& Disaster -: (Eia (Eia – Emp) (Ra-Dmp)

REPORT No. SC - EIA - 2K19 - 1007 October 2019

E NVIRONMENTAL I MPACT A SSESSMENT

& E NVIRONMENTAL M ANAGEMENT P LAN (EIA – EMP)

WITH R ISK A SSESSMENT & D ISASTER M ANAGEMENT P LAN (RA - DMP)

Project : Expansion Of – Synthetic Organic Chemicals a t e xisting m anufacturing site at Ankleshwar GIDC Notified Industrial Estate

- : PROPONENT : -

Plot No. 6213 & 6213/1 , Notified GIDC Industrial Estate, Ankleshwar – 393 002 , District - Bharuch, State - Gujarat, India.

Project Sector as per Schedule of EIA notification, 2006 : - Sr. No. 5( f ) - Synthetic Organic Chemicals Industry

Proposal No: S IA/GJ/IND2/ 31093 /2019 dated 01/05/2019 ToRs issued vide letter no. SEIAA/GUJ/TOR/5(f)/978/2019 dated 25 - 06 - 2019 & Final Minutes for 507 th State Expert Appraisal Committee (INDUSTRY - 2) meeting held on 15/05/2019 uploaded on official website of SEIAA

EIA Consultant Organization & Analytical Laboratory for Baseline Studies

MoEF&CC recognized Environmental Laboratory GPCB recognized NABET accredited Category A FDA Approved Public under EPA , 1986 Env. Auditors EIA Consultant Organization Testing Laboratory (Period of recognition: 09 - 02 - 2017 to 08 - 02 - 2020)

Regd. Off. : “Kamal Arcade – The Vertical Sunclock”, Comm. Plot No. C - 3/3, Near SBI Ind. Branch, G.I.D.C., Ankleshwar – 393 002 Dist. Bharuch, Gujarat State, India Telefax : 02646 224805, 223805 E - Mail: [email protected] www.siddhigreen.com

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 1 of 265 REPORT No. SC - EIA - 2K19 - 1007 October 2019 TITLE OF THE FINAL REPORT OF REPORT Environmental Impact Assessment & EMP Report with Risk Assessment & Disaster Management Plan (RA - DMP)

For Proposed Expansion of Synthetic Organic Chemicals at Existing unit at Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat, India .

Project Sector of Schedule of EIA Notification, 2006 : - Sr. No. 5( f ) - Synthetic Organic Chemicals Industry CLIENT (PROJECT Avdhoot Pigments Pvt. Ltd. PROPONENT)

CONDUCTED SIDDHI GREEN EXCELLENCE PVT. LTD. BY MoEF&CC recognized Environmental Laboratory under EPA, 1986 G.P.C.B recognized Environmental Auditor FDA Approved Public Testing Laboratory NABET accredited EIA Consultant Organization for Category A projects of Synthetic Organic Industry & Pes ticides Industry

Regd. Office at : “Kamal Arcade – The Vertical Sunclock”, Comm. Plot No. C - 3/3, Nr. SBI Industrial Branch, Station Road, G.I.D.C, Ankleshwar – 393 002 , Gujarat State, IndiaPh. No. : (02646) 224805, 223805 Email : siddh [email protected] Website : www.siddhigreen.com

EC appln. Proposal No. SIA/GJ/IND2/31093/2019 dated 01 - 0 5 - 2019 Reference TO Rs issued vide letter no. SEIAA/GUJ/TOR/5(f)/978/2019 dated 25 - 06 - 2019 & Final documents Minutes for 507 th State Expert Appraisal Committee (INDUSTRY - 2) meeting held on 15/05/2019 uploaded on official website of SEIAA .

Report No. Rev. Date of Issued for Prepared by : Approved by No. Release SC - EIA - 2K19 - 100 7 00 02 - 10 - 2019 Appraisal by S EAC Mrs. Kuntal P. Shah Mr. P. M. Shah

Disclaimer : - This report is prepared solely for the use of the project proponent, regulatory bodies and relevant stakeholders. Siddhi Green Excellence Pvt. Ltd. has taken due precautions in the preparation of this report and ensured that the facts and information presented in the report are correct, authentic and latest as on the date of release. However, possibility of err ors or omissions is not eliminated absolutely and therefore Siddhi Green Excellence Pvt. Ltd. accepts no liabili ty resulting from the use or application of the information contained in this report. All primary data presented in the report is sole property of Siddhi Green Excellence Pvt. Ltd. and should not be used for any other purpose other than declared in the rep ort. The data cannot be syndicated or resell or transferred to any other user except the client including any affiliated companies. Siddhi Green Excellence Pvt. Ltd. will not be responsible for any loss, damage , delays, litigations etc. incurred by the da ta user arising due to the use of the data or its wrong interpretation

The information contained herein is to be used by the recipient solely for the purpose for which it was supplied. It shall no t be disclosed in whole or in part, by any other party with out the written permission of Siddhi Green Excellence Pvt. Ltd.

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 2 of 265 REPORT No. SC - EIA - 2K19 - 1007 October 2019 Undertaking from Project Proponent for Ownership of this EIA – EMP & RA - DMP report

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 3 of 265 REPORT No. SC - EIA - 2K19 - 1007 October 2019 Undertaking by EIA Consultant Organization for compliance with prescribed TORs

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 4 of 265 REPORT No. SC - EIA - 2K19 - 1007 October 2019 DECLARATION BY EXPERTS contributing to this EIA - EMP and Risk Assessment & DMP report (as per prescribed format Annexure VII of NABET Scheme version 3 as on June 2015) Declaration by EIA Co - ordinator/s under NABET scheme for Accreditation of EIA Consultant Organizations

Functional Area Experts : Sr. Functional areas Name of Expert/s Involvement Signature No Period Tasks and date 1 . Air Pollution Purvesh M. Shah January 2019  Site and study area visit Monitoring, to September  Extract relevant AAQM baseline monitoring data

Prevention and 2019 from primary data Control  Interpretation of baseline AAQM data (AP)  Determine stackwise pollutants emitted and estimate emission rates for air quality modeling  Review APCM proposed for adequacy, suitab ility and capability and suggest corrective actions if any  Impact assessment and finalization of required mitigation measures with client  Assess sources of fugitive emissions, quantify wherever possible and assess propose d control measures  Identifying Odou r generating sources and review proposed management of odour  Finalize Post project monitoring plan  Suggest housekeeping methods and other practices to minimize dusting and fugitive emissions  Review construction phase impacts and propose mitigation measures  Assess traffic increment and related air pollution scenario  Review of proposed environmental monitoring measures w.r.t. suitability and adequacy for applicable compliances  Direct AFAE for report drafting 2 . Water Pollution, Purvesh M. Shah January 2019  Site and study area visit Prevention & to September  Identify and assess impacts during all phases

Control (WP) 2019  Review and approve water balance  Finalize process and other effluent sources and characterization  Assess water consumption source, quantity, reuse and recycle options  Assess – proposed effluent treatment scheme for adequacy and capability based on hydraulic calculations and type of treatment units proposed, adequacy of contingency storage, proposed mitigation measures and suggest addi tional mitigative measures if required  Approve Post - project environment monitoring plan w.r.t WP  Suggest water conservation measures  Impact assessment for construction and erection Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 5 of 265 REPORT No. SC - EIA - 2K19 - 1007 October 2019

Sr. Functional areas Name of Expert/s Involvement Signature No Period Tasks and date phase 3 . Solid & Hazardous Purvesh M. Shah January 2019  Assess existing and proposed hazardous wastes Waste to September and ascertaining compliance with applicable HW Management 2019 rules for proposed storage facilities, generation qty. (SHW) and disposal methods  Impact assessment for construction and erection phase  Suggestions for better management and handling in compliance with applicable rules  Explore possibilities of co - processing or other utilization of wastes for reducing waste going for incineration or landfilling 4 . Socio - Economics Mahendrasinh June 2019 to  Site visit (SE) Rathod September  Extract relevant socio - economic data from primary 2019 data  Prediction & Assessment of impacts on social and economic status and review proposed mitigation measures  Suggest further measures if found necessary  Review current CSR activities by proponent and suggest further based on need assessment done during primary and secondary survey data. 5 . Ecology & Mrs. Priti S. Raval June 2019 to  Site visit Biodiversity (EB) September  Review and interpret Baseline conditions from 2019 primary and secondary data to e stablish baseline status of study area w.r.t flora, fauna, endangered species, nearest ecologically sensitive areas  Identify impacting activities of project and required mitigation measures  Review of Greenbelt development requirement of the project – suggestion for species, type of plantation  Compilation of EB report 6 . Hydrology and Dr. Manish June 2019 to  Interpretation of results of primary survey and Ground water Sharma September analysis w.r.t. project to establish baseline status of (HG) 2019 groundwater, surfacewater and geology of the study area  Impact prediction and review of proposed mitigation measures for suitability and amendments further 7 . Geology (G) No Geology expert was engaged in the EIA since it is not mandatory for this sector as per version 3 of NABET EIA scheme 8 . Soil Conservation No Soil Conservation expert was engaged in the EIA since it is not mandatory for this sector as per (SC) version 3 of NABET EIA scheme 9 . Air Quality Mrs. Kuntal P. June 2019 to  Assessment of pollutant release rates, sources, Modellin g (AQ) Shah September identifying sensitive discrete receptors 2019  Carrying out simulations on Industrial Source Complex Model (ISCST3) using baseline meteorological data, geological data, identifying sources and receptors, source inventory, worst case scenarios.  Prediction of GLC and plotting of GLC Isopleths  Study of GLCs obtained from simulation and calculating resultant concentration of pollutants in AAQ after the projec t is operational 10 . Noise (N) Vikram R. Gohil June 2019 to  Extract relevant noise level data from primary data September  Review of baseline noise levels, sources and their 2019 compliance with permissible limits  Identify sources of noise generation from the project activities during each phase, also due to traffic increment at access roads  prediction of resultant increase in noise levels of sensitive receptors of the study area  Suggest mitigation and minimization measures

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 6 of 265 REPORT No. SC - EIA - 2K19 - 1007 October 2019

Sr. Functional areas Name of Expert/s Involvement Signature No Period Tasks and date  Post project monitoring plan w.r. t. N 11 . Land Use (LU) S. Deviprasad June 2019 to  development of landuse maps of study area using September GIS / related tools, site visit for ground truth survey 2019  Prepare land use classification and determine baseline LULC of the area  Prediction of impacts on land use pattern and land cover  Suggest mitigation measures 12 . Risk Assessment Mrs. Kuntal P. June 2019 to  Determine worst and most credible accident and Hazard Shah September scenarios of given chemicals and their inventories Control (RH) 2019  Obtain basic information about handling processes, frequency, mode of transport, storage conditions, MSDS information  Carry out consequence analysis using ALOHA software for different release scenarios and for various toxic and flammable effect s and determination of damage criteria for heat radiation, pressure wave and toxic concentration levels with recourse to health criteria, dose - response relations and vulnerability models.  The results of the analysis are studied to assess the max. area of e ffect and the safe distances and locations  Provide suggestions for culminating the unsafe consequences Details of Associate Functional Area Experts and other team members involved in the EIA is annexed as Annexure – 21

Declaration by the Head of the Accredited Consultant Organization:

I, Purvesh M. Shah , hereby, confirm that the above mentioned experts prepared the EIA / EMP Report for proposed Expansion project of synthetic organic chemicals o f M/s. M/s. Avdhoot Pigme nts Pvt. Ltd. at their existing unit at Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat, India . I also confirm that Siddhi Green Excellence Pvt. Ltd. shall be fully accountable for any mis - le ading information mentioned in this statement.

Name : PURVESH M. SHAH Designation : Managing Director & CEO Signature :

Name of the EIA Consultant Organization : SIDDHI GREEN EXCELLENCE PVT. LTD.

NABET Certificate No. : NABET/EIA/1821/RA 0104 valid upto April 27, 2021 NABET accreditation certificate and Re - accreditation letter are annexed as Annexure – 1A.

ACKNOWLEDGEMENTS

The process of environmental impact assessment involves close co - ordination with the unit’s management and employe es at every visit. Without the support and co - operation of the management, many inconveniences are faced by the assessment agency while conducting the assessment, for data collection, data verification, site visits etc.

We, the members of the assessment t eam of M/s. SIDDHI GREEN EXCELLENCE PVT. LTD., acknowledge the co - ordination received from the management representatives of M/s. AVDHOOT PIGMENTS PVT. LTD. for carrying out the EIA study. The management has shown full involvement and interest in the asse ssment procedures and made the experience of the study, a joint effort.

(PURVESH SHAH) Managing Director & CEO

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 7 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

EIA – EMP With Risk Assessment & DMP Report For Propose d Expansion In Existing Unit of M/s. Avdhoot Pigments Pvt. Ltd . for manufacturing of Synthetic Organic Chemicals At Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat. India

Executive Summary Executive Summary

Proposal The proposal is for prior environmental clearance to the project for proposed expansion in existing premises for synthetic organic chemicals by M/s. Avdhoot Pigments Pvt. Ltd. at Plot No. 6213 & 6213 /1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat, India .

Project Type a nd Category As Per The Schedule To The EIA Notification 2006  Project Type : 5 (f ) Synthetic Organic Chemicals Industry  Category : ‘ B1 ’

Application details : Proposal No. SIA/GJ/IND2/31093/2019 dated 01 - 05 - 2019 TORs issued vide letter no. SEIAA/GUJ/TOR/5(f)/978/2019 dated 25 - 06 - 2019 & Final Minutes for 507th State Expert Appraisal Committee (INDUSTRY - 2 ) me eting held on 15/05/2019 uploaded on official website of SEIAA . These TORs have been addressed to completeness and included in the report, references to each TOR is given in earlier section.

Compliance to additional TORs at Sr. No. VII. of TOR letter : - Sr. Additional TOR Compliance No. 1. Details with respect to justification for proposed expansion: (1) To address Section 2.24.1 of proportionate availability of space for production plant. (2) To address proportionate Chapter 2 availability of storage area for raw materials finished goods, utilities and goods carrier movement within premises. (3) To address proportionate captive/common infrastructure available to accommodate addition al load due to proposed expansion. (4) Environment impact and its mitigation measures for common/ captive infrastructure due to proposed production. 2. Compliance of MoEFCC's OM dated 01/05/2018 regarding “Corporate Environment Section 10.12.1 of Responsibility” (CER). Fund allocation for Corporate Environment Responsibility Chapter 10 (CER) shall be made as per MoEFCC's O.M. No. 22 - 65/2017 - IA.III dated 01/05/2018 for various activities therein. The details of fund allocation and activities for CER shall be incorporated in EIA/EMP report. 3. Explore the use of renewable energy to the maximum extent possible. Details of Section 10.15.1 of provisions to make the project energy - efficient through of energy efficient devices and Chapter 10 adoption of modes of al ternative eco - friendly sources of energy like solar water heater, solar lighting etc. Measures proposed for energy conservation. 4. Qualitative and quantitative analysis of hazardous waste streams generation from the Section 2.19.1 of manufact uring process (Product wise). Explore the possibility to reuse such waste Chapter 2 streams within premises as raw materials for other products or to convert it into valuable products instead of selling out side. Sound management of such waste streams as per the HW Rules 2016 as amended time to time. Feasibility report for utilization shall be incorporated in EIA report. 5. Furnish status of all the applicable rules, acts, regulation, clearances in a tabular form. Section 1.9 of Chapter 1 6. Address appropriate mode of disposal in hazardous waste matrix specifically for spent Section 2.19.1 of Hcl, sodium hypochlorite and spent Alcl3 with technical justification. Chapter 2 7. Leak Detection and Repairing Programme (LDAR) for all the volatile organic solvent Section 6.1.1 of proposed for use in - house with detailed chemical properties including vapor pressure. Chapter 6 LDAR shall endeavor prevention of losses of solvents to the best minimum extent. 8. Safety precautions to avoid haza rd during unloading, storage, transportation handling Section 10.7.3 of and processing of Cl2 as per PESO standards. Chapter 10 9. Segregation of waste water streams based on characteristics and its proper Section 2.16.1.1 of management keeping in view direction under section 18 (1) (b) of the Water Chapter 2

Siddhi Green E xcellence Pvt. Ltd., Ankleshwar Page 8 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Sr. Additional TOR Compliance No. (Prevention and Control of Pollution) act, 1974 issued by CPCB regarding compliance of CETP. 10. Unit shall produce MoU for final disposal of above mentioned solutions which are Annexure - 27 going to be ge nerated as Hazardous Waste as per HWR - 2016, (1) Spent HCl, (2) Spent sodium hypochlorite and (3) spent aluminium chloride at the time of appraisal of Environmental Clearance.

EIA - EMP report This Environmental Impact Assessment (EIA) – Environmental Management Plan (EMP) with Risk Assessment and DMP Report is prepared in accordance with Terms of Reference (ToRs) prescribed by State Level Environment Impact Assessment Authority ( SEIAA) .

EIA Consultant Organization  M/s. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Accreditation from NABET - for Synthetic Organic Chemicals Industry & Pesticides sector for category A. Own Labora tory of Siddhi Green Excellence (Accredited by NABL for ISO/IEC 17025 : 2017) has been utilized for various analytical activities of the EIA study, relevant documents are annexed as Annexure – 1A & 1B respectively.

Proposal Expansion in existing unit – by –  enhancing production capacity of existing products Proposed Project Cost Rs. 8.6911 Crore s (For Proposed Expansion Only) Proposed EMS budget Rs. 1 .5 Crore s (For ETP, solid / hazardous waste management and disposal facilities, green belt development, Air pollution control devices )

Brief Project Information Name of the Industrial M/s. Avdhoot Pigments Pvt. Ltd. - henceforth referred to as APPL Unit Project Site Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat, India . Address of Same as above correspondence Registered Office address Same as above Name of the Applicant Mr. Dixit J. Patel (Director) E - mail ID of the Applicant [email protected] Plot area 4979 .75 sq.m Green Belt Area Existing: 5 01 sq.m. (Approx. 10 % of total plot area) . B alance area of green belt shall be developed on GIDC specified area. Existing and Proposed Production Existing Proposed for EC Total Production ( MT/Month ) ( MT/Month ) ( MT/Month ) Synthetic Organic Chemicals 13 157 170

Type of Product sector Synthetic Organic Chemicals End Use of Products In various Chemical Industries producing Paints, dyes, inks, coatings, plastics, rubbers and textiles Environmental Clearance Unit was setup in 199 3 and hence , EC as per EIA notification, 2006 is not obtained for for existing production existing production. Unit had obtained Environmental Clearance from MoEF&CC for other products in 2008. But due to hydraulic load constraints, the EC was not converted to CTO and validity of that EC has lapsed. Project setup The proposed expansion unit shall be accomplished by augmenting production area & requirements utilities along with necessary additions in support infra - structure like ETP, Air pollution control systems, Hazardous Waste storages area shall be provided as per requireme nt. Water source and Source of water : GIDC reservoir

Siddhi Green E xcellence Pvt. Ltd., Ankleshwar Page 9 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary consumption Presently the maximum GIDC water consumption granted in existing Consent to Operate is 23.4 KL D which is supplied from GIDC reservoir. (Copy of CTO is attached as Annexure – 2 8 ).

After proposed expansion, fresh water consumption shall be 260 KL D for different water usages. Existing Proposed Total after expansion Domestic : 0.5 KL D Domestic : 2 KLD Domestic : 2.5 KLD Industrial : 22.4 KL D Industrial : 229.6 KLD Industrial : 252 KLD Gardening : 0.5 KL D Gardening : 5 KLD Gardening : 5.5 KLD Total : 23.4 KL D Total : 236.6 KLD Total : 260 KL D Letter from GIDC for supply of additional water requirement is received and annexed as Annexure - 11.

Recycle / Reuse of water: 1. Total water requirement for the project: 286.25 KLD 2. Quantity to be recycled : 26.25 KLD Remarks regarding Source of waste Application area with quantity in feasibility to reuse i.e. w/w water for reuse with KLD characteristics (COD, quantity in KLD BOD, TDS etc.) Recycled wash 3 rd stage wash water shall be water (from recycled for 4 th stage washing COD: <500 mg/l process): 20 KLD after passing through filter Boiler Blow down – 2 Boiler blow down of 2 KLD & COD: < 100 mg/l KLD cooling tower blow down of 4.25 BOD: < 30 mg/l Cooling tower blow KLD shall be used for washing TDS: < 500 mg/l down – 4.25 KLD purpose after passing through cartridge filter. 3. Total fresh water requirement: 260 KLD. Fuel Requirement Sr. No. Fuel Name Existing Proposed Total 1. Natural gas 250 Nm 3 /day 9600 Nm 3 /day 9850 Nm 3 /day 2. Diesel -- 100 L/h 100 L/h Natural Gas is obtained from M/s. Gujarat Gas Company Ltd . Power Requirement Resource Consumption Source Existing Proposed Total Power – Continuous Supply 375 KVA 375 KVA 750 KVA From DGVCL Standby Power in case of -- 2 nos. DG 2 nos. DG Set -- power supply failure from Set (320 (320 KVA each) DGVCL KVA each)

Manpower Requirement Existing Man power : 5 Nos. Company employees + 10 Nos. on Contract basis Proposed additional Man power : 15 Nos. Company employees + 40 Nos. on Contract basis Total after proposed expansion : 20 Nos. Company employees + 50 Nos. on Contract basis Type Manager Officer Operator/ Contract Total Worker Labor Existing 1 4 4 6 15 Proposed 1 8 21 25 55 additional Total after 2 12 25 31 70 expansion  There shall be recruitment in the field of Plant Op eration, Laboratory Activities, Maintenance, Security, Purchase, Accounts, Warehouse, Housekeeping and such Siddhi Green E xcellence Pvt. Ltd., Ankleshwar Page 10 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary other fields related to a manufacturing facility.  Maximum efforts for recruitment from local area and within district and state.  Project specific training shall be imparted to enh ance skills and increase local people . Project Implementation Within two years after getting Environmental clearance from SEIAA . Schedule

About the Project Proponent M/s. Avdhoot Pigments Pvt. Ltd. is a small scale unit located in Ankleshwar GIDC estate and engaged for manufacturing of pigments. The company is governed by board of directors. The details of directors of the company are annexed as Annexure - 13 .

M/s. Avdhoot Pigment Pvt. Ltd. has been providing specialized service to the manufacturers of paints, links, plastic, rubber, textile etc and is evolving continuously to provide better performance and results. A prime aspect of a modern day business is top quality product with consistency and the company has persiste ntly emphasized total quality management.

M/s. Avdhoot Pigment Pvt. Ltd. has received ISO 9001:2008 and ISO 14001:2004 certification by the top management consultants for providing assurance about the ability to satisfy quality requirements and to enhance customer satisfaction in supplier - customer relationships.

Manufacturing facilities APPL has only one manufacturing site at Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar, Dist. Bharuch, State - Gujarat, India . – where the proposed ex pansion is planned .

History of Project site Plot No. 6213/1 was acquired by Ankleshwar GIDC as industrial plot and purchased by M/s. Avdhoot Pigments Pvt. Ltd. as first owner in the year 1993 . Further Plot no. 6213 was amalgamated with Plot no. 6213/1 in the year 2012. Land possession documents are annexed as Annexure – 7 .

Site management  There is a defined organizational structure for all major operations and management in the unit.  The company is supported by various technical persons. The directors are technically well qualified and highly experienced.  The support staff is competent to carry out various operations, including the environmental health and safety of people in and around t he plant.  The unit has a defined HSE management supported with an Environmental Policy approved by the Board of Directors.  Production and quality control standards are stringent. The unit is accredited fo r ISO 9001: 2008, ISO 14001: 2004 . Certificates of t he same are annexed as Annexure – 31 .

Need for the project Proposed expansion project is needed to serve increasing demand of the proposed products in export as well as domestic market. The proposed production capacities are based on detailed market survey by APPL .

Demand - Supply Gap The gap between demand and availability of pigments for textiles and printing industry is likely to increase over the years. This calls for such projects which can help in bridging the gap. “Make in India” campaign is al so expected to add impetus to the emergence of India as a manufacturing hub for the chemicals industry in the medium term.

Imports vs. Indigenous production The products are presently available from indigenous manufacturers as well as from imports. There is considerable demand which is catered both by Indian as well as overseas manufacturers .

Siddhi Green E xcellence Pvt. Ltd., Ankleshwar Page 11 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary

Export Possibility The products have good demand of about 20% in local/national markets and 80% in international market .

Site - level benefits  Complete utilization of the open land available in the plot  Reduce operational costs and increase productivity  The existing infrastructure facilities and land availability shall be utilized to the fullest with more efficiency

Its importance to the country can be accounted by  Reduce dependence on Imports  Add to foreign exchange generated by exports  Ensure continued employment to workforce without affecting work conditions and hence supporting their families  Lead to generation of direct and indirect employment opportunities.  Th e project will create employment during the construction as well as operational phase.  The present level of employment shall increase through requirement of skilled/ unskilled labour, qualified professionals and also develop the estate as such.  Proponent i s committed to employ local affected population based on academic skills and qualifications.

Project Site The p roposed expansion shall be carried out in the existing unit, located at Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 39 3 002, District - Bharuch, State - Gujarat, India . The site is located within Notified GIDC Industrial Estate of An kleshwar and hence there is no agricultural or forest land involved in the project site.

The Proposed expansion is planned in the same factor y premises since –  There is sufficient unoccupied area in existing premises to accommodate new sections and utilities. Presently ~40% of factory area is unoccupied and available for expansion. Hence, expanding the manufacturing facilities in existing plot premises and utilizing the open land is the most suitable option for the proposed expansion .  The layout and areas provided to each section are adequate with sufficient distances and internal paved roads.  The augmentation for proposed expansion shall be conveniently done without any disturbances to the existing facilities. Access to site Ankleshwar GIDC Estate can be reached through National Highway No. 48 on the Vadodara – Surat stret ch passing through Ankleshwar. Ankleshwar also has a Railway Junction .

Google Imagery of site and surrounding features

Siddhi Green E xcellence Pvt. Ltd., Ankleshwar Page 12 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary

Co - ordinates of Centre of Project Site: Latitude: 21°37'13.90" N , Longitude: 73°2'31.50" E

Latitude and Longitude of the Corners of the Project site Description Latitude (N) Longitude (E) A 21° 37' 13.31"N 73° 2' 29.79"E B 21° 37' 14.94"N 73° 2' 29.93"E C 21° 37' 14.70"N 73° 2' 33.55"E D 21° 37' 13.07"N 73° 2' 33.42"E Elevation above Mean Sea Level (MSL) ~ 30 - 31 m

Site layout plan of the project site showing proposed plant facilities is annexed as Annexure – 16.

Salient Features of the Project Site Sr. Particulars Details (Nearest aerial distance measured from centre of the plot, in km)* No. 1. Census Town Ankleshwar (INA) 2. Taluka Ankleshwar 3. District Bharuch 4. Northward Overview M/s. Shiv Silica Pvt. Ltd. ( Precipitated Silica manufacturing) 5. Southern Overview GIDC Road and beyond that M/s. Rusan Pharma Ltd. (Pharmaceutical products), M/s. Ambica Metallic Chemicals (Manufacturing of Metallic Inorganic Sulphates ) and Open GIDC plot 6. Western Overview GIDC Road and beyond that M/s. Sanofi India Limited (Pharmaceutical products) 7. Eastern Overview M/s. BASF India Ltd. (Manufacturing of Optical Whitening agents & their formulations) 8. Water Bodies around the Amravati river – 2.93 km towards NNE GIDC estate Chhapra Khadi – 2.78 km towards NNW Kondh ki khadi – 2.43 km towards E GNFC Reservoir - 3.93 km towards NW GIDC Reservoir, Bhadkodara – 3.49 km towards SWW Amla Khadi – 4.28 km towards W Ankleshwar Lake(near Jalaram nagar) - 5.61 km towards NWW

Siddhi Green E xcellence Pvt. Ltd., Ankleshwar Page 13 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Sr. Particulars Details (Nearest aerial distance measured from centre of the plot, in km)* No. Narmada river – 8.55 km towards NNW 9. Internal Roads around NH - 48 to Asian Paints Chowkdi – 1.97 km towards W the GIDC estate Hathuran - Panoli road – 11.53 km towards SW Hansot - Panoli Road – 11.55 km towards SW 10. State Highway around SH - 64 – 1.71 km towards N the GIDC estate SH 13 – 3.24 km towards SW SH 76 - 4 km towards W SH - 6 - 4.26 km towards W 11. National Highway around NH 48 – 2.6 km towards N W the GIDC estate 12. Nearest Railway Station Ankleshwar Railway station – 4.24 km towards W around the GIDC estate 13. Nearest Airport/ Airbase Surat airport – > 50 km towards SSW around the GIDC estate Vadodara – > 50 km towards N E * Co - ordinates of Centre of Project Site: Latitude: 21°37'13.90" N, Longitude: 73° 2'31.50" E

Products applied for EC with production capacity Sr. CAS No./ Quantity (MT/Month) Name of Products End Use No. Cl no. Existing Proposed Total Paints, inks, coatings, plastics, 1 . CPC Green 1328 - 53 - 6 10 140 150 rubbers and textiles As a colorant in paints, dyes, 2 . Beta Blue 147 - 14 - 8 3 17 20 inks, coatings, plastics, rubbers and textiles TOTAL 13 157 170

End use of products The products are pigments having end uses in various Chemical Industries producing Paints, dyes, inks, coatings, plastics, rubbers and textiles .

Plant Facilities Site plan is annexed with EIA report as Annexure – 16. Landuse breakup is given in chapter 2 of EIA report. Sr. Facility for expan sion Details 1. Manufacturing Plants One additional process plant to be constructed. 2. Utilities Existing natural gas based 1 no. Boiler of capacity 5 lakh kcal/hr and 1 no. (Boiler, cooling towers, utility Thermic Fluid Heater of capacity 2 lakh kcal/hr shall be continued and block, water storage tank etc.) additionally 1 no. Boiler of capacity 5 lakh kcal/hr & 5 nos. of Thermic Fluid Heater of capacity 2 lakh kcal/hr each shall be req uired for proposed expansion. New coo ling towers shall be installed. Additional Utility area shall be provided adjacent to existing plant building and adjacent to office building near engineering store . 2 nos. D.G. set (320 KVA each) shall be installed at proposed DG area. One additional water storage tank of capacity 500 KL is proposed for expansion. 3. Storages (Tanks, cylinder Chlorine Tonner Storage shed is provided near RM storage area . storage, etc.) New tanks for Monochlorobenzene & Caustic lye are proposed near new process plant building. Adequate dykes and separations as well as drain shall be provided. 4. Warehouses Existing raw material and finished good storage area shall be enough for proposed expansion. 5. Hazardous Waste Storage Existing hazardous waste storage area shall be augmented . Wastes are Areas disposed regularly and minimum storage is kept and same shall be followed after proposed expansion. 6. ETP Existing ETP of 60 KLD capacity shall be upgraded to 180 KLD capacity having Siddhi Green E xcellence Pvt. Ltd., Ankleshwar Page 14 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Sr. Facility for expan sion Details primary and secondary treatment units. 7. HT/ LT substations, Already present at site. Shall be augmented if required. Switchyards 8. Admin Building, QA, QC Lab Admin block, Engineering Store and Change room are already provided at site and R&D Lab, Washroom and shall be modified within constructed are a if required. Block, Engineering Store 9. Other infrastructure Internal roads (paved), security cabin, storm water and containment drainages, lightification, pipe racks, offices and control rooms etc. 10. Green belt after expansion 501 sq.m. (~10%) inside the plot premises and the balance greenbelt shall be developed in the area specified by GIDC.

