reckitt benckiser (india) private...

Pre-Feasibility Report

1

PRE-FEASIBILITY REPORT

(Submitted to Ministry of Environment, Forest & Climate Change, New Delhi)

FOR THE BULK DRUG MANUFACTURING UNIT

By

RECKITT BENCKISER (INDIA) PRIVATE LIMITED

Plot No.: 176 OF SIPCOT, Phase 1,

MOOKANDAPALLI VILLAGE

HOSUR TALUK

KRISHNAGIRI DISTRICT

December 2017

TAMIL NADU


2

Contents

S.NO DESCRIPTION PAGE NO

1 EXECUTIVE SUMMARY 4 1.1 Salient Features of the Project 5 2.0 INTRODUCTION 6

2.1 Identification of the Project and Project Proponent

6

2.2 Project Proponent

7

2.3 Brief Description of the Nature of the Project

8

2.4 Need for the Project and its Importance to the Country and or Region

8

2.5 Employment Generation 8 3 PROJECT DESCRIPTION 9

3.1 Location 9 3.2 Alternate Sites 15 3.3 Product and Production Capacity 15 3.4 Raw Materials 16 3.5 Material Balance 16 3.6 Manufacturing Process 17

3.6.1 Process Description 17 3.6.2 The Chemical Reaction involved in the process 18 3.7 Resource – Utilize & Recycling 19

3.7.1 Water 19 3.7.2 Power Requirement 20 3.7.3 Utilities 20 3.8 Quantity of Waste to be generated 21

3.8.1 Waste water generation and utilization 21 3.8.2 Solid Waste Generation and Disposal 21

4.0 SITE ANALYSIS 22 4.1 Connectivity 22 4.2 Land Form, Land use and Land ownership 22 4.3 Existing Infrastructure 23 4.4 Climatic Data 23 4.5 Social Infrastructure 23 5 PLANNING 23 5.1 Planning Concept 23 5.2 Population Projection 23 5.3 Land Use Planning 24 5.4 Assessment of Infrastructure Demand 24 5.5 Amenities/Facilities 24 6 PROPOSED INFRASTRUCTURE 25 6.1 Industrial Area 25 6.2 Residential Area 25 6.3 Greenbelt 25 6.4 Social Infrastructure 25 6.5 Connectivity 25


3

6.6 Drinking Water Management 25 6.7 Sewerage System 25 6.8 Industrial Waste Management 25

6.8.1 Process Emissions Management 26 6.8.2 Emissions–Utilities 26 6.8.3 Noise Environment 26

6.9 Hazardous / Solid Waste Management 27 6.9.1 Power Requirement & Supply / Source 27

7.0 REHABILITATION AND RESETTLEMENT (R&R) PLAN 27

8.0 PROJECT SCHEDULE & COST ESTIMATES 27 8.1 Time Schedule for the project construction 27 8.2 Estimated Project Cost 27 9.0 ANALYSIS OF PROPOSAL (FINAL RECOMMENDATIONS) 28 9.1 Budgetary allocation for Pollution Control Measures 28


4

List of Figure

FIGURE NUMBER

NAME OF FIGURE PAGE NO

1 Location of Project Site 10 2 Topographical Map showing 10 Km Radius 11 3 Specific location (project location in SIPCOT Industrial

complex) 12

4 Plant Layout 14 5 Satellite Image of project site 13

List of Tables

TABLE

NUMBER NAME OF TABLE PAGE NO

1 Co-ordinates of all corners of the Project site 13 2 List of Permitted Product with its capacity 15 3 List of Proposed Product with its capacities 15 4 List of Raw Materials 16 5 PCMX Material Balance 16

5A Material Balance - Side Reactions 16 5B Material Balance - Side Reactions 17 6 Water Balance for the proposed project 19 7 Waste water Generation Details 21 8 Existing Hazardous & Other Waste, Quantity &

Disposal details 21

9 Proposed Hazardous & Other Waste, Quantity & Disposal details

22

10 Break Up of Land Use Pattern 24 11 Maximum Process Emission 26 12 Budget for Pollution Control Measures 29

List of Annexures

ANNEXURE NUMBER

NAME OF ANNEXURE PAGE NO

1 Industry letter to TNPCB showing Consent order dated 23-12-1993 30-33 2 Environmental Clearance dated 27-2-2008 34-38 3 CTO dated 9-3-2009 39-62 4 Latest CTO dated 13-9-2017 valid upto 31-03-2018 63-68 5 Hazardous Waste Authorization dated 26-7-2017 valid upto 25-7-2022 69-72 6 CA Certificate 73 7 GEPIL Agreement 74-87


5

Pre-Feasibility Report for Expansion of Bulk Drug Manufacturing Unit

1.0 EXECUTIVE SUMMARY

M/s. Reckitt Benkiser (India) Private Limited proposes to expand its Bulk Drug Manufacturing

unit in the existing plant premises of 3.20 Ha. (32010. 19 sq.m). The Unit is located in Plot 176,

SIPCOT Industrial Complex. Phase 1, Hosur, Krishnagiri District, Tamilnadu. The expansion proposal is

to obtain Environmental Clearance (EC) from the Ministry of Environment, Forests and Climate

Change (MoEF&CC) to expand the manufacturing of Para Chloro Meta Xylenol (PCMX) from

permitted production capacity of 1500 TPA to 3000 TPA.

Background:

Industry was established in the year 1993 (Annexure-I) and obtained first Consent Order

from TNPCB (Tamil Nadu Pollution Control Board) to manufacture Para Chloro Meta Xylenol with a

total capacity of 500 TPA by Consent order No. 8629 vide TNPCB proceeding no.

T10/DMP/F335/R/W/93 dated 23-12-1993 and obtaining renewal consents for Operation regularly.

In 2008, Industry proposed for expansion and obtain Environment Clearance from MoE&F for the

expansion of the PCMX production capacity from 500 TPA to 1500 TPA vide No. F.No. J-

11011/995/2007-IA (II) dated 27-2-2008 (Annexure-II). Also obtained CTE expansion from TNPCB

vide proceeding no. T10/TNPCB/F-38575/KNI/R-L/A/2008 dated 11-6-2008 and Consent Order for

Operation under Air & Water acts vide consent order No.17797 dated 09-03-2009 with proceedings

No.T10/TNPCB/F-38575/KNI/R-L/A/2008 dated 09-03-2009 (Air act) and consent order no. 21758

dated 09-03-2009 with proceedings No. T10/TNPCB/F-38575/KNI/R-L/W/2008 dated 09-03-2009

(Water act) (Annexure-III). Industry obtaining renewal consents regularly under Air & Water Acts.

Latest consent order No.170824675689 dated 13-9-2017 with proceedings No.

T4/TNPCB/F.0804HSR/RL/HSR/A/2017 dated 13-09-2017 (Air Act) & Consent order

No.170814675689 dated 13-9-2017 with proceedings No. T4/TNPCB/F.0804HSR/RL/HSR/W/ 2017

dated 13-09-2017 (Water Act) and the both consents are valid upto 31-03-2018 (Annexure-IV).

Industry also obtain renewal of Authorization for Hazardous Waste handling from TNPCB vide

Authoriziation No. 17HRC6788106 dated 26-7-2017 with proceeding No.

T2/TNPCB/F.0804HSR/HWA/RL/HSR/2017 dated 26-7-2017 valid upto 25-7-2022 (Annexure – V).


6

Due to high market demand, Industry once again proposing for expansion of PCMX

production from 1500 TPA to 3000 TPA within the existing premises with a total investment of Rs.

3,872.79 Lakhs including the existing investment of Rs. 2,240.63 Lakhs. (Annexure – VI)

The proposed expansion of the manufacturing of PARA CHLORO META XYLENOL (PCMX) is a

bulk drug falls under 5 (f) synthetic organic chemicals industry (bulk drug intermediate excluding

drug formulations) and is categorized under “A” as its location being in proximity (0.4km) to

interstate boundary of Tamil Nadu and Karnataka and will be appraised at center level by the

Ministry of Environment, Forest and Climate Change, Govt. of India, New Delhi.

Industry has prepared Form-I along with draft Terms of Reference (ToR) in the process of

obtaining ToR for preparation of EIA, in line with issue of Environmental Clearance. Hence, pre-

feasibility report highlighting the expansion project and the various operations including waste

generation and mitigation measures are prepared & submitted to the Environmental Appraisal

Committee (EAC) for issuing ToR.

