GUJARAT POLLUTION CONTROL BOARD REGIONAL OFFICE GERI COMPOUND, RACECOURSE ROAD, VADODARA – 390 007

Website : www.gpcb.gov.in

PUBLIC HEARING PROCEEDINGS

In response to the request application made by the project proponent, M/s Solaris Chemtech Ltd located at Vill: Karakhadi, Padra- Jambusar Road, Ta: Padra Dist : Vadodara for their proposed project expansion of their Bromine Derivatives and speciality chemical and addition of new products; Public Hearing was organized as per the provisions of notification no. S. O. 1533 dated 14/09/2006, Ministry of Environment and Forests, Government of India, New Delhi which is covered under Category A of the above referred notification:. A copy of the Draft Environment Impact Assessment Report and the Summary of Environment Impact Assessment Report were sent to the following authorities or offices to make available the draft EIA Report for the inspection to the public during normal office hours, till the Public Hearing is over : 1. The District Collector Office, Vadodara 2. Jilla Panchayat Office, Vadodara 3. District Industries Centre, Vadodara 4. The Chief Conservator of Forests, Ministry of Environment & Forests, Govt. Of India, Regional Office (West Zone), Kendriya Paryavaran Bhavan, E – 5, Area Colony,

Link Road – 3, Ravishankar Colony, BHOPAL – 465 016 5. Regional Office, Gujarat Pollution Control Board, GERI Compound, Race Course, Vadodara - 390007 Other concerned persons having plausible stake in the environmental aspects were requested to send their responses in writing to the concerned regulatory authorities. They were requested to send their comments to the regulatory authorities as under: Central Government in Ministry of Environment and Forests, Govt. Of India, CGO Complex, Lodi Road, New Delhi – 110 003 as the matter falls under Category A of Schedule of the aforesaid notification. The Public Hearing was scheduled on date 29th January, 2009 at 11:00 hours at Manusmruti Hall, Near Parnami Agarbatti, Vill. Padra, Dist : Vadodara. An advertisement in English was published in “Indian Express ” dated 26/12/2008 and in Gujarati in “Gujarat Samachar” dated 26/12//2008 Shri V. V. Vaja, Additional District Magistrate, Vadodara, supervised and presided over the entire public hearing process. A statement showing participants present during the Public Hearing is enclosed herewith as Annexure A. A statement showing the salient points highlighting issues raised by the participants and responded to by the representative of the applicant during the Public Hearing in English and Gujarati Languages is enclosed herewith as Annexure B and B1. The copies of responses received in writing from other persons having plausible stake in environmental aspects and the replies by the applicants to the same are enclosed herewith as Annexure C (C1 to C7).

(A. A. Dolti) ( V. V. Vaja ) Place: Padra, Dist: Vadodara Date : 29/01/2009

Regional Officer, GPCB, Vadodara As Representative of the

Member Secretary, GPCB.

Addl. District Magistrate and Addl. District

Collector, Vadodara

Encl.: 1. Annexure A, B, B1 and C as above. 2. Video CD of Public Hearing.

ANNEXURE – B (ENGLISH) As per the provisions of notification no. S. O. 1533 dated 14/09/2006 issued by Ministry of Environment and Forests, Government of India, New Delhi, Public Hearing is conducted for the project covered under Category A of the said notification, of M/s Solaris Chemtech Ltd. for their proposed expansion of their Bromine Derivative and speciality chemical and addition of new products at their existing unit located at Vill: Karakhadi, Padra- Jambusar Road, Ta: Padra Dist : Vadodara Shri A. A. Dolti, Regional Officer, GPCB and representative of Member Secretary, GPCB welcomed all present to the Public Hearing. He outlined the various provisions of the Notification and briefed the procedural details for conducting this public hearing including the advertisement given earlier in the local dailies. He announced that as per the provisions of Notification, only locally affected persons will be allowed to represent in the Public Hearing while others having plausible stake may give their representation in writing which would be included in the proceedings. He then opened the Public Hearing after due permission from the Addl. District Magistrate. He invited the Project Proponent to give their introduction and to make the presentation. He also mentioned that after the presentation the forum would be open to the concerns of the locally affected people of the area. Mr. Ashok Shinde Sr. Manager (HR) of the Company welcomed panel of the public hearing committee as well as all the participants and briefed about their group company. He also briefed about priority given to local employment by the Unit. He also stated that the Project Proponent will welcome creative suggestions received during the Public Hearing. Movie showing establishment of their group companies all over India together with their production plants etc. was also shown to the gathering. Then after, Mr. Mahendra Sadadia – representative of the project proponent made presentation in Gujarati language covering introduction of the Company, technical information, details of proposed project, Environmental Management System, its impact on the environment along with proposed mitigation measures and industry’s activities regarding Corporate Social Responsibilities. After the presentation by project proponent, the Addl. District Magistrate opened the forum for representations / suggestions from the locally affected people. The statement showing issues raised by the participants and responded to by the representative of the applicant during the Public Hearing is as under : Sr. No.

