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Office : A-106 Kotia Nirman, New Link Road, Andheri (West), Mumbai - 400 058 Tel: +91 22 6677 6846 Fax: +91 22 6677 6847 Email : [email protected] CIN : U99999MH1993PLC073845 03 rd January 2019 To, Member Secretary EAC Violation Ministry of Environment & Forest & CC Indira Paryavaran Bhavan Jorbagh Road New Delhi – 110003 Sub : Consideration of our proposal for Environment Clearance in upcoming EAC Meeting Ref : 1. Our Environment Clearance application File No. J-11011/241/2017-IA-II ( I ) 2. Compliance Report of recommendations in the Minutes of 15 th EAC Meeting held on 28 – 30 th November 2018 (Sr. No. 15.4.2.4) Respected Sir, We thank the respected Committee for the recommendations mentioned in the 15 th EAC meeting. We would like to submit the point wise Compliance Report with reference to the observations made by the EAC violation committee, in its 15 th meeting held on 28 – 30 th November 2018 in Sr. No. 15.4.2.4 : Point Nos. Points recommended in 15 th EAC meeting Sr. No. 15.4.2.4 Annexure & Pg. No. Point No. : ( i ) The response of the project proponent to the issues raised during the public hearing should be replied appropriately and to be resubmitted and the same should be reflected in the chapter of the Environment Management Plan of Environment Impact Assessment Page No. 1 – 18 Page No. 19 - 38 39 - 42 Reply to Point ( i ) Reply to the Point No. 1 and Advertisement in English & Marathi & photographs of Public Hearing are addressed in Chapter 7 of Environment Impact Assessment Report. Pls find enclosed the following documents relating to Public hearing, as Annexures : Signed Minutes of Meeting of Public Hearing ( Annexure 1)... List of Attendees of Public Hearing ( Annexure 2 )……. Point No. : ( ii ) Revised CER based on the issues raised during the Public Hearing and emerged in the social impact assessment covering the activities, timelines and budgetary requirement

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Page 1: New Letter Head - HOenvironmentclearance.nic.in/writereaddata/Online/EDS/0_0_03_Jan_2… · Office : A-106 Kotia Nirman, New Link Road, Andheri (West), Mumbai - 400 058 Tel: +91 22

Office : A-106 Kotia Nirman, New Link Road, Andheri (West), Mumbai - 400 058 Tel: +91 22 6677 6846 Fax: +91 22 6677 6847 Email : [email protected]

CIN : U99999MH1993PLC073845

03rd January 2019 To, Member Secretary EAC Violation Ministry of Environment & Forest & CC Indira Paryavaran Bhavan Jorbagh Road New Delhi – 110003 Sub : Consideration of our proposal for Environment Clearance in upcoming EAC Meeting Ref : 1. Our Environment Clearance application File No. J-11011/241/2017-IA-II ( I )

2. Compliance Report of recommendations in the Minutes of 15th EAC Meeting held on 28 – 30th November 2018 (Sr. No. 15.4.2.4)

Respected Sir, We thank the respected Committee for the recommendations mentioned in the 15th EAC meeting. We would like to submit the point wise Compliance Report with reference to the observations made by the EAC violation committee, in its 15th meeting held on 28 – 30th November 2018 in Sr. No. 15.4.2.4 : Point Nos. Points recommended in 15th EAC meeting

Sr. No. 15.4.2.4 Annexure &

Pg. No. Point No. :

( i ) The response of the project proponent to the issues raised during the public hearing should be replied appropriately and to be resubmitted and the same should be reflected in the chapter of the Environment Management Plan of Environment Impact Assessment

Page No. 1 – 18

Page No. 19 - 38

39 - 42

Reply to Point ( i )

Reply to the Point No. 1 and Advertisement in English & Marathi & photographs of Public Hearing are addressed in Chapter 7 of Environment Impact Assessment Report. Pls find enclosed the following documents relating to Public hearing, as Annexures : Signed Minutes of Meeting of Public Hearing ( Annexure 1)... List of Attendees of Public Hearing ( Annexure 2 )…….

Point No. : ( ii )

Revised CER based on the issues raised during the Public Hearing and emerged in the social impact assessment covering the activities, timelines and budgetary requirement

Page 2: New Letter Head - HOenvironmentclearance.nic.in/writereaddata/Online/EDS/0_0_03_Jan_2… · Office : A-106 Kotia Nirman, New Link Road, Andheri (West), Mumbai - 400 058 Tel: +91 22

Office : A-106 Kotia Nirman, New Link Road, Andheri (West), Mumbai - 400 058 Tel: +91 22 6677 6846 Fax: +91 22 6677 6847 Email : [email protected]

CIN : U99999MH1993PLC073845

should be submitted. Page No. 43 - 47

Reply to Point ( ii )

Action plan for CER Activity enclosed. We have revised the plan and amount as discussed in EAC meeting.

Point No. : ( iii )

The Risk Assessment Report with Risk Curve in the event of explosion / accident of the inventory of Toxic and Hazardous Chemicals as per the DOW Index summary sheet

Page No. 48

Reply to Point ( iii )

Drawing and Layout enclosed

Point No. : ( iv )

NOC from MIDC for the additional water requirements

Page No. 49 - 50

Reply to Point ( iv )

NOC from MIDC is enclosed

Point No. : ( v )

Certificate & Agreement of acceptance by MIDC for accommodating the effluent discharge during emergency

Page No. 51 – 63

Reply to point ( v )

Certificate is provided herewith

Point No. : ( vi )

The coverage of Green Belt and plantation shall be to the extent of 33% of the total plot area against the proposed green belt of 11,825 sq. mtr. Area. The density of the plants to be increased as per the guidelines of the Ministry. Selection of the trees / plant as per the CPCB guidelines.

Page No. 64 - 70

Reply to point ( vi )

Action plan for the Green Belt is enclosed herewith

Point No. : ( vii )

Detailed Consequences and the action plan in case of Reactor failure or damage / worst case scenario ( SOP’s )

Page No. 71 - 76

Reply to Point ( vii )

Worst case scenario ( SOP’s ) enclosed

Point No. : ( viii )

Toxicity test Report ( Bioassy Test ) of the treated effluent

Page No. 77 - 78

Reply to Point ( viii )

Bioassay Test Report is enclosed herewith

Point No. : ( ix )

Analytical data related to surface and ground water and soil

Page No. 79 - 83

Reply to Point ( ix )

Ionic Balance Sheet for Ground water and Surface water is attached in Annexures 3 & 4

Point No. : ( x )

The ecological impacts, mitigation and the remediation measures during construction operation phases furnished by the PP is found to be inadequate in the following :

Page No. 84 - 110

Reply to Point ( x )

Refer attached Annexure 5. We have considered the points recommended by EAC.

Page 3: New Letter Head - HOenvironmentclearance.nic.in/writereaddata/Online/EDS/0_0_03_Jan_2… · Office : A-106 Kotia Nirman, New Link Road, Andheri (West), Mumbai - 400 058 Tel: +91 22

Office : A-106 Kotia Nirman, New Link Road, Andheri (West), Mumbai - 400 058 Tel: +91 22 6677 6846 Fax: +91 22 6677 6847 Email : [email protected]

CIN : U99999MH1993PLC073845

With the above submissions, we have complied to all pending points raised by respected EAC. As you are aware, we have been waiting for grant of Environment Clearance since very long time. We request you to kindly consider our proposal and grant us Environmental Clearance in the upcoming EAC meeting in January 2019. We will be obliged and forever grateful. Thanking you, Yours truly For SHOGUN ORGANICS LTD.

M. V. HANDE Director Encl : Compliance Report with Annexures

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2018

1. The response of the project proponent to the issues raised during the public hearing

should be replied appropriately and to be resubmitted and the same should be reflected

in the chapter of the Environment Management Plan of Environment Impact

Assessment.

The issues raised during public hearing have being noted by the project proponent and the

replies to the same are addressed below -

Public Hearing

“Public Consultation” refers to the process by which the concerns of locals likely to be

affected/all the stakeholders who have plausible stake in the environmental impacts due to the

project or activity are ascertained with a view to taking into account all the material concerns

in the project or activity design as appropriate. M/s Shogun Organics Ltd. will execute the

proposed capacity enhancement activity within the existing manufacturing facility located at

Plot No : D - 18 , MIDC Kurkumbh , Taluka – Daund, District - Pune, State – Maharashtra,

India. The public hearing was carried out dated 5th

September, 2018 within the company

premises of M/s Shogun Organics Ltd. The advertisement issued in public interest, in two

newspapers, in English and Marathi languages namely, The Indian Express and Loksatta

newspapers respectively, is given below in the Fig-1.1. The detailed table showing

observations/issues of the villagers and panel members and reply by the project proponent is

tabulated below –

1. SHRI BHANUDAS BHANDLIKAR, RESIDENT OF PATAS, DIST-PUNE

Sr.

No.

Issue/Question Raised Comments made by Project

proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 Which procedure is followed to

know the general public about the

conducting of the public hearing?

Convener of the Public Hearing and

Sub Regional Officer, Pune-I, MPCB,

Pune informed that as per the EIA

Notification of Ministry of

Environment, Forest & Climate

Change, Govt. of India, (i.e.

MoEFCC, GoI) dated 14th

September, 2006 as amended on 1st

December, 2009, one month advance

public notice was published in the

local Marathi newspaper Loksatta and

National English newspaper Indian

Express on 04-08-2018. Also the

copies of Executive Summary and

EIA Report were available at various

offices of Government i.e. Ministry

----

1

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2018

of Environment, Forest & Climate

Change, Western Zone Office,

Nagpur; District Magistrate Office,

Pune, Additional District Magistrate

Office, Pune, Zilla Parishad Office,

Pune, District Industries Centre

Office, Pune, Tahsil Office- Daund,

Dist, Pune, Grampanchayat offices of

Kurkumbh, Pandharewadi, Sub

Regional Office, MPCB, Pune-I,

Regional Office, MPCB, Pune and at

Head Office of MPCB at Mumbai,

Environment Department, Govt. of

Maharashtra, Mumbai and on the

website of MPCB. The public in

general were appealed to send any

suggestion or objection regarding the

expansion of above project.

2 Why the copies were not made

available at Patas Grampanchayat?

Convener of the Public Hearing

Committee informed that the copies

were made to project affected

grampanchayats only. The copies

were made available to Revenue Area

Incharge at Daund i.e.Tahsildar

Daund, & SDM Daund as Patas

Grampanchayat falls under his

jurisdiction.

----

3 He further asked how the company

is carrying activities without

obtaining prior Environmental

Clearance?

Member of the Public Hearing

Committee and I/c Regional Officer,

MPCB, Pune informed that for

carrying Formulation & trading

activities, there is no requirement of

EC and no new products are being

manufactured.