1.1 Salient Features of the Project

S No Parameter Description

1 Category of Project as per EIA Notification & Amendments

5 (f)-A

2 Project Cost Existing – Rs. 2240.63 Lakhs Additional – Rs. 1632.16 Lakhs After Expansion –Rs. 3872.79 Lakhs

3 Location Plot No. 176 SIPCOT Industrial Complex. Phase 1. Village: Mookandaplli Taluk: Thiruvallur District: Krishnagiri State: Tamil Nadu

4 Geographical Location LAT : 12°45'27"N

Long:77°47'43"E

5 Land Use Classification Industrial Use

6 Source of water SIPCOT

7 Nearest Town Hosur (3 Km SE from the project site)

8 Populated areas Mookandapalli village at 0.6 Km SE

9 Nearest Airport Kempegowda International Airport (BLR) -

48 Km (NNW)

10 Nearest Railway station Hosur Railway station 5.2 Km (SE)


7

11 Resources

i)Power Requirement Existing- -225 HP Additional: 150 HP After expansion: 375 HP DG sets: Existing: 320 KVA & 62.5 KVA Additional : 500 KVA After Expansion: 500, 320 & 62.5 KVA.

ii)Source of electricity TNEB

iIi) Fuel Diesel: 180 lit/hr for DG sets Briquettes: 25 TPD for 5 TPH biomass fired boiler.(Existing 2 TPH boiler will be standby after expansion)

iv) Water Consumption Existing-70 KLD After Expansion- 107 KLD (incl. recycle water of 34 KLD)

v) Source of water SIPCOT

vi) Waste water generation Existing- 10.0 KLD sewage 11.7 KLD trade Effluent After Expansion -10 KLD sewage 25 KLD Trade Effluent

vii) Mode of disposal Sewage- after treatment is utilized for Greenbelt Trade effluent- after treatment in ETP ZLD, treated is recycled for re use in the Cooling tower & Boiler

viii) Manpower Existing: 85 Nos. Additional: 120 Nos. After expansion: 205 Nos.

12 Industries Located in SIPCOT Industrial Complex. Ashok Leyland SIDCO Industrial Estate

2.0 INTRODUCTION

2.1 Identification of the Project and Project Proponent

The present unit was established in 1993 by M/s. Reckitt Benckiser India Private Limited for

manufacturing PCMX of 500 TPA and obtain consents from TNPCB. In 2008, Industry proposed for

expansion of PCMX from 500 TPA to 1500 TPA and obtained Environmental Clearance (EC) from the

Ministry of Environment and Forest (MoEF), New Delhi and Consents from TNPCB. Latest renewal

consents from TNPCB under Air & Water Acts are consent order No.170824675689 dated 13-9-2017

with proceedings No. T4/TNPCB/F.0804HSR/RL/HSR/A/2017 dated 13-09-2017 (Air Act) & Consent


8

order No.170814675689 dated 13-9-2017 with proceedings No. T4/TNPCB/F.0804HSR/RL/HSR/W/

2017 dated 13-09-2017 (Water Act) and the both consents are valid upto 31-03-2018.

2.2 Project Proponent

Reckitt Benckiser is a Global Company having its operations in over 60 countries worldwide.

The company is famous for its leading brands in the categories of Antiseptics, Analgesics, Polishes,

Lavatory care, Surface care, Fabric care, Insecticide etc. Products like Dettol, Lysol, Harpic, Airwick,

Durex, Mortien, Nurofen, Scholl, Strepsils, Vanish, Veet, Woolite, Clearsil, Finish, Gaviscon,

Nutramigen, Calgon are trusted in most markets across the globe.

At Reckitt Benckiser, we see our important role as custodians of healthier lives and happier

homes. Our products are the everyday reminder that we are what we make and sell. By driving the

principles of ethical marketing and putting the consumer at the heart of everything we do, we all

deliver the Reckitt Benckiser purpose. Every day, we work relentlessly to give innovative health,

hygiene & home care product solutions based on the firm belief that consumers are and should be

“at the heart” of our brands and our business.

We have a responsibility to mine unique consumer insights that help deliver our purpose and

use them responsibly for activities that will reflect in positive outcomes for our consumers, society

and for our company.

We’re 40,000 entrepreneurs, all inspired by a vision of a world where people are healthier

and live better. At the heart of our rapidly growing consumer health business is a passionate desire

to help people feel better. We invest in research and development to find new ways for people to

look after themselves, their families and homes.

We believe there's a better way to do business – we like to call it 'better business'. Socially,

environmentally and financially, we act responsibly and sustainably. We believe passionately in doing

things the right way, and we believe the better way helps us deliver high quality products that touch

consumers each and every day. Health is no longer just the absence of illness, it’s being able to lead a

fitter and happier life. Our responsibility is to help people achieve this, while making the right kind of

social and environmental impact. That’s what we call better business. We follow a set of values that

help us realize our purpose and vision.


9

Reckitt Benckiser (India) Private Limited, Hosur Factory is one of the factories in India. We are

manufacturing PCMX here which is the raw material for Antiseptics. Procedures and measures

stipulated for ensuring the quality of products manufactured by Reckitt Benckiser (India) Private Ltd,

Hosur, ensuring the requirements of Environment, Health & Safety of personnel involved in

manufacturing.

2.3 Brief Description of the Nature of the Project

M/s. Reckitt Benckiser (India) Private Limited has proposed to expand its production of PCMX

from permitted 1500 TPA to 3000 TPA. The manufacturing process of PCMXs consists of chemical

synthesis and single stage of processing involving chemical reactions gives Product and byproducts.

The entire process operations are operated by various technical, skilled and unskilled persons with

due care to be met various standards prescribed by authorities.

Industry is adopting the state of art technologies and dedicated team of environmental

professionals for treatment and recycling of effluents, operation and monitoring of all pollution

control equipment. Industry has a defined EHS policy and robust environmental management system

supported by a well-defined organizational structure to ensure the prevention of pollution and to

protect the environment.

2.4 Need for the Project and its Importance to the Country and or Region

In the last few decades, India’s population is skyrocketing. People are becoming health

conscious and awareness is increased so that the demand for hygiene products increased. To satisfy

this need, more production of hygiene product like PARA CHLORO META XYLENOL (PCMX) is needed.

The expansion of the industry will be beneficial to the region. The company will bring new job

opportunities for the local people. They will therefore become economically stronger

2.5 Employment Generation

At present the total strength of employees is 85 including contract workers. The proposed

project will provide direct employment to about 120 personnel during proposed expansion phase.


10

3. PROJECT DESCRIPTION

M/s Reckitt Benckiser proposes for expansion of its bulk drug manufacturing unit of capacity

from 1500 TPA to 3000 TPA.

The manufacturing of PARA CHLORO META XYLENOL (PCMX) comes under drug

manufacturing unit which falls under 5 (f) synthetic organic chemicals industry (bulk drug

intermediate excluding drug formulations) and is categorized under “A” as its location being in

proximity (0.4 km SW) to interstate boundary of Tamil Nadu and Karnataka

3.1 Location:

Project is located at Plot No. 176, SIPCOT Industrial Complex. Phase 1, Hosur Taluk, Krishnagiri

district, Tamilnadu. There are no archaeological, historical sites located nearby. Therefore, the

project Site does not offer any negative impact on the local area, but rather has a positive Impact on

socio economic conditions of the habitants around it. The proposed plant is well connected to

National Highway 45 (Chennai -Bangalore) and Railway line at Hosur Railway Station.

The map showing general location, topographical map of 10 km radius, specific location, Google map

showing the Co-ordinates and Plant layout of the project showing existing and proposed facilities are

presented at Fig 1, 2, 3, 4 & 5 respectively.


11

Figure 1: Location of Project Site

Project site


12

Figu

re 2

: To

pogr

aphi

cal M

ap sh

owin

g 10

Km

Rad

ius


13

Figu

re 3

: Sp

ecifi

c lo

catio

n (p

roje

ct lo

catio

n in

SIP

CO

T In

dust

rial c

ompl

ex)


14

Figure 4: Satellite (Google) image of The Project Site

Table 1: Co-ordinates of all corners of the Project site

Sl. No. Latitude Longitude Sl. No. Latitude Longitude A 12°45'35"N 77°47'48"E F 12°45'24"N 77°47'44"E

B 12°45'33"N 77°47'46"E G 12°45'29"N 77°47'47"E

C 12°45'28"N 77°47'45"E H 12°45'30"N 77°47'47"E

D 12°45'29"N 77°47'42"E I 12°45'34"N 77°47'49"E

E 12°45'25"N 77°47'40"E


15

Figu

re 5

: Pl

ant L

ayou

t


16

3.2 Alternate Sites

This proposed expansion project is in the existing plant premises at Plot No. 176, SIPCOT

Industrial Complex. Hence, Alternate sites are not considered for the present expansion project.

