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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 S. D. Intermediates, for proposed manufacturing of Synthetic Organic Chemicals (intermediates for dyes & pharmaceuticals); to be located at S. No. 88, Block No.96/B/2, Village : Karkhadi, Ta: Padra Dist : Vadodara; under the supervision of Shri C. J. Patel, Additional District Magistrate and Additional District Collector, Vadodara. Shri A. A. Dolti, Regional Officer, GPCB and representative of Member Secretary, GPCB – a panel member of public hearing committee; 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 actions taken by GPCB for vide publicity of this public hearing and 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 of their project. Shri Ketan Parikh, Managing Partner of M/s S. D. Intermediates, gave a brief introduction of the Company and project summary. Then after 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, Regional Officer, GPCB with the due permission of the Addl. District Magistrate opened the forum for representations / suggestions / objections from the locally affected people. The statement showing issues / suggestions / objections / opinion 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 Shri Krushna M. Chauhan Vill, Dabka

• He introduced himself as Environment literate and informed that he has gone through the EIA report submitted by the industry and EMS proposed seems to be adequate.

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2 Shri Narendrabhai M. Patel (Mukhi) Vill. Karkhadi

• He opined that health problems in an area increases due to pollution

• Project proponent assured for compliance.

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Sr. No.

Name and Address Points represented Replies from Project Proponent

and there shall be no addition on account of proposed industry. He also suggested industry that EMS as proposed shall be installed and operated so as there is no adverse impact. He further suggested that as submitted in writing, local people shall be absorbed.

3 Shri Pradhyumansinh Chauhan, Vill. Dabka

• He opined that progress is due to industrialization in this area and industry shall operate keeping environment in view.

• Project proponent assured for compliance.

4 Shri Natvarsinh Padhiyar Vill. Latipura

• He appreciated the details included by the industry in their presentation.

• Industrialization shall not be at the cost of agricultural activity and production shall be taken in such a way that there is no harm to the environment.

• Local people shall be given preference for employment as per their qualification.

• Poor student shall be provided financial aid for study.

• He inquired to know whether industry has obtained permission from F & D Department?

• Project proponent assured that they will ensure that due to their industrial activities there shall be no adverse impact on the environment and will absorb the local people for the employment.

• Project proponent replied

that since they are going to manufacture intermediates of dyes & pharmaceuticals and not the finished product, they are not required to obtain permission from F & D Department.

5 Shri Jigneshkumar T.

Patel, Vill. Karkhadi

• He inquired to know whether industry is going to respond to their queries once it is established?

• Project proponent replied in affirmative.

6 Shri Devendra C. Chauhan Vill. Majatan

• He expressed his feelings poetically and opined that due to unprecedented industrialization ecological balance of an area is disturbed and therefore industry shall be allowed keeping future generations in view.

• ---

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Regional Officer, GPCB informed the forum that three written representations were received prior to public hearing. One from Ahmedabad based NGO, one in form of suggestions from Ankleshwar based NGO and one from resident of Ankleshwar, which would be included in proceedings. The same are enclosed as Annexure C1, C2 and C3 along with the replies submitted by the project proponent as Annexure D1, D2 and D3 respectively. The statement showing issues / suggestions / objections / opinion raised by the participants during public hearing and also submitted in writing and responded to by the representative of the applicant during the Public Hearing is as under: Sr. No.

Name and Address Points represented and / or written submission

Replies from Project Proponent

1 Shri Arjunsinh Ganpatsinh Padhiyar Vill. Chokari

• Annexure C4 & C5 • He also further

inquired to know about hazardous waste management, about probable air pollutants along with its mitigation measures, ETP along with its capacity, production capacity and green belt development.

• Annexure D4 & D5. • It was replied by the

representative of the industry that hazardous wastes would be stored within the dedicated storage area as per the regulation and would be disposed off to common facility namely NECL. It was further informed that there would be four different types of air pollutants for which two stage water & alkali scrubbers would be provided. About ETP, it was replied that it would contain primary, secondary and tertiary treatment units having total capacity of 175 – 200 KL as against waste water generation of 142 KL. Green belt would be developed in an area of 1374 sq. m.

2 Shri J. P. Patel Samajik Nyay Morcho Gujarat, Vill. Karkhadi

• Annexure C6 • Annexure D6

3 Shri Arvindbhai Padhiyar and others Vill. Mujpur.

• Annexure C7 • ---

4 Shri Arvindbhai Padhiyar Vill. Mujpur.


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The statement showing issues / suggestions / objections / opinion submitted in writing during the public hearing and responded to by the representative of the applicant in writing then after is as under: Sr. No.

Name and Address Written submission Replies from Project Proponent

1 Shri Yogeshbhai P. Pandya Safety, Health and Environment Association, Bharuch


2 Shri Rohitbhai S. Parmar Vill. Majatan


3 Shri Pravinbhai P. Parmar Vill. Majatan


4 Shri Kesarisinh N. Padhiyar Vill. Chokari


5 Shri Vikramsinh U. Padhiyar Vill. Mujpur


6 Shri Maheshkumar G. Parmar Vill. Majatan


7 Ms. Sitaben N. Jadhav Member – Jilla Panchayat Vill. Chokari


8 Ms. Laxmiben J. Gohil Sarpanch - Chokari


Sarpanch of village Karkhadi of Dist. Vadodara and Piludra of Dist. Bharuch submitted their support to the project in writing which are enclosed as Annexure C17 and C18 respectively. Shri A. A. Dolti, Regional Officer, GPCB and representative of Member Secretary, GPCB – a panel member of public hearing committee informed to the gathering that :

• What so ever issues / suggestions / objections / opinion are received are going to be included into the minutes and would be forwarded to MoEF, New Delhi for their consideration.

