S. MONTHLY COMPLIANCE REPORT-APRIL to SEPTEMBER... · Industri al Domest ic Total As Per EC Received 1 300 36 336 * Effluent generation is much lower than ... multi cyclone separator

S.

No Conditions of Environment Clearance

Status Status of Compliance

1 Kindly refer to your letter dated 28th April,

2011 along with project documents

including Form I. Terms of References,

Pre-feasibility Report, EIA/EMP Report,

public hearing report and subsequent

communications vide your letters dated

25th June, 2011, 30th June, 2011 and 2nd

August, 2012 on the above mentioned

subject.

Complied Noted.

2 The Ministry of Environment and Forests

has examined the application. It is noted

that the proposal is for expansion of

Specialty Chemicals Manufacturing Unit at

Plot No.166/1-3,171/1,172,167,168,

Village Padana. Gandhidham, District

Kutch. Gujarat by M/s Kutch Chemicals.

Total cost of the project is Rs.117.6 Crore.

Total plant area is 75,000 m2. Following

products will be manufactured:

Complied Proposal is for expansion of Specialty

Chemicals Manufacturing Unit at Plot

No.166/1-3.171/1,172,167,168, Village

Padana. Gandhidham, District Kutch,

Gujarat by M/s Kutch Chemicals.

Total cost of the project is INR 117.6

Crore including the cost of existing

plant. Total plant area is 75,000 m2.

At present, we are not manufacturing all

EC Products. We are only manufacturing

Acetanilide, Sulfamic Acid, Di methyl

Sulphate, Diethyl Sulphate, Di calcium

Phosphate and Power plant from

Proposed EC product list.

S

.

N

.

Products

Exist

ing

(MT

PM)

Additi

onal

(MTP

M)

Total

(MTP

M)

1

Nitro Derivates

of hydrocarbon

such as Nitro -

chloro benezene,

Nitro toluene.

Nitro Cumene,

nitro Xylene,

nitro benzene

2400 - 2400

2

Amino

Hydrocarbon

such as Chloro

aniline, toludine,

Cumidine,

Xylidine, aniline

2000 - 2000

3

Methoxylation of

nitro chloro

compound &

hydrolysis such

as Ortho

anicidine, para

100 - 100

S.



anicidine

4

Amonolysis of

nitro chloro

compound &

hydrolysis such

as Ortho nitro

aniline, Para

nitro aniline

100 - 100

5 Mono Chloro

Benzene 1000 - 1000

6 Di Chloro

Benzene 500 - 500

7 Chlorinated

paraffin wax 550 - 550

8 Acetanilide 1000 3000 4000

9 Vinyl Sulphone 500 4000 4500

1

0

Sulphonation of

PNT, ONT, VS,

Tobias, etc.

0 1500 1500

1

1

Benzene

Sulphonyl

Chloride

0 1500 1500

1

2 DASDA 0 1000 1000

1

3 V.S. Condense 0 1000 1000

1

4

Dimethyl Sulfate

(DMS) 100 3000 3100

1

5

Dimethyl Aniline

(DMA) 0 1500 1500

1

6

Diethyl Sulfate

(DES) 0 1500 1500

1

7 Sulfamic Acid 0 1000 1000

1

8

Power Plant

(Coal)

2.5

MW

(FO)

10

MW

(Coal)

12.5

MW

(FO &

Coal)

1

9

Sulphuric Acid

(98%) 7500 15000

2250

0

2

0

Oleum (23% &

65%) 0 3000 3000

S.



2

1

Liquid SO3 (70-

90%) 0 7500 7500

2

2

Chloro Sulphonic

Acid 1200 5000 6200

2

3 Thionyl Chlroide 0 5000 5000

2

4

Sodium

Bisulphite (SBS) 0 3000 3000

2

5 Calcium Chloride 0 4000 4000

2

6

Dicalcium

Phosphate (DCP) 0 1500 1500

2

7

Sulphur

Monochloride 0 200 200

2

8

Sulphuryl

Chloride 0 200 200

2

9

Alumunium

Sulphase (ALIM) 0 1000 1000

3 Multi-cyclone followed by bag filter will be

provided to the coal fired boiler.

Adequate scrubbing system will be

provided to the process vents to control

process emissions viz HCl, SO2 and NH3.

Total fresh water requirement from

Gujarat Water Infrastructure Limited will

be 1,520 m3/day after expansion.

Industrial effluent generation will be 336

m3/day after expansion.

Complied

APCM Provided in Power Plant:

S.

