Annexure I

TOR letter dated 10/7/2017

Government of IndiaMinistry of Environment, Forest and Climate Change

(IADivision)

Yogendra Pal SinghScientist 'D'F. No. J-llOll/205/2017-IA.1I (I)

Indira Paryavaran BhawanAliganj, Jor Bagh Road

New Delhi - 110003

Te1efax:91-11-24695365E-mail: yogendra78@nic.in

Dated: 10thJuly, 2017To,

The Managing Director(Shri M S Bagla)MIs Hindustan Adhesives LimitedB2/8 Safdurjung Enclave,New Delhi-110029

Sub: Adhesives (Chemical) Manufacturing Unit for Captive Consumption atVillage Bhadreshwar, Tehsil Mundra District Kutch, Gujarat by MIsHindustan Adhesives Limited - Terms of References - reg.

Ref.: Youronline Proposal No. IA/GJ/IND2/64169/2017; dated 24th April, 2017.

Sir,Kindly refer your proposal no. IA/GJ/IND2/64169/2017; dated 24th April,

2017, along with project documents including Form-I, Pre-feasibility Report anddraft 'Terms of Reference' as per the EIA Notification, 2006. It is noted that theproposal is for Adhesives (Chemical) Manufacturing Unit for Captive Consumption atVillage Bhadreshwar, Tehsi1 Mundra District Kutch, Gujarat by M/s HindustanAdhesives Limited.

2.0 Total land area is 2000 m-, of which green belt will be developed in 30 % area(600 m2). The estimated project cost is ~ 2 crore. Employment generation will be 100persons.

3.0 It is reported that no national parks, wildlife sanctuaries, Biosphere Reserves,Tiger/Elephant Reserves, Wildlife corridors etc. lies within 10 km distance. SakraNadi is flowing at a distance of 2.18 km in NWdirection. Chhe1a Nadi is flowing at adistance of 3.1 km in SE direction; Mitti Nadi is flowing at a distance of 4.44 km inSW direction. Lerakh Nadi is flowing at a distance of 7.96 km in NE direction. HighTide Line is situated at a distance of 3.11 km in SE direction. Bhadreshwar ReserveForest is situated at a distance of 3.7 km in SW direction. Luni Reserve Forest issituated at a distance of 7.71 in SWdirection.

4.0 Proposed product is Adhesives (Emulsion Polymer) (water based emulsion ofButyl acrylate);

• Phase 1:- 1000 TPM or 12000 TPA;• Phase 11:-2000 TPM or 24000 TPA;• Phase III: 3000 TPM or 36000 TPA

Proposal no. IA/GJjIND2/64169/2017 Page lof2

5.0 Draft Terms of Reference (TOR) have been discussed and finalized during 23rd

Expert Appraisal Committee (Industry-2) meeting held during 3rd - 5th May, 2017 forpreparation of EIA/EMP report. The Committee prescribed the following additionalTOR in addition to standard TOR (refer Ministry's website) for preparation of EIA-EMP report:

A. Additional TOR

i. Public Consultation shall be done as per provisions of the EIA Notification,2006.

ii. Submit ZLD plan.iii. Layout Plan for 10 m wide green belt around periphery of the plant to be

submitted.

6.0 These 'TORs' should be considered for the preparation of EIA/EMP forAdhesives (Chemical) Manufacturing Unit for Captive Consumption at VillageBhadreshwar, Tehsil Mundra District Kutch, Gujarat by M/s Hindustan AdhesivesLimited in addition to all the relevant information as per the 'General Structure ofEIA' given in Appendix III and IlIA in the EIA Notification, 2006. The draft EIA/EMPreport shall be submitted to the State Pollution Control Board for public hearing. Theissues emerged and response to the issues shall be incorporated in the EIA report.

7.0 You are requested to kindly submit the final EIA/EMP prepared as per TORsand incorporating all the issues raised during Public Hearing/Public Consultation tothe Ministry for considering the proposal for environmental clearance within 3years as per the MoEF O.M. No. J-11013/41/2006-IA.II (I) dated 8th October,2014.

8.0 The consultants involved in the preparation of EIA/EMP report afteraccreditation with Quality Council of India/ National Accreditation Board ofEducation and Training (QCI/NABET) would need to include a certificate in thisregard in the EIA/EMP reports prepared by them and data provided by otherOrganization(s)/Laboratories including their status of approvals etc.

4 ~~~·Y:.'lo\\

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(Yogendra Pal Singh)Scientist 'D'

Copy to:-1. The Member Secretary, Gujarat Pollution Control Board, Sector 10-A, Gandhi

Nagar - 382010, Gujarat.2. Guard File/Monitoring File/Website/Record File.

(Yogendra Pal Singh)Scientist 'D'

Proposalno.lA/GJfiND2/64169/2017Page 20f2

Annexure II

Change in Land use Document

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Annexure III

Water and Fuel Consumption and permission

Details of Water Consumption:

There will be no extraction of water from ground. The source of water will be treated water from the

tanker supply (fresh water). The various manufacturing operations in the proposed activity require

water for its process operations, utilities and domestic purposes. Waste water treatment shall be a

Multi Effect Evaporator that would have capacity enhancement in phased manner for treatment of

waste water from washing of containers or vessels, boiler blowdown, scrubber waste water etc.