Environmental considerations of this expansion project site.

• 3.6 km away from Hosur

• Water Bodies

a) Dharga Lake at 2.5 km (SE)

b) Rama Naicken Lake at 3.8 km (SE)

c) Basthi Lake at 4.8 km (E)

d) Pond near Attibele at 1.8 km (NW)

e) Pond near Arehalli at 3.4 km (W)

f) Bidaraguppe Lake at 4.4 km (NW),

g) Chinnar River at 3.8 km (E)

• Exist Transportation and Communication network

• There are no rare or endangered or endemic or threatened (REET) species of animals or birds.

3.3 Product and Production Capacity

Existing and proposed product details given in below table.

Table: 2 List of Permitted Product with its capacity

S NO PRODUCT NAME Existing Quantity (TPA)

1 PARA CHLORO META XYLENOL (PCMX) 1500 BY PRODUCTS 1 Dil.HCL 720 2 Mixed Chloroxylenol 36

Table 3: List of Proposed Product with its capacities

S NO PRODUCT NAME Proposed Quantity (TPA)

1 PARA CHLORO META XYLENOL (PCMX) 3000 By Products 1 Dil.HCL 786 2 Mixed Chloroxylenol 142 3 Sodium Hypoclorite 111


17

3.4 Raw Materials

Table: 4 List of Raw Materials

S No Name of the Raw material Qty per Batch (Kg)

Qty per day (Tons)

1. Metaxylenol 600 8.16

2 Cupric Chloride 2400 32.64

3 Dil. HCl (26%) 9000 122.4

4 Chlorine 375 5.1

5 Sodium Hydroxide 0.0145 0.2

Note: PCMX Batch size: 735 Kg/batch PCMX Daily capacity: 10 TPD (13.6 batches /day) No. of Production days: 300

3.5 Material Balance

Table :5 PCMX Material Balance

INPUT Kg

OUTPUT Kg

Product

M Xylenol = 600

PCMX = 735

Cupric Chloride = 2400

By products reuse in next batch

Dilute HCl (26%) = 9000

Dilute HCl (26%) = 9000

Cuprous Chloride = 2050.8

By products

Mixed Chloroxylenol = 34.7

Byproduct for sale as Dil. HCl (26%) after scrubbing

HCl gas = 179.5

Total Input = 12000

Total Output = 12000

Table :5A Material Balance - Side Reactions

INPUT Kg OUTPUT Kg Product reuse in next batch

Cuprous Chloride = 2050.8 Cupric Chloride = 2400 Chlorine = 375 Process Emissions Process Emissions = 25.8 Chlorine 25.8

Total Input = 2425.8 Total Output = 2425.8


18

Table :5B Material Balance - Side Reactions

INPUT Kg OUTPUT Kg By product

Chlorine = 25.8 NaOCl (Sodium Hypochlorite) = 27.07

NaOH = 14.54 Byproduct for sale as Dil. HCl (26%) after scrubbing

HCl gas = 13.26 Total Input = 40.34 Total Output = 40.33

3.6 Manufacturing Process

Manufacturing process for PARA CHLORO META XYLENOL (PCMX) involves four steps i.e., Reaction,

Filtration, Drying, Chlorination. Detailed Flow chart for the steps is given below,

3.6.1 Process Description:

1. Reaction: Meta Xylenol (MX) (which is solid at room temp) is heated to melt in a drum melter.

The molten MX is charged into an MSGL (Mild Steel Glass Lined) reactor having the Cupric

Chloride solution in Dilute Hydrochloric acid. The entire mass is refluxed at a temp of 105 to

108oC for 3 hours. MX gets chlorinated to give Para Chloro Meta Xylenol and in the process

Cupric Chloride gets reduced to Cuprous Chloride.

Dilute Hydrochloric Acid (By product): For every mole of PCMX formed one mole of Hydrochloric

acid is formed. The HCl vapors formed is passed through an absorption tower (scrubber) to get

the dilute Hydrochloric acid as a byproduct. The mass is cooled to 55 to 60 oC and filtered.


19

2. Filtration: The slurry containing product PCMX is filtered and the filtrate is collected in tanks for

re use after chlorination. The cake is washed with water and the washings are sent to the ETP for

treatment.

Mixed Chloroxylenol (By Product): The filtrate collection in intermediate tanks is cooled to 30-

32oC by pumping through the Graphite Heat Exchanger. The byproduct of Mixed Chloroxylenols

will crystallizes out. The thin slurry is filtered through the Centrifuge to separate the Mixed

Chloroxylenols.

3. Drying: The washed wet PCMX is dried in Fluid Bed Dryer at 45 to 50 oC and the dried product is

packed in HDPE bags lined with LDPE bags. The product obtained after drying is used as such in

the formulation.

4. Chlorination: Chlorine gas is passed into the solution of Cuprous Chloride in Hydrochloric acid

(the filtrate obtained from the reaction step above). This will convert Cuprous into Cupric

Chloride. The Cupric chloride in the solution is analyzed and used for the next batch by

replenishing with additional quantity of fresh Cupric Chloride required if any as per the reaction

requirements

3.6.2 The chemical reaction involved in the process is as follows:

Dil. HCl

1. C6 H3 (CH3)2 OH + 2 Cu Cl2 C6 H2 (CH3)2Cl OH + 2(Cu Cl) + HCl

(MetaXylenol) (Cupric Chloride) (PCMX) (Curprous Chloride)

M. Wt: 122 2 (134.5) 156.5 2(99) 36.5

Dil. HCl

2. 2(Cu Cl) + Cl2 2 Cu Cl2

M. Wt: 2 (99) 71 2(134.5)


20

3.7 Resource – Utilize & Recycling

3.7.1 Water

Water requirement of the project for domestic and industrial activity during operation phase will be

107 KLD (including recycle water of 34 KLD). Hence fresh water will be 73 KLD. The water

requirement will be met through SIPCOT water source. The detailed water balance shown in below

Table.

Table:6 Water Balance for the proposed project

Sl. No. Description

Input (KLD) Output (KLD)

Disposal Method Fresh Water Recycled

Evaporation loss / in

byproduct

Total Wastewater

1 Process 0 - - 0 No effluent

2 Washings (reactors, filters, floor moping, PCMX cake,etc.)

18 - -- 18 Collection and Treatment separately in ETP with ZLD

System consists of Neutralization - settling -

Ultra filtration - RO.

RO reject sent to MEE with ATFD and salt sent to

GEPIL Ranipet.

RO product and MEE & ATFD condensate reuse in

Cooling tower & Boiler.

3 Boiler 25 7 30 2 (Proposed 5 TPH) (make up)

4 Cooling Towers 0 17 16 1 300 TR (Bleed)

5 Softner regeneration 1 - - 1

6 Q.C and R&D 1 - -- 1

7 Scrubber (Process & Dryer)

11 - 9 2 (in byproduct)

8 Domestic (205 nos at 50 lpcd) 12 - 2 10 STP and treated water

used for greenbelt 9 Greenbelt 5 10 15 --

Total 73 34 72 35 Water loss & Moisture in ETP sludge ~ 1 KLD 107 107

3.7.2 Power Requirement

Power requirement of proposed project will be made available through TNEB. Total power

requirement for proposed expansion is 375 HP (incl. Existing 225 HP). D. G. set of capacity 500 KVA

will be additional to the existing 320, 62.5 KVA to meet the emergency power requirement of the

plant

3.7.3 Utilities

M/s. Reckitt Benckiser (India) Private Limited is proposes to install 5 TPH Biomass boiler in addition

to existing 2 TPH Biomass boiler. Existing 2 TPH biomass fired boiler will be standby in the proposal.

Fuel requirement of Briquettes will be around 25 TPD and High-Speed Diesel will be around 180 lph

for 500, 320 & 62.5 KVA DG sets.


21

3.8 Quantity of Waste to Be Generated

3.8.1 Waste Water Generation and Utilization

Total effluent generated in the project is 35 KLD. There is no effluent in the process other than

washing. Trade Effluent of 25 KLD will be treated in ETP - ZLD system. RO permeate, MEE & ATFD

condensate will be reused in the Cooling tower & Boiler. RO reject will be evaporated in the MEE.

The sewage generated due to domestic activities will be sent to STP and treated water will be used

for greenblet purpose.