N

As

per

EC

Provided

at Site Details

1

Multi-

Cyclon

e +

Bag

Filter

ESP

Higher

efficient

ESP is

provided

having 3

fields and

>99%

efficiency.

Though expansion has not taken place,

existing plants is having scrubbing

system for HCl, SO2 & NH3.

Fresh Water Requirement:

S.

No

.

Fresh Water Requirement in

KLD

Industri

al

Domest

ic Total

As Per EC Received

1 1,470 50 1,520

* Since, no major expansion has taken

S.



Process effluent from vinyl sulphone after

recovery of sodium sulphate will be sent to

incinerator.

High TDS effluent stream will be passed

through stripper followed by Multi effect

evaporator (MEE). Condensate and low

COD/ TDS effluent stream will be treated

in effluent treatment plant (ETP).

Domestic sewage will be treated in

Sewage Treatment Plant STP, Treated

effluent will be recycled/reused within

factory premises.

No effluent will be discharged outside the

premises and 'Zero' effluent discharge

concept will be adopted.

ETP sludge process inorganic, evaporation

salt and incinerator salt will be sent to

treatment storage disposal facilities (TSDF)

for hazardous waste.

Used oil will be sold to registered

recyclers/re-processor.

Fly ash will be sent to brick

manufacturers/cement industry.

place at site till date; water requirement

is much lower than the quantity as

mentioned in EC.

S.

N

o.

Waste Water Generated in

KLD

Industri

al

Domest

ic Total

As Per EC Received

1 300 36 336

* Effluent generation is much lower than

the quantity as mentioned in EC as no

major expansion has taken place.

Effluent from existing Vinyl Sulphone

(VS) after recovery of sodium sulphate

is sent to incinerator. Same will be done,

once the expansion of VS takes place.

High TDS effluent stream is passed



COD/ TDS effluent stream is treated in

effluent treatment plant (ETP).

STP is not installed at the site. Domestic

sewage is currently disposed off in

septic tank & soak pit.

No effluent is discharged outside the


concept is adopted.

ETP sludge process inorganic,

evaporation salt and incinerator salt is

currently being sent to treatment

storage disposal facilities (TSDF) for

hazardous waste. Logbook of ETP &

MEE is being maintained copy of the

same is attached as Annexure-1.

Maximum quantity of used oil is reused

within the plant premises and excess oil

is stored in the drums (Closing stock 0.1

S.



KL) and will be sold to registered

recyclers/re-processor.

Fly ash is sent to brick manufacturers.

4 Public hearing was conducted on 1st

February, 2011.

Complied

.

Public hearing was conducted on 1st

February, 2011. Compliance of all the

points are provided in previous EC

Compliance report (October 2016 to

March 2017)

5 All synthetic organic chemical industries

located outside the notified industrial

estate/area are listed at S.N. 5(f) under

category 'A' and appraised at Central level.

Complied

.

Noted.

6 The proposal was considered by the Expert

Appraisal Committee (lndustry-2) in its 7th,

25th and 2nd meetings held during 15th-

16th January, 2010, 28th- 30th July, 2011

and 29th - 31st October, 2012 respectively.

The Committee recommended the

proposal for environmental clearance.

Complied

.

Noted.

7 Based on the information submitted by the

project proponent, the Ministry of

Environment and Forests hereby accords

environmental clearance to above project

under the provisions of EIA Notification

dated 14th September, 2006, subject to the

compliance of the following Specific and

General Conditions.

Complied Noted.

A Specific Conditions

1 National Emission Standards for Organic

Chemicals Manufacturing Industry issued

by the Ministry vide G.S.R. 608(E) dated

21st July, 2010 and amended time to time

shall be followed by the unit.

Complied Emission standards for organic chemical

manufacturing industries is being

complied.

1) Stack Results:

Stack monitoring results are attached as

Annexure-2.

2) Waste water Analysis Results:

All values in mg/l, except pH, which has

no unit.

Where, S1: Boiler Blow down + Cooling

tower Blow down + Organic Process like

Nitration etc., S2: VS Process Stream,

S3: Condensate Recovery, S4:

Concentrated Stream

NM: Not Measurable, BDL: Below

Detection Limit

S.



Waste Water results are attached as

Annexure-3.

3) Noise Results:

Noise monitoring results for are

attached as Annexure-4.

2 Multi-cyclone followed by bag filter shall be

provided to the coal fired boiler to control

particulate emissions within permissible

limit.

The gaseous emissions shall be dispersed

through stack of adequate height as per

CPCB/GPCB guidelines.

Complied APCM Provided in Power Plant:

S.

