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fiqq: Carbon Di-sulphide (50,000 TPA) Manufacturir.rg Unit at Plot No. Z-711 & Z-8lPart.

Taluka vagara, Dahej SEZ, District Bharuch, Gujarat by M/s Indo Baijin chemicals Pvt.

Ltd. - Environmental Clearance reg.

ri<tf ;. Ministry's letter no .l-11011/301/2011-lA Il(l) dated 24 12.2012

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ql{f, g{-o-rtGOVERNMENT OF INDIA

csf{i'r. T{ Tq qdqtg qM'q riildqMINISTRY OF ENVIRONMENT, FOREST &

CI-IMATE CHANGE

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2. Mr. Ajit Bagade, Chief Operating Officer (COO), Z-7l1Vagra, Dist: Bharuch, Guj arat

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II

I \ Monitoring the Implementation of Environmental Safeguardst nlinistry of Environment & Forest & Climate Change

1 Western Region, Regional Office, Bhopalt uoNrroRrNc REPoRT

PART_ IDATA SHEET

Project type : River- valley/ Mining/Industry/ Thermal/ Nuclear/Other (specily)

lndustry

2. Name of the pro ject indo-Baijin Chemicals Pvt. Ltd. - Ptoduction ofCarbon Di-Sulphide

3 Clearance ietter (s)/OM No. ancl date F. No. J - 11011/301/2011 IA II (D dated 24'n

December. 2012

4. Location :

a) District (s)

b) Stare (s)

c) Location Latitude/Longitude

Bharuch

Gujarat

Latitude: 2lo 42' 32.64" N

Longitude: 72037'08.16"E

5. Address lbr correspondence

a) Address of the Concerned Project ChiefEngineer (with Pin Code & telephone/

telex/ fax numbers)

b) Address o[ the Executive Project

Engineer / Manager

Mr. Ajit Bagade

Chief Operating Officer (COO)

Z-711 & Z-8lParr, Dahej SEZ. Tal:

Bharuch. Guj arat

Mobile No: +917046833369

Email : abaeade-ibilOmodi.com

Mr. Hemant Kulkarni

Chief Manager (CM)

Z-711 & Z-\lPart, Dahej SEZ, Tal:

Bhanrch. Guj arat

Mobile No: +9 17 490022008

Email : hkulkami-ibj @modi.com

Vagra, Dist:

Vagra, Dist

Salient features

a) Of the project

b)Of the EMP

Break up ofthe project area

IBJ is the leading manufacturer of CSz

India and the first of its kind in India to

Green Technology,

o IBJ has maintained ZLD.

Sulphur recovery efficiency is being 99.9 'A'highest achieved in India till date in such plants.

o Sewage is treated in STP located within

premises,

o Industry has valid membership of TSDF site -BEIL, Bharuch for incineration, treatment

and disposal of hazardous waste.

. Sulpher recovery unit is provided for the

99.9%o recovery of SulPher.

. There is no discharge of the industrial effluent

outside company premises and maintained

ZLD.

r Industry has developed greenbelt area lvhich

is 337o of the total plot area.

o Industry has facility for in-house monitoring

and analysis of effluent.

Environmental Audit and EnvironmentMonitoring through third party are beingconducted

S.

No.Particulars

Area('n')

Process Plant 15.999

2. Ground Coverage area 11,931

3. Future expansion 3,569

4. Green Belt 16,501

Total s0,000

ln

use

a)

b)

Submergence area: forest & non-Forest

Others

NIL

NIt.

8. Break up of the project affected populationwith enumeration of those losinghouses/dwelling units only agricultural land

only both dwelling units & agricultural land

& landless laborers/artisans:

a) SC, ST/Adivasib) Others

(Please indicate whether these figures are

based on any scientific and systematic

survey carried out or only provisional

figures, if a suryey is carried out give

details & year of survey)

NIL

NIL

9. Financial details :

a) Project cost as originally planned and

subsequent revised estimates and theyear of price reference

Rs. 250 Crores as on 2014

b) Allocation made lor EMP with itemwise and year wise break-up

c) BC ratio/IRR and the year of assessment

d) Whether @ includes the cost of EM as

shown in the above

e) Actual expenditure incurred on the

project so farf) Actual expenditure incurred on the EMP

so far

Allocation made lor Environmental management

plan is attached as Annexure- l .

10% for the year 2016-2017

YES

Rs.21,67,02,635.00

10 Forest land requirement

a) The status of approval for diversion oflorest land lor non-forestry use

b) The status ofclearing 1-elling

c) The status ofCA, ifanyd) Commerts on the viability &

sustainability of CA program in the lightofactual field experience so far

NOT APPLICABI,E

l1 The status of clear falling in non-forest

areas (Such as submergence area or

NOT APPLICABLE

reseruoir, approach Roads.), if any withquantitative information required.

12 Status of construction (Actual &lorplanned)

a) Date of commencement (Actual &/orplamed)

b) Date of completion (Actual &lorplanned)

04105120),1

31/0312014

l3 Reason for delay If the project is yet tostart.

Unit is operational since 2014

14 Dates of site visitsa. The dates on which the project was

monitored by rhe RO on previousoccasions, if any

b. Date of site visits by RO, MoEF&CCBhopal, for this monitoring report

0st08t2016 ( by GPCB)

06.04.2011

15 Details of correspondence with PA forobtaining action plans/information on status

of compliance to safeguards other than theroutine letters for logistic supporl for sitevisits.

Last Six Monthly compliance report was submitted

in 28th Feb.2o17.

Date Letter from RO Date Reply from PA

(i) Query Letter received from Regionaloffice, MoEF, Bhopal vide letter no.5-9/2013 (ENVy205 dated 31.03.2017

(i1) 06.04.2011 E-mail seeking modifiedcomprehensive compliance

(i) Six monthly compliance report submitted to

Regional office, MoEf, Bhopal by letter no.

IBJ/MoEF, Bhopal by letter no. IBJ/MoEF-BL/2017 /04 dated, 28.02.2017

(iD Revised compliance report with request lorcertified compliance report of our existing EC

submitted vide letter no. IBJ/MoEF-PL12017105dated 11.03.2017

(iii) Revised consolidated six monthly complianceReport vide letter no. IBJ/MoEF- BL12017106 dated08.04.2017

(iv) Email dated 18.04.2017 stating the position ofcoufi case and show cause/ closure notice-

Annexure 2 - GPCB site visit report

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, PART*II&iltI DESCRIPTIVE REPORT ON STATUS OF COMPLIANCE FORTHE PERIODI OF APRIL 2016 , SEPTEMBER,2016 TO CONDITIONS OF,

ENVIRONMENTAL CLEARANCE AND ENVIRONMENTALMANAGEMENT

Ref. No. J/ll0ll 1301 120o. rIl-IA-II I datecl.24.12.2012

,i; I conditions Compliance status

Specific Condition

Stack of adequate height to be provided to tailgas treatment unit & flue gas reaction fi:rnace asper CPCB / Guj arat Pollution Colttrol Board(GPCB) guidelines.

The flare system shall be provided as per nonns.

The process emissious [(CS:, HuS, SO2. NOx.HC (Methane & Non * Methane)l & VOCsfrom various units shall conlbrm to thestandards prescribed under the Environment(Protection) Act, 2008.At no time, the emission levels shall go beyondthe prescribed standards.fhe system shall be interiocked with thepollution control equipments so that in case ofany increase ir-r poliutants beyond permissiblelirnits, plant shall be automatically stopped.