Manufacturing processes In general, manufacturing processes include Reaction and Separation processes mainly by Chlorination, Drowning & Filtratio n, Washing, Distillation, Water & Caustic Scrubbing, Layer Separation, Drying, Pulverizing & Packaging .

Products are solid in state. Therefore drying or solid - liquid separations are involved. The reaction temperatures vary from normal to 17 0°C and are controlled using cooling water while distillation processes are carried out at atmospheric pressure as well as vacuum with primary and secondary condensers operating on cooling water.

All unit processes and unit operations shall be carried out in closed s ystem and under stringent controls and monitoring through local indicators and emergency control procedures .

Storage and Handling of Hazardous Chemicals For proposed expansion, unit shall store and use hazardous chemicals of toxic and flammable nature in the form of organic and inorganic chemicals as liquids, solids as well as compressed gas. Details of product - wise consumption is given as Annexure – 24 . It should be noted that not all inventory shall be made at a time at site. These materials shall be procured and stored at the site according to requirement of production schedule.

All chemicals shall be stored and handled in accordance with Material Safety Dat asheet. MSDS of few chemicals are annexed as Annexure – 32. The hazardous properties of chemi cals are tabulated in Annexure – 26. Details of inventory and method of storage is given at chapter 2 of this EIA report.

Storage hazards are identified and delineated in onsite emergency plan. Required preventive and control measures are evaluated and verified through safety audits. Presently unit is an MAH installation in accordance to the schedule 3 of MSIHC rules, 2000 for chlorine storage of 15 tonners . Unit has obtained license for storage of chlorine tonners, c opy of license is annexed as Annexure - 23. There shall be no increase in storage of chlorine after expansion and hence no change in MAH status of the unit.

Mode of transport: - Majority of raw materials shall be procured from Ankleshwar and Panoli industr ial estates or within Gujarat or from other states and very few shall be imported through nearby ports. The raw materials shall be transported conveniently by rail and road as NH - 48 passes very near to the estate and Ankleshwar has a railway junction facil ity with container yard.

Utilities Sr. Type of Utility Existing Additional for Proposed Expansion No. No. Capacity No. Capacity 1 Boiler 1 5 lac kcal/h 1 5 lac kcal/h 2 Thermic Fluid Heater 1 2 lac kcal/h 5 2 lac kcal/h each 3 Cooling Towers 2 2 TR each 2 2 TR each 4 Raw water tank 1 500 KL 1 500 KL 5 D.G. set -- -- 2 320 KVA each

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Executive Summary Pollution Potential and proposed mitigation measures Wastewater generation, treatment and disposal Type of Effluent Quantity as per CTO in KLD Total after expansion in KLD Industrial Effluent 19.8 155.8 Domestic Effluent (Sewage) 0.4 2.2 TOTAL 20.2 158 Domestic effluent is disposed through soak pit via septic tank and same will be continued after expansion .

Industrial : - Present scenario -  Presently, unit is a member of CETP of M/s. ETL, Ankleshwar for 550 KL/month effluent disposal.  Acidic and general effluent are segregated and given primary and secondary treatment in own ETP and treated effluent having COD values between 600 - 1200 mg/L is sent to CETP for final treatment and disposal into deep sea via FETP of M/s. NCT, Ankleshwar . After proposed expansion: -  Total industrial effluent generat ion is estimated to be 155.8 KLD max.  It is proposed to upgrade existing ETP from 60 KLD to 180 KLD capacity by installing additional units for primary and secondary treatment  The treated effluent shall be sent to CETP ( Common Effluent Treatment Plant) of M/s. ETL, Ankleshwar after conforming to their inlet norms through tankers for final treatment and disposal into deep sea via FETP of M/s. NCT, Ankleshwar . Complete details of effluent treatment scheme & ETP components are given in chapter 2 of this re port .

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Executive Summary Water Balance Diagram for proposed expansion project

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Executive Summary Flue gas and emissions and their control measures Presently 1 no. Boiler having 5 lac kcal/h capacity and 1 no. Thermic fluid heater having 2 lac kcal/h ca pacity are installed which are operated on Natural gas. These shall be continued after expansion. The flue gas emissions from these utilities remain well within permi ssible limits of CTO as Natural gas is used as fuel. Hence, no air pollution control measures are required.

After proposed expansion, there shall be additional flue gas emissions from :  Stack attached to proposed additional 1 no. natural gas based Boiler with 5 lakh kcal/hr capacity ,  common stack attached to 2 nos. natural gas based Thermic fluid heater with 2 lakh kcal/hr capacity each and  common stack attached to 3 nos. natural gas based Thermic fluid heater with 2 lakh kcal/hr capacity each.

T he flue gas emissions from above mentioned new utilities shall also remain well within permissible limits of CTO as Natural gas shall be used as fuel. Hence, no air pollution control measures shall be required.

2 nos. DG Set (320 KVA each) are proposed to be used as a stand - by power source for emergency operations only. Adequate stack height and stack monitoring facilities shall be provided.

Process gas emissions and their control measures Presently there is process emission of HCl and Cl 2 during manuf acturing of CPC green . Water and Caustic Scrubber are provided for control of these emissions within permissible limits of CTO. After proposed expansion, process emission of HCl and Cl 2 shall increase for which a dditional 2 nos. of water scrubbers and 2 nos. of caustic scrubbers shall be instal led . There shall be no new process gas emission from proposed expansion.

Disposal of scrubbing solution - Hydrochloric acid ( ~ 30%) generated from scrubbing of HCl emission shall be us ed in ETP to maximum extent or shall be sold to authorized actual end users who are having authorization with valid CTO and permission under Rule 9 of Hazardous waste rules. - Sodium Hypochlorite (10%) generated from scrubbing of Cl 2 emission shall be used i n ETP to maximum extent or shall be sold to authorized actual end users who are having authorization with valid CTO and permission under Rule 9 of Hazardous waste rules . The Unit (APPL) shall make MOU with actual end users for its utilization. If actual users have not obtained the authorization under Rule - 9, APPL shall ensure that actual users obtain such authorization within one year following the “Principle of Producers Extended Responsibility” and shall give its wastes up to one year from the date of i ssue.

Fugitive emissions and their control measures Sources of Fugitive Dust Area Type of activity Continuous or Pollutant added to Intermittent ambient air Production area Solid chemical charging from bags Intermittent activity Chemical dust Solid Product bagging area Bag filling of product powder or lumps Intermittent activity Chemical dust

For control of fugitive dust , the packaging as well as charging of solid material areas shall be enclosed and with adequate ventilation, covered transfer systems shall be adopted, workers shall be provided PPEs, machinery shall be provided with dust extraction systems if found necessary by work place monitoring, minimum manual operations, local exhausts and roof top ventilators shall be provided wherever re quired .

Sources of Fugitive Chemical Vapors & their control Continuous or Area Type of activity Pollutant added to ambient air Intermittent Production and drum handling Charging, reaction, Intermittent activity HAP chemicals with low V.Ps areas transfer

Sr. No. Probable sources Control measures 1. Pump glands and seals All pumps handling low V.P chemicals and pressurized gas shall have

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Executive Summary Sr. No. Probable sources Control measures mechanical seals or sealless pumps. 2. During reactions & Solvent All reactors shall be closed and provided with primary and secondary recovery systems condenser s with cooling water circulation for maximum vapor recovery Solvent recovery of minimum 95% shall be acheived Temperature and pressure conditions shall be stringently controlled as per the process requirement and optimized with low temperature and vacuum conditions wherever feasible. 3. Vents of storage tanks – during Liquid raw materials will be charged by pumping & closed loops. withdrawal to day tanks Metering pumps shall als o be used wherever required. Suitable stoichiometric calculations will be done and followed to regulate the quantity of reactants to be charged to reaction vessels in order to avoid use of excess chemicals, which in turn will minimize organic load in the effluent. 4. Release from Sampling Lines Shall be carried out using a closed loop sampling system. 5. Emissions from Bulk Storage Storage tanks storing low V.Ps chemicals are provided with Breather valve Tanks during storage, loading as sembly , PSVs, Rupture discs wherever applicable. and unloading Tank Pressure equalization shall be applied wherever required. Closed Transfer systems 6. Valves, Flanges, plugs and Welded pipes to be used wherever feasible instrument connections Suitable gasket material to be used Suitable gland packing to be used in valves Periodic inspection and maintenance of pipes and pipe fittings 7. Chemical vapors during filtration Covered transfer systems shall be adopted, workers shall be provided PPEs, and drying process l ocal exhausts and roof top ventilators wherever required 8. Charging from drums Covered transfer systems shall be adopted, workers shall be provided PPEs , area shall be adequately ventilated 9. Warehouse storing drums and Spillages shall be strictly prevented by providing drip pans, proper handling bags equipment, Spill control procedures and equipment shall be provided.

Hazardous & other waste management : Disposal at Landfill site – Waste going for Reuse/ Recycle/ Recovery - ETP waste - Used Oil - Discarded Containers, Barrels / Liners Wastes to be sold to actual users or authorized Wastes to be reused within premises to maximum extent dealers under rule 9 (as and when generated) - Spent Solvent - Hydrochloric acid (30%) - Sodium hypochlorite (10%) - Sodium hypochlorite (10%) - Hydrochloric Acid (30%) - Aluminium chloride (20%, 30%, 40%) - Aluminium chloride (20%, 30%, 40%)

Hazardous wastes covered in Schedule II :  By - products ( Sodium hypochlorite (10%), Hydrochloric Acid (30%), Aluminium chloride (20%, 30%, 40%) are included as hazardous wastes under Rule 9 of The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.  Proponent has MoU with actual users who have valid authorization and have applied for permission under Rule 9 of The Haza rdous and Other Wastes (Management and Transboundary Movement) Rules, 2016, for selling the existing by - products. MoU is annexed as Annexure – 27.  For by - products generated after expansion, unit is committed to have MoU with those actual end users who have valid authorization as well as compliance for utilization of the by - products under Rule 9 of The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. If actual users have not obtained the authorization under Rule - 9, proponent e nsures that actual users obtain such authorization within one year following the “Principle of Producers Extended Responsibility” and gives its wastes up to one year from the date of issue

Memberships of Common Disposal Facilities to be availed for propos ed expansion Unit has membership of M/s. Bharuch Enviro Infrastructure Ltd. (BEIL) – Ankleshwar TSDF site for sending landfilling wastes. Copy of letter o f membership and request letter for additional quantity is annexed as Annexure – 27.

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Executive Summary

Proponent will try to send maximum waste to co - processing and / or recycling and / or recovery and balance quantity will be sent to common disposal or incineration facility.

Solvent Recovery Solvent recovery is carried out by simple distillation directly from reactor ve ssels provided with distillation assembly in dedicated distillation units depending on the solvent composition. Recovered solvents are reused in process. Distillation assembly comprises of packed column, condensers with cooling water circulation to obtain minimum 95% recovery. Proposed new process vessels shall also have same facility .

Environment Management System  In order to mitigate the negative impacts, adequate mitigation measures have been proposed during construction, erection and operational phase of the project. EMS adequacy certificate for proposed Environment Management S ystem is annexed as Annexure – 2 2 .  The unit has an EHS cell to carry out various environmental management measures.  Impact Prediction and Assessment for the given project indicates that the project will have negligible impacts after mitigation.  There shall be economic benefits during all the three phases of the project through employment generation and ESR and CER contribution .  Various recommendations and suggestions have b een given by EIA consultant for improvising the mitigation measures and proponent has committed to put sincere efforts to include the same to the best possible extent while planning the EMP and allocate sufficient budget for the same.

Fire fighting Arrang ements  Fire water storage is provided in the plant to facilitate firefighting by DPMC fire tender . Fire extinguishers are also provided at all necessary locations and of suitable type and capacity.  Flammable areas shall be classified as per applicable rules and protected by spark avoidance and flameproof electric fittings. The fire protection and fire fighting arrangements shall be provi ded in new plant sections also.  Emergency handling equipments l ike SCBA sets, Gas mask, PPEs, Chlorine emergency Kit, chlorine hood provided.  The organization has developed an on - site emergency plan to handle emergencies and accidents and is upgraded periodically .  Hazardous chemicals are stored and handled as per MSDS and control measures are provided accordingly.  Safety is given prime importance by management and continuous efforts are made to maintain safety through safety audits, workers tr ainings and awareness programs, etc.  The details about DMP & On - site Emergenc y plan are mentioned in chapter 7 .

Baseline Environmental Status Since this is a Rapid EIA study, p rimary Baseline Environmental data collected for February 2017 to April 2017 is used for this EIA study as the monitored locations were covered in the study area of APPL.

Following the final TORs as issued by SEIAA , the impact or study area has been considered to be the area within radius of 10 km from the project site.

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Executive Summary

Co - ordinates of Centre of Project Site: Latitude: 21°37'13.90" N, Longitude: 73° 2'31.50" E

The study area comprises of: -  Ankleshwar Industrial Estate – marked with green boundary  Part of Panoli Industrial Estate – marked with blue boundary  Part of Jhagadia Industrial Estate – marked with orange boundary  53 Nos. of areas having residential and agricultural land uses  Reservoirs, Ponds and Lakes  Narmada & Amravati river stretches  Kondh Ki Khadi, Amla Khadi, Van Khadi, Chhapra Khadi  Ukai Canal  Part of NH - 48, SH - 13, SH - 6, SH - 76 & SH - 64  Western railway (Main line) - Mumbai - Ahmedabad railway line  Western railway - Ankleshwar - Rajpipla section

Ref: Census 2011 & Toposheet No. F43M14 & F43N2, Survey of India. (Toposheet is attached as Annexure - 17 )

Baseline Environmental Components The environmental parameters for each VEC are established are selected based on –  A nticipated project activities during construction, erection and comm issioning and operational phase  Additional and S tandard ToRs issued by SEAC for synthetic organic chemicals sector for this project .

Parameters considered for Data collection Sr. Environmental Parameters No. Attribute 1. Air Climate conditions (site - specific Meteorological data), Ambient Air quality for parameters relevant to expected air pollutants, Ambient Noise levels 2. Water Surface Water quality (lakes, nalas, canals, rivers, reservoirs, ponds), Ground Water quality (borewells, handpumps, tubewells), Hydrology, Water level measurement 3. Land Geological information, Soil characteristics, Land use pattern and land cover, Digital Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 21 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Sr. Environmental Parameters No. Attribute terrain mapping 4. Ecology & Biodiversity Terrestrial ecology and biodiversity 5. Socio - economics Demography, Community survey, Literacy rate, Occupational structure, Religious structure, Educational facilities, Health and sanitation facilities, Water supply and irrigation facilities, Civic amenities, View / Opinion for the Project for Perception of risk, health and safety, Displacement / Relocation concerns, Loss of livelihood, Loss of lan d / structures, Loss / Reduction of resources, Loss of access to community infrastructure / public utility lines, Employment opportunities, Trade and commerce opportunities, Attitude towards newcomers (migrating labour, residing employees and workforce of the project), Community changes, Sharing of infrastructure and resources 6. Noise Ambient Noise levels – inside the premises, outside the premises, due to traffic Traffic survey for roads used to access site. Primary data collected by Siddhi Green Excellence Pvt. Ltd. and secondary data collected by government bodies as well as reputed institutes is used for establishing the baseline status.

Study Period T h ree months primary baseline data collected for 1 st February 2017 to 3 0 th Aril 201 7 by Siddhi Green Excellence Pvt Ltd. has been considered for establishin g Baseline Environmental Status of the study area . Location reference of this project whose primary baseline data is used: Project Distance and direction from project site of APPL* M/s. Gujarat Insecticides Limited 2.6 km towards W (260°) Plot No. 805/806, G.I.D.C. Ankleshwar, Dist. Bharuch, State - Gujarat, India Co - ordinates of Centre of Project Site: Latitude: 21°37'13.90" N, Longitude: 73° 2'31.50" E

Meteorology For the present study primary data for meteorological parameters was monitored during at the site and for reference secondary data obtained from Indian Meteorological Department (IMD) for Bharuch district was utilized The project site is in Bharuch District which has semi arid climate (rainfall 500 - 750mm). It experiences following seasonsal weather during the year: Season Climate Summer (pre - monsoon) Hot and dry, storms and rain showers are experienced in March, April and May for one or Mid - March to Mid June two days since last two years. May is the hottest month of the year with temperatures exceeding 40°C. Heat waves are experienced for one to three days in the month s of March, April and May when the hourly temperatures reach above 40 °C. Monsoon – South - west monsoon with humid climate. Mid June to September The average annual rainfall of Bharuch (nearest rain gauge station) is about 731.2 mm end calculated for last 14 years of period i.e. 2004 - 2017.Rainy days range from 30 to 45 days. Post monsoon Little hot and dry October to Mid - November Winter Cold and dry. December is the coldest month of the year with minimum temperatures Mid - November to reaching 10 °C. B right cloudless days and clean nights and piercing winds. February

Temperature & Humidity  Maximum daily temperature occurs between 1500 to 1600 hours while minimum daily temperature occurs between 0600 to 0700 hours.  Industrial estates of Ankleshwar, Panoli and Jhagadia have effect on local temperature & Humidity.  The Green cover in this area is considerably good which has effect on local temperatures.  Looking at the recordings of temperature, it can be said that the w eather in the study area is of the nature suitable for plume rise.

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Executive Summary  Average relative humidity in the morning remains around 70% during summer and around 50% during winter, whereas evening values remain around 20 - 30%. Primary data collected from February 201 7 to April 2017 are inline with the annual data. Rainfall The district has south - west monsoon starting from June to October. Average rainfall for last 14 years is 731.2 mm. Rainy days range from 30 to 45 days .

Mixing height The minimum mixing height is observed during winter season at the time of dawn. This mixing height is around 30 m for this region. Hence, stack heights more than 30 m may have horizontal dispersion of pollutants till the inversion prevails. Overall mixing heights are more than 100 m f or more than 80% of daytime over the year.

Wind direction and wind speeds The wind speed within Ankleshwar Industrial estate remain s moderate to high with drifting directions. The wind direction also has variations during daytime and night time. The calm periods during primary baseline study were around 14.88% during February, 24.06% in March while decreased to 12.50% during April as per the climatic conditions of this zone. Season Summer Monsoon Post monsoon Winter Duration Mid - March to Mid June Mid June to October to Mid - Mid - November to September end November February First Predominant Wind Direction South - west South - west North - East North, North - East Second Predominant Wind Direction West, South West West West North North - West Third Predominant Wind Direction West, South West West South West West North - West North - North - East Calm periods (%) ~29 ~30 75 - 80 ~60

Vulnerability to natural disasters Earthquake – Bharuch district falls in Seismic Zone No. III and hence has moderate risk of earthquake. Floods – only near to Narmada river bank Cyclones – Bharuch District is in close proximity to the sea and a perennial large river like the Narmada, the area is prone to medium level of cyclonic damage. Cloud burst – This region does not have vulnerability to cloud burst as the elevations do not exceed 50 m. Tsunami – The Gulf of Khambhat does not have any past incidence of Tsunam i.

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Executive Summary Baseline Ambient Air Quality (Monitoring period – February 201 to April 2017 ) Parameters analyzed : in compliance with the NAA QS 2009 and TORs issued by SEIAA ) Upwind or Range in µg/m 3 except for CO Type Name of downwind w.r.t. Area of PM , CO HCl, Probable sources of air pollutants Village predominant wind 10 SO NO NH BTX Benzene Area PM 2 x mg/m 3 3 Free Cl direction (SW - NE) 2.5 2 Within 3 Within Industrial emissions and Emissions due to km from Ankleshwar 70 - 79, I Upwind 11 - 21 17 - 28 0.6 - 1.3 6 - 23 2.6 - 4.3 <0.5 - 1.6 BDL vehicular movement within industrial project GIDC 16 - 28 estate site Estate 62 - 79, Vehicular traffic on NH - 48 ,Industrial Motali R Crosswind 9 - 21 14 - 27 <0.5 - 0.9 BDL 1 - 2.3 BDL BDL 15 - 30 emissions from GIDC Ankleshwar and Emissions from domestic activities such as burning of agricultural wastes, 63 - 75, Uchhali R Downwind 9 - 21 11 - 22 BDL BDL 1.1 - 2.6 BDL BDL fuelwood for cooking, fireplaces, use of 9 - 25 diesel in pumps and other machinery for irrigation Ankleshwar Vicinity of NH - 48, Vehicular traffic on SH - Between Railway 76 - 91, C Crosswind 13 - 26 20 - 32 <0.5 - 1 6 - 26 1.7 - 4.8 0.8 - 2.2 BDL 76, GIDC overbridge and surrounding 3 - 5 km Station 17 - 33 GIDC industrial estate from area, GIDC project Gadkhol 69 - 81, R - C Crosswind 16 - 27 11 - 29 <0.5 - 1.3 6 - 24 1.3 - 3.7 0.7 - 2 BDL Vehicular traffic on SH - 76 site (CT) 19 - 32 70 - 83, Vehicular traffic on SH - 13 (Valia - Kosamadi R Upwind 7 - 24 12 - 27 <0.5 - 0.9 <5 - 24 < 0.5 - 2.2 <0.5 - 1.2 BDL 19 - 30 Ankleshwar road) Railway Station, Vehicular traffic on SH - 76 & SH - 6, Emissions from domestic 68 - 83, activities such as burning of agricultural Piraman I - R Crosswind 8 - 18 11 - 33 BDL <5 - 9 <0.5 - 1.7 <0.5 - 0.9 BDL 15 - 28 wastes, fuelwood for cooking, fireplaces use of diesel in pumps and other machinery for irrigation Between 69 - 83, Emissions from domestic activities such Kansiya R Crosswind 12 - 19 10 - 23 <0.5 - 0.8 BDL 0.6 - 2 BDL BDL 5 - 10 16 - 26 as burning of agricultural wastes, km from fuelwood for cooking, fireplaces use of 61 - 85, project Diva R Crosswind 9 - 24 8 - 30 <0.5 - 0.7 <5 - 19 <0.5 - 1.8 BDL BDL diesel in pumps and other machinery for 8 - 24 site irrigation & Dust emissions from kaccha Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 24 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Upwind or Range in µg/m 3 except for CO Type Name of downwind w.r.t. Area of PM , CO HCl, Probable sources of air pollutants Village predominant wind 10 SO NO NH BTX Benzene Area PM 2 x mg/m 3 3 Free Cl direction (SW - NE) 2.5 2 roads.

Vehicular traffic on SH - 13 (Valia - Ankleshwar road), emissions from nearby industries & Emissions from domestic 68 - 81, Kondh I - R Crosswind 16 - 26 18 - 28 <0.5 - 0.9 <5 - 12 <0.5 - 2.4 <0.5 - 1.2 BDL activities such as burning of agricultural 16 - 32 wastes, fuelwood for cooking, fireplaces, use of diesel in pumps and other machinery for irrigation Emissions from domestic activities such as burning of agricultural wastes, fuelwood for cooking, fireplaces use of 56 - 82, diesel in pumps and other machinery for Sardarpura R Downwind 11 - 25 13 - 28 <0.5 - 0.8 BDL 0.8 - 2.6 BDL BDL 15 - 29 irrigation, Dust emissions from kaccha roads and vehicular emissions from adjacent road connected to Jhagadia GIDC estate. Vehicular traffic on NH - 48, Industrial emissions from GIDC Panoli and Emissions from domestic activities such 70 - 84, Kharod I - R Upwind 8 - 19 10 - 23 <0.5 - 1.1 <5 - 12.3 <0.5 - 2.2 <0.5 - 0.7 BDL as burning of agricultural wastes, 15 - 29 fuelwood for cooking, fireplaces, use of diesel in pumps and other machinery for irrigation. Sanjali 74 - 84, Vehicular traffic on NH - 48, Industrial I - R Upwind 9 - 22 15 - 28 <0.5 - 1.4 7 - 20 1.5 - 4.1 <0.5 - 1.9 BDL (CT) 19 - 28 emissions from GIDC Panoli. R : Residential, R - I : Residential - Industrial All parameters remain within permissible limits of NAAQS . Ambient air quality at project site remain within stipulated limits of CTO as per Environment audit reporti

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Executive Summary Hydrology and Groundwater & Surface water Quality  The short term (2004 - 2017) average annual rainfall is 731.20 mm. Maximum rainfall observed in 2013 is 1165.10 mm and minimum rainfall in 2012 is 401.70 mm.  The Narmada River is the major river in the study area. Narmada Estuary is about 41 km from project site (Ankleshwar GIDC) on west side. Finally, the river enters the Gulf of Khambhat. Non - compliance in values of BOD, DO and Total coliforms in sample of Narmada River & Amr avati River is attributed to moderate to heavy eutrophication. The rivers do not receive any industrial discharges and are primarily used only for animal bathing and washing purposes. There is eutrophication observed during the sampling period indicating a ddition of urinal and sewage to the rivers.  Amla Khadi, Chhapra Khadi and Amravati River are water bodies merging into Narmada River towards the North and Northwest direction from project site. Van Khadi is water body merging into Narmada Estuary towards t he West direction from project site. Non - compliance in values of BOD & DO and Total coliforms of Amla Khadi (Nr. Piraman), Kondh Ki Khadi is attributed to moderate to heavy eutrophication. The canals/ khadis do not receive any industrial discharges and are primarily used only for animal bathing and washing purposes thereby causing eutrophication.  The g eneral topographic slope is in N W direction  There is irrigation canal network of Tapi and Ukai dams in study area .  The site does not fall near to the pollute d stretch of Amla Khadi (Pungam to Bharuch).  The ponds are used for animal bathing and clothes washing.  Garbage dumping and sewage water addition was also observed in few ponds.  Because of this, eutrophication of the level of moderate to high covering majo r part of the ponds was observed and the DO levels of these ponds were therefore low.  The ponds are now being considered for revival or restoration to solve the water supply shortages for irrigation.  GIDC estate of Panoli and Ankleshwar have structured net work of storm water drainages connected to pumping station of NCT for conveyance to FETP .  Common Effluent treatment and conveyance pipeline project of NCT is operational since 2006 in which insitu treated effluent from industries and CETPs of estates of An kleshwar, Panoli and Jhagadia are collected through underground drainage and pumped to Final Effluent Treatment Plant (FETP) and final treated effluent is then conveyed into deep sea in the Gulf of Khambhat, where it is discharged through scientifically de signed diffuser, where instantaneous dispersion and large dilutions exists  Probable sources of chemical pollutants in Amla Khadi are illegal discharges from industries of GIDC estates and overflow of effluents from ETPs and mixing in stormwater drain of GI DC.  Domestic sources of water pollution in village ponds and khadis include sewage, animal bathing, clothes washing, domestic garbage dumping and surface run - offs from agricultural farms carrying excessive fertilizers and pesticides .  GIDC reservoir water w as found to be complying to IS 10500 : 2012 .

Groundwater status  The static water level varied between 3.06 m to 29.06 m.  The general groundwater flow is in SW & NW direction.  Majority of villages and towns in the study area use borewell waters mixed with GIDC supply water or after treatment in RO plant.  The quality of borewell water sampled at users’ end were found to be complying with drinking water standard IS 10500 : 2012 except for few samples non - complying w.r.t to organic matter and total coliforms which can be attributed to pipeline of o/h storage tank from where samples were taken. Such water can be considered fit for consumption and potable purpose with primary treatm ent .

Soil Quality  Geologically, entire study area comprises Alluvium of Holocene age and Sedimentary rocks of Tertiary.  The general topographic slope is in NW direction.  Soil of the study area is of clayey type.  The physical and chemical analysis of th e soil samples indicates that the soil of entire study area falls suitable for agricultural purpose .

Noise Environment

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Executive Summary Monitored locations Type of Activities contributing to noise Day time noise levels Night time noise levels area (0600 to 2200 hrs.) (22 00 to 0600 hrs.) Diva, Kosamadi, entirely residential activities Within permissible limit of Within permissible limit of Kansiya, Motali, R and roadside traffic noise at 55 dBA 45 dBA Uchhali, Sardarpura Kosamadi and Motali Railway station and connecting Within permissible limit of Within permissible limit of Piraman R - I road traffic 55 dBA 45 dBA Within permissible limit of Within permissible limit of Kharod R - I NH - 48 – 450 m from village 55 dBA 45 dBA industrial sources and rural Occasionally higher than Occasionally higher than Sanjali (CT), Kondh R - I sources of noise pollution permissible limit of 55 dBA permissible limit of 45 dBA continuous traffic movement Within permissible limit of Within permissible limit of Gadkhol (CT) R - C from Ankleshwar and Bharuch 55 dBA 45 dBA on SH - 76 continuous traffic movement Ankleshwar Railway Frequently higher than Occasionally higher than C from GIDC and Railway Station Area, GIDC permissible limit of 65 dBA permissible limit of 55 dBA station. Within Ank. GIDC Utility, boiler operations & Within permissible limit of Within permissible limit of I Estate maintenance activities 75 dBA 70 dBA R : Residentia l R - I : Residential - Industrial I : Industrial

Land use Pattern of the study area For determining the baseline land use pattern, at and around the project site, Land use classification is done on satellite imagery of IRS - R2 received from NRSA and reference to toposheet for the study area and supported with ground checks and ground truth verification. 1. Agricultural land Cropland / Fallow land :  About 59% comprises of cropland or fallow land. Both Kharif and Rabi crops are taken in this region. Cotton, Castor, Tuver and Banana are predominantly grow in this region.  The land is kept fal low for considerable period during the year depending on self assessment of cropping and requirement of farming .

2 . Built - up land  Industrial occupied land comprises of GIDC estate of Ankleshwar, Panoli & Jhagadia as well as other industrial premises occupy ~11%.  Village area is about ~9%. All villages fall in Ankleshwar, Jhagadia and Valia Talukas of Bharuch district & Mangrol Taluka of Surat District  53 Nos. census settlements of villages and 19 Nos. township are located in stud y area.

4. Waterbody  The water body including Rivers/ Pond/ Khadi/Canal /Drainage/ Reservoir is about 4% of total area.  Part of Narmada river passes through NW of the study area.  Amravati River is another river passing through the study area in NE & SE E quarter  There are four Khadis passing through the study area with their tributaries: - Kondh Ki Khadi (Passing along Kondh Village, Jitali upto Dadhal where it meets Amravati River), Amla Khadi (along left side of Ankleshwar GIDC estate flowing towards Northwest meeting Narmada river near Alia Bet), Van Khadi (from Piludara, Umarwada towards southwest meeting Estuary near Samli, Kantiyajal, Jetpor village) and Chhapra Khadi (originates near Andada (CT)) flows towards north - north - west passes along SH - 76 villages and converges with Narmada river near Golden Bridge).  Ukai Canal network is across the study area primarily covering SW quadrants of the study area.  There are two reservoir of GIDC. Ankleshwar GIDC & Panoli GIDC have water supply through Ukai canal network.