• It was pointed out by one of the participant that there is no checking about the installation and operations of the EMS as given in Environmental Clearance, to which it was replied that GPCB, MoEF – Bhopal office, DoEF, CPCB etc. are monitoring the industry from time-to-time to check for the compliance by the industry.

• About the various representations regarding non-availability of EIA report / executive summary about the project prior to environmental public hearing, it was informed that as per the provisions of the EIA Notification – 2006 the same were already made available to public at various offices as mentioned in the advertisement published in two new papers and also were intimated to Sarpach of villages covered in EIA study area. It was added that now onwards EIA

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ANNEXURE –BI (GUJARATI) pyaRvr` Ane vn m>t/aly wart srkar, nvI idLhI na no3IfIkexn n>.Aes.Ao.ÉÍËË ta. ÉÌ-Ñ-ÊÈÈÎ ANvye "ke3egrI : Ae" ma> AavrI levayel me. Aes. DI. [N3rmIDIye3, s.n.ÐÐ Blok n> ÑÎãbIãÊ moje. Gaam krqDI ta.Paadra, +.vDodranI isN4e3Ik kabRnIk rsayòÜDa[z Ane famaRSyui3kl ma3ena [N3rimiDye3\sÝ na ]TpadnnI suict piryojna A4eR lok sunavÌnu> Aayojn ta.ÊÍ-ÈÍ-ÊÈÈÑ na roj, ÉÉ.ÈÈ klake mnuSm<ithol, prnamI AgrbTtI pase, vDodra padra roD, ta. padra, +.vDodra qate Ai2k ijLla me+S§e3, 7I sI.je. p3elnI deqreq he#5 raqvama> Aavel 7I Ae. Ae. doltI, p/adeixk Ai2karI, gujrat p/du8` iny>t/` boDR Ane sWy sicv 7I, gujrat p/du8` iny>t/` boDR na p/itnIi2 Ane lok sunavÌ smItIna penl sWy trIke lok sunavÌma> ]piS4t sOne AavkayaR, teAoAe [.Aa[. Ae. no3IfIkexn A>tgRt iviv2 jogva[Ao Ane lok sunavÌ p/ikya babt s>i9Ptma> maihtI AapI. temè Aa lok sunavÌnI bho5I p/is@2I A>ge gujrat p/du8` iny>t/` boDRe krel kayRvahInI mahItI AapI Ane S4aink dEink pt/oma> Aga] Aapel jaherqbrno ]Lleq kyoR. v2uma teAoAe =herat krI ke sdr no3IfIkexnnI =egva[Ao Anusar fKt S4aink Asrg/St loko Aa sunavÌma> mOiqk rjuAat krI xkxe Jyare VyajbI hIt 2ravta ANy VyaiktAo teAonI rjuAat leiqtma> krI xkxee. Tyarbad Ai2k ijLla me+S§e37I 7I sI.je. p3elnI prvangI4I lok sunavÌ x½ krel. teAoAe p/ojek3 p/ponN37I ne temna suict prIyojna ivxe maihtI rju krva jàvel. 7I ketn prIq, mene+>g pa3Rnr me. Aes. DI. [N3rmIDIye3s Ae lok sunavÌ simitnI penl Ane ]pS4It g`ne AavkayaR Ane temnI k>pnI ivxe pircy Aapel,Tyarbad p/ojeK3 p/ponN3na p/itini2 ¹ara suict piryojna A>ge pe/zN3exn krel jema> 3ekinkl maihtI Ane pyaRvr` VyvS4apn pµit, pyaRvrÌy Asro Ane tena iny>t/` A>ge sucIt pgla temj temnI sama+k jvabdarI A>genI p/v<itAo ivxenI maihtI Aapel. p/ojeK3 p/ponN3na p/itini2 ¹ara rjuAat pu`R 4ya bad p/adeixk Ai2karI, gujrat p/du8` iny>t/` boDRAe Ai2k +Lla me+S§e37InI AnumtI me5vIe S4aink Asrg/St lokonI rjuAatoã v>a2a sucno ma3e m>c quLlu muKyu. loksunavÌ drMyan hajr loko ¹ara pu0vama> Aavel p/Äo temj Arjdarna p/itini2 ¹ara Aapvama> Aavel jvab nIce mujb 0e. k/m. Naam Ane

srnamu> rju krel mudda k>pnI ¹ara Apayel

p/Tyutr. É. 7I k<*`

Aem coEha` gam : Dbka

• tem e pote pyaRvr` [jnerI ivxe =`karI 2ravta hovanu jàVyu Ane ]meyRuke temè sdr p/ojeK3na [.Aa[. Ae,

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Aheval no AWyas krel 0e. Ane tema suict pyaRvrÌy VyvS4apn yojna purtI hovanu m>tVy rju kyuR.