Name and Address Points represented Replies from Project Proponent

1 Villagers of Karkhadi (Annexure – C1)

1. How many employee of vill. Kharkhadi are working in the existing factory?

2. How much pollution would be increased due to proposed project?

3. Industry should pay compensation to the surrounding in the event of damage to

1. Presently 13 employees are of Vill. Kharkhadi out of total 45.

2. As described in the presentation, adequate mitigation measures would be provided for the additional pollution load.

3. Precautions are being taken. However, any such complaint would be properly addressed to and

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Sr. No.

Name and Address Points represented Replies from Project Proponent

the agriculture. 4. Out of 80% of local

Gujarati employment, 40% should be from Padra Taluka.

5. Superiors of out states in the company misbehave with local sub-ordinates.

resolved. 4. Presently also most of the

workers are from Ta. and committed that similar policy would be adhered to.

5. No such discrimination is in existence in the company. However, it is committed that proper care would be taken.

2 Shri Chimanbhai Padhiyar, Sarpanch, Vill. Piludra, Ta. Jambusar.

In case of complaint investigation made with regard to their complaint about environmental pollution; reports of the same should be made available to them so as to make themselves aware about the findings.

Addl. Dist. Magi. replied that suggestion is well taken and would be implemented in line with existing Government procedure.

Shri V. V. Vaja, Addl. District Magistrate and Addl. Collector, Vadodara informed the forum that two written representations were received. One from Ahmedabad based NGO and other from Ankleshwar based senior citizen, which would be included in proceedings. The same are enclosed as Annexure C2, C4. Replies submitted by the project proponent to the same are attached as Annexure C3 and C5 respectively. After completion of public hearing Sarpanch of Karkhadi Gram Panchayat submitted their opinion in writing which is enclosed as Annexure – C6 where as that by Shri Nilesh K. Patel, Vill. Kharkhadi is enclosed as Annexure – C7. Additional District Magistrate during the public hearing raised the following points.

• Management of plastic waste. : It was replied by the representative of project proponent that liners after decontamination would be sold to actual users for recycling.

• Steps to be taken for the noise reduction. : It was replied by the representative of the project proponent that they will identify the sources of noise generation and suitable acoustic measures would be taken where as awareness programme would be conducted at Primary School – Chokari and Tithor Temple where base line noise level found higher then the specified standard. It was suggested to the project proponent that they should study and adopt measures for noise control measures available in-house / foreign and noise level should be minimized. It was suggested to the project proponent that plantation shall be carried out at Primary School – Chokari to which they agreed up on. ADM also suggested that plantation shall be selective and dense enough to abate noise related pollution.

• For which parameters and how monitoring is proposed? : It was replied by the representative of the project proponent that they would monitor for the probable air pollutants like HBr, BR2 and VOC regularly. They have VOC meter and laboratory for the in-house analysis of the said parameters. It is further added that monitoring is also out sourced and done by their environmental consultant as well as by environmental auditor.

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Additional District Magistrate while summing up the public hearing, opined that presently Government of Gujarat is attracting industries to invest and thus welcomed but industry should play pro-active role seriously and shall bear social responsibility like free of cost health check-up camp for the surrounding villagers, welfare programmes for the workers etc. together with all necessary steps for environmental pollution control measures.