5. Wasteland ~17% is scrubland i.e. it is uncultivated at area alongside khadis and canals and a significant scrubland is present near villages Bhilvada, Borbhatha, Gujarat Guardian Township . Siddhi Green Exc ellence Pvt. Ltd., Ankleshwar Page 27 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary

Ecological Information  The entire study area of 10 km radius does not include any Protected Area or any ecologically sensitive zone like National Park, Wildlife Sanctuary, Biosphere Reserve or Community Reserve etc. therefore there is no potential threat t o any of the terrestrial ecosystem in the vicinity of the area .  The entire study area did not show presence of any potential wetlands that could harbour the migratory waterfowl except for GNFC Reservoir , GIDC Reservoir - Bhadkodara & GIDC Reservoir - Panol i .  During the entire survey, none of the species of flora or fauna belonged to rare, endangered or threatened category as described by IUCN .  There is no removal of existing floral species from core zone. Therefore, there will not loss of floral diversity & will not significant impact on the species diversity & habitat structure of fauna .  The study area falls under Biogeographic Zone No. 4, ‘Semi - Arid Zone’ and covered under Biotic Province 4B – ‘The Gujarat - Rajwara Province’ and has ~58% land occupied for a griculture and rest of the area has landcover pertaining to villages, towns, townships and industrial estates. Therefore, common species of flora & fauna are observed and there is no probability of loss of floral, faunal diversity & population due to the p roposed expansion project .  Schedule - I species i.e Indian Peafowl ( Pavo cristatus ) is habitant of some pockets of dense greenbelt areas of Ankleshwar (INA) and Bengal Monitor Lizard ( Varanus bengalensis ) is observed in some pockets Jhagadia INA owing to fav orable environment in this zone like feeding, breeding etc .

Socio - Economic Environment Demography  In the study area of 10 km radius, there are 53 census settlements consisting of 49 villages its subpart, 02 Municipality, 02 Industrial notified areas and 05 census towns covered in Ankleshwar, Jhagadia and Valia Talukas of Bharuch district & Mangrol Taluka of Surat District.. In addition to this, there are 19 urban settlements in the form of townships within these areas.  Ankleshwar Industrial Notified Area (INA) and Panoli Industrial Notified Area (INA) also has urban settlements  Due to industrial development in this area, there is considerable influx of outside population in Piraman, Kosamadi, Ankleshwar (M), Ankleshwar INA, Bhadkodara (CT), Andada (CT), Gadkhol (CT), Panoli INA and Sanjali (CT).  Population in Bharuch (M) & Kosamadi village.  Bharuch (M) and Kondh village are comparatively large in area.  Chhapra & Motali are small village w.r.t area.  Boridara has the lowest population density (169).  Vatariya, Kapodara, Mandvabuzarg Dadhal, Govali and Kosamadi village have population density more than 800. Sanjali (CT), Andada (CT), Ankleshwar (M) & Bharuch ( M ) have population density more than 6000.  Population of SC is more in Andada (CT) – 13.3%  ST population ranges from 2.4% to 98.8% ( Amrutpura ).  Major migration is from nearby villages as well as nearby regions of Gujarat as well as from other states such as Dahod, Godhara, Narmada, U.P., Bihar, M.P. due to rise in employment in upcoming industries in Estate areas. Common employment opportunities are unskilled and skilled labour and technicians for construction and erection activities of coming up industries.  Labour colonies are also coming up near industrial areas .

Population range No. of areas i n study area % Population range No. of areas in study area % < 200 0 0 2000 - 4999 15 30.6 200 – 499 1 (Sardarpura) 2.0 5000 - 9999 3 6.1 500 - 999 10 20.4 10000 - 50000 6 12.2 2 1000 - 1999 12 24.5 > 50000 4.1 Ankleshwar (M) & Bharuch (M)

Literacy  Literacy rate ranges from 54% (Samor) to 85% (Ankleshwar (INA). As per Census 2011, the literacy rate of Ankleshwar Taluka is about 85.74 %.  The literacy rates are comparatively good in villages as well as in towns owing to good no. of schools. However, o wing to the continuous development of the Industries in GIDC, the awareness for literacy among the local Siddhi Green Exc ellence Pvt. Ltd., Ankleshwar Page 28 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary population is increasing in this area. Also new schools and colleges are coming up and existing educational facilities are being upgraded as part of ES R and CER activities by industries and GIDC .

Occupational structure of study area Many villages have Agriculture and Animal Husbandry as their main occupation  But due to industrial development and associated developments people are shifting their occupat ion in industrial associated development like transportation, construction work, domestic supplies, industrial supplies and services, as a labour in industries also. While Piraman, Gadkhol (CT), Andada (CT), Kosamadi, Ankleshwar INA, Kapodara, Sanjali (CT) , Panoli INA being near to the industrial areas have a significant population engaged in industrial and commercial activities.  The industrial Estates generate ample employment for skilled as well as unskilled manpower. GIDC has started Skill Development Ce nter at Dahej and Ankleshwar.  There is a section of the population which raises its income by working in different sectors of the industrial area viz. labour, housekeeping, packaging, technicians, construction activities , construction supplies, catering se rvices, transportation services, etc. The industrial area also has an effect on the type of education taken by the youth in this region.  Trade and Commerce, construction and communication services have also taken up in these areas.  Transportation services (Buses, vans, cars, etc.) and automobile and construction equipment supply and accessories are also newly developed industrial services by local population to cater to upcoming new industries.  Hotel business is picking up in this area, as on date, there ar e many small and medium hotels along SH - 13, SH - 6 4, NH - 48 road. This is indicating that catering and hospitality business may become significant in the coming years.

Details for Crops - Wheat, Jowar, Cotton, Maize, Pulses (Pigeon pea), Sugarcane and Banana are the main crops of this region. Nilgiri farming, flowers farming (Galgota and other ornamental flowers) as well as wood farming has also picked up in this region in recent years .

Civic Amenities Shelters & Roads  All villages have majority pucca shelters with kuchcha shelters where BPL families reside.  Pucca Internal roads are present in many of the villages having good population and area.  GIDC is continuously carrying out construction of roads in these villages as per its social development programme .

Water Facilities  Supply network for supplying water to all villages through Gujarat Water Supply & GIDC water (Karjan Water Supply and GIDC Canal Water)  Almost all villages have tap water facility with overhead tanks.  Only few villages are devo id of this facility and use tubewells or borewells.  Use of ground water is limited to domestic and agricultural uses and not preferred for drinking water.  RO water plants are installed at Boidara, Piraman, Sanjali (CT) and Motali.  Irrigation Water Facility is partially available through canals and partially through borewells .

Educational Facilities in study area  There are govt. as well as private aided and unaided pre - primary, primary, secondary and higher secondary schools of Gujarati medium within nomina l access distances.  There are English medium schools with GSEB, CBSE, ICSE board education in Valia and Ankleshwar GIDC estate.  Ankleshwar INA has hindi medium school also.  Ankleshwar INA, Valia and Bharuch have many Gujarati and English schools as well as International education based schools.  Ankleshwar has ITI colleges, Science, Arts and Commerce Colleges.  There is Engineering College at Vataria.  Other engg. and medical colleges are in Bharuch, Vadodara and Surat.  Distance learning centres are also a vailable at Ankleshwar (M) and Ankleshwar INA.  Transport buses are also being provided through CSR programmes .

Health Facilities Siddhi Green Exc ellence Pvt. Ltd., Ankleshwar Page 29 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary

Health facility Available at (within study area) Whether Government or Private Community Health Centre / Primary Diva, Piraman, Kosamadi, Kharod Government Health Centre Private Dispensary Diva, Piraman, Ankleshwar (M), Ankleshwar INA, all Private towns Mobile Health Unit (MHU) A Mobile Medical Van of Gattu Vidyalaya Private Hospitals (General) Ankleshwar (M), Ankleshwar INA, Piraman , Diva, Government & Private Kharod Maternity And Child Welfare Centre Ankleshwar (M), Ankleshwar INA Government & Private Hospitals (specialty) ESIC Hospital at Ankleshwar INA -- Veterinary Hospital / Dispensary Ankleshwar (M), Ankleshwar INA Government

Sanitation  Drainage system is good in most of the villages and towns.  Garbage collection facility is available in towns

Electricity  Electricity from Dakshin Gujarat Vij Company Ltd. (DGVCL) for all purposes (domestic, agricultural and commercial) is available in all villages and towns in the study area.

Telecommunications  Post offices are available in most of the villages.  All villages have BSNL Telephone (landlines connectivity).  Mobile Phone Coverage is also available in all villages.  Private Courier facilities are available in Piraman, Diva, Kosamadi, Kapodara and towns.

Transport  Government bus, jeep, vans, tractors and tempos are used in most of the villages.  All villages are well connected through a network of Pucca road as well as Kaccha approach road.  There is proper approach for State highways and NH - 48.  Bharuch and Ankleshwar are the nearest railway station for passenger travel having stoppage for all major route tra ins.  Bus is the main mode of transportation and bus stands are provided at all villages.  Ankleshwar and Bharuch Bus depot is used for commuting to nearby villages and cities.

Other facility  Nationalized bank branches are available at major villages and at all towns  Major Private Banks are having their branch in towns  ATMs of major banks are also available in towns and at Piraman and Kosamadi  Domestic LPG Gas supply office is also available in Piraman, Kapodara, Kosamadi & Diva  Domestic CNG gas supply is available at Ankleshwar (M) & Ankleshwar INA  There are CNG Gas Stations near Ankleshwar INA along SH - 13, Ankleshwar - Valia road and Gadkhol (CT).

Ankleshwar Nagarpalika and Gram Panchayats are carrying out various infrastructure and social development act ivities in the villages and towns. Operational units in Ankleshwar and Panoli GIDC have also initiated CER activities in these villages at small and big scales.

Looking to the above, it can be concluded that this region is fast developing in terms of in frastructure, civic amenities, educational and health facilities. The gap in the living standards of villages is expected to reduce in the coming years as industrial development continues in this estate .

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Executive Summary Prediction Of Impacts Phase of Project Adverse impacts Beneficial impacts Construction & It is anticipated that there shall be marginal and localized increase in the levels of PM 10 , PM 2.5 , SO 2 and NO x in Ambient air quality, noise, flora, soil within the site – Erection Phase the vicinity of excavated areas within the site. About 12% of plot area shall be excavated for expansion. significant and continuous (Greenbelt) Minor and temporary rise in temperature when machineries are operating. There may be periods of loud and irritative noise, which may cause discomfort to the working manpower near Employment to skilled and unskilled manpower - the construction areas. significant and continuous There is probability of sewage being disposed off directly onto the open land on labour camps and penetrating into ground waters of ne arby shallow aquifers after long periods. Trade and commerce opportunities - signi ficant and Health and safety of manpower within the site and on roads accessed to reach site – marginal and seldom frequent Diesel shall be consumed on regular basis during the excavation, construction period and for transportation. Safety of stray and domestic animals using roads accessed to reach site – marginal and seldom Development of ancillary businesses – moderate and Soil contamination from PM deposition from vehicular emission within the site and on roads accessed to reach frequent site – marginal and seldom Social and population chang es due to labour mobilization – negligible Education and living - moderate and frequent (CSR & CER activities) Commissioning Ambient air quality within the site and on roads accessed to reach si te owing to vehicular emissions – marginal Ambient air quality, noise, flora, soil within the site – and Operational and occasionally significant and continuous (Greenbelt) Phase Chemical vapors and fugitive emissions from improper storage and handling facilities of Hazardous chemicals Employment to skilled and unskilled manpower - and hazardous processes may result in accidents or toxic release and shall add to HAPs in ambient air and significant and continuous indirect impact on social and biological e nvironment within the site by odour generation, difficulty in breathing, Trade and commerce opportunities - signific ant and respiratory diseases, headache and such nausea. frequent Odour generation and solvent vapors addition into ambient air may occur if storage, transfer or handling of Development of ancillary businesses – moderate and volatile and odourous chem icals at production and warehouses is not carried out as per requirement of MSDS frequent and can have negative impact on health of biological and social environment. Education and living – significant and frequent (CSR Process emissions if not controlled adequately within permissible limits shall have marginal adver se health & CER activities) impacts to surrounding biological and social environment through air. Water consumption from Dam (GIDC water supply) – moderate and continuous The adequacy and efficiency of proposed ETP if not maintained may result in non - conforming effluent b eing sent to CETP ultimately affecting CETP performance. Health and safety of manpower within the site and on roads accessed to reach site – marginal and seldom Safety of stray and domestic animals using roads accessed to reach site – marginal and seldom So il contamination from PM deposition from vehicular emission within the site and on roads accessed to reach site – marginal and seldom Social and population changes due to labour mobilization – negligible Noise – at site – negligible and on roads accessed t o reach site – marginal and occassionally

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Executive Summary

Beneficial impacts during construction and erection phase There shall be increase in trade and commerce opportunities of the area through requirement of machinery, repair & maintenance services and supplies, drinking water suppli es. There shall be employment of skilled labour for operating construction machinery, supervising construction activities and mai n tenance & repair work. There shall be temporary employment of unskilled labour for construction activities and maintenance & repair work. Both local s as well as migrated labour shall be employed through construction agencies. There shall be generation of business related to domestic supplies, canteen, drinking water supplies as well as domestic requirements of labour camps, tra nsportation of labour through rickshaws, tempos, vans, etc.

Benefical Impacts during operational phase Parameter Benefits Countrywide benefits Benefit to country’s economy and revenue through taxation and exports Trade and commerce There shall be considerable business allotment to local as well as non - local transport agencies for transportation of raw materials and products, fuel, opportunities engineering supplies, other ancillary supplies. Raw material manufacturers and suppliers shall gain business from expansion requirements. distributors, dealers, transportation agencies shall gain business out of selling of products Local traders and service providers shall be preferred and given opportunity Generation of temporary Temporary employment of locals and migrated labour for loading and unloading activities shall add to their income. employment Generation of employment Effluent treatment processes involve material loading, sludge movement, packaging, such other activities where unskilled labo ur shall be deployed by for unskilled labour company or contract agency Enhancement and maintenance of greenbelt shall require empl oyment of nursery personnel through contract or permanent recruitment. There shall be approx. 10 locals employed for this purpose. There shall be additional recruitment of approx. 150 unskilled employees in the field of security, gardening, housekeeping, packaging, loading and unloading and such other fields related to a manufacturing facility. Generation of employment There shall be additional recruitment of skilled employees in the field of plant operation, laboratory activities, engi neering, maintenance, security, purchase, for skilled labour accounts, warehousing, housekeeping and such other fields related to a manufacturing facility. Employees are covered under insurance and other benefits of employment are also made available. Marketing of products shall require skilled manpower wherever product market is to be accessed. Local skilled and unskilled manpower shall be given priority. Proponent is committed to give employment to local affected people as per Government rules and re gulation. Priority shall be given to local affected people according to skill and academic qualification. Development of ancillary There shall be rise in business opportunities for local as well as non - local related to machinery spares, repair and service. businesses There shall be business opportunity for nurseries of this region for enhancement and maintenance of greenbelt and requirement of fertilizers, pesticides, saplings, and other accessories. Proponent shall engage marketing agencies which shall further generate business for related suppliers for marketing material. Siddhi Green Exc ellence Pvt. Ltd., Ankleshwar Page 32 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Parameter Benefits Local service providers shall be preferred and given opportunity Education and Standard of Proponent is committed to take up various social welfare activities in the nearby vi llages as per requirement and applicable statutory legislations. For this living project, management shall initiate discussion with representative panchayats of local villages to plan CER activities therein . Pl. refer Chapter 10 for CER activities.

Environment Management Plan (EMP) EMP for Construction and Erection Phase EMP for Air and Noise Environment At Construction areas Maintenance of excavation equipment and construction equipment to minimize exhaust emission. Regular checking and maintenanc e of vehicles shall be ensured (valid PUC). Use of cleaner fuel for machinery. Gensets (DG sets) shall be well maintained to ensure low emissions. Night time construction shall be avoided as far as possible. Unwanted material and solid bags shall be place d as noise barriers during major construction activities. Ear muffs and Ear plugs shall be provided to labour and workers. Existing greenbelt shall be enhanced which shall provide adequate dust abatement and which supports the terrestrial flora and fauna o f the area.

Abatement of Dust from loading / unloading operations & construction machinery There is a developed peripheral greenbelt at the site, which shall provide adequate dust abatement during construction phase. For unloading activities of construc tion material at site, it shall be ensured that dispersal of dust borne particles are minimized by using water sprinklers or covered unloading by a sheet made of either jute, tarpaulin, plastic or any other effective material. Areas where loading / unloadi ng (fugitive dust) activities shall be demarcated and located such that dust dispersal is minimized. Ready mixed concrete shall be used in building construction as far as possible. Build higher barricades to arrest dust generated at ground levels and adopt covering (jute, plastic, tarpaulin etc) of construction material / wastes.

Reference : CPCB guidelines on Environmental management of Construction & demolition (C & D) Wastes

During Transportation Regular checking and maintenance of vehicles shall be e nsured (valid PUC). Transporters shall be instructed to use clean fuels for their vehicles. Routes of transport vehicles within construction site be damped by water. (preferably treated waste water) Vehicles hired for bringing construction material to the site and other machinery to be used during construction should be in good condition and should conform to applicable air and noise emission standards. No parking outside the plant premise, parking shall be done only at earmarked areas for parking vehicles provided by GIDC in the estate.

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Executive Summary Roads within residential areas shall not be used for transport. EMP for Water, Land and Ecological Environment Sanitation facilities shall be provided to the workers within the construction site and sewage shall be disposed through soak pit via septic tank. Plastic sheets or tarpaulin shall be used for storage of construction materials. All the topsoil excavated during construction activities should be stored for use in horticulture/ landscape development with in the project site. Construction waste shall be collected on plastic sheets or containers and covered so that it does not mix with soil. It shall be disposed off properly. Greenbelt within the site shall support the terrestrial flora and fauna of the area. EMP for Socio - economic aspects, Health and Safety At site: Construction areas shall be cordoned with appropriate fencing and signage also shall be placed when heavy machinery or vehicl e movement is on. Supervision from contractor shall be vigilant during suc h activities. Company shall prefer local suppliers wherever feasible and qualifying vendor specifications. As per census information, villa ges around GIDC estate have occupations related to transport, construction materials and machinery which are availed by industries on regular basis. Construction labour shall be resided at GIDC allotted land in the estate and hence their interaction with locals shall be min imum. HR department shall counsel with labour whenever necessary.

During transportation: Transporters shall be advised by procurement department to remain conscious about their truck drivers alertness during driving on roads and minimiz e risks of accidents through surveillance for harsh driving, drunk drivers, bad condition of tyres and engine s and such other concerns. EMP for Fuels Presently diesel is available in ample and regular supply in this region. Presently cooking fuels are available in ample and regular supply in this region.

EMP for Operational Phase Ambient Air quality and climate Stack Emissions Control measures Flue gas emissions shall remain well within permissible limits as Natural gas is to be used as fuel. Adequate stack height an d monitoring facilities shall be provided.  Gensets (DG sets) shall be well maintained to ensure low emissions.  Production activities shall be started only after adequate scrubber systems are installed for process emissions.  All APCMs for process emissions shall be operated efficiently & vigilantl y.  APCM shall be given D.G set power as standby  PM and other air pollutant levels shall be monitored periodically by third party laboratory.  Performance of APCM shall be monitored through regular monitoring and online systems wherever applicable as detaile d in chapter 6 Fugitive emission control measures  Sources of fugitive emissions have been identified for chemical dust and chemical vapors and control measures are proposed in Chapter 2 of this Report. Control measures proposed for these emissions shall be adequate and appropriate for maintaining pollution free and odour free environment in the factory.  Stringent monitoring and control shall be done for preventing malfunctioning of process operations. Siddhi Green Exc ellence Pvt. Ltd., Ankleshwar Page 34 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary  Greenbelt at the site shall provide adequate dust and po llutant abatement. The greenbelt shall also maintain ambient temperatures around it lower during hot climate by transpiratio n effects. This shall inturn have beneficial impacts on health of manpower working within the site as well as surrounding resid ents , flora and fauna. Vehicular emission control measures  Regular checking and maintenance of vehicles shall be ensured through checking of PUC certificates. Transporters shall be ins tructed to use clean fuels for their vehicles.  No parking outside the plant premise, parking shall be done only at earmarked areas for parking vehicles provided by GIDC in the estate.  Internal village roads and roads within residential areas shall not be used for transport.  Roadside plantation shall be done Safety Road safety To provide transport facility for workers to the best possible extent. Suppliers shall be instructed to ensure that 1) about their drivers alertness during driving on roads and minimize risks of a ccidents through surveillance for harsh driving, drunk drive rs, bad condition of tyres and engines and such other concerns. 2) Trucks and drivers are well aware of the hazards of chemicals and also they are transporting and have training on emergency handling. 3) TREM cards are available with drivers. 4) Spill cont rol procedures and equipment are available with the drivers during transportation. 5) Not to use village internal roads.

EHS personnel inspect trucks and trailers regularly for leakages, damages, drum stacking procedures, conditions of pipes, val ves, fitt ings, corrosion and surfaces etc. Unit shall develop an onsite emergency plan wherein emergency handling procedures for hazardous chemicals spillage will be av ailable for application to on - road incidents also.

At site Production area The reactors are ge nerally equipped with safety systems to take care for over - temperature and over - pressure scenarios. Alarm and trip interlocks shall be installed wherever required. For distillation – primary and secondary c ondensers with cooling water shall be provided on reactors All unit processes and unit operations shall be carried out under stringent controls and monitoring through local indicators and emergency control. The work environment shall be kept free of chemical vapors by adequate exhaust systems in all plant s at all levels of shop floor. Mechanical seals will be provided for agitators for reactors for reduction of fugitive emissions. Pumps with mechanical seals or sealless pumps shall be used for transfer of low V.P chemicals. All open - ended intermediate vessels shall be covered securely during period of operation and storage. Advanced bag filling machinery, covered in packaging rooms with local exhaust systems. Closed transfer systems shall be adopted, workers shall be provided PPEs, minimum manual operations. Solvent recovery system on reactors to yield minimum 95% recovery.

Tankfarms and warehouses Storage and handling of hazardous chemicals like acids, VOCs shall be in accordance with MSDS requireme nts. Tankfarms and tanks shall be constructed with adequate safety features and instrumentation controls Loading and unloading in tanks and reactors shall be carried out using standard safe operating procedures Proper handling of all spillages by spill con trol procedures Only trained persons shall be deputed for handling of hazardous chemicals and operations. Siddhi Green Exc ellence Pvt. Ltd., Ankleshwar Page 35 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Warehouse for storage of raw materials and finished products shall be well - equipped with fire and toxic release control arrangements.

Fire extinguish ers shall be placed at all required locations Fire water storage is available for use by external fire tender. Fire station is available at Ankleshwar for handling all types of emergency. The proponent is member of Disaster Prevention & Management Centre , Ankleshwar. Mutual aid from other industries of GIDC Ankleshwar estate is also available. APPL has developed onsite emergency plan (DMP) in full compliance with the requirements of Factories Act, 1948, Gujarat Factories Rules, 1963 an d The Manufacture , Storage and Import of Hazardous Chemical (Amendment) Rules, 2000. Greenbelt shall be maintained for adequate count, suitable species for pollution control. Night time maintenance activities shall be avoided as far as possible. Health Negative impacts due to pollution shall be mitigated by mitigating impacts on air, water and land environment. Green belt shall improve the air quality as well as absorb hazardous air pollutants including particulate matter. Consequentl y there shall be beneficial impact on health of manpower working within the site as well as surrounding residents, flora and fauna. Company mentions hazard information and safety measures on label of product packaging. Hazardous wastes and chemicals are stored in RCC covered areas and in ap propriate containers in full compliance with the requirements of MSDS and applicable statutory rules and regulations. Measures to control Fugitive vapors of chemical and fugitive dust from vehicle and personnel movement : -  To take upmost care to prevent leakages from pipe fitting, valves etc., drains shall be provided at all plants to route such occasional effluent to ETP.  All movement areas shall be paved.  Spill control procedures to be practiced.  Stringent monitoring and control shall be employed for preventing malfunctioning of process operations.  To use proper loading and unloading procedures for materials and cover them wherever required.  Operation equipment shall be kept closed.  There shall be separate storage areas for different hazardous chemical s constructed in compliance to the applicable rules.  Proper containment system shall be provided for runoff of chemicals in case of spillages.  There shall be sufficient holding capacity for storage of treated and untreated effluent.  Proper housekeeping pra ctices shall be followed in the unit to maintain clean and clear environment & prevent contamination of surface runoffs and s torm water.  The new plant sections shall be provided well - structured drainage network same as existing for preventing surface run - o ffs from mixing into sewers during monsoon.  Workplace environment monitoring shall be carried out as per plan delineated in chapter 6. Effects on agricultural farms Mitigation measures taken for air and water management shall mitigate the adverse impacts on agricultural farms also. Terrestrial fauna and flora The management of air, water, noise and land environment as proposed in the previous sections shall ensure that there is no a dverse impact on the terrestrial and aquatic ecology of the

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Executive Summary area. Intern al village roads shall not be used for transport. Transporters are advised by procurement department to remain conscious about their drivers alertness during driving on roads and minimize risks of accidents through surveillance for harsh driving, drunk dri vers, bad condition of tyres and engines and such other concerns. Ambient Noise Levels and Traffic Noise Control Use of acoustic enclosures for utility installations. Maintenance of pumps and machinery & all rotating equipment. Proper loading and unloading procedures. The greenbelt shall abate noise and prevent it from reaching to surrounding residents and fauna.

Internal village roads shall not be used for transport. Regular checking and maintenance of vehicles shall be ensured through checking of PUC certificates. Transporters shall be instructed to use clean fuels for their vehicles. No parking outside the plant premise, parking shall be done only at earmarked areas for parking vehicles provided by GIDC in the estate Soil Quality Land pollution due to industrial wastewater percolation is eliminated as there is no discharge of effluent onto land or inland wat er bodies. Sewage is disposed off through soak pit via septic tank and same shall be continued. Solid wastes to be stored in RCC fl oors with drains to contain any spillages or chemical seepages. Hazardous wastes shall be stored in covered areas in compl iance with the requirements of The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Landfill wastes are disposed to authorized TSDF facilities. These sites abide with the conditions of HW rules and are also monitored by state au thorities for compliance. Proponent is committed to send hazardous wastes only to those site/s which have valid consent to operate granted by SPCB. Co - processing shall also be adopted to the best possible extent to reduce waste sent to landfilling sites. For by - products, proponent is committed to ensure that the actual users have valid authorization for utilization of the by - produc ts under Rule 9 of The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. Hazardous chemicals shall be transported in bags, drums and carboys, loaded on trucks and hence there is very less probabilit y of spillage. EHS personn el shall ensure that drums are secured properly and protected from damage or failure of seals. Proponent shall explore possibilities for reducing manual handling of hazardous wastes wherever possible - by packing the waste at place of generation, minimum t ransport distances, transport in closed containers, and minimum inventory of wastes. Surface water quality management Sewage is disposed off through soak pit via septic tank and same shall be continued. There is no discharge of effluent onto land or inland water bodies as industrial effluent shall be sent to CETP . Well structured storm water drainage network within the site for preventing surface run - offs from mixing into sewers during monsoon. Periodic monitoring of storm water shall be carried out to ensure that it is not contaminated. All plant areas shall be paved. For unforeseen waste stream generation due to equipment breakdown or emergency control, following measures shall be taken,  Handling of ch emicals for all plant buildings shall be provided with proper drains which shall be connected to separate collection tank for storage of such unexpected effluents. This Siddhi Green Exc ellence Pvt. Ltd., Ankleshwar Page 37 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary effluent shall be analyzed in laboratory for giving suitable treatment in controlled ma nner in the ETP. Untreatable effluent shall be sent for incineration. Surface water quantity management 3rd stage wash water shall be recycled for 4th stage washing after passing through filter thereby reducing GIDC water requirement. Boiler blowdown and Cooling tower blowdown shall be reused for washing after passing through cartridge filter and then sent to ETP, thereby reducing GIDC water requirement. Following measures are suggested to further reduce water consumption : -  Drip irrigation for watering of green belt.  Dry sweeping of passages and building floors in place of washing with water.  Water saving faucets in toilets and washrooms.  Rainwater harvesting shall be explored Groundwater quantity and quality management Ground Water shall not be used; undertaking stating that no borewell shall be dug within the premises is annexed as Annexure – 8. Mitigation measures taken for impacts due to handling of hazardous chemicals and waste within the site as well as during tran sportation shall also prevent contamination of ground waters of villages near the site and roads to the site. Aquatic ecosystems (including marine ecosystem) There shall be sufficient holding capacity for storage of treated and untreated effluent. For performance monitoring of ETP, proponent is committed for following measures :  Maintain online magnetic flow meter on inlet and outlet of ETP  Monitor the performance of ETP by regular analysis by inhouse laboratory and third party analysis  To have separate electric meter & operational logbook for effluent treatment systems to monitor daily operations.  To take utmost care to prevent leakages from pipe fittings, valves etc., drains shall be provided at all plants to route such occasional effluents to ETP.  Spill control procedures to be practiced.  Maintain the adequacy and efficiency of all ETP components. Fuel consumption Presently Diesel and Natural Gas is available in ample and regular supply in this region. Diesel requirement for D.G set shal l be only during power failure from DGVCL, which is not frequent in this region. Cooking fuel is available in ample supply. Population change Migrated labour do not add to local population and do not interact with local population as they reside in labour camps of GIDC estate only. HR department shall counsel with labour whenever necessary. The employees migrating from outside shall be educated and counseled to become part of the prevailing society and respect the cultural aspects as well as follow and comp ly with administrative structure. The company’s HR department shall take care that harmony is established between such groups and resolve disputes and disposit ions if arise. Only consumer items such grocery, fruits, vegetables shall be taken from local market. Their share of such items shall be very nominal and not affect supply to locals. The area’s regional heritage, culture, social and economic wellbeing shall always be given priority by the company’s manageme nt.

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Executive Summary Odour Control Plan Proponent has already implemented satisfactory level of Odour control measures for existing production. The same shall be followed for new plant sections also.

Odour management plan for odorous solids  Solid materials are stored in closed warehouses and handled in closed system with dust collectors wherever required . The packaging areas shall be well - ventilated and exhausts shall be provided if n ecessary.