No Manufacturing activity

is carried out presently

within the company

however only formulation

and trading activities are

carried out for which

obtaining prior

environmental clearance is

not applicable.

2. SHRI VIJAY CHAVAN, RESIDENT OF PANDHAREWADI, DIST-PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 Due to expansion of Pesticide

Manufacturing & Formulation

Unit, whether there will be any

ill-effects on air and health of

public?

Environment Consultant of the project

informed that – 1)The Environment

Management Plan will be

wholeheartedly implemented.

2) The industrial effluent after treatment

will be recycled to use it in the process.

The domestic effluent after treatment

will be used in the factory premises for

green belt development. Thus the project

will be Zero Liquid Discharge.

3)To avoid ill-effects/pollution from

Taking into view the

expansion capacity, as

written in the EIA report,

there will be generation of

effluent, flue gases due to

fuel combustion, process

emissions, however

appropriate mitigation

measures like ETP for

achieving Zero Liquid

Discharge, adequate stack

2

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2018

boiler and process, 30 Mtr. Chimney will

be provided to boiler. Also 12 Mtr.

Chimney to Scrubber will be provided.

3.0 Mtr. Chimney will be installed to

D.G. set.

height for ensuring proper

dispersion of pollutants,

process scrubber for

scrubbing the process

emissions. All necessary

pollution control

equipments will be installed

within the company and

will be regularly monitored,

also Environment

Management Plan will be

wholeheartedly

implemented. Therefore

probability of ill-effects on

air and health of public is

negligible.

2 Here Convener of the Public

Hearing Committee asked to

give pollution control measures

in the production activities

only.

Environment Consultant explained that

in the production activities, solvent will

be used which will be sent through

closed system to scrubber.

Convener of the Public Hearing

Committee informed in the Marathi that

effluent will be scrubbed in the closed

vessel.

All the raw material will be

charged under vacuum

through closed feed system.

The vents of all the reactors

are connected to Alkaline

Scrubber.

3 He raised objections regarding

the pollution of the area and

suggested that like another

company i.e. Harmony

Organic, all the polluting

industries should be closed. If

there is going to be pollution

then permission should not be

granted.

1)Member of the Public Hearing

Committee informed that any permission

is not at all granted by this Committee.

The objections, suggestions made in this

meeting are incorporated in the minutes

and report along with final EIA is

submitted to the Expert Committee of

MoEFCC, GoI. After considering the

objections, suggestions only, the Expert

Committee takes further decision.

2) The Committee appealed the general

public only to raise objections or

suggestions regarding the particular

project, whose public hearing is in

process.

--

4 He read a news item of a

particular company in which it

is mentioned that the company

should be closed, if there is

pollution.

Member, Public Hearing Committee

informed that this public hearing is

conducted for the Shogun Organics only.

Hence environmental issues of Shogun

Organics should be discussed. He

further informed that this Committee

does not give any permission to the

project. The aim is to know the feelings,

suggestions, objections of the local

people regarding the proposed expansion

in environmental point of view.

----

3

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2018

3) SHRI ABHIMAN ABASAHEB NIMBALKAR, RESIDENT OF PANDHAREWADI,

DIST – PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project

Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 1) The location of the factory

is at upsite / upstream. Due to

percolation of the effluent, the

wells at downstream may be

totally polluted.

2) The well water located at

a distance of 500 Mtr., from the

plant should be checked

periodically;

3) Downstream agriculture

fields have became totally barren

due to effluent of industries;

4) We are not against the

project, but people should not

suffer due to this project;

5) Local people should be

given job opportunities and

should be treated gently while

registering the complaints.

Environment Consultant of the

project informed that

1)The industrial effluent after

treatment will be recycled and will be

used in the production. The domestic

effluent after treatment will be used in

gardening. Thus it will be Zero

Liquid Discharge project;

2)The MPCB officials do collect the

well water samples periodically;

3)As there will no discharge of any

effluent outside the factory, the

nearby agriculture fields will not be

polluted, Hence people should not

fear about the soil pollution of their

agriculture fields.

4)It is informed that at present 27

persons are working in the unit.

There will requirement of 41 persons

after expansion. Thus total strength

will be 68 persons.

5) As Environment Management Plan

will be implemented strictly, the local

people should not fear about the

pollution.

The project will be operated

as a Zero Liquid Discharge

Unit. The treated water

from the ETP will be

entirely re-used for the

Cooling tower make-up.

The sewage effluent will be

treated in STP and the

treated water will be used

for gardening.

At present 27 persons are

working in the unit. There

will requirement of 41

persons after expansion.

Company will employ local

people as per their skill and

qualifications.

4) SHRI RIZWAN MULANI, RESIDENT OF KURKUMBH, DIST – PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project

Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 He requested to inform the name

and designation of the Public

Hearing Committee.

It is informed by the Public Hearing

Committee that while starting the

proceedings, it is made. But

Convener of the Public Hearing again

introduced the Public Hearing

Committee and designations of the

Committee Members.

----

4

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2018

5) SHRI SHRIKANT JADHAV, RESIDENT OF MUKADAMWADI :-

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project

Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 1) Whether at any products

are manufactured in the

company? If not, how many days

it is closed?

The factory is not producing any

product and since last 1-1/2 years, it

is closed. Only Formulation trading

activities are going on in the unit.

No Manufacturing activity

is carried out within the

company however only

formulation and trading

activities are carried out.

2) He objected how activity

is continued without prior

Environmental Clearance?

Convener of the Public Hearing

Committee informed that

Environmental Clearance (EC) is not

required for Formulation & trading

activities. After obtaining EC, then

only the factory can start additional

production activities.

No Manufacturing activity

is carried out within the

company however only

formulation and trading

activities are carried out for

which obtaining prior

environmental clearance is

not applicable.

3) Whether Effluent

Treatment Plant will be built to

treat additional effluent due to

expansion?

Project Environment Consultant

informed that at present 4.5 CMD

industrial effluent is produced and

after expansion, there will be increase

of 12.28 CMD. The total 16.78 CMD

industrial effluent will be treated in

the ETP of the 18 CMD capacity.

The total industrial effluent will be

treated and will be recycled in the

production activities. It will be Zero

Liquid Discharge project.

Existing ETP and STP are

sufficient to treat additional

effluent after expansion.

4) The company will use

treated domestic water for

gardening. What will be its

TDS?

Convener of the Public Hearing asked

to inform TDS and COD of the

treated domestic water which will

used for gardening. Project

Consultant informed that Distillation

system will be implemented. After

distillation, there will be condensation

The TDS will be less than 50 mg/l -

60 mg/l and COD will be negligible

i.e. less than 10 mg/l;

The domestic water will be

treated in STP and the

treated effluent will be used

for gardening. The TDS

will be around 100 – 120

mg/l.

5) The factory is located at

the up side, hence the effluent

will go to downside. Hence will

the drinking water sources at

downside will be polluted ?

As the project will be Zero Liquid

Discharge, there will not be any liquid

discharge outside the factory.

ZLD system will be

continued after expansion.

6) Whether company will

give commitment in writing that

there will be no pollution?

1) Project Environment Consultant

informed that MPCB officials do visit

the factory periodically to check the

water and air pollution.

2) Member of the Public Hearing and

I/c Regional Officer, MPCB informed

that there is writing commitment in

the EIA, Executive Summary and in

It is written in the EIA

report that the company

will continue ZLD.

5

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2018

Presentation that project will be Zero

Liquid Discharge.

6) SHRI ZUMBER SHITOLE, RESIDENT OF KURKUMBH, DIST – PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 He objected that there were

many public hearings before

commencement of production.

The commitments were given,

but nothing is done.

Environment degradation is

continued. He said that the

local people are not against the

project. But pollution should

be controlled. There should

be Zero Pollution.

It is informed that this project is Zero

Liquid Discharge.

The Project Proponent

assures that project will

work as a Zero Liquid

Discharge unit.

2 He informed that after giving

commitments, M/s Alkaline

Amines is polluting the

environment. . The discharge

from CETP should be

inspected immediately and

MPCB should take stringent

action against the polluters

The Committee asked to give complaint

about this other company, and action will

be taken as per Law.

In present public hearing, only issues of

Environment management of Shogun

Organics should be raised

----

3 As local people desires,

writing commitment regarding

No Pollution should be given

by the company.

This project is zero effluent. The

Committee sends the objections and

suggestions made in the meeting. The

permission is given by the Central

Government

As written in the EIA

report, Environment

Management Plan will be

wholeheartedly

implemented. All

necessary pollution

control equipments will

be installed within the

company and will be

regularly monitored also

the project will operate as

a ZLD unit hence all the

effluent after proper

treatment will be reused

within the company

premises.

4 Whether factory is running or

production activities are

closed?

It is informed that only formulation

activities are carried. After obtaining the

Environmental Clearance, the additional

production activities will be carried.

No Manufacturing

activity is carried out

within the company

however only formulation

and trading activities are

carried out.

5 If the formulation activities is

running, how there is effluent

stored at the factory?

Project consultant informed that at present

domestic effluent is 0.9 CMD. It is

treated in the treatment plant.

Member of the Public Hearing Committee

asked to show effluent after hearing.

The entire plant including

ETP and STP was shown

to the public attending the

Public hearing after

presentation.

6

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2018

7) SHRI ASIM SHAIKH, RESIDENT OF KUKUMBH, DIST – PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 The complaints are sent to

local MPCB office several

times, but no action is taken by

MPCB. Hence there should be

Suggestion / Complaint

Register at CETP site/office ,

then only local people can

register the complaint there.

MPCB can take cognizance of

the complaint.

Chairman of the Public hearing

committee welcomed the suggestion and

he directed MPCB officials to take further

cognizance immediately.

----

2 How many amount will be

spent for Kurkumbh village

under CER Fund as the project

falls under Kurkumbh area

The details were informed by the Project

Proponent.

Under CER Rs. 32 lakhs

will be spent for Kurkumbh

and Pandhrewadi village

having equal contribution

during next 3 years.

3 Local people should be given

job opportunities.

Project officials informed that the

management do give job opportunities to

local people only.

At present 27 persons are

working in the unit. There

will requirement of 41

persons after expansion.

Company will employ local

people as per their skills

and qualifications.

8) SHRI SHAHAJI JADHAV, EX-MEMBER, PANDHAREWADI GRAMPANCHAYAT

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 He opined that commuters

passing through State

Transport Buses do recognize

Kurkurmbh due its obnoxious

smell from various polluting

industries. He opined that

there is no objection by

villagers for this company, but

they should take care of

environment. It should be Zero

Pollution in the area. He

asked how many fresh water

require for the production and

how much effluent will be

generated and its treatment?

1) Project consultant informed that there

will not be any obnoxious smell from the

factory.