Ê. 7I nreN¸ Aem. p3el Ü muqI Ý gam : krqDI

• tem e potanu m>tVy rju krta jàVyu ke temna ivStarma> p/du8`na karè AaroGy iv8yk smSyaAoma> v2aro 4yel 0e Ane suict prIyojnane kar e tema v2aro n 4vo =e[Ae.tem e sucn kyRu ke drqaSt mujbnI [.Aem. Aes. S4apvI =e[Ae Ane tene yoGy rIte clavvI =e[Ae je4I ko[ ivprIt Asr n 4ay.temè v2uma> jàVyuke k>pnIAe rju kyaR mujb S4aink lokone rojgarI AapvI =e[Ae,

• p/ojeK3 p/ponN3Ae jrurI xrtonu paln krvanI qatrI dxaRvI.

Ë. 7I p/@ymnis>h cOha` gam : Dbka

• tem e m>tVy rju kyRuke AO2ogIkr`ne prIàme Aa ivStarma> ivkas 4yel 0e Ane Ane ]2oge pyaRvr`ne @yaneraqIne s>caln krvuu =e[Ae.

• p/ojeK3 p/ponN3Ae jrurI xrtonu paln krvanI qatrI dxaRvI.

Ì 7I n3vris>h pi!yar gam : ltIpura

• tem e ]2ogna p/ezN3exnma> AavrI levayelI ivgtone AavkarI.

• AO2ogIk p/v<iTtno ivkas k<i8 p/v<iTtna woge n 4vo =e[Ae. AO2ogIk ]Tpadn pyaRvr`ne nuksan n 4ay te rIte 4vu =e[Ae

• S4aink lokone laykat Anusar rojgarIma> p/a2aNy Aapvu =e[Ae.

• grIb iv24IRAone AWyasma3e naàkIy shay purI paDvI =e[Ae.

• tem e p<C0a krI ke xu ]2oge ANn Ane AO82 ivwagnI prvangI il2el 0e?

• p/ojeK3 p/ponN3e qatrI Aapta jàVyuke temnI AO2ogIk p/vi<Tt4I pyaRvr` pr ivprIt Asr n 4ay tenu @yan raqxo. tAo S4aink lokone rojgarIma> p/a2aNy Aapxe.

• p/ojeK3 p/ponN3e p/Tyutr Aapta jàVyuke teAo Da[z Ane

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famaRSyuui3klna> [N3rmIiDye3 bnavvana 0e Ane A>tIm p/oDk3 bnavvana n4I je4I ANn Ane AO82 ivwagnI prvangIlevanI rhetI n4I.

Í 7I +Gnexkumar 3I p3el gam : krqDI

• tem ee p<C0a krI ke ]2ognI S4apna 4ya bad xu temnI rjuAatone teAo s>aw5xe?

• p/ojeK3 p/ponN3e hkarma> ]Ttr AaPyo

Î 7I deveN¸ sI.cOha` gam : mjta`

• tem e temnI lagÌAo p/dxIRt krta m>tVYa rju kyRuke Aivrt AO2ogIkr` ne kar e Aa ivStarma> pyaRvrÌy smtula qorva[ rhI 0e Ane AavnarI pe!IAone @yane raqIne AO2ogIk ivkas 4vo =e[Ae.

---

p/adeixk Ai2karI gu.p/.in.boDe formne jàVyuke loksunavÌ Aga] Amdavad iS4t SvEiC0k s>g#n trf4I Aek, A>kle&vr iS4t SvEiC0k s>g#n trf4I Aek, Ane A>kle&vr iS4t Aek rhevasI trf4I Aem kul t/` leiqt rjuAato m5el 0e jeno kayRvahIma smavex krel 0e.Aa rjuAato Anuk/me Aene9r sI-É, sI-Ê, sI-Ë Ane k>pnI ¹ara leiqtma> Aapel jvab Aene9r DI-É, DI-Ê Ane DI-Ë trIke ibDa`ma> 0e. loksunavÌ drMyan hajr loko ¹ara leiqtma> rjukrvama> Aavel p/Äoã va>2a sucno ãm>tVy temj Arjdarna p/itini2 ¹ara Aapvama> Aavel jvab nIce mujb 0e. k/m. Naam Ane

srnamu> rju krel mudda ã leiqt

rjuAat k>pnI ¹ara Apayel p/Tyutr.

É 7I AjRunish g`ptis>h pi!yar gam : cokarI

• Aene9r sI-Ì Ane sI-Í

• tem e v2uma> nIce mujb p<C0a krel :

6n kcranu VyvS4apn, s>wivt hva p/du8ko Ane tena inyt/ ma3ena pgla,[.3I.pI Ane tenI 9mta, ]Tpadn 9mta Ane hrIt p¤ano ivkas

• Aene9r DI-Ì Ane DI-Í • ]2ogna p/itin2IAe p/TyuTtr Aapta jàVyuke =eqmI 6n kcrano s>g/h tena inyt s>g/h ivStarma> inym p/ma e krvama> Aavxe Ane A>itm inkal Aen.[.sI. AEl. trIke Ao5qatI samuhIk suvI2a qate krvama> Aavxe. v2uma jàVyuke car iwNn p/karna vayu p/du8ko

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ink5xe jena iny>t/` ma3e paÌ Ane AaLklI Sk/br mukvama> Aavxe. [.3I.pIma> p/aymrI, sek>NDrI Ane 3xIRyrI §I3meN3 Aekmo hxe Ane kul 9mta ÉÏÍ-ÊÈÈ iklo.lI3r p/tIidn hxe Jyare g>dapaÌno j$4o ÉÌÊ iklo.lI3r p/tIidn hxe. hrIt p¤o ÉËÏÌ vgR mI3r ivStarma> ivkas krvama> Aavxe.