PP submitted as under:

As per the CPCB guidelines H: 14 x Q^0.3 -14 x 8.54^0.3 = 26.65 m for flare stack and IBJhas provided 30 m stack height to flare system*'hich is as per nol'ms.IBJ have provided Tail gas treatment unit &l1ue gas reaction lurnace having 80 m stackheight as per CPCB/GPCB guidelines.IBJ have provided 30 meters stack height to theflare system, which is as per GPCB norms.complied

PP submitted as under:Monthly rnonitoring for process emissionsfi'om Furnace has been done regularly.Stack monitoring analysis report by third partyand monthly comparison are attached asAnnexure -.1. All the emissions are wellwithin the GPCB norms. Summarv ol theresults are mentioned below:

S.

No Particulars

Parameters

PM

(mg/Nm1

Soz(ppm)

NOx

(ppm)

HC

(gm/

kw-hr)

1

ProcessGas

0-1012-22

3-130

2.D. G. Set -lOOO KVA

47-69

20-27

16-

361.1-1.8

3.D. G. Set -lOOO KVA

43-63

2l-JI'

12-39

t_)

1.8

t.

lt.

1.< 4.0

The analysis is carried out by NABLAccredited & MoEF appler,gd laboratory ollvVS Unistar Envirorunental and Research LabsPvt. Limited. GIDC Vaoi. Di: Valsad

Continuous online stack monitoring tbr theparameters SO2 & H2S has been provided at theprocess gas emission and connected with theDCS control room. Photographs of the sameare attrched as Annerure - 5.complied

GPCBLimit 50100t50

llL

Sulphur recovery unit (SRU) shall be installedfor control ol H2S emissions and 99.9 %elficiency ofthe SRU shall be maintained.

Continuous on-line stack monitoring for SO2and HrS shall be caried out. Efficiency of SRIIshould be monitored regularlv and maintainedproperly.


o SRU is installed lor control of H2S emissionand 99.9% efficiency ol the SRU ismaintained. SRU is monitored monthly andmaintained properly.

o Summary of or.rline stack monitoring report tbrIast six months is attacl.red as Annexurc - 18.

Continuous online stack monitor.ing for theparameters SO2 & H2S has been provided at tl.reprocess gas emission and connected with tlreDCS control room. Photographs ol the sameare attached as Annexure - 5.complied

lv,

Record of sulphur balance shall be rlaintained atthe unit as part of the environmental data onregular basis.

The basic component of sulphur balance includesr:lphur input through feed, sulphur or-rtpr:t fion.runit through products, byproduct (elemer.ttalsulphur), atmospheric emissions etc.


o Record of Sulphur balance is nlaintained at tlteunit as part of the environmental data regularly.

o The basic component of suJphur balar.rceinclude sulphr-rr input through feed, sulphuroutput from unit through products. byproduct(elemental sulphur). atmospheric emissions e1c.

are attached as Annexure - 22.Complied.

AnTbier.rt air quality data shall be collected asper N.A AQIS starrdards norified br rhe Minisrryvide G.S.R. No. 826 (E ) daled l6rr' Seprember.2009.

The ievels ol PM1e. SO:, NOx. H2S, VOC andCS2 shall be monitored in the ambient air andemissions from the stacks and displayed at acor.rvenient location near the main sate of the


e Ambient Air quality rnonitorir.rg is carried outat three locations within the premises which ismentioned below:

I . Near Main Gate Dorvn Wind direction2. Near RRU Unit3. Near MSPU Plant Up Wind direction

o Arnbient air analysis report and nonthlycomparison of ambient analysis repoft areattached as Annexure - 6. All the results are

company and at impofiant public places.

The company shall upload the results ofmonitored data on its website and shall update

the same periodically.

It shall simultaneously be sent

office of MOEF. the respectiveCPCB and the GPCB.

to the RegionalZonal office of

In plant control measures for checking lugitiveemissions lrom all the vulnerable sources shall

be provided.

Fugitive emissions shall be controlled byploviding closed storage, closed handling &conveyance of chemicals/materials, multi

S.

No.

Locations

Parameters

PMroPMz.

5Soz

NOx

HuS CS:

!rglm3

I

NearMainGate

65-86

18-26

13-21

21-32

NotDetected2.

NearRRUPlant

68-81

)1

2621-25

32-38

3.

NearMSPUPlant

73-84

21-27

l8-23

28-36

4.GPCBLimit

100 60 80 80 500 2000

The analysis is carried out by NABL Accredited& Mol F annror ed laboraton of M S Uni:(ar

Environn.rental and Research Labs Pvt. Limited.GIDC Vapi. Di: Valsad

well within the CPCB norms. Summary of the

results are mentioned below:

The monitoring results are displayed near the

main gate of the company.

Company is uploaded the results of monitoreddata on its website indobaijin.com and update

the same periodically.

o Company is sent the monitoring results to

regional oltrce of MoEFCC. GPCB & CPCB

and copy of the same is attached as Annexure

- 17.However, it has not been confirmed if the same

has been carried out as Per NAAQESstandards notified by the Ministry vide G.S.R.No. 826 (E) dated 16th September, 2009' Aslo,the adequacy of three stations that too withinthe premises need to be explained as normallyl0 km diameter is the study area.

Partly complied.

PP suhmitted as under:

. fhe plant is automated & whole process isoperated in closed loop thus avoid any release

to atmosphere.

. A1l chetnicals except Sulphur stored in closed

storage.

cyclone separator and water sprinkling system.

Dust suppression system including watersprintling system shall be provided at loadingand unloading areas to control dust erlissions.

Fugitive emissions in the work zoneenvironment, product, raw materials storagearea etc. shall be regularly monitored.

The emissions shall conform to the limitsstipulated by the GPCB.

To control the Sulphur dust emission. rroltenSulphur is used instead of melting granularsulphur based on availability.

Water spray system is provided at CSl loading

To avoid fugitive emission.60 odd lield gas

detectors with alarm in DCS room are providedat strategic locations in the plant.

Also u,ork zone monitoring report is doneregularly by third party and is attached as

Annexure - 6.

Information notconformity rvithprovided.

Partly complied.

provided with regardGPCB norms. This is to

tobe

vll. For further control of fugitive emissions,following steps shall be followed:


L Closed handling system shall be provided forchenicals"

o "We have provided close handling system fbrall raw materials and finished products.

2. Reflux condensel shall be provided over reactor. r We have provided Reflux condenser over allreactors.

System ol ieak detection and repair olpump/pipeline based on preventivemaintenance.

We have provided I-DAR with 60 odd tield gas

detectors at strategic locatior.rs all over the plantwhich are conllected to DCS control room.Also checked bv using hand held detectors.Preventive maintenance schedr-rle is made &strictly fbllowed.

4.

The acids shall be taken from storage tanks toreactors through closed pipeline. Storage tanksshall be vented through trap receiver andcondenser operated on chilled water.

. We have provided closed handling and pipinglor hydro chloric acid. which is srored in rhe

tank and handled through closed pipirrgnetwork and tlre tank is provided r,rirh reqLrircd

srlet) godgcts like rrap Tcceirer. PRV. clriller.r ent, flrme arTeslor clc.

5.

Cathodic protection shall be providedunderground solvent storage tanks.

the o Not applicable, as we are not using any solvent.

