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ADDITIONAL INFORMATION SOUGHT BY COMMITTEE IN 46 TH EAC MEETING FOR M/s SPECTRUM ETHERS LIMITED AT GAT NO. 367, RASEGAON VILLAGE, TEHSIL DINDORI, NASHIK DISTRICT, MAHARASHTRA

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Page 1: M/s SPECTRUM ETHERS LIMITED - Welcome to …environmentclearance.nic.in/writereaddata/Online/EDS/0_0...ADDITIONAL INFORMATION SOUGHT BY COMMITTEE IN 46TH EAC MEETING FOR M/s SPECTRUM

ADDITIONAL INFORMATION

SOUGHT BY COMMITTEE IN 46TH

EAC MEETING

FOR

M/s SPECTRUM ETHERS LIMITED

AT

GAT NO. 367, RASEGAON VILLAGE, TEHSIL

DINDORI, NASHIK DISTRICT, MAHARASHTRA

Page 2: M/s SPECTRUM ETHERS LIMITED - Welcome to …environmentclearance.nic.in/writereaddata/Online/EDS/0_0...ADDITIONAL INFORMATION SOUGHT BY COMMITTEE IN 46TH EAC MEETING FOR M/s SPECTRUM

Point 1: Action plan to install dedicated incinerator for odorous gas

Reply:

The company has installed multi-stage scrubber system to remove odorous gas as per the MPCB

Consent.

Comprehensive Control system for ‘Air Pollution Control’ is in place, as detailed under.

(i) Multistage scrubber with Hydrogen Peroxide and Specialty Chemicals

(ii) Polishing Scrubber with Caustic lye solution

(iii) Polishing Scrubber with Hypo Chlorite solution

(iv) Multi Cyclone Dust Collector (MDC) for Boiler.

(v) Local Ventury scrubbers with specialty chemicals as scrubber solutions.

(vi) De-odor chemicals are used.

The scrubbers are connected to various reaction systems are provided with negative suction

blower systems.

In order to reduce smell nuisance and the emissions resulting from the processes, we have

provided additional stage dosing of H2O2 at Improved temperature condition, for maximizing the

Effectiveness.

Chemicals having odorous smells like Phosphorous Penta Sulphide and Mercaptans are handling

in closed cubicles, provided with local hoods, connected to induced draft blowers, through

scrubbing system.

By providing and utilizing all the above environment management systems, we observe that

‘stack emissions as well as the ambient air quality’ are very much well within the limits

prescribed by MPCB. Periodical reports of Stack monitoring and ambient monitoring are

submitted to MPCB and MOEF. Environment monitoring reports duly filled in Form-V are

submitted to MPCB and MOEF, regularly.

These proven systems shall be utilized for future products and improvised logics shall be

applied, as required, to keep control on air pollution in and around the premise and environment

control.

Also we wish to submit that after future expansion, we will have 40 different products. This will

result in generation of gases in different types, temperature and pressure. Also the gas generation

is not continuous. Hence it is not feasible to install incinerator for odorous gases.

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POINT 2: Existing effluent treatment scheme to be submitted

Reply:

We have installed Effluent Treatment systems, appropriate to the pesticide manufacturing Industry.

Fig. 1: Existing Effluent Treatment Scheme

Quantity of trade effluent per day is below 25.0 m3. The effluent is treated in ETP comprising of Primary,

secondary, tertiary treatment system. After Equalization, chemical oxidation and neutralization, the

effluent is passed through Multiple Effect Evaporator (MEE) and Dryer systems (ATFD). Distillate from

MEE is further treated in ETP comprising of Biological aerators, followed by Sand/Carbon filters to meet

the consent conditions, prior to using the same for cooling, recycling in process and for green belt

development in the factory premises. Slurry from MEE is fed to Dryer (ATFD) system and the residual

sludge is sent to CHWTSDF at Ranjangaon, for further treatments and disposal, as per the Consent

conditions.

To incinerator

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POINT 3: Wastewater characteristic of ETP at inlet and outlet

Reply:

The wastewater characteristics of ETP at inlet and outlet are given below:

# Parameter Results in mg/l except pH

Before Treatment After Treatment

1 pH 8 7.8

2 BOD 500 28.4

3 COD 1000 ppm 100

4 Suspended Solids 1000 32.2

5 Oil & Greases N. D. --

6 Total Heavy Metals, if any -- --

Source: Compliance Report on Charter on Corporate Responsibility on Environmental Protection

– Report, prepared by MPCB.

Reports of regular monitoring of ETP outlet conducted by MPCB are attached as Annexure I.

POINT 4: Present mode of disposal of treated effluent and hazardous waste

Reply:

We have provided separate covered shed for storing HW generated. We are the member of

CHWTSDF M/s MEP Ltd., Ranjangaon (Agency approved by MOEF/CPCB/MPCB) and we are

disposing off our HW generated under various categories through them. The Manifestoes are

submitted regularly to MPCB, as per the Consent order. Also periodical Reports are submitted to

MPCB/MOEF-Zonal Office, Bhopal, on regular basis. The category of hazardous waste,

particulars, quantity and mode of disposal is given in table below:

Cat.

No. Particulars

Existing

MTPY Mode of Disposal

29.1 Process waste 237.05 Incineration at CHWTSDF (MEPL, Ranjangaon)

29.2 ETP waste 722.85 Disposal to TSDF site (MEPL, Ranjangaon)

29.3 Off-specification pesticides

(Provision only) 61 Incineration at CHWTSDF (MEPL, Ranjangaon)

33.1 Residue from

decontamination 16.4 Disposal to TSDF site (MEPL, Ranjangaon)

33.2 Sludge cleaning 6.6 Disposal to TSDF site (MEPL, Ranjangaon)

33.3 Discarded Containers /

Barrels 136 Sold to authorized vendor after decontamination

36.4 Distillation residues 25.2 Incineration at CHWTSDF (MEPL, Ranjangaon)

5.1 Used oil

Sold to CPCB authorized re-processor

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POINT 5: Air dispersion modeling should be done for winter season.

Reply:

We have conducted the air modeling for winter season November 2013-January 2014. The GLC

is given in following table. It is formed at the distance of 1 Km in the WSW direction of the

factory.

Predicted 24-Hourly Short Term Maximum Incremental Ground Level Concentration

Pollutants Maximum Incremental

Levels, µg/m3

Distance,

km

Direction

Bagasse as fuel

PM 0.44 1.0 WSW

Coal as fuel

PM 0.44 1.0 WSW

SO2 15.46 1.0 WSW

NOx 0.72 1.0 WSW

The detailed report is attached as Annexure 2.