Table:7 Waste water Generation Details

S.NO SOURCE OF WASTE WATER EXISTING KLD

AFTER EXPANSION

KLD 1 Sewage 10.0 10

2 Trade Effluent 11.7 25

Total 21.7 35

3.8.2 Solid Waste Generation and Disposal

The types of Hazardous and non-Hazardous wastes generated from the project, method of disposal is

shown in below table. Industry has entered an agreement with GEPIL Ranipet for disposal of

Hazardous waste (Annexure-VII).

Table :8 Existing Hazardous & Other Waste, Quantity & Disposal details

S. No

Category No. Name of the Waste Existing

Quantity Mode of Disposal

Hazardous waste

1 5.1 Used Spent oil 0.2 T/annum Send to authorized recycler

2 33.1 Discarded container / Empty Barrel used for hazardous Chemicals

72 T/annum Send to authorized recycler

3 34.1 Chemical residue from decontamination (MX residue)

0.015 T/ annum Reused in process

4 35.3 Chemical Sludge from ETP 3.6 T/annum Sent to GEPIL, Ranipet Other Solid Waste generation from the Plant

1 Plastic waste 1 Kg/day Sold as scrap 2 Metal scrap 25 Kg/day Sold as scrap 3 Used bags 2 Kg/day Sold as scrap 4 Paper waste 12 Kg/day Sold as scrap


22

Table :9 Proposed Hazardous & Other Waste, Quantity & Disposal details

S. No

Category No.

Name of the Waste After

Expansion Quantity

Mode of Disposal

Hazardous waste

1 5.1 Used Spent oil 0.5 T/annum Send to authorized recycler

2 5.2 Oil soaked cotton waste & contaminated PPE

10 Kg/annum Sent to GEPIL, Ranipet

3 33.1 Discarded container / Empty Barrel used for hazardous Chemicals

200 T/annum

Send to authorized recycler

4 34.1 Chemical residue from decontamination (MX residue)

30 Kg/annum Reused in process

5 35.3 Chemical Sludge from ETP 125 Kg/day Sent to GEPIL, Ranipet Other Solid Waste generation from the Plant

1 Plastic waste 2 Kg/day Sold as scrap 2 Metal scrap 30 Kg/day Sold as scrap 3 Used bags 4 Kg/day Sold as scrap 4 Paper waste 12 Kg/day Sold as scrap 5 Boiler ash 10 TPD Sold to brick mfrs

6 STP sludge 20 Kg/day Used as manure for greenbelt

4.0 SITE ANALYSIS

4.1 Connectivity

M/s. Reckitt Benckiser (India) Private Limited is located at Plot No.176, SIPCOT Industrial Complex.

Phase 1, Hosur Taluk, Krishnagiri District, Tamilnadu.

• The nearest habitation from the site is Hosur Town at a distance of 3 Km (SE)

• The nearest railway station is Hosur Railway station at a distance of 5.2 km (SE) from the site

• The nearest airport is Kempegowda International Airport (BLR) -48 Km (NNW).

4.2 Land Form, Land use and Land ownership

The present land use classification of the Expansion project is in the Existing land of Notified

industrial Land (SIPCOT Industrial Complex). Land is in possession of Project Proponent. Total 34.7%

(1.11 Ha) out of Plant area 3.2 Ha. is being allocated for green belt development. Total 753 trees are

available in site area.


23

4.3 Existing Infrastructure

Existing Infrastructure like office building, process area, storage area, STP, ETP and other

facilities like DG set for power backup are available and well developed.

4.4 Climatic Data

Temperature Maximum: 33.6 °C. Minimum: 17.1 °C.

Normal annual rainfall 830 mm

4.5 Social Infrastructure

Adjacent to the road connecting to Hosur and Bengaluru in NE. Road network, Transportation

facilities, SIPCOT water supply, TNEB Power supply, Fire station, Hospitals, Telecommunication

facility, Schools, Community centers etc., are available at Hosur located at a distance of 3 km (aerial

distance).

5.0 PLANNING

5.1 Planning Concept

Type of Industry: Bulk Drug (Synthetic Organic Chemical) Manufacturing Unit.

Facilities: Industry has proposed for expansion in the existing land and facilities required for the

project will be provided as per requirement.

Transportation: Transportation of raw materials and final products is done via roads as the proposed

expansion project in the existing land is well connected to Road, Rail and Airways.

Town and Country Planning Classification: Project is located in SIPCOT Industrial Complex. Phase 1,

(Notified Industrial Area) with an industrial use classification and is in possession of project

proponent.

5.2 Population Projection

Proposal is for expansion of the existing industry and there is a scope for increase in the

population in the vicinity as most of the skilled workers prefers to stay in the nearby locations to

avoid travelling from long distances. However semi-skilled and indirect employment potential is

from local villages. Hence, there is a possibility of increase in population of the skilled and semi-

skilled workforce. The local unskilled villagers will be preferred for the unskilled jobs such as

gardening, movement of materials, etc. Educated youth will be employed as semi-skilled workers


24

and training will be provided. However, overall there is a possibility of little increase in population of

the area

5.3 Land Use Planning

The expansion unit has been proposed is in existing area of about 3.2 Ha i.e., 32010.19 sq.m.

The Land use pattern of the proposed expansion is presented in Table 6

Table 10: Break Up of Land Use Pattern

Sl. No Location

Existing area

in Sq. m

Additional area

in Sq. m

Total area % in Sq. m Ha.

1 Manufacturing area 1781.68 908.98 2690.66 0.269 8 2 Utility 1663.03 40 1703.03 0.170 5 3 HW storage area 32 32 64 0.006 0.2 4 Scrap yard 80 100 180 0.018 1 5 ETP area 1204.5 600 1804.5 0.180 6 6 Greenbelt 9130 1980 11110 1.111 35 7 Roads 2475 1000 3475 0.348 11 8 Open land 15643.98 0 10983 1.098 34

Total 32010.19 4660.98 32010.19 3.201

5.4 Assessment of Infrastructure Demand

On assessment of infrastructure demand near the project area Hospital with Ambulance

facility and Fire station requirement for the nearby villages of project area. Project site located in

Hosur Taluk, Krishnagiri District and is near to the Karnataka state capital Bengaluru..

5.5 Amenities/Facilities

Industry will continue to provide and upgrade the following amenities / facilities in the

proposed expansion project.

• Canteen • Potable drinking water • Training block • Laying of Concrete internal roads • Fire hydrant facility • Eye/body wash showers • First Aid kits at all prominent places. • Head nurse for emergency medication. • Rest Room for employees • Seating facilities for those employees who do their work standing and ergonomically

designed seating facilities for those who do their work seating • Pre-employment and routine medical examinations and the necessary follow up actions


25

• Communication systems like Phone, Internet with safety measures, etc. • Security system at the entrance etc.

6.0 PROPOSED INFRASTRUCTURE

6.1 Industrial Area

Additional Production Blocks, Utilities area, ETP & ZLD upgradation has been proposed in the

existing area of 3.20 Ha.

6.2 Residential Area

There will be no residential area within the project site.

6.3 Greenbelt

The existing Greenbelt of 34.7% i.e. 1.11 Ha out of 3.20 Ha total area of the project.

6.4 Social Infrastructure

As an Enterprise Social Commitment (ESC), Industry will continue to contribute for

development of village social infrastructure.

6.5 Connectivity

There is no change in connectivity compare to existing facility.

6.6 Drinking Water Management

Potable drinking water will be provided to additional employees. The source of drinking water

is from SIPCOT Water Supply which is treated through Drinking RO System in the unit.

6.7 Sewerage System

Sewage will be generated from the Canteen and Toilets, which will be collected into sewage

collection tank through pipelines and will be sent to the Sewage Treatment Plant of Capacity 20KLD,

further to which the treated sewage will be utilized for Greenbelt purposes.

6.8 Industrial Waste Management

Existing storage system needs to be enhanced to meet the expansion project demand. The

management of these wastes will be handled very sensitively and by adopting proper segregation

techniques.


26

6.8.1 Process Emissions Management

Manufacturing of Parachloro Metaxylenol (PCMX) will result in gaseous emissions. Maximum

process emissions for existing and proposed products are given in Table 7. Proposed gaseous

emissions will be scrubbed in two stages with water and caustic solution based on the characteristics

of gases.

Table:11 Maximum Process Emission

SL. PROCESS MAXIMUM QUANTITY

TREATMENT ON VARIOUS

NO. EMISSIONs COMBINATIONS (Kg/day)

1. HCl 2621.5 Scrubber using Chilled water & caustic lye solution

2. Cl2 350.8 Scrubber using caustic lye solution

6.8.2 Emissions–Utilities

Boilers and DG sets are the main sources contributing to emissions from the plant. Proposed

5 TPH will be in addition to Existing 2 TPH Biomass Boiler about fuel requirement of Briquettes will

be around 25 TPD Existing 2 TPH boiler will be standby after expansion.