The Public Hearing concluded with thanks.

l.

(A. A. Dolti) ( V.V. Vaja )

Place: Padra, Dist: Vadodara Date : 29/01/2009

Regional Officer, GPCB, Vadodara As Representative of the Member

Secretary, GPCB.

Addl. District Magistrate and Add District

Collector Vadodara

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Ref: PM/MP/206/2009 Date: 27 January 2009 To Mr. Mahesh Pandya CENTRE FOR SOCIAL JUSTICE – JANVIKAS Ahmedabad Sub: Environmental Public Hearing of M/s Solaris Chemtech Ltd at

Padra, Vadodara on 29/01/2009. Ref: PM/MP/206/2009, dated 27 January 2009. Sir, We are in receipt of a copy of your letter addressed to Shri Sajeev Tyagi, Member Secretary, Gujarat Pollution Control Board, Gandhinagar. We have studied the points contained in this letter and would like to send our reply/ clarifications as under.

1. Whether Company has valid consolidated Consent and Authorization of GPCB under various Acts for its existing unit? Please give copy of it and copy of compliance report of Consent and Authorization. What is date of validation of CCA?

Amendment for Time limit & additional product application is under process at GPCB, Gandhinagar

2. Please give copy of GPCB visit report and air/water/solid waste

sample analysis report for existing unit in last two years.

GPCB analysis report of sample dated 24/2/07 is attached 3. Whether company had been issued show cause notice / closure

order/notice under Water Act 1974 or Air Act 1981 or Environment Protection Act 1986 since starting of existing unit? If yes give copy of it. Also what remedies had been taken for restarting operation?

Show cause notice was issued and corrective action report submitted.

4. Whether unit has submitted Environmental Audit Reports regularly to GPCB for existing plant? What were suggestions of Auditor in last two years report?

Yes, Summary of suggestion are enclosed as Annexure-I 5. Please give data of production, water consumption, wastewater

generation and discharge to ETC, solid waste generation and disposal for last two years.

Enclosed as Annexure-II 6. Whether GPCB has issued NOC for proposed expansion of

project? No, not applied for NOC. 7. As per table on page 45, land requirement would be same after

expansion and for existing project!! Proposed expansion will be done in the existing land. 8. Whether permission of Central Ground Water Board has been

obtained for withdrawal of water from bore well for existing plant? If yes give copy of it.

No. 9. Whether permission of CGWB has been obtained / applied for

withdrawal of around 5.39 lakh Liter per day of water?

No, we will obtain necessary permission from CGWB.

10. Please mention calculation of ground water recharge. What would be impact of withdrawal of ground water of 5.39 lakh Liter per day on surrounding area? Exactly how much water would be recharged to balance this withdrawal?

32015 M3 per season of rain water will be recharge to

considering 8000 sqm area and 750 mm rain falls. 11. For increase in 15 personnel in plant after expansion domestic

water requirement has been doubled from 8 to 16 cum per day. Please justify.

We will correct it in our final EIA report. 12 After expansion greenbelt water requirement has been increased

from 0.5 L per sqm to 1.1 L per sqm. What changes in greenbelts would be made?

Water requirement will be increase with height of spices

of greenbelt. 13. It is written that there is no boiler in existing plant while in water

balance diagram water used in boiler has been shown. Please justify.

Boiler is operated in our sister concern which is managed

by us. 14. Whether any surface water sampling was done for Mahi River? No, we have not taken the sample from river Mahi

because it is not passing in the study area. 15. Bromine content in ground water and soil samples are not

measured as baseline monitoring. There are no chances to spillage of bromine on land so no

chance of water & soil contamination. 16. Please give name of CPCB authorized recycler/trader to who

waste oil and other solid hazardous waste is given for existing unit.

Suraj Barrel Supply Co & Unity petroleum Co is CPCB

registered recycler for used lubricating oil. 17. Please show membership certificate of NECL for disposal of solid

waste quantities after expansion. NECL certificate attached as Annexure-III 18. Please provide detailed greenbelt development programme, in

terms of type and no. of species, area and water requirement.

We will increase the greenbelt area to plant spices which exist in our existing greenbelt.