Ê 7I je.pI.p3el sama+k Nyay morco gujrat gam : krqDI

Aene9r sI-Î Aene9r DI-Î

Ë 7I Ariv>dwa[ pi!yar Ane ANy gam : mujpur

Aene9r sI-Ï ----

Ì 7I Ariv>dwa[ pi!yar gam : mujpur

Aene9r sI-Ð Aene9r DI-Ð

loksunavÌ drMyan loko ¹ara leiqtma> rju krvama> Aavel p/Äoã va>2a sucno ãm>tVy temj Arjdarna p/itini2 ¹ara leiqtma> Aapvama> Aavel jvab nIce mujb 0e. k/m. Naam Ane srnamu> leiqt rjuAat k>pnI ¹ara Apayel

p/Tyutr. É 7I yogexwa[ pI

p>Dya seF3I heL4 AeND AenvayrmeN3 AesosIAexn wruc.

Aene9r sI-Ñ Aene9r DI-Ñ

Ê 7I rohItwa[ Aes. prmar gam : m=t`

Aene9r sI-ÉÈ Aene9r DI-ÉÈ

Ë 7I p/iv`wa[ pI prmar gam : m=t`

Aene9r sI-ÉÉ Aene9r DI-ÉÉ

Ì 7I kesrIUis>h Aen pi!yar gam : mujpur

Aene9r sI-ÉÊ Aene9r DI-ÉÊ

Í 7I ivk/mis>h yu. Pi!yar gam : mujpur

Aene9r sI-ÉË Aene9r DI-ÉË

Î 7I mhexkumar +. Aene9r sI-ÉÌ Aene9r DI-ÉÌ

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prmar gam : m=t`

Ï istaben Aen.=dvsWy vDodra +Lla p>cayt gam : cokarI

Aene9r sI-ÉÍ Aene9r DI-ÉÍ

Ð li(mben je. gohIl srp>c cokarI

Aene9r sI-ÉÎ Aene9r DI-ÉÎ

gam krqDI +Llo vDodra Ane gam iplu¸a +Llo wrucna srp>c7IAoAe suict prIyojna ma3e leiqtma sm4Rn rju krel je Anuk/me Aene9r sI-ÉÏ Ane sI ÉÐ trIke ibDa`ma> 0e. 7I Ae. Ae. doltI p/adexIk Ai2karI gu.p/.in. boDR Ane sWysicv, gu.p/.in. boDR na p/itini2 ke je lok sunavÌna penl sWy 0e tem e ]piS4t g`ne jàVyuke :

• At/e je p` rjuAato ã va>2a sucno ã m>tVyo rju 4yel 0e teno smavex kayRvahI no2ma> krvama> Aavxe Ane v2u kayRvahI ma3e pyaRvr` Ane vn m>t/aly, nvI idLhIne moklvama> Aavxe.

• ]piS4t g` pEEkI Aek sWyAe jàvel ke pyaRvrÌy m>jurI Anusar pyaRvrÌy VyvS4apn p@2itnu S4apn ke s>caln krvama> Aavtu n4I jena ]Ttrma> jàvvama> AaVyuke gu.p/.in. boDR, pyaRvr` Ane vn m>t/aly – wopal kcerI, vn Ane pyaRvr` ivwag rajy srkar, keNdIy p/du8` inyt/` boDR ivgere ¹ara ]2ogo ¹ara jrurI xrtona paln babte smyaNtre ckasÌ krvama> Aave0e.

• pyaRvrÌy lok sunavÌ Aga] [. Aa[. Ae. rIpo3R ã kayRkarI sara>x ]plB2 nhI hova A>genI rjuAato babte jàvvama> AaVyuke [.Aa[. Ae. no3IfIkexn ÊÈÈÎnI =egva[Ao Anusar Aa Ahevalo S4aink vtRman pt/oma> p/is@2 krel =her sucna Anusar iviv2 kcerIAoma =her jnta ma3e ]plB2 kravvama> Aavel. [. Aa[. Ae AWyas ivStarma> AavrI levayel gamona srp>c 7IAone p` =` krvama> Aavel.v2uma> [. Aa[. Ae. rIpo3R ã kayRkarI sara>x Aga]4I loksunavÌna S45e p` ]plB2 kravvama> Aavxe.

• ]2ogo ¹ara g>da paÌna inkal ma3e irvsR borI>g krvama> Aavtu hovanI frIyado babte jàvvama> AaVyuke gu.p.in.boDR ¹ara AO2ogIk Aekmonu inymIt monI3rI>g krvama> Aave 0e Ane Aavo ko[ ikSso @yane Aavel n4I. tem e ]piS4t g`ne coKKs maihtI, =e hoy to, Aapva jàVyu je4I Aava ko[ ]2og same sqt pgla l[ xke. ]2og ¹ara AavI p/v<iTt g>wIr guno 0e je ko[ p` s>=egoma> clavI levaxe nhI.