N

As

per

EC

Provided

at Site Details

1

Multi-

Cyclon

e +

Bag

Filter

ESP

Higher

efficient

ESP is

provided

having 3

fields and

>99%

efficiency.

Though expansion has not taken place,

existing plants is having scrubbing

system for HCl, SO2 & NH3.

Stack details are calculated as per

formula provided by CPCB for Power

Plant, H=14 (Q)^0.3, where Q = SO2

emisisons (in kg/hr). In our case, 156

TPD Coal having 0.5% sulphur content

is considered for 6.5 MW Power Plant.

S.

No

.

Stack

attache

d to

Stack

Height

Provide

d

Stack

Height

as per

CPCB

1

New

Power

Plant

60 mtrs 48 mtrs

S.



3 Two stage chilled water/caustic scrubber

shall be provided to process vents to

control HCL. Two stage scrubbers with

caustic lye media solution shall be

provided to process vents to control SO₂.

Two stage scrubbers with chilled Water

media shall be provided to process vents

to control NH₃. The scrubbing media shall

be sent to effluent treatment plant (ETP)

for treatment. Efficiency of scrubber shall

be monitored regularly and maintained

properly. At no time, the emission levels

shall go beyond the prescribed standards.

Scrubbers vent shall be provided with on-

line detection and alarm system to indicate

higher than permissible value of controlled

parameters.

Complied Expansion is not taken place for organic

products. For existing plants, chilled

water caustic scrubber to control HCl

emission, where as two stage scrubbers

with caustic lye media solution to control

SO2 and chilled water scrubbing is

provided to control the NH3 emissions.

The scrubbing media is being sent to

Effluent Treatment Plant for further

treatment. Efficiency of above scrubbers

is being monitored regularly and

maintained properly.

Online detection and alarm system will

be installed once expansion for organic

products will take place.

4 Ambient air quality data shall be collected

as per NAAQES standards notified by the

Ministry vide G.S.R. No. 826(E) dated 16th

November, 2009.

The levels of PM, SO2, NOx, VOC, HCl, NH3

and CO shall be monitored in the ambient

air and displayed at a convenient location

near the main gate of the company and at

important public places.

The company shall upload the results of

monitored data on its website and shall

update the same periodically. It shall

simultaneously be sent to the Regional

office of MOEF, the respective Zonal office

of CPCB and Gujarat Pollution Control

Board (GPCB).

Complied

.

The locations of ambient air quality

monitoring stations were decided in

consultation with the GPCB and one

stations is installed in the upwind and

downwind direction as well as where

maximum ground level concentrations

are anticipated. Ambient Air Monitoring

was carried out by Ecosystem Resource

Management Pvt. Ltd,Surat at different

location like Main Gate, Near Sulphur

Storage Area, Near VS Plant & Near

ETP.

It is found that average AAQ meets the

prescribed standards.

Results are monitored and displayed at

Main gate. One copy of result is

attached as per Annexure-5.

Six monthly compliance report having

the monitored data are uploaded on the

company’s website. The same is sent to

the Regional office of MOEF, Bhopal &

GPCB time to time. Uploaded photo of

screen shot of six monthly compliance

S.



report on website is attached as per

Annexure-5A.

5 In plant control measures for checking

fugitive emissions from all the vulnerable

sources shall be provided.

Fugitive emissions shall be controlled by

providing closed storage, closed handling

& conveyance of chemicals/materials,

multi cyclone separator and water

sprinkling system. Dust suppression

system including water sprinkling system

shall be provided at and unloading areas

to control dust emissions.

Fugitive emissions in the work zone

environment, product, raw materials

storage area etc. shall be regularly

monitored.

The emissions shall conform to the limits

stipulated by the GPCB.

Complied

Control measures provided for fugitive

emissions within existing unit is

tabulated below:

S. N.

Parameter

Location

Control Measures

1 SPM

Coal Handling

Area

• Closed conveyor belts are provided for transfer of Coal from Coal yard to Boiler.

• At crusher, water is being spread through sprinklers to avoid dusting.

• Apart from above, dust extraction system at coal crusher, bunkers is provided to avoid dusting.

2 HCl

MCB Plant, CPW Plant & VS Plant

• Water Scrubber are provided.

3 SO

2

Sulphuric Acid

Plant, VS

Plant

• In sulphuric acid plant, online SO2 analyzers are provided.

• Caustic Scrubber are provided.

4 NH

3

Chillers

• Chilled Water Scrubber are provided.