High Speed Diesel will be around 180 liter/hour will be used in the DG sets of Existing 320 &

62.5 KVA and proposed 500 KVA DG set. Stack height will be provided as per CPCB.

The various measures proposed to minimize the pollution from the boiler are as follows:

Multi-cyclone separator followed by Bag filter will be installed to control the particulate (PM)

emissions within statutory limit. To facilitate wider dispersion of pollutants, 30m height stack

each will be installed.

Stacks will be provided to proposed D.G sets as per CPCB / SPCB Guidelines.

Fugitive dust will be controlled by adopting dust extraction and dust suppression measures

and development of greenbelt along the periphery of the proposed Boiler area

6.8.3 Noise Environment

• Compressors, Boilers and DG sets will be the major noise generating units in the plant.

• The noise levels of the DG sets will be well within the limits as these will be installed with

acoustic enclosures. Workers will always be provided with ear muffs.


27

• All the equipment in the plant would be designed to have a total noise level not exceeding

85-90 dB(A) as per the requirement of OSHA (Occupational Safety and Health Administration)

standards.

6.9 Hazardous / Solid Waste Management

• Solid waste mainly segregated into ETP sludge / ATFD salt, Spent oil, Cotton waste, MX

(phenol) waste. These waste will be stored in dedicated covered area and disposed as

mentioned in Table 8.

• Boiler ash will be sold to brick manufacturers.

6.9.1 Power Requirement & Supply / Source

The proposed power requirement from TNEB (Tamil Nadu Electricity Board) for the plant is

375 HP including existing 225 HP. Proposed D.G. sets are 500 KVA, in addition to existing 320 KVA &

62.5 KVA DG set. DG set which will be used as standby during power failure.

7.0 REHABILITATION AND RESETTLEMENT (R&R) PLAN

The proposed project is in the existing land located in a SIPCOT Industrial Complex. Phase 1,

and is in possession of project proponent. Therefore, Rehabilitation and Resettlement plan is not

applicable to this expansion project. The nearest habitation is Mookandapalli village is 0.6 km (SE)

away from the project site.

8.0 PROJECT SCHEDULE & COST ESTIMATES

8.1 Time Schedule for the project construction

The timelines for commencement of proposed construction activity will be from June 2018 as

it is expected that the expansion project will be in a position to obtain Environmental Clearance for

the project and Consent to Establish from the State Pollution Control Board. By December 2018 the

commercial production is expected to be commenced.

8.2 Estimated Project Cost

Overall estimated cost involved in the total project (existing and proposed) like land, building,

plant & machinery is Rs. 3,872.19 Lakhs. Total capital cost allocated towards environmental pollution

control measures is Rs. 339 Lakhs including the existing Rs. 127.45 Lakhs and the Recurring cost will

be about Rs. 102 Lakhs per annum.


28

9.0 ANALYSIS OF PROPOSAL (FINAL RECOMMENDATIONS)

• The proposed expansion project will result in growth of surrounding area by generating direct

and indirect employment to local people. Around 120 members will be benefitted due to the

expansion project (including existing 85 nos.).

• Under the Enterprise Social Commitment, Industry will continue to develop a policy of

developing the surrounding villages in the vicinity by identifying the requirements.

• No adverse effect on environment is envisaged as proper mitigation measures will be taken up.

• Industry will strengthen the existing Safety, Health & Environment Department and also

continue to engage recognized laboratories to carry out all necessary monitoring parameters

for its activities.

• The segregated wastewater as Trade and Domestic will be regularly analyzed before and after

treatment in ETP-ZLD and STP.

• Qualified staff will be appointed for the purpose of Operation and Maintenance of the pollution

control facilities.

• Stand-by facilities will be provided to all the pumps so as to ensure fail proof treatment,

handling and disposal

9.1 Budgetary allocation for Pollution Control Measures

The management will set aside adequate funds in its budget to fully meet the stated

objectives of the environmental policy. The proposed and existing capital equipment for

environmental management include up-gradation of effluent treatment plant, pipelines and

channels for wastewater discharge, greenbelt development, air pollution control equipment and the

environment laboratory. The Estimated break-up of budgetary allocation for various control

measures is presented in Table 12


29

Table:12 Budget for Pollution Control Measures

S.No Description Capital Cost

In Lakhs

Operational Cost

In Lakhs Per Annum

1 Environmental Laboratory & Monitoring

20 10

2 Sewage Treatment Plant 50 5.5

3 Effluent Treatment plant 200 72

4 Rain Water Harvesting 24 2.5

5 Drainage System 25 2.5

6 Solid Waste Management 10 4.5

7 Green Belt Development 10 5

TOTAL 339 102

GKK:nc/CD/A-11/99 t1arch 14, 1994

The Di5tr1ct Env1ronmenta1 Engineer Tam :i.l r~etdu PollutlOII ~antral }31-)al~d

MIG 78 Old ASTC Housing Colony HOSUR 635 109

Daar S:. r·,

Sub: Consent for the d1scharge of sewage and trade effluent under Sec~ion 25 of the Water (Prevention and Control of Pollution) Act, 197~ <c~~tral Act 6 of 1974)

Ref: Consent Order No 802'1

We n~ve been grante.:t :~fl--. - OrdPr No 8629 vide you~ ~roc eedings No T10/DMP/F335/R/W/93 dated 23 12 1993 . This consent is valid for a period end1ng 31 03 1~94. We her~by ~pply for the rene~al o~ this Consent and confirm the fol!ow1nQ:

A

B

1 That there 1s no change in the production c:apaLi ty and pl•odLtc::t... r-.anlffaci-ured a~

~ndicated 1n the Consent Ord~r.

2 No change ln t.he qt•a~tit~' of ~H!I•JagP./tr- oe effluent mentioned 1n the Coneent O~dnr .

~ Nc ch nge in the mode o~ dl~pos~l of s~wage/trada effluent.

4 Dcmund Dr~ft No 739~e6 datP.n 2 3 109~ 1or R-::. 2. _u0/- tot>~ards th,. tre (bot h fop Water and A1r> fo r renewal of the Consent Order is enclosed her~with.

5 Latest report of analy-Js cf ~~e treated trac~ ~ffluent (RQA ~ WP/MEL/HOS/93 dat ed 31. 1 1994 from ·tami l Nadu Pollution Control Beard , Mobile Env1ronment3l Laboratory, Ho~ur> is enclosed he~ewith.

ANNEXURE-I

30

kecpl2

Highlight

Kindly acknowledge receipt of this letter and grant us the renewal of the Consent Order NQ 8629.

Thanking yoll

YoL~rs faithfully RECKITT & COLMAN OF INDIA LIMITED

}J/Jl ~L~ DR B D SII\:GH GENERAL MANAGER <CHEMICAlS DIVISION)

Encl: De•and Draft No 739286 dated 2 3 1994 for Rs 2e,ese1-

An lysh• Report :lOA No MP/HEl/HOS/93 dated 31 1 1'194

cc Member Secretary T.:tmi1· t add Pc1lu'tit:n Control Bc~'"'d 32 Santhome h1~h Road MADRAS 60~ t'h)4·

'

ANNEXURE-I

31

-

SKK:nc/CD/A-11/99 Ma rch 14, 1994

The District Envi ron men t al Engine er Tam1l N~du Pollu t ion Control Boar d MI G 78 Ol d ASTC Hous1ng Colony HOSUR 635 109

Dear S1r,

Sub: Consent ~or e x isting/expansion o~ the Plant und&r Se ct ion 21 o~ the Ai r <Prevention and Control of Pol lut~on ~ Act, 1981

Ref: Consent Order No 6825

We have b~qn ~~unted Consent Order No 60-5 v1de your proceecllngs ~to T10/DMr/F3::r:;;rFu;.;.:; date-d 2~ 12 1993 . Th is Consent ~s vuli~ till 31 3 199A. WP hereby app ly fo r the ren~vlai OT tn 1s Consent a n d confi r m t h e fo l lowing : .