Odour management plan for odorous liquids  Closed pumping systems for charging from drums or tanks to daytanks or reactors. Vessel vents shall be connected to scrubbers during charging .  Drum handling is reduced by providing intermediate tanks.  Process scrubbers are provided with heat exchangers for increasing efficiency  Online sensors to be provided for Haz ardous Chemicals like Chlorine etc.  Periodic Internal & External work place monitoring for such chemicals  Solvent recovery more than 95%.  Pum ps and agitators for HC and odorous chemicals with mechanical seals  Regular inspection and Preventive maintenance of equipment including pumps, valves, pipes etc.  Green belt development & plantation of specific species for absorbent gas.  Solid wastes are covered with tarpaulin .  Warehouse for storing drums and bags are well - ventilated with roof top ventilators.  Effluent drains are covered with min. inspection cover s.

Occupational Safety and Hazard Management Preventive Measures provided  Flammable Storage Tanks: - Flame proof fittings, Earthing and Bonding, SOP for tanker unloading, Flame arrester provided on tank Top, Lightning arrester provided near to tank, wind flag, Tanks shall be provided with Level indicator with high level alarm  All electrical and instrumentation fixtures are Flame proof  Lightning arresters and wind socks are provided as per requirement.  Critical Production processes are carried out under stringent control and supervision with adequate instrumentation through temp. and pressure ind icators, controllers and recorders.  Alternate power supply available to substitute electrical power failure and provide cooling during critical stage processes.  Chlorine tonner shed – licensed area with chlorine kit, scrubber system, chlorine detectors  Gas detectors and regular work place monitoring  All pressure vessels are equipped with PSVs.  Welded pipes to be used wherever feasible  Suitable gasket material and gland packing to be in valves and flanges.  In - house Training programs as well as programs with help of outside agencies on Health hazards and safety for the workers and staff as per yearly plan.  Proper handling of all spillages by introducing spill control procedures for various chemicals.  Hazardo us Zone Classification done for entire site  Regular inspection and Preventive maintenance are carried out with reference to plant operations like pumps, valves, pipes etc as per maintenance program and defined checklist.  Do’s and don’ts for maintenance of critical equipment and machinery prepared and instructed to operators  Written safe operating procedures available for all operations and workers are given training on SOPs as per annual training calendar.  Work Permit system implemented for hot work in Pla nt / Storage area, Vessel Entry Permit, Working at Height, Opening of the Process lines.  Safety audit are conducted periodically  Safety Committee formulated for maintaining plant safety aspects.

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Executive Summary Control Measures Provided : -  Fire water line network coveri ng production and storage areas .  Portable Fire Extinguishers are installed as per requirement.  Safety shower and eye wash installed at critical locations  Storage tanks provided with dyke for containment.  Flame arrestor and breather valves for flammable material storage tanks  C hlorine storage shed provided with scrubber and hood  ECC equipped with Self Contained Breathing Apparatus (SCBA) and gas masks available for attending toxic leakages.  Well - equipped first aid centre  PPE’s selected as per MSDS  Onsite Emergency plan is in place.  Site has a dedicated and trained Fire fighting team and First Aider team .  Unit is member of DPMC for Emergency help and Mutual aid from surrounding industries Details of emergency control measures are given in chapter 7 of this report.

Control of Exposure levels of hazardous chemicals All measures taken for control of fugitiv e emissions detailed in chapter 2 shall also ensure that the permissible exposure levels are not exceeded. Detectors shall be placed at new plant a reas wherever applicable. Odor control plan as delineated above s hall also control exposure levels. Workplace monitoring s hall be carried out as given in Chapter 6. Handling of hazardous chemicals at various stages of operation will be carried out under su pervision of trained supervisor and adequate information to the operating personnel will be provided. Workers shall be properly educated, trained and communicated for handling hazardous chemicals and operating in hazardous areas through standard procedures , instructions in local languages, signboards, displays etc.

Following recommendations are given by EIA consultant, which are agreed upon by proponent for implementation to the best possible extent.  Check and review regularly all control measures for thei r effectiveness to minimize exposure of hazardous chemicals  Emphasis workers training and safety awareness through displayInform to minimize the risks Automation shall be used wherever possible and feasible  The route of movement shall be minimum distanced a nd without any other obstructions and interference from other activities.  It shall be ensured that workers wear proper PPE’s without fail through stringent supervision by shift incharge.  Good housekeeping should be practiced at all times. No chemicals sho uld be stored outside.  Planned schedule for inspections of safety devices shall be followed and records shall be maintained.  Ensure that the transporters of hazardous chemicals are provided with PPE and carry TREM Cards during transportation  Process equipment designed and fabricated as per standards for safe and efficient working  All aspects of Industrial hygiene and Occupational health shall be considered at the time of detail engineering of the project - noise minimization, - proper illuminatio n at all floors, - minimum exposure to fugitive emission while charging, - proper plant layout and equipment design to provide correct working postures and body postures, - suitable platforms and ladders to minimize accidents due to movements

Medical Facilit ies First - aid Facilities First aid box es are provided in admin office and production plant having all the necessary items , it is m aintained by production in charge. They are inspected on regular intervals. First aid box shall be provided in new plant building . First Aid Centre is provided in admin building having necessary equipment and arrangements for first - aid treatments : - First – Aid box, bed, observation cum treatment table, medicine Cupboard with antidotes, dressing & dispensing

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Executive Summary arrangement, washb asin, air conditioner, computer – printer, ophthalmic charts, eye washer, Stethoscope, Thermometer, Weight Machine. Center is connected with intercom facility. The contact number of all nearby hospitals and medical facilities are maintained in the First Aid Center. Selected employees from each department are trained for first - aid course to be available in all shifts. All first aiders are given refresher training atleast once in a year. List of trained first aiders shall be kept in onsite emergency plan . Antidotes for major chemicals are identified and list is attached as Annexure - 20.

Visiting CIH doctor is appointed as Factory Medical Officer (FMO), who visits once in a month to attend routine work related / non related complaints . FMO is responsible for carrying out the periodical medical examination.

External aid for firefighting and medical emergency Following hospitals are contacted for medical treatment, the hospitals are having specialist panel of doctors and modern medical equipment and facilities :  Shrimati Jayaben Modi General Hospital, GIDC Ankleshwar  ESIC hospital, GIDC Ankleshwar  Civil Hospital, Bharuch Unit has own transport vehicle for emergency transport . Ambulance facilities are available from 108, Shrimati Jayaben Modi General Hospital , DPMC as well as vehicals from nearby units (Chemet Chemicals)

Medical examination practice Yearly medical checkup of all employees is carried out by FMO. Health Register in Form No. 32 (prescribed under Rule 68 T and 102) is maintained. Certificate of f itness is issued to workers by factory medical officer in Form No. 33.

Other systems and procedures to be adopted for occupational safety and health are:  Conduct In - house Training programs as well as other programs with help of outside agencies on Health hazards and safety for the workers and staff. Trainings shall cover topics on fire fighting, toxic release control, awareness training for hazards, first aid, onsite emergency plan, etc.  Proper handling of all spillages by introducing spill control proc edures for various chemicals.  Work permit system for specific task.  PPE as per operations shall be provided and it shall be ensured that workers make proper use of PPEs .

Greenbelt Enhancement plan As per CPCB guidelines, 33% of plot area i.e ~1643.32 sq. m. of area should be developed as greenbelt by the proponent. Unit is developed peripheral g reenbelt within plot premises covering 501 sq.m. (~10 % of plot area). Greenbelt development areas are marked on site plan attached as Annexure – 16. Balance area of greenbelt shall be developed on GIDC specified land. For this, proponent has submitted request to GIDC to allot land (Copy annexed as Annexure – 14) and is committed to develop and maintain greenbelt area under its responsibility.

EIA Consultant has s uggested greenbelt species for plantation based on the following:  CPCB guidelines for green belt development  SEAC guidelines for suitable green belt species for South Gujarat  Native species observed in the terrestrial survey of baseline study for the project  Species which suit the soil and water properties of the area

A greenbelt plantation programme within five years from construction phase is proposed and proponent has allocated Rs. 87,000 for new plantation and Rs. 87,000 for annual budget for gree nbelt maintenance. Tree density of 1500 trees per ha shall be achieved in five years duration .

Detailed plan including species suitable for plantation, schedule of plantation, type of plantation as suggested by EIA consultant and budget is given in chapt er 10 of this report.

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Executive Summary Roadside Plantation Proponent shall plant new trees on GIDC roads in consultation with GIDC, species planted shall be dust absorbers, SO 2 and NOx absorber species.

Rain Water Harvesting Estimated total roof top area available for rain water harvesting is 592 m 2 . Estimated rooftop rain water harvesting potential is ~213 KL/year considering 731.20 mm annual average rainfall and 50% attainment. Proponent has intended to plan for rainwater harvesting system after ascertaining its fe asibility through detailed studies .

Risk Assessment & DMP for the project The unit is handling flammable and toxic chemicals for existing as well as proposed expansion. Probable hazards to be present in the unit due to proposed activities are identified and their mitigation measures and control measures have been proposed. Firefighting arrangements and toxic release control are available as per requirement of MSDS which shall be augmented as per requirement for expansion. Consequence analysis is carried out for major storage inventories and their threat zones are mapped on site plan and study area map to review the impact distances and suitable actions to be taken to minimize risk are also delineated. Details are provided in chapter 7 of this report.

Pro ponent has develop ed onsite emergency plan (DMP) in compliance with the requirements of Factories Act, 1948, Gujarat Factories Rules, 1963 and The Manufacture, Storage and Import of Hazardous Chemical (Amendme nt) Rules, 2000. T he DMP includes emergency pre paredness plan, emergency response team, emergency communication, emergency responsibilities, emergency facilities, and emergency actions. Additions shall be required in the onsite plan for the proposed expansion for which the proponent is committed. Reco mmendations are given in chapter 7 of this report.

Post Project Monitoring Plan Inhouse Laboratory monitoring Component Present monitoring plan After Proposed Applicable compliance expansion standard Raw, intermittent and Presently treated effluent analysis To be analyzed for For treated effluent as per treated effluent from carried out randomly, industrial major parameters ( pH, inlet norms for CETP of ETL, ETP effluent is sent to CETP. COD, TDS, Chlorides, Ankleshwar as stipulated in sulphates, Ammonical Consent to Operate (CTO) of nitrogen) – daily once – unit. Inhouse Scrubber solutions of Scrubbing solution analyzed for To be analyzed fo r pH -- Process emission pH and concentration – randomly and concentration – control systems daily – once Hazardous and non - Records of generation, storage To be continued. Conditions stipulated in hazardous waste and disposal in manifests Consent to Operate (CTO) management prescribed by H/W authorization. granted by GPCB Hazardous waste records are updated monthly by EMS cell in monthly patrak and form 4. Environmental Submitted to GPCB at the end of To be continued. Conditions stipulated in Statement each financial year. Consent to Operate (CTO) granted by GPCB

Online monitoring systems Applicable compliance Component Present monitoring plan After Proposed expansion standard Fresh Water Water meter reading is To be continued. Permissible limits stipulated Consumption (GIDC recorded and submitted to in Consent to Operate (CTO) supply) GPCB with water cess. granted by GPCB Treated Effluent Presently not provided, Flow meter to be provided at Permissible limits stipulated quantity generated industrial effluent is sent to inlet and outlet of ETP in Consent to Operate (CTO) Siddhi G reen Excellence Pvt. Ltd., Ankleshwar Page 42 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Applicable compliance Component Present monitoring plan After Proposed expansion standard CETP granted by GPCB

Third party monitoring by NABL accredited Laboratory or MoEF&CC recognized Environmental Laboratory Applicable compliance Component Present monitoring plan After Proposed expansion standard Drinking water Presently not carried out To be analyzed for major IS 10500 : 2012 quality parameters given in IS 10500 : 2012 – once in a year – records to be maintained Treated effluent from - Analyzed for all the To be continued For treated effluent as per ETP parameters as per the CTO inlet norms for CETP of ETL, granted by GPCB - quarterly Ankleshwar as stipulated in by GPCB recognized Consent to Operate (CTO) of Schedule - II Environmental unit. Auditor - tanker sent to ETL, analyzed for pH and COD Ambient Air Quality Carried out quarterly by GPCB To be continued with Permissible limits stipulated Monitori ng recognized Schedule - II addition of HCl parameter in Consent to Operate (CTO) Environmental Auditor granted by GPCB at - Nr. Main gate - Nr. ETP area

Parameters analyzed: - PM 10 , PM 2.5 , SO 2 , NO x Manual Flue gas Monitoring of all flue gas To be continued with Permissible limits stipulated Stack monitoring stacks – quarterly by GPCB addition of new stacks in Consent to Operate (CTO) recognized Schedule - II granted by GPCB Environmental Auditor Process emission Monitoring of all process gas To be continued with Permissible limits stipulated stack monitoring stacks – quarterly by GPCB addition of new stacks in Consent to Operate (CTO) recognized Schedule - II granted by GPCB Environmental Auditor Noise level Carried out by GPCB To be continued with Permissible limits for measurement recognized Schedule - II addition of new locations Industrial area as per Noise Environmental Auditor – Rules, 2000 quarterly at  Near main gate  Near ETP Plant Near Boiler house Work place Presently carried out randomly To carry out work place Applicable OSHA / NIOSH monitoring monitoring for VOC at standards storage areas and plant floors having VOC chemicals. For dust sixmonthly at - Solid chemicals charging areas - Solid chemicals warehouse - Solid product packaging Monitoring under Leaks are attended urgently by portable VOC detecting Applicable EPA standards Siddhi G reen Excellence Pvt. Ltd., Ankleshwar Page 43 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Executive Summary Applicable compliance Component Present monitoring plan After Proposed expansion standard Leak Detection And instrument (EPA 21 method) Repair Program and dragger tubes – Once in (LDAR) a year Soil from within Presently not carried out To be analyzed for pH, To be compared with premises – unaltered Conductivity, Cation baseline quality of soil and undisturbed exchange capacity, Sodium established during EIA study area absorption ratio, permeability, Water holding capacity, Chloride, Sulphates, NPK, - one sample from within the premises - Once in a year Illumination during Presently not carried out To carry out Single point Lux IS.6665.1972 - Industrial day time and night measurement at all lighting time productio n units and floors of plant buildings, utilities and warehouses, access roads, major workplaces - Once in a year Environment Audit Yearly by GPCB recognized To be continued Schedule - II Environmental Auditor Occupational Health As per applicable rule under To be con tinued Gujarat Factories Rule - 68 J & safety Audit as per Factories Act, 1948 and (9) and IS: 14489 - 1998, Gujarat Factories Gujarat Factories Rules 1963 Manufacture, Storage and Rules - 68 J (9) and and Manufacture, Storage and Import of Hazardous IS:14489 - 1998 Import of Hazardous Chemicals Rules, 1989 Chemicals Rules, 1989 Apart from this, it is suggested by EIA consultant –  This plan should be considered as tentative for final planning of Environment Monitoring programme. All directions given by SPCB, CPCB and MoEF&CC shall be followed religiously and included appropriately in the programme.  To have periodic inspection and preventive maintenance schedule for important pollution control equipment : ETP units, APCM units, Storm water drains, ETP drains around plant and storage and warehouse areas.

Environment Budget Allocation Proponent has committed to allot Rs. 1.50 crore s towards investment in Environmental Management System (EMS) cons tituting augmentation of wastewater treatment facilties , Air pollution control measures, Solid / hazardous waste management and disposal faci lities, green belt development. A draft sheet for individual allotments for air, water and solid waste management is given in chapter 10.

Corporate Environment Responsibility (CER) As per OM no. 22 - 65/2017 dated 01/05/2018 regarding “Corporate Environment Responsibility” (CER), Brownfie ld projects having investment Rs. <100 crore have to contribute 1% of additional c apital investment. Accordingly propo nent has committed to allocate Rs. 9 lakh for CER activities to be conducted after the project is operational . Details are given in Chapter 10 of this report.

Conclusion It is thus concluded that the proposed expansion of M/s. Avdhoot Chemicals Pvt. Ltd. for manufacturing synthetic organic chemicals at their existing unit at Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, S tate - Gujarat. India is feasible considering appropriate mitigation of adverse environmental impacts as delineated in this report and shall be beneficial for the socio - economic growth of the local community as well as for the country as a whole.

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Terms of Reference and their Compliances TERMS OF REFERENCES (TORS) AND THEIR COMPLIANCES

The following Terms of reference were prescribed by SEIAA for EIA study to be done covering 10 km radial distance from the project boundary.

Compliance to additional TORs at Sr. No. VII. of TOR letter Sr. Additional TOR Compliance No. 1. Details with respect to justification for proposed expansion: (1) To address Section 2.2 4 .1 of proportionate availability of space for production plant. (2) To address proportionate Chapter 2 availability of storage area for raw materials finished goods, utilities and goods carrier movement within premises. (3) To address proportionate captive/common infrastructure availab le to accommodate additional load due to proposed expansion. (4) Environment impact and its mitigation measures for common/ captive infrastructure due to proposed production. 2. Compliance of MoEFCC's OM dated 01/05/2018 regarding “Corporate Environment Section 10.12.1 of Responsibility” (CER). Fund allocation for Corporate Environment Responsibility Chapter 10 (CER) shall be made as per MoEFCC's O.M. No. 22 - 65/2017 - IA.III dated 01/05/2018 for various activities therein. The details of fund allocation and activities for CER shall be incorporated in EIA/EMP report. 3. Explore the use of renewable energy to the maximum extent possible. Details of Section 10.15 .1 of provisions to make the project energy - efficient through of energy efficient dev ices and Chapter 10 adoption of modes of alternative eco - friendly sources of energy like solar water heater, solar lighting etc. Measures proposed for energy conservation. 4. Qualitative and quantitative analysis of hazardous waste streams generation from the Section 2.1 9 .1 of manufacturing process (Product wise). Explore the possibility to reuse such waste Chapter 2 streams within premises as raw materials for other products or to convert it into valuable products instead of selling out side. Sound management of such waste streams as per the HW Rules 2016 as amended time to time. Feasibility report for utilization shall be incorporated in EIA report. 5. Furnish status of all the applicable rules, acts, regulation, clearances in a tabular form. Section 1.9 of Chapter 1 6. Address appropriate mode of disposal in hazardous waste matrix specifically for spent Section 2.19.1 of Hcl, sodium hypochlorite and spent Alcl3 with technical justification. Chapter 2 7. Leak Detection and Repa iring Programme (LDAR) for all the volatile organic solvent Section 6.1.1 of proposed for use in - house with detailed chemical properties including vapor pressure. Chapter 6 LDAR shall endeavor prevention of losses of solvents to the best minimum extent. 8. Safety precautions to avoid hazard during unloading, storage, transportation handling Section 10.7.3 of and processing of Cl 2 as per PESO standards. Chapter 10 9. Segregation of waste water streams based on characteristics and its proper Section 2.16.1.1 of management keeping in view direction under section 18 (1) (b) of the Water Chapter 2 (Prevention and Control of Pollution) act, 1974 issued by CPCB regarding compliance of CETP. 10. Unit shall produce MoU for final disposal of above mentioned so lutions which are Annexure - 27 going to be generated as Hazardous Waste as per HWR - 2016, (1) Spent H C l, (2) Spent sodium hypochlorite and (3) spent aluminium chloride at the time of appraisal of Environmental Clearance.

Standard TORs approved by SEIAA : - Sr. Terms of Reference Compliance No. 1 . A tabular chart with index for point - wise compliance of below mentioned TORs. -- 2 . Executive summary of the project – giving a prima facie idea of the objectives of the Executive summary included in the proposal, use of resources, justification, etc. In addition, it should provide a report after acknowledgment. compilation of EIA report, including EMP and the post - project monitoring plan in

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Terms of Reference and their Compliances Sr. Terms of Reference Compliance No. brief. 3 . Justification for selecting the proposed product and unit size. Chapter 5 4 . Land requirement for the project including its break up for various purposes, its Section 2.24 of Chapter 2 availability and optimization. 5 . Land possession documents. Copy of NA order showing permission to use the Land possession documents are project land for Industrial purpose. If located in GIDC, copy of plot holding certificate annexed as Annexure – 7. obtained from GIDC Authority. 6 . Location o f the project site and nearest habitats with distances from the project site Toposheet is annexed as Annexure - 17 to be demarcated on a toposheet (1: 50000 scale). 7 . Topography details of the project area. Section 3.7 of Chapter 3 8 . Geological features and Geo - hydrological status of the study area. Section 3.8.1 & 3.11 of Chapter 3 9 . In case of project located outside notified area : Legal Undertaking stating that unit is Not Applicable as project is located complying the three conditions [i.e. water consumption less than 25 M 3 /day; Fuel within Notified GIDC Industrial Estate of con sumption less than 25 TPD; and not covered in the category of MAH units as per Ankleshwar the Management, Storage, Import of Hazardous Chemical Rules (MSIHC Rules), 1989] as per the amendment to EIA Notification, 2006 vide SO 1599 (E) dated 25/06/2014. 10 . Present land use pattern of the study area shall be given based on satellite imagery. Section 3.7 of Chapter 3

11 . Layout plan of the factory premises clearly demarcating various units within the Layout plan of the fact ory premises is plant. Provision of separate entry & exit and adequate margin all round the annexed as Annexure – 16 periphery for unobstructed easy movement of the emergency vehicle / fire tenders without reversing back. Mark the same in the plant layout. 12 . Technical details of the plant/s along with details on best available technologies Section 2.10 of Chapter 2 (BAT), proposed technology and reasons for selecting the same. Section 5.1.3 of Chapter 5 on alternate a nalysis 13 . Product spectrum (Proposed products along with production c apacity) and Section 2.8.1 of Chapter 2 processes. Manufacturing processes are annexed as Annexure - 25 14 . Chemical name of each proposed product to be manufactured. Details on end use Product List & Details of end use of each of each product. (Provide CAS number of all the products & raw materials. In case product are given in Section 2.8.1 & of Dyes, CI number). 2.8.2 of Chapter 2. Raw material list is annexed as Annexure - 24 15 . Details o n raw materials, source and storage within the premises. Section 2.9 of Chapter 2 Raw material list is annexed as Annexure - 24 16 . Details of complete manufacturing process / operations of each product along with Manufacturing processes are annexed chemical reactions, process flow diagram describing each unit processes and unit as Annexure - 25 operations along with material balance, consumption of raw materials etc. 17 . Details on strategy for the implementation of cleaner production activities. Section 10.11 of Chapter 10 18 . Assessment of source of the water supply with adequacy of the same to meet with Section 2.13 of Chapter 2 the requirements for the project. Permission obtained from the concern authority for GIDC water supply lett er is annexed as supply of raw water. Annexure – 11. 19 . Undertaking stating that no bore well shall be dug within the premises (If project is Annexure - 8 located within the Industrial estate). 20 . Details on water balance including quantity of effluent generated, recycled & reused. Section 2.13 & 2.16 of Chapter 2 Details of methods to be adopted for the water conservation. 21 . Efforts to minimize effluent discharge and to maintain quality of receiving water Section 2.16 of Chapter 2 body. 22 . Explore the possibilities for Zero Liquid Discharge (ZLD) option for the proposed Section 2.16 of Chapter 2 project. 23 . Segregation of waste streams, characterization and quality with specific treatment Section 2.16.1 of Chapter 2 and disposal of each stream including action plan for maximum recycle of treated waste water and minimum discharge for effluent. 24 . Capacity of ETP in KL/day. Details of ETP including dimensions of each unit along Section 2.16.1 & 2.16.2 of Chapter 2 with schematic flow diagram. Inlet, transitional and treated effluent qualities with Siddhi G reen Excellence Pvt. Ltd., Ankleshwar Page 46 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Terms of Reference and their Compliances Sr. Terms of Reference Compliance No. specific efficien cy of each treatment unit in reduction in respect of all concerned/regulated environmental parameters. Inlet effluent quality should be based on worst case scenario considering production of most polluting products that can be manufactured in the plant con currently. 25 . In case of discharge into GIDC drainage / Pipeline : Not applicable. I. Copy of permission letter with quantity (KL/day) from the concern authority of I ndustrial effluent shall be treated in own drainage network / pipeline with confirmation for spare capacity availab le to take ETP (Capacity: 180 KLD), treated additional effluent. effluent shall be sent to CETP of M/s. II. Characteristics of the combined effluent and treated water to be sent to Common Enviro Technology Limited (ETL), pipeline with reference to the MoEFCC/CPCB/GPCB discharge norms. Ankleshwar through tankers. III. Provision of Continuous Monitoring System for waste water discharge. 26 . In case of waste water sent to Common Facilities (CF) like CETP, MEE, Spray Dryer Unit has received permission letter from etc. M/s. ETL, Ankleshwar for the additional a . Details of Common facilities including (1) Total capacity of the CF (2) Copy of effluent quantity for proposed expansion CC&A of the CF. (3) Actual load at present (Qualitative and Quantitative – KL and is annexed as Annexure - 27 . per day) (4) Booked quantity & Spare capacity of CF (5) Co pies of XGN generated Inspection reports with analysis reports of the water/ Air/ Hazardous samples collected by GPCB (Last 2 year). Copies of instructions issued by GPCB in last 2 year and point wise compliance thereof. (6) Copies of Show - cause notices, closure notices etc. served by the GPCB and its compliance (7) Recommendations and suggestions of the last two Environment Audit reports of CETP and its compliance report. (8) Common Facility Up gradation scheme, if any. b . Status of compliance to the 18(1) ( b) direction issued by the CPCB with respect to CETP compliance & CEPI area action plan along with relevant supportive document. c . Give status of compliance of Environmental norms of existing Common Infrastructure i.e. CETP, MEE & Spray Dryer (whichever is applicable) in which you are a member. d . Submit adequacy of Common Infrastructure i.e. CETP, MEE & Spray Dryer for additional load (whichever is applicable) along with written confirmation/membership certificate mentioning the same (Total consented quantity, total quantity booked so far, quantity booked for the unit, spare quantity available). 27 . In case of Zero Liquid Discharge (ZLD) : Not applicable. I . Action plan for ‘Zero’ discharge of effluent shall be included. Notarized I ndustrial effluent shall be treated in own undertaking for assuring that underground drainage connection will not be ETP (Capacity: 180 KLD), treated taken in the unit and there shall be no effluent discharge outside the plant effluent shall be sent to CETP of M/s. premises. Enviro Technology Limited (ETL), II . Economical and technical viability of the effluent treatment system to achieve Ankleshwar through tankers. Zero Liquid Discharge (ZLD). III . Certification of adequacy of proposed ZLD scheme through credible institutes of National Repute. IV . To estimate & monitor ground water quality & its contamination status, piezometer wells, one on up gradient of the groundwater flow and other three on the down gradient side of the ground water flow of the proposed project at different depth based on available ground water depth shall be established and all the parameters mentioned in IS 10:500 for potable water standard shall be monit ored. 28 . In case of in - house MEE/Spray dryer for waste water tre atment : Capacity of MEE in Not applicable. KL/hr. Technical details of MEE including evaporation capacity, steam required for I ndustrial effluent shall be treated in own evaporation, adequacy of the proposed boiler to supply steam for evaporation in ETP (Capacity: 180 KLD), treated addition to the steam required for the process etc. Techno - economi cal viability of effluent shall be sent to CETP of M/s. the evaporation system. Control measures proposed for the evaporation system in Enviro Technology Limited (ETL), order to avoid/reduce gaseous emission/VOC from evaporation of industrial effluent Ankleshwar through tankers. containing solvents & other chemicals. 29 . Technical details of ATFD/Crystallizer/Spray Dryer, RO/NF system etc. (If any). Not applicable. I ndustrial effluent shall be treated in own ETP (Capacity: 180 KLD), treated Siddhi G reen Excellence Pvt. Ltd., Ankleshwar Page 47 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Terms of Reference and their Compliances Sr. Terms of Reference Compliance No. effluent shall be sent to CETP of M/s. Enviro Technology Limited (ETL), Ankleshwar through tankers. 30 . Details of the treatability and feasibility of wastewater to be disposed off by means Not applicable. of spray dryer and its impact on environment and Human Health. I ndustrial effluent shall be treated in own ETP (Capacity: 180 KLD), treated effluent shall be sent to CETP of M/s. Enviro Technology Limited (ETL), Ankleshwar through tankers. 31 . Undertaking stating that a separate electric meter will be provided for the waste Annexure - 8 water treatment system viz. ETP, RO, MEE, Spray dryer etc. (Whichever is applicable) 32 . Economical and technical viabilit y of the effluent treatment system. Section 2.16.4 of Chapter 2 33 . Plans for management, collection and disposal of waste streams to be generated Section 10.3 & 10.4 of Chapter 10 from spillage, leakages, vessel washing, used container washing etc. Measures proposed for preventing effluent discharge during unforeseen circumstances. 34 . Action plan for reuse of waste streams like Spent acids, Poly Aluminum Chloride There shall be few waste streams which etc. within premises to convert into valuable products instead of sending outside to shall be directly reused within premises. actual end - users. Details are given in Section 2.19 of Chapter 2 35 . Adequacy of the proposed EMS with respect to the pollution load envisaged in EMS adequacy certificate is annexed as terms of Air, Water and hazardous wa ste. Annexure – 22. 36 . One season Site - specific micro - meteorological data using temperature, relative Section 3.9 of Chapter 3 humidity, hourly wind speed and direction and rainfall should be incorporated. 37 . Anticipated environmental impacts due to the proposed project/production may be Section 4.3, 4.4, 4.5 & 4.11 of Chapter 4 evaluated for significance and based on corresponding likely impacts VECs (Valued Environmental Components) may be identified. Baseline studies may be conducted within the stud y area for all the concerned/identified VECs and likely impacts will have to be assessed for their magnitude in order to identify mitigation measures. 38 . One complete season base line ambient air quality data (except monsoon season) Section 3.10 of Chapter 3 to be given along with the dates of monitoring. The parameters to be covered shall be in accordance with the revised National Ambient Air Quality Standards (NAAQS) as well as project specific parameters like NH3, HCl, CL2, HBr, VOC etc. Locations of the monitoring stations should be so decided so as to take into consideration the pre - dominant downwind direction, population zone and sensitive receptors. There should be at least one monitoring station in the upwind direction. There sh ould be at least one monitoring station in the pre dominant downwind direction at a location where maximum ground level concentration is likely to occur. 39 . Modeling indicating the likely impact on ambient air quality due to propos ed Section 4.6 of Chapter 4 activities. The details of model used and input parameters used for modeling should be provided. The air quality contours may be shown on location map clearly indicating the location of sensitive receptors, if any, and the habitation. The wind rose show ing pre - dominant wind direction should also be indicated on the map. Impact due to vehicular movement shall also be included into the prediction using suitable model. Results of Air dispersion modeling should be superimposed on satellite Image/ geographica l area map. 40 . Base line status of the noise environment, impact of noise on present environment Base line status of the noise due to the project and proposed measures for noise reduction including engineering environment is given at section 3.12 of controls. Chapter 3. Noise impact prediction in section 4.7, 4.8 & 4.9 of Chapter 4 41 . Specific details of a) Process gas emission from each unit process with its quantification. a) & b) - Section 2.17.2 & 2.17.3 of b) Air pollution Control Measures (APCM) proposed for proce ss gas emission. Chapter 2 Adequacy of the air pollution control measures (APCM) for process gas emission measures to achieve the GPCB norms. c) Details of the utilities required. c) Section 2.12 of Chapter 2 d) Type and quantity (MT/hr & MT/Day) of fuel to be used for each utility. d) Section 2.15 of Chapter 2