5 Cl2

Thionyl

Chloride, MCB Plant

& Chlori

ne yard

• Online gas leakage detection system and caustic scrubbers are provided.

• Scrubbing system which is being operated manually, is planned to switch over in auto mode.

6 VOC

MCB Plant,

• Online VOC detection system is provided.

Benzene UG

• Condensers are provided on vents.

S.



Tank Farm Area

Similar control measures and measures

as mentioned will be taken as and when

expansion & new plants are established.

Weekly in-house Work place monitoring

is carried out within the plant and

displayed at different locations as shown

in Annexure-6. Apart from that,

monitoring from third party is also

conducted by Third Party, M/s. ECO

Care having MoEF &CC approved

laboratory. Results of the same are also

provided in Annexure-6.

6 For further control of fugitive emissions,

following steps shall be followed :

(a) Closed handling system shall be

provided for chemicals.

(b) Reflux condenser shall be provided

over reactor.

(c) System pf leak detection and repair of

pump/pipeline based on preventive

maintenance.

(d) The acids shall be taken from storage

tanks to reactors through closed pipeline

storage tanks shall be vented through trap

receiver and condenser operated on chilled

water.

(e) Cathodic protection shall be provided

to the underground solvent storage tank.

Complied All the steps are being taken to control

the fugitive emissions in existing plant

and same will be taken as and when

expansion & new plants are established.

Photograph of benzene sensor near

existing benzene tank farm is given in

Annexure-7. Calibration certificate of

Cl2 sensors is provided in Annexure-8.

7 The gaseous emissions from DG set shall

be dispersed through adequate stack

height as per CPCB standards. Acoustic

enclosure shall be provided to the DG sets

to mitigate the noise pollution.

Complied At present no additional DG Sets are

required. Existing DG sets are provided

with acoustic enclosures and stack

height of 12 meters as per the

requirement of CPCB standards.

8 Solvent management shall be carried out

as follows:

(a) Reactor shall be connected to chilled

brine condenser system to condensate

solvent vapors and reduce solvent losses.

(b) Reactor and solvent handling pump

shall have mechanical seals to prevent

Complied During solvent storage and handling in

the existing plant, solvent management

is carried out as follows:

(a) Reactor is connected to chilled brine

condenser system to condensate solvent

vapors.

(b) Reactor and solvent handling pump

S.



leakages.

(c) The condensers shall be provided with

sufficient HTA and residence time so as to

achieve more than 95% solvent recovery.

(d) Solvents shall be stored in a separate

space specified with all safety measures.

(e) Proper earthling shall be provided in all

the electrical equipment wherever solvent

handling is done.

(f) Entire plant shall be flame proof. The

solvent storage tanks shall be provided

with breather valve to prevent losses.

have mechanical seals.

(c) The condensers are provided with

sufficient HTA and residence time.

(d) Solvents area stored in a separate

space specified with all safety measures.

(e) Proper earthling is provided in all the

electrical equipment wherever solvent

handling is done.

(f) Entire plant shall is flame proof. The

solvent storage tanks are provided with

breather valve to prevent losses.

All the similar steps will be carried out

when expansion & new plants are

established.

Photographs of earthing relay provided

at existing solvent storage tank is


9 Proper hood along with suction facility and

scrubbing arrangement shall be provided

in the chlorine storage area. Alarm for

chlorine leakage if any in the liquid

chlorine storage area is provided along

with automatic start of the scrubbing

system.

Complied Photograph of hood along with suction

facility and scrubbing arrangement in

the existing chlorine storage area is

shown in Annexure-10. Sensors for

chlorine are provided in chlorine

handling units. On-site emergency plans

are made and followed.

10 Total fresh water requirement from

Gujarat Water Infrastructure Limited

should not exceed 1,520 m3/day and prior

permission shall be obtained· from the

Competent Authority.

Complied Fresh Water Requirement:

S.

No

.

Fresh Water Requirement in

KLD

Industri

al

Domest

ic Total

As Per EC Received

1 1,470 50 1,520

* Since, no major expansion has taken

place at site till date, water requirement

is much lower than the quantity as

mentioned in EC.

11 Industrial effluent shall not exceed 336

m³/day.

Complied Effluent Generation:

S.

No

.

Waste Water Generated in

KLD

Industri

al

Domest

ic Total

S.



As proposed, process effluent from vinyl

sulphone after recovery of sodium

sulphate shall be sent to incinerator.

High TDS effluent stream should be

passed through stripper followed by MEE

Condensate and low COO/Low TDS

effluent stream shall be treated in ETP.