Regarding applicabilify of cathodic protection,a call may be taken by the Ministry.Complied otherwise

The gaseous emissions frorn DG set shall bedispersed through adequate stack height as perCPCB standards.

Acoustic enclosure shall be provided to the DGsets to mitigate the noise pollution.

A proper Leak Detection and Repair (LDAR)Program lor CS2 industrl shall be prepared andimplemented as per CIPCB guidelines. Focusshall be given lor prevention of fugitiveemissions for which preventive maintenance ofpumps, valves, pipelines are required.

Proper maintenance of mechanical seals ofpumps and valves shall be given.

A preventive maintenance schedule lbr eachunit shall be prepared and adhered to.


. D. G. Set having stack height of 11 m isprovided. Analysis reporl of the same areattached as Annexure - 4 and are well withinthe norms.

However, it has not been established if thestack height of DG set is as per CPCBnorms. This has to be submitted.

Partly complied.

o Acoustic enclosure is provided to the D. G. Seto mltlgate the norse Dollutton.

S.

No Particulars

Parameters

PM

(mg,t'{m

1

Sou(ppm)

NOX

(ppm)

HC

(g-/

kw-hr)

ID. G. SetlO(]O KVA

4t-69

20-27

16-36

1.1-

1.8

2.D. G. Set -lOO() KVA

13-63

21-i0

t2-39

t1

1.8

t. GPCBLimit 150 100 50

< 4.0

flre anallsis is carried our b) NABLAccredited & MoEF applevqd laboratory ol.

M/S Unistar Environn.rental and Research LabsPvt. Limited. GIDC Vani. Di: Valsad


o Leak detection is done with 60 odd online gasdetectors proVided at strategic locations allover the plant which are connected to DCScontrol loom.Preventive Maintenance addresses preventive,predictive, coruective & break downmaintenance to avoid unexpected break downin pumps. valves, instruments, equipment &pipeline.Periodically monitoring of the emissioninternally and through GPCB recognized thirdparty laboratory.

Daily shift wise monitoring of specificsuggested Iocation I,here leakages possibilitiesshould be there by cletector and iecord maintainit in daily observations.Total 15 Nos. of mobile H2S and CSz gasdetectors are provided in diflerent depanmiriwithin plant prerrises.

X.

.{s proposed, online cor.rtinuous detectingsensors at all locations where there is likelihooiof presence of CS: and H2S along u,ith alarn.rshall be installet'i

Effective measures shall be taken immetliately,when monitoring results irrdicate above thepemissible limits.

The plant shall automatic shut dor.vn if anvl'ailule obsen ed in SRU. llare svsrenr rnd o;ercritical system.

o Continuous online stack monitoring lras beenprovided at the process gas entission anciconnected r',,ith the DCS control room.Photographs of tlre sante are attached asAnnerurc - 5-

o Leak detectior.r is done with 60 odd online fleldgas detectors provided at strategic locations allover the plant which are contrected to DCScontrol room.

r Process interlocks are provided on DCS controito give diff'erent rypes ol alarm (LL. H. HHetc.) uirh interlock ro stop or resrr.ict rheOpetaliolts.ilt.Ca5e an) procc55 up5et & OpetalCplanr tn sa le Iim its.Complied

I-{owever PP is silent onwhich nav be provided.Dee med complied.

PP has submitted as uncler:

PP submitted the following:


rhe CPCts g Lride lincs

o Fresh u'ater is provided by GIDC. perntissionletter olthe same is attached as Annexurc _ 7.o Fresh water requirentenl is zl20 mr/dav ancl isnut exceedinB 750 nrr dar.

o Cround uatcr is rror berrrg u.ec1.Com plied

Intlrrsrrial eflluenr generariorr from tLnir is 7gttt da; and i> rrot er,ceedi p 204 rrr'day

. Ef}luent is treated in elfluent Ueatment piantand treated water is recl,c lcd/re used in coolinirtower within factory prentises

. No process effluent is being discharged in andaround the pro.ject site.

Total fi^esh waler requirement fi.om GIDC l,,atersupply shall not exceed 750 n.r3/ciay.\o grorrrrd \ aler shall be u.cd.

The indu:trial ellluent gell(ration Iront unirshall not exceed 204 ml'dav

F'f}luenr shall be treated in tt.,e "tttL,.nt

treatmentplant and treated water shall be recycled/reuseJwithin factory prenrises.

No process effluent shall be discharged in andaround the project site.

Water quality o1. lreated efTluent shall beo Water quality of treated effluent is beins

i1

ii

monitored regularly and nonitoring repofi shallbe submitted to the GpCB.

Ser.vage sl,all be treated in the STp.

] No efi)uent shallindustrial premises

"iii. I rhull be adopted.

be discharged outside theand zero discharge concepts

X I\'.

Process elfluent/anv wastewater shall not bealiolved to mix u,ith storm \\'arer.Storm water dlain shall be passed through guar.dpond.

monitored regularly and monitoring report issubmitted to the GPCB regularly.Chlorine demand of sewage varies with respectto time therefore chlorine demand analysis isnot done and maximLrm calculatedconcentration of chlorine is dosed to get thelesults of free residr.ral chlorine > 0.5 to complyu'ith the consent limit.

Sewage is treated in STP. Monitoring report ofthe same is attacl.red as Annexure - 8. All theresults are w.ell within the GpCB nonns.

Complied


o Elfluent is treated in effluent treatment plantand treated water is recycled/reused in coolingtower within factory premises.

r Treated etJlr"rent is being reused in gardeningr.vithin lactory premises.

o No process elfluerrt is being discharge outsidetl.re ilrclustrial premises and zero dischargeconcept is adopted.Complied


. Separate line is provided lor effluent and stormwater dlain.

. Stornt water drain is passed through guardpond.

r Storm water drain network is designed in sucha way that wastewater is not mix with stormwater by any means"Complied

Hazardous chemicals shall be stored in tar.rks.tank iarms. drurns. carbol: ctc.I]lame aresters shall be provided on tank farm.

Solvent transler shall be by pumps.


. We have provided isolated storage tank loreach hazardous liquid chemicals withnecessary salety measure like flash back/ flameanesters, dyke, fixed gas detector. fire hydrantsystems. cooling svstems. etc.

r All chemicals are transfer in closed loop usingpumps & piping.

o No solvent is being used within premises.

Complied

As ploposed. Iurnace slar.:. sludgc lronr srrlphrrrirlrer shail be sent at conlnton inciner.rtionfacility. ETP sludge and evaporation salt shall

.0.''..r::, 1o I realmenr Srorage Disposal Facilirf

( 1 5Dl ) tot' hazardous wasr--

The Corrlp1nl shall s11i..111 corrplr r.rith thelr-rlcs arrd puideline: under Vanulccrtu.e. Storapeand Imporl of Hazardous Chernicals (MSiHAjRules, I 989 as amencled tinre to time.

All Transportation of Hazardous Chemicalsshall be as per the Motor Vehicle Act (MV6,1989

PP submitte d as under:

Complicd

PP submif ted as under:


. Furnace slag, sludge lrom sulphur ftlter. isbeirrg serrt Jt cunlt.tun irre irrcrator at H II .Bharuch.

. !T^l:dq" and evaporation salt is 6eing sentat TSDF site of BEIL. Bharuch.. BEIL, Bharuch rnembership certificate altdlatest.manifest copy which is to be dirpor;;iiatest by 28 1212016 are altache.l as Annexu.e*9.