Total Water Requirement after implementation of Phase III (at peak production) shall be 155 KLD out

of which 115 KLD shall be sourced from Tanker Supply (Fresh Water) and the remaining requirement

shall be fulfilled by using 40 KLD of treated water. The major water requirement is of water being added

into the final product and therefore the requirement is high. 100 KLD fresh water will be directed to RO

plant/ water treatment system, wherein permeate of 60 KLD shall be used in Process (addition into

product- 55 KLD), Domestic use (2 KLD) and miscellaneous purposes (washing/ reactor cleaning and

minor uses- 3 KLD). The remaining 15 KLD of fresh water will be used in Gardening (5 KLD) and Boiler

plant (10 KLD). Treated water of 40 KLD derived from Evaporator shall be used in Cooling Tower system

of the unit. Concentrate (2 KLD) of Evaporator shall be dried in solar evaporation pond and resulting

solids shall be disposed off at TSDF approved by GPCB.

Domestic sewerage waste water would be discharged to septic tank followed by soak pit. STP is not

feasible to be operated due to limitation of land area and extremely low quantity of waste envisaged in

the complex.

The details of water consumption for the proposed activity are given in Table below:

TABLE – Details of Water Consumption

S. No Description Quantity (KLD)

1 Process (addition into product) 55 (RO permeate)

2 washing/ reactor cleaning and minor uses (misc.)

3 (RO permeate)

3 Domestic 2 (RO permeate)

4 Boiler plant 10 (Fresh water)

5 Gardening 5 (Fresh water)

6 Cooling Tower make-up 40 (from evaporator)

Total 115 KLD

42 KLD of waste water treatment shall be treated in an Evaporator of capacity 50 KLD, where the waste

water would be mainly RO Reject and DM Plant reject(s) and Boiler blow down. 40 KLD of treated water

shall be used in Cooling Tower system. Concentrate (2 KLD) of Evaporator shall be dried in solar

evaporation pond and solids as above shall be disposed off at TSDF approved by GPCB. As all the treated

waste water will be reused within the complex, hence there will be no pollution load on water

environment and it will be a zero- liquid discharge industrial unit.

S. No Description Quantity (KLD)

1 Process (addition into product)

0

2 Cooling Tower plant 0

3 Misc. (Washing/reactor cleaning and other minor uses)

1

4 Boiler plant 1

5 Gardening 0

6 RO reject 40

TOTAL TRADE EFFLUENT 40 KLD

Total Quantity of sludge 2

Total Quantity of Wastewater 42 KLD

Details of Fuel Consumption:

Particular Fuel Quantity Fuel Type

2 x 1 TPH Boiler 400 Kg/day Agrofuel

125 KVA 6 litre/hr Low Sulphur Diesel

Annexure IV

Issues raised during Public Hearing

Public consultation for this project was conducted on 26/12/2017 at 11:00 A.M. at Hindustan Adhesives Limited, Survey No. 380, Village. Bhadreshwar, Ghandhidham-Mundra Road, Tahsil- Mundra, District - Kutch which was presided over by the Collector & District Magistration and attended by officers of GPCB, Gandhinagar. The public hearing was attended by nearby villages, NGO & other organizations. Requisite publicity through local newspapers/ media i.e. in Gujarat Samachar and Times of India Dated 23.11.2017 was given 30 days in advance of the date; as fixed for public hearing through the Collector and State Pollution Control Board official in the matter. The views and grievances of the attendees were listened. The project proponent has given commitment to fulfil the environmental and social responsibility for development of community of nearby villages. In this report, public hearing proceedings and minutes of public hearing is included in the final EIA/EMP report and submitting to Expert Appraisal Committee (EAC), MoEF, New Delhi for Environment Clearance.

S.No. Issues raised

by the Public Points Represented Response/ Commitment of Project

Proponents REMARKS

1. Shri Hari

Gadhvi,

Village

Vahar, Ta

Mundra,

Kutch, Gujrat

He represented the

following points

• Is public hearing held before establish of company or later?

• According to the rule, how many meters away the company should operate from the legal road or the residences area?

• It has been seen above the internet that there is a rule that distance of construction of any complex should be away up to 75 meters from road side. This

Representative of the project

responded that

• The adhesive (chemicals) manufacturing unit will be constructed in the next phase. The company that is currently constructing does not require environmental clearance as for this unit approval of GPCB CTE is already received.

• There is no rule for any number of K.M. as per Environmental rule. The company has done construction has done construction as per rules.

• Boundary wall constructed by the company is per the received N.A. permission.

means that the wall starts from 75 meters forward. This company’s wall is within 5 meters.

• It is said that toilets will be built for school, but 100% toilets are already done as per record, so how will you contruct toilets?