• lok sunavÌna S45 babte p/ojeK3 sa[3 pr ke tenI n+k sunavÌ go#vva A>genI xKyta ckasvama> Aavxe.

[.sI.pI. cenlnI ApurtI 9mta Ane sIpej lIkej A>genI rjuAato babte 7I hema>g w¤, =e[N3 Aem.DI. [.sI.pI.lImI3eDAe jàVyuke [.sI.pI.cenl c`trnI bnel 0e Ane samaNy rIte ËÍ v8R ]pyog9m 0e. tem e jàVyuke cenl ÊÏ v8R 4I kayRrt 0e. tem e cenlna s>caln Ane =5vÌ A>genI

S. D. INTERMEDIATES Regd. Off. : 607, Sterling Centre, R.C.Dutt Road, Alkapuri, BARODA – 390007. Admin. Off. : 4 Impala House, 36 Vishwas Colony, Alkapuri, BARODA – 390007. Tel No: 91 265 2334396 / 3080760 Fax: 91 265 3087678 E-Mail: [email protected] Website: www.sdichem.com

___________________________________________________________

Proposed Works: Block No. 96/B/2, Village Karkhadi, Tal. Padra, Dist. Vadodara, GUJARAT.

Annexure: D-1/1 25th May, 2009

To,

Paryavaran Mitra (Centre for Social Justice – Janvikas) 502, Raj Avenue, Bhaikaka Nagar Road, Nr. Thaltej Cross Road, Thaltej, Ahmedabad - 380059

Dear Sir,

We are in receipt of your above referred letter regarding the subject matter and in this

context we would like to clarify here that we have made available the whole EIA report

of our proposed project on the websites of GPCB for the inspection electronically as

per the directions and guidelines prescribed under Annexure-IV of EIA notification SO-

1533, dated 14/09/2006 of the MOEF. We have also made available the full draft EIA

report for reference at a notified places as per the prescribed guidelines.

However, on receipt of your written request trough above refereed letter we arranged

to forward you the full draft EIA report with the permission of printing by our consultant

through the email on the same day i.e. 20/05/2009. The same EIA report was also

uploaded on the websites of GPCB very next day i.e. 21/05/2009.

We hope this will suffice your requirements.

Thanking you,

Sincerely yours,

For, S.D. Intermediates

(Ketan Parikh) Partner

Subject : EIA reports and Executive Summaries Of our proposed project is not permissible to print by the authors.

Reference : Your Letter Ref.: #PM/MP/290/2009, dated 20/05/09

Annexure: C-1/2 Ref: #PM/MP/287/2009 Date: 20 May 2009 To Shri R G Shah Member Secretary Gujarat Pollution Control Board Gandhinagar Sub. : Environmental Public Hearing of S D Intermediates Pvt. Ltd on 25/05/09 at Padra, Vadodara Sir, We have reviewed EIA report of above mentioned project. Following are our comments/suggestions/observations regarding project and EIA report.

1. Whether permission of Central Ground Water Board has been obtained for withdrawal of water from own bore well even it is fall under safe area? Please give copy of it.

2. Whether alternative of ground water usage has been explored at time of planning for total water requirement of plant?

3. What is the exact fuel which would be used in both boilers? Different fuel has different impact and different pollution levels in air.

4. Please justify the stack heights, as fuel is yet not decided. 5. Please give details of hazardous waste storage area. 6. Please show membership certificate of NECL for disposal of hazardous waste. 7. Baseline monitoring data are more than one year old. 8. Please give exact dates of baseline monitoring data in summer 2008. 9. Please provide detailed greenbelt development programme, in terms of type and no. of

species, area and water requirement. 10. How many skilled/unskilled people from surrounding area will get employment in

proposed project? Yours truly Mahesh Pandya Cc: Regional officer, GPCB, Vadodara

Paryavaran Mitra 502, Raj Avenue, Bhaikakanagar road Thaltej, Ahmedabad - 380059 Telefax - 079-26851321 email - [email protected] website - www.paryavaranmitra.org.in


___________________________________________________________


Annexure: D-1/2 25th May, 2009

To,

Paryavaran Mitra (Centre for Social Justice – Janvikas) 502, Raj Avenue, Bhaikaka Nagar Road, Nr. Thaltej Cross Road, Thaltej, Ahmedabad - 380059

Dear Sir,

We are in receipt of your above referred letter regarding the subject matter and in this

context we would like to submit following point - wise clarification and details as per

your requirement,

1. Whether permission of Central Ground Water Board has been obtained for

withdrawal of water from own bore well even it is fall under safe area? Please give copy of it.

Our proposed project site falls under White/Safe zone as per the 'Geo

Hydrology map' of GWRDC, Gandhinagar. Hence, we do not need to obtain the

permission for the ground water withdrawal. However, we have applied to the

Central Ground Water Authority, Ahmedabad for the withdrawal of water 140.5

KL/day on dated 04/03/2009.

2. Whether alternative of ground water usage has been explored at time of

planning for total water requirement of plant? There is Narmada canal passing nearby our proposed site, however which is

not the perennial source and flowing through out the year. As well at present the

water from the canal is not available for the industrial purpose. In future, we will

try to use the same source if it is available.