. industry has obtained authorization i. e. CC&Afrom GPCB vide letter no: GpCB/BRC]I{_B_CCA/ID-39306/227931 dated gtr, Ocrot;.20.14 which is valid up 1o 1.rAprii.20l9 i;;collection. storage altd disposal of hazar.clouswastc under the Hazardous Waste{\4aDa!:entcnt. Hrndling lrrd I rans.Bourrchrrlvto\ ement) Ruler. 2009 and amendcd a. .)ltdate for managemenr ol Haza:.dous wastes.

o Copy of the CC&A is attached as Annexure _10.

. We have. provided adcquate fire tightingslstem within the prenrises.Fir.e hydranr l'ayouiis attached as Annexure _ l l along r,r,ithfirefighting system.

Complied

XVl] 1

. ('un)paD) is 111ig1l1 eotnpllirrg r.rith tite rulcsrnd grrideliles rrndcr Manulacru,e. Storug. .nJIn.rpoft o1' Hazardous Chemicals fv'irHll]Rules. 1989 as amended ti-e to iinle anihighlighr of the same are mentioned belou,:

o Rule..9,. isolaied storage facilit), fbr CSr isprovided.

o Rule .17" Iabel. mark. tag and docuntents areprovided to e\rery container ol hazardous

chcnricaio All Transportation ol Hazardous Chemicals is

being carried out as per the Motor Vehicle Aci(MVA), 1989.

Complied

The company shall obtain Authorization forcollection, storage and clisposal of hazardous\\,aste under tl.re Hazardous Waste

l)1nne"r.1. Harrdling lrd fr.r n,_ Bnil rda"r.1ivlo\ en)ent) Rulc>. l00g and antenJcd ,r o,r darefor nanagement of l{azardous wastes and priorpermission fi.om GpCB shall be obtuin"j fo.disposal of solid / hazardous waste in the TSDF.

Measures shall be taken lor firefighting lacilitiesin case of emergency.

The company shall undertake following wasteminimization measures :-


Metering and control of quantities of activeirrgred ierrt" to minimize waste.

. Waste reduction is a continuous improvementprocess and effofi is being/u'ill be made tomake improvement in this field.Specific response not given,

Reuse of by-products frommaterials or as raw materialprocesses.

the process as rawsubstitutes in other

Sulphur is being feed fiom SRU pit to RRUreaction tube by sulphur feed pump. Excess 8-12% Sulphur being f'eed to control thereaction and treatir.rg NG as limiting factor. InRRU suiphur is being reacted with purifiedNG in presence of heat supplied by desorbedNG at 880 degree C. In reaction both CS2,

H2S is generated. Excess Sulphur is beingremoved in CSr distillation tower as bottomcut and sent it back to MSPU. CS: is beingdistilled out and sent to storage tank fbrquality clearance and dispatch. H2S is beingremoved from the system as top cut and sent itto SRU. H2S is being converted in to SO: andsimultaneously to Sulphur by catalyticconvertor and condensed to liquid SLrlphurthrough Sulphur condensers and sent back toSulphur pit. Remaining Sulphur containingrnaterial like S02, Sulphur vapor, COS. C52 isbeing converted to H2S through catalyticconvefior in TGTU. H2S is being stripped offlrom the gas through Amine absorptionsection. Again HzS from the absorptionsection is being removed through Amineregeneration section and recycled back toSRU section.

Use of automated filling to mininiize spillage. Company has automated leeding system forCS: tanker filling system to control overllowand maintain safety and protection ofenvironment due to spillage or overflow.

Use of Close Feed system into batch reactors. r Company has DCS automated closed system tocontrol and operate process in safe manners. Incase any leakage or abnormal situation plantfixed detectors detect and identified at DCScontrol room penal and process control alamsalso activated and control automatically.

Venting equipment through vapour recoverysystem.

All vents are connected through recoverysystem and then connected to incinerator.

Use of high pressure hoses for equipmentclearirrg to reduce waslewaler generation.

o Pressure vessels and piping regularly checkedand tested by competent person. Continuouslydaily shift wise inspection.

CompliedA1l the measures proposed in the riskassessment study shall be implemented.


. A mitigation measure in the risk assessmentstudy is being implemented is attached asAnnexure - 19 and highlight of the somepoints are mentioneJ belou :

o Buller vessel is provided instead ol flamearrestor on atmospheric vent as per S. No. 5 ofmitigation measures.

o An emergencl' shutdown valve closing on highpressure a1 the inlet ol natural gas frompurification unit is provided as per S. No. l8 ofrnitigation measures.Complied

XX] -

The unit shall make the arrangement forprotection of possible fire hazards duringrnanufacturing process in material handiing. Firefighting system shall be as per the norms.


o We have provided adequate fire fightingsysten.r within the premises. Fire hydrant iayoutis attached as Annexure - 11 alons with flrefighting system.Complied


o Corlpany l.ras carried out occupational healthsurveillance of the workers on a regular basisand records maintained as per the Factories Actwhich is attached as Annexure - 12.Complied _

PP submitted as undcr:

. The struclural design is done as per relevanlcodes to negate the threat of environmental andother damages.Deemed Complied

XX11 ] Occupational healrh surveillarrce of rhe uorkersI shall be done on a regular basrs and records

maintained as per tl.re Factories Act.

Since the site falls under the earth quake zone-III and proper care will be taken at the designstage itsell lbr this aspect.

XX111

XXIV

Thick greenbelt shall be developed in 16501 m2out of total land 50,000 m2 in and around theplant premises to mitigate the ellects ol fi-rgitiveemissions all around the plant as per the CPCBguidelines in consultation with DFO. Selectionol plant species shall be as per the CpCBguidelines.


. ( unlpany has dcr eloped gr.eerrbelr irr lrr. j0lnr'in alrd around plant prernise:.

o More than 2,000 Nos. of trees are plantedwithin pro.ject site.

o Trees like Ficus, ueem, Sam. Ashoka. RoyalPalm" Peepal, Bakul. Gulmohar. Tikorna.Bangali Baval. Badam, Banyan. Bamboo.Ja-rrd arc planred u itlrin prernises.

. Photographs ol greenbeit within premises areattached as Annexure - 16.Horvever all along the periphery/ boundryproper green lvas not found. Alsoconsultation with DFO has not been heldand it also is not clear if CPCB guideline has

been followed.Partly Complied

Provision shall be made fbr the housing for theconstruction labour within the site with allnecessary infrastructure and lacilities such asfuell for cooking, mobile toilets. mobile sewasetreatment plant. safe drinking water. mediJlhealth care. crdche etc. The housing nray be inthe tbrm of temporary structure to be removedafter the completion of the project. All theconstruction wastes shall be managed so thatthere is no impact on the sunoundingenvirorunent.


o Local worker was employed duringconstruction phase and hence housing facilitywas not provided to the construction workers.

. Sanitation. drinking and all other welf-arefacilities were provided and mair.rtainedthroughout the construction phase.

Deemed Complied since construction is over

General Conditions

The project authoritiesthe stipulations madePollution Control Board.

n.rust strictly adhere toby the Gujarat State


o industry l.ras obtained CC&A from GpCB videGPCB/BRCH-B-CCA/ID.

383061227931 dated 9r1'October. 2014 which isvalid up to 1'r April, 2019. Copy of the same isattached as Annexure - 10.

. Company adheres to all stipulations made bvthe GPCB lor rhe obrained CC&A and NOC.However, condition wise repoft has r.rot beensubmitted. This requires to be submitted toassess the compliance.