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Terms of Reference and their Compliances Sr. Terms of Reference Compliance No. e) Flue ga s emission rate emission from each utility. e) & f) Section 2.17.1 of Chapter - 2 f) Air Pollution Control Measures (APCM) proposed to each of the utility along with its adequacy g) List the project specific sources of fugitive emission along with its quantification g) Section 2.18 of Chapter - 2 and proposed measures to control it. h) Details on tail gas treatment.(If any) h) Not applicable 42 . Provision of CEMS (Continuous Emission Monitoring System) Section 6 . 1 of Chapter 6 43 . Action plan for odour control to be submitted. Section 10.5.1 of Chapter 10 44 . Management plan for solid/hazardous waste including storage, handling, utilization Section 2.19 of Chapter 2 and safe d isposal as per the Hazardous and Other Wastes (Management and Transboundary Movement) Rules 2016. CPCB guidelines in respect of specific treatment, such as solar evaporation, incineration, etc., need to be followed. 45 . How the manual handling of the hazardous wastes will be minimized? Methodology Section 2.19.3 of Chapter 2 of de - contamination and disposal of discarded containers and its record keeping. 46 . Management of by - products which fall under the purview of the Hazardous an d Section 2.8.3 of Chapter 2 Other Wastes (Management and Transboundary Movement) Rules 2016 as per the said rules and necessary permissions from the concerned authority. 47 . Membership of Common Environmental Infrastructure like TSDF, Common Annexure - 27 Incineration Fa cility (CHWIF), MEE, Spray dryer etc. 48 . Name and quantity of each type of solvents to be used for proposed production. Section 2.21 of Chapter 2 Details of in - house solvent recovery system including mass balance, solvent loss, recovery efficiency (% recovery), feasibility of reusing the recovered solvents etc. for each type of solvent. 49 . Appropriate monitoring network has to be designed and proposed, to assess the Impact aspect analysis given in Chapte r possible residual impacts on VECs. 2 at Section 2.27.1 Monitoring network is detailed in Chapter 3 50 . A detailed EMP including the protection and mitigation measures for impact on Chapter 10 human health and environment as well as detailed monitoring plan and environmental management cell proposed fo r implementation and monitoring of EMP. The EMP should also include the concept of waste minimization, recycle/reuse/recover techniques, energy conservation, and natural resource conservation. Total capital cost and recurring cost/annum earmarked for envir onment pollution control measures. 51 . Details of in - house monitoring capabilities and the recognized agencies if proposed Section 6.1 of Chapter 6 for conducting monitoring. 52 . Permission from PESO, Nagpur for storage of solvents, other toxic chemicals, if Annexure - 23 any. 53 . Occupational health impacts on the workers and mitigation measures proposed to Section 10.7 of Chapter 10 avoid the human health hazards along with the personal protective equipment to be provided. Provision of industrial hygienist and monitoring of the occupational injury Work place monitoring plan is given in to workers as well as impact on the workers. Plan for periodic medical checkup of Section 6.1 of Chapter 6 the workers exposed. Details of work place ambient air quality monitoring plan as per Gujarat Factories Rules. 54 . Details on volatile organic compounds (VOCs) from the plant operations and Section 4.6.8 of Chapter 4 occupational safety and health protection measures. Proposal for Leak Detection and Repair (LDAR) program as per the CPCB guid elines. Proposal for Leak Detection and Repair (LDAR) program is given at Section 6.1.1 of Chapter 6 55 . Risk assessment including prediction of the worst - case scenario and maximum Chapter 7 credible accident scenarios should be carried out. The worst - case scenario should take into account the maximum inventory of storage at site at any point of time. The Consequences Analysis results for Risk risk contours should be plotted on the plant layout map clearly showing which of the Assessment is annexed as Annexure - facilities would be affected in case of an accid ent taking place. Based on the same, 12 proposed safeguard measures including On - Site / Off - Site Emergency Plan should be provided. 56 . MSDS of all the products and raw materials. Annexure - 32

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Terms of Reference and their Compliances Sr. Terms of Reference Compliance No. 57 . Details of hazardous characteristics and toxicity of raw materials and products to be Details of hazardous characteristics and handled and the control measures proposed to ensure safety and avoid the human toxicity of raw materials and products to health impacts. This shall include the details of Antidotes also. be handled is annexed as Annexure - 26 Control measures proposed to ensure safety & avoid the human health impacts are given in Section 10.7 of Chapter 10 List of Anti dotes is annexed as Annexure - 20 58 . Details of quantity of each hazardous chemical (including solvents) to be stored, Section 2.9 .2 of Chapter 2 Material of Construction (MoC) of major hazardous chemical storage tanks, dyke Section 7.6 & 7.9 of Chapter 7 details, threshold storage quantity as per schedules of the Manufacture, Storage & Import of Hazardous Chemicals Rules of major hazardous chemicals, size of the biggest storage tank to be provided for each raw material & product etc. How the manual handling of the hazardous chemicals will be minimized? 59 . Details of the separate isolated storage area for flammable chemicals. Details of Section 7.6 & 7.9 of Chapter 7 flame proof electrical fittings, DCP extinguishers and other safety measures proposed. Detailed fire control plan for flammab le substances and processes showing hydrant pipeline network, provision of DG Sets, fire pumps, jockey pump, toxic gas detectors etc. 60 . Submit checklist in the form of Do’s & Don’ts of preventive maintenance, Annexure - 18 strengthening of HSE, Manufacturing utility staff for safety related measures. 61 . Specify safety precautions to be taken for chemical storage, process, handling & Section 10.7.2 & 10.7.3 of Chapter 10 transportation hazard. 62 . Details on workers training before engaging work, periodical, in - house, outside etc. Section 10. 7.4 of Chapter 10 63 . Details on various SOP to be prepared. Section 10.7.5 of Chapter 10 64 . Details on safety audit to be carried out and their compliance status . Safety audits under Factories Act, 1948 is carried out by the unit and same shall be followed after proposed expansion also. 65 . Specific safety measures to be taken for general Public living in the vicinity. Section 10.3 & 10.4 of Chapter 10 66 . Details on hazard identification i.e. HAZOP, HAZAN, Fault tree analysis, Event tree Section 7.5 to 7.8 of Chapter - 7 analysis, Checklist, Audit, etc. to be adopted for the safety operation of the plant. 67 . Detection and monitoring of VOCs / gases. Chapter 6 68 . Detailed five year greenbelt development program including annual budget, Section 10.8 of Chapter 10 planning schedule, species, width of plantations, number of trees to be planted, area under green belt development [with map], budgetary outlay etc. along with commitment of the management t o carry out the tree plantation activities outside the premises at appropriate places in the nearby areas and elsewhere. 69 . Action plan for the greenbelt development – species, width of plantations, planning Section 10.8 of Chapter 10 schedule, etc., in acc ordance to CPCB published guidelines. 70 . Detailed socio - economic development measures including community welfare Section 10.12 of Chapter 10 program most useful in the project area for the overall improvement of the environment. Submit a detailed plan for s ocial corporate responsibilities, with appropriate budgetary provisions for the next five years and activities proposed to be carried out; specific to the current demographic status of the area. 71 . (a) Does the company have a well laid down Environment Policy approved by its 1 . Yes, the policy is annexed as Board of Directors? If so, it may be detailed in the EIA report. Annexure – 15. (b)Does the Environment Policy prescribe for standard operating process / 2 . Section 10.2.1 of Chapter 10 procedures to bring into focus any infringement / deviation / viol ation of the environmental or forest norms / conditions? If so, it may be detailed in the EIA. 72 . What is the hierarchical system or administrative order of the company to deal with Chapter 10, Figure – 10 - 1 t he environmental issues and for ensuring compliance with the EC conditions. Details of this system may be given. 73 . Does the company have a system of reporting of non compliances / violations of Section 1.6.1 of Chapter 1 environmental norms to the Board of Directors of the company and / or shareholders or stakeholders at large? This reporting mechanism should be detailed in the EIA Report.

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Terms of Reference and their Compliances Sr. Terms of Reference Compliance No. 74 . Phase wise project implementation schedule with bar chart and time frame, in terms Section 2.3 of Chapter 2 of site development, infrastructure provision, EMS implementation etc. 75 . Certificate of accreditation issued by the NABET, QCI to the environmental Annexure - 1A consultant should be incorporated in the EIA Report. 76 . An undertaking by the Project Proponent on the ownership of the EIA report as per Attached on Page No. 3 & 4 of EIA the MoEF&CC OM dated 05/10/2011 and an undertaking by the Consultant report. regarding the prescribed TORs have been complied with and the data submitted is factually correct as per the MoEF&CC OM dated 0 4/08/2009. 77 . All documents to be properly referenced with index and continuous page numbering. Complied 78 . Where data are presented in the Report especially in Tables, the period in which the Source is mentioned in this report as data were collected and sources should be indicated. applicability 79 . Project Proponent shall enclose all the analysis/testing reports of water. Air, soil, EMS adequacy certificate at Annexure - noise, etc. using the MoEF&CC/NABL accredited laboratories. All the original 22 analysis/testing reports should be available during appraisal of the Project. 80 . In case of Expansion of the project a . Need for the proposed expansion should be justified in detail. (a) Section 1.3 of Chapter – 1 b . Adequacy of existing EMS (Environmental Management System). (b) Annexure - 22 c . Explore the possibility to achieve Zero Liquid discharge (ZLD) for existing as (c) Section 2.16 of Chapter - 2 well as proposed activity. d . Records of any legal breach of Environmental laws i.e. details of show - cause (d) Annexure - 30 notices, closure notices etc. served by the GPCB to the existing unit in last five years and actions taken then after for prevention of pollution. e . Copies of Environmental Clearances obtained for the existing plant, its point (e) Section 1.6.3 of Chapter - 1 & wise compliance report. Annexure - 22 f . Environmental audit reports for last 3 ye ars and compliance of its (f) Section 10.11.1 of Chapter - 10 recommendations/Suggestions. (Include latest audit report and its compliance.) g . Copy of Consent to Operate (CC&A) obtained along with point wise compliance status of all the conditions stipulated therein. (g) Annexure - 28 h . Compliance of MoEF&CC ci rculars vide No: J - 11011/618/2010 - IAII (I) dated 30/05/2012 and J - 11013/41/2006 - IA - II(I) dated 20/10/2009. (h) Please refer (c) and (d) i . Copies of XGN generated Inspection reports with analysis reports of the water/ Air/ Hazardous samples collected by GPCB (Last 2 year). Copies of (i) Annexure - 29 & 30 ins tructions issued by GPCB in last 2 year and point wise compliance thereof. 81 . In case of project is located in Ankleshwar - Panoli, Vatva - Narol & Vapi GIDC. ( A ) Compliance of MOEF&CC’s OM no. J - 11013/5/2010 - IA.II (I) dated 25/11/2016 (A) Proponent is committed to comply regarding lifting of moratorium on the consideration of projects for with any applicable direction from environmental clearance. the regulatory body ( B ) Compliance of direction under section 18 (1) (b) of the Water (Prevention and Control of Pollution) act, 1974 issued by CPCB dated 31/03/2016 regarding (B) compliance of CETP. a) No action is initiated by GPCB a ) Action initiated by GPCB, if any, against proposed unit regarding non - against proposed unit regarding non - compliance of prescribed standards under the various environmental laws. compliance b ) Performance of CETP with respect to current hydraulic load & prescribed standards with No Objection Certificate of CETP regarding incorporation of b) Performance of CETP of M/s. ETL, the proposed unit for acceptance of waste water. Ankleshwar is monitored by GPCB and c ) Performance of TSDF site with respect to current load & prescribed results are uploaded on website of standards with No Objection Certificate of TSDF sit e regarding GPCB, Unit has obtained No Objection incorporation of the proposed unit for acceptance of hazardous waste to the Certificate of CETP for effluent common infrastructure. discharge after expansion d ) Copies of quarterly action report taken for the above points submitted to the CPCB. c) Unit has membership of TSDF site of e ) Report of GPCB which have conducted monitoring as per the s aid direction M/s. BEIL, Ankleshwar and request letter by CPCB dated 31/03/2016. for additional quantity after expansion is submitted.

d) & e) submissions are made by GPCB to CPCB

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Abbreviations & Symbols used in this report ABBREVIATIONS AND SYMBOLS USED IN THIS REPORT

Organization abbreviations Abbreviation Full form APHA American Public Health Association APPL Avdhoot Pigments Pvt. Ltd. AWH Air Water Hazardous waste BEIL Bharuch Enviro Infrastructure Ltd. CPC B Central Pollution Control Board CDC Centers for Disease Control and Prevention DGVCL Dakshin Gujarat Vij Company Ltd. SEAC State Expert Appraisal Committee SEIAA State Environmental Impact Assessment Authority EAC Expert Appraisal Committee GIDC Gujarat Industrial Development Corporation GEPIL Green Gene Enviro Protection & Infrastructure Pvt. Ltd. GPCB Gujarat Pollution Control Board GSDMA Gujarat State Disaster Management Authority IMD Indian Metereological Department MoEF&CC Ministry of Environment, Forest and Climate Change NAAQS National Ambient Air Quality Standards NABL National Accreditation Board for Testing and Calibration Laboratories NABET National Accreditation Board for Education and Training NCT Narmada Clean Tech NIOSH National Institute for Occupational Safety and Health NRSA National Remote Sensing Centre PESO Petroleum and Explosives Safety Organization PETL Panoli Enviro Technology Ltd. RSPL Recycle Solutions Pvt. Ltd. SCN Show Cause Notice SEPPL Saurashtra Enviro Projects Pvt. Ltd. SGEPL Siddhi Green Excellence Private Limited SEAC State Expert Appraisal Committee SEIAA State Environmental Impact Assessment Authority

Project specified abbreviations Abbreviation Full form Abbreviation Full form AAQ Ambient Air Quality IDLH Immediately dangerous to life or health AAQM Ambient Air Quality Monitoring ISO International Organization for Standardization AMB. Ambient KL Kilo Liter ATM. Atmospheric KVA Kilo volt ampere APCD Air Pollution Control Devices LDAR Leak Detection and Repair APCM Air Pollution Control & Management LEL Lower explosive limit BLEVE Boiling liquid expanding vapor explosion MAH Maximum Accident Hazard MT/A & Metric Tons per Annum & Metric Tons per BOD Biochemical Oxygen Demand MT/M Month BTX Benzene Toluene Xylene MCC Motor control center CC&A Consolidate Consent and Authorization MEE Multi - Effect Evaporation COD Chemical Oxygen Demand MOC Material of Construction CEMS Continuous Emission Monitoring System MSDS Material Safety Data Sheet CFM Cubic feet per minute PCC Power Control Center CMEE Common Multi - Effect Evaporation PLC Programmable Logic Controller CHWIF Common Hazardous Waste Incineration Facility PPE Personal Protective Equipment CER Corporate Environment Responsibility ppm Parts per million CSR Corporate Social Responsibility PSV Pressure Safety Valve CTE Consent to Establish QC Quality control CTO Consent to Operate QTY. Quantity CEPI Comprehensive Environmental Pollution Index RT Room Temperature DCS Distributed Control System SCADA Supervisory control and data acquisition

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Abbreviations & Symbols used in this report Project specified abbreviations DG Diesel Generator SH State Highway DMP Disaster Management Plan STEL Short - Term Exposure Limits EC Environmental Clearance SW Surface Water ECC Emergency Control Center TN Total Nitrogen EMP Environmental Management Plan TSDF Treatment, Storage & Disposal Facility EMS Environmental Management System TSS Total Suspended Solids EPA Environment Protection Act TPA Tons per Annum ETP Effluent Treatment Plant TPH Tons per Hour FD Forced Draft TR Ton of refrigeration GLC Ground Level Concentration TPD Tons per day GW Ground Water TOC Total Organic Carbon HAP Hazardous air pollutants ToR Terms of References HAZOP Hazard and operability study TWA Time weighted average HC Hydrocarbon UG Underground HSD High speed diesel VOC Volatile organic compound HSE Health, Safety & Environment HT & LT High Tension and Low tension ID Induced Draft

Commonly used Chemical name abbreviations PM 10 Particulate Matter (size less than 10  m) HCl Hydrogen Chloride PM 2.5 Particulate Matter (size less than 2.5  m) Cl 2 Chlorine SO 2 Sulphur Dioxide H 2 Hydrogen NOx Oxides of Nitrogen (measured as NO 2 ) HBr Hydrogen Bromide BTX Benzene(B), Toluene(T) and Xylene (X) Br 2 Bromine NH 3 Ammonia H 2 S Hydrogen Sulphide CO Carbon Monoxide VOC Volatile Organic Chemicals

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Contents CONTENTS UNDERTAKING FROM PROJECT PROPONENT ...... 3 UNDERTAKING BY EIA C ONSULTANT ORGANIZATI ON ...... 4 DECLARATION BY EXPER TS ...... 5 ACKNOWLEDGEMENTS ...... 7 EXECUTIVE SUMMARY ...... 8 TERMS OF REFERENCES (TORS) AND T HEIR COMPLIANCES ...... 45 ABBREVIATIONS AND SY MBOLS USED IN THIS R EPORT ...... 52 LIST OF TABLES ...... 59 LIST OF FIGURES ...... 61 LIST OF ANNEXURES ...... 62 1 INTRODUCTION ...... 63 1.1 P URPOSE OF THE REPORT ...... 63 1.2 D ETAILS OF PROJECT ...... 63 1.2.1 Proposal ...... 63 1.2.2 Size of the project ...... 63 1.3 N EED FOR THE PROJECT ...... 63 1.3.1 Site - level benefits ...... 64 1.4 I MPORTANCE OF THE PRO JECT TO THE COUNTRY AND REGION ...... 64 1.5 P ROMOTING C OMPANY HISTORY ...... 64 1.5.1 Manufacturing facilities ...... 64 1.6 A BOUT THE PROJECT SIT E ...... 64 1.6.1 Site management ...... 64 1.6.2 Environmental Management Policy and system ...... 64 1.6.3 Photographs of Factory Premises ...... 65 1.6.4 Status of compliances w.r.t applicable environmental regulations ...... 66 1.7 S OCIO - COMMERCIAL B ACKGROUND OF P ROMOTERS OF THE PROJ ECT ...... 67 1.8 A PPLICABILITY OF EIA NOTIFICATION 2006 ...... 67 1.9 R EGULATORY F RAMEWORK OF THE I NDUSTRY ...... 67 1.10 S COPE OF THE S TUDY ...... 68 1.11 E NVIRONMENTAL I MPACT A SSESSMENT (I NTRODUCTION ) ...... 68 1.12 M ETHODOLOGY A DOPTED F OR T HE S TUDY ...... 68 1.13 S TRUCTURE O F T HE R EPORT ...... 69 2 PROJECT DESCRIPTION ...... 71 2.1 T YPE O F T HE P ROJECT ...... 71 2.2 C OMPONENTS O F T HE P ROJECT ...... 71 2.3 P ROPOSED SCHEDULE OF APPROVAL AND IMPLEME NTATION ...... 71 2.4 L OCATION O F T HE P ROJECT ...... 72 2.5 A BOUT B HARUCH DISTRICT ...... 73 2.6 A BOUT A NKLESHWAR GIDC ...... 73 2.7 L AYOUT O F THE P ROJECT S ITE ...... 74 2.7.1 Salient Features of the Project Site ...... 76 2.8 L IST OF E XISTING & P ROPOSED PRODUCTS ...... 77 2.8.1 List of products – Existing and Proposed ...... 77 2.8.2 End use of products ...... 77 2.8.3 Management of By - products ...... 77 2.9 R AW M ATERIALS ...... 77 2.9.1 Consumption (p er kg of product as well as per month) ...... 77 2.9.2 Hazardous Chemicals Inventory ...... 77 2.10 P LANT FACILITIES ...... 78 2.11 M ANUFACTURI NG P ROCESS ...... 79 2.12 U TILITIES ...... 79 2.13 W ATER B ALANCE ...... 79 Siddhi G reen Excellence Pvt. Ltd., Ankleshwar Page 54 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Contents

2.13.1 Water Balan ce for the proposed expansion project ...... 79 2.14 P OWER R EQUIREMENT FOR PROPO SED EXPANSION PROJEC T ...... 83 2.15 F UEL R EQUIREMENT FOR PROPO SED EXPANSION PROJEC T ...... 83 2.16 W ASTEWATER STORAGE , TREATMENT AND DISPOS AL ARRANGEMENT ...... 83 2.16.1 Effluent Characterization ...... 84 2.16.2 Existing Effluent Treatment system ...... 84 2.16.3 Adequacy of Effluent treatment system ...... 87 2.16.4 Economical and technical viability of Effluen t Treatment system ...... 87 2.16.5 Disposal of treated effluent ...... 87 2.16.6 Arrangements for Performance monitoring of treatment systems ...... 87 2.17 A IR E MISSIONS : S OURCES , Q UANTITIES , C ONCENTRATIONS , C ONTROL MECHANISM ...... 87 2.17.1 Flue Gas Emissions & control measures (Existing & Proposed) ...... 87 2.17.2 Process gas emissions and control measures ...... 88 2.17.3 Details of Scrubber systems for Process emission control ...... 88 2.18 F UGITIVE E MISSIONS ...... 89 2.19 H AZARDOUS / N ON - H AZARDOUS W ASTES M ANAGEMENT ...... 91 2.19.1 Compliance to additional TOR No. VII (4) & (6) prescribed by SEIAA – Qualitative and quantitative analysis of hazardous waste streams & appropriate mode of disposal ...... 91 2.19.2 Compliance to additional TOR No. VII (10) prescribed by SEIAA – MoU for final disposal of 30% HCl, Sodium hypochlor ite solution and spent aluminium chloride ...... 92 2.19.3 Method for de - contamination and disposal of discarded containers and its record keeping ...... 92 2.20 O NLINE MONITORING ARR ANGEMENTS ...... 92 2.21 S OLVENT R ECOVERY ...... 93 2.22 H OUSEKEEPING ...... 93 2.23 F IRE F IGHTING F ACILITIES ...... 93 2.24 I NF RASTRUCTURE A VAILABILITY ...... 93 2.24.1 Compliance to additional TOR No. VII (1) prescribed by SEIAA – proportionate availability of space 94 2.25 P ROJECT C OST ...... 96 2.26 M ANPOWER R EQUIREMENT ...... 97 2.27 S UMMARY OF R ESOURCES AND I MPACT – ASPECT RELATIONS W . R . T PROJECT ...... 9 7 2.27.1 Impact aspect analysis ...... 97 3 DESCRIPTION OF THE E NVIRONMENT ...... 99 3.1 I NTRODUCTION ...... 99 3.2 M ETHODOLOGY ...... 99 3.3 V ALUED E NVIRONMENTAL C OMPONENTS (VEC S ) & THEIR PARAMETERS ...... 99 3.3.1 Parameters considered for Data collection ...... 100 3.3.2 Prevailing Environment Quality Standards ...... 100 3.4 S TUDY PERIOD ...... 101 3.5 D EMARCATION OF I MPACT B OUNDARY ...... 101 3.6 S ALIENT F EATURES OF THE P ROJECT S ITE & STUDY AREA ...... 102 3.6.1 Geographical information ...... 102 3.7 T OPOGRAPHY , L ANDUSE AND L ANDCOVER ...... 106 3.7.1 Classification levels for LULC mapping ...... 106 3.7.2 Statistics and graphical representation of land use and land over ...... 109 3.7.3 Interpretation ...... 109 3.8 L AND E NVIRONMENT ...... 111 3.8.1 Geology ...... 111 3.8.2 Geomorphology ...... 111 3.8.3 Soils ...... 112 3.8.4 Primary data collection – Soil sampling and analysis ...... 112 3.8.5 Baseline Status of Soil Quality ...... 115 3.9 M ICRO M ETEOROLOGY ...... 116 3.9.1 Secondary Meteorological data sources ...... 116 3.9.2 Primary Meteorological data (Site - specific) ...... 116 3.9.3 Data Collation and Interpretation ...... 116 3.9.4 Interpretation ...... 121 3.10 A IR E NVIRONMENT ...... 122 3.10.1 Primary Data Collection ...... 122 Siddhi G reen Excellence Pvt. Ltd., Ankleshwar Page 55 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

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3.10.2 Parameters for monitoring ...... 125 3.10.3 Presentation of Results ...... 126 3.10.4 Secondary Data Source ...... 127 3.10.5 Air Environment at Industry ...... 131 3. 10.6 Conclusion on baseline status of Air Environment in study area ...... 132 3.11 W ATER E NVIRONMENT ...... 132 3.11.1 Drainages ...... 132 3.11.2 Surface Water Quality ...... 135 3.11.3 Data Interpretation and Conclusion on Surface water Quality ...... 144 3.11.4 Geo Hydrology ...... 144 3.11.5 Water Level ...... 145 3.11.6 Ground Wate r Quality ...... 147 3.11.7 Interpretation: ...... 153 3.11.8 Summary of Groundwater of study area ...... 153 3.12 N OISE E NVIRONMENT ...... 153 3 . 12 . 1 Methodo logy ...... 154 3 . 12 . 2 Measured Noise levels in the study area ...... 155 3.13 T RAFFIC S TUDY ...... 156 3.13.1 Access rout e to the project site ...... 156 3.14 E COLOGICAL I NFORMATION ...... 158 3.14.1 Aquatic Biology Studies: ...... 167 3.14 .2 Conclusions on Baseline Study: ...... 169 3.15 S OCIO - E CONOMIC E NVIRONMENT ...... 169 3.15.1 Demography ...... 169 3.15.2 District and Taluka Information from Census 2011 ...... 171 3.15.3 Primary Survey for Socio - Economic status ...... 172 3.15.4 Status of Amenities in Ankleshwar Taluka ...... 173 3.15.5 Occupational Structure ...... 178 3.15.6 Cultural and Aesthetic Attributes ...... 180 3.15.7 Status of Civic Amenities ...... 181 4 ANTICIPATED ENVIRONM ENTAL IMPACTS & MITI GATION MEASURES ...... 184 4.1 I NTRODUCTION ...... 184 4.2 M ETHODOLOGY ...... 184 4.3 I DENTIFICATION OF I MPACTING A CTIVITIES ...... 184 4.3.1 Impacting Activities during Construction & Erection phase ...... 184 4.3.2 Impacting activities during Commissioning phase & Operational phase ...... 185 4.4 I DENTIFICATION OF E NVIRONMENTAL A TTRIBUTES ...... 185 4.5 I MPACT I DENTIFICATION , P REDICTION AND A SSESSMENT ...... 186 4.5.1 Tools for Prediction of Impacts ...... 186 4.5.2 Likelihood of occurrence of impact and Criteria for likelihood ...... 186 4.5.3 Severity of Impact and criteria for severity ...... 187 4.5.4 Final impact assessment evaluation criteria ...... 187 4.6 A SSESSMENT OF E NVIRONMENTAL IMPACTS FROM S TACK EMISSIONS & MITIGATION MEASURES ...... 188 4.6.1 Dispersion Modelling for estimation of GLC of air pollutants from flue gas emissions ...... 188 4.6.2 Flue gas emissions ...... 188 4.6.3 GLC simulation results for flue gas emissions ...... 189 4.6.4 Inference for PM 10 from Dispersion modeling ...... 191 4.6.5 Process emissions ...... 191 4.6.6 GLC si mulation results for HCl & Cl2 emissions ...... 192 4.6.7 Inference for Process emissions from Dispersion modeling ...... 19 3 4.6.8 Fugitive emissions and their control ...... 193 4.7 P REDICTION & M ITIGATION OF I MPACTS ON A MBIENT N OISE FROM C ONSTRUCTION ACTIVITI ES ...... 193 4.8 P REDICTION & M ITIGATION OF I MPACTS ON A MBIENT N OISE DURING OPERATIO NAL PHASE ...... 194 4.9 N OISE PREDICTION D UE TO T RANSPORTATION ...... 194 4.9.1 Noise prediction for NH - 48 – Mumbai to Delhi ...... 195 4.10 A SSESSMENT OF W ATER S OURCE & W ASTEWATER TREATME NT AND DISPOSAL ...... 195 4.10.1 Assessment of source of the water supply ...... 195

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4.10.2 Wastewater treatment and disposal ...... 195 4.11 P ROJECT P HASE - WISE I MPACT A SSESSMENT AND M ITIGATION M EASURES ...... 197 4.11.1 Activitywise Impact Assessment ...... 197 4.11.2 Interpretation of impact assessment ...... 204 5 ANALYSIS OF ALTERNAT IVES ...... 206 5.1 A LTERNATIVE ANALYSIS & J USTIFICATION OF THE PROJECT ...... 206 5.1.1 For Project selection ...... 206 5.1.2 For Site selection ...... 206 5.1.3 For technology / process selection ...... 207 6 ENVIRONMENT MONITORI NG PROGRAM ...... 208 6.1 E XISTING E NVIRONMENTAL M ONITORING P LAN & PROPOSED ADDENDUM ...... 208 6.1.1 Proposal for Leak Detection and Repair (LDAR) program as per the CPCB guidelines – Compliance to additional TOR No. VII (7) prescribed by SEIAA ...... 210 7 RISK ASSESSMENT & DI SASTER MANAGEMENT PL AN ...... 213 7.1 B ACKGROUND ...... 213 7.2 O BJECTIVES ...... 213 7.3 S COPE OF W ORK ...... 213 7.4 M ETHODOLOGY ...... 213 7.5 H AZARD I DENTIFIC ATION ...... 214 7.6 S TORAGE H AZARDS A ND C ONTROL M EASURES ...... 214 7.7 P ROCESS H AZARDS A ND T HEIR C ONTROL M EASURES ...... 215 7.8 O THER H AZARDS & C ONTROL ...... 215 7.8.1 Se nsitive locations around the project ...... 215 7.9 P ROPOSED R ISK REDUCTION MEASUR ES FOR THE PROJECT ...... 216 7.9.2 Operational Safety ...... 219 7.9.3 Fire Fighting Arrangements & Emergency preparedness ...... 220 7.10 V ISUALIZATION OF A CCIDENT S CENARIOS ...... 222 7.10.1 Selection of Initiating Events and Scenarios ...... 222 7.11 C ONSEQUENCE A NALYSIS ...... 223 7.11.1 Frequencies Estimation: ...... 224 7.11.2 Assumptions Common for all Scenarios ...... 226 7.11.3 Summarized Table for effects of Consequences ...... 227 7.11.4 Inference of Consequence analysis ...... 228 7.11.5 Risk to Individuals from a Major Release ...... 228 7.12 R ECOMMENDATIONS ...... 230 7.13 D ISASTER M ANAGEMENT P LAN ...... 231 8 PROJECT BENEFITS ...... 234 8.1 P ROJECT B ENEFITS DURING C ONSTRUCTION PHASE ...... 234 8.2 P ROJECT B ENEFITS DURING O PERATIONAL PHASE ...... 235 9 ENVIRONMENTAL COST B ENEFIT ANALYSIS ...... 236 10 ENVIRONMENTAL MANAGE MENT PLAN ...... 237 10.1 N EED FOR E NVIRONMENTAL M ANAGEMENT P LANNING ...... 237 10.1.1 Objectives of Environmental Management Plan ...... 237 10.2 E NVIRONMENTAL M ANAGEMENT S YSTEM ...... 237 10.2.1 Environmental Policy ...... 237 10.2.2 Environment, Health and Safety (EHS) Cell ...... 237 10.3 EMP F OR C ONSTRUCTION AND E RECTION P HASE O F T HE P ROJECT ...... 239 10.4 EMP FOR C OMMISSIONING AND O PERATIONAL P HASE ...... 240 10.5 EMP FOR CONTROL OF EMISS IONS ...... 245 10 .5.1 Odor Control ...... 245 10.6 E NVIRONMENT MANAGEMEN T THROUGH H OUSEKEEPING ...... 245 10.7 O CCUPATIONAL S AFETY AND H AZARD M ANAGEMENT ...... 245 10.7.1 Control of Exposure levels of hazardous chemicals ...... 246 10.7.2 Safety precautions to be taken for Chem. storage, process, handling & transportation hazard...... 247