Treated effluent shall be recycled/reused

within factory premises. 'zero' effluent

discharge concept should be adopted and

no effluent will be discharged outside the

premises.

As Per EC Received

1 300 36 336

* Effluent generation is much lower than

the quantity as mentioned in EC as no

major expansion has taken place.

Effluent from existing Vinyl Sulphone

(VS) after recovery of sodium sulphate

is sent to incinerator. Same will be done,

once the expansion of VS takes place.

High TDS effluent stream is passed



COD/ TDS effluent stream is treated in

effluent treatment plant (ETP).

No effluent is discharged outside the


concept is adopted. And same will be

achieved once expansion & new plants

are established. Logsheet of MEE and

ETP are provided in Annexure-1.

12 As proposed, high calorific value waste

shall be sent to cement industries.

ETP sludge, process inorganic, evaporation

salt and incinerator salt should be disposed

off to the TSDF.

The fly ash from boiler shall be sold to

brick manufacturers/cement industry.

Complied Currently no high CV waste is being

generated.

ETP sludge, process inorganic and

incinerator ash disposed off to the TSDF.

The fly ash from boiler is sold to brick

manufacturers.

13 Incinerator along with its pollution control

device shall be designed as per CPCB

guidelines.

Complied Incinerator is designed as per CPCB

guidelines. Design of incinerator is


14 The company shall obtain Authorization for

collection, storage and disposal of

hazardous waste under the Hazardous

Waste (Management, Handling and Trans

Boundary Movement) Rules, 2008 and

amended as on date for management of

Hazardous wastes and prior permission

from GPCB shall be obtained for disposal

of solid / hazardous waste in the TSDF.

Complied The company has obtained CC&A as

AWH-65490 Authorization dated

30.09.2014, valid upto 18/07/2020.

Permission from GPCB is also taken for

disposal of solid / hazardous waste in

the TSDF.

S.



Measures shall be taken for firefighting

facilities in case of emergency.

Fire fighting facilities in case of

emergency are in place. Fire Hydrant

system is installed as per norms in the

whole plant.

15 The Company shall strictly comply with the

rules and guidelines under Manufacture

Storage and Import of Hazardous

chemicals (MSIHC) Rules, 1989 as

amended time to time.

All transportation of Hazardous Chemicals

shall be as per the Motor Vehicle Act

(MVA), 1989

Complied SOP is evolved & implemented for

movement of Hazardous chemicals as

enclosed as Annexure-12. All statutory

compliances for movement of Hazardous

chemicals like approval of CCE, RTO,

safe loading quantity, etc. are being

strictly followed.

16 The company shall undertake following

waste minimization measures :-

(a) Metering and control of quantities of

active ingredients to minimize waste

(b) Reuse of by-products from the process

as raw materials or as raw material

substitutes in other processes.

(c) Use of automated filling to minimize

spillage.

(d) Use of Close Feed system into batch

reactors.

(e) Venting equipment through vapour

recovery system.

(f) Use of high pressure hoses for

equipment clearing to reduce wastewater

generation

Complied Following waste minimization measures

have been taken for the existing units:

(a) Metering and control of quantities of

active ingredients to minimize waste

(b) Reuse of by-products from the

process as raw materials or as raw

material substitutes in other processes.

(c) Use of automated filling to minimize

spillage.

(d) Use of Close Feed system into batch

reactors.

(e) Venting equipment through vapour

recovery system.

(f) Use of high pressure hoses for

equipment clearing to reduce

wastewater generation.

All the steps as mentioned will be taken

as and when expansion & new plants

are established.

17 The unit shall make the arrangement for

protection of possible fire hazards during

manufacturing process in material

handling. Fire fighting system shall be as

per the norms.

Complied Fire Hydrant system is installed as per

norms in the whole plant.

Details of their components is provided

as under:

S. N. Fire Equip. Quantity

(Nos.)

1 Fire

Extingushier 250

2 Safety 40

S.



Shower

3 Sprinkler 4

Photograph is provided in Annexure-

13.

18 Training shall be imparted to all employees

on safety and health aspects of chemicals

handling.

Pre-employment and routine periodical

medical examinations for all employees

should be undertaken on regular basis.

Training to all employees on handling of

chemicals should be imparted.

Occupational health surveillance of the

workers should be done on a regular basis

and records maintained as per the

factories Act.

Complied Training is given to all employees on

safety and health aspects of chemicals

handling.



are conducted regularly. Training to all

employees on handling of chemicals is

provided regularly.

Details of training & medical checkup is

provided as below:

S.