Subject : Environmental Public Hearing on 25/05/2009 for our proposed project to be set up at village Karkhadi of Padra Taluka in Vadodara district.

Reference : Your Letter Ref.: #PM/MP/287/2009, dated 20/05/09


___________________________________________________________


Contd…2

-::2::-

We propose to use ground water and to compensate the water withdrawal we

are going to adopt the rain water harvesting system.

3. What is the exact fuel which would be used in both boilers? Different fuel

has different impact and different pollution levels in air. As far as possible we will use natural gas but in the case of non availability of

the natural gas we will use LDO /Coal/firewood which is easily available.

We have already considered the maximum impact for the worst case scenario.

4. Please justify the stack heights, as fuel is yet not decided.

We will provide 35 m height for the stack attached to steam boilers considering

the worst case scenario for use of any fuel mentioned above.

5. Please give details of hazardous waste storage area. The unit will provide isolated area of 183.0 m2 for the hazardous waste storage

within premises having pucca floor, roof cover and leachate collection system

for the on-site storage of hazardous waste.

6. Please show membership certificate of NECL for disposal of hazardous

waste. We have already obtained the acceptance letter from the NECL for the disposal

of hazardous waste which is attached here as Annexure – VIII in our REIA

report.

7. Baseline monitoring data are more than one year old.

The baseline data was collected during the period of 13/03/2008 to 02/06/2008

and the presentation for the project profile and EIA study was made before

Ministry of Environment and Forest (MoEF), New Delhi on dated 22/12/2008

and subsequently we have submitted the EIA report to the GPCB for conducting

the public hearing on dated 24/02/2009.


___________________________________________________________


Contd…3

-::3::-

Hence, the period is less than 9 months between study period and the

submission of EIA report to the GPCB for public hearing.

8. Please give exact dates of baseline monitoring data in summer 2008. The baseline monitoring data is collected during the 13/03/2008 to 2/06/2008.

9. Please provide detailed greenbelt development programme, in terms of, area and water requirement.

We have already given the details of green belt in terms of area, types and no.

of species in Chapter – 5; Section No. 5.10, Page No. 14 of 19 and water

requirement for greenbelt development in chapter-2 Section No. 5.10, Page No.

14 of 19 of our REIA report.

10. How many skilled/unskilled people from surrounding area will get employment in proposed project?.

For the operation of the proposed project approximate 71 peoples will be

required and out of that most of the skilled/unskilled people will be employed

from the surrounding area.

We hope this will suffice your requirements and justify your clarifications.

Thanking you,

Sincerely yours,

For, S.D. Intermediates



___________________________________________________________


Annexure: D-2 25th May, 2009

To,

Pravinbhai Sheth, A-8, Kalindi Appartment, Chikuwadi, Ankleshwar-393001, Gujarat Subject : Environmental Public Hearing on 25/05/2009 for our proposed

Projectsituated at village Karkhadi of Padra Taluka in Vadodara district. Reference : Your Letter dated 16/05/09

Dear Sir,

We are in receipt of your above mentioned letter regarding the above subject matter

and in this context we would like to submit point wise clarification and further details as

per your requirement,

1. It is appreciated that,

a) Employment opportunity is for 71 persons.

b) Net water withdrawal rate approx 5.45 %.

c) Expenditure towards occupational health Rs. 4 Lacs.

d) Good philosophy Considered for green belt development.

e) Adopting cleaner production technology.

f) Chemicals quantum is very well defined in manufacturing process

We are thankful for your views and appreciation for our proposed project 2. Have you identified buyers for disposing off various bye- products?

We are aware of many parties who are dealing in / using these by-products. However we have not yet confirmed any arrangements with them as it is too early to do so. We are likely to start production only in 2010-2011 and so before we start production, we will tie up with them.

Contd…2/-


___________________________________________________________


-: 2 :-

3. Is any process Exo-thermic in nature, if so,

a. What sort of chilling operations are designed?

b. In case of an explosion, what emergency plans are worked out?

There are some processes which are exothermic in nature. We will be installing Cooling towers and Chilling plant, if required. So in case of emergency, circulation of water / chilled water will be done. We will also install rupture discs and safety valves on reactors so that in case of extreme problems, the rupture disc / safety valve will open and lead the gases through scrubber system into catch pot. This will release the pressure safely and avoid any major explosions as well as pollution problems.

4. a) What will be individual solvent recovery percentage wise?

b) How you will reduce it further say in first three years?

a) We propose to use various solvents and the type of solvent for each particular process will be decided at the time of operation. Hence the individual solvent recovery and balance at this stage is not possible to give. This topic has been discussed in detail along with overall solvent consumption and mass balance in Chapter – 2; Section No. 2.6.2, Page No. 65 of 95 of our REIA report.

b) Initially we will adopt best available technology for the distillation which will comprises of brine / chilled water circulation in the condenser and whenever require it will be carried out under vacuum. In future it will be upgraded and modified in harmony with latest scenario and necessity of the process.

5. Ground water analyzed for Eight villages & being certified that it complies drinking

water standards BUT, has all samples analyzed for all parameters as listed in IS

10500?