2) Project consultant further informed that

at present 4.5 CMD industrial effluent is

produced and after expansion, there will

be increase of 12.28 CMD. The total

16.78 CMD industrial effluent will be

treated in the ETP of the 18 CMD

capacity. The total industrial effluent

will be treated and will be recycled in the

production activities. It will be Zero

Liquid Discharge project.

All the raw material will be

charged under vacuum

through closed feed system.

The vents of all the reactors

are connected to Alkaline

Scrubber.

2 Whether there will be

pollution of well water?

Project Consultant informed that The total

industrial effluent will be treated and will

Project is ZLD.

7

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2018

be recycled in the production activities. It

will be Zero Liquid Discharge project.

After expansion, the factory may run in

two shifts.

9) SHRI SHRIKANT JADHAV, RESIDENT OF PANDHAREWADI:

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 Whether Safety measures and

fire fighting system is

provided in the plant?

1)As per strict guidelines of the

Government, the onsite Fire Fighting

Extinguisher are kept;

2) The training is extended to the

employees to handle the same at time of

any mishap.

Firefighting tank of 200 m3

has been provided at site.

Fire hydrant line has been

provided throughout the

plant premises. Appropriate

fire extinguishers, smoke

detectors have been

installed. Onsite & Offsite

emergency plan have been

prepared.

10) SHRI RAHUL BHOSALE, SARPANCH, KURKUMBH

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 The local people desire that

the project of Shogun Organics

should be commenced. There

is no adverse opinion for this.

But MPCB should take action

against the other polluting

industries. Also writing

commitment should be sought

from the project proponent

regarding non-pollution from

the unit.

It is informed that -

1) MPCB keeps periodical

surveillance and action is always

taken against the polluters

following due procedure of Law.

2) The project proponent has given

writing commitment in the report

regarding Zero Discharge Project

which will be submitted to

Central Government with the

minutes of this meeting.

The writing commitment

regarding non-pollution

from the unit viz. Zero

liquid discharge and

installation of necessary

Pollution control

equipments are given in

chapter 4 of the

Environment impact

Assessment Report.

2 He further informed that as

there were many pollution

complaints from this area, the

Collector, Pune directed

MPCB that two officers should

be available whole time in the

MIDC Kurkumbh area.

Nothing is done till to-date.

Here also it is informed that periodical

surveillance is carried by MPCB officials.

-----

8

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11) SHRI TYATASAHEB ZAGDE, RESIDENT OF PANDHAREWADI, DIST-PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 He asked whether CSR Fund

is reserved with production

percentage. How much CSR

Fund is spent for the year

2018. Which villages have

been selected?

Project Environment Consultant informed

that CSR Fund (Now it is called as CER

Fund). It is informed that environment

plan expenditure is Rs. 5.65 lakhs per

year and total Rs. 28.25 lakhs is reserved.

The amount for the 2018 is ear-marked

Rupees 5.65 lakhs. The amount will be

spent for providing basic amenities to two

Zilla Parishad Schools at Firangai Devi

Nagar and Patas. It is informed that local

people will be taken into confidence and

amount will be spent accordingly.

Rs. 32 lakhs for 3 years is

reserved under CER for two

villages, namely Kurkumbh

and Pandharewadi.

2 Though the project is in

operation in Pandharewadi

village, why the name of

village Pandharewadi is

deleted?

The objection is noted by the Committee.

Chairman of the Committee directed that

name of the Pandharewadi should be

included while preparing final EIA Report

and local people should be taken into

confidence while spending amount of

CER Fund.

Rs. 32 lakhs for 3 years will

be spent equally under CER

for 2 villages, namely

Kurkumbh and

Pandharewadi.

3 Local people should be given

job opportunities.

Project Proponent informed that local

people are always given priority in job

opportunities.

At present 27 persons are

working in the unit. There

will requirement of 41

persons after expansion.

Company will employ local

people as per their skills

and qualifications.

4 He asked in which laboratory

the samples of water and air

are analyzed by the Project

Consultant while preparing

EIA report? He opined that

the project proponent should

give Pollution Control

Commitment in writing.

It is informed that the samples of water

and air are analyzed in laboratory which

is recognized by MoEF&CC, Govt of

India, which has valid license till 2nd

January, 2019.

Commitment for Pollution

Control are given in the

chapter 4 of the

Environment Impact

Assessment Report .

5 Whether project proponent

will make available fire

brigade and ambulance to the

local people and what will be

the cost of service?

Chairman of the Committee here

informed that MIDC office at Kurkumbh

made available the services of Fire bridge.

He further informed that even if District

Administration uses Fire Brigade of

MIDC, the cost of services have to be

paid.

The project proponent has

membership with rotary

club, Kurkumbh. Project

proponent will request the

hospital authority of Rotary

club, kurkumbh to provide

the ambulance service

where and when required to

the locals.

Fire Brigade service is

available at MIDC,

kurkumbh at nominal

charges and can be used by

Locals.

9

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12) SHRI CHETAN JAGTAP, RESIDENT OF MUKADAMWADI, DIST-PUNE

Sr.

No.

Issue/Question Raised Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 The Environment Consultant

informs that distilled water

will be used for boiler. But as

per Indian Boiler Act, distilled

water should not be used for

Boiler.

The Project Environment Consultant

informed that the distilled water will have

good quality than soft water. The TDS

will be 50-60 mg/l. It will be used for

boiler and cooling tower.

---

13) SHRI AYUB SHAIKH, RESIDENT OF KURKUMBH, DIST – PUNE

Sr.

No.

Issue/Question Raised Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 The local people have suffered

a lot due to pollution from

MIDC Kurkumbh industries.

We are not at all against the

industries. But pollution

should be controlled.

Noted by the Public Hearing Committee. Environment Management

Plan will be wholeheartedly

implemented also all

necessary pollution control

equipments will be installed

within the company and

will be regularly monitored.

2 There are always incidences of

noise and air pollution due

releasing of gasses. Hence

“Air & Noise Pollution

Detector” should be installed

with display board 500 Mtrs

away from the project at

Pandharewadi.

Chairman of the Committee welcomed

the suggestion. He asked Member and

Convener of the meeting to keep follow

up for the same.

----

3 He along with others asked

about the Ambient Air Quality

Monitoring Survey locations.

Project Environment Consultant informed

that as mentioned on slide no.20, the

locations have been selected as per wind

direction. Total eight locations have been

selected and longitude and latitude of the

locations are mentioned.

Representative of

Environmental Consultant

M/s Sadekar Enviro

Engineers Pvt. Ltd. Shown

the location of monitoring

station to the villagers of

Kurkumbh and

Pandharewadi

4 Here most of local people

blamed that Ambient Air

Quality Monitoring (AAQM)

survey is not carried properly.

They objected that why local

people were not ; prior

informed while carrying the

survey. Most of them opined

that survey should be carried

in front of local people.

After detailed discussions, Chairman of

the Committee directed Environment

Consultant to show the exact location of

each village where AAQM survey is

carried to group of local residents. Also

the exact location where the water sample

is collected & also requested the people

visit around the industry to have look at

production activity & ETP status etc

After the Public Hearing

completed, the

representative of

Environmental Consultant

M/s Sadekar Enviro

Engineers Pvt. Ltd. Shown

the location of monitoring

station to the villagers of

Kurkumbh and

Pandharewadi.

10

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14) SHRI CHANDRAKANTDADA BHOSALE, RESIDENT OF MUKADAMWADI, DIST-

PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 Whether the project proponent

have hazardous chemicals

storage as per the Rules.

Project Environment Consultant informed

that the project proponent will have

hazardous chemicals storage as per strict

norms of DISH i.e. Directorate of

Industrial Safety & Health.

Hazardous chemicals stored

as per strict norms of DISH

i.e. Directorate of Industrial

Safety & Health

2 Whether Safety Audit is

undertaken?

It will be undertaken periodically as per

the guidelines of the Government.

Yes. Safety Audit has been

done and it will be done

periodically and record

shall be maintained.

3 How the air pollution will be

controlled?

Scrubber will be installed to air pollution

control devices and only neutral air will

be released.

Sufficient height for boiler

stack has been provided to

ensure proper dispersion of

pollutant.

Alkaline scrubber is also

installed to scrub the

process emissions.

15) DR. H.D.GANDHE, MEMBER, PUBLIC HEARING COMMITTEE

Sr.

No.

Issue/Question Raised Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 Member, Public Hearing

Committee informed asked

that boiler fuel requirement is

shown as 62.5 liter. After

expansion, the boiler fuel

requirement is shown as 548.5

liter. How 10% more will be

required?

It is informed that after expansion the unit

will run in two shifts. It may run in three

shifts and maybe 30 days in a month also,

considering the requirement.

After expansion the unit

will run in two shifts. It

may run in three shifts and

maybe 30 days in a month

also, considering the

requirement.

16) SHRI AMOL KULANGE, RESIDENT OF PANDHAREWADI, DIST – PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 He raised objection that most

of industries are polluting the

area and local people suffers

since last many years. After

Member, Public Hearing Committee

informed to give specific complaint

against other factories that may be

polluting. MPCB always initiate action

----

11

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sending complaints several

times, MPCB is not taking

action against the polluters.

against the defaulters as per the Law. He

further informed that a notice is also

served to CETP Administration.

17) SHRI VINOD SHITOLE, RESIDENT KURKUMBH, DIST – PUNE

Sr.

No. Issue/Question Raised

Comments/Commitments made by

Project Proponent

Comments/Commitments made by

Project Proponent/Consultant/Public

Hearing Committee

Commitment by the

Project Proponent

1 He appealed to consider the

sentiments of local people. He

said that local people is not

against the project, but against

the pollution.

It is informed that the promises are

already made. The project is pollution

free project. Local people are given job

opportunities in the project.

Environment Management

Plan will be wholeheartedly

implemented. All necessary

pollution control

equipments will be installed

within the company and

will be regularly monitored

also the project will operate

as a ZLD unit hence all the

effluent after proper

treatment will be reused

within the company

premises

Summary of Public hearing -

The Public Hearing Committee appealed all to raise suggestion or objections for the

expansion of the project. As there was no suggestions or objections, Chairman of the Public

Hearing Committee while concluding the meeting reviewed the points raised during the

meeting.

Chairman of the Public Hearing Committee informed that –

• As per the presentation, to control air pollution, stack height of process scrubber will be

increased to 12 Meter. The boiler stack will be increased by 10.0 Meter. There will increase

in the requirement of water of 48.63 CMD after expansion. Naturally, there will increase in

industrial effluent of 12.28 CMD. The domestic effluent will be increased by 4.4 CMD.

The project officials are promising that the total industrial effluent after treatment will

recycled in the process. The domestic effluent after treatment will be used for green belt

development.

• The suggestion is received that there should be display of noise and air pollution and the

complaint register should be maintained at CETP. Both suggestions have been welcomed

and MPCB officials are directed to take follow up for the same.

• As per the Rule, the project has already obtained Membership of CHWTSDF, Ranjangaon.