POINT 6: Action plan to install bagfilter instead multicyclone dust collector in the

coal/biomass fired boiler.

Reply:

Our boiler is a multi fuel fired boiler of small capacity, which is run hardly at 50% of its installed

capacity and it had been provided with built-in Multi Cyclone Dust Collector (MDC), as per the

Boiler design Standards specifications. Periodical Inspection is carried out by Boiler Inspector.

The boiler is provided with proper stack of 36 m height and stack monitoring is done by us as

well as by MCPB. The emissions are well within the limits and the reports are submitted to

MPCB periodically. The results are shown below:

Date Of

Sampling

Boiler (Bagasse and Coal)

TPM SO2

<150 mg /Nm3 <60 Kg/ Day

26.02.2013 126.1 2.0

13.06.2013 111 0.5

30.09.2103 132.3 0.8

31.12.2016 138 ND

09.03.2014 62.8 NIL

22.06.2014 30 ND

26.09.2014 42 1.0

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It is inferred from MPCB results that the emissions from boiler with Multicyclone Dust Collector

are within the permissible limits. 9 to 10 months in a year bagasse will be used as boiler fuel.

Hence TPM generation will be low and can be mitigated by Multi Cyclone Dust Collector.

POINT 7: Action Taken Report (ATR) on the non-complied points observed by the

Regional Office

Reply:

Action Taken Report (ATR) on the non-complied points observed by the Regional Office is

prepared and attached as Annexure 3.

POINT 8: Quantitative Risk assessment report for solvent storage

Reply:

Quantitative Risk assessment report for solvent storage is prepared for the plant. Study is

conducted for pool fire and fireball scenario of the solvents based on their storages. List of

solvents is given below. The detailed study report is attached as Annexure 4.

# Solvent Sp.Gr. B.P. Flash Point

1 Benzene 0.86-0.87 80-82 <37.8

2 CYCLOHEXANE 0.77 81 -18

3 CYCLOHEXANONE 0.945 - 0.947 155.65 46

4 DMF 0.94 - 0.95 152-154 57

5 DMSO 1.09 - 1.1 189 89-95

6 EDC 1.24 - 1.26 83 6

7 MCB 1.107 - 1.11 131 23

8 MDC 1.31 - 1.32 40 *

9 Mix XYLENE 0.85 - 0.87 135-166 21

10 Solvent C-9 0.865 to 0.870 155-181 43

11 Toulene 0.86-0.87 110-112 4

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POINT 9: Point-wise replies to issues raised during public hearing

Reply:

Public hearing was conducted on 01/07/2014 at the project site.

The PP and MPCB had made EIA report and executive summary available for public

perusal, among others, with the following 8 grampanchayat officers from Dindori Tehsil

namely Rasegaon, Deherewadi, Indorey, Kochargaon, Pimpalnare, Umrale Kh.,

Madakijamb and Jambutake.

# Name of the

questioner

Regarding Reply by Company

1 Shri. Dinesh

Gadhve, resident

Rasegaon

Explain the arrangements made

for effluent treatment plant

Industry representative

explained the process of

effluent treatment plant.

2 Hon’ble Chairman Details of odorous effluent

mentioned in the flow chart of

effluent treatment plant.

Industry representative

informed that the tanks holding

the odorous effluent are

provided with vents. These

vents are connected to air

pollution control system.

3 Hon’ble Chairman Storage and disposal methods

adopted for hazardous waste

generated in the effluent

treatment plant.

Industry representative

informed that the hazardous

waste generated from the

effluent treatment plant is

sludge in the form of slurry. The

sludge is further processed in

dryer & about 10 % of moisture

is retained in the sludge which

is filled in plastic bags and

transported through drums to

Common Hazardous Waste

Treatment facility, Pune,

Ranjangaon for scientific

disposal.

4 Shri. Tukaram More,

Resident Rasegaon

Repeat the details of air pollution

control facility provided by the

industry.

Project proponent explained the

working of venturi-scrubber

and other scrubbing

arrangements.

5 Shri.

BalasahebDhage,

resident Rasegaon,

Stated the importance of rivers

and dams within the study area to

local people & referred to

Project Proponent informed that

this incidence is about six to

seven years old.

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Hon’ble Chairman

Shri. Rajesh Pandit,

NGO and

Environmentalist

incidences of pollution that have

occurred in the past wherein

water supply for nearby towns

was stopped for few days.

Incidence of river water

pollution that had occurred and

sought additional information

regarding water supply and

stoppage of water supply.

Maharashtra pollution control

board officials came to the

industry to serve closure notice to

the industry.

6 Shri. Balasaheb

Dhage, resident

Rasegaon,

Requested District Magistrate to

start investigation in this matter.

He expected that Bhopal

incidence should not be repeated

in Rasegaon. He informed that

Rasegaon, Dindori is an

environmentally sensitive

illiterate tribal belt and hence

proper decision with regards to

the enquiry may be taken.

7 Hon’ble Chairman

Assured to enquire about the

reason for water pollution and

whether traces of pesticide were

observed in that water. He also

assured that it is his responsibility

that the objections, suggestions

and views raised during public

hearing will be properly

communicated.

8 Shri. Balasaheb

Dhage, resident

Rasegaon,

Due to the water pollution

incidence lakhs of Rupees worth

fish died. He District Magistrate

should give in writing that due to

adverse effect of air pollution,

infants will not born disabled and

Chairman of the Public hearing

instructed the convenor to make

available copy of video

recording at earliest.

Convenor of the Public hearing

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that there will not be adverse

effect on wildlife and

environment safety. He also

demanded copy of the video

recording of this public hearing

within 24 hours as it is his moral

and human-right to obtain the

same.

informed the public that the

minutes of this public hearing

will be available for perusal at

District Collector’s Office and

Maharashtra pollution Control

Board’s office at Udyog

Bhavan, Satpur, Nashik.

9 Shri. Sharad Gorde,

Resident Indorey

Reiterated that the incidence that

had occurred six to seven years

ago and how it affected the

villagers that time. He tried to

establish the skin itching caused

to the women who washed

clothes in River after the incident

to the pollution. He also

challenged the industry’s claim of

planting 40,000 trees. He

informed that if even a liter of

industrial effluent is applied to

any tree, the tree will not survive.

He on behalf of Indorey villagers

opposed future expansion of the

industry. He objected that there

were few blank pages left in the

public hearing attendance register

on purpose and suspected foul

play.