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10.7.3 Compliance to additional TOR No. VII. (8) prescribed by SEIAA – Safety precautions to avoid hazard during unloading, storage, transportation handling and processing of Cl2 as per PESO standards...... 247 10.7.4 Details on workers training before engaging work, periodical, in - house, outside etc...... 249 10.7.5 Details on various SOPs ...... 249 10.7.6 Medical Facilities ...... 250 10.8 G REENBELT D EVELOPMENT ...... 251 10.8.1 Road side Plantation ...... 252 10.8.2 F ive year plan for Green belt development ...... 253 10.8.3 Capital and recurring expenses for green belt development ...... 253 10.9 R AIN W ATER H ARVESTING ...... 253 10.1 0 CP TECHNIQUES TO BE IMP LEMENTED ...... 254 10.10.1 Compliance to suggestions and recommendations of Environmental Audits of last Three years ...... 254 10.11 A CTIVITIES UNDER C ORPORATE E NVIRONMENT R ESPONSIBILITY (CER) ...... 256 10.11.1 Compliance to additional TOR no. VII. (2) prescribed by SEIAA – CER ...... 256 10.12 C OMPLIANCE TO CREP GUIDELINES ...... 257 10.13 L ONG TERM STRATEGIES FOR REDUCTION IN WAS TE ...... 258 10.14 E NERGY C ONSERVATION M EASURES ...... 259 10.14.1 Compliance to additional TOR no. VII (3) prescribed by SEIAA – explore use of renewable energy .. 259 11 SUMMARY & CONCLUSION S ...... 260 12 DISCLOSUR E OF CONSULTANT ORGA NIZATION ENGAGED ...... 264 12.1 NABET ACCREDITATION STATUS OF M/ S . S IDDHI G REEN E XCELLENCE P VT . L TD ...... 265 12.2 NABL ACCREDITATION OF LAB OF M/ S . S IDDHI G REEN E XCELLENCE P VT . L TD ...... 265

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List of Tables LIST OF TABLES

Table 2 - 1 Salient Features of the Project Site ...... 76 Table 2 - 2 Products with production capacity ...... 77 Table 2 - 3 List of Hazardous chemicals to be handled after expansion ...... 78 Table 2 - 4 List of Proposed Facilities for Utility ...... 79 Table 2 - 5 Water Consumption (For Existing & Proposed expansion) ...... 80 Table 2 - 6 Power Requirement for proposed expansion project ...... 83 Table 2 - 7 Fuel Requirement for proposed expansion project ...... 83 Table 2 - 8 Waste Water Generation (For Existing & Pro posed Expansion) ...... 83 Table 2 - 9 Effluent Characteristics ...... 84 Table 2 - 10 Existing and proposed additoinal flue gas stacks and control measures ...... 88 Table 2 - 11 Existing & Proposed additional process stacks ...... 88 Table 2 - 12 Sources of Fugitive Dust & their control measures ...... 89 Table 2 - 13 Sources of Fugitive Chemical vapors & their control measures ...... 89 Table 2 - 14 Hazardous Waste Generation ( For existing & proposed expansion) ...... 91 Table 2 - 15 Details of solvent recovery ...... 93 Table 2 - 16 Break up of different land use of factory (for existing & after expansion) ...... 94 Table 2 - 17 Project Cost Breakup ...... 96 Table 2 - 18 Valued Environmental Components ...... 98 Table 3 - 1 Salient features of Project Site and Study area of 10 km radius ...... 103 Table 3 - 2 Industries nearby the project site ...... 105 Table 3 - 3 Land use Pattern of the study area ...... 109 Table 3 - 4 Location of Soil sample collection ...... 113 Table 3 - 5 Chemical Characteristics of Soil ...... 115 Table 3 - 6 IMD Bharuch station data for the year 2017 ...... 1 16 Table 3 - 7 Average annual rainfall of Bharuch District (2004 - 2017) ...... 117 Table 3 - 8 Site Specific Meteorological Data ...... 117 Table 3 - 9 Location of Ambient Air Quality Monitoring Stations ...... 123 Table 3 - 10 Photographs of AAQM ...... 124 Table 3 - 11 List of parameters & their test methods for Ambient Air Quality Monitoring ...... 125 Table 3 - 12 Locations of Surface Water sampling ...... 136 Table 3 - 13 Photographs of Surface water sampling are as below...... 137 Table 3 - 14 Photographs of Reservoir & Lake water sampling ...... 138 Table 3 - 15 Analysis result of Pond water (surface water) (not used as drinking water source) ...... 139 Table 3 - 16 Analysis result of water of rivers (not used as drinking water source) ...... 140 Table 3 - 17 Analysis result of water of Khadis (surface water) (not used as drinking water source) ...... 141 Table 3 - 18 Analysis result of water of canals (surface water) (not used as drinking water source) ...... 142 Tabl e 3 - 19 Analysis result of GIDC Reservoir water (used as drinking water source) ...... 143 Table 3 - 20 Locations of water level measurement ...... 145 Table 3 - 21 Locations of Ground Water sampling ...... 148 Table 3 - 22 Photographs of GW sampling : ...... 149 Table 3 - 23 Analysis results of Borewell water (used as drinking water) ...... 150 Table 3 - 24 Analysis Result of Borewell/Openwell (Not Used As Drinking Water Source) ...... 151 Table 3 - 25 N oise levels at ambient air monitoring stations ...... 155 Table 3 - 26 Major Residential areas within the study area ...... 169 Table 3 - 27 Census 2011 Demographic statement of Bharuch district ...... 171 Table 3 - 28 List of villages covered for primary data collection ...... 172 Table 3 - 29 Demographic Data from Census 2011 for Study area Villages & Towns ...... 175 Table - 3 - 30 Primary data for Occupational status ...... 178 Table 4 - 1 Baseline Environmental Indicators of Environmental Attributes ...... 185 Table 4 - 2 Receptor stations selected for Dispersion simulation ...... 189 Table 4 - 3 First Three Highest 24 - Hourly Average GLC Values for HCl & CL 2 with APCM ...... 192 Table 4 - 4 Estimation of fugitive losses from storage tanks (Fixed roof tanks) ...... 193 Table 6 - 1 Inhouse Laboratory Infrastructure ...... 210

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List of Tables Table 7 - 1 Process Hazards and their Control Measures ...... 215 Table 7 - 2 Sensitive locations around t he project ...... 215 Table 7 - 3 Worst Case (WCS) and Most Credible Accident (MCS) Scenarios selected for the study ...... 223 Table 7 - 4 Assumed failure rate for the study ...... 224 Table 7 - 5 Damage Due To Incident Radiation Intensity ...... 225 Table 7 - 6 Physiological Effects Of Threshold Thermal Doses ...... 225 Table 7 - 7 Heat Radiation & Escape Time ...... 225 Table 7 - 8 Tolerable Over Pressure Limits For Various Objects ...... 226 Table 7 - 9 Flammable End points of Consequence Analysis ...... 227 Table 7 - 10 Toxic End points of Consequence Analysis ...... 227 Table - 10 - 1 Green Belt Areas at the site ...... 251 Table 10 - 2 Suggested species for green belt ...... 251 Table 10 - 3 Five year plan for Green belt development ...... 253 Table 10 - 4 Environment Budget Allocation Sheet for the proposed expans ion project ...... 254 Table 10 - 5 CER proposal ...... 256

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EIA – EMP With Risk Assessment & DMP Report For Propose d Expansion In Existing Unit of M /s. Avdhoot Pigments Pvt. Ltd . for manufacturing of Synthetic Organic Chemicals At Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat. India List of Figures LIST OF FIGURES

Figure 2 - 1 Map showing location of the Project site in India ...... 72 Figure 2 - 2 Project Site Co - ordinates on Google earth imagery ...... 75 Figure 2 - 3 Photographs of surroundings of the site ...... 75 Figure 2 - 4 Water Balance Diagram after proposed Expa nsion ...... 82 Figure 2 - 5 Schematic diagram of ETP ...... 86 Figure 2 - 6 Photographs of ETP ...... 87 Figure 3 - 1 Study Area Map (Area within 10 km radius from the project site) ...... 101 Figure 3 - 2 Satellite Imagery obtained from NRSA ...... 107 Figure 3 - 3 Landuse & Landcover Map of Study area ...... 108 Figure 3 - 4 Land use pattern of study area ...... 109 Figure 3 - 5 Geological Map of study area ...... 111 Figure 3 - 6 Digital Elevation Model of Study area ...... 111 Figure 3 - 7 Soil Map of study area ...... 112 Figure 3 - 8 Photographs of soil sampling are attached below: ...... 112 Figure 3 - 9 Weather monitoring station ...... 116 Figure 3 - 10 Hourly average temperature for study period ...... 118 Figure 3 - 11 Wind Rose Diagram for site - specific weather monitoring data ...... 119 Figure 3 - 12 Wind rose diagram for stud y period (1 st February 2017 to 31 st April 2017) ...... 120 Figure 3 - 13 Wind class Frequency distribution ...... 120 Figure 3 - 14 Photographs of Survey work carried out for Socio - Economic Baseline study ...... 172 Figure 3 - 15 Photographs of Amenities and facilities are as below: ...... 179 Figure 10 - 1 Environment, Health and Safety (EHS) Cell ...... 237

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List of Annexures LIST OF ANNEXURES

Sr. Annexure No. 1A. NABET Accreditation Certificate 1B. NABL Certificate (No. TC - 5007) of laboratory for ISO 17025:2017 Compliance and Scope of Accreditation 2 . National Ambient Air Quality Standards ( NAAQS ) (2009) 3 . Indian Standards For Drinking Water IS : 10500:2012 4 . General Standards for effluents (EPA, 1986) 5 . Ambient Noise Standards As Per The Noise Pollution Rules, 2000 6 . Damage Risk Criteria For Hearing Loss (OSHA) 7 . Copy of Plot allotment from GIDC 8 . Undertaking for no digging of borewell in factory premises and separate Electric meter for ETP 9 . Content page of onsite emergency plan 10 . Final TORs issued by SEIAA for EIA - EMP Preparation 11 . GIDC letter for additional water supply 12 . Consequence Analysis results for Risk Assessment 13 . List of Director of M/s. Avdhoot chemicals Pvt. Ltd. 14 . Request letter to GIDC for allocating land regarding development of additional g reenbelt 15 . Health and Safety policy of company 16 . Site layout plan of the project site with demarcation of Green belt area 17 . Toposheet for the study area 18 . Do’s and Don’ts of plant operation Sampling and analytical methods adopted for AAQM, GW and SW analysis, Floral, Faunal & Micro Biota 19 . documentation 20 . List of Antidotes for major chemicals 21 . Details of FAEs and FAAs involved in the EIA 22 . EMS adequacy certificate of Schedule II Environmental Auditor License from Chief Controller of Explosives (CCOE), Petroleum & Explosives Safety Organization (PESO) for 23 . chlorine storage 24 . Raw materials & their consumption with CAS No. of product 25 . Details of Manufacturing of each product 26 . Chemical, Physical and Hazardous properties of chemicals Request letter to M/s. BEIL, Ankleshwar for receiving additional hazardous was te after expansion for disposal 27 . land filling waste at TSDF , Membership letter and permission for additional discharge of M/s. ETL, Ankleshwar and MoU with actual end users utilizing AlCl 3 and HCl solution. 28 . Copy of existing Consent to Operate (CTO) with compliance report 29 . Details of instructions issued by GPCB in last 2 years and action taken by proponent thereof. 30 . Copies of show cause notices served by GPCB with action taken reply 31 . Copy of ISO 9001 : 2008 & ISO 14001 : 2004 certificate s 32 . MSDS of major chemicals

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Chapter 1. Introduction

1 INTRODUCTION

1 . 1 P URPOSE OF THE REPORT This Environmental Impact Assessment (EIA) – Environmental Management Plan (EMP) with Risk Assessment and DMP Report is prepared in accordance with Terms of Reference (ToRs) prescribed by State Level Environment Impact Assessment Authority (SEIAA).

1 . 2 D ETAILS OF PROJECT

Name of the Industrial Unit M/s. Avdhoot Pigments Pvt. Ltd. - henceforth referred to as APPL Project Site Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat, India. Address of Same as above correspondence Registered Office address Same as above Name of the Applicant Mr. Dixit J. Patel (Director) E - mail ID of the Applicant [email protected]

1 . 2 . 1 Proposal Proposal Expansion in existing unit – by –  enhancing production capacity of existing products

1 . 2 . 2 Size of the project Production Existing Proposed for EC Total (MT/Month) (MT/Month) (MT/Month) Synthetic Organic 13 157 170 Chemicals

Project Cost Proposed Project Cost Rs. 8.6911 Crores (For Proposed Expansion Only) Proposed EMS budget Rs. 1.5 Crores (For ETP, solid / hazardous waste management and disposal facilities, green belt development, Air pollution control devices)

1 . 3 N EED FOR THE PROJECT Pro posed expansion project is needed to serve increasing demand of the proposed products in export as well as domestic market. The proposed production capacities are based on detailed market survey by APPL .

Demand - Supply Gap The gap between demand and availability of pigments for textiles and printing industry is likely to increase over the years. This calls for such projects which can help in bridging the gap. “Make in India” campaign is also expected to add impetus to the emergence of India as a manu facturing hub for the chemicals industry in the medium term.

Export Possibility The products have good demand of about 20% in local/national markets and 80% in international market.

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Chapter 1. Introduction 1 . 3 . 1 Site - level benefits  Complete utilization of the open land available in the plot  Reduce operational costs and increase productivity  The existing infr astructure facilities and land availability shall be utilized to the fullest with more efficiency

1 . 4 I MPORTANCE OF THE PRO JECT TO THE COUNTRY AND REGION  Reduce dependence on Imports  Add to foreign exchange generated by exports  Ensure continued employment to workforce without affecting work conditions and hence supporting their families  Lead to generation of direct and indirect employment op portunities.  The project will create employment during the construction as well as operational phase.  The present level of employment shall increase through requirement of skilled/ unskilled labour, qualified professionals and also develop the estate as su ch.  Proponent is committed to employ local affected population based on academic skills and qualifications.

1 . 5 P ROMOTING C OMPANY HISTORY M/s. Avdhoot Pi gments Pvt. Ltd. is a small scale unit located in Ankleshwar GIDC estate and engaged for manufacturing of pigments. The company is governed by board of directors. The details of directors of the company are annexed as Annexure - 13.

M/s. Avdhoot Pigment Pv t. Ltd. has been providing specialized service to the manufacturers of paints, links, plastic, rubber, textile etc and is evolving continuously to provide better performance and results. A prime aspect of a modern day business is top quality product with c onsistency and the company has persistently emphasized total quality management.

1 . 5 . 1 Manufacturing facilities APPL has only one manufacturing site at Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar, Dist. Bharuch, State - Gujarat, India . – where the proposed expansion is planned .

1 . 6 A BOUT THE PROJECT SIT E 1 . 6 . 1 Site m anagement There is a defined organizational structure for all major operations and management in the unit. The company is supported by various technical persons. The directors are technically well qualified and highly experienced. The support staff is competent to carry out various operations, including the environmental health and safety of people in and around the plant. The unit has a defined HSE management sup ported with an Environmental Policy approved by the Board of Directors. Production and quality control standards are stringent. The unit is accredited for ISO 9001: 2008, ISO 14001: 2004. Certificates of the same are annexed as Annexure – 31.

1 . 6 . 2 Environmental Management Policy and system APPL has formulated Environment, Health and Safety (EHS) policy approved by Director . It mentions about its commitment and diligence towards compli ance to rule s and regulations. The policy is annexed as Annexure – 15 .

In compliance with the requirement of EPA and Factories Act, the unit has an EHS cell to keep a close watch on the performance of the pollution control equipments and the quality of surrounding environment in accordance with the monitoring program. The cell includes the safety cell for observing, inspecting and regulating the safety measures inside the plant campus.

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Chapter 1. Introduction EHS organogram

Th e EHS cell reports directly to S ite Manager for environmental issues including non - compliances and the board of directors are appraised through emails. Six monthly compliance reports shall be submitted to MoEF&CC on timely basis.

The company has provided adequate Environmental Manageme nt systems. - Presently effluent is sent to CETP ( Common Effluent Treatment Plant) of M/s. ETL (Enviro Technology Limited) , Ankleshwar after conforming to their inlet norms through tankers for final treatment and disposal into deep sea via FETP of M/s. NCT, Ankleshwar. - Unit has a separate storm water drainage network and separate septic drainage system as well as spill control procedures for prevention of contamination of groundwater as well as soil. - Unit is a member of TSDF site of M/s. BEIL, Ankleshwar and shall append the membership of TSDF Site for additional quantity of solid / hazardous waste .

1 . 6 . 3 Photographs of Factory Premises

Admin Building Finish Goods Storage

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Chapter 1. Introduction

1 . 6 . 4 Status of compliances w.r.t applicable environmental regulations Unit has following Consent to Operate (CTO) as on 09 - 09 - 2019 – copy is attached as Annexure - 28 with compliance status . Sr. No. CTO No. and date of issue Valid up to 1. AWH - 67033 date of issue: 18 - 12 - 2014 28 - 09 - 2019 – already applied for renewal

Unit has no Consent to Establish (CTE) pending to be converted to Consent to operate as on 09 - 09 - 2019 .

There is no litigation pending against the project and/ or any direction/ order passed by any Court of Law against the project .

Details of notices received under the Section 5 of Environment (Protection) Act, 1986 or relevant Sections of Air and Water Acts and compliance/ATR to the notice(s) and present status of the case are presented herewith - as on 09 - 09 - 2019.

SN Dir no. and date Corrective action taken Compliance 1 . SCN - 350023, 28/03/2016 Reply to Notice Complied You have installed one D.G. Set (cap -  The company has uninstalled the D.G. set and shall 225 KVA) without getting CTE/CCA. be used only after obtaining CTE/CTO from the Board. 2 . SCN - 429419, 16/11/2017 Reply to Notice Complied Generated aluminium chloride solution is  Generated aluminium chloride solution is sold sold out to units who has not obtained actual end user. After visit, company insisted the permission under rule 9. actual user to apply for Rule - 9 and the company has applied for Rule - 9.  Last three months aluminum chloride solution generation and disposal data has been submitted to the Board. 3 . SCN - 446001, 26/02/2018 Reply to Notice Complied 1 . About 50 KL of Acidic Aluminium  Noted. Aluminium Chloride solution shall be sold to Chloride solution was found stored authorized end users. during inspection.  Unit has submitted the data for Generation and sale 2 . The unit has not furnished details of of Aluminium Chloride solution. sale of Aluminium Chloride solution  Unit has insisted the end user to apply for Rule 9 from April - 2015 to Nov – 2017. and in future unit shall sell the this material to the 3 . The unit has not ensured the sale of end users who have applied for Rule 9 or have acidic Aluminium Chloride solution to obtained necessary permission from Board. end users having permissions under  Unit has dedicated tanker for supply of Aluminium rule 9 of Haz waste Rules 2016 and Chloride solution and within 15 days the tanker will not using manifest system for the be facilitated with GPS system. same. Also the tankers used for this acidic Aluminium Chloride solution transportation are not equipped with GPS track. 4 . SCN - 471813, 09/10/2018 Reply to Notice Complied Approx. 100 kg green color solid waste  M/s. Avdhoot Pigments Pvt. Ltd. i s a SSI unit. i.e. insulation, cement waste, etc filled in  Unit was in process of replacing the insulation on plastic bags was lying near the southern different equipments/vessels and which is being gate of the unit. There is a full chance of done on contract basis. rainwater contamination.  Please note that approximately 100 kg of insulation waste was generated which has been segregated by the contractor in HDPE bags near the gate from where an open drain is passing. Due to rains water seeped in and green coloured was observed inside Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 66 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Chapter 1. Introduction SN Dir no. and date Corrective action taken Compliance the same.  The insulation waste has been already disposed off to TSDF site of M/s. BEIL, Ankleshwar. 5 . SCN - 509732, 13/06/2019 Reply to Notice Complied During visit acid brick line damage some  The acid brick line damage has been duly repaired places in neutralization tank of ETP. in the neutralization tank in ETP.  Unit has also submitted the action taken report against the observations by the GPCB officials during inspection conducted on 25 - 03 - 2019 to RO - GPCB, Ankleshwar. Copies of notice and reply letter are annexed as Annexure – 3 0 . Details of instructions issued by GPCB in last 2 year s and actions taken by proponent are annexed as Annexure – 29 .

1 . 7 S OCIO - COMMERCIAL B ACKGROUND OF P ROMOTERS OF THE PROJ ECT The details of Directors name and address are annexed as Annexure - 13.

Key Personnel for this project : Mr. Dixit J. Patel (Director)

The directors have direct and immediate involvement in the project as well as various project activities viz. construction, equipment procurement and installation, raw material supply, technology procurement, process know - how, manufacturing operations, ma npower arrangement, storage and handling, finished product transportation, accounts, marketing etc.

1 . 8 A PPLICABILITY OF EIA NOTIFICATION 2006 The project falls under project type 5(f) and Screening Category B1 (Industrial sector) of the EIA notification date d 14 - 09 - 2006 and therefore requires prior Environmental Clearance from the State Environment Impact Assessment Authority (SEIAA), Gujarat having their office at Gandhinagar.

Application in prescribed Form - 1 has been submitted. Details of further scrutiny of the application are as under :

Proposal No. SIA/GJ/IND2/31093/2019 dated 01 - 05 - 2019 TORs issued vide letter no. SEIAA/GUJ/TOR/5(f)/978/2019 dated 25 - 06 - 2019 & Final Minutes for 507th State Expert Appraisal Committee (INDUSTRY - 2 ) meeting held on 15/05/2019 uploaded on official website of SEIAA .

For conducting EIA as per the TORs, the project proponent has retained the services of M/s. Siddhi Green Excellenc e Pvt. Ltd., Ankleshwar who are NABET accredited EIA Consultant Organization for synthetic organic chemicals industry sector and pesticides sector for category A. Own Laboratory of Siddhi Green Excellence (Accred ited by NABL for ISO /IEC 17025 : 2017 ) has been utilized for various analytical activities of the EIA study, relevant documents are annexed as A nnexure – 1A & 1B respectively.

1 . 9 R EGULATORY F RAMEWORK OF THE I NDUSTRY Compliance to additional TOR No. VII. (5) prescribed by SEIAA The proposed expansion project is that of manufacturing Synthetic Organic Chemicals . For this project , the regulatory framework along with their applicability status is as under:

Rules/Acts/Regulations Status The Environment (Protection) Act 1986 & Rules, 1986 Unit is strictly abiding by this act & rules and amendments amendments in 1999, 2001, 2002, 2003, 2004 therein. Air (Prevention & Control of Pollution) Act 1981 Unit has obtained Consent To Operate (CTO) from the Board Water (Prevention & Control of Pollution) Act 1974 and is following all the conditions of the said act as well as Hazardous and Other Wastes (Management and rules. Transboundary Movement) Rules, 2016 The Noise Pollution (Regulation and Control) Leq dB(A) during day time and night time remain within the

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Chapter 1. Introduction Rules/Acts/Regulations Status (Amendment) Rules, 2010 permissible limits as per the mentioned Rules. Unit is strictly abiding by this act & rules and amendments therein. EIA Notification, 2006 Unit was established in 1993 and hence prior EC is not obtained for present production. Unit had obtained EC from MoEF&CC in the year 2008 for new products, but due to hydraulic load constraints on ETL, the EC was not converted to CTO and validity period of the same has lapsed. Unit has now applied for prior Environmental Clearance for enhancing production of existing products under Category B1 (Project type: 5(f)) from State Environment Impact Assessment Authority of Gujarat. After obtaining EC, 6 monthly compliance report of the same shall be timely submitte d to RO MoEF&CC, Bhopal. Public Liability Insurance Act, 1991 amended 1992 & The company shall obtain PLI policy, if applicable Rules therein The Factories Act 1948 & Rules therein Unit is following the conditions of the said act as well as rules & The Gujarat Factory Rules, 1963 and amendments neces sary licenses for factory operation are obtained. Also therein medical examination of employees, facilities for workers, etc. is carried out under the said rules. Manufacture Storage and Import of hazardous Unit is storing the chemicals in accordance with the chemicals Rules, 1989, amended 2000 requirement of rules and all preventive and control measures are taken for safety of plant and personnel. The same shall be followed after proposed expansion also. Petroleum Act, 1934 & Petroleum Rules, 2002 As per the said rules, Unit has already obtained licence from The Static and Mobile Pressure Vessels (Unfired) PESO for storage of chlorine which is valid upto 30/09/2026. Rules, 1981 Unit shall store and handle chemicals in accordance with the Gas Cylinder Rules, 2016 requirement of rules and all preventive and control measures Chemical Accidents (Emergency planning, shall be taken for safety of plant and personnel. Preparedness and Response) Rules, 1996 The Motor Vehicle Act, 1988 and its amendment 2019 Unit is committed to abide with the said rules and necessary permits shall be taken as per the applicability.

1 . 10 S COPE OF THE S TUDY This Environmental Impact Assessment was carried out for the various operations and activities which are anticipated during the construction, commissioning and operational phase of proposed expansion at existing unit of M/s. Avdhoot Pigments Pvt. Ltd. at A nkleshwar Notified GIDC Industrial estate . Area considered for study includes t he factory area and the study area within 10 km radial distance is taken into consideration as per prescribed standard TORs . Copy of TORs is annexed as Annexure - 10.

1 . 11 E NVIRONMEN TAL I MPACT A SSESSMENT (I NTRODUCTION ) Environmental Impact Assessment is a management tool used to identify, frame and prioritize the environmental issues so that the required mitigation measures can be worked out at the project planning phase and the negat ive impacts can be minimized or avoided during actual operation of the proposed action.

1 . 12 M ETHODOLOGY A DOPTED F OR T HE S TUDY A set of Standard procedures for conducting EIA is followed by the EIA team comprising of EIA Co - ordinator and Functional Area Expe rts formulated for this EIA by Siddhi Green Excellence Pvt. Ltd. These procedures are prepared based on the guidelines and manual issued by MoEF&CC and SEAC, latest development in EIA methodologies and the Assessment Agency’s experience. The procedure addr esses the following main components of the EIA :  Detailing the proposal – products proposed, production capacity, raw materials and their consumption, project site location, TORs issued by SEAC/EAC, study area basemaps and satellite imagery.  Determining the pollution potential of the various project activities and various project phases Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 68 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Chapter 1. Introduction  Preparation of Functional Area (CA) wise Activity chart and bar charts with distribution of role and responsibilities of each individual FA team  Site visit and study area visits to collect ground realties of the area and project infrastructure and layout as well as sources of pollution  Baseline Environmental Data generation through primary and secondary sources. Compliance requirements mentioned in the Guidance manual of M oEF&CC, SEAC guidelines and TORs (applies to selection of monitoring locations, parameters to be monitored, duration of sampling, methodologies and techniques to be adopted etc.) is fulfilled. Both primary and secondary data passes through defined procedu res for authentication, completeness, relevance and reliability before use.  Identification of Impacting activities of the project during construction, erection and commissioning and operational phase and their applicability to each FA in impact – activity m atrix  Prediction of impacts through statistical models, logical reasoning and software  Assessment and quantification of final impacts and projecting the cumulative impact of the project on environment  Assessment of Adequacy and appropriateness of the mitig ation measures proposed by the proponent and conclusions drawn and suggestions to be made for improvement or modifications.  Attempts made to explore possibilities of eliminating the negative impacts first, then reducing the impacts and lastly mitigating the impacts.  Listing of important components of Environmental Management Plan incorporating monitoring, Green belt developme nt, standard procedures, pollution control devices and their maintenance etc. Action plans to be formulated as per requirement.  Addressing measures required for Occupational Health Management  Conducting Need assessment and suggesting CSR activities in agr eement with proponent

References:  Acts, rules, notifications and publications issued by MoEF & CC  Technical Guidance Manual (TGM) – prepared by IL&FS Ecosmart Ltd. for The Ministry of Environment and Forests, GOI  Factories Act 1948 and amendments thereof  Gu jarat Factory Rules, 1963 and amendments thereof  Manufacture Storage and Import of hazardous chemicals Rules, 1989, amended 2000  Petroleum Act 1934  Petroleum Rules,2002  The Gas Cylinder Rules, 2016 and its amendment thereafter  Hazardous and Other Wastes (M anagement and Transboundary Movement) Rules, 2016  Chemical Accidents (Emergency planning, Preparedness and Response) Rules, 1996  Analytical methods for Environmental Sampling and Analysis – IS, EPA & APHA  EPA guidelines and publications  AP – 42 (EPA) for Emission Factors  CPC B guidelines and documents available on its website  OSHA standards and analytical methods  NIOSH standards and analytical methods  Material Safety Datasheets

Software used for this EIA – EMP report : AERMOD from Lakes Environmental – for Air Quality Modeling for pollutant dispersion and GLC estimation ALOHA – for consequence analysis of chemical storages TANKS (EPA) – for quantification of fugitive emissions from chemical tanks SURFER – for generating contour maps

1 . 13 S TRUCTURE O F T HE R EPORT This report comprises of twelve (12) chapters inline with the generic structure of EIA report given in Annexure III of the EIA notification, 2006 as well as to furnish detai ls required in prescribed TORs.