It is mandatory to the project officials to send their hazardous wastes to CHWTSDF for

further treatment and disposal;

12

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• Some local people raised that the wells at downstream are polluted due to discharge of

untreated effluent by other factories industries. The TDS of well water observed to be 3,000

mg/l– 4,000 mg/l, due to which agriculture fields have become barren. Here, this industry

promises that the project will be Zero Liquid Discharge;

• But MPCB officials and other departments should be always be vigil while carrying the

periodical surveillance;

The name of Pandharewadi should be included while preparing final EIA report for carrying

the work under the CER Fund. Certain funds should also allotted to Pandharewadi;

• MPCB officials will visit other outside for inspection, after the hearing.

• Chairman of the Committee further informed that this information the suggestions, objections

raised during the meeting will be sent along with minutes of meeting, final EIA report to

Expert Committee of MoEFCC, GoI. The Expert Committee will take note of the same while

taking further action.

• Chairman of the Committee mentioned in general that there were number of pollution

problems in the MIDC Kurkumbh area. But as this project proponent is going to implement

Environment Management Plan wholeheartedly, it will be towards positive steps. There is no

objections to this project. But the project proponent should also follow the strict standards as

prescribed by MPCB and other Competent Authorities.

Chairman of the Public Hearing Committee declared the meeting is concluded.

The meeting ended extending thanks to the Chair.

The copy of PH MoM is attached as Annexure -1 and the list of attendees of Public hearing

of Shogun Organics Ltd. is attached as Annexure – 2.

13

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Figure 1.1: Photographs of Advertisement in Newspaper.

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Figure no 1.2: Photographs of Public Hearing of Shogun Organics Ltd.

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Annexure-1

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Annexure-2

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2. Revised CER based on the issues raised during the public hearing and emerged in the

social impact assessment covering the activities, timelines and budgetary requirement

should be submitted.

Action Plan for CER Activity

In order to carry out the CER activity it was decided that the proponent would provide basic

facilities in the area of safe drinking water, educational aid for the nearby Panchayat Schools

of Kurkumbh and Pandharewadi village, also the proponent had planned to install solar street

lights in consultation with the panchayat of Kurkumbh and Pandharewadi Villages.

During the survey it was observed that the schools lacked in basic facilities such as safe

drinking water, sanitation and other essential facilities such as computer, projector, etc and

also the villages lacked street lights which are essential for the villagers at the time of night.

Keeping in view the issues and problems raised in the public hearing by the villagers of

Kurkumbh and Pandharewadi, proponent plans to carry out analysis of ground water & soil

and to carry out health checkup in consultation with the panchayat of the above mentioned

villages. Thus, keeping the above factors in mind the CER for the proponent is presented in

Table 2.1

.

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Table 2.1: List of CER Activity

Total Cost

of Project

Cost for

the CER

Activity

Year of

Implemen

tation

Amount in

Lakhs Activity Cost Estimate

14.5 Cr. is

the total

Project Cost.

32.00.000/-

2019 1,070,000/-

Providing basic amenities to

two nearby Panchayat school

present in Kurkumbh and

Pandharewadi.

Analysis of ground water

quality in Kurkumbh and

Pandhare wadi village.

Analysis of polluted soils in

Pandharewadi and Kurkumbh

village.

Skill development

programmes, Specific

Training

programs/workshops to be

organized at Factory

premises for nearby locals.

Particulars Amount

(Approx.)

For Water Purification

R.O. + UV purification System

(3 nos)

90,000/- (each)

= 2,70,000/-

Analysis of ground water

Analysis of groundwater at 6

nos of wells in Kurkumbh and

Pandharewadi villages

35,000/- (each)

=2,10,000/-

Analysis of soils

Analysis of soils in

Pandharewadi and Kurkumbh

village (5 samples)

42,000/- (each)

=2,10,000/-

Particulars Amount

(Approx.)

Organising Skill development

programmes 2,00,000/-

Organising Training

programmes/Workshops. 1,80,000

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2020 1,075,000/-

Organizing Health Check-up

camp for the students of

Kurkumbh and Pandharewadi

villages including regular

health check, respiratory tests

like lung function test and

liver function test

Analysis of ground water

quality in Kurkumbh and

Pandhare wadi village.

Providing modern teaching

facilities to schools of

Kurkumbh village.

Analysis of ground water

Analysis of groundwater at 6

nos of wells in Kurkumbh and

Pandharewadi villages

35,000/- (each)

=2,10,000/-

Particulars Amount

(Approx.)

Computer (6 nos x 1 Schools) 40,000/- (each)

=2,40,000/-

Projector (1 no. x 1 Schools) = 40,000/-

Projector Screen (1 no..x 1

Schools)

20,000/- (each)

= 20,000/-

Particulars Amount

(Approx.)

Normal Health Checkup &

Lung function test & liver

function test

5,65,000/-

2021 1,055,000/-

Installation of Solar Street

lights in consultation with

the grampachayat,

Kurkumbh and Pandhrewadi.

Providing modern teaching

facilities to schools of

Pandharewadi village.

Particulars Amount

(Approx.)

Solar street Lights in

kurkumbh Village (15 nos) +

Installation Charges*

25,000/-* (each)

= 3,75,000/-

Solar street Lights in

Pandharewadi Village (15 nos)

+ Installation Charges*

25,000/-* (each)

= 3,75,000/-

45

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Particulars Amount

(Approx.)

Computer (5 nos x 1 Schools) 40,000/- (each)

= 2,00,000/-

Computer Table (5 nos) 4,000/- (each)

=20,000/-

Projector (1 no. x 1 Schools) 40,000/- (each)

= 40,000/-

Projector Screen (1 no..x 1

Schools)

25,000/- (each)

= 25,000/-

3 Green Boards =20,000/-

46

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Although Maharashtra is one of the affluent states in India with the highest per capita income, and

contributes over 15% of the country's national income and 40% of the tax revenues, having one of the

largest industrial economies, still the benefits of development have not reached in every corner of the

society. The availability well being of any individual can be ensured by providing timely supply of food,

primary health care and adequate education. Out of these food and education is receiving attention to

some extent from the government but that in the area of healthcare and medical supplies is yet a

challenge to for the state.

In order to bridge the gap of medical and health care facilities the proponent plans to carry out health

checkups for the villager of the above mentioned villages.

For the purpose of this as per the commitment around 2.2 % of the total project cost is planned to be

engaged in the social welfare. A road map for the same is provided in the above segment.

47

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3. The Risk Assessment report with Risk Curve in the event of explosion/accident of the inventory of

Toxic and Hazardous chemicals as per the DOW index summary sheet.

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4. NOC from MIDC for the additional water requirements.

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5. Certificate of acceptance by MIDC for accommodating the effluent discharge during

emergency.

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6. The coverage of green belt and plantation shall be to the extent of 33% of the total plot area

against the proposed green belt of 11,825 sqm area. The density of the plant to be increased as per

the guidelines of the Ministry. Selection of the Trees/Plant as per the CPCB guidelines.

Action Plan for Green Belt Development

Generally a thick green belt developed along the factory boundary helps to arrest/capture dust emissions

from escaping beyond the factory boundary and also to minimize the noise intensity propagating out of

the factory premises along with improving the aesthetics of project site.

Design and development of green belt

Design: Thick green belt will be developed along the boundary of the project plot as per the Standard

TOR prescribed by MoEF & CC for Synthetic Organic Chemical industries and the project specific

TOR granted by Expert Appraisal Committee (EAC) - Violation Committee during 1st EAC meeting dt.

22nd

June 2017 and additional compliances given by the Expert Appraisal Committee (EAC) - Violation

Committee in its 15th

meeting dtd 27th

November, 2018.

Area allocation for green belt: Total area under green belt will be 35124.3 sq. m., out of which there is

an existing developed green belt of area 7164.5 sq. m. and additionally 27959.8 sq . m of green belt will

be developed.

Area consideration for growth of individual tree: The area assumption for individual large/medium

size growth achieving tree is 2.6 m x 2.6 m = 6.76 sq. m. as per the Standard TOR prescribed by MoEF

& CC for Pesticides and Pesticide Specific Intermediates manufacturing industry.

Selection of plant species: The plants to be planted are selected considering the floral scenario as

observed in the study area during the baseline assessment study (preferably native fast growing, non

fruiting plants having large leaf area).

Details of existing green belt

Shogun Organics Ltd. is located on Plot No. D-18, MIDC, Kurkumbh, Tal. Daund, Dist. Pune, Pin -

413802 which admeasures an area of 1,06,384.00 sq. m. the said plot has been in use since 2008 for

64

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manufacture of Pesticides accordingly along with these existing operations green belt development has

been done in an area of 7,164.5 sq. m.

The exiting green belt is developed along the southern boundary of the project plot. A total of 1,059.00

plants were planted.

Proposed green belt

Reconnaissance survey were conducted along with the project proponent to identify sites for proposed

green belt & the areas thus demarcated for the proposed green belt & existing green belt were plotted on

the Autocad system the layout plan thus generated is depicted in the figure no. 6.1

65

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Table 6.1: Details break up of existing & proposed green belt

Sr.

No.

Green

Belt Site

Area in sq. m. Location of green belt No. of plants

Existing Proposed Existing Proposed

1 Block A 7,164.5 -- Along the 1

st half of the southern boundary wall of the project plot,

starting form transformer yard up to effluent treatment plant

1,059.00 --

2 Block B -- 5,070 Along the 2

nd half of the southern boundary wall of the project plot,

starting from effluent treatment plant up to end of the boundary wall

-- 749.00

3 Block C -- 9165.60 Along the eastern boundary -- 1356.00

4 Block D -- 13426.2 Along the northern boundary wall of the project plot and western

boundary wall near main gate

-- 1987.00

5 Block E -- 298.00 Along the western boundary of the project plot near canteen 44.0

Total 7,164.5 27959.8 1,059.00 4136.00

35124.3 5195.00

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Figure No 6.1: Project plot layout plan depicting existing and proposed green belt

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Action plan & estimated budgetary allocation for proposed green belt development

The proposed green belt in an area of 27959.8 sq. m. will be developed in phase wise manner

viz. plantation will be done in two phases during January 2019 and January 2020 respectively.

Table 6.2 : Estimated budgetary allocation for green belt development during January

2019

Estimate for block plantation - January 2019 along the 2nd

half of the southern boundary of the

project plot in ‘B’ Block and ‘C’ block along the east boundary

Plantation to be done in Green belt -

„B‟ Block & „C‟ Block

Total area: 14235.00 sq. m.

No. of plants to be planted : 2105

Estimated Expenditure

Sr.

No. Particulars of work Magnitude

Rate ( Rs.) per

unit Amount (Rs.)