19. Whether workers had been given any workplace safety related

trainings in past? If yes give details. How many training would be given after expansion?

Yes, we have provided workplace safety related trainings every three month and same practice will continuous after expansion.

20. How many skilled and unskilled people from surrounding area

will get employment in proposed expansion project?

Around 80% of local people will get the employment in proposed expansion project

I hope the detailed clarification given by us will help you to assess our proposal and EIA report in proper perspective.

Yours truly For, Solaris Chemtech Limited K. G. Raju Unit Head

January 29, 2009 To, Pravinbhai Sheth A-8, Kallindi Apartment, Chikuwadi, Ankleshwar-393001 Gujarat. Sub:-Environment public hearing of proposed project of M/s

Solaris Chemtech Limited on 29/01/2009 at Padra, Dist. Vadodara

Respected Sir, We are in receipt of a copy of your letter addressed to Mr. R. G. Shah, Member Secretary, Gujarat Pollution Control Board, Gandhinagar. We have studied the points contained in this letter and would like to send our reply/ clarifications as under.

Sr. No.

Findings reply/ clarifications

(a) As regards drinking water, ground water sample not tested for all the specified parameters, how can you mention that it meets desired specification?

Maximum parameters which likely to contaminate by proposed activities are analyzed and found within acceptable norms.

1

(b) What treatment facilities are provided at project site

RO plant, soft water and DM water plants are available

(a) What are the environment sensitive places in study area

No environmentally sensitive place found in the study area except Schools.

2

(b) What are noise level monitoring parameters for such area

Results of noise level monitoring are given in Table No. 3-11 of EIA report

3 Green belt area is mentioned as 30%. How much % free space is available as per construction norms considering all four directions at project site

Approx. 44% of total area will be open to sky including green belt area

4 As regards to land requirement as mentioned in tabular form, Sr No.13, area open to sky and total area does not tally mathematically. What is the correct figure

Total area in which proposed expansion will take place is part of existing land.

(a) As regards cooling process how 33m3/day waste water is generated? If it is so, fresh water replacement will be > 10%. What will be mitigation measures reduce fresh water requirement?

33 m3/day waste water is generated from cooling tower blow down. Effective measures will be considered during project detailing to reduce blow down quantity and thus by fresh water requirement

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(b) Evaporation loss is 82 m3/day for existing plant and 160 m3/day on expansion, it seems too high and high water quantity will be required as replacement. What mitigation measures you suggest to reduce such high evaporation loss (It is not sure whether cooling tower is installed or not

Cooling tower of 2500TR is considered for expansion which was described in page no.2-4. Considering the cooling water pump capacity evaporation loss will not be more than 1.5%. However usage of energy efficient cooling towers will be considered during project detailing

(a) As regards ETP performance present BOD level is 1964 mg/lit what can be reason for such high value

Biodegradable organics 6

(b) How BOD level not markedly increasing in estimated waste water quality

It is based on the treatability study

7 You are using coal as boiler fuel. How "CO" level not monitored as it is also a part of NAAQ standards

At present, we have no boiler. We have monitored CO as AAQM and mentioned in table no-3.7 of EIA report.

(a) How long construction period continue?

Around one year.

(b) Any chance for developing habitat disturbances?

No, it will limited to our factory premises.

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(c) If so, what mitigation Not required in our case

measures are recommended to overcome such negative adverse impact? (a) What are storage details of solvents, hazardous chemicals, carcinogenic chemicals likewise (b) Whether it will be stored in drums or in tanks (underground / over head)

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(c) What will be inventory level

Details are provided in table no-6.1 of EIA report.

10 (a) Incase of emergency, what is evacuation procedure/

Explained in chapter-7

(b) Where is site plan show assembly point

Two assembly points are identified

Any poisonous / toxic gases likely to get generated during either of the process?

Br2 & HBr 11

If so, what are the details and how you will safe guard employees from health hazards

Two stage Scrubbing systems will be installed with required stack heights

12 Please furnish membership letters with validity period of organizations, where organic residues shall be sent for incineration. Any dioxan or furan likely to get emitted in vent during incineration?