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Chapter 1. Introduction Chapter 1. Introduction - Purpose of the report, Identification of project & project proponent, Brief description of nature, size, location of the project and its importance to the country, region, Scope of the study, EIA methodology and info rmation about assessment agency

Chapte r 2. Project Description -  Type of project, Need for the project, Location maps showing general location, specific location, project boundary & project site layout), size of project,  Technology and process description  utilities, resource consumption etc .  Condensed description of those aspects of the project (based on project feasibility study), likely to cause environmental effects  Proposed schedule for approval and implementation,  Description of mitigation measures incorporated into the project to meet environmental standards,  Assessment of New & untested technology, if applicable, for the risk of technological failure

Chapter 3. Description of the Environment – Demarcation and d escription of Study area, study period, components as identified in the scope & methodology of baseline study, Establishment of baseline for valued environmental components, results of the study and inferences , Base maps of all environmental components, wh erever applicable

Chapter 4. Anticipated Environmental Impacts & Mitigation Measures -  Details of Investigated Environmental impacts due to the project location, possible accidents, project design, project construction, regular operations  Measures for mi nimizing and / or offsetting adverse impacts identified,  Irreversible and Irrevertible consequences on environmental components  Assessment of significance of impacts (Criteria for determining significance, Assigning significance), Mitigation measures requ ired for each adverse impact.  Mitigation measures

Chapter 5. Analysis of Alternatives (Technology & Site) – description of each alternative, its adverse impacts, mitiga tion and criteria for selection

Chapter 6. Environmental Monitoring Program • – Plan of Actions and activities required for ensuring that mitigative measures are implemented and their effectiveness monitored, after approval of the EIA, including measurement methodologies, frequency, location, data analysis, reporting schedules, eme rgency procedures, detailed budget & procurement schedules)

Chapter 7. Additional Studies - Risk assessment

Chapter 8. Project Benefits - Improvements in the physical infrastructure, Improvements in the social infrastructure, Employment potential – skilled; semi - skilled and unskilled, Other substantial benefits

Chapter 9. Environmental Cost Benefit Analysis – This study is no t recommended in specified TORs

Chapter 10. EMP – Description of the administrative aspects of ensuring that the mitigative measures are implemented and their effectiveness monitored after approval of EIA

Chapter 11 . Summary and Conclusions - Overa ll justification for the project and explanation of how adverse effects have been mitigated

Chapter 12. Disclosure of Consultants engaged : The names of the Consultant/s engaged with their brief resume and nature of Consultancy rendered

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Chapter 2. Project Description

2 PROJECT DESCRIPTION

2 . 1 T YPE O F T HE P ROJECT The proposal is for prior environmental clearance to the project for proposed expansion in existing premises for synthetic organic chemicals by M/s. Avdhoot Pigments Pvt. Ltd. at Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat, India.

Proposal Expansion in existing unit – by –  enhancing production capacity of existing products

The proposed expansion unit shall be accomplished by augmenting production area & utilities along with necessary additions in support infra - structure like ETP, Air pollution control systems, Hazardous Waste storages area shall be provided as per requirement.

2 . 2 C OMPONENTS O F T HE P ROJECT For comprehensive analysis of the proposed expansion project, the components of the project are summarized hereunder, detailed study of which is necessary for complete Environmental Impact Assessment study:  Site development  Building Construction to accommodate the proposed production activities.  Installation and com missioning of the Infrastructure facilities i.e. reaction vessels , e quipment for process, utilities, etc.  Use of Natural resources for operation of the Project (water, fuel).  Use, storage, transport, handling or production of substances or materials, i.e. raw materials, products and manufacturing processes.  Generation, collection and treatment of industrial effluent and reuse/ recycling.  Release of pollutants or any hazardous, toxic or noxious substances to air.  Production of solid wastes, hazardous waste and non - hazardous waste, during commissioning, operation or decommissioning;  Risks of accidents, explosion, fire and toxic release during commissioning or operation of the proposed production, Employment generation and trade opportunities  Corporate Environ mental Responsibilities of the proponent and proposed welfare activities

2 . 3 P ROPOSED SCHEDULE OF APPROVAL AND IMPLEME NTATION The project shall be started Within two years after getting Environmental clearance from SEIAA. Tentative s chedule of activities in months Month Project Activity 2 4 6 8 10 12 14 16 20 22 24 26 Site development activity

Green belt plantation

Construction of plant buildings, civil structures

Structural and erection activities

Fabrication work

Equipment Installation

Piping, electrical and other installations including DCS

Installation of fabricated and vendor equipment including equipment for environment management Commissioning of the plant

Operational phase to begin

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Chapter 2. Project Description 2 . 4 L OCATION O F T HE P ROJECT The proposed expansion shall be carried out in existing factory premises of M/s. Avdhoot Pigments Pvt. Ltd. The site is located at Plot no. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, District - Bharuch, State - Gujarat, India. The location of the project site can be viewed from Figure below.

Figure 2 - 1 Map s howing location of the Project site in India

Notified GIDC Industrial Estate , Ankleshwar - 393 002, Dist. Bharuch, Gujarat, India.

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Chapter 2. Project Description 2 . 5 A BOUT B HARUCH DISTRICT Bharuch is located on the banks of River Narmada and is a major sea port and the administrative headquarter of the district. It is one of the heavily industrialized cities in Gujarat. There are a number of chemical plants here, producing fertilizers, paints, dyes, cotton, textiles and dairy products. Gujarat's biggest Liquid cargo term inal is also situated here. Many multinational companies have set up their manufacturing units in and around Bharuch. It is one of the most densely populated districts in terms of industrial population.  Bharuch is a formidable industrial base in sectors as diversified as chemicals & petrochemicals, textiles, drugs & pharmaceuticals and ports & ship building.  Several private business conglomerates have their presence in Bharuch. Some of them include:  Guardian Corporation, Videocon, BadischeAnilin - und Soda - Fabrik (BASF), Reliance, Tatas, Aditya Birla Group, Welspun - Stahl Rohrren, Aventis, Wockhardt, Rallis, Pfizer, Larson & Toubro (L&T), Bayer, Glenmark, Lupin and Gujarat Fluorochemicals Ltd.  Over 11,500 units of small and medium enterprises, involved in d ifferent sectors, such as chemicals and petrochemicals, textiles etc. are present in the district  With over 70 medium and large scale industries, Ankleshwar is a major industrial center in Bharuch witnessing a large number of business activities

2 . 6 A BOUT A NKLESHWAR GIDC Ankleshwar GIDC Notified Industrial Estate is located in Ankleshwar town of southern part of Bharuch District, Gujarat, India. It was set up by Gujarat Industrial Development Corporation in early 70s. This industrial estate is spread over a n area of 1600 hectares in close proximity to National Highway No. 48 and Delhi - Mumbai Railway Line. Being an ideal location for industrialization, as on date, more than 1200 industries, consisting of chemicals, pesticides, pharmaceuticals, bulk drugs, pe troleum products, engineering, textiles, plastics, rubber and packaging etc. are located in this industrial estate  No reserved forests or sanctuaries or archeological sites are located in the vicinity of the area .  No rehabilitation or resettlement of local people  GIDC provides land, sheds and extends active help and support towards providing infrastructure requirements such as water, drainage, streetlights etc.

Connectivity: It has road and railway connectivity to New Delhi,t he National Capital and Mumbai , the commercial Capital of India. It is a part of Delhi - Mumbai Industrial Corridor (DMIC).  Roadways – It is well connected with National Highway (NH - 48) & State Highways (SH - 6, SH - 13, SH - 76 & SH64). The 133 - year - old Golden Bridge connects Ankleshwar to B haruch across the Narmada on the station front, a new four lane bridge is under construction, while two bridges connects the highway.  Railways – connected by the Western Railway Division of Indian Railways, Ankleshwar itself has a railway station, Bharuch has railway station, Ankleshwar - Rajpipla has broad gauge rail route .  Air route - Nearest airport of Surat & Vadodara  Sufficient height from the sea level to be geographically suitable for industrial activity

Availability of Resources viz.  Water - from GIDC reservoir.  Fuel - Natural gas pipeline from Gujarat Gas Company Ltd.  Power - from DGVCL, most of the major industrial plants have own captive power plants

Common Effluent Treatment and Disposal Facilities:  CETP of M/s. Enviro Technology Ltd. (ETL)  CETP and Common Spray dryer plant of M/s. Panoli Enviro Technology Ltd. (PETL)  Common effluent treatment conveyance pipeline of M/s. Narmada Clean Tech (NCT) via FETP : - GIDC has built a liquid effluent drainage network across the estate to facilitate the members to discharge the treated effluents to the drainage sump. From the sump the treated effluents are pumped to M/s. NCT’s Final Effluent treatment plant (FETP) at Surti Bhagol (Ankleshwar) and from there the treated effluents are discharged into deep s ea in Arabian sea through underground conveyance pipeline laid by NCT.

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Chapter 2. Project Description  Common Hazardous waste Treatment, Storage Disposal Facility (TSDF), Common Hazardous Waste Incineration Facility (CHWIF) facility and Common Multi Effect Evaporation Facility (CMEE) of M/s. Bharuch Enviro Infrastructure Ltd. (BEIL) at Ankleshwar  Under commissioning CETP of M/s. Ankleshwar Cleaner Process Technology Centre Private Limited (ACTPTL), Ankleshwar

Ankleshwar GIDC Estate - General Information Sr. No. Particulars Details 1 . Land acquired 1661.00 Hectare* 2 . Land developed 1226.00 Hectare* 3 . No. of Plots 1891* 4 . No. of allotted Plots 1876* 5 . No. of Vacant Plots 15* 6 . No. of Units in Production 1809* 7 . Area under forest cover 91.05 Hectare* *Information as on 2011

Ankleshwar Industries Association Ankleshwar Industries Association was established in 1978 by the industries located in Ankleshwar GIDC estate. Ankleshwar Industries Association stands out from other state based industries associations by its achievements in diversi fied areas. Several activities are being undertaken under the umbrella of AIA. They include redressal of grievances faced by member industries, infra - structural development of estate through member's participation, providing guidelines to small scale indus tries to fulfill various legal requirements, green - belt development, activities related to environmental preservation and pollution control, disaster prevention and management, creating awareness among surrounding population about various issues, etc. To c arry out above activities in the most efficient manner, Ankleshwar Industries Association has promoted Ankleshwar Industrial Development Society, Ankleshwar Environmental Preservation Society, Enviro Technology Ltd, Bharuch Enviro Infrastructure Ltd and Na rmada Clean Tech (NCT).

Source of Information Brief Industrial Profile of Bharuch District, MSME Development Institute, Government of India, Ministry of MSME (micro, small & medium enterprises) http://dcmsme.gov.in/dips/dip%20bharuch_gu.pdf http://www.aiaindia.org/about.php

2 . 7 L AYOUT OF THE P ROJECT S ITE The proposed expansion shall be carried out in the existing unit, located at Plot No. 6213 & 6213/1, Notified GIDC Industrial Estate, Ankleshwar – 393 002, Distr ict - Bharuch, State - Gujarat, India. The site is located within Notified GIDC Industrial Estate of Ankleshwar and hence there is no agricultural or forest land involved in the project site.

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Chapter 2. Project Description Figure 2 - 2 Project Site Co - ordinates on Google earth imagery

Co - ordinates of Centre of Project Site: Latitude: 21°37'13.90" N, Longitude: 73° 2'31.50" E Site layout plan of the project site showing proposed plant facilities is annexed as A nnexure – 16.

Latitude and Longitude of the Corners of the Project site Description Latitude (N) Longitud e (E) A 21° 37' 13.31"N 73° 2' 29.79"E B 21° 37' 14.94"N 73° 2' 29.93"E C 21° 37' 14.70"N 73° 2' 33.55"E D 21° 37' 13.07"N 73° 2' 33.42"E Elevation above Mean Sea Level (MSL) ~ 30 - 31 meter The study area of 10 km aerial radius demarcated on Google Earth Imagery is given in Chapter 3.

Figure 2 - 3 Photographs of surroundings of the site

South Boundary - GIDC Road and beyond that M/s. North Boundary – M/s. Shiv Silica Pvt. Ltd. Rusan Pharma Ltd., M/s. Ambica Metallic Chemicals and Open GIDC plot

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Chapter 2. Project Description

West Boundary – GIDC Road and beyond that M/s. East Boundary – M/s. BASF India Ltd. Sanofi India Limited Photographs of Factory Premises are given in chapter 1.

2 . 7 . 1 Salient Features of the Project Site Table 2 - 1 Salient Features of the Project Site Sr. Particulars Details (Nearest aerial distance measured from centre of the plot, in km)* No. 1. Census Town Ankleshwar ( INA) 2. Taluka Ankleshwar 3. District Bharuch 4. Northward Overview M/s. Shiv Silica Pvt. Ltd. (Precipitated Silica manufacturing) 5. Southern Overview GIDC Road and beyond that M/s. Rusan Pharma Ltd. (Pharmaceutical products), M / s. Ambica Metallic Chemicals (Manufacturing of Metallic Inorganic Sulphates ) and Open GIDC plot 6. Western Overview GIDC Road and beyond that M/s. Sanofi India Limited (Pharmaceutical products) 7. Eastern Overview M/s. BASF India Ltd. (Manufacturing of Optical Whitening agents & their formulations) 8. Water Bodies around the Amravati river – 2.93 km towards NNE GIDC estate Chhapra Khadi – 2.78 km towards NNW Kondh ki khadi – 2.43 km towards E GNFC Reservoir - 3.93 km towards NW GIDC Reservoir, Bhadkodara – 3.49 km towards SWW Amla Khadi – 4.28 km towards W Ankleshwar Lake(near Jalaram nagar) - 5.61 km towards NWW Narmada river – 8.55 km towards NNW 9. Internal Roads around NH - 48 to Asian Paints Chowkdi – 1.97 km towards W the GIDC estate Hathuran - Panoli road – 11.53 km towards SW Hansot - Panoli Road – 11.55 km towards SW 10. State Highway around SH - 64 – 1.71 km towards N the GIDC estate SH 13 – 3.24 km towards SW SH 76 - 4 km towards W SH - 6 - 4.26 km towards W 11. National Highway around NH 48 – 2.6 km towards NW the GIDC estate 12. Nearest Railway Station Ankleshwar Railway station – 4.24 km towards W around the GIDC estate 13. Nearest Airport/ Airbase Surat airport – > 50 km towards SSW around the GIDC estate Vadodara – > 50 km towards NE Co - ordinates of Centre of Project Site: Latitude: 21°37'13.90" N, Longitude: 73° 2'31.50" E

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Chapter 2. Project Description

2 . 8 L IST OF E XISTING & P ROPOSED PRODUCTS 2 . 8 . 1 List of products – Existing and Proposed Table 2 - 2 Products with production capacity Sr. CAS No./ Quantity ( MT/Month) Name of Products End Use No. Cl no. Existing Proposed Total Paints, inks, coatings, plastics, 3 . CPC Green 1328 - 53 - 6 10 140 150 rubbers and textiles As a colorant in paints, dyes, 4 . Beta Blue 147 - 14 - 8 3 17 20 inks, coatings, plastics, rubbers and textiles TOTAL 13 157 170

2 . 8 . 2 End use of products The products are pigments having end uses in various Chemical Industries producing Paints, dyes , inks, coatings, plastics, rubbers and textiles .

2 . 8 . 3 Management of By - products Following By - products shall be generated from proposed production: S N Name of By - product Generated from - Management of by - product 1 Hydrochloric acid (30%) From water scrubber Maximum used for ETP purpose OR If required Collection & attached to reaction Disposal by selling out to authorized users who are having vessel of CPC green authorization with valid CTO and permission under Rule - 9. 2 Sodium Hypochlorite From caustic Maximum use for ETP purpose OR If required Collection & (10%) scrubber attached to Disposal by selling out to authorized users who are having reaction vessel of authorization with valid CTO and permission under Rule - 9. CPC green 3 Aluminium Chloride From drowning and Collection & Disposal by selling out to authorized users who Solution (20%, 30% filtration step during are having authorization with valid CTO and permission 40%) production of CPC under Rule - 9 . green

2 . 9 R AW M ATERIALS 2 . 9 . 1 Consumption (per kg of product as well as per month) For proposed expansion, unit shall store and use hazardous chemicals of toxic and flammable nature in the form of organic and inorganic chemicals as liquids, solids as well as compressed gas. Details of product - wise consumption is given as Annexure – 24. It should be noted that not all inventory shall be made at a time at site. These materials shall be procured and stored at the site according to requirement of production schedule.

All chemicals shall be stored and handled in accordance with Material Safety Datasheet. MSDS of few chemicals are annexed as Annexure – 32. The hazardous properties of chemicals are tabulated in Annexure – 26.

Mode of transport: - Majority of raw materials shall be procured from Ankleshwar and Panoli industrial estates or within Gujarat or from other states and very few shall be imported through nearby ports. The raw materials shall be transported conveniently by rail and road as NH - 48 passes very near to the estate and Ankleshwar has a railway junctio n facility with container yard.

2 . 9 . 2 Hazardous Chemicals Inventory Storage hazards are identified and delineated in onsite emergency plan. Required preventive and control measures are evaluated and verified through safety audits. Presently unit is an MAH installation in accordance to the schedule 3 of MSIHC rules, 2000 for chlorine storage of 15 tonners. Unit has obtained license for storage of chlor ine tonners, copy of license is annexed as Annexure - 23. There shall be no increase in storage of chlorine after expansion and hence no change in MAH status of the unit.

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Chapter 2. Project Description Table 2 - 3 List of Hazardous chemicals to be handled after expansion Storages in drums Physical State No. of Size of container Sr. Max. Storage Hazardous Chemical Name i.e. Liquid / Solid Container at No. Litre (each) Qu antity (KL) / Gas site 1 N - Butanol Liquid 1 170 0.1 7

Bags Storage (Solids) Physical State Size of bags Sr. No. of bags at Max. Storage Hazardous Chemical Name i.e. Liquid / Solid No. site Kg (each) Quantity (MT) / Gas 1 Anhydrous Aluminium Chloride Solid 960 25 24

Storages in tanks Storage Parameters Max. Storage Sr. Hazardous Chemical Physical Proposed Existing tank/s Temp Pressure Quantity (KL) No. Name State Additional (°C) (Kg/cm 2 ) 1 Monochlorobenzene Liquid 3 X 10 KL 3 X 10 KL Amb. Atm 60 1 X 15 KL and 2 Caustic lye (48%) Liquid 1 X 15 KL Amb. Atm 40 1 X 10 KL Amb.: Ambient Atm. : Atmospheric

Gas Cylinder Storage Sr. Hazardous Chemical Physical No. of tonners at Size of tonner Max. Storage Quantity No. Name State site Kg (each) (MT) 1 Chlorine Gas 15 900 13.5

2 . 10 P LANT FACILITIES Site plan is annexed with EIA report as Annexure – 16. Landuse breakup is given in chapter 2 of EIA report. Sr. Facility for expansion Details 1. Manufacturing Plants One additional process plant to be constructed. 2. Utilities Existing natural gas based 1 no. Boiler of capacity 5 lakh kcal/hr and ( Boiler, cooling towers, utility block, 1 no. Thermic Fluid Heater of capacity 2 lakh kcal/hr shall be water storage tank etc.) continued and additionally 1 no. Boiler of capacity 5 lakh kcal/hr & 5 nos. of Thermic Fluid Heater of capacity 2 lakh kcal/hr each shall be required for proposed expansion. New cooling towers shall be installed. Additional Utility area shall be provided adjacent to existing plant building and adjacent to office building near engineering store. 2 nos. D.G. set (320 KVA each) shall be installed at proposed DG area. One additional water storage tank of capacity 5 00 KL is proposed for expansion. 3. Storages (Tanks, cylinder storage, Chlorine Tonner Storage shed is provided near RM storage area. etc. ) New tanks for Monochlorobenzene & Caustic lye are proposed near new process plant building. Adequate dykes and separations as well as drain shall be provided. 4. Warehouses Existing raw material and finished good storage area shall be enough for proposed expansion. 5. Hazardous Waste Storage Areas Existing hazardous waste storage area shall be augmented. Wastes are disposed regularly and minimum storage is kept and same shall be followed after proposed expansion. 6. ETP Existing ETP of 60 KLD capacity shall be upgraded to 180 KLD capacity having primary and secondary treatment units. 7. HT/ LT substations, Switchyards Already present at site. Shall be augmented if required. 8. Admin Building, QA, QC Lab and Admin block, Engineering Store and Change room are already

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Chapter 2. Project Description Sr. Facility for expansion Details R&D Lab, Washroom Block, provided at site and shall be modified within con structed area if Engineering Store required. 9. Other infrastructure Internal roads (paved), security cabin , storm water and containment drainages, lightification, pipe racks, offices and control rooms etc. 10. Green belt after expansion 501 sq.m. ( ~10%) inside the plot premises and the balance greenbelt shall be developed in the area specified by GIDC.

2 . 11 M ANUFACTURING P ROCESS Please refer to Annexure – 25 for details of manufacturing of each product in cluding: 1 . Brief process description. 2 . Chemical reactions. 3 . Mass balance. 4 . Block diagram.

In general, manufacturing processes include Reaction and Separation processes mainly by Chlorination, Drowning & Filtration, Washing, Distillation, Water & Caustic Scrubbing, Layer Separation, Drying, Pulverizing & Packaging .

Products are solid in state. Therefore drying or solid - liquid separations are involved. The reaction temperatures vary from normal to 170°C a nd are controlled using cooling water while distillation processes are carried out at atmospheric pressure as well as vacuum with primary and secondary condensers operating on cooling water.

All unit processes and unit operations shall be carried out in c losed system and under stringent controls and monitoring through local indicators and emergency control procedures .

2 . 12 U TILITIES Table 2 - 4 List of Proposed Facilities for Utility Sr. Type of Utility Existing Additional for Proposed Expansion No. No. Capacity No. Capacity 1 Boiler 1 5 lac kcal/h 1 5 lac kcal/h 2 Thermic Fluid Heater 1 2 lac kcal/h 5 2 lac kcal/h each 3 Cooling Towers 2 2 TR each 2 2 TR each 4 Raw water tank 1 500 KL 1 500 KL 5 D.G. set -- -- 2 320 KVA each

2 . 13 W ATER B ALANCE Source of raw water: GIDC reservoir of Ankleshwar GIDC Estate.

2 . 13 . 1 Water Balance for the proposed expansion project Presently the maximum GIDC water consumption granted in existing Consent to Operate is 23.4 KLD which is supplied from GIDC reservoir. (Copy of CTO is attached as Annexure – 28).

After proposed expansion, fresh water consumption shall be 260 KLD for diffe rent water usages. Existing Proposed Total after expansion Domestic : 0.5 KLD Domestic : 2 KLD Domestic : 2.5 KLD Industrial : 22.4 KLD Industrial : 229.6 KLD Industrial : 252 KLD Gardening : 0.5 KLD Gardening : 5 KLD Gardening : 5.5 KLD Total : 23.4 KLD Total : 236.6 KLD Total : 260 KLD Letter from GIDC for supply of additional water requirement is received and annexed as Annexure - 11.

Recycle / Reuse of water: 1. Total water requirement for the project: 286.25 KLD 2. Quantity to be recycled : 26.25 KLD Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 79 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Chapter 2. Project Description Remarks regarding Source of waste Application area with quantity feasibility to reuse i.e. water for reuse in KLD w/w characteristics with qu antity in KLD (COD, BOD, TDS etc.) Recycled wash 3rd stage wash water shall be water (from recycled for 4th stage washing COD: <500 mg/l process): 20 KLD after passing through filter Boiler Blow down – Boiler blow down of 2 KLD & COD: < 100 mg/l 2 KLD cooling tower blow down of BOD: < 30 mg/l Cooling tower blow 4.25 KLD shall be used for TDS: < 500 mg/l down – 4.25 KLD washing purpose after passing through cartridge filter. 3. Total fresh water requirement: 260 KLD.

Table 2 - 5 Water Consumption (For Existing & Proposed expansion) Water requirement (KLD) Proposed Total after Remarks Existing (Additional) expansion (A) Domestic 0.5 2 2.5 -- (B) Gardening 0.5 5 5.5 -- (C) Industrial Processing 14.9 175.1 190 170 KLD Fresh water requirement + 20 KLD Recycled internally in process Boiler 2.7 13 15.7 -- Cooling 3.8 35 38.8 -- Washing 0.5 26.25 26.75 20.5 KLD Fresh water requirement + 6.25 KLD recycled Boiler blow down of 2 KLD & Cooling tower blow down of 4.25 KLD after proposed expansion (Existing: 0.25 KLD and Proposed additional: 4 KLD) after passing through cartridge filter, shall be used for washing purpose. So the additional fresh water requirement for Washing shall be reduced to 20 KLD. Others (APCM) 0.5 6.5 7.0 -- Industrial Total 22.4 255.9 278.25 Fresh water: 252 KLD + Recycled water: 26.25 KLD Grand Total 23.4 262.9 286.25 Fresh water: 260 KLD + Recycled water: 26.25 KLD (A+B+C)

(A) Domestic Water After proposed expansion, water consumption shall be increase from 0.5 KLD to 2 .5 KLD by way of drinking, flushing, bathing, dishwashing and other usages related to catering. The sewage generation is estimated to increase from 0.4 KLD to 2.2 KLD by way of sanitary and other usages relat ed to catering. Domestic effluent is disposed of f through soak pit via septic tank and same shall be continued after proposed expansion.

(B) Green belt development and maintenance 5.5 KLD of water shall be used for greenbelt development and its maintenance after proposed expansion .

(C) Industrial Water (a) Process Water : Existing 14.9 KLD of fresh water requirement for process shall increase to 170 KLD . 20 KLD 3rd stage wash water shall be recycled for 4th stage washing after passing through filter thereby reducing freshwater requirement for washw ater. Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 8 0 of 265 Project Sector – Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Chapter 2. Project Description P rocess effluent generation shall increase from 19.05 KLD to 149.05 KLD after proposed expansion.

(b) Boiler : At present there is 1 no. 5 lac kcal/hr boiler and additionally 1 no. of 5 lac kcal/hr boiler is proposed for catering to the steam requir ement of process plants. The total boiler blowdown water works out to be 2 KLD which shall be used for washing after passing through cartridge filter and boiler makeup water works out to be 15.7 KLD.

(c) Cooling Tower: Additionally 2 nos. of cooling towe r s shall be req uired for the proposed project. The water requirement for cooling tower after proposed expansion shall increase from 3.8 KLD to 38.8 KLD. Out of which 4.25 KLD cooing tower blowdown shall be generated which after passing through cartridge filter, shall used for washing and then sent to ETP.

(d) Washing : After proposed expansion, the total water requirement for washing purposes shall be 26.75 KLD. 6.25 KLD of blowdown from boiler and cooling towers after passing through cartridge filter, shall be used for washing purpose and then sent to ETP. Hence the water requirement for washing shall be reduced to 20 KLD. Washwater effluent shall be treated in ETP.

(e) APCM: The water required in scrubber during manufacturing of products shall increa se from 0.5 KLD to 7 KLD .

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Chapter 2. Project Description Figure 2 - 4 Water Balance Diagram after proposed Expansion

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Chapter 2. Project Description

2 . 14 P OWER R EQUIREMENT FOR PROPO SED EXPANSION PROJEC T Table 2 - 6 Power Requirement for proposed expansion project

Resource C onsumption Source Existing Proposed Total Power – Continuous Supply 375 KVA 375 KVA 750 KVA From DGVCL Standby Power in case of -- 2 nos. DG 2 nos. DG Set -- power supply failure from Set (320 (320 KVA each) DGVCL KVA each)

2 . 15 F UEL R EQUIREMENT FOR PROPO SED EXPANSION PROJEC T Table 2 - 7 Fuel Requirement for proposed expansion project

Sr. No. Fuel Name Existing Proposed Total 1. Natural gas 250 Nm3/day 9600 Nm3/day 9850 Nm3/day 2. Diesel -- 100 L/h 100 L/h Natural Gas is obtained from M/s. Gujarat Gas Company Ltd.

2 . 16 W ASTEWATER STORAGE , TREATMENT AND DISPOS AL ARRANGEMENT Wastewater: Sources & Quantities Type of Effluent Quantity as per CTO in KLD Total after expansion in KLD Industrial Effluent 19.8 155.8 Domestic Effluent (Sewage) 0.4 2.2 TOTAL 20.2 158

Table 2 - 8 Waste Water Generation (For Existing & Proposed Expansion) Wastewater generation (KLD) Existing Proposed Total after Remarks (Disposal Scenario after proposed expansion) (Additional) expansion (A) Domestic 0.4 1.8 2.2 Sewage shall be disposed to soak pit via septic tank. (B) Industrial Processing 19.05 130 149.05 Recycled: 20 KLD internally in process Effluent to be treated in own ETP and Treated effluent from ETP shall be sent to CETP (Common Effluent Treatment Plant) of M/s. ETL (Enviro Technology Limited), Ankleshwar after conforming to their inlet norms through tankers for final disposal. Boiler 0 2 2 Recycled: 6.25 KLD Cooling 0.25 4 4.25 Boiler blow down of 2 KLD & Cooling tower blow down of 4.25 KLD after proposed expansion (Existing: 0.25 KLD and Proposed additional: 4 KLD) after passing through cartridge filter, shall be used for washing purpose and then shall be further treated in ETP. Washing 0.5 26.25 26.75 Effluent to be treated in own ETP and Treated effluent from ETP shall be sent to CETP (Common Effluent Treatment Plant) of M/s. ETL (Enviro Technology Limited), Ankleshwar after conforming to their inlet norms through tankers for final disposal. Others 0 0 0 -- Total Industrial 19.8 162.25 182.05 Discharge quantity: 155.8 KLD + Recycled water: 26.25 waste water KLD Total waste water 20.2 164.05 184.25 --

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Chapter 2. Project Description

2 . 16 . 1 Effluent Characterization Domestic Effluent Domestic effluent is disposed through soak pit via septic tank and same will be continued after expansion.

2 . 16 . 1 . 1 Compliance to ad ditional TOR No. VII. (9) prescribed by SEIAA Segregation of waste water streams based on characteristics and its proper management keeping in view direction under section 18 (1) (b) of the Water (Prevention and Control of Pollution) act, 1974 issued by CPCB regarding compliance of CETP.

Present scenario -  Presently, unit is a member of CETP of M/s. ETL, Ankleshwar for 550 KL/month effluent disposal.  Acidic and general effluent are segregated and given primary and secondary treatment in own ETP and treated effluent having COD values between 600 - 1200 mg/L is sent to CETP for final treatment and disposal into deep sea via FETP of M/s. NCT, Ankleshwar . After proposed expansion: -  Total industrial effluent generation is estimated to be 155.8 KLD max.  It is propos ed to upgrade existing ETP from 60 KLD to 180 KLD capacity by installing additional units for primary and secondary treatment The treated effluent shall be sent to CETP ( Common Effluent Treatment Plant) of M/s. ETL, Ankleshwar after conforming to their i nlet norms through tankers for final treatment and disposal into deep sea via FETP of M/s. NCT, Ankleshwar

Table 2 - 9 Effluent Characteristics Parameter Unit Collection tank (Inlet to ETP) Treated effluent to Acidic Effluent General effluent CETP ~60 KL D ~ 96 KLD pH -- 3 - 6 6.5 - 8.5 7.5 to 8.0 Total Dissolved Solids mg/l 5000 - 6000 5000 - 6000 7000 - 8000 COD mg/l 1500 - 2000 1500 - 2000 600 - 1200 Total Suspended Solids mg/l < 100 < 100 < 10 Ammonical Nitrogen mg/l < 40 < 40 < 30

2 . 16 . 2 Existing Effluent Treatment system Existing ETP capacity: 60 KLD ETP capacity after proposed expansion: 180 KLD

( A ) Concentrated Stream

The acidic effluent from the plant is taken to either of neutralization tank fitted with stirrer. The acidic effluent is neutralized using lime and it is pumped to plate and frame type of filter press. The filtrate from the plate and frame filter press is taken to collection tank of g eneral stream for further treatment. The sludge is removed from filter press at periodic interval and is stored and sent to TSDF.