1 Alignment & Digging of pits 2105 85 178925.00

2 Purchase of plants (saplings of

large growing trees) 2105 130 273650.00

3

Transportation cost

(transportation of plants to

project site including loading &

unloading) & planting in pits

60,000.00 60,000.00

4 Purchase of soil & fertilizers 2,10,000.00 2,10,000.00

5

Purchase of bricks/fencing

material (for green belt

bordering/fencing)

45,000.00 45,000.00

Total 7,67,575.00

Table 6.3 : Estimated budgetary allocation for green belt development during January

2020

Estimate for block plantation - January 2020 along the eastern, northern & western boundary of

the project plot in Blocks D and E respectively

Plantation to be done in Green belt - D and

E Blocks

Total area: 13724.00 sq. m.

No. of plants to be planted : 2031

Estimated Expenditure

Sr.

No. Particulars of work Magnitude

Rate ( Rs.) per

unit Amount (Rs.)

1 Alignment & Digging of pits 2031 100 2,03,100.00

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2 Purchase of plants (saplings of large

growing trees) 2031 140 2,84,340.00

3

Transportation cost (transportation of

plants to project site including loading

& unloading) & planting in pits

73,000.00 73,000.00

4 Purchase of soil & fertilizers 2,20,000.00 2,20,000.00

5 Purchase of bricks/fencing material

(for green belt bordering/fencing) 66,000.00 66,000.00

Total 8,46,440.00

Table 6.4: Estimated recurring cost for maintaining green belt

Estimate for maintaining the Green Belt Estimated

Expenditure -

Recurring/Annum Sr. No. Particular of work

1 Caretaker 3 No. for 12 month @ 1X 10,000/month 3,60,000.00

2 Estimated miscellaneous expenses such as

replenishing soil/fertilizer/weeds removal etc.

50,000.00

Total 4,10,000.00

Suggested plant species

A mix plantation of native of trees as depicted in the below table is suggested for proposed green

belt & replacement of any dead tree in the existing green belt.

Table No. 6.5 : List of suggested plant species

Sr. No. Botanical Name Family Common name Habit

1 Heterophragma quadriloculare Bignoniaceae Waras Tr

2 Oroxylum indicum Bignoniaceae Tetu Tr

3 Nerium oleander Apocyanceae Kaner Sh

4 Schleichera oleosa Sapindaceae Kusum Tr

5 Terminalia elliptica Combretaceae Ain Tr

6 Terminalia paniculata Combretaceae Kinjal Tr

7 Alstonia scholaris Apocynaceae Saptaparni Tr

8 Butea monosperma Fabaceae Palash Tr

9 Erythrina variegata Fabaceae Panghara Tr

10 Cassia fistula Caesalpiniaceae Bahava Tr

11 Helicteres isora Sterculiaceae Murudsheng Sh

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12 Tabernaemontana alternifolia Apocyanaceae Naagkuda Tr

13 Macaranga peltata Euphorbiaceae Chandwar Tr

14 Azadirachta indica Meliaceae Neem Tr

15 Bridelia retusa Phyllanthaceae Asana Tr

16 Bombax ceiba Bombacaceae Sawar Tr

17 Pterospermum acerifolium Sterculiaceae Muchkund Tr

18 Cordia dichotoma Boraginaceae Shelu Tr

19 Neolamarckia cadamba Rubiaceae Kadamba Tr

20 Firmiana colorata Sterculiaceae Kaushi Tr

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7. Detailed consequences and the action plan in case of reactor failure or damage/worst

case scenario (SOPs).

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8. Toxicity test report (bioassay test) of the treated effluent.

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Interpretation:

The findings of Bio-assay test shows that there is 90% survival of fishes in the treated water

sample of ETP.

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9. Analytical data related to surface and ground water and soil.

Ionic Balance Sheet for Ground Water and Surface Water is attached as Annexure 3 & 4.

The analytical data for soil was checked and found to be correct.

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Annexure-3

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Biol.

pH EC DO Temp. Colour Odour pH EC TDS TSS NH3 NO2-

NO3- Total

PO4-- BOD COD

Phen.

Alkalinity

Total

Alkalinity

Total

HardnessCa

++ Hardness Ca

++Mg

++Na

+K

+Cl

- SO4--

CO3--

HCO3- Si F

- BTotal Faecal Chlorop

hyll-A

mS/cm mg/L 0C Hazen mS/cm mg/L mg/L mg N/L mg/L mg/L mg/L mg/L mg/L mg CaCO3/L mg CaCO3/L mg CaCO3/L mg CaCO3/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L

MPN/100

ml

MPN/100

mlmg/L

[1] [2] [3] [4] [5] [6] [7] [8] [9] [10] [11] [12] [13] [14] [15] [16] [17] [18] [19] [20] [21] [22] [23] [24] [25] [26] [27] [28] [29] [30] [31] [32] [33] [34] [35] [36] [37]

1 GW 1 8.15 583.82 8.15 583.8235 397 7.1 1 <3 <4 301 75.3 25.5 63 1.4 119 50.1 245 0.08 132 GW 2 7.81 526.47 7.81 526.471 358 3.2 1 <3 <4 265 68.1 20.6 60 1.6 115 39.5 195 0.06 293 GW 3 7.92 1729.2 7.92 1729.17 1245 7.5 1 <3 <4 1025 277 75.4 212 2.95 405 29.8 189 0.09 144 GW 4 7.48 688.71 7.48 688.71 427 6.8 1 <3 <4 324 79.4 29.4 67.2 1.5 128 49.3 205 0.06 165 GW 5 7.68 630.43 7.68 630.435 435 4.6 1 <3 <4 315 75.4 25.9 70 1.2 142 25.72 175 0.05 0

6 GW 6 7.84 2141.8 7.84 2141.79 1435 2.1 1 <3 <4 1200 325 89.4 246 1.84 469 41.51 184 0.08 11

7 GW 7 7.93 480 7.93 480 312 4.4 1 <3 <4 216 59.2 14.4 54.2 1.1 98 39.21 211 0.07 0

8 GW 8 8.2 596.97 8.2 596.97 394 5.6 1 <3 <4 304 75.4 25.8 63.4 1.3 121 42.5 192 0.09 0

Ca++ Mg++ Na+ K+ Total

CationsCl- SO4

-- CO3-- HCO3

- NO2- NO3

-

Total

Anion

s

Measured TDS,

mg/L

Calculated TDS,

mg/L

EC,

mS/cm

mg/L mg/L meq/L meq/L meq/L meq/L meq/L meq/L meq/L meq/LCalculated

Hardness

Measured

HardnessRatio

[1] [2] [3] [39] [40] [41] [42] [43] [44] [45] [46] [47] [48] [49] [50] [51] [52] [12] [53] [54] [11] [55] [+] [56] [-] [57] [58]

1 GW 1 0 3.6897 2.091 2.709 0.035 8.5247 3.332 1.002 0 3.92 0 0.1136 8.368 0.93001 0.81303 397 341.48 1.162586389 583.8 1.46015 0.5849 0.68 293.31 301 1.026218

2 GW 2 0 3.3369 1.6892 2.58 0.04 7.6461 3.22 0.79 0 3.12 0 0.0512 7.181 3.13543 0.80124 358 308.06 1.162111277 526.5 1.452332 0.58514 0.68 255.122 265 1.038719

3 GW 3 0 13.573 6.1828 9.116 0.07375 28.94555 11.34 0.596 0 3.024 0 0.12 15.08 31.4943 0.80388 1245 1009.74 1.232990671 1729 1.67396 0.58395 0.72 1003.148 1025 1.021783

4 GW 4 0 3.8906 2.4108 2.8896 0.0375 9.2285 3.584 0.986 0 3.28 0 0.1088 7.959 7.38743 0.80625 427 361.66 1.180666925 688.7 1.33997 0.52513 0.62 319.628 324 1.013678

5 GW 5 0 3.6946 2.1238 3.01 0.03 8.8584 3.976 0.5144 0 2.8 0 0.0736 7.364 9.21195 0.75704 435 344.87 1.261344855 630.4 1.405126 0.54704 0.69 295.208 315 1.067044

6 GW 6 0 15.925 7.3308 10.578 0.046 33.8798 13.132 0.8302 0 2.944 0 0.0336 16.94 33.3336 0.80551 1435 1174.93 1.221349357 2142 1.581844 0.54857 0.67 1180.828 1200 1.016236

7 GW 7 0 2.9008 1.1808 2.3306 0.0275 6.4397 2.744 0.7842 0 3.376 0 0.0704 6.975 -3.98754 0.84934 312 270.58 1.153078572 480 1.341604 0.56371 0.65 207.328 216 1.041827

8 GW 8 0 3.6946 2.1156 2.7262 0.0325 8.5689 3.388 0.85 0 3.072 0 0.0896 7.4 7.32254 0.80466 394 335.09 1.175803515 597 1.435399 0.56132 0.66 294.796 304 1.031222

0

DATA VERIFICATION FOR CHECKING THE CORRECTNESS OF WATER ANALYSIS

DATA RECORD:

Lab

Sample

No.

Station Name Date of Collection

Field Determinations General Nutrients Organic Matter Alkalinity Hardness Major Ions Other Inorganics Coliforms

DATA VALIDATION:

Lab

Sample

No.

Station NameDate of

Collection

Cations Anions Anion-Cation Balance Measured TDS & Calculated TDS Measured EC & Ion Sums Calculated TDS & EC Measured TDS & EC

% Difference =

{ [∑(Cation)-∑(Anion)+/

*∑(Cation)+∑(Anion)+} x1000.8<[Na

+/Cl

-]<1.2 1.0<[TDSM/TDSC]<1.2 0.9<*∑(Cation/Anion)x100+/EC<1.1 0.55<[TDSC/EC]<0.9

Acceptnce Criteria Reanalysis For Reanalysis For Reanalysis For Reanalysis For Reanalysis For

Ratio of calculated and

measured hardness

Calculated Hardness/ Measured

Hardness> 1.00.55<[TDSM/EC]<0.9

81

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Annexure-4

82

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Biol.

pH EC DO Temp. Colour Odour pH EC TDS TSS NH3 NO2-

NO3- Total

PO4-- BOD COD

Phen. Alkalinity

Total Alkalinity

Total Hardness

Ca++

HardnessCa

++Mg

++Na

+K

+Cl

- SO4--

CO3--

HCO3- Si F

- BTotal Faecal Chlorop

hyll-A

mS/cm mg/L 0C Hazen mS/cm mg/L mg/L mg N/L mg/L mg/L mg/L mg/L mg/L mg CaCO3/L mg CaCO3/L mg CaCO3/L mg CaCO3/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L

MPN/100 ml

MPN/100 ml

mg/L

[1] [2] [3] [4] [5] [6] [7] [8] [9] [10] [11] [12] [13] [14] [15] [16] [17] [18] [19] [20] [21] [22] [23] [24] [25] [26] [27] [28] [29] [30] [31] [32] [33] [34] [35] [36] [37]