Inconclusive

No furlher expansion or modifications in theplant shall be canied out without prior approvalolthe Ministry of Environment and Forests.

L.r case of deviations or alteratiotrs in the projectproposal liom those submitted to this Miniitrvlor clqrrarree. a liesh r.elerence ,hall be rnade tothe Ministry to assess the adequacy ofconditions imposed and to add additionalenvironmental protection fleasures required, ifany.


. Company assures that no further expansion ormodificatior.r in the plant shall be carried outwilhout prior approval ol. MoEF&CC.

o A fresh reference shall be made for anvdeviation & change in the plant.

Complied

iij. J he locutiorr' .,f lrnhierrt air qurlitl monitorirrgstations shall be decided in consultation with theState Pollution Control Board (SpCB) and itshall be ensured that at least one stations is


. Compan)- has set up three locations asmentioned in specific conditior.rs (v) and inconsultation with GPCB.

o Ambient Air quality monitoring is carried out

installed in the upwind and downwind directionas well as where maximurn srorutd levelconcentrations are anticipated.

The overall noise levels in and around the plantarea should be kept well within the standards byproviding noise control measures includingacoustic hoods, silencers, enclosures etc. on allsources of noise generation. The ambient noiselevels should conform to the standardsprescribed under Environment (Protection) Act"1986 Rnles, 1989 viz. 75 dB (A) (day time) and70 dB (A) (night time).

at three locations within tl.re premises which ismet.rtioned below:

L Near Main Gate - Down Winddirection

2. Near RRI.I I lnit3. Near MSPU Plant Up Wind

direction. Ambient air analysis repofi and monthl)

comparison of ambient analysis report areattached as Annexure - 6. All the results arewell within the GPCB norms. Summary of theresults are mentioned below:

However, it is to be decided rvhether the PPshould undertake monitoring l'ithin 10kmboundary which is the study area for EIA andperiodically compare with base line data.Complied for the present.


. Noise monitorir.rg has carried out by third party.o Noise level was high during day time at CS2

loading point due to release of excess sleamth rough vent in almosphere.

o Monitoring results of the same are attached as

Annexure-13.

S.No.

Locations

Parameters

PMroPMz.

5SOr

NOx

H:S CSz

pg/m'

1

NearMainGate

65-86

18-26

13-21

2t-12

2.

NearRRUPlant

68-81

21-26

2t-25

32-38

t.NearMSPUPlant

l3-84

21-2l

l8-23

28-36

4.GPCBLimit 100 60 80 80 500 2000

The analysis is carried out bv NABL Accredited& VoEF appro"eO iabo

Environmental and Research Labs Pvt. Limited.GIDC VapLDi: Valsad

The PP has not submitted comparison ofnoise level with the permissible limit and didnot indicate as to what measures a takenwhen noise level is high.Partly Complied

i

v1.

I

The Company shall harvest rainwater from therooltops olthe buildings and storm water dr.ainsto recharge the ground water and use the samewater lol the process activities of the project toconserve fiesh water.


We have already starled work for rain waterharvesting and will be completed within onemonth time. And also rain water will be reusein the process to minimize the fresh waterconsumptior.r.

The action should have been taken earlier asthe EC is sulficiently old.Not Complied

1'raining shall be ir.r.rparted to all employees or.r

safety and health aspects ol chemicals handling.

Pre-emplovment and routine periodical medicalexaminations for all employees shall beunde(aken on regular basis.

'fraining to all employees ou handling ofchernicals shall be imparted.


Cornpany is being regularly provided trainingto all en.rployees on salety and health aspects olchemicals handling.Records on training to all employees onhandling ol chemicals are attached asAnnexure - 20.

Pre-employinent and routine periodical medicalexaminatious lor all employees are beinglcgularll carried out and repon of the same isattached as Annexure - 12.Complied

Vll.

\ 111.

Usage o1' Personnel Protection Equipments(PPEs) by all en.rployeesl workers shall beensured.


. All emplo.vees/workers is being regularly usedPPEs.

Complied

The con.rpany shall also comply with all theenvironmental protection measures andsalegr-rards proposed in the documents subnittedto the Ministn.

All the recommendations made in the EIA/EMPin respect of environmental management. riskmitigation measures and public hearing relatingto the project shall be irnplemented.


Sewage is lreated in STP located withir.r premises.

o L.rdustry has valid membership of fSDF site -BEIL, Bharuch for incineratior.r. treatment anddisposal ol hazardous waste.

e Sulphur recoverv unit is provided lor tlie99.9% recovery of Sulphur.

o There is no discharge of the industrial effluentoutside company prernises and mair.rtained7,LD.

. Industry has developed greenbelt area which is33% ofthe total plot area.

. Industry has facility for in-house monitoringand analysis of effluent.

Environmental Audit and EnvironmentMonitoring through third pany are beingconducted regularly.

The company needs to submit what has beenapprove and proposed in the EIA report vis_i_vis what has been actually implemented onground along with investment made.

Partly Complied

o Company has Environmental Management Cell

ll,l4C, in.pt.ace equipped "i,h

-fril n;;;iraoorarory lacilitl .

r Detail of EMC and laboratory are attached asAnnexure - 14.

o Compary 's Management belier es insuslarnable management ol natural resortrcesan^d

_errvirorrn rerrt ol project ,i," a ,rrro,rrar5,

areas Ior ralriclr funds r,rill lot be a co,rstraint. 'Complied



.IBJ management believes in sustainablemanagement of natural resources andenvironment ofproject site. Adequate funas u."available for the same.

o The companl :hall proride Acrual erpelditurerncurred on the Enr rronmenral managernentplan so far Rs. 21,67,02,635"00

o The _company shall provide recurringexpenditure incurred on the Environmentajmanagement plan so far Rs. 4j,02,435.00

The cornpany shall unclefiake all relevantmeasures for improving the socio_economiccondllrons of the surroLrnding area. CSRac.tivities shall be undertat

"n Uy inuotuing lo"ui

villages and administration.


Shall be Complied.

o The industrr was running in ioss and has norbeen able ro reach rhe financial r iabilirr.FIouerer. very recenlly indurtry has ,taneJplcl''lns Llp and givsn r: undertaking ro irririarethe CSR activities in the next financial vear.Undenakirrg of rhe .ame ,, ur,u.h.,l

-1,,

Annexure - 21.

Not Complied and a view may be taken

'fh". company shall undertake gca-developntental measures inclutling

"ommunitvuellare. nreasures in the pro.i"ar "urau

io,] rt.,"o\ era rmprovement of the en\ ironmeltl.

A separate environmental management cell

13uin1ed wirh lull fledged Iaborarory lacilirie>

5raU De set up to carrv out tlre errviroru|entalmanagement and monitor.ing firnctions.

The company shall earmark sufficient fundstoward capital cost and recurring.or, par rnnrrnto, implement the conditions .tipulat"a Uy it eMinistry of Environment and Forests u. *!f t"u,the State Government along u,ith d;implen.rentation schedule lor ali ihe conditionsstipulated herein. The funds so earmarked forenvironment management/ pollution controlmeasures shail not be diverted for anv othe.purpose.

The PP ought to have submitted the details

of EMP arisen out of GoI and arisen out ofState Govt imposed conditions. Both capexand recurring cost separately. The wholeand important condition has been treatedcasually and it seems company does not haveproper dafa and records in this regard,Partly complied.

xl1t.