Contd…3/-


___________________________________________________________


-: 3 :-

We have not analyzed all the parameter as listed in IS 10500, but we have covered all the parameter which are very important to identify the characteristics of water and susceptible to the contamination looking the project profile.

6. Your project site land area is LOW LYING area & you do not need to fill it, as it is

known that No. of industries are nearby,

a) Will their storm water discharge (or effluent discharge by chance) not disturb

your production?

b) Where is contour plan?

a) At present there is no storm water discharged in to our proposed project site from the nearby area and if so it will be diverted properly. Hence, there will not be any chances for disturbance during our production activities. We have also proposed to install rain water harvesting system within the premises and all the storm water will be diverted for the ground water recharge.

b) It is too early to prepare the contour plan and in future it will be prepared,

if required. 7. Refer to table 5.7 (A),

a) Which trees are suitable to absorb air pollutants like NOx, SO2, HCL, HBr?

b) What will be their air pollution tolerance index APTI ?

As per the table No. 5.7 (A), the listed trees have been selected looking to the surrounding environment of Padra Taluka and Out of which Neem, Peepal, Eucalyptus, etc. are very suitable to absorb NOx, SO2 & SPM and hence the APTI for the same is not worked out.

8. Lot of chemicals are toxic & hazardous, what Antidotes & its quantity will be kept

handy & ready to meet any likely chemicals poisoning exigencies?

Contd…4/-


___________________________________________________________


-: 4 :-

We have already mentioned about first aid antidotes in Chapter - 6 of our REIA report and beside these, we will also provide some general/common antidotes to counteract the poisoning effect; like Eye wash & Shower equipments, Oxygen or other respiratory supports, Universal Antidotes, milk, Gastric lavage (Stomach Pump), Whole Bowel Irrigation ( Poly Ethylene Glycol).

9. Though chemicals quantum is very well defined in manufacturing process & flow

diagram, what will be total monthly requirements (this should have been

incorporated separately in one tabular form for an easy reference.

We have already defined Raw Material Details with monthly requirement in separate tabular form in Chapter – 2; Section no. : 2.6.1; Table No. 2.18 (B); Page No. : 62 of 95 of our REIA Report.

10. In replying to parking area questions by Authority, you mentioned parking area as

NA, BUT with no. of employees employed, visitors visiting around & fleet Cargo

Trucks / Tempos movement around, why parking area is not planned for a better in

house traffic control.

We will provide sufficient parking area on common/open plot nearby to our Administration Building.

Referring to Authority Questionnaire, some contradictions are observed, please correct such contradictions or is there any explanation? (Sr. No. 11 to 19 )

11. In replying" whether any industries existing in study area" question you

mentioned as NA while on other side you have listed no. of industries’ name &

distance.

As mentioned in Questionnaire there is not any Thermal Power Plant situated within the existing study area, but numbers of industries of various types are there, which are listed in Chap. No. 3; section No.: 3.2.1; Table No. : 3.3 of page No.: 5 of 62 of our REIA Report.

Contd…5/-


___________________________________________________________


-: 5 :-

12. Water in put you mentioned as 140.5 M3/day then how treated effluent is

increasing to 142 M3/day, IS THERE NOT ANY PROCESS LOSS?

We have already given clarification for the higher waste water generation than the consumption in Chapter – 2; Section no. : 2.9.1 (A); Page No. : 78 of 95 of our REIA report. According to that clarification there will not be any process Loss.

13. One side you mentioned as no toxic / hazardous material & on other side you listed

the same in annexure – IX.

In our REIA report we have nowhere mention that there will not be any toxic / hazardous materials and the details about the same are given separately in Annexure – IX.

14. One side you mentioned that no recycling / recovery of any wastage & other side

you mentioned to adopt cleaner production technology.

Right from the conception of the project, We have explore the opportunity to recover and sell the off stream products other than the main product, which can have potential users. Hence we have not mentioned it as wastage.

Simultaneously, we also propose to adopt cleaner production technology by taking action like Pollution prevention, Water conservation, Energy conservation, Reuse-recycling, Good house keeping, etc

15. One side you mentioned that no solid waste will be generated & other side you

mentioned the same will be sent to TSDF site.

There will not be any generation of the solid waste from the manufacturing of proposed products. But the type of waste likely to be generated due to our proposed project and which are covered under the Hazardous waste (Management, Handling & Transboundry Movement) Rules, 2008 has been considered as Hazardous Waste. These waste will be handled and disposed as per the applicable rules.

Contd…6/-


___________________________________________________________


-: 6 :-

16. One side you mentioned that competing users of drinking water source SW - GW

as NA (Not Available ) and other side you have listed no. of GW source & analyzed

to comply standards. Ground water is the only source in the study area for the drinking and

industrial purpose. There are so many other competing users for the ground water and authentic data for the same with respect to size and quantity is not available.

17. One side you mentioned total production capacity is 615 MT / M & other side you

mentioned monthly production capacity as total 1353 MT/ M.

(7 Category / batch size X no. of batches considering min 85 % Yield)

In our REIA report we have clearly mentioned that our gross total of Cumulative Production of each category will be 615 MT/Month and we have not mentioned anywhere in our REIA report about the Monthly production capacity as 1353 MT.

18. One side in one of manufacturing process (2.5.2) no solvents refers as usage,

while in flow diagram solvent recovery is mentioned.