1 SW1 7.5 460 7.5 460 322 11.4 1.9 5.4 21 198.4 63.6 22.6 41.5 1.9 79.4 48.4 197 0.32 SW2 7.2 393.38 7.2 393.4 255.7 8.9 2.1 6.9 26 166.8 57.4 15.4 35.1 2.1 65.7 29.2 166 0.023 SW3 7.7 518.97 7.7 519 301 9.1 1.5 4.4 13 192 61.2 18.4 40.7 1.5 74.3 46.1 194 0.34 SW4 7.1 633.33 7.1 633.3 380 12.6 2.5 5.6 25 256 76.4 24.4 48.7 2.5 92.4 60.1 213 0.35 SW5 7.9 534.78 7.9 534.8 369 11.9 2.3 10.2 56 224 73.1 23.1 47.9 2.3 90.5 59.2 208 0.02

6 SW6 8 453.33 8 453.3 272 7.4 2.4 6.1 23 174 59.4 16.8 36.1 2.4 68.5 38.9 179 0.02

7 SW7 7.9 464.52 7.9 464.5 288 8.8 2.5 5.9 20 182 62.6 18.1 37.9 2.5 72.4 45.9 192 0.02

8 SW8 7.6 431.82 7.6 431.8 285 7.6 1.8 4.4 12 180 60.2 16.5 37.5 1.8 71.8 42.7 181 0.02

0

0

1 7.6 121 0.43 1.1 92 12.6 10.9 9.2 1.3 15.9 10.8 86.3 0.232 7.3 130 1.85 1.2 72.8 13 9.6 5.2 1.1 8.6 18.9 56.7 0.27

0

Ca++

Mg++ Na+ K+ Total

CationsCl- SO4

-- CO3-- HCO3

- NO2- NO3

-

Total

Anions

Measured TDS,

mg/L

Calculated TDS,

mg/L

EC,

mS/cm

mg/L mg/L meq/L meq/L meq/L meq/L meq/L meq/L meq/L meq/L

[1] [2] [3] [39] [40] [41] [42] [43] [44] [45] [46] [47] [48] [49] [50] [51] [52] [12] [53] [54] [11] [55] [+] [56] [-] [57] [58]

1 SW1 0 3.1164 1.8532 1.7845 0.0475 6.8016 2.2232 0.968 0 3.152 0 0.1824 6.526 2.07095 0.80267 322 269.1 1.19658 460 1.478609 0.585 0.7

2 SW2 0 2.8126 1.2628 1.5093 0.0525 5.6372 1.8396 0.584 0 2.656 0 0.1424 5.222 3.82349 0.82045 255.7 213.82 1.19587 393.4 1.433 0.54354 0.65

3 SW3 0 2.9988 1.5088 1.7501 0.0375 6.2952 2.0804 0.922 0 3.104 0 0.1456 6.252 0.3443 0.84123 301 251.6 1.19634 519 1.213029 0.48481 0.58

4 SW4 0 3.7436 2.0008 2.0941 0.0625 7.901 2.5872 1.202 0 3.408 0 0.2016 7.399 3.2824 0.80941 380 317.4 1.19723 633.3 1.247526 0.50116 0.6

5 SW5 0 3.5819 1.8942 2.0597 0.0575 7.5933 2.534 1.184 0 3.328 0 0.1904 7.236 2.40666 0.81283 369 308.02 1.19797 534.8 1.419885 0.57597 0.69

6 SW6 0 2.9106 1.3776 1.5523 0.06 5.9005 1.918 0.778 0 2.864 0 0.1184 5.678 1.91814 0.80933 272 229.52 1.18508 453.3 1.301581 0.50629 0.6

7 SW7 0 3.0674 1.4842 1.6297 0.0625 6.2438 2.0272 0.918 0 3.072 0 0.1408 6.158 0.69184 0.80392 288 248.22 1.16026 464.5 1.344151 0.53436 0.62

8 SW8 0 2.9498 1.353 1.6125 0.045 5.9603 2.0104 0.854 0 2.896 0 0.1216 5.882 0.66119 0.80208 285 238.12 1.19688 431.8 1.38028 0.55144 0.66

0 0 0

0

0.55<[TDSM/EC]<0.9

Acceptnce Criteria Reanalysis For Reanalysis For Reanalysis For Reanalysis For Reanalysis For

Measured TDS & Calculated TDS Measured EC & Ion Sums Calculated TDS & EC Measured TDS & EC

% Difference =

{ [∑(Cation)-∑(Anion)+/

*∑(Cation)+∑(Anion)+} x1000.8<[Na+/Cl-]<1.2 1.0<[TDSM/TDSC]<1.2 0.55<[TDSC/EC]<0.9

Lab

Sample

No.

Station NameDate of

Collection

Cations Anions Anion-Cation Balance

Hardness Major Ions Other Inorganics Coliforms

DATA VALIDATION:

DATA VERIFICATION FOR CHECKING THE CORRECTNESS OF WATER ANALYSIS

DATA RECORD:

Lab Sample

No.Station Name Date of Collection

Field Determinations General Nutrients Organic Matter Alkalinity

83

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Compliance to points raised by EAC (Violation Cases) MoM of 15th EAC meeting held on 27-29th November, 2019

10. The ecological impacts, mitigation and the remediation measures during

construction/operation phase furnished by the PP is found to be inadequate in the

following:

Attached as Annexure-5

84

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Introduction

M/s Shogun Organics Ltd., located at Plot no. D-18, Kurkumbh MIDC, Taluka – Daund, District –

Pune, Maharashtra, India, is a Brown-field project. The proposed expansion project falls under the

schedule 5 (b), category ‘A’ as per the EIA Notification, 2006.

The project has been started in 2008 for the manufacturing of technical and intermediate pesticides

with consent to operate granted by SPCB.

The proposed expansion activity will be held on existing plot, having total area of 1,06,384 sq.m.

Minor modifications would be done in existing structure to make it compatible for expansion activity.

No new plot will be purchased for the expansion activity. The existing production quantity of the

project is 27.95 MT/M which includes the technical product (5.7 MT/M) and intermediate product

(22.25 MT/M). The total production capacity of the unit after expansion, considering the existing

products as well as proposed products viz Technical products = 44.5 MT/M (existing quantity 5.7

MT/M + proposed quantity 38.8 MT/M), Intermediate = 12.25*MT/M (existing quantity 22.25 MT/M

+ proposed quantity 10 MT/M) with proposed formulations quantity of 113.6 MT/M and proposed

byproduct quantity of 13.8 MT/M. Heater Machine which is also a proposed product which would be

25000Nos/M.

(Note: Two existing intermediate Allethlone Alcohol & Prallethrolone Alcohol each of capacity

10MT/M will be stopped)

Project Location

The project is located at Plot no – D-18, MIDC Kurkumbh, Taluka – Kurkumbh, District – Pune. The

area is a notified industrial area by Govt. of Maharashtra.The MIDC has the plot allotted on the name

of Shogun Organics Ltd. for manufacturing of insecticides and formulations.

Nature of Violation -

The industry has obtained consent to establish vide no – BO/U-BHIMA/C-168 dated 03.02.1995 for

the manufacturing of chrysanthemic acid and allethrolone to the quantity of 6 MT/M each. The

industry has been operative since June, 2008 after obtaining consent to operate from Maharashtra

Pollution Control Board for the manufacturing of Technical products, however Environmental

Clearance was not obtained.

85

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Damage Assessment Report –

PHASES ACTIVITIES

Fig 1: Phases of damage assessment

o Scoping o Legal Requirements

o Data Collection to assess the damage caused if any

o Interaction with relevant competent agencies

o Assessment of previous compliances and statutory guidelines with respect to environment

o Reporting the damage. o Assessing the damage o Quantification of the damage o Comparison against the baseline value.

o Establish monitoring & reporting programme for remediation plan.

o Identify the parameters required to be monitored and frequency of the monitoring.

o Define remediation objectives o Suggestive different alternatives for

remediation and select the most appropriate one technically as well as commercially

o Implement the agreed remediation plan

Remediation/EMP Monitoring &

Validation

Damage Assessment Initiation

Remediation Planning/EMP &

Implementation

Damage Reporting

Damage Assessment

86

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Damage Assessment Initiation –

Scoping – Identification of the various operations and processes at the project site and related

activities which could affect the environment. The parameters to be monitored, no. of

monitoring locations are decided on the basis of type of activity and severity of the impact on

the environment.

Legal requirements – Verification of the project activity, operations & compliances with

respects to EIA Notification, 2006, MoEF Notification vide no – S.O 804 (E) dated 14th

March, 2017, The Environmental (Protection) Rules, 1986 and its amendments, other

Notifications, O.M and office orders relevant to the said activity issued by the MoEF & CC

from time to time. Permissions/ limits issued by the MPCB under the consent to operate,

Circulars/Orders issued by CPCB/MPCB from time to time.

Interaction/ Cross verification of reports & notices of relevant stakeholders.

Interactions were held with the Gram Panchayat Members, MIDC Kurkumbh office to

enquire for any violations carried out by M/s Shogun Organics Ltd. particularly by illegal

release of effluents and dumping of hazardous waste.

Visit Reports of Factory Inspector, MPCB officers were checked to investigate any non-

compliance.

Assessments of previous compliances with respect to violation of statutory guidelines

M/s Shogun Organics Ltd. has received directions under section – 5 of the Environment

(Protection) Act, 1986 for violation of provisions of the EIA Notification, 2006 on 18.04.2016

from MoEF & CC dated 05.02.2016. Based on the MoEF letter, MPCB sent a direction of

closure. Industry has been closed since April, 2016. The same has been verified by MPCB visit

reports dated 08.08.2016 and 17.11.2017. The industry has not done any product expansion

production has been done since the first consent to operate was obtained by M/s Shogun

Organics Ltd.

The company has been regularly doing compliances namely submission of water cess,

submission of Form – 4, Form – 10 (Previous – Form – 13) and Form – V and the same have

been submitted to the MPCB.

87

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Damage Assessment –

A. Construction Phase -

The project proponent had obtained consent to establish from the MPCB dated 3rd

February, 1995

vide no – BO/U-BHIMA/C-168 dated 03.02.1995 for the manufacturing of chrysanthemic acid and

allethrolone to the quantity of 6 MT/M each. The investment of the project was less than 1 crore

during the establishment, which do not attract violation of EIA Notification, 1994. The

construction work of plant was started in March 2007 after obtaining water connection from

MIDC, Kurkumbh. but production was not started due to working capital problem. The first

consent to operate was obtained vide no – ROP/E-25/CC/PUNE/5/ dated 13.06.2008. The

construction materials were procured from local vendors from Patas and Varvand villages.

The major activities, ecological damage and mitigation measures are tabulated below –

Table No 1 : Table showing major activities, impacts, and mitigation measures in

construction phase Sr.