A copl' of the clearance letter shall be sent bythe project proponent to concerned Panchayat.

Zila Parisad/Municipal Corporation. Urban localBody and the local NGO. if any, from whosuggestions' repre5enlat iolls. il an1- \ erereqeived while processing the proposal.


r Wc have already sent copy of environmentalclearance to concerned Panchayat in the monthof March 201 3. Also we have put up on ourcompany's website.No documentary providence has beenprovided.

Not Complied

The proj ect proponent shall also submit sixmonthly reports on the status of compliance ofthe stipuiated Environmental Clearanceconditions including results of monitored data(both in hard copics as well as by e-mail) to ther espective Regional Olfice o I MoEF. therespective Zonal Office of CPCB and theGujarat Polldion Control Board. A copy olEnvironmental Clearance and six monthlycompliance status repo( shall be posted on thewebsite of the company.


r IBJ is regularly submitting six monthly reporton status ol compliance of EC conditions by e-mail to Regional Olfice of MoEFCC and thesame comprehensive physical repofi by post tothc Regional olfice of MoEFCC, the respectivezonal office of CPCB and the State PollutionCor.rtrol Board and also posted on the websites'u'w.indobaiiin,com/ehs-conrpligtlegs. Copyof the same is attached as Annexure - 17.

Complied

The environmental statement lbr each lu-rancialyear er.rding 3 1" March in Form-V as ismandated shall be submitted to the concemedState Pollution Control Board as prescribedunder the Environment (Protection) Rules. 1986,as amended subsequently, shall also be put onthe website of the company alor.rg with the statusof compliance of enviror.rmental clearanceconditions and shall also be sent to therespeclive Regional Olfices of MoEF by email.


o Six monthly compliance repofi along with themonitoring data are regularly submitted to thenronitoring agencies.

o Last six monthly compliance report wassubmitted to the MoEF&CC in the month ofAugr:st - 20 16.

o Environmental statement for each financialvear in Form V is being submitted to GPCBand regional office ol MoEFCC and alsouploaded on the wwu'.indobaiiin.com/ehs-sar]1!lj4]1g!!. Copy of the same is attached as

Annexure - 3.Complied


. Copy of the clearance letter has been sent toconcerned authorities and is also available atwebsite of the Ministry.

xl\.

The project proponent shouldLhat the projecL has

environmental clearance by

inform the publicbeen accorded

the Ministry and

copies ol the clearance letter are available withthe SPCB/Committee and may also be seen at

Website of the Ministry at http:/envfor.nic.in.This shall be adverlised within seven days fromthe date of issue of the clearance letter, at leastin two local newspapers that are widelycirculated in the region of which one shall be inthe vernacular language ol the localityconcerned and a copy of the same shor-rld be

lbrwarded to the Regional office of theMinistrv.

IBJ did not received the EC letter by the postand IBJ collect the EC letter from MoEF&CC.New Delhi by hand and immediately given inthe newspaper for advertisement.Information on Environmental Clearance rvas

advertised in two local newspapers as detailedbelow and a copy of the same was also

tbru'arded to the Regional Olfice of theMinistry. The copy of the same is attached as

Annexure - 15.1. Gujarat mitra & Guj arat darpan

March, 2013.2. Times City or.r l6!l'March,2013

16t1'

There was huge delay in publishing in NewsPaper i.e from December to March means 3

months in place of 7 days. PP did notproduce evidence as to when they receivedthe EC letter, In any case such delay maynot be justified.

Not Complied

xvlr.

The project authorities shall inform the RegionalOlhce as well as the Ministry. the date olfinancial closure and final approval ol theproject by the concerned authorities and the date

of start of the project.


r Our total project cost is Rs. 250 Crore as on2014 and finance taken liom Exim Bank and

Union Bank of India. We have started work forthe project in the month of April 2012.We have

already inlormed Regional office as well as

Ministry.Deemed Complied

10.

The project authorities should inlorm theRegional Office as well as the Ministry, the date

of financial closure and tinal approval of theproject by the concerned authorities and the date

of starl of land developrnent work.

PP submitted as below:

We have started land der eloping in ihe monthof April 2012.

However, about financial closure nothingmentioned.

Not Complied

11

The ministry may revoke or suspend tl.re

clearance, if implementation of any of the aboveconditions is not satisfactory.

PP informed that they agreed.

12.

The ministry reserves the right to stipulateadditional conditions if foLnd necessary. Thecompany in a time bound manr.rer willimplement these conditions.

PP stated that they agreed & complied

The above conditions will be enforced, inter-aliaunder the provisions of the Water (Prevention &Control of Pollution) Act, 1914, the Air(Prevention & Control of Pollution) Act, 1981,the Environment (Protection) Act, 1986,Hazardous Waste (Management, Handling andTrans-Boundary Movement) Rules, 2008 andthe public liability insurance Act, 1991, alongwith their amendments and mles.

PP stated that they have noted & agreed tocomply

Summary:

Out ol a total main 46 conditions, it may be seen that 25 are complied ,7 are partlycomplied, 4 are deemed complied, 6 are not complied, 3 are agreed for compliance and 1

is found to be inconclusive. The PP needs to formulate a time bound action plan for fullycomplying with the not complied and padly complied conditions.

(ii) Details of Court cases:

It has been stated by the PP that there is no courl case against the unit.

(iii) Details of Show Cause/Closure Notices

It has been stated by the PP that no show cause or closure notice has been issued against the unit.

Scientist'G'

1

S. No.

Conditions Compliance status

Specific Condition

v.

Ambient air quality data shall be collected as per NAAQES standards notified by the Ministry vide G.S.R. No. 826 (E) dated 16

th September, 2009.

The levels of PM10, SO2, NOx, H2S, VOC and CS2 shall be monitored in the ambient air and emissions from the stacks and displayed at a convenient location near the main gate of the company and at important public places. The company shall upload the results of monitored data on its website and shall update the same periodically. It shall simultaneously be sent to the Regional office of MOEF, the respective Zonal office of CPCB and the GPCB.

PP submitted as under.

Ambient Air quality monitoring is carried out at three locations within the premises which is mentioned below:

1. Near Main Gate – Down Wind direction 2. Near RRU Unit 3. Near MSPU Plant – Up Wind direction

Ambient air analysis report and monthly comparison of ambient analysis report are attached as Annexure – 6. All the results are well within the GPCB norms. Summary of the results are mentioned below:

S. No.

Locations

Parameters

PM10 PM2.5 SO2 NOx H2S CS2

µg/m3

1. Near Main Gate

65-86 18-26 13-21

21-32

Not Detected

2. Near RRU Plant

68-81 21-26 21-25

32-38

3. Near MSPU Plant

73-84 21-27 18-23

28-36

4. GPCB Limit

100 60 80 80 500 2000

The analysis is carried out by NABL accredited & MoEF approved laboratory of M/s. Unistar

Environmental and Research Labs Pvt. Ltd., GIDC Vapi, Dist: Valsad.

The monitoring results are displayed near the main gate of the company.

Company is uploaded the results of monitored data on its website indobaijin.com and update the same periodically.

Company is sent the monitoring results to regional office of MoEFCC, GPCB & CPCB and copy of the same is attached as Annexure – 17.