Convener of the Public hearing

informed that the complete

proceeding is video recorded and

there is no foul play in taking

attendance. He explained to the

Chairman that the blank pages

are left only to serve as divider.

Chairman expressed his

satisfaction on this attendance

matter.

Representative of the industry

informed that in the year 2008

the industry had provided solar

evaporation ponds for effluents.

After 2008, as per the

guidelines of central pollution

control Boards these solar

evaporation pond were scrapped

and state of the art multi effect

evaporative (MEE) system was

constructed and commissioned

due to this not even single

droplet of water is discharged

out of industry premises. He

strongly mentioned that the

industry obtained zero discharge

level.

10 Shri Rajaram

Yashwant Dhage,

Resident Rasegaon

Villagers of Rasegaon need to

bring drinking water from four

miles as the industries effluent

has entered bore well water.

Chairman instructed that MPCB

officers should contact Shri

Rajaram Dhage & arrange to

collect samples of bore well for

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Bore water cannot be polluted on

its own.

analysis purpose. He also

suggested that if required the

samples may send to any

laboratory which Shri Dhage

suggest if there is any doubt in

his mind.

Chairman explained that even in

absence of industries due to

domestic waste from the cities

bore well water becomes unfit

for consumptions.

11 Shri. Balasaheb

Dhage, resident

Rasegaon,

Before 1998 none the bore wells

had water as today.

Chairman informed that report

from Maharashtra pollution

control Board will be called in

with respect of bore well water

pollution in the vicinity of the

industry.

12 Shri. Rajesh Pandit,

NGO and

Environmentalist

Hon’ble Chairman

Shri. Rajesh Pandit,

NGO and

Environmentalist

Hon’ble Chairman

Whether any provision of free of

cost medical check-up camps for

the nearby villagers is made to

check if there is any health issues

due to the industry.

Initiatives to be taken under

corporate responsibility by the

industry

Industry has grown many trees,

however they should plant trees

like neem instead of gulmohar

trees as gulmohar trees grows fast

but does not produce good

quantity of oxygen compared to

other trees.

Give a detailed report about the

compliances made by the industry

in respect of the conditions

prescribed by maharashtra

Representative of the industry

informed that industry has

planted Gulmohar trees as well

as different varieties of trees in

consultation with experts from

Forest Department.

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pollution control board.

13 Shri. Prabhakar

Dhage

Local residents are presently

suffering because of smell

nuisance and irritation due to

pollution.

Dr. Kasodkar informed that the

industries employees check up

is carried on every Sunday and

there is no health issue among

the employees.

14 Shri. Balasaheb

Dhage, resident

Rasegaon,

Due to heat and pollution small

children will develop dysentery.

He also invited Dr. Kasodkar to

set up a clinic in Rasegaon

Dr. Kasodkar proposed that he

will carry out health check-up

of villagers once in the three

months through medical camps.

15 Shri. Vilas Dhage,

resident Rasegaon

Hon’ble Chairman

Hon’ble Chairman

If the industry is in operation

since many years, why medical

camps for villagers were not

conducted previously?

Under what provision he has been

employed to study health effects

on the employees.

Is there any provision for the

medical check-up of nearby

surrounding villagers?

Dr. Kasodkar informed that in

future the medical camp will be

conducted for villagers

Representative of the industry

informed under the factory act

the medical check-up of

employees is mandatory.

Representative of the industry

replied that under corporate

responsibility of the industry the

provisions are made for medical

check-up of the nearby

villagers.

16 Shri. Vilas Dhage,

resident Rasegaon

His agricultural land is adjacent

to the industry and no one can

stay there due to pollution. He

requested that the poor people

should not be held ransom.

17 Shri. Sharad Gorde,

resident Rasegaon

No Objection Certificate of all the

neighbouring 10 to 12

Grampanchayat should be taken

instead of only Grampanchayat of

Rasegaon.

18 Shri. Vilas Dhage,

resident Rasegaon

Enquired with the convenor of the

public hearing as to when

Convenor of the Public hearing

informed that copies of EIA &

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documents related to the industry

were kept for perusal at Rasegaon

Grampanchayat.

Executive summary were kept

at various Government offices.

However, considering the

sensitivity of the issue copies

were also kept at 09

Grampanchayat offices four

month prior to Public Hearing.

He also informed that

acknowledgement copies of the

submission are available with

him.

The Chairman instructed that

the copies and video recording

should be made available to the

interested people so as to

maintain transparency of public

hearing procedure. He

instructed industry

representatives to announce

local names of the additional

products to be manufactured by

the industry.

19 Shri. Vilas Dhage,

resident Rasegaon

If the products manufactured do

not cause harm to the mankind

and villagers oppose this

expansion the villagers are at loss,

however if products

manufactured does cause harm

and if the villagers do not oppose

the project , in both situation it

will be loss to the villagers. He

informed that during visit to

Maharashtra Pollution Control

Board Office he has seen the

acknowledgement copy of EIA

and executive summary given to

Grampanchayat Rasegaon,

however, the Gramsevak did not

make available copies of the same

The Chairman instructed the

Gramsevak to make copies

available to the literate villagers

for study purposes.

Representative of the industry

informed that villagers had

approached them to get

information about the

expansion of the project.

Industry had explained and

given executive summary in

Marathi language to about 70

to 80 villagers.

Gramsevak, Grampanchayat –

Rasegaon informed that copies

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for perusal.

There are many literate villagers

in Rasegaon and they can read

English also. He again alleged

that the gramsevak did not make

available copies of EIA and

executive summary on demand.

related to the public hearing

were made available for perusal.

He also instructed the villagers

to approach the industry for

further clarification.

The Chairman announced that

copies will be made available in

English as well as Marathi

languages. Only two to three

people are raising questions, he

appealed that other people

should also make their

recommendation/ objections

and participate in public

hearing.

20 Shri. DinkarBhoi,

resident Umrale

If expansion of the industry is

allowed, it will have adverse

effect on the health of about 9 to

10 village residents. He

requested to Honourable District

Magistrate and Sub- Regional

Officer, MPCB to not to allow

expansion of the industry and

also instruct industry to control

present pollution. He further

requested them to ensure that no

danger is posed to health of these

villagers.