No.

Activities Site Specific

Impacts

Damage assessed Mitigation

1 Site

Construction

Air Pollution Based on the emission factor as per AP

42, Fifth Edition, Volume I, Chapter 13:

Miscellaneous Sources, the emission

factor was found to be 1.41 g/s.

Incremental studies were carried out for

understanding the dispersion of dust

during the construction phase. Figure

showing incremental concentration of

SPM (Construction Phase) is given in fig

no: 2 below. Based on the isopletes it

can be seen that the villages of

Kurkumbh and Pandharewdi may be

affected due to the dust emissions as

these villages are located in the

downwind direction. The predicted

incremental concentration of TPM at

Kurkumbh village would be 10 µg/m3

and Pandhare wadi would be 6 µg/m3.

Plantations to be done in the downward

direction of the MIDC in Pandharewadi and

Kurkumbh village.

Site was isolated by barricading the site

along the periphery for breaking the wind.

Health check up to be conducted for locals

of Firangaidevi Nagar.

Ambient air monitoring in Pandharewadi

and Kurkumbh village

2 Site Water Pollution Unethical use of water from a natural Water supplied by MIDC was used for

88

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Construction source, i.e. river, ground water would

cause a stress on the local villagers for

water supply.

Flow of debris from the construction site

in the seasonal water streams will cause

physical changes in water.

construction purpose, after obtaining

relevant permission from the MIDC,

Kurkumbh

Proper storm water drains to be provided,

the storm water to be connected to settling

tank and the overflow will be discharged

further.

3 Site

construction

Soil erosion/Top

soil management

The top surface of the soil is fertile and

needs to be used as a resource.

The top soil to be excavated from the soil to

be used for green belt development.

4 Tree felling /

Site Clearance

Loss of habitat for

flora and fauna,

loss of

biodiversity.

(Ecology and

Biodiversity)

The developed land of Plot no – D-18

allotted by MIDC, Govt. of Maharashtra for

chemical manufacturing activity. It is found

from the older satellite imagery that there

was no vegetation on the said plot area

which had to be cleared. It was evidenced in

the field visits and also by the google earth

imagery that the surround area also is

mostly barren interspersed with patches of

vegetation. The old google images of the

plot and surrounding area is shown in Fig –

5, 6 and 7 respectively.

5 Site

construction

Occupational

health of workers

Construction workers at site in an

unscientific way without use of proper

PPE’s may cause serious effect on the

overall health of the workers

Medical checkups to be organized for the

local villagers in the villages of

Pandharewadi and Kurkumbh village.

Providing PPE’s to the locals who work as

labourers at construction sites.

89

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Fig 2 : Incremental concentration of SPM (Construction Phase)

90

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Damage Assessment in operational phase –

Data Collection – For assessing the damage it was essential to identify the effects of various

pollutants namely stack emissions, process emissions, effluent, hazardous waste, noise on

various components of environment (air, water, soil, ecology & biodiversity, socio

economy.)

Analysis of ambient air, noise ground water, surface water, soil in the 10 km study area was

already done while collecting the baseline data. The findings showed that all the values are

within MPCB limits.

However being an insecticide manufacturing unit it was important to find whether there has

been any releases of effluents/chemicals in the nearby areas.

Thus. the soil samples were collected in the plot area and all 8 soil monitoring locations from

the study area for comprehensive analysis with respect to correlate the parameters with

product and raw materials used by M/s Shogun Organics Ltd was done to ascertain any

effluent releases or hazardous waste disposals in the area. After interacting with the technical

persons of project, site visits and detailed discussions with the FAE’s the EC is of the opinion

that damage assessment can be identified and quantified based on the analysis reports of soil

samples and ground water samples. The results for plot specific soil analysis and soil analysis

in study area are shown below.

Additionally, ground water at 2 locations have been analyzed for presence for raw materials

used and products manufactured by M/s Shogun Organics Ltd. The ground water monitoring

station are shown in the Table-3 below.

91

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

The soil sampling locations have been shown on google earth below

Fig 3 : Location of soil monitoring stations for damage assessment.

Table No 2 . Details of Soil Quality Sampling Stations

Sr.

No.

Sampling Code &

Location

Shogun Organics Ltd. Area/Land

use type Direction Dist. (Km) Lat. & Long.

1. S 9 Project site.

(North side) -- -- 18°24'24.19"N, 74°29'55.64"E Industrial

2. S 10 Project site.

Near ETP --

-- 18°24'19.27"N, 74°29'52.69"E Industrial

3 S 11 Project site.

( Toward east) --

-- 18°24'18.86"N, 74°30'2.69"E Industrial

92

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Fig 4 : Location of Groundwater monitoring stations for damage assessment.

Table No 3 . Details of Groundwater Sample Locations

Sr.

No. Sampling Location & codes

Shogun Organics Ltd. Type of Water

Body/Source Direction Dist. (km) Lat. & Long.

1 GW9 Well in Pandharewadi

village SW 0.69

18°23'59.00"N

74°30'19.50"E Dug well

2 GW10 Well in Pandharewadi

village S 1.01

18°23'43.35"N

74°29'50.31"E Dug well

93

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Table No 4 . Results of Analysis of Soil samples

Sr.

No. Parameters

Location Location

Units At depth of 0.15 m At depth of 0.8 m

S9 S10 S11 S9 S10 S11

1 pH 7.20 7.16 7.44 7.22 7.18 7.49 -

2 Moisture Content 10.84 10.30 11.2 11.78 11.45 11.23 %

3 Organic matter 1.04 1.08 0.98 0.78 0.68 0.59 %

4 Exchangeable Calcium as Ca 60.8 59.4 65.1 61.2 60.2 65.4 mg/kg

5 Color Black Black Black Black Black Black -

6 Soil texture Clay Clay Clay Clay Clay Clay mg/kg

7 Electrical Conductivity 0.84 0.81 0.87 0.86 0.78 0.89 mS/cm

8 Water holding Capacity 74 71 75 77 75 78 %

9 Arsenic as As BDL BDL BDL BDL BDL BDL mg/kg

10 Cadmium as Cd BDL BDL BDL BDL BDL BDL mg/kg

11 Chromium as Cr BDL BDL BDL BDL BDL BDL mg/kg

12 Lead as Pb BDL BDL BDL BDL BDL BDL mg/kg

13 Magnesium as Mg 88.2 86.8 92.4 87.9 86.2 91.8 mg/kg

14 Iron as Fe 1.87 1.82 2.17 1.78 1.80 2.24 mg/kg

15 Potassium as K 96.9 96.8 108.4 96.5 96.7 107.2 mg/kg

16 Total Nitrogen 67.8 66.7 78.2 67.9 67.8 79.2 mg/kg

17 Phosphate as PO4- 14.9 14.9 18.9 13.8 18.2 18.8 mg/kg

18 Cation exchange capacity 16.25 14.25 13.56 15.12 14.10 13.25 meq/100gm

19 SAR 0.07 0.08 0.08 0.06 0.09 0.07 -

20 Toluene <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 mg/kg

21 Prallethrin <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 mg/kg

22 Poly aromatic hydrocarbons (as

PAH)

<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 mg/kg

23 d-trans Allethrin <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 mg/kg

24 d-Allethrin <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 mg/kg

25 Transfluthrin <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 mg/kg

94

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource Augmentation Plan.)

Table no 5 –Analysis of pesticide related soil parameters for soil samples taken during baseline study.

Sr. No Parameters Location

Units S1 S2 S3 S4 S5 S6 S7 S8

1 Toluene <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 mg/kg

2 Prallethrin <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 mg/kg

3 Poly aromatic

hydrocarbons (as PAH)

<0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 mg/kg

4 d-trans Allethrin <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 mg/kg

5 d-Allethrin <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 mg/kg

6 Transfluthrin <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 <0.025 mg/kg

Note: Monitoring & Analysis performed by Sadekar Enviro Engineers Pvt. Ltd, Laboratory

95

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Annexure – 5 (Damage Assessment, Remediation Plan, Natural and Community Resource

Augmentation Plan.)

Table no 6 –Analysis of raw materials and products manufactured by M/s Shogun Organics Ltd in

ground water.

Sr. No Parameters Location

GW 9 GW 10 Units

1 Toluene <0.1 <0.1 mg/l

2 Prallethrin <0.1 <0.1 mg/l 3 Poly aromatic hydrocarbons (as PAH) <0.025 <0.025 mg/l 4 d-trans Allethrin <0.025 <0.025 mg/l 5 d-Allethrin <0.025 <0.025 mg/l 6 Transfluthrin <0.025 <0.025 mg/l

Contamination of soil and ground water for presence of raw materials and products

manufactured by M/s Shogun Organics Ltd.

The parameters considered for pesticide parameters namely raw materials used and products

manufactured by the company, the analysis were done for the same. All the chemicals were

found below the detectable limits.

Comparison of LULC from google imagery pre construction and post construction

phase

As per the oldest available google imagery shown in Fig – 5 and 6, it can be seen that the

land cover is of open scrub type and there is no thick vegetation as such in the area

surrounding the project.

It is evident from the older google imagery dated 20.11.2017 that there was very less

vegetation on the plot which had to be cleared, some shrubs and grass were cleared off the

plot. The latest google imagery is shown in Fig no – 7

The latest google imagery suggests that the project proponent has carried out plantations in

the south direction and there is not much alteration in the tree cover as compared to the

earlier image.

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Figure 5 : Oldest Google Earth Imagery dated 12.11.2007 showing the project boundary

Figure 6 : Google image showing surrounding areas around the project site.

97

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Figure 7 : Latest Google Earth Imagery showing the project location and boundary

B. Operation Phase

There has been no expansion or modification or change in product mix done since obtaining

the first consent to operate in June, 2008 till date. The google earth imagery justifies that there

is no major change in factory area, the same is shown in Fig 5 and Figure – 7 (google images

of 2007 and 2018 respectively.)

The company has applied for expansion to MoEF & CC (violation cases) was identified by

EAC in its 1st meeting held during 30

th November 2015 to 1

st December 2015 and direction

was issued under section – 5 of the Environment Protection Act, 1986 vide F. No – J-

11011/71/2015-IA II (I) dated 05.02.2016. The industry is operating with valid consent to

operate. The industry is being operated as a ZLD unit since its inception till date. The company

has membership with CETP, Kurkumbh. The proposal was again considered in ToR was

approved for the preparation of EIA report and to assist the ecological damage and to prepare

the remediation plan.

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Table 7 : Table showing major activities, impacts, and mitigation measures in operation

phase.

Sr.

No

Activities Damage assessed Mitigation

1 Flue gas emissions,

Process emissions,

Fugitive emissions

and Vehicular

emissions

Incremental studies have

been performed for PM10,

PM2.5, SO2, NOx, CO

have been done.The Air

Pollution, Soil Pollution,

Water Pollution, Impact on

Ecology and Biodiversity

including surrounding

crops.