However, it has not been confirmed if the same has been carried out as per NAAQES standards notified by the Ministry vide G. S. R. No. 826 (E) dated 16

th September, 2009. Also, the adequacy of

three stations that too within the premises need to be explained as normally 10 km diameter is the study area. Partly Complied

Compliance: Since, the laboratory is NABL accredited and follows predefined Set of Procedures, the

2

S. No.


ambient air quality monitoring was carried out by following the IS: 5182, CPCB and AWMA. NABL Certificate is attached as Annexure A.

As per the AAQM guidelines, location within the industrial premises have been selected and IBJ regularly carries out ambient air quality monitoring at three locations within the premises as below:

1. Near Main Gate – Down Wind direction 2. Near RRU Unit 3. Near MSPU Plant – Up Wind direction

Also, we will carry out AAQM for the 10 km study area after the proposed expansion.

vi.

In plant control measures for checking fugitive emissions from all the vulnerable sources shall be provided. Fugitive emissions shall be controlled by providing closed storage, closed handling & conveyance of chemicals/materials, multi cyclone separator and water sprinkling system. Dust suppression system including water sprinkling system shall be provided at loading and unloading areas to control dust emissions. Fugitive emissions in the work zone environment, product, raw materials storage area etc. shall be regularly monitored. The emissions shall conform to the limits stipulated by the GPCB.


The plant is automated & whole process is operated in closed loop thus avoid any release to atmosphere.

All chemicals except Sulphur stored in closed storage.

To control the Sulphur dust emission, molten Sulphur is used instead of melting granular sulphur based on availability.

Water spray system is provided at CS2 loading area.

To avoid fugitive emission, 60 odd field gas detectors with alarm in DCS room are provided at strategic locations in the plant.

Also work zone monitoring report is done regularly by third party and is attached as Annexure – 6.

Information not provided with regard to conformity with GPCB norms. This is to be provided. Partly Complied.

Compliance: As per factory act, concentration for the H2S at work place monitoring should not be more than 10 ppm which is already mentioned in the work place monitoring reports. GPCB has no norms for the H2S for work place monitoring.

Also work zone monitoring report is done regularly by third party and was attached as Annexure – 6 in the Six Monthly Report submitted earlier.

viii.

The gaseous emissions from DG set shall be dispersed through adequate stack height as per CPCB standards. Acoustic enclosure shall be provided to the DG sets to mitigate the noise pollution.

Complied.

D. G. Set having stack height of 11 m is provided. Analysis report of the same are attached as Annexure – 4 and are well within the norms.

Acoustic enclosure is provided to the D. G. Set to mitigate the noise pollution.

S. No.

Particulars

Parameters

PM (mg/ Nm

3)

SO2 (ppm

)

NOx (ppm)

HC (gm/kw-

hr)

µg/m3

1. D. G. Set – 1000 KVA

47-69 20-27 16-36 1.1-1.8

2. D. G. Set – 1000 KVA

43-63 21-30 12-39 1.2-1.8

3

S. No.


3. GPCB Limit

150 100 50 <4.0

The analysis is carried out by NABL accredited & MoEF approved laboratory of M/s. Unistar

Environmental and Research Labs Pvt. Ltd., GIDC Vapi, Dist: Valsad.

However, it has not been established if the stack height of D. G. Set is as per GPCB norms. This has to be submitted. Partly Complied.

Compliance: As per the CPCB/MoEF guidelines H = h+0.2√KVA (= 0 + 0.2 √1650 = 8.12 m) m for D. G. stack and IBJ has provided 11 m stack height to D. G. Set which is as per norms.

xix. The company shall undertake following waste minimization measures: -

a.

Metering and control of quantities of active ingredients to minimize waste.

Complied.

Waste reduction is a continuous improvement process and effort is being/will be made to make improvement in this field.

Specific response not given.

Compliance: We have adopted fully automatic processes so that there is minimal losses and minimal waste generation from the process. Also, we have a zero-liquid discharge system for our unit, hence no liquid discharges are released outside the premises. Moreover, we have a waste Minimization Plan which aims at reduced waste generation. Waste Minimization Plan attached as Annexure B.

xxiv.

Thick greenbelt shall be developed in 16501 m2 out

of total land 50,000 m2 in and around the plant

premises to mitigate the effects of fugitive emissions all around the plant as per the CPCB guidelines in consultation with DFO. Selection of plant species shall be as per the CPCB guidelines.

Complied.

Company has developed greenbelt in 16,501 m2 in

and around plant premises.

More than 2,000 Nos. of trees are planted within project site.

Trees like Ficus, neem, Saru, Ashoka, Royal Palm, Peepal, Bakul, Gulmohar, Tikoma, Bangali Baval, Badam, Banyan, Bamboo, Jasud are planted within premises.

Photographs of greenbelt within premises are attached as Annexure – 16.

However, all along the periphery/ boundary proper green was not found. Also consultation with DFO has not been held and it also is not clear if CPCB guideline has been followed. Partly Complied.

Compliance: IBJ has already developed 16,501 m2 greenbelt with consultation from the DFO area within

project premises. IBJ has carried out plantation along the periphery/boundary on three sides and at front boundary due to parking and main gate, plantation has not carried out. However, 33% greenbelt area as per CPCB guidelines has been carried out within the premises. Greenbelt layout plan and photograph is attached as Annexure C.

B. General Conditions

4

S. No.


iv.

The overall noise levels in and around the plant area should be kept well within the standards by providing noise control measures including acoustic hoods, silencers, enclosures etc. on all sources of noise generation. The ambient noise levels should conform to the standards prescribed under Environment (Protection) Act, 1986 Rules, 1989 viz. 75 dB (A) (day time) and 70 dB (A) (night time).

Complied.

Noise monitoring has carried out by third party.

Noise level was high during day time at CS2 loading point due to release of excess steam through vent in atmosphere.

Monitoring results of the same are attached as Annexure-13.

The PP has not submitted comparison of noise level with the permissible limit and did not indicate as to what measures a taken when noise level is high. Partly Complied.

Compliance: IBJ has already submitted the comparison of noise level with the permissible limit which was attached as Annexure 13 in the Six Monthly Compliance Report and the same is attached as Annexure D for your ready reference. Moreover, proponent provides adequate measures to control the noise such as provide PPEs, rotation of workers, acoustic enclosures, greenbelt and periodical maintenance of equipments etc

v.

The Company shall harvest rainwater from the roof tops of the buildings and storm water drains to recharge the ground water and use the same water for the process activities of the project to conserve fresh water.

We have already started work for rain water harvesting and will be completed within one month time. And also rain water will be reuse in the process to minimize the fresh water consumption.

The action should have been taken earlier as the EC is sufficiently old. Not Complied.

Compliance: Implemented Pictures Attached Annexure G.

viii.

The company shall also comply with all the environmental protection measures and safeguards proposed in the documents submitted to the Ministry. All the recommendations made in the EIA/EMP in respect of environmental management, risk mitigation measures and public hearing relating to the project shall be implemented.

Sewage is treated in STP located within premises.

Industry has valid membership of TSDF site - BEIL, Bharuch for incineration, treatment and disposal of hazardous waste.

Sulphur recovery unit is provided for the 99.9% recovery of Sulphur.

There is no discharge of the industrial effluent

outside company premises and maintained ZLD.

Industry has developed greenbelt area which is 33% of the total plot area.

Industry has facility for in-house monitoring and analysis of effluent.

Environmental Audit and Environment Monitoring through third party are being conducted regularly.