21 Smt. Yogita More,

Sarpanch, Rasegaon

She has not observed any

discharge of effluent from the

industry in her tenure of three

years as Sarpanch. She informed

that Grampanchayat Rasegaon

and the villagers have always

received co-operation from the

industry. She felt that air

pollution and smell nuisance is

observed receding during last

few years. She is of the opinion

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that industrialisation of the

country is necessary. This will

generate employment to jobless

people and new schemes will be

implemented in villages. She

said that due to expansion of the

industry if the villages are going

to be benefited, the project needs

to be carried out. She informed

that due to this project

employment will be generated

for the tribal Dindori district and

also there will be increase in

revenue due to additional tax of

Rasegaon Grampanchayat and

various schemes can be

implemented leading to progress

of the village.

22 Shri. Sanjay

Bendkule, resident

Rasegaon

There is development of a village

due to industry however, there is

need to change production.

Industry provides revenue to

villages to build temple, however

this does not profit the people.

He also pointed out that the

village in which the industry is

located benefits, but what about

neighbouring villages? He

pointed out that the villagers face

problems due to pollution of the

industry and also pointed out that

a relative who had come for a

visit to his house faced health

issue of vomiting. He also

pointed out that smell nuisance is

faced upto 25 kilometres from

the industry. He suggested that

the industry should purchase 50

Acres of land elsewhere and

setup this project there or else

Representative of the industry

informed that the new proposed

products are of lower

concentrations of fungicide type

and will cause lesser smell

nuisance. Old products will be

phased out gradually in a step

by step manner and replaced by

new products proposed.

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completely change production to

prevent smell nuisance and

relieve them of smell nuisance

problem.

23 Smt. Yogita More,

Sarpanch, Rasegaon

Elaborate on new products. Representative of the industry

informed that following

products are proposed: DM-45

and TrisulphateZol are

fungicide, Glycosate is a

weedicide, BDVP and

Chloropyrophos are

insecticides. The proposed

products are of lesser severity

and most of them fall under blue

category of pesticides and are

fungicide and weedicide types.

24 Shri. Prabhakar

Dhage, resident

Rasegaon

Few villagers in

unison

One of the villagers

Smell nuisance is also generated

during manufacture of

chloropyrophos.

The industry should declare that

they will control 100 % smell

nuisance.

DDVPA gas generates smell and

is poisonous

Representative of the industry

informed that during

production of chloropyrophos,

chlorination is carried out and

there is a group of phosphate in

this group. Due to chlorination

severity of smell nuisance is

reduced.

Representative of the industry

assured that measures will be

taken to control 100 % smell

nuisance.

25 Hon’ble Chairman Whether any instruments are

available to measure smell and

whether any standards are

prescribed for smell that induces

irritation and vomiting?

Representative of the industry

informed that concentration of

gasses can be measured

however, presently there are no

instruments to measure smell.

26 Hon’ble Chairman Whether instruments to measure

smell are available

internationally? He also enquired

Representative of the industry

informed that the industry has

provided sensors for detection

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as to whether pesticide industries

in foreign countries also have

same severity of smell nuisance?

of H2S gas and HCl fumes.

27 Hon’ble Chairman Whether by any means severity of

smell nuisance can be reduced

during production process?

Representative of the industry

informed that severity of smell

nuisance was there five years

ago is accepted, however

severity of smell nuisance has

been significantly reduced by us

and we are further attempting to

reduce the same. He also

informed that assurance has

been giver that production of

smell generating products will

be gradually reduced. Steps will

be also taken to reduce smell

during manufacture of Phorate

product.

28 Hon’ble Chairman How many products out of 10

presently manufactured are

exported?

Representative of the industry

informed that most of the

products are exported.

29 Hon’ble Chairman To which countries are these

products exported?

Representative of the industry

informed that the products are

exported to Latin America,

Taiwan etc.

30 Shri. Dattatray

Upsunde, resident

Rasegaon

The smell nuisance is due to

present production capacity itself.

Due to additional production

smell nuisance will increase;

hence additional production

should not be taken and the

villagers oppose the proposed

expansion of products. He

suggested that the Doctors should

have carried out medical check-

ups of the employees and

villagers also.. He informed that

he has no objection to the present

project, however instructed to

reduce smell nuisance.

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31 Hon’ble Chairman Enquired about the number of

laborers and officers employed

presently.

Representative of the industry

informed that presently 140

laborers and officers are

employed and that there are

maximum local labor from

Rasegaon village and about 20

to 25 laborers come from other

places.

32 Hon’ble Chairman Enquired as to whether laborers

are skilled or unskilled

Representative of the industry

informed that the present work

requires a mixture of skilled

and unskilled laborers and

hence both are included.

33 Hon’ble Chairman Enquired as to what percentage of

production is exported.

Representative of the industry

informed that about 20 % of

total production is exported.

34 Hon’ble Chairman To which countries are these

products exported?

Representative of the industry

informed that the products are

exported to Latin America,

Taiwan etc.

35 Hon’ble Chairman Enquired about the brand names

by which the industry sells its

products.

Representative of the industry

Informed that production of

industry is sold throughout the

country. The industry does not

have its own distribution

network. The industry has a tie

up with M/s. Zuari Agro

Chemicals Ltd., M/s. Shriram

Fertilizers and Chemicals Ltd.,

M/s. Paradeep Phosphate Ltd.,

Chambal fertilisers Ltd., etc. for

selling of formulation products.

Technical grade products are

sold to industries for

formulation.

36 Few Villagers Industry should take the villagers

in confidence before taking any

permission

37 Hon’ble Chairman Whether there is a system to store Representative of the industry

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and then let out smell. He gave

example of water bottle with lid

i.e. Store the smell in the bottle

and open it to let out smell. He

also enquired whether industry is

in operation at this moment.

informed that the industry is in

operation at this moment. He

also informed that there is no

provision of storing and letting

out smell. However due to

sudden power failure smell

nuisance may be aggravated at

some times.

38 Hon’ble Chairman Whether the industry has carried

out any social work like medical

camps, educational programs etc.

Through corporate social

responsibility funds.

Representative of the industry

informed that during summer

season water is supplied to the

villagers through tankers also

eye check-up and surgery camp

was held and free surgery and

distribution of spectacles were

carried out.

39 Shri. Vasant Thete,

resident Nalegaon

Industry has provided pipeline for

water supply from Nalegaon dam.

He expressed his apprehension

that industry may use the same

pipeline to discharge their

effluent. He declared his

objection to the project stating the

reason that due to pollution of the

industry, children are affected

with symptoms like lack of

enthusiasm, headache etc.