Regarding to the manufacturing process (2.5.2) it is clearly mentioned that purification will be carried out if it is required as per the market demand for the quality of finished product. Hence it is the optional case, when the purification will be require, solvent will be used and which will be already included in our mass balance/process flow diagram.

19. One side you mentioned annual rainfall as 348 mm & other side you refer the same

as 1083 mm Will our water withdrawal rate not vary?

At this point we would like to clarify that, 348 mm rainfall is the maximum rainfall during the year in the month of July not the annual rainfall and the Average annual rainfall is @ 1000 mm for the Baroda district as per the handbook of Climate of Gujarat.

20. Treated effluent final discharge you mentioned total as 142 M3/Day for Eight

locations, what is individual locations discharge quantity? Contd…7/-


___________________________________________________________


-: 7 :-

Our treated effluent @ 142 M3/Day will be discharged only into ECPL (Effluent Channel Project Ltd.) channel which carries the treated effluent into ESTUARY of river Mahi for the final disposal and there will be only one discharge point which is highlighted in our Questionnaire for Environmental Appraisal. And apart from this there will not be any other kind of disposal to any other mode.

21. Methanol referred as non-corrosive, rather it is more important to note as TOXIC? It is noted as per your suggestion.

22. As there are no. of industries in study area, may be also using coal as a fuel why

CO not monitored as it is also a one of parameter in NAAQ standards?

As mentioned in our report we will use coal / wood/ LDO/ NG as fuel and we will try to minimize incomplete combustion by installing best quality burners and maintaining proper fuel to air ratio. So that the emission of the CO in the air from our proposed unit will be negligible and hence it was not necessary to monitor CO in Ambient Air.

23. Why table 3.11 A & B is not visible fully? (How one can stud these data)

During the pdf conversion problem the table was not fully visible, we assure that next time we will take special care for the same.

24. Lot of flammable chemicals will be used, in order to avoid any fire risk,

a) How do you neutralize static charge of solvent drums / tanker at the gate entry

point itself?

b) How many lightning arrestors will be installed at project site?

c) How much reserved water stock will be maintained?

d) How much foam compound shall be kept ready as a minimum inventor? There will be provision of earthing to neutralize static charge of solvent

drums / tankers at the terminals of the loading and unloading of the products/raw materials.

As per requirements and advised by safety consultants, lighting arrestors, reserve water stock and foam compound will be provided.

Contd…8/-


___________________________________________________________


-: 8 :-

25. Charter Accountant has certified Capital cost as Rs. 870 lacs it is good BUT, WHY

HIS CONTACT DETAILS LIKE FULL ADDRESS & TELEPHONE / FAX / EMAIL

DETAILS ARE NOT ON HIS LETTER HEAD? (this is just to have authentic

transparency) Due to inferior quality of Xerox the details on the letter head were not clearly

visible. We will take care to improve the Xerox quality Next time.

SUGGESTIONS TO BE IMPLEMENTED IF FOUND ACCEPTABLE AND ECONOMICAL:

26. All possible care should be taken at the time of handling poisonous chemicals,

flammable solvents. Will be Complied

27. Please ensure incorporating inbuilt sensors like fire, heat, smoke and flame in fire

alarms system in case of likely solvent fire. Will be Complied

28. As regards green belt, please monitor periodically CO2 & 02 level for ascertaining

green belt effectiveness.

It is not require to monitor periodically C02 & 02 level . 29. Before constructing building blocks requiring air conditioning / refrigeration, please

ensure to calculate proper R value & U factor for slab, roof, side walls, lasses to

achieve maximum power saving

Proper R value or U factor for slab, roof, side walls, glasses will be considered before constructing building blocks to achieve maximum power saving.

30. Please encourage timber free construction wherever possible & use ecofriendly

construction material.

We will definitely try for the timber free construction wherever possible & use ecofriendly construction material.

Contd…9/-


___________________________________________________________


-: 9 :-

31. In order to encourage energy conservation drive, please use solar system (street

lights, garden lantern, heater, pumping water to overhead tank, etc.) Also use CFL

lamps (with due care to handle discarded lamps to avoid mercury pollution)

Will be complied 32. Restrict use of CFC & alternates should be encouraged to avoid Global Warming &

to honour national drive campaign.

Other green gases emissions should be kept at possible minimum level.

Will be complied 33. It would have been appreciated if baseline studies would have been incorporate for

whole year all seasons (except monsoon) data to understand pollution load in a

batter way which would rather help for an effective EMP to overcome negative

adverse impacts.

We have conducted base-line studies for one season as per the Terms of Reference issued by the Ministry of Environment & Forest (MoEF), New Delhi.Secondly, ours is a small scale unit and looking to the project profile the baseline studies carried out for one season is sufficient to understand the pollution load and also to assess the impacts on Environment.

34. For Equipments generating noise, it is advisable to specify in purchase order itself

to specify suitable acoustic measures with permissible dBA.

Will be complied. 35. Draft REIA prepared by environment consultant should have been properly

reviewed by project proponent to rectify shortfalls before submitting to GPCB.

Noted and will be taken care in future

We hope this will suffice your requirements and justify your clarifications.

Yours Sincerely,

From, S.D. Intermediates,


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