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Date: 08/12/16 To, the Member Secretary, State Level Expert Appraisal Committee, Gujarat C/O

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Date: 08/12/16 To, the Member Secretary, State Level Expert Appraisal Committee, Gujarat C/O Date: 08/12/16 To, The Member Secretary, State Level Expert Appraisal Committee, Gujarat C/o. Gujarat Pollution Control Board, Paryavaran Bhavan, Sector-10 A, Gandhinagar – 382 010 Subject : Submission of additional details for the grant of Environmental Clearance of our proposed manufacturing unit. Reference : 1. Proposal No.: SIA/GJ/IND2/16476/2015 2. File No.: EIA-10-2014-6940-E/2298 3. Your Letter No.: EIA-10-2016-6940-E.2132 dated 14/09/2016 Respected Sir, In regards to the above subject and reference, we are submitting herewith desired information as sought by you for the grant of Environmental Clearance of our proposed manufacturing unit. We have incorporated point wise clarification and details as attached in the APPENDIX with supporting documents for your kind perusal. We hope the details are adequate as per the requirements and looking to this we request you to process and consider our application for grant of Environmental Clearance at the earliest. Yours faithfully, Enclosure APPENDIX : POINT-WISE CLARIFICATION FOR ADDITIONAL DETAILS Annexure A : Revised Form 1 Annexure B : Treatability Study & Adequacy of Proposed ETP Annexure C : AAQM result of HBr at Project site and within study area 409 – Saffron Complex, Fatehgunj, Vadodara – 390002 (Gujarat) INDIA Phone : +91-265-3916549, Fax : +91-265-3916548 Email: [email protected], URL : www.choruspharmachem.com APPENDIX POINT-WISE CLARIFICATION OF ADDITIONAL DETAILS SOUGHT APPENDIX Point wise Clarification for Additional details 1. Revised Form-1 considering (1) additional plot no. 174, (2) revised Waste water quantity (3) Management of waste items i.e. Dilute Hydro Bromide (HBr – 30%), Dilute Hydrochloric Acid (HCl – 30%) & Dilute Ammonia (NH3 – 17.5%) as per the Hazardous and Other Wastes (Management and Transboundary Movement) Rules 2016. Details of the additional plot no., water balance and management of waste items have been revised as follows and incorporated in the revised Form-1 attached as Annexure A. i. Details of additional Plot No. The proposed project is to be located at Plot No. 184, 185 & 174 in notified industrial estate of GIDC-Nandesari. Plot No. 174 is addressed in attached revised Form 1.GIDCplot transfer letters for all the three plots were already submitted as Annexure 1 with EIA report. ii. Revised Water Balance Sr. Water Requirement, Wastewater Particulars No. KLD Generation, KLD I Domestic 4.0 3.0 II Other use (Gardening) 2.0 Nil III Industrial a) Process & APCE 16.0 24.3 b) Boiler 25.0 4.5 c) Cooling 2.0 0.1 d) Washing 2.0 2.0 e) Water Treatment Plant 10.0 10.0 Total Industrial 55.0 40.9 Grand total (I+II+III) 61.0 43.9 409 – Saffron Complex, Fatehgunj, Vadodara – 390002 (Gujarat) INDIA Phone : +91-265-3916549, Fax : +91-265-3916548 Email: [email protected], URL : www.choruspharmachem.com Revised Water Balance Diagram Fresh Water (4.0) (3.0) To soak pit (Source: GIDC Water Domestic through supply) septic tank (61.0) (2.0) Gardening Nil Fresh Industrial (55.0) (51.0) (9.5) REJECT (10) Water Treatment Plant Loss Loss (2.0) (2.0) (41.0) (1.9) (24.5) (16.0) (25.0) Process & Boiler Cooling Washing APCM (Make-up) (24.3) (4.5) (0.1) (2.0) To APCM (30.9) (10.0) ETP (40.9) Hydrodynamic Cavitation Discharge into CETP of M/s. NIA (Nandesari Industries Association) for further treatment and Final Disposal Note : All quantities are expressed in KLD. 409 – Saffron Complex, Fatehgunj, Vadodara – 390002 (Gujarat) INDIA Phone : +91-265-3916549, Fax : +91-265-3916548 Email: [email protected], URL : www.choruspharmachem.com iii. Management of Hazardous waste There will be generation of Dilute Hydro Bromide (30%), Dilute Hydrochloric Acid (30%) & Dilute Ammonia (17.5%) as a by-product which will be handled as per Hazardous and Other Wastes (Management and Transboundary Movement) Rules 2016, the details of which are summarized in the following table. Sr. Quantity Name of By-Product Source Management No. (Ton/Annum) Dil. Hydro Bromide APCM during mfg. of 1. 18.00 (HBr-30%) Memantine-HCl Dil. Hydrochloric Acid APCM during mfg. of Sell to actual end users 2. 13.92 (HCl–30%) Piroctone-Oliamine authorized by GPCB Dil. Ammonia Liquor APCM during mfg. of 3. 29.28 (NH3 – 17.5%) Venlafexine-HCl Copies of the agreement for purchase of by-products from authorized end-users were already submitted as Annexure 3 with EIA report. 2. Separate quantity of fuel consumption in MT/day for Biofuel/Agro waste& Coal. Unit proposes to use Biofuel/Agrowaste and/or Coal for Steam Boiler (5.0 TPH) and Diesel for DG Set (20 KVA). Details of the fuel requirement are given below; Sr. Maximum Average Fuel Calorific Value Utility No. Requirement Requirement Bio Fuel/ Steam 1. 