N. Type

Number of

Person

1 Medical

Checkups 389

2

Safety &

Environment

Training

2,500

hrs/year to

330 persons

Photograph of such training is given in

Annexure-14.

Occupational health surveillance of the

workers is done on regular basis and

records maintained as per the factories

Act. Details of safety equipment:

S.

N. Safety Equip.

Quantity

(Nos.)

1 Helmets 550

2 Safety Googles 550

3 Safety Shoes 550

4 Different types of

gloves 1,000

19 Occupational health surveillance of the

workers shall be done on a regular basis

and records maintained as per the

factories Act.

Complied We have own health center. For

employees and contractors, medical

tests are being conducted yearly, and

records are maintained as per the

S.



factories Act.

20 The company shall comply with the

recommendations made in the

EIA/EMP/Risk assessment report. Risk

assessment shall be included in the safety

Manual.

Complied Based on the risk assessment studies

during EIA, all the recommendations for

the existing units are taken. Once, the

expansion and new projects are

implemented the recommendations will

be complied. Safety manual includes risk

assessment details. Safety audits are

conducted at regular intervals.

21 Green belt should be developed at least in

33% of the plant area in and around the

plant premises to mitigate the effects of

fugitive emissions all around the plant as

per the CPCB guidelines in consultation

with DFO. Selection of plant species should

be as per the CPCB guidelines.

Partially

Complied

Since, the plant was commissioned in

year 2004 (before the EIA notification,

2006); land for greenbelt development

was not provided at that stage. Thus,

Greenbelt is developed in 10% of total

area. As per CPCB guidelines, species

like Neem, badam, coconut, khajur

species are developed for improving

greenbelt.

Photographs of greenbelt development

are shown in Annexure-15.

22 All the commitments made to the public

during public hearing/public consultation

meeting held on 1st February, 2011 should

be satisfactorily implemented and

adequate budget provision should be

made accordingly

Complied Agreed and is complied with.

23 At least 5% of the total cost of the project

shall be earmarked towards the Enterprise

Social Commitment based on earlier Public

Hearing Issues.

Locals need and item- wise details along

with time bound action plan shall be

prepared and submitted to the Ministry's

Regional Office at Bhopal Implementation

of such program shall be ensured

accordingly in a time bound manner.

Complian

ce in

progress

Since all the products as mentioned in

EC are not established, the total project

cost as provided in EIA, is not yet spent.

Based on the phase wise

implementation of project, 5% of

incurred project cost will be spent in 5

years in CSR Activities till 2023.

Since it is a 5 years of action plan, it will

be completed progressively over a

period of time as committed.

Therefore, compliance is in progress.

24 The Company shall submit within three

months their policy towards Corporate

Environment Responsibility which should

inter-alia address

(I) Standard operating process/procedure

to being into focus any

Complied We are submitting herewith policy of

Corporate Environment Responsibility.

Please refer Annexure-16.

S.



infringement/deviation/violation of

environmental or forest norms/conditions,

(ii) Hierarchical system or Administrative

order of the Company to deal with

environmental issues and ensuring

compliance to the environmental clearance

conditions and

(iii) System of reporting of non

compliance/violation environmental norms

to the Board of Directors of the company

and/or stakeholders or shareholders.

25 Provision shall be made for the housing for

the construction labour within the site with

all necessary infrastructure and facilities

such as fuel for cooking, mobile toilets safe

drinking water, medical health care, creche

etc. The housing may be in the form of

temporary structure to be removed after

the completion of the project. All the

construction wastes shall be managed so

that there is no impact on the surrounding

environment.

Complied No such housing was required as local

construction manpower was employed.

During construction phase of few

products & power plant, excavated soil

was reused for filling low lying area

hence there was no impact on the

surrounding environment. Other

construction waste was disposed off

properly.

B GENERAL CONDITIONS

26 The project authorities shall strictly adhere

to the stipulations made by the Gujarat

Pollution Control Board.

Complied Agreed and Shall be complied. Valid

NOC & CCA is received from GPCB.

27 No further expansion or modifications in

the plant shall be carried out without prior

approval of the Ministry of Environment

and Forests. In case of deviations or

alterations in the project proposal from

those submitted to this Ministry for-

clearance. A fresh reference shall be made

to the Ministry to assess the adequacy of

conditions imposed and to add additional

environmental protection measures

required, if any.

Complied Agreed and Shall be complied with if any

further expansion takes place in future.

28 The National Ambient Air Quality Emission

Standards issued by the Ministry vide

G.S.R. No. 826(E) dated 16th November.