The company needs to submit what has been approve and proposed in the EIA report vis a vis what has been actually implemented on ground along with investment made. Partly Complied

Compliance: IBJ has provided SRU unit as an APCM to control air emissions. All the generated effluent is being evaporated in Combination Cooling Tower, hence unit is a zero liquid discharge unit. All the solid / hazardous wastes is be handled as per Hazardous Wastes (Management and Transboundary Movement)

5

S. No.


Rules, 2016 and obtained TSDF BEIL permission for disposal of solid wastes. The unit has already obtained Consent from Gujarat Pollution Control Board (GPCB) vide letter No: AWH-64179 dated: 02/04/2014, which is valid up to 01/04/2019. Photographs of the same are shown as Annexure E.

ix.

The company shall undertake all relevant measures for improving the socio-economic conditions of the surrounding area. CSR activities shall be undertaken by involving local villages and administration.

Shall be Complied.

The industry was running in loss and has not been able to reach the financial viability. However, very recently industry has started picking up and given as undertaking to initiate the CSR activities in the next financial year. Undertaking of the same is attached as Annexure – 21.

Not Complied and a view may be taken.

x.

The company shall undertake eco-developmental measures including community welfare measures in the project area for the overall improvement of the environment.

Compliance: The Group company already carries out ESC activities for the welfare of nearby population. The industry was running in loss and has no been able to reach the financial viability. However, very recently industry has started recovering from the loss scenario and is committed to give back to the community as a part of its social responsibility. Undertaking for the same is attached as Annexure F. We have already allocated a budget of Rs. 37,50,000 for ESC for welfare activities to be carried out within 5 years from now.

xii.

The company shall earmark sufficient funds toward capital cost and recurring cost per annum to implement the conditions stipulated by the Ministry of Environment and Forests as well as the State Government along with the implementation schedule for all the conditions stipulated herein. The funds so earmarked for environment management/ pollution control measures shall not be diverted for any other purpose.

Complied.

IBJ management believes in sustainable management of natural resources and environment of project site. Adequate funds are available for the same.

The PP ought to have submitted the details of EMP arisen out of GoI and arisen out of State Govt imposed conditions. Both capex and recurring cost separately. The whole and important condition has been treated casually and it seems company does not have proper data and records in this regard. Partly complied.

Compliance: The proponent will allocate adequate funds for environment management/ pollution control, budget plan for the same is attached as Annexure E.

xiii.

A copy of the clearance letter shall be sent by the project proponent to concerned Panchayat, Zila Parisad/Municipal Corporation, Urban local Body and the local NGO, if any, from whom suggestions/ representations, if any, were received while processing the proposal.

Complied.

Copy of the clearance letter has been sent to concerned authorities & has also been put on the company’s website.

We have already sent copy of environmental clearance to concerned Panchayat in the month of March 201 3. Also we have put up on our company's website.

No documentary providence has been provided. Not Complied

Compliance: We have already send copy of Environmental Clearance to concerned Panchayat in the month of March-2013. However, we have not collected any acknowledgment copy from Panchayat. We have also put up EC letter on our company’s website.

xvi.

The project proponent should inform the public that the project has been accorded environmental clearance by the Ministry and copies of the


Copy of the clearance letter has been sent to concerned authorities and is also available at

6

S. No.


clearance letter are available with the SPCB/Committee and may also be seen at Website of the Ministry at http:/envfor.nic.in. This shall be advertised within seven days from the date of issue of the clearance letter, at least in two local newspapers that are widely circulated in the region of which one shall be in the vernacular language of the locality concerned and a copy of the same should be forwarded to the Regional office of the Ministry.

website of the Ministry.

IBJ did not received the EC letter by the post and IBJ collect the EC letter from MoEF&CC, New Delhi by hand and immediately given in the newspaper for advertisement.

Information on Environmental Clearance was advertised in two local newspapers as detailed below and a copy of the same was also forwarded to the Regional Office of the Ministry. The copy of the same is attached as Annexure – 15.

1. Gujarat mitra & Gujarat darpan 16th March,

2013. 2. Times City on 16

th March, 2013

There was huge delay in publishing in Newspaper i. e. from December to March means 3 months in place of 7 days. PP did not produce evidence as to when they received the EC letter. In any case such delay may not be justified. Not Complied.

Compliance: IBJ did not receive the EC letter by the post and IBJ collected the EC letter from MoEF&CC, New Delhi personally and on receipt of the same, the EC letter was advertised in local newspapers namely 1. Gujarat Mitra & Gujarat Darpan on 16th March, 2013 and 2. Times City on 16th March, 2013. Moreover, EC document is also uploaded on company’s website www.indobaijin.com-ehs-compliances

10.

The project authorities should inform the Regional Office as well as the Ministry, the date of financial closure and final approval of the project by the concerned authorities and the date of start of land development work.

PP submitted as below: We have started land developing in the month of April 2012. However, built financial closure nothing mentioned. Not Complied.

Compliance: Industry has obtained CC&A from GPCB vide letter no: GPCB/BRCH-B-CCA/ID-38306/227931 dated 9

th October, 2014 which is valid up to 1

st April, 2019.

Also, IBJ has received EC for existing unit for which compliance report is being submitted was received on 24

th Dec 2012. On receiving the EC, land development work was started and the Regional Office and Ministry

were informed of the same through email on 05.01.2013. On receiving EC for the proposed expansion, we shall inform the Regional Office as well as Ministry regarding the details of financial closure and final approval of the project.

7

ANNEXURE A NABL CERTIFICATE

8

ANNEXURE – B WASTE MINIMIZATION PLAN

Waste Minimization / Reuse / Recycle: The project will be designed to have Zero Wastewater Discharge. This concept has system of Combination Cooling Tower which uses all the wastewater streams in the unit as make up water. This will lead to a saving in consumption of 300 m3/day or 100,000 m3/annum of water. When this concept is compared with reverse osmosis units for zero discharge, it is less power intensive.

ANNEXURE C

GREENBELT DETAILS

Existing Greenbelt

S. No.

Species Number of

trees Year of plantation

1 Neem 70 2016

2 Saru 600 2015 &2016, 2017

3 Ashoka 350 2014,2015,2016

4 Royal Palm 80 2015-2016

5 Bakul 150 2014,2015,2016

6 Gulmohar 80 2014,2015

7 Tikoma 95 2015,2016

8 Banyan Tree 20 2015,2016,2017

9 Bamboo 180 2015,2016,2017

10 Jasud 20 2015,2016

11 Peepal 15 2016,2017

12 Mango 10 2015,2016

13 Ficus 190 2015,2016,2017

14 Badam 10 2016,2017

15 Bangali Baval 250 2015,2016,2017

9

In front of Admin Building

Near SRU & WWTP Boundary wall towards Indofil

Photographs of Green Belt area

10

Greenbelt Layout

11

Annexure D Noise Level Comparison

12

Annexure E

Photographs & budget for Environment Management and Pollution Control Measures

Photographs of WWTP

13

Stack attached with Tail Gas treatment unit

Photographs of Hazardous Waste Storage Area

14

Combination Cooling Towers

Budget for EMP

S. No. Description Budget

(Rs.)

1. IBDC Dahej – Laboratory 7,08,914.41

2. IBDC Dahej - SRU & TGTU 69,34,65,167.46

3. IBDC Dahej – Utility 45,54,85,055.49

4. IBDC Dahej – Wastewater 2,88,77,149.70

Total 1178536286.65

15

Annexure F

CSR Undertaking

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