1

2

3

4

5

Whether there 1s any change 1n the quantity of product!> manufGI.c-tured pP.r mon~h

Whether ther~ is any change in the numb2r a n d he;ght oT chimneys

Wh ether there 1s any change in th~ qttantit;y of E~rn:r. i ss1 ons

A sum of Rs =e,S00/is enclo~ed <bot h for Water ~~ A 1 r ) vide

Ai r Pollut i on Con tro l me~sures prov1ded/ ornnosed along wi~h

re l evant drawir1gs 'f'r:Jr the 1mprovement of ex1st1ng cand1tions

No

No

No

Demand date<;! renel.oJa1

Droft No 7:928o 2 :; 1994 tat>lai'ds

of Consent

Our ~orkinQ ~nvolves me r ely ...,u;rnng of ·furnace oil throttgh b•.tr••l?l'S for bcllP r~ {c::team bo1lel' ~

hot oil unit> ~ emm1t~ing the exhaust through chlmneyz . We ~re controlling the quality of stoc~ emmlssion by mon1toring t~e

rat1o of fuel and air for f1ring ins1oc th~ boiler.

ANNEXURE-I

32

.,.,

6 Capacity of the boiler installed indicating t he steam generation in tonnes,hr . Type and qLtan t i ty of fL\e 1 used per day for the boiler

7 Number of generator

8

9

10

sets installed indicating the1r rates capac1t:y in I<VA

The height of the building(shed> ttlhere 'in eac:h generator sec i:::; installed

Tne nelyh't of the e::haLt.:.t pip~ i:tttOJ.ched to eaci-, genera to!' net (abOV8 ground leveli

The height of the neighbouPing building to the bo1ler house

:

2.5 tonnes I hour· Type Furn<lc: e Oi 1 Quantity of fuel us"'d pet Cl <lY vaT'i~:>s

from 3!:10 l::gs to 4fHJ kgs.

One set of 250 KVA

18' high

He1ght of e~haust p1pe ;;obov~:: ground lt'lvel is 13'

Heigt-,t o·r th·~ neighbouring building is 18'

We request you to ~1ndly look 1nto the mutter and grant L!$ the renewal OT the Consent Qt·der· mentioned aoove under Air (PrQvention & Control of Pollution> Act, 1981.

Looking f6rward to yo~r ~ind co-operatlon.

Th;:mk 1ng you

Your3 faithfully RECK ITT & COLMAN OF INDIA LIMITED

};~~~ DR B B SINBH GENERAL MANAGER CCHEt'IICALS DIVISION>

Encl: De•a.nd Draft No 739286 datPd :t.. 3 199.t: fc~r Rs 29,899/- (both for Wa~er and Air>

cc: D

The Member oecretnry Tam1l Nadu.Pollution Control B' rd 32 Santhome High Road MADRAS 600 004

ANNEXURE-I

33

ANNEXURE-II

34

ANNEXURE-II

35

ANNEXURE-II

36

ANNEXURE-II

37

ANNEXURE-II

38

ANNEXURE-III

39

ANNEXURE-III

40

ANNEXURE-III

41

ANNEXURE-III

42

ANNEXURE-III

43

ANNEXURE-III

44

ANNEXURE-III

45

ANNEXURE-III

46

ANNEXURE-III

47

ANNEXURE-III

48

ANNEXURE-III

49

ANNEXURE-III

50

ANNEXURE-III

51

ANNEXURE-III

52

ANNEXURE-III

53

ANNEXURE-III

54

ANNEXURE-III

55

ANNEXURE-III

56

ANNEXURE-III

57

ANNEXURE-III

58

ANNEXURE-III

59

ANNEXURE-III

60

ANNEXURE-III

61

ANNEXURE-III

62

1

TAMIL NADU POLLUTION CONTROL BOARD

CONSENT ORDER NO. 170814675689 DATED: 13/09/2017.

PROCEEDINGS NO.T4/TNPCB/F.0804HSR/RL/HSR/W/2017 DATED: 13/09/2017

________________________________________________________________

RENEWAL OF CONSENT is hereby granted under Section 25 of the Water (Prevention and Control ofPollution) Act, 1974 as amended in 1988 (Central Act, 6 of 1974) (hereinafter referred to as “The Act”) and therules and orders made there under to

The General ManagerM/s.RECKITT BENCKISER (INDIA) PRIVATE LIMITED,S.F.No. 176 of SIPCOT - I,MUKONDAPALLI village,Hosur Taluk,Krishnagiri District.

Authorising the occupier to make discharge of sewage and /or trade effluent.

This is subject to the provisions of the Act, the rules and the orders made there under and the terms andconditions incorporated under the Special and General conditions stipulated in the Consent Order issued earlierand subject to the special conditions annexed.

This RENEWAL OF CONSENT is valid for the period ending March 31, 2018

SUB: Tamil Nadu Pollution Control Board - RENEWAL OF CONSENT – M/s. RECKITT BENCKISER(INDIA) PRIVATE LIMITED , S.F.No. 176 of SIPCOT - I, MUKONDAPALLI village, HosurTaluk and Krishnagiri District - Renewal of Consent for the operation of the plant and discharge ofsewage and/or trade effluent under Section 25 of the Water (Prevention and Control of Pollution)Act, 1974 as amended in 1988 (Central Act 6 of 1974) – Issued- Reg.

REF: 1. Board Proceeding No.: T3/TNPCB/F.0103HSR/RL/HSR/W/A/2015 DATED: 01/11/2015.2. Unit’s application No: 4675689 dated:09/03/2016 & 27/06/20173. IR.No : F.0804HSR/RL/JCEE-M/HSR/2017 dated 05/07/2017.

For Member Secretary,Tamil Nadu Pollution Control Board,

Chennai

ANNEXURE-IV

63

2

SPECIAL CONDITIONS

1. This renewal of consent is valid for operating the facility for the manufacture of products/byproducts(Col. 2) at the rate (Col 3) mentioned below. Any change in the product/byproduct and its quantity hasto be brought to the notice of the Board and fresh consent has to be obtained.

Sl.No.

Description Quantity Unit

Product Details1. PCMX (Para chloro meta xylenol) 1500 T/Yr

By-Product Details1. Dilute Hydrochloric acid 60 T/M

2. Mixed chloro xylenol 3 T/M2. This renewal of consent is valid for operating the facility with the below mentioned outlets for the

discharge of sewage/trade effluent. Any change in the outlets and the quantity has to be brought to thenotice of the Board and fresh consent has to be obtained.

Outlet No. Description of Outlet Maximum daily dischargein KLD

Point of disposal

Effluent Type : Sewage

1. Sewage 10.0 On units land

Effluent Type : Trade Effluent

1. Trade effluent 11.7 R.O. permeate reused inthe process R.O. rejectevaporated in themechanical evaporator

ANNEXURE-IV

64

3

To

The General Manager,

M/s.RECKITT BENCKISER (INDIA) PRIVATE LIMITED,

176,Sipcot Industrial Complex,Hosur,Krishnagiri,

Pin: 635126

Copy to:

1.The Commissioner, HOSUR-Municipality, Hosur Taluk, Krishnagiri District .

2. The District Environmental Engineer, Tamil Nadu Pollution Control Board, HOSUR.

3. The JCEE-Monitoring, Tamil Nadu Pollution Control Board, Vellore.

4. File

-----------

** This consent order is computer generated by OCMMS of TNPCB and no signature is needed**

Additional Conditions: 1.The unit shall operate and maintain the STP efficiently and continuously so as to satisfy thestandards prescribed by the Board.2.The unit shall operate and maintain the ETP, RO system, RMS continuously and efficiently so as toachieve zero discharge at all times.3.The unit shall comply with the provisions of the Hazardous and Other Wastes (Management andTransboundary Movement) Rules, 2016.The unit shall maintain and regularly calibrate the online Continuous effluent quality monitoringsystem parameters to avoid error in the data transmitted to Care Air Centre, TNPCB4.The unit shall continue to develop green belt within the unit premises.5.In case of revision of consent fee by the Government/or any change in the GFA, the unit shall remitthe difference in amount within one month from the date of notification. Failing to remit the consentfee, this consent order will be withdrawn without any notice and further action will be initiated againstthe unit as per law


Chennai

ANNEXURE-IV

65

1

TAMIL NADU POLLUTION CONTROL BOARD

CONSENT ORDER NO. 170824675689 DATED: 13/09/2017.

PROCEEDINGS NO.T4/TNPCB/F.0804HSR/RL/HSR/A/2017 DATED: 13/09/2017

________________________________________________________________

RENEWAL OF CONSENT is hereby granted under Section 21 of the Air (Prevention and Control ofPollution) Act, 1981 as amended in 1987 (Central Act 14 of 1981) (hereinafter referred to as “The Act”) and therules and orders made there under to

The General ManagerM/s.RECKITT BENCKISER (INDIA) PRIVATE LIMITED,S.F.No. 176 of SIPCOT - I,MUKONDAPALLI village,Hosur Taluk,Krishnagiri District.