Representative of the industry

informed that this region is at a

height of 80 meters and water is

brought to the industry by

pumping. There is a small

rivulet lowing near the base of

the dam. Provision of pumps by

spending 1 Lac rupees and with

assistance of Rasegaon,

Nalegaon and Umrale villagers

is made to pump the rivulet

water into the dam to increase

its water level.

40 Hon’ble Chairman Presently whether industry

discharges any effluent outside

premises? He further enquired as

to whether water requirement will

increase due to increase in

production?

Representative of the industry

informed that provision of

additional 0.063 TMC water

reserved for industrial purpose

through Alandi dam is made.

41 Shri. VasantThete,

resident Nalegaon

Industry has spent 23 to 25 Lac

Rupees for getting water through

pipeline. He also informed that

the villagers don’t use water from

pipeline for drinking purpose,

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instead they use bore-well water.

He also stated that the possibility

of villagers facing water scarcity

cannot be ruled out and the

industry management will be

responsible for such situation.

42 Shri. Babasaheb

Upsunde

During low atmospheric pressure

it takes about 1 to 2 hours for the

smell to subside within his house.

He requested the industry

administration to take steps to

reduce smell nuisance.

43 Shri. Yogesh

Upsunde

Appealed to the Honorable

Chairman to consider the present

nuisance faced by the villagers

and nuisance generated due to

the additional production before

taking any further decision.

44 Smt. Bendkule, local

tribal

There is acute scarcity of water.

Local Marathi villagers harass us

by throwing away our utensils.

However, the industry supports us

by delivering water to us through

tankers.

Honorable Chairman of the

Public Hearing instructed

Gramsevak to investigate

difficulties faced by the tribal’s

and villagers and submit his

report. He assured to assist the

villagers wherever possible

within the purview of his

official capacity.

45 Shri. Raosaheb

Lahange, resident

Rasegaon

There is acute water scarcity in

the village and the industry helps

by supplying water through

tankers.

Honorable Chairman of public hearing summarized the proceedings with following points:

a. Most of the issues raised during the public hearing can be settled through dialogue

between industry management and villagers

b. Feeling of villagers are strong with respect to the issue of smell nuisance

c. Industry is not properly implementing CSR activity, he instructed the industry to

implement CSR activities forthwith.

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d. He expressed that he has own doubts about increase in pollution load due to expansion,

however he mentioned that there is competent authority at MoEF to take decision.

e. He mentioned that pesticides are necessity in farming. Pesticides do not emit smell. Such

kind of industries is needed, however development of people should be ensured.

Convener took permission of Hon. Chairman to conclude the public hearing.

Regional Officer, MPCB gave vote of thanks and concluded the proceedings of Public Hearing.

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ANNEXURE 1

CREP INFORMATION

AND

MPCB RESULTS

FOR EFFLUENT TREATEMNT PLANT

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MAHARASHTRA POLLUTION CONTROL BOARD

Grams : “PREPOLL” Tel .No : 2365150, 2362820 Fax : 2365161 E-mail : [email protected]

SUB – REGIONAL OFFICE UDYOG BHAVAN, 1st floor, Near ITI Signal, Trimbak road, MIDC Compound, Nashik – 422 007. Date: 23.06.2015

Name of the Industry : M/s. Spectrum Ethers Ltd. :

Location Address : Gat No. 367 A/p-Rasegaon.Tal-Dindori.Nasik :

Contact Person (with e mail and cell no.) : Mr.V.N.Pawar ([email protected])

02557(226371)

Date or Year of Establishment : 1994

Total number of workers : 154 nos

(Include all shifts, offices staff, contractual etc.)

1. Products manufactured in last 3 years

Sr.No. Product Quantity manufactured in MT

2014-15 2013-14 2012-13

1. Phorate Technical 1990.93 1519.23 1777.440 2. Profenofos Technical 1143 1540.165 1037.250 3. Terbufos Technical 105.6 54.340 297.940 4. Propiconazole technical 183.15 309.232 100.505

2. Fuel Consumption

Sr.No. Fuel Quantity used in MT

2014-15 2013-14 2012-13

1. Bagasse 13400 13400 11902

2. Coal 760 760 3429

3. LDO 0 0 0

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3. Water Consumption

Sr.No. Category of Use Quantity used in cu.m per month

2014-15 2013-14 2013-12

1. Vessel washing/floor washing 0 0 0

2. Process 496.37 482.77 548

3. Cooling 5348.82 5549 2719

4. Boiler 1198.13 1243 1694.68

5. Domestic 128.37 133 200

4. Waste Water Generation

Sr.No. Category of Use Quantity in cu.m per month

2014-15 2013-14 2013-12

1 Daily quantity of trade

effluent

442 988 683.6

2 Daily quantity of sewage

effluent from the factory.

180 135 177.7

3 Daily quantity of treated

effluent

700 780 683.6

5. Characteristic of waste water

Sr.

No.

Parameter Results in mg/l except pH dtd.

Before Treatment After Treatment

1. pH 8 7.8

2. BOD 500 28.4

3. COD 1000 ppm 100

4. Suspended Solids 1000 mg/l 32.2

5. Oil & Greases N.D. -

6. Total heavy Metals, if any - -

Disposal of treated waste water (a) on Land for irrigation

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6. Stack Emission Data, if applicable

Sr.

No.

Stack/Chimney

attached to

Gas

Flow/Discharge

in Nm3/hr

Parameters mg/ Nm3

Particulate

matter

Sulphur

dioxide

H2S

1. DETA stack 413.44 22.55 0.02 -

2. Phorate stack 1181.92 22.28 0.25 -

3. ETP stack 1158.39 17.35 0.3 0.3

4. Formulation

stack

570.2 15.23 0.1 -

7. Hazardous Waste (HW) generation

Sr.No. Name of Hazardous Waste Quantity in cu.m per month

2014-15 2013-14 2012-13

1. 29.1 95.175 206.446 255.278

2. 29.2 768.624 776.985 530.540

3. 29.3 - - -

4. 32.2 - - -

5. 33.1 - - -

6. 33.2 - - -

7. 33.3 92.370 94.084 61.552

8. 36.4 - - -

8. Method of Hazardous Waste Treatment and Disposal

Sr.No. Name of

Hazardous

Waste

Method of Treatment

Direct

Landfill

Treatment &

Landfill

Incineration Recycling/Reuse

on site or sale

1. 29.1 - - Incineration -

2. 29.2 - - Incineration -

3. 29.3 - - - -

4. 32.2 - - - -

5. 33.1 - - Incineration -

6. 33.2 - - - -

7. 33.3 - - Incineration -

8. 36.4 - - Incineration -

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9. Handling of Hazardous Chemicals as per MSIHC Rules, 1989, as amended

Sr.No

.