• The chemical acid specified, what will be side effects of their use? What will be the side effects of it on animals, birds and human beings?

• Regarding water, which category of water will be procured?

• 50 people who will be employed out of them what will be the percent of company employee and what will be percent of contract?

• We will bring together the people of panchayat and village and devise appropriate solution for the same.

• There will be no side effects of the chemical, as well as on the environmental attributes like animal, bird, human. There will not be any negative impact which is included in EIA that we hereby undertake.

• Fresh water will be sourced for manufacturing.

• All the 50-people employed will be of company.

2. Shri

Kumbhar

Umar

Mamad – Ex.

Sarpanch,

Bhadreshwar

Gram

Panchayat,

Kutch

He represented the

following points

• From where the water will be sourced and what is arrangement for waste water disposal. Clarification of fresh water tanker, request you to clarify the disposal of water in the entire unit.

• Clarification on the use of bore wells and the bore wells made in the company presently. In the past, the people of the village are being cheated and what has been done for vigilance not to fight for the problem of borewell in the future.

• The village Panchayat is not taken into confidence in the construction of the unit.

• Local people have not been given any

Representative of the project

responded that

• Water will be brought through tankers. Waste water will not be generated during the production process and if it is released then it will be evaporated.

• When the company purchased the land, the old bore was done by the farmer and at present stage bore well is not used. In the future the water will not be stretched from the borewell. We guarantee that we will not use it without obtaining requisite.

• The company has got the approval of Taluka panchayat for construction.

guarantee for employment. All the answered of above questions should be reported to the village panchayat in writing with the guarantee.

• What steps the company has taken to provide technical and non-technical competence to the people of the village?

• For development in Bhadreshwar village panchayat, what is the provision for development of the people? What is the benefit of the village from the company?

• Will the company give assurance above all things in written?

• At Local level company will give employment to 50 people. Giving training to the surrounding people, we will endeavor to tackle the problems of village Panchayat from all the above-mentioned matters and get appropriate solution for the village.

• After providing employment to the people of the village at the local level, training to the people of the surrounding villages will be provided and the company has provisioned of development of unemployed people of the villages.

• An amount of 25 lakhs is provisioned of the surrounding villages within 5 years of starting the unit. Rs. 25 lakhs under C.S.R activity will be used by taking people of Gram panchayat into faith and will progress for development.

• Written assurance will be given to the gram panchayat after discussion with management within seven days.

• Details area given in Section 8.5 of 8 chapter

Shall be

submitted

to Gram

Panchayat

3. Shri

Pradyuman

Sinh Jadeja –

Ex.

Sarpanch,

Taluka

Panchayat,

Present

member

Taluka

Panchayat –

Smt. Jadeja –

Chairman,

Taluka

Panchayat

Mundra.

He represented the

following points

• Any industry unit must have distance of 45 meters from the General State Highway or the boundary of the residential space.

• Many industries have been established in the past at the local level and they have received cooperation by the village people.

• Up till now, whatever construction has been done by the unit is approval taken from the gram panchayat for the same? What is the maximum number of local people will be employed.

Representative of the project

responded that

• This industry is constructed according to the state highway rule; this boundary is temporary.

• Approval has been received from taluka panchayat, and applied in the village panchayat. At present, construction contract for the purpose of providing local employment will be given to the local people, priority is given for construction. After the technical expiration of the project after next 6 to 12 months, keeping in mind the employment of more local people, with the help of local village panchayat sarpanch’s keeping in mind the leading people, the question of unemployment will be solved.

4. Shri

Shamjibhai

Ahir

Sarpanch,

Village-

Tuna, Tahsil-

Gandhidham

He represented the

following points

• That for local employment it is suggested to include employment of the disabled people, windows or the physically handicapped women along with local people of the village.

• Representative of the unit welcomed this suggestion

5. Shri Hari

Gadhvi,

Village-

Vavar,

Tahsil-

Mundra,

Kutch, Gujrat

He represented the

following points

• Question to Regional officer, G.P.C.B that various companies are spreading pollution in the region and application against the companies are already done. However, no action is yet taken on these applications then why this public hearing for this company is held.

• This company has bore well and is constructed without permission of the village panchayat what action

Regional officer, G.P.C.B replied that

• One can raise this concern today related to this project only. In case you have representative on other subject, you can submit separately. Earlier, your representation was taken care of and necessary actions were taken by the board.

• Collector and district magistrate said that this is hearing is related to pollution and environment issues. Application can be filled separately for all other issued and investigation will be done

will be taken against it.

accordingly.

6. Shri Hari

Asha Jogi,

village-

Vadala,

Tahsil-

Mundra

He represented the

following points

• Company and said thank you very much to start the company and suggested to employ the poor people.

• Representative of the unit welcomed this suggestion.

7. Shri Rabari

Shankar

Vanka,

Sarpanch –

Village

Kukadsar,

Tahsil-

Mundra

He represented the

following points

• They have stated that people around the area get employed in the company and that there is no false pollution.

• Representative of the unit said that as suggested more and more employment will be given to people of surrounding area.