Authorizing the occupier to operate the industrial plant in the Air Pollution Control Area as notified by theGovernment and to make discharge of emission from the stacks/chimneys. This is subject to the provisions of the Act, the rules and the orders made there under and the terms andconditions incorporated under the Special and General conditions stipulated in the Consent Order issued earlierand subject to the special conditions annexed.

This RENEWAL OF CONSENT is valid for the period ending March 31, 2018

SUB: Tamil Nadu Pollution Control Board - RENEWAL OF CONSENT –M/s. RECKITT BENCKISER(INDIA) PRIVATE LIMITED , S.F.No. 176 of SIPCOT - I, MUKONDAPALLI village, HosurTaluk and Krishnagiri District - Renewal of Consent for the operation of the plant and discharge ofemissions under Section 21 of the Air (Prevention and Control of Pollution) Act, 1981 as amendedin 1987 (Central Act 14 of 1981) –Issued- Reg.

REF: 1. Board Proceeding No.: T3/TNPCB/F.0103HSR/RL/HSR/W/A/2015 DATED: 01/11/2015.2. Unit’s application No: 4675689 dated:09/03/2016 & 27/06/20173. IR.No : F.0804HSR/RL/JCEE-M/HSR/2017 dated 05/07/2017.


Chennai

ANNEXURE-IV

66

2

SPECIAL CONDITIONS

1. This renewal of consent is valid for operating the facility for the manufacture of products (Col. 2) atthe rate (Col. 3) mentioned below. Any change in the products and its quantity has to be brought to thenotice of the Board and fresh consent has to be obtained.

Sl.No.

Description Quantity Unit

Product Details1. PCMX (Para chloro meta xylenol) 1500 T/Yr

By-Product Details1. Dilute Hydrochloric acid 60 T/M

2. Mixed chloro xylenol 3 T/M2. This renewal of consent is valid for operating the facility with the below mentioned emission/noise

sources along with the control measures and/or stack. Any change in the emission source/controlmeasures/change in stack height has to be brought to the notice of the Board and freshconsent/Amendment has to be obtained.

I Point source emission with stack :

StackNo.

Point Emission Source Air pollutionControl measures

Stack heightfrom GroundLevel in m

Gaseous Dischargein Nm3/hr

1 PCMX plant reactors Wet scrubber withstack

15

2 Biomass Boiler Dust collectorswith stack

30

3 DG Set 320 KVA Acousticenclosures withstack

6.2

4 DG Set 62.5 KVA Acousticenclosures withstack

4.6

5 Fluid Bed Dryer Wet scrubber withstack

10

II Fugitive/Noise emission :

Sl.No.

Fugitive or Noise Emissionsources

Type of emission Controlmeasures

1. DG set Noise Acousticenclosures

ANNEXURE-IV

67

3

ToThe General Manager,M/s.RECKITT BENCKISER (INDIA) PRIVATE LIMITED,176,Sipcot Industrial Complex,Hosur,Krishnagiri,Pin: 635126

Copy to:1.The Commissioner, HOSUR-Municipality, Hosur Taluk, Krishnagiri District .2. The District Environmental Engineer, Tamil Nadu Pollution Control Board, HOSUR.3. The JCEE-Monitoring, Tamil Nadu Pollution Control Board, Vellore.4. File-----------

** This consent order is computer generated by OCMMS of TNPCB and no signature is needed**

Additional Conditions: 1. The unit shall operate and maintain the Air Pollution Control measures efficiently and continuouslyso as to satisfy Ambient Air Quality / Emission Standards prescribed by the Board2. The unit shall maintain and regularly calibrate the CAAQMS & online Continuous stack emissionmonitoring system parameters to avoid error in the data transmitted to Care Air Centre, TNPCB3. In case of revision of consent fee by the Government/or any change in the GFA, the unit shall remitthe difference in amount within one month from the date of notification. Failing to remit the consentfee, this consent order will be withdrawn without any notice and further action will be initiated againstthe unit as per law


Chennai

ANNEXURE-IV

68

1

FORM 2

[See rule 6 (2)]

FORM FOR GRANT OR RENEWAL OF AUTHORISATION TO THE OCCUPIERS,RECYCLERS, REPROCESSORS, REUSERS, USER AND OPERATORS OF DISPOSALFACILITIES

Member SecretaryTamil Nadu Pollution Control Board

Chennai

AUTHORISATION No. 17HRC6788106 dated 26/07/2017

Proceeding No. T2/TNPCB/F.0804HSR/HWA/RL/HSR/2017 dated 26/07/2017

Sub: Tamil Nadu Pollution Control Board – Hazardous Waste Authorization-Renewal- M/s. RECKITTBENCKISER (INDIA) PRIVATE LIMITED, S.F.No. 176 of SIPCOT - I, MUKONDAPALLIVillage, HOSUR Taluk, Krishnagiri District - Authorization under Rule 6 (2) of theHazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 enacted underEnvironment (Protection) Act, 1986 – Issued- Reg.

Ref: 1.Board Proceeding No.:T10/TNPCB/HWM/HSR/12162/2009 dt: 28/7/2009.2.Unit’s application on 21.09.2016 and resubmitted on 27/6/2017.3.HWA-IR.No.0804HSR/HWA/RL/JCEE-M/VLR/2017 dated 11/07/2017.

1. Number of authorization: 17HRC6788106 and dated : 26/07/2017

2. The General Manager of M/s. RECKITT BENCKISER (INDIA) PRIVATE LIMITED is herebygranted an Authorisation based on the based on the enclosed signed Inspection report for Generation,Collection, Storage, Reuse ,Transport and Disposal of hazardous or other wastes or both on thepremises situated at S.F.No. 176 of SIPCOT - I, MUKONDAPALLI Village, HOSURTaluk, Krishnagiri District.

Sl No Schedule / Name of theProcesses

Name of HazardousWaste (with category No)

Quantity Activities for whichAuthorization is

issued1 Schedule I/5. Industrial

operations using mineral orsynthetic oil as lubricant inhydraulic systems or otherapplications

5.1-Used or spent oil 0.2 T/Annum Generation, Collection,Storage, Transport toauthorized recyclers

2 Schedule I/33. Handling ofhazardous chemicals andwastes

33.1-Emptybarrels/containers/linerscontaminated with hazardouschemicals /wastes

72 T/Annum Generation, Collection,Storage, Transport toauthorized recyclers

3 Schedule I/34.De-contamination ofbarrels/containers used forhandling of hazardouswastes/chemicals

34.1-Chemical-containingresidue arising fromdecontamination

0.015T/Annum

Generation, Collection,Storage, and reusedalong with Rawmaterial.

4 Schedule I/35. Purificationand treatment of exhaustair/gases, water and wastewater from the processes inthis schedule and commonindustrial effluent treatmentplants (CETP’s)

35.3-Chemical sludge fromwaste water treatment

3.6 T/Annum Generation, Collection,Storage, Transport, anddisposal to M/s.GEPIL,Ranipet.

3. This authorization shall be valid for a period upto 25/07/2022.

The Authorization is issued subject to the following general and special conditions annexed.

ANNEXURE-V

69

2

A. GENERAL CONDITIONS OF AUTHORIZATION

B. SPECIFIC CONDITIONS - HW Generator

1. The authorised person shall comply with the provisions of the Environment (Protection) Act, 1986 andthe rules made there under.

2. The authorization or its renewal shall be produced for inspection at the request of an officer authorizedby Tamil Nadu Pollution Control Board.

3. The person authorized shall not rent, lend, sell, transfer or otherwise transport the hazardous and otherwastes except what is permitted through this Authorisation.

4. Any unauthorized change in personnel, equipment or working conditions as mentioned in theapplication by the person authorized shall constitute a breach of his authorization.

5. The person authorised shall implement Emergency Response procedure (ERP) for which thisauthorisation is being granted considering all site specific possible scenarios such as spillages, leakages,fire ,etc and their possible impacts and also carry out mock drill in this regard at regular interval oftime.

6. The person authorised shall comply with the provisions outlined in the CPCB guidelines on“Implementing Liabilities for Environmental damages due to Handling and Disposal of HazardousWastes and Penalty”.

7. It is the duty of the authorized person to take prior permission of Tamil Nadu Pollution Control Boardto close down the facility.

8. The imported Hazardous and other wastes shall be fully insured for transit as well as the accidentaloccurrences and its clean-up operation.