3,850 Kcal/Kg 5.4 TPD Agricultural waste Boiler 5 TPD 2. Coal 4,500 Kcal/Kg (5.0 TPH) 4.6TPD DG Set 3. Diesel 9,500 Kcal/Lit 1.25 Lit/Hr 1.25 Lit/Hr (20 KVA) 3. Justification for disposal of spent catalyst into TSDF site. Requirement of Raney Nickel catalyst will be 3.96 Ton/Annum for the manufacturing of product Venlafexin HCl and the generation of spent catalyst will be 4.5 Ton/Annum. This may contain other impurities and will not be feasible to recover Nickel from the same. Hence, spent catalyst Raney Nickel has been proposed to dispose by landfilling at TSDF. However, we will explore the possibilities to recover the precious metal by sending it to re-processors if it is techno-economically feasible. 409 – Saffron Complex, Fatehgunj, Vadodara – 390002 (Gujarat) INDIA Phone : +91-265-3916549, Fax : +91-265-3916548 Email: [email protected], URL : www.choruspharmachem.com 4. Treatability study & adequacy report for High Ammonical waste bearing stream. The industrial effluent generation from proposed project will be 40.9 KLD. Earlier with the EIA report, we submitted proposal to treat industrial effluent in ETP having MBBR technology comprising of primary, secondary and tertiary treatment units. Now, we propose to adopt ETP scheme based on hydro-dynamic cavitation treatment which effectively removes Ammonical Nitrogen from effluent, hence segregation of high ammonical waste bearing stream will not be required. Treatability study carried out for hydro-dynamic cavitation by Nandesari Industries Association (NIA) is enclosed in Annexure B. Treatability results show that proposed ETP having hydro-dynamic cavitation system will be adequate to treat industrial effluent in achieving norms prescribed by the CETP of NIA for further treatment and final disposal. Stream-wise and stage-wise characteristic of effluent are given in Table 1 and Table 2 respectively. The details of ETP units are given in Table 3. Treatment Scheme: The wastewater from the plant will be collected in the collection cum neutralization tank. The wastewater will be equalized over organic matter and flow. The pH of the wastewater will be raised to 10.5 by addition of hydrated lime and filtered. Then the filtered wastewater will be pumped through a ventury into hydrodynamic cavitation tank. At the suction side, chlorine will be injected to achieve hydrodynamic cavitation. This is a batch process and the system will be kept under recirculation till the COD reaches to desired limit. pH of the effluent will be checked continuously and when it will drop about 8, fresh lime will be added into the effluent. The process will be continued until the effluent gets colorless and COD drops below the inlet norms of CETP of NIA. The effluent will again be filtered in the filter press and then it will be sent to CETP through tankers. The following checks and precautions will be taken for hydrodynamic cavitation process. 409 – Saffron Complex, Fatehgunj, Vadodara – 390002 (Gujarat) INDIA Phone : +91-265-3916549, Fax : +91-265-3916548 Email: [email protected], URL : www.choruspharmachem.com 1. The hydrodynamic cavitation tank will be provided with 6 m liquid depth and will be kept half empty. 2. Barometric header of minimum 7 m for addition of chlorine will be provided. 3. pH of the effluent will be checked continuously. 4. Venturi with pipe flocculator will be provided for the best results as chlorine will be mixed completely. 5. Sparger will also be provided for through mixing in order to achieve better results. 6. Alkaline pH will be maintained to control emission of un-reacted Cl2 during hydrodynamic cavitation process. However, any un-reacted Cl2 gas generated will be sent to caustic scrubber provided in the process plant through vent on hydrodynamic cavitation reactor. The schematic diagram of effluent treatment scheme and set up of hydrodynamic cavitation system are given in the Figure 1&Figure2 respectively. Figure 1: Schematic Diagram of proposed ETP 409 – Saffron Complex, Fatehgunj, Vadodara – 390002 (Gujarat) INDIA Phone : +91-265-3916549, Fax : +91-265-3916548 Email: [email protected], URL : www.choruspharmachem.com Figure 2: Setup of Hydrodynamic Cavitation System Table 1: Stream-wise Characteristics of Effluent Sr Wastewater Stream Process Boiler Cooling Washing WTP Composite No. Hydraulic Flow Rate, a 24.3 4.50 0.1 2.0 10.0 40.9 KL/Day b Concentration of Parameters are in mg/L except pH 1 pH 5-7 8.0 8.5 7.5 7.5 7.0-8.0 2 TDS (Max) 11,481 1,400 1,400 1,000 2000 7,596 3 COD (Max.) 18,687 30 40 3,000 45 11,255 4 BOD (Max.) 5,647 5 10 600 10 3,385 5 Ammonical Nitrogen (Max.) 399 - - - - 237 6. Phenolic Compound (Max.) 13 - - - - 8 Table 2: Characteristics of treated effluent Sr. Composite Design Effluent CETP Parameter Unit No.
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