( B ) General Stream

The general stream consisting of wastewater other than the acidic stream from process is collected in a stora ge tank fitted with arrangements for coarse air bubbling. The dosing cum flocculating system is provided prior to Primary Settling Tank (PST). The clear supernatant from PST is sent to the aeration tank having floating diffuser arrangement and settled sludge from the PST is removed and send to filter press for dewatering. The overflow of aeration tank with biomass is send to Secondary Settling Ta nk where settled biomass is recycled back to the aeration tank and the overflow of the Secondary Settling Tank is collected to final Treated Water Sump prior to disposal. The treated effluent is sent to CETP of M/s. ETL, Ankleshwar after conforming the CE TP inlet norms, through tankers.

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Chapter 2. Project Description

List of Equipments (Existing and additional for expansion ): Existing Proposed Additional Parame Sr. No. ter Item Name No. of Volum Volum MOC No. Size of Size units e (m 3 ) e (m 3 ) units Acid proof brick lined 55 HRT – 3 1. 2 5.8×3×3 1 5×4×4 80 RCC Tank (each) days Acid proof brick lined 14 HRT – 3 2. 2 2.8×2.2×3 1 5×5×4 100 RCC neutralizer (each) days Plate and Frame Filter 1.2×1.2×48 1.2×1.2×48 PP - -- 3. 1 -- 1 -- Press plates plates FRP Acid proof brick lined HRT – 3 4. 1 7×6×2.5 105 1 7×6×2.5 105 RCC Collection Tank days Hopper Bottom Settling 2.5×2.5×(2 2.5×2.5×(2+ -- 5. 1 21.87 1 21.87 RCC Tank +1.5) 1.5) 6. MCC House 1 4.5×4 - - - - Brick -- Concret HRT – Aeration Tank 1 6×3×3 54 2 6×3×3 108 e 33 hrs 7. Concret Aeration tank 1 6×3×3 54 - - - e Secondary Settling -- 8 1 2.1×2.1×3 13.23 - - - RCC Tank 3.5×4.5×2. -- 9 Treated water sump 1 40 - - - RCC 5 Concret -- 10 Sludge drying bed 2 - - 2 - - e Circulation pumps, transfer pumps, piping, instrumentation – as required

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Chapter 2. Project Description Figure 2 - 5 Schematic diagram of ETP Note: The schematic flow diagram of ETP shall remain same, only number of some ETP components shall be increased for the prop osed expansion .

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Chapter 2. Project Description Figure 2 - 6 Photographs of ETP

Treated effluent storage tank ETP area

2 . 16 . 3 Adequacy of Effluent treatment system From above details, it is concluded that the existing effluent treatment scheme and proposed enhanced capacity of ETP shall be adequate and efficient for treating the effluent for conforming to the inlet norms of CETP of M/s. ETL, Anleshwar. EMS adequacy certificate of Schedule II Environmental Auditor is annexed as Annexure - 22.

2 . 16 . 4 Economical and technical viability of Effluent Treatment system Operating treatment cost of ETP and disposal cost to CETP & TSDF accounts less than Rs. 2 / litre of effluent . Hence it is economically as well as technically viable

2 . 16 . 5 Disposal of treated effluent The industrial effluent generation shall increase after proposed expansion for which it is proposed to upgrade existing ETP from 60 KLD to 180 KLD capacity by installing additi onal units for primary and secondary treatment. The treated effluent shall be sent to CETP (Common Effluent Treatment Plant) of M/s. ETL, Ankleshwar after conforming to their inlet norms through tankers for final treatment and disposal into deep sea via F ETP of M/s. NCT, Ankleshwar. Unit has received permission letter from M/s. ETL, Ankleshwar for the additional effluent quantity and is annexed as Annexure – 27.

2 . 16 . 6 Arrangements for Performance monitoring of treatment systems For performance monitoring of ETP, proponent is committed for following measures :  Maintain online magnetic flow meter on inlet and outlet of ETP  Monitor the performance of ETP by regular analysis by inhouse laboratory and third party analy sis  To have separate electric meter & operational logbook for effluent treatment systems to monitor daily operations.  To take utmost care to prevent leakages from pipe fittings, valves etc., drains shall be provided at all plants to route such occasional e ffluents to ETP.  Spill control procedures to be practiced. Maintain the adequacy and efficiency of all ETP components.

2 . 17 A IR E MISSIONS : S OURCES , Q UANTITIES , C ONCENTRATIONS , C ONTR OL MECHANISM 2 . 17 . 1 Flue Gas Emissions & control measures (Existing & Proposed) Presently 1 no. Boiler having 5 lac kcal/h capacity and 1 no. Thermic fluid heater having 2 lac kcal/h capacity are installed which are operated on Natural gas. These shall be continued after expansion. The flue gas emissions from these utilities remain well within permissible limits of CTO as Natural gas is used as fuel. Hence, no air pollution control measures a re required.

After proposed expansion, there shall be additional flue gas emissions from : Stack attached to proposed additional 1 no. natural gas based Boiler with 5 lakh kcal/hr capacity, common stack attached to 2 nos. natural gas based Thermic flui d heater with 2 lakh kcal/hr capacity each and common stack attached to 3 nos. natural gas based Thermic fluid heater with 2 lakh kcal/hr capacity each.

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Chapter 2. Project Description The flue gas emissions from above mentioned new utilities shall also remain well within permissible limits of CTO as Natural gas shall be used as fuel. Hence, no air pollution control measures shall be required.

2 nos. DG Set (320 KVA each) are proposed to be used as a stand - by power source for emergency operations only. Adequate stack height and stack monitoring facilities shall be provided.

Table 2 - 10 Existing and proposed additoinal flue gas stacks and control measures Type of Sr. Source of emission Stack Height - Quantity Air Pollution Control Type of Fuel emissions i.e. No. with Capacity From G.L. (m) of Fuel Measures (APCM) Air pollutants Existing Boiler Adequate Stack Height is 1 . 11 Natural gas PM 5 lac kcal/h 250 provided S O 2 Thermic Fluid Heater Nm3/day Adequate Stack Height is 2 . 11 Natural gas NO x 2 lac kcal/h provided Proposed Additional Boiler 6000 Adequate Stack Height shall 3 . 11 Natural gas 5 lac kcal/h Nm 3 /day be provided Thermic Fluid Heater 1440 Adequate Stack Height shall 4 . (2 nos.) 11 Natural gas Nm 3 /day be provided 2 lac kcal/h (each) PM SO 2 Thermic Fluid Heater 2160 NO x Adequate Stack Height shall 5 . (3 nos.) 11 Natural gas Nm 3 /day be provided 2 lac kcal/h (each) D.G. Set (2 nos.) 11 Adequate Stack Height with 6 . Diesel 100 L/h 320 KVA each (each) SMF

2 . 17 . 2 Process gas emissions and control measures Table 2 - 11 Existing & Proposed additional process stacks Sr. Specific source of emission (Name of Stack/Vent Air Pollution Control Type of emission No. product & process) Height (Mt) Measures (APCM) Existing Chlorination and drowning vessel during HCl Water Scrubber & 1 . 15 production of CPC green Cl 2 Caustic Scrubber Proposed Chlorination and drowning vessel during Water Scrubber & 2 . 15 production of CPC green HCl Caustic Scrubber Chlorination and drowning vessel during Cl 2 Water Scrubber & 3 . 15 production of CPC green Caustic Scrubber Note: There shall be no new process gas emission from the proposed expansion. Additional 2 nos. of water scrubbers and 2 nos. of caustic scrubbers shall be installed for the proposed expansion.

2 . 17 . 3 Details of Scrubber systems for Process emission control Scrubber systems shall consist of packed columns with adequate height and intalox or saddle packings of PP or suitable resistant material. Typical arrangement is shown below (one column for each stage)

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Chapter 2. Project Description

Exit Gas Venting through Process Stack with sampling point and ladder ID fan

Two stage packed column Scrubber with PP Intalox saddles packing media

Gas stream from reaction vessel

Scrubbing media receiving tank with circulating pump Scrubbing media for HCl – water Scrubbing media for Cl 2 – Caustic solution

Disposal of scrubbing solution - Hydrochloric acid (~30%) generated from scrubbing of HCl emission shall be used in ETP to maximum extent or shall be sold to authorized actual end users who are having authorization with valid CTO and permission under Rule 9 of Hazardous waste rules. - Sodium Hypochlorite (10%) generated from scrubbing of Cl2 emission shall be used in ETP to maximum extent or shall be sold to authorized actual end users who are having authorization with valid CTO and permission under Rule 9 of Hazardous waste rules. The Unit (APPL) shall make MOU with actual end users for its utilization. If actual users have not obtained the authorization under Rule - 9, APPL shall ensure that actual users obtain such authorization within one year following the “Principle of Producers Extended Responsibility” and shall give its wastes up to one year from the date of issue.

2 . 18 F UGITIVE E MISSIONS Fugitive emissions can be defined as the emissions due: -  To the evaporation of raw material and solvents from open vessels, open ends etc.,  Due to spills, leaks , improper handling and transfer of chemicals, etc.  Poor housekeeping,  Lack of proper maintenance leads to the huge amount of fugitive emissions of reactants/products/solvents

These fugitive emissions usually spread in the plant posing a threat to the workmen and sometimes leading to formation of clouds a nd explosions due to increased concentration of pollutants. Thus, proper collection, conveyance, treatment and disposal become highly necessary.

Table 2 - 12 Sources of Fugitive Dust & their control measures Area Type of activity Continuous or Pollutant added to Intermittent ambient air Production area Solid chemical charging from bags Intermittent activity Chemical dust Solid Product bagging Bag filling of product powder or lumps Intermittent activity Chemical dust area

For control of fugitive dust, the packaging as well as charging of solid material areas shall be enclosed and with adequate ventilation, covered transfer systems shall be adopted, workers shall be provided PPEs, machinery shall be provided with dust extraction systems if found necessa ry by work place monitoring, minimum manual operations, local exhausts and roof top ventilators shall be provided wherever required.

Table 2 - 13 Sources of Fugitive Chemical vapors & their control measures

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Chapter 2. Project Description Continuous or Area Type of activity Pollutant added to ambient air Intermittent Production and drum handling Charging, reaction, Intermittent activity HAP chemicals with low V.Ps areas transfer

Sr. No Probable sources Control measures . 1. Pump glands and seals All pumps handling low V.P chemicals and pressurized gas shall have mechanical seals or sealless pumps. 2. During reactions & Solvent All reactors shall be closed and provided with primary and secondary recovery systems condensers with cooling water circulation for maximum vapor recovery Solvent recovery of minimum 95% shall be acheived Temperature and pressure conditions shall be stringently controlled as per the process requirement and optimized with low temperature and vacuum conditions wherever feasible. 3. Vents of storage tanks – during Li quid raw materials will be charged by pumping & closed loops. withdrawal to day tanks Metering pumps shall also be used wherever required. Suitable stoichiometric calculations will be done and followed to regulate the quantity of reactants to be charged to reaction vessels in order to avoid use of excess chemicals, which in turn will minimize organic load in the effluent. 4. Release from Sampling Lines Shall be carried out using a closed loop sampling system. 5. Emissions from Bulk Storage Storage tanks storing low V.Ps chemicals are provided with Breather valve Tanks during storage, loading assembly, PSVs, Rupture discs wherever applicable. an d unloading Tank Pressure equalization shall be applied wherever required. Closed Transfer systems 6. Valves, Flanges, plugs and Welded pipes to be used wherever feasible instrument connections Suitable gasket material to be used Suitable gland packing to be used in valves Periodic inspection and maintenance of pipes and pipe fittings 7. Chemical vapors during filtration Covered transfer systems shall be adopted, workers shall be provided PPEs, and drying process local exhausts and roof top ventilators wherever required 8. Charging from drums Covered transfer systems shall be adopted, workers shall be provided PPEs, area shall be adequately ventilated 9. Warehouse storing drums and Spillages shall be strictly prevented by providing drip pans, proper handling bags equipment, Spill control procedures and equipment shall be provided.

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Chapter 2. Project Description 2 . 19 H AZARDOUS / N ON - H AZARDOUS W ASTES M ANAGEMENT Table 2 - 14 Hazardous Waste Generation ( For existing & proposed expansion) 2 . 19 . 1 Compliance to additional TOR No. VII (4) & (6) prescribed by SEIAA – Qualitative and quantitative analysis of hazardous waste streams & appropriate mode of disposal Specific Source of Quantity Category and Sr. Type/Name of generation (MT/Annum) Schedule as Management of HW no. Hazardous waste (Name of the Activity, per HW Rules. Existing Proposed Total Product etc.) 1 . ETP Waste From ETP Cat: 35.3 & 7.2 1008 1015.2 Collection, Storage, Transportation, Disposal to Sch: I TSDF at M/s. BEIL, Ankleshwar. 2 . Discarded From Raw material Cat.: 33.1 & 2.16 21.84 24 Collection, Storage, Decontamination, Reuse, Containers containers / bags Sch: I (144 Nos./yr) (1456 Nos./yr) (1600 Nos./yr) Transportation, Disposal by selling to authorized 0.48 1.92 2.4 recyclers Bags/liners (2400 Nos./yr) (9600 Nos./yr) (12000 Nos./yr) 3 . Used Oil From Machinery Cat.: 5.1 0.036 5.964 6 Collection, Storage, Decontamination, Transportation, Disposal by selling to registered re - processor. 4 . Hydrochloric acid From water scrubber Cat.: B - 15 & 240 3168 3408 Maximum used for ETP purpose OR If required (30%) attached to reaction Sch: II Collection, Storage, Transportation, Disposal by vessel of CPC green selling out to authorized users who are having authorization with valid CTO and permission under Rule - 9. 5 . Sodium From caustic scrubber Cat.: B - 7 & 0 528 528 Maximum use for ETP purpose OR Collection, Hypochlorite (10%) attached to reaction Sch: II Storage, Transportation, Disposal by selling out to vessel of CPC green authorized users who are having authorization with valid CTO and permission under Rule - 9. 6 . Aluminium Chloride From drowning and Cat.: B - 10 & 480 / 360 / 240 13332 / 8892 / 13812 / 9252 / Collection, Storage, Transportation disposal by Solution (20%, 30% filtration step during Sch: II KL 6672 KL 6912 KL reuse within p remises or by selling out to authorized 40%) production of CPC users who are having authorization with valid CTO green and permission under Rule - 9. 7 . Spent Solvent* From distillation in MCB Cat.: 26.4 & 0 109 109 Reused continuously in production through recovery step during Sch: I distillation columns having Primary and secondary production of CPC condensers inbuilt with reactors without any storage green in the premises *Note: Spent solvent category is to be added in existing Consent To Operate AWH - 67053 dated 18/12/2014. Request letter for the inclusion of spent solvent has already been sent to GPCB.

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Chapter 2. Project Description To ensure proper handling, storage and disposal of hazardous/non - hazardous wastes, the following measures have been suggested by the EIA agency.  Necessary preventive steps should be adopted for handling, loading and unloading hazardous wastes.  Proponent to explore possibilities for reducing manual handlin g of hazardous wastes wherever possible - by packing the waste at place of generation, minimum transport distances, transport in closed containers, and minimum inventory of wastes.  Proponent shall keep a vigilant check on the characteristics of each waste and review storage and disposal methods periodically.

Disposal at Landfill site – Waste going for Reuse/ Recycle/ Recovery - ETP waste - Used Oil - Discarded Containers, Barrels / Liners Wastes to be sold to actual users or authorized Wastes to be reused within premises to maximum extent dealers under rule 9 (as and when generated) - Spent Solvent - Hydrochloric acid (30%) - Sodium hypochlorite (10%) - Sodium hypochlorite (10%) - Hydrochloric Acid (30%) - Aluminium chloride (20%, 30%, 40%) - Aluminium chloride (20%, 30%, 40%)

2 . 19 . 2 Compliance to additional TOR No. VII (10) prescribed by SEIAA – MoU for final disposal of 30% HCl, Sodium hypochlorite solution and spent alumini um chloride Unit shall produce MoU for final disposal of above mentioned solutions which are going to be generated as Hazardous Waste as per HWR - 2016, (1) Spent H C l, (2) Spent sodium hypochlorite and (3) spent aluminium chloride at the time of appraisal of Environmental Clearance.

Hazardous wastes covered in Schedule II :  By - products ( Sodium hypochlorite (10%), Hydrochloric Acid (30%), Aluminium chloride (20%, 30%, 40%) are included as hazardous wastes under Rule 9 of The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.  Proponent has MoU with actual users who have valid authorization and have applied for permission under Rule 9 of The Haz ardous and Other Wastes (Management and Transboundary Movement) Rules, 2016, for selling the existing by - products. MoU is annexed as Annexure – 27. For by - products generated after expansion, unit is committed to have MoU with those actual end users who hav e valid authorization as well as compliance for utilization of the by - products under Rule 9 of The Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016. If actual users have not obtained the authorization under Rule - 9, proponent ensures that actual users obtain such authorization within one year following the “Principle of Producers Extended Responsibility” and gives its wastes up to one year from the date of issue . MoU shall be produced at the time of appraisal of Environmental Clearance.

Memberships of Common Disposal Facilities Unit has membership of M/s . Bharuch Enviro Infrastructure Ltd. (BEIL) – Ankleshwar TSDF site for sending landfilling wastes. Copy of letter of membership and request letter for additional quantity is annexed as Annexure – 27.

2 . 19 . 3 Method for de - contamination and disposal of discarded containers and its record keeping Contaminated drums, carboys are collected in dedicated area prov ided with impervious flooring. The drainage is connected to ETP drain. It is ensured that no washing effluent gets overflowed outside the washing area or get s mixed with storm water drain. After decontamination, the containers are properly drained and stacked properly. They are r eused withi n plant premises or sold to GPCB approved merchant.

2 . 20 O NLINE MONITORING ARR ANGEMENTS It is suggested to install : -  Temperature and pH meter on scrubber media tanks  Flow meter on ETP inlet and outlet

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Chapter 2. Project Description 2 . 21 S OLVENT R ECOVERY Solvent recovery is carried out by simple distillation directly from reactor vessels provided with distillation assembly in dedicated distillation units depending on the solvent composition. Recovered solvents are reused in process. Distill ation assembly comprises of packed column, condensers with cooling water circulation to obtain minimum 95% recovery. Proposed new process vessels shall also have same facility.

Table 2 - 15 Details of solvent recovery Solvent % Purity Subject to Recovered Solvent Product Product charged of solvent recovery % Purity of Solvent per batch % Sr. No. Name kg per used in kg per recovered (kg) Recovery batch batch batch solvent Mono Chloro 1 CPC Green 50 99 49.5 48 99 96 Benzene 2 Beta Blue N - Butanol 100 99 99 96 99 96

2 . 22 H OUSEKEEPING The proponent has assured to follow good housekeeping policy for the proposed expansion.

Following Suggestions are given by EIA consultant and proponent has committed to implement them to the best possible extent.  To regularly inspect housekeeping in various sections of the plant  To maintain stairways in good condition  To carry out engineering and mai ntenance jobs in separate designated area.  To carpet Internal roads and major walkways as well as work areas either by asphalt or paverblocks to minimize dusting as well as provide ease of transportation and movement.  To keep walkways free from obstruction s and put signages for each area  To label all equipment, auxiliaries and piping appropriately  To follow Piping Color code  To collect wastes in each department in separate containers with labels and marking and sent to common waste  collection area in the fa ctory for disposal  To keep Spill Control kits in each production and material handling area and give training to shift incharge.  Dry Sweeping to be done in all departments on daily basis.  To house electrical wirings properly in cable trays and strips.  To p rovide localized exhausts for air circulation .

2 . 23 F IRE F IGHTING F ACILITIES With context to operational safety, proponent has taken suitable safety measures with modern & adequate facilities for accident prevention and hazard control.  Fire water storage is provided in the plant to facilitate firefighting by DPMC fire tender. Fire extinguishers are also provided at all necessary locations and of suitable type and capacity.  Flammable areas shall be classified as per applicable rules and protected by spark avoidance and flameproof electric fittings. The fire protection and fire fighting arrangements shall be provided in new plant sections also.  Emergency handling equipments like SCBA sets, G as mask, PPEs, Chlorine emergency Kit, chlorine hood provided.  The organization has developed an on - site emergency plan to handle emergencies and accidents and is upgraded periodically.  Hazardous chemicals are stored and handled as per MSDS and control mea sures are provided accordingly.  Safety is given prime importance by management and continuous efforts are made to maintain safety through safety audits, workers trainings and awareness programs, etc.

2 . 24 I NFRASTRUCTURE A VAILABILITY The Proposed expansion is planned in the same factory premises since –

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Chapter 2. Project Description There is sufficient unoccupied area in existing premises to accommodate new sections and utilities. Presently ~40% of factory area is unoccupied and available for expansion. Hence, expanding the manufacturing facilities in existing plot premises and utili zing the open land is the most suitable option for the proposed expansion. The layout and areas provided to each section are adequate with sufficient distances and internal paved roads. The augmentation for proposed expansion shall be conveniently done w ithout any disturbances to the existing facilities.

Site plan showing the areas is annexed as Annexure – 16 and details of total plot area and built - up facilities are summarized table below .

Table 2 - 16 Break up of different land use of factory (for existing & after expansion) Additional for Total for Sr. Existing proposed proposed Proposed Land use % % % No. area (sq.m) expansion expansion (sq.m) (sq.m) 1 Administrative block 142.00 2.85 0.00 0.00 142.00 2.85 2 Plant Facilities 497.80 10.00 326.5 6.56 824.30 16.55 3 Utility Facilities 204.00 4.10 194 3.90 398.00 7.99 4 Ware House 550.00 11.04 0.00 0.00 550.00 11.04 5 Electrical Facilities 24.00 0.48 0.00 0.00 24.00 0.48 6 ETP 105.00 2.11 120.00 2.41 225.00 4.52 Hazardous/non - hazardous 7 35.00 0.70 40 0.80 75.00 1.51 waste storage area 8 Approach road(s)/ drains 806.00 16.19 0.00 0.00 806.00 16.19 Others (Security cabin, 9 35.50 0.71 0.00 0.00 35.50 0.71 change room etc.) Total occupied 2399.30 48.18 680.50 13.67 3079.80 61.85 11 Open area 2079.45 41.76 -- -- 1398.95 28.09 12 Green belt 501.00 10.06 0.00 0.00 501.00 10.06 Total Area under 4979.75 100.00 4979.75 100.00 possession – Sq. Mt. (Source : Plot layout plan – Drawing No. SGE/APPL/L - 01 rev. 01 dated 24 - 07 - 2019 )

2 . 24 . 1 Compliance to additional TOR No. VII (1) prescribed by SEIAA – proportionate availability of space Details with respect to justification for proposed expansion project:

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Chapter 2. Project Description

Area allocated for production plant : 824.30 m 2 of plot area (Ground floor, 1 st floor & 2 nd floor) % of total plot area : 16.55%

Hence, area shall be adequate for manufacturing of proposed products and proposed capacity.

(2) To address proportionate availability of storage area for raw materials, finished goods, utilities and goods carrier movement wi thin premises.

Storage Period of Maximum Type of storage Capacity Required Allocated storage storage MT per sq. m Space, space, required sq. m sq. m (MT) Raw Material 3 days 44 MT Drums & bags 1 44 100 Finished goods 3 days 17 MT Bags 1 17 200 Storage Hazardous 70 days 204 Bags in stacking 3 68 75 waste storage arrangement & Drums Total 375 % of plot area 7.53

Hence, area shall be adequate for manufacturing of proposed products and proposed capacity.

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Chapter 2. Project Description (3) To address proportionate captive/common infrastructure available to accommodate load due to proposed project.

ETP @ 60 KLD shall be augmented to 180 KLD within area of 225 m 2 where treatment tank s shall be adequately located.

(4) Environment impact and its mitigation measures for common/ captive infrastructure due to proposed production. After proposed expansion, the ETP capacity shall be augmented to 180 KLD consisting of primary and secondary treatment to treat the effluent & treated effluent shal l be sent to CETP of Ms. ETL, Ankleshwar after conforming the CETP inlet norms.

The existing area of 4979.75 sq.m (plot no. 6213 & 6213/1) has o btained consent of 13 MTM production capacity. Unit has already obtained Environmental clearance from MoEF vide F. No. J - 11011/620/2008 - IA - II (I) dat ed 29/12/2008 for expansion upt o 190 MTM in the plot no . 6213 (area: 2479.75 sq.m). But due to hydraulic load constraints, the EC was not converted to CTO and the validity period of the the same has lapsed. Now, the u nit proposes expansion at plo t no. 6213 & 6213/1 (4979.75 sq.m) (Amalgamation order by GIDC already received on 13/04/2012). Hence the present plot area is adequate for expansion.

2 . 25 P ROJECT C OST Proposed Project Cost Rs. 8.6911 Crores (For Proposed Expansion Only) Proposed EMS budget Rs. 1.5 Crores (For ETP, solid / hazardous waste management and disposal facilities, green belt development, Air pollution control devices)

Table 2 - 17 Project Cost Breakup Group Particulars Nos. Cost (Rs. In lakh) Reactors 4 64 Condenser 3 6.75 Hydrogenated reactor 3 46.5 Process Plant Dumping Tanks 2 19 Process pumps 11 20 Valve and Instruments 32 15 Boiler + Thermic Fluid Heater 6 205 D.G Set 2 30 Utilities Compressors 3 2.85 Cooling tower 2 8 Water Storage Tank 1 7 Storage Tanks Raw material storage tank / bullets 5 30 Effluent treatment plant (ETP) -- 120 Environment Green Belt Development -- 10 Air Pollution Control Devices (APCD) 4 20 Plant building civil and structural work 95 Piping Installation 25 Insulation & Painting 12 Safety items -- 10 Civil Electrical installation 2 9 Miscexpenses: - Lab, office, ware house, furniture & fixtures, office & lab -- 35 requirement

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Chapter 2. Project Description Group Particulars Nos. Cost (Rs. In lakh) Total 790.10 Contingencies (10%) 79.01 Grand Total 869.11

2 . 26 M ANPOWER R EQUIREMENT Existing Man power: 5 Nos. Company employees + 10 Nos. on Contract basis Proposed additional Man power: 15 Nos. Company employees + 40 Nos. on Contract basis Total after proposed expansion: 20 Nos. Company employees + 50 Nos. on Contract basis

Type Manager Officer Operator/ Contract Total Worker Labor Existing 1 4 4 6 15 Proposed 1 8 21 25 55 additional Total after 2 12 25 31 70 expansion  There shall be recruitment in the field of Plant Operation, Laboratory Activities, Maintenance, Security, Purchase, Accounts, Warehouse, Housekeeping and such other fields related to a manufacturing facility.  Maximum efforts for recruitment from local area and within district and state. Project specific training shall be imparted to enhance skills and increase local people.

Development of ancillary business and trade opportunities Other trade and commerce opportunities shall be provided to local people in way of  mechanical supplies,  machinery services and repair work  spare parts and accessories supplies  canteen services and supplies,  hou sekeeping,  security,  green belt maintenance,  contractual labor for packaging and other activities.

2 . 27 S UMMARY OF R ESOURCES AND I MPACT – ASPECT RELATIONS W . R . T PROJECT The proposed expansion project at APPL involves following resource requirement: Sr. Consumption/ Generation Resource Source No. Existing Scenario Total after expansion 1 Water 23.4 KLD 260 KLD GIDC Supply Power – 375 KVA 750 KVA From DGVCL Continuous Supply 2 -- 2 nos. DG Set of 320 KVA To be used as standby during Power – Standby each power failure Fuel 3 Natural Gas 250 Nm 3 /day 9850 Nm 3 / day Gujarat Gas Ltd. Diesel -- 100 L/h Local supplier 5 Nos. Company 20 Nos. Company Max. efforts for recruitment from 4 Manpower employees + 10 Nos. on employees + 50 Nos. on local areas and within district and Contract basis Contract basis state

2 . 27 . 1 Impact aspect analysis Below table provides a rationale for establishment of baseline environmental status w.r.t envisaged impacts on various environmental/human resources due to the proposed exp ansion project.

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Chapter 2. Project Description Table 2 - 18 Valued Environmental Components Sr. Environment Major Impacting activities & probable impacts during Baseline parameters to be No. operational phase of the project monitored 1 . Landuse & No change in landuse and landcover of area outside the site Present Landuse and Landcover Landcover for specified radial distance of 10 km from project site 2 . Air Process emissions if not controlled appropriately may add Ambient Air Quality Monitoring Environment pollutants to ambient air and endanger the health of locality for PM 10 , PM 2.5 , SO 2 , NOx, and ecology . VOC as BTX, CO, NH 3 , HCl, HC may be liberated from chemical handling during process Cl 2 – at residential, industrial and from packing area which shall add pollutants to ambient areas air if not controlled PM from vehicular emission may increase to a marginal level due to increased road traffic and may have minor adverse health impact on social and biological environment . 3 . Water Pondwaters - Physico - Environment chemical parameters, The treated water from ETP at proponent’s facility shall be sent microbiological parameters, to C E TP by tankers . Marine water quality shall be affected if drainage 4 . Land effluent discharged into deep sea is not treated adequately to Groundwaters - Physico - Environment conform to stipulated norms. chemical parameters, Adulteration of nearby po nds, soil and groundwater if microbiological parameters, contaminated surface run - offs and stormwaters released from static water level, recharge the unit get added into them. This may inturn affect health of Soil – physico - chemical users including human and agricultural crops . analysis of soil samples of villages in the study area, Agricultural pattern 5 . Ecology & The adverse impacts on air, water, soil and noise shall have Terrestrial, Aquatic Biodiversity indirect impacts on terrestrial flora and fauna surrounding the ecosystems of study area of project site. 10 km radius

6 . Noise There shall be increase in noise during the construction phase. Ambient Noise levels at Much noise is not expected during the operational life of the villages and near state plant. Road transport shall increase which shall cause addition highways in road traffic noise levels. Higher levels of noise cause disturbance to biological environment a nd related lifecycle processes. 7 . Socio - The adverse impacts on air, water, soil and noise shall have Demography, literacy, Economics indirect impacts on health of residents of the study area . occupational structure, The employment generation due to the proposed project shall community structure, culture, benefit the economy . civic amenities, religion, social and economic development. ** As TO R stands governing for scope of EIA studies – the paramet ers considered are as per the TO R.

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