9 The record of consumption and fate of the imported hazardous and other wastes shall be maintained.

10. The Hazardous and other wastes which gets generated during recycling or reuse or recovery or pre-processing or utilisation of imported hazardous or other wastes shall be treated and disposed of as perspecific conditions of Authorisation.

11 The importer or Exporter shall bear the cost of import or export or mitigation of damages if any.

12 An application for the renewal of an authorization shall be made as laid down under these Rules.

13 13.Any other conditions for compliance as per the Guidelines issued by the MoEF and CC or CPCBfrom time to time.

14 Annual returns shall be filed by June 30th for the period ending 31st March of the previous financialyear.

1. The occupier/generator shall be responsible for safe and environmentally sound management ofhazardous and other wastes.

2. The occupier shall follow the following steps for the management of hazardous and other wastes. (a)prevention (b)minimization (c)reuse (d)recycling (e)recovery, utilisation including co-processing and(f)safe disposal

3. The occupier shall take all the steps while managing hazardous and other wastes - (a) To containcontaminants and prevent accidents and limit their consequences on human beings and theenvironment; and (b) To provide persons working in the site with appropriate training, equipment andthe information necessary to ensure their safety.

4. The occupier shall store the hazardous and other wastes for a period not exceeding ninety days and shallmaintain a record of sale, transfer, storage, recycling, recovery, pre-processing, co-processing andutilisation of such wastes and make these records available for inspection:

5. The hazardous and other wastes shall be stored temporally in an isolated area earmarked for the purposewithin the occupier’s premises (it shall not be accessible to rain water) till scientific disposal. Thestorage area shall be fenced properly and a sign of danger shall be placed at the storage site.

6. The containers holding the hazardous and other wastes shall be kept in good condition and made ofmaterials which can withstand the physical and environmental conditions during storage andtransportation. Only properly cleaned containers shall be used for storage of hazardous and otherwastes.

7. The occupier handling hazardous or other wastes shall maintain records of such operations ofgeneration, handling, storage and disposal as per Form 3.

8. The hazardous and other wastes generated in the establishment of the occupier shall be sent or sold toan authorised actual user or shall be disposed of in an authorised disposal facility.

9. The occupier handling hazardous or other wastes shall ensure that the hazardous and other wastes arepackaged in a manner suitable for safe handling, storage and transport as per the guidelines issued bythe Central Pollution Control Board from time to time

10. The labelling of package of hazardous or other wastes shall be done as per Form 8. The label shall be ofnon-washable material, weather proof and easily visible.

ANNEXURE-V

70

3

ADDITIONAL SPECIFIC CONDITIONS1.The unit shall ensure that all provisions of Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016 and guidelines of CPCB are complied with while handling hazardouswaste.2.The unit shall comply with the general terms and conditions stipulated in Form-2, special conditionsspecified in the authorization order for onsite storage requirements, general packaging requirements,transportation requirements and record keeping and reporting to concerned authority.3.The unit shall take effective raw material and water conservation measures to minimize the generationof hazardous wastes.4.The hazardous waste shall be stored on an impervious platform in closed shed to prevent pollution ofground water and surface soil and shall not store the hazardous wastes outside the premises.5.The unit shall maintain the Form -3 for the hazardous wastes at the unit. The unit shall submit thereturns regarding handling of hazardous wastes in Form- 4 by 30th June of every year for the precedingperiod April to March.6.For transportation of proposed hazardous Wastes, manifest system as per Hazardous and Other Waste(Management and Trans boundary Movement) Rules, 2016 and guidelines of CPCB shall be followed.7.In case of any violation in the conditions stipulated, the permission shall be withdrawn at any time.8.Tamil Nadu Pollution Control Board reserves the right to review / impose additional conditions ofrevoke, change or alter any of the terms and condition.9. The hazardous wastes shall be stored in a closed designated area, without exposure to rain, sunlightetc.10..The unit shall ensure that adequate fire safety measures have been provided to avoid any fireaccidents in the unit.11.The unit shall maintain the display board provided for specifying the quantity of hazardous wasteaccumulated and disposed in the storage area.

Member Secretary

Tamil Nadu Pollution Control BoardChennai

To

11. The hazardous and other wastes shall be transported from the occupier’s establishment to an authorisedactual user or to an authorised disposal facility in accordance with the provisions of these rules.

12. The transport of the hazardous and other wastes shall be in accordance with the provisions of theserules and the rules made by the Central Government under the Motor Vehicles Act, 1988 and theguidelines issued by the Central Pollution Control Board from time to time in this regard..

13. The occupier shall provide the transporter with the relevant information in Form 9, regarding thehazardous nature of the wastes and measures to be taken in case of an emergency and shall label thehazardous and other wastes containers as per Form 8

14. The authorisation for transport shall be obtained either by the sender or the receiver on whose behalf thetransport is being arranged.

15. The transporter/sender of the hazardous and other wastes shall prepare and maintain manifest in Form10.

16. The occupier or the operator or the transporter shall immediately intimate TNPCB through telephone,e-mail about the accident and subsequently send a report in Form 11, where an accident occurs at thefacility of the occupier handling hazardous or other wastes and operator of the disposal facility orduring transportation

17. The occupier who intends to get its hazardous and other wastes treated and disposed of by the operatorof a treatment, storage and disposal facility shall give to the operator of that facility, such specificinformation as may be needed for safe storage and disposal.

18. The occupier shall be liable for all damages caused to the environment due to improper handling andmanagement of the hazardous and other wastes.

19. The occupier handling hazardous and other wastes shall submit annual returns containing the detailsspecified in Form 4 to TNPCB on or before the 30th day of June of every year for the preceding periodApril to March.

20. Any increase in quantity of handling of hazardous and other wastes, any change in category ofhazardous and other wastes and any change in method of handling operations shall be brought to thenotice of the TNPCB and fresh authorization shall be obtained.

ANNEXURE-V

71

4

The General ManagerRECKITT BENCKISER (INDIA) PRIVATE LIMITED176,Sipcot Industrial Complex,Hosur,KrishnagiriPin:635126

Copy to: 1. The JCEE-Monitoring, Tamil Nadu Pollution Control Board, Vellore.2. The District Environmental Engineer, Tamil Nadu Pollution Control Board, HOSUR. -----------

ANNEXURE-V

72

CA .S. K. SANIAY, rcrPartnerMem. No.:200763

Phone : 2420778, 2420784, 2563333Email ld : [email protected]

E. S. & ASSOCTATESChartered AccountantsNo. 765, lst Floor,Bank Of Baroda BuildingGandhi Square, Mysore - 570 001Karnataka, India

Firm No z 0112365PAN: AACFE 2507 QST Regn No: AACFE2507QST0O2

CERTIFICATE

TO WHOM SOEVER tT MAY CONCERN

We have verified the betow mentioned documents / statements /workings provided to us with respect to Fixed Assets held byM/S Reckitt Benckiser (l) Pvt Ltd, Hosur unit, situated at plot No. 176,5lPCOT Industrial complex, Hosur-635 126, Iamil Nadu forcertification of Gross value of Fixed Assets ;

1) Fixed Asset Register2) Management Letter / workings with respect to proposed additions during the expansion period in the current financial

year 2017-I8.3) Explanation given by the Management team.

Based on the verification of the above do'cuments / statements /workings, We certify the Gross value of various categories of fixedassets hereunder, The value has been certified in Lakhs (lNR)

sl.No.

Assets Category

Gross value as

on 3lst March,2017

ProposedAdditions during

expansion in

2017-18

Proposed Gross value aftercompletion of expansion

1 Land 5.38 s.38

1 Building 1 n5? ?q 53 1.70 1,585.05

3 Plant and Machinerv 97s.10 1002.09 L,977.19

A ETPlSTP/APC r27.45 78.43 20s.88

5 Other Assets 79.35 L9.94 99.29

Totalt

2,240.63 t632.16 3,872.79

Gross value stated above is correct to the best of our knowledee and belief which is based on the reliance olaced on the abovereferred documents / statements /workings.

This certificate has been issued on 6'n November,2O!7 atthe request of the Company.

For E. S. & AssociatesChartered Accountants

ANNEXURE-VI

73

ANNEXURE-VII

74

ANNEXURE-VII

75

ANNEXURE-VII

76

ANNEXURE-VII

77

ANNEXURE-VII

78

ANNEXURE-VII

79

ANNEXURE-VII

80

ANNEXURE-VII

81

ANNEXURE-VII

82

ANNEXURE-VII

83

ANNEXURE-VII

84

ANNEXURE-VII

85

ANNEXURE-VII

86

ANNEXURE-VII

87

reckitt benckiser (india) private...

Documents