G PETROCHEmiCALS LlfTllTEDRef: IGPL/JKS/2017/PA-4/AMD Date: 02/08/2017

The Member Secretary,Expert Appraisal Committee (Industry 2)Ministry of Environment, Forest & Climate Change (MOEFCC),Indira Paryavaran Bhavan, Aliganj, Jorbagh Road,New Delhi-110 003

Sub: Request for Amendment in Environment Clearance

Ref: Environment Clearance Letter No. 1-11011/73/2016-IA-II (I) dated 18th July 2017for Proposed Expansion project of petrochemical & synthetic organic chemicalmanufacturing facility at Plot T-2 MIDC Taloja, Tehsil Panvel, District Raigad, Maharashtra

Kind Attention: Dr. O.K. Srivastava (Member Secretary)

Respected Sir,

With reference to above, we wish to inform that we have received Environment Clearanceletter in respect of our PA-IV expansion and Plasticizer project vide above letter and thankyou for the same.

We wish to request your kind attention for amendment in Specific conditions ofEnvironment Clearance as below:

Point No. ii: At least 5 % of the total cost of the project shall be earmarked towards theEnterprise Social Commitment (ESC) based on local needs and action plan with financialand physical breakup/details shall be prepared and submitted to the Ministry's RegionalOffice at Nagpur. Implementation of such program shall be ensured accordingly in a timebound manner.

Reply: We are already taking up social upliftment programs as part of our CSR initiativeand amount spent by us is 2.5% of our profits which is in compliance with provisions ofThe Companies Act, 1956.

Enterprise Social Commitment (ESC) is an additional cost which was not part of ourplanned costs on environmental protection cost while planning our project. We feel thata sum of 5% of project cost towards Enterprise Social Commitment (ESC) is very high asfor the capital Investment Planned by us (Rs 350 crores), this translates to a total cost ofRs 17.5 crore.

We request you to permit us 2.5 % of the project cost towards Enterprise SocialCommitment (ESC), which will be about Rs. 8.75 crore.

Higher ESC will endanger the viability of the Project and we won't be able to keep projectsustainable and to compete in the International Market.

# 2 #

We agree for the cost to be retained at 2.5% level although this was not part of plannedproject costing in acceptance of the role deemed by EAC for uplifting nearbyareas/society.

Point No. iv: The unit shall adhere to Zero Liquid Discharge (ZLD)

Reply: At present scenario, our consented effluent quantity is 686 cmd which is requiredto be treated in ETP & permitted to be sent to CETP for disposal. Our effluent isconsistently meeting the standards set by MPCB and we have installed ONLINE effluentmonitoring system which also shows compliance to MPCB consent parameters. Theadditional effluent generation in the proposed expansion will be 174 cmd and duringexpansion, we were planning for complete recycle of 174 cmd within plant, thus retainingour effluent discharge to within the existing discharge permitted that is 686 cmd.

We have already done Treatability and Feasibility for the additional effluents generated.This has been detailed in the EIA report alongwith the scheme of effluent treatment andproposal for upgradation of ETP are as under:

for Plasticizer plant: we will have an in plant facility comprising Physico chemicaltreatment followed by RO and MEE at a cost of Rs 2.2 Crore. Only condensate from MEEwill be taken to our upgraded ETP for treatment

for PA- IV plant: Since the effluents in PA-IV plant are similar to existing effluents fromPA-I to PAJII plants and our ETP consistently meets the MPCB norms hence, the ETP willbe upgraded suitably to treat additional effluent volume.

To Recycle our Effluent: In order to recycle the effluent, we will have to install RO +MEE at the outlet of the ETP to recycle the treated effluent for cooling and other sundryuses.

In accordance with EAC desire to reach ZERO discharge Level, we have studied thefeasibility of recycling the (a) effluent from expansion 174 cmd (b) partial recyclematching available steam within site and (b) complete recycle and ZLD. From this, weobserve that recycling the effluent completely will not be feasible at the site since this willentail installing a new boiler as steam requirement are insufficient for 100% recycle.

As far as capital costs are concerned, cost for recycle of effluent equivalent to theexpansion volume (174 cmd) is estimated at Rs 7.70 Crore, which capital cost forcomplete ZLD will be very high (approximately Rs 30 crore including new boiler, chimneyetc- with modification in EIA/EC). Considering present steam availability and optimumcosts, we request that the EAC to permit us a discharge of 220 cmd. This will require acapital cost of about Rs. 22 crore, but can be managed within existing steam availability.

Hence, we request you to amend the EC and permit us a discharge of 220 cmd to CETP.

# 3 #Final Request:

We are enclosing herewith the amended EMP budget for the environmental protectionwithout ESR for each of the above three scenarios viz (a) effluent from expansion 174 cmd(b) partial recycle matching available steam within site and (c) complete recycle and ZLD,which is enclosed herein as Annexure I.

As per the annexure presented, even if we select option (b) that is partial recycle anddischarge to CETP at 220 cmd, the capital cost of environmental protection works out toRs 33.20 crore, which is nearly 10% of project cost.

In the same vein, we again request to peg the ESC cost at 2.5% that is Rs 8.75 crore as thiswill be over and above the EMP budget. Thus, total cost will be Rs 33.20 crore (EMPbudget) +Rs 8.75 crore (ESC cost) = Rs 42 crore which is nearly 12% of the project cost.

We humbly request to consider our application favourably for Amendment in EC letter inforthcoming meeting and oblige.

ankingyou,

ours Faithfully,ETROCHEMICALS LIMITED,

(JKSABOO)EXECUTIVE DIRECTOR

Encl: As above

Copy to: Dr. J. P. Gupta(Chairman- Expert Appraisal Committee- Industry 2)A- 1/2 Panchsheel Enclave, New Delhi-110070

AnnexureI

ENVIRONMENT MANAGEMENT PLAN f Budgetary provision!

Environmental ControllingMeasure

Air Pollution Control (Scrubberfor Heater + 3 stage scrubber forprocess + Warehouse dedustingsystem)

Environment Monitoring

Water Pollution Control

In plant Effluent Treatment[DEP/DMP)Effluent treatment plant (forexpansion of IGPL & MPCLJ withMulti Effect Evaporator/ ATFD

Hazardous waste & Solid wastemanagement

Green Belt Development

Occupational Health & Safety

Total

Capital Investment(Rs. In Lakhs)

800

100

Case 1 175 cmdrecycle & 686cmd to CETP

220

550

100

20

30

1820

800

100

Case 2discharge of220 cmd toCETP, balancerecycled220

2000

150

20

30

3320

800

100

Case 3 TotalRecycle UnitasZLD

220

3000

200

20

30

4370

Note:

In addition to above Enterprise Social Commitment Cost Rs 8.75 Crore at 2.5%