Name of Hazardous Chemical Quantity Handled, MT

2014-15 2013-14 2012-13

1 Ethyl alcohol ( Absolue alcohol –99.9 % pure

1140 1181.179 1127.574

2 DETA 0 0 0

3 Toluene 2.8 8.1 11.025

4 P2S5 919 991.8 907.32

5 Ethyl Mercaptan 512.350 552.135 476.362

6 Formaldehyde 37 % 720.410 794.581 730.584

7 Nitrogen ( 7 m3 cylinders ) 7 10 11

8 Methyl bromide - - 0

9 t- Butyl mercaptan 51.860 37.440 108.45

10 Thio diphenol ( TDP) 0 0 0

11 Dimethyl Thio Phosphoryl chloride ( DMTCl)

0 0 0

12 Methanol 0.3 0.3 0.299

13 Caustic lye ( 100 % ) 0.5 0.550 0.1

14 Caustic lye ( 48 % ) 885 1110.379 901.651

15 Parabromo Orthochloro Phenol ( PBOCP )

0 0 0.25

16 Trimethyl Amine ( TMA ) 865.650 1313.465 776.04

17 DETCl 584.410 910.565 595.343

18 n- Propyl bromide 422.616 654.724 438.381

19 Bromoacetophenone 0 0 0

20 1,2 Pentane diol 93.208 117.920 42.5

21 1,2,4 Triazole 74.175 88.609 33.05

22 Methylene dichloride 0 0 0

23 Dimethyl formamide 0 0 0

24 Mixed Xylene 0 0 0

25 Emulsifier 5 5.3 0

26 Stabilizer 0 0 0

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27 2 chloro 5 chloro methyl pyridine 0 0 0

28 n- cyano methyl imidate 0 0 0

29 Mono methyl amine 0 0 0

30 Hydro chloric acid( 30 % ) 3.825

31 OCP 404 596.793 437.092

32 Bromine 636 921.425 566.816

33 DICAP 155.557 197.5 74.5

34 MCB 141 343.773 228.097

10. Any Other Information-

Sub-Regional Officer, Nashik

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1/7

ANNEXURE 2

AIR DISPERSION MODELING

FOR

WINTER SEASON

M/s SPECTRUM ETHERS LIMITED

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2/7

1.0 Impact on Air Quality

Spectrum Ethers Ltd. has proposed additional boiler of capacity 7.5 TPH in the existing

premises of plant located at Rasegaon village, Dindori tahsil of Nasik Dist. in Maharashtra state.

Air quality impact is envisaged due to operation of this proposed boiler. Boiler will be operated

on bagasse most of time of year however it will also use coal as fuel when bagasse is not

available. Hence there will be emission of Particulate Matter (PM), Sulphur Dioxide(SO2) and

Oxides of Nitrogen (NOx) due to burning of these fuels.

Ground level concentrations (GLCs) have been predicted using AERMODCloud software. The

application incorporates U.S. EPA air dispersion models AERMOD and ISCST3 into one

integrated graphical interface. The model uses rural dispersion and regulatory defaults options as

per guidelines on air quality models (PROBES/70/1997-1998).

1.1 Input to Model

Proposed boiler will be connected to existing stack attached to boilers (capacity 7.5+2.5 TPH).

Two modeling options are considered when boiler will be operated on Bagasse and other using

coal. The stack details and flue gas characteristics are provided below:

Table-1: Stack Emission

Parameters Unit Stack Attached to proposed boilers 7.5

TPH

Stack height m 36

Stack diameter at exit / top m 1.6

Stack exit gas velocity m/s 4.95

Stack gas temperature at exit Deg. C 109.5

Fuel type Bagasse Coal

Fuel requirement T/day 118 52

(S-0.5%)

PM Emission g/sec 0.17

(120 mg/Nm3)

SO2 Emission g/sec -- 6.02

NOx Emission g/sec -- 0.28

Air pollution control

equipment

Mechanical dust collector

Hourly meteorological data recorded at site for winter season (Nov-Dec, 2013 and Jan 2014)

on wind speed, direction and temperature is used as input. Site specific wind-rose for this

season is shown in Figure-1. For the site-specific mixing heights CPCB document

PROBES/88/2002-2003 is followed. Average hourly data for 24 hrs used for modeling is

tabulated in Table-2.

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3/7

Figure-1: Site Specific Wind Rose for Winter Season

(Nov-Dec 2013 and Jan 2014)

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4/7

Table-2: Average Hourly Meteorological Data for 24 Hours used for Modeling

Time W.D.* W.S. Temp. Stability M.H.

Hr. Deg. m/s Deg.K Class m

1 248 0.83 293 6 50

2 248 0.83 292 6 50

3 23 0.28 291 6 50

4 68 0.56 290 6 50

5 293 0.56 288 6 50

6 23 0.83 287 6 50

7 45 1.11 288 2 50

8 68 1.67 288 2 50

9 90 1.11 291 1 200

10 45 1.11 291 1 500

11 68 1.39 291 1 600

12 90 1.39 291 1 1000

13 113 0.83 292 1 1200

14 68 0.83 292 1 1200

15 338 0.56 291 1 1200

16 23 0.56 292 1 1200

17 360 0.56 291 2 1000

18 270 1.39 289 2 700

19 45 1.11 288 6 600

20 68 1.39 289 6 500

21 68 1.39 290 6 300

22 68 1.39 290 6 200

23 68 0.56 292 6 100

24 45 0.83 291 6 100

* W.D. are blowing from

In the short-term simulations, the incremental ground level concentrations were estimated to

obtain an optimum description of variations in concentrations within 10 km radius w.r.t. stack

attached to boiler as centre.

1.2 Prediction

The predicted results are tabulated below in Table-3 and dispersion trend is shown as

isopleths in Figure-1, 2 and 3 respectively for PM, SO2 and NOx.

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5/7

Table-3: Predicted 24-Hourly Short Term Maximum Incremental

Ground Level Concentration

Pollu-

tants

Maximum Incremental

Levels, µg/m3

Distance,

km

Direction

Bagasse as fuel

PM 0.44 1.0 WSW

Coal as fuel

PM 0.44 1.0 WSW

SO2 15.46 1.0 WSW

NOx 0.72 1.0 WSW

The maximum incremental GLCs (Refer Table-3) of PM, SO2 and NOx are superimposed on

the baseline concentrations recorded during the study period to arrive at the likely resultant

concentrations after implementation of the proposed boiler. The cumulative concentration

(baseline + incremental) is tabulated below in Table-4.