Complied AAQM Result from Eco System Resource

Management PVt. Ltd, Surat as per

G.S.R No. 826(E) dated 16.09.2009 is

S.



2009 shall be complied. enclosed as Annexure-5.

29 The locations of ambient air quality

monitoring stations shall be decided in

consultation with the State Pollution

Control Board (SPCB) and it shall be

ensured that at least one stations is

installed in the upwind and downwind

direction as well as where maximum

ground level concentrations are

anticipated.

Complied Within the factory premises, four

locations (as mentioned in S. No. 4)

were selected as per the guidelines of

GPCB.

30 The overall noise levels in and around the

plant area shall be kept well within the

standards by providing noise control

measures including acoustic hoods.

silencers enclosures etc. on all sources of

noise generation. The ambient noise levels

shall conform to the standards prescribed

under Environment (Protection) Act. 1986

Rules. 1989 viz.75 dBA (day time) and 70

dBA (night time)

Complied We have carried out the Noise level

Monitoring in and around plant area of

Padana Village) and their report duly

signed & stamped by Sarpanch of

Padana Village is enclosed as

Annexure-17.

31 The Company shall harvest rainwater from

the roof tops of the buildings and storm

water drams to recharge the ground water

and use the same water for the process

activities of the project to conserve fresh

water.

Complied Action taken. Roof of office/plant

building are connected with suitable

pipe lines to raw water tank. We are

taking this harvested rainy water to raw

water storage tank and thereby further

use it in the plant through mixed filters.

32 Training shall be imparted to all employees

on safety and health aspects of chemicals

handling Pre-employment and routine

periodical medical examinations for all

employees shall be undertaken on regular

basis. Training to all employees on

handling of chemicals shall be imparted.

Complied Training is given to all employees on

safety and health aspects of chemicals

handling.



are conducted regularly. Training to all

employees on handling of chemicals is

provided regularly.

33 Usage of Personnel Protection Equipments

(PPEs) by all employees/ workers shall be

ensured.

Complied PPEs like different types of helmets,

goggles, safety shoes, dust masks, gas

masks, hand gloves, ear plugs, ear

muffs etc. are provided to all the

employees & contractors, and its use is

ensured by doing plant round, CCTV

cameras.

S.



34 The company shall also comply with all the

environmental protection measures and

safeguards proposed in the documents

submitted to the Ministry. All the

recommendations made in the EIA/EMP in

respect of environmental management risk

mitigation measures and public hearing

relating to the project shall be

implemented.

Complied Agreed and being complied with.

35 The company shall undertake all relevant

measures for improving the social

economic conditions of the surrounding

area. CSR activities shall be undertaken by

involving local villages and administration.

Complied Based on the phase wise

implementation of project*, 5% of

incurred project cost will be spent in 5

years in the Health & Hygiene, Safe

Drinking Water, Educational Activities,

Sanitation & Drainage System, Skill

Development/ Training Program &

developing Eco development Activities.

36 The company shall undertake eco-

developmental measures including

community welfare measures in the

project area for the overall improvement of

the environment.

Complied Eco development activities of nearby

areas are initiated. Accordingly Neem,

Pipal, badam are planted in village

Padana.

37 A separate Environmental Management

Cell equipped with full fledged laboratory

facilities shall be set up to carry out the

Environmental Management and

Monitoring functions.

Complied Environmental Management Cell is in

place as shown in Annexure-18.

38 The company shall earmark sufficient

funds towards capital cost and recurring

cost per annum to implement the

conditions stipulated by the Ministry of

Environment and Forests as well as the

State Government along with the

implementation schedule for all the

conditions stipulated herein. The funds so

earmarked for environment management/

pollution control measures shall not be

diverted for any other purpose.

Complied The state has stated in their CTO dated

12.09.2017 (general condition No. 12)

that we have to follow EMP requirement

as stated in EC dated 10th May, 2013.

Issued by MoEF. Therefore, there is no

separate EMP requirement for state and

MoEF.

39 A copy of the clearance letter shall be sent

by the project proponent to concerned

Panchayat, Zila Parisad/Municipal

Corporation. Urban local Body and the

local NGO if any, from who suggestions /

representations, if any, were received

Complied We do agree that there is some delay in

meeting with requisite compliance.

The EC copy is provided to Gram

Panchayat office of Padana Village on

14.05.2017 & their acknowledgement

S.



while processing the proposal. confirmation duly signed & stamped

Is enclosed as Annexure-19.

Therefore, now Compliance is fully met

with EC requirement.

