local body and the local NGO, if
any, from who suggestions/
representations. If any were received
while processing the proposal.
Clarification/Action plan: Copy of the clearance letter forwarded to Village
Panchayat-Indrad, Zila Parisad-Mehsana and other plausible stack holder from
representations received during public hearing.
2. The ES for each financial year ending Complied. PA has submitted ES Form-V
31st March in Form-V as is mandated to GPCB regularly. With regard to
shall be submitted to the concerned uploading on the website the
SPCB as prescribed under the EP Rules, implementation is same as above
1986, as amended subsequently, shall mentioned general condition no. 17 of
also be put on the website of the EC 2008.
company along with the status of
compliance of EC conditions and shall
also be sent to the respective RO of
MoEF by email.