Table-4: Resultant Concentrations Due To Incremental GLC's

Sce-

nario

Incremental

Concentrations,

g/m3

Baseline

Concentrations,**

g/m3

Resultant

Concentrations,

g/m3

CPCB Limit for

Industrial, Residential,

Rural & Other Area,

g/m3

PM 0.44 82.70 83.14 100

SO2 15.46 26.00 41.46 80

NOx 0.72 35.00 35.72 80

** - Maximum Baseline concentration in study area

1.3 Impact Assessment

Ambient air quality in study area w.r.t. PM, SO2 and NOx is within NAAQS 2009 as seen from

Table-4 above. Hence, any significant impact is not envisaged.

2.0 Mitigation Measures

Ambient air quality will be within NAAQS 2009 as mentioned above. Mechanical dust collector

is provided as air pollution control measures and stack of adequate height, 36 m is also provided

to disperse the flue gas.

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6/7

Figure-2: Short Term 24 Hourly Incremental GLCs of PM

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7/7

Figure-3: Short Term 24 Hourly Incremental GLCs of SO2

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8/7

Figure-4: Short Term 24 Hourly Incremental GLCs of NOx

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ANNEXURE 3

ACTION TAKEN REPORT FOR

POINTS OBSERVED BY RO OFFICE

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Action Taken Report for Points Observed by RO Office

Specific Conditions

Cond.

No.

Condition Summary Action Plan

i Process effluent generation,

segregation of high COD toxic

waste stream, recycling of

condensate from MEE & CT and

domestic effluent

Process effluent is within prescribed limit.

Effluents generated are segregated in to high COD

toxic waste stream and tertiary treatment is given.

Slurry is passed through ATFD system and solid

waste is disposed to CHWTSDF, Ranjangaon.

Condensate from MEE is treated in tertiary system

consists of bio sludge aerators, passed thru sand

/carbon filters along with CT blow down and then

final out let water is used for recycled in the

process/CT make up/ Green belt. Domestic

effluent is treated in Septic tank and O/F is used

for dilution of stream taken for gardening.

ii Adequate stack height & acoustic

treatment for DG Set, Multi-stage

scrubber to control process

emissions

7 m stack is provided to DG set and DG set are

used only in case of power failure. Acoustic

enclosures are provided to DG sets and periodic

monitoring is done to check noise levels. Multi-

stage scrubbers are attached to process vents with

specialty chemicals used as scrubber solutions and

stack monitoring is done periodically and reports

are submitted to MPCB/MOEF.

iii Monitoring of non-methane HC,

H2S, Cl2, Br & its submission to

Ministry

Online monitoring systems installed and

commissioned. Uploading of the “data” is under

process. Screen Shots are attached.

iv Publishing monitoring data on

company website

The factory is remotely located and having net

work related problems. We have applied to BSNL

Lease Line for continuous internet connection.

However uploading “DATA” is initiated, with

existing internet connection.

v Standard notified for pesticide

under EP act to be followed

EP act standards are being complied. Consent

compliance reports are being submitted regularly

to MPCB.

vi Authorization under HWMH &

trans-boundary movement rules

2008, MPCB permission for

disposal of TSDF. Fire fighting

measures in case of emergency.

Complied. Authorization is obtained under

HWMH & trans-boundary movement rules

2008,vide our consent to operate issued by MPCB.

We are members of m/s MEPL & Mem. No.

MEPL/CAS008 for disposal of hazardous waste

The manifestos are submitted to MPCB regularly.

Full fledged fire hydrant system, various types of

Fire Extinguishers,Sprinklers,Foam tenders etc.are

in place. Mock drills are regularly conducted &

Measures are taken for firefighting as per the

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DISH requirements and Risk Analysis report

suggestions.

vii Compliance of MSIHC Rules &

MVA Rules

We are regularly complying various MSIHC and

MVA Rules. The inspection is done by Factory

Inspector regularly. We have got CCOE license

and Solvents license and we are fulfilling the terms

and conditions of the same.

viii Company shall undertake waste

minimization measures

The suggestions by RO, MoEF are already in

practice.

ix Fugitive emissions shall be

monitored regularly and shall

conform to limits imposed by

MPCB

The fugitive emissions are monitored in work zone

and reports are submitted regularly to MPCB

x Solvent Management shall be

undertaken

The suggestions by RO, MoEF are already in

practice.

xi Storage tanks under negative

pressure, N2 blanketing, closed

handling system for chemicals and

solvents, magnetic seals for

reactors, chilled brine condensers

for VOC and solvent traps

Storage tank vent lines are diverted through

scrubbing system. N2 blanketing is provided.

closed handling system is provided for chemicals

and solvents. Chilled water/brine condensers are

provided to minimize VOC emissions, followed by

ventury scrubber.

xii Provision of vapour recovery,

LDAR system & LEL indicators

LDAR systems for all required components are

installed with LEL indicators and maintained.

Photos are attached here with.

xiii Spillage shall be avoided and

garland drains to be constructed to

avoid mixing of spillage with

domestic waste & storm drain

All floor collections are connected to collection pit

through acid resistant tile lined covered drains.

Spill control program is in place. No major

spillage reported in last 3 years. Other drains are

provided separately. Dry gutter are targeted and

maintained ,as verified by RO .

xiv Arrangement for control of odour

nuisance

Processes vents are routed through double deck

vent condensers to localized multi stage ventury

scrubbers and finally to common polishing

scrubbing system. Continuous dosing of H2O2 is

done to deodorizer to control odour nuisance.

xv Financial provision for above

suggested environmental

safeguards

For above purpose, Rs. 388.67 Lakhs have been

allocated for Year 2014-15. This is shown as part

of Six monthly monitoring reports, submitted

regularly to MoEF, Bhopal.

xvi Occupational Health Surveillance

of workers

One Doctor with paramedic staff is appointed for

Occupational Health Surveillance of workers.

Regular health checkup is done and records are

maintained as per factory Act.

xvii Arrangement for prevention of

possible fire hazard

Adequate preventive measures are provided while

designing the plant and due care is taken through

HAZOP studies. Suitable fire extinguishers and

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fire hydrant system is provided in all working

areas.

xviii Training to all employees for

safety and health aspects, pre-

employment and regular medical

examination Training for handling

the chemicals

All employees are trained in matter of safety and

health. The trainings are also given at the time of

recruitment. Mock drills are also conducted on

site. Medical examination of employees is done at

the time of employment and medical check-up is

conducted time to time.

xix Usage of PPEs by all employees

shall be ensured.