The isoplethes of incremental

concentration shows that the that the

plume disperses in the north west

direction towards Kurkumbh village,

Pandhare wadi and Firangai devi

nagar area.

However appropriate mitigation

measures have been provided.

Stack of sufficient height is provided

to the boiler, D.G Set to ensure

proper dispersion of pollutants.

Alkali scrubber of capacity 1500

CFM is provided to mitigate process

emissions.

Raw material is stored in closed and

cool area to reduce emissions.

1. The roads within the premises are

paved to avoid the dust generation

from vehicular activity.

2. It will be ensured that all the

transportation vehicles have a valid

PUC (Pollution under Control)

Certificate

2 Indiscriminate release

of effluent from

industrial operations

in water bodies,

ground water and

agricultural fields.

Surface water and ground

pollution by degradation of

water quality thereby

impacting its potential use

for different purposes.

Adverse health effects, due

to contact with polluted

water bodies.

Contamination and

degradation of soil quality,

potential threat of

pollutants entering the food

chain through soil. Bio

accumulation and bio

magnification of pollutants

in animals and humans.

1.It is a ZLD project.

2. Effluent generated from industrial

activities is treated in ETP. The

treated water is reused for cooling

tower make-up.

3.The company does not discharge

any kind of untreated or treated

effluent in the surrounding

environment therefore the soil and

agricultural field contamination

will not be envisaged.

4. Domestic Effluent is treated in

STP. The treated effluent from

STP is reused for gardening.

5. Hence, effect of untreated

effluent on biotic environment is not

envisaged.

3 Indiscriminate

dumping of

hazardous waste in

Surface water and ground

pollution due to

contamination with

1. The hazardous waste is disposed

at CHWTSDF, Ranjangaon.

2. The vehicles carrying hazardous

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water bodies, ground

water and agricultural

fields.

hazardous waste and

degradation of water

quality thereby impacting

its potential use for

different purposes.

Adverse health effects, due

to contact with polluted

water bodies.

Contamination and

degradation of soil quality,

potential threat of

pollutants entering the food

chain through soil. Bio

accumulation and bio

magnification of pollutants

in animals and humans.

waste or chemicals always

assisted with a person trained in

dealing with any kind of

accidental spillage.

3. One spill kit is also provided

along with vehicles to effectively

manage the spillage scenario.

4 Generation of noise

from different

operations and

process within the

plant area.

There are no ecologically

sensitive receptors near the

study area.

There are no habitations in

the nearby area.

The nearest habitation is

Pandharewadi which is at a

distance of 1.4 kms from

the project site.

1. The noise generating machines,

operations are carried out in

enclosed area so that resultant

noise level will be in limits.

2. Noise damping pads, enclosures

are used to reduce the noise. PPEs

are provided to workers working in

surrounding areas.

3. A thick green belt is provided

along the southern boundary of the

plot. A total of 33% of the plot

area will be kept exclusively for

green belt development.

5 Occupational Health The workers are exposed to

various chemicals which

are toxic, flammable or

corrosive in nature. Any

type of physical contact or

inhalation of fumes or

vapors can cause serious

threat to the health of

workers and residents in

the surrounding area.

Exposure to high intensity

of noise by use of

equipments can cause

detritious effects of

workers and local villagers

in the immediate vicinity.

Appropriate PPE’s like ear muffs,

ear plugs, breathing masks to be

provided to workers to the workers

on site and in Panchayat office of

Pandharewadi and Kurkumbh

villages.

The industry is a member of Rotary

club of Kurkumbh which has a

hospital built for workers in

Kurkumbh MIDC and nearby

villagers.

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6 Impacts of release of

air pollutants,

effluents on the local

ecology and

biodiversity.

The industry is located in

notified area developed

exclusively as a chemical

zone. The area is mostly

barren. The land use is

mainly agricultural along

with some scattered

vegetation in the study

area. The nearest protected

area is Mayureshwar Supe

Wildlife sanctuary about

15 kms from the project

site

Fruit bearing native trees to be

planted in the amenity spaces of the

MIDC to attract birds and

butterflies.

Funds will be given to Maharashtra

Forest Department for building of

water holes in the sanctuary.

Development of water holes near the

periphery of Vadane, Kutwalwadi

and Supe villages for herders which

will reduce the conflict and frequent

entry of herders inside the sanctuary

for grazing cattle.

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Fig – 8 Incremental concentration of PM10 in operation phase

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Fig – 9 Incremental concentration of PM2.5 in operation phase

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Fig – 10 Incremental concentration of SO2 in operation phase

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Fig – 11 Incremental concentration of NOx in operation phase

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Fig – 12 Incremental concentration of CO in operation phase

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Remediation Planning/EMP & Implementation

The study of baseline values (air, water, noise, soil, Ecology and biodiversity, socio economy) has

been done and identified and quantified the area of damage from the baseline study report and

interacting with the stakeholders, proponent and inputs received from FAE’s during the site visit.

The impact of operation is more on the industrial land within the factory premises compared to the

surrounding study area. The baseline values of air, water, noise, are well within the norms

prescribed by CPCB. Therefore, impact has been not quantified.

The industry is engaged in the manufacturing in technical grade insecticides and intermediates

which is highly polluting activity, the raw materials used for the manufacturing and the process

involved is hazardous in nature. The insecticides manufactured by the industry are highly toxic to

acquatic organisms. (fish and invertebrates), also if these chemicals come in contact with humans

by means of ingestion or inhalation or contact they can cause harm to humans. The impact of

violation is physically observed on the land of the company near ETP area and production area

where the contact of pollutants are frequently observed during the manufacturing process. The soil

sample analysis near the ETP and within the plant premises has been done to identify the

contamination due to handling of raw material and exposure to production activity. The analysis

reports are summarized in table no – 3

From the analysis reports it is observed that the soil is not contaminated, however during site visit

by FAE’s physically, the area of impact has been identified and quantified to assess the damage

control.

The ETP is located approx.20 meters from the Intermediate Plant – III and IV. The effluent which

is being generated from the manufacturing activity is diverted through closed pipeline up to ETP for

treatment. It is decided that 20 metres (l) x 1 metres (w) x 0.9 metres (d) soil area to be removed

and replaced with fresh soil and concreting the area as a part of damage control remediation plan.

The area quantified and cost of remediation is summarized as below –

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Table 8– Cost of Soil remediation and concretization near ETP.

Sr.

No

Description Quantity

of soil

Action Plan Cost of

excavation

and disposal

Cost of

refilling

of soil

Cost of

concreti

ng.

1 For pipeline

area from

Intermediate

plant III &

IV to ETP.

20 m3 Soil samples have been

collected from a depth of 0.15

m and 0.8 m. There is slight

variation in the texture and

organic content level, other

parameters are coarsely same.

Thus soil up to 0.9 m depth

would be excavated and

disposed through CHWTSDF.

Fresh soil of 0.6 m will be

refilled and 0.3 m concreting

will be done on the top. 20 m3

soil will be excavated and

sent to CHWTSDF.

a. Cost of

excavation

, 2000 Rs

per cu.m x

20

– 40,000/-

b. Cost of

disposal –

5000 Rs

per ton x

32 tonnes

1,60,000/-

Fresh

soil

require

ment

will be

12 m3 =

3000 per

m3 x 12

=

36000/-

Cost of

concreti

ng –

12,000

per m3 x

6 –

72,000/-

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Cost of remediation plan

Sr.

No

Component Measures to be taken Funds

allocated

1 Air Pollution Plantation of 1000 trees in downward direction of MIDC

Kurkumbh before Kurkumbh and Pandharewadi village and its

maintainence for 1 year.

Windbreakers, barricades in the periphery of project site

Health checkups for people in Firangai Devi Nagar

Six monthly Ambient Air Monitoring at Kurkumbh village and

Pandharewadi villages for 3 years (6 locations)

3,75,000/-

50,000/-

2,00,000/-

1,20,000/-

2 Water

Pollution

Construction of settling tank for storm water drains to prevent

flow of debris.

40,000/-

3 Soil Pollution Soil remediation and concretization near ETP area

Segregation of top soil and using for green belt development.

3,08,000/-

30,000/-

4 Occupational

Health

Medical checkups in Kurkumbh and Pandharewadi villages.

Membership of Rotary Club of Kurkumbh for a period of 20

years. Rs 10,000 per annum x 20 years

Providing PPE’s to workers at construction site

2,50,000/-

2,00,000/-

50,000/-

5 Noise

Pollution

PPE’s to be provided at Talati/Panchayat Ofiice of villages of

Pandharewadi and Kurkumbh

70,000/-

6 Ecology and

Biodiversity

Plantation of 600 fruit bearing native trees to be planted in the

amenity spaces of the MIDC to attract birds and butterflies and

maintainence of the same for 1 year

Funds will be given to Maharashtra Forest Department for

building of water holes in the sanctuary.

Development of water holes near the periphery of Vadane,

Kutwalwadi and Supe villages for herders which will reduce

the conflict and frequent entry of herders inside the sanctuary

for grazing cattle.

2,00,000/-

3,00,000/-

Total 21,93,000/-

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Natural Resource & Community Augmentation Plan –

The major natural resources used in an industrial project have been considered.

Sr.

No.

Description Budget

Natural Resource Augmentation Plan

1. Provision of solar street lights in Kurkumbh and Pandharewadi

village

1,00,000/-

2. Maintenance of village roads in nearby villages 80,000/-

3. Restoration of wells in Kurkumbh and Pandharewadi where the

water quality has degraded

1,50,000/-

4.

Community Resource Augmentation Plan

1. Provision of R.O plant in Kurkumbh and Pandharewadi area 90,000/-

2. Health checkup of locals in nearby villages 1,00,000/-

3. Funds to be given in nearby villages for distribution of medicine at

cheaper rates

50,000/-

Table 9– Natural Resource & Community Augmentation Plan

Economic benefit due to violation –

The company has been operational since 2008, and has generated revenue to the

Government by means of taxes, cess etc.

There are 27 workers directly employed by the industry, it has helped to develop the socio

economic status of these employees and their dependents.

Indirect employment by means of transportation, outsourcing of repair and maintenance

related jobs has benefitted the local socio economic environment.

Summary of budgetary allocation with respect to violation

Sr. No. Description Budget in (Rs)

1. Cost for remediation plan 21,93,000/-

2. Natural Resource Augmentation Plan 3,30,000/-

3. Cost for Community Augmentation Plan 2,40,000/-

4. Total 27,63,000/-

Table 10 –budgetary allocation with respect to violation

Implementation schedule of planned activities and related bank guarantee

The above mentioned activities will be implemented by the project proponent. The total bank

guarantee of Rs 27,63,000 will be submitted by the project proponent to MPCB which would be

returned after successful completion of the above mentioned plan.

110