Membership No.300 with NECL, Nadesari. Membership letter attached. May no chances to emit dioxan or furan.

13 Solvents will be used in no. of processes, what will be % evaporation loss & how you will reduce it further?

Solvent losses are expected to be in the range of 1-5%. This will be further expected to be reduced by installation of vent condensers

14 Where is decontamination procedure for discarded barrels before reuse/ sell ?

Decontamination procedure available at plant. Contaminated water will be treated with our effluent.

15 As regards green belt development

We will increase the greenbelt area to plant spices which exist in our existing greenbelt which have

(a) What types of trees will be planted (b). How many trees will be planted (c ) What will be APTR of trees (d) To protect environment from Bromine vapor pollution. What special trees will be planted? What will be height of the trees? (e) What will be fresh water consumption?

more than 75% survival rate. Around 30 kl/d water requirement for greenbelt after expansion.

16 As regard waste minimization concept Which byproducts you will recover & reuse? What will be monthly quantity? Where is rain water harvesting schematic diagram? How much rain water will be harvested?

Hydrobroic acid and sodium bromide by-products will be recovered. Quantity generation is shown in product wise material balance sheets. 32015 M3 per season of rain water will be recharge to considering 8000 sqm area and 750 mm rain fall.

As regards occupational health & safety

What is last three years safety health & environment track record of existing plant.

No recordable accident were occurred since last three years and we received appreciation certificate from Gujarat Safety council for safety performance in the year 2008.

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During periodic health check-up any serious case of infections disease or carcinogenic disorder was reported ? If so what are details & what health care facilities offered to such employees for existing plants.

No.

18 What chemicals/ Vapors will lead to Chemical Poisoning & what antidotes will be kept in ready stock.

HBr may consider toxic gas and Soda water ready to kept in our plant for neutralization.

19 What is decontamination procedure before charging any new batch.

Product changeover check list and batch log sheets are used before charging any batch

20 How do you ensure that in summer hot water will not flow through pipe line connected to eye wash fountain.

Periodical flushing of fountain carried out which ensure that no hot water will flow through pipeline.

21 Is there any exothermic reactions ? If so, what safety measures will be adopted ?

Some reactions are exothermic. High temperature alarms and auto temperature cut-off/on controls will be provided for such reactions

22 In order to justify project sustainability, what will be pay back period of Rs.30 Crores project cost ?

It is irrelevant question with environment.

23 What are details on environment protection measures for which Rs. Three Crores will be spent?

Effluent treatment plant, scrubbing systems, dust collection systems, greenbelt development, monitoring instruments etc

Suggestions: 24 As regards green belt, please

monitor periodically CO2 & O2 level for ascertaining green belt effectiveness.

Good suggestion, Will be done

25 Before constructing building blocks requiring air conditioning / refrigeration, please ensure to calculate proper R value & U factor for slab, roof and side walls to achieve maximum power saving

Will be done wherever possible

26 Please encourage timber free construction wherever possible & use eco-friendly construction material

Will try to maximize usage of eco-friendly construction material

27 Inorder to encourage energy conservation drive, please use solar system (Street lights, garden lantern, pumping water to

Will try to implement wherever possible

overhead tanks) Also use CFL lamps (with due care to handle discarded lamps to avoid mercury pollution

28 Restrict use of CFC & alterantes should be encourages to aviod global warming & to honour national drive campaign. Other green house gases emmission should be kept at minimum possible level

Will be done

29 It would have been appreciated if base line studies would have been incorporated for whole year all seasons (except monsoon) data to understand predicted pollution load in a better way which would rather help for an effective EMP to overcome negative adverse impacts

The baseline study is carried out for one season as per the guideline of MoEF for REIA and TORs recommended by MoEF.

30 Please budget some amount towards donation to uplift society weaker class persons like needy widows, handicapped, blind, orphans, senior citizens like wise

Good suggestion, company is proactive for CSR initiatives.

31 Please avail carbon credit by adopting cleaner/green technology

Will evaluate the possibility

I hope the detailed clarification given by us will help you to assess our proposal and EIA report in proper perspective. Thanks & Regards For, Solaris Chemtech Limited K.G.Raju Unit Head