PPEs are provided to all workers to prevent any

untoward situation, Their use is compulsory.

xx Follow-up of CREP

Recommendations

Company is submitting CREP information

regularly to SPCB in prescribed format. The CREP

recommendations are being complied.

xxi Action plan for waste

minimization

The steps are already being taken for waste

minimization. E. g. In profenofos production,

NaCl (salt) generated was disposed as hazardous

waste. It is segregated and now converted to non-

hazardous waste and then sent for secure landfill.

xxii Company shall undertake rain

water harvesting measures

rain water harvesting structure is provided. The

water is collected in pond and used in lean season

xxiii Green Belt as per CPCB

guidelines

41,325 trees are already planted, taking into

consideration the recommendations from MPCB.

Casuarina plantation is already done on site and

will be preferred in future too.

xxiv Facilities provision for

construction workers

The construction is minimum. Majority is only

fabrication work. Accommodation with facilities

are locally provided, nearby factory.

General Conditions

i Pas shall strictly adhere to

stipulations made by SPCB

We have valid consent from MPCB and consent

compliance is submitted regularly to MPCB

ii No further expansion/

modification is to be done without

prior approval of MoEF

We agree to this condition.

iii At no time emissions shall exceed

prescribed limit. In event of failure

of pollution control, unit shall be

automatically put out of operation

and shall not restart till desired

efficiency is achieved.

Complied. Scrubber pumps and blower interlock

system provided to control the addition of critical

chemicals, in the reactors.

iv Emissions from Process shall

conform to standards prescribed

by concerned authorities. In event

of failure of Pollution control

system, unit shall not be restarted

till situation is rectified. Stack

monitoring shall be carried out for

The emissions are within limit. Stack monitoring is

being carried out regularly. The reports are

submitted during the visit. We agree that In event

of failure of Pollution control system, respective

unit shall not be restarted till situation is rectified.

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SO2, NOx, HCl and SPM

v Locations of AAQ monitoring

shall be decided in consultation

with MPCB. At least 1 station

each shall be upwind, downwind

and at GLC location

AAQ monitoring locations are as per CPCB

guidelines. AAQ monitoring is done by MPCB.

Reports are submitted regularly.

vi Dedicated scrubbes and stacks as

per CPCB guidelines. Scrubbed

water shall be sent to ETP.

Dedicated scrubbers (odd 5 + 4 series)are

provided. Appropriate stack height (36 m) is

provided as per CPCB guidelines. Scrubber

solution is sent to ETP.

vii Noise Monitoring and Noise

control measures

Noise levels are monitored on regular basis and

reports are submitted to MPCB/MOEF and are

within prescribed limits. DG sets are provided with

Acoustic enclosures and Ear plugs are provided for

electricians operating DG sets.

viii Implementation of

recommendations made in respect

of Environmental Management

and risk mitigation measures

Complied. Quantitative Risk Analysis is done and

recommendations are being followed.

ix CSR We are already doing the CSR activities in the

vicinity of project site. The details are attached.

CSR Activities of last 3 years:

# Particulars Amount Rs.

Lakh

2013

1 Cultural and Religious

Activities

25.67

2 Drinking water supply 2.44

3 Veterinary Camp 0.25

2014

1 Cultural and Religious

Activities

0.45

2 Nasik Rural Police

Welfare

0.25

3 Drinking water supply 1.5

2015

1 Dr. Ambedkar Temple

and Jayanti celebration

1.61

2 Cultural and Religious

Activities

0.61

x Eco-development measures

including community welfare

The company is currently doing social forestry and

plant distribution in the vicinity of project site. In

future, we are planning to provide solar street

lights, guidance for rainwater harvesting and

groundwater recharging and biogas plants for

nearby villages as a step towards eco-development

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of the area.

xi Separate EMC equipped with full-

fledge lab shall be set up to carry

out environmental management &

monitoring

EMC with lab facility is set up. It is headed by

Plant Manager of the unit with help of managers

and 3 workers. Monitoring is done on site. Also

the services of MoEF & CC approved external labs

are hired to carry out monitoring.

xii Adequate funds to implement

conditions stipulated by MoEF and

State Govt.

We have budgeted Rs. 7 crores vide the proposed

expn., to implement future conditions going to be

stipulated by MoEF and State Govt.

xiii Environmental action plan and six-

monthly compliance report

We are submitting six-monthly compliance reports

regularly to MoEF, Bhopal as per the action plan.

xiv Copy of clearance letter to be sent

to local authority/ NGO if any

from who suggestions/

representations were received

while processing the proposal

We agree to this condition.

xv Six-monthly compliance report We are submitting six-monthly compliance reports

regularly to MoEF, Bhopal

xvi Environmental Statement &

compliance of EC conditions shall

be submitted to SPCB, RO of

MoEF and shall be uploaded on

website of company

We have already submitted “On Line” this year’s

Environmental Statement and Compliance of EC

submission. It is being uploaded to Company’s

website.

xvii PP shall inform public regarding

accord of EC through local

newspapers

We have informed the public regarding accord of

existing EC through local newspaper.

xviii PA shall inform RO & ministry

the date of financial closure and

final approval of project by

concerned authorities and date of

start of project

For existing project Final approval was obtained in

24 th Nov 2009 and Project was commissioned in

January 2011.

9 Ministry may revoke or suspend

the clearance if implementation of

any of above conditions is not

satisfactory

We agree to this condition.

10 Ministry reserves the right to

stipulate additional conditions, if

found necessary. The company

will implement these conditions in

time bound manner.

We agree to this condition.

11 Any appeal against this EC shall

lie with national Appellate

Authority if preferred within 30

days

We agree to this condition.

12 Above conditions will be enforced

inter-alia under the provisions of

We agree to this condition.

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Water Act 1974, Air Act 1981, EP

Act 1986, HW Rules 2003/2008

and public liability Insurance Act

1991along with their amendments

and rules.

Summary

We have been advised to implement and follow Environmental management, CREP guidelines,

Green belt development, CSR, Eco-development measures, road/drain preparations and

submission of six-monthly reports. We are already implementing these measures and shall

continue to do so in future.

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ANNEXURE 4

QUANTITATIVE RISK ASSESSMENT

REPORT

FOR SOLVENT STORAGE

M/s SPECTRUM ETHERS LIMITED

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