40 The project proponent shall also submit six

monthly reports on the status of

compliance of the stipulated Environmental

Clearance conditions including results to

monitored data (both in hard copies as

well as by e-mail) to the respective

Regional Office of MoEF, the respective

Zone Office of CPCB and the Gujarat

Pollution Control Board. A copy of

Environmental Clearance and six monthly

compliance status report shall be posted

on the website of the company.

Complied We are hereby submitting six monthly

EC compliance reports for the duration

of April-2017 to September-2017.

41 The environmental statement for each

financial year ending 31st March in Form-v

as is mandated shall be submitted to the

concerned State Pollution Control Board as

prescribed under the Environment

(Protection) Rules. 1986, as amended

subsequently. shall also be put on the

website of the company along with the

status of compliance of environmental

clearance conditions and shall also be sent

to the respective Regional Offices of MoEF

by e-mail.

Complied

.

We are submitting Form-V regularly to

GPCB on XGN Portal. It is also

forwarded to RO, MoEF& CC by e-mail.

It is also uploaded on KCIL’s website.

42 The project proponent shall inform the

public that the project has been accorded

environmental clearance by the Ministry

and copies of the clearance letter are

available with the SPCB/Committee and

may also be seen at Website of the

Ministry at www.moef.nic.in. This shall be

advertised within seven days from the date

of issue of the clearance letter, at least in

two local newspapers that are widely

circulated in the region of which one shall

be in the vernacular language of the

locality concerned and a copy of the same

shall be forwarded to the concerned

Regional Office of the Ministry.

Complied EC was not received within the seven

days of the date of issue. Once EC was

received, it did not have complete

product list. By-product list was missing.

Thus, EC was amended and received on

28th March, 2017. Advertisement of the

same was published in Times of India

and Gujarat Samachar, Kutch Edition on

14th April, 2017. Letter was provided to

the concerned authorities and pubic with

the copies of advertisements.

We have also submitted copy of

advertisement in Gujarat Samachar and

Times of India. Please refer Annexure-

20.

S.



43 The project authorities shall inform the

Regional office as well as the Ministry. The

date of financial closure and final approval

of the project by the concerned authorities

and the date of start of the project.

Complied Agreed. Financial closure and final

approval for the expansion unit will be

informed to Regional office as well as

the Ministry.

M/S. KCIL EC COMPLIANCE REPORT

Annexure-1: Log sheets of ETP & MEE

Log sheet of ETP


Log sheet of MEE Plant



Log sheets of incinerator


Annexure-2: Stack Analysis Results


Annexure-3: Waste water Analysis Results


Annexure-4: Noise Monitoring Results


Annexure-5: AAQM Results

&

Annexure-5A: Screen shot of uploaded report


Annexure-6: Work place monitoring Results



Annexure-7: Photograph of Benzene Sensor


Annexure-8: Certificate of Cl2 Sensor



Annexure-9: Photograph of earthing relay


Annexure-10: Photograph of Hood along with Suction facility and Scrubbing

System


Annexure-11: Design details of Incinerator

Sr.

No. Description Details

1 Type Vertical

2 Capacity 2,000 Lit/Hr

3 Size - Diameter 1.0 meter

4 Incinerator Height 5.0 meter

5 Inlet feed rate 2,000 Lit/Hr

6 Fuel Consumption 250 Lit/Hr

7 Fuel LDO

8 LDO Feed System Pumping

9

Nozzle

LDO

Mother liquor

Lap – 1 (2 Nos.)

Lap – 2 (2 Nos.)

10 Operating Temperature 800 – 1,100 °C

11 Scrubber Ventury Scrubber

12 Stack Height 20 meter


18

Annexure-12: SOP for Hazardous chemicals


19


20


21


22


23


24

Annexure-13: Photographs of Fire Hydrant System


25

Annexure-14: Photographs of Safety trainings


26


27

Annexure-15:

Photographs of Greenbelt development

Photograph-1

Photograph-2

New Plantation at Outer Periphery of the plant

Photograph-3

Photograph-4


28

Annexure-16: Corporate Environment Policy


29

Annexure-17: Noise level Certificate from Padana Gram Panchayat


30

Annexure-18: Environment Management Cell


31

Annexure-19: Acknowledgement letter from Padana Gram Panchayat


32


33

Annexure-20: EC Advertisement in News Paper

Documents

S. MONTHLY COMPLIANCE REPORT-APRIL to SEPTEMBER... · Industri al Domest ic Total As Per EC Received 1 300 36 336 * Effluent generation is much lower than ... multi cyclone separator