5.1 DETAILS OF MEASURES PROPOSED FOR THE ONLINE … · • Moreover unit proposes to install LUX...

M/s. T. J. Agro Fertilizers Pvt. Ltd. Envirocare Engineers & Consultant, Surat February-2011 CHAPTER 5 ENVIRONMENTAL MONITORING PROGRAM

[5-1]

ENVIRONMENTAL MONITORING

5.1 DETAILS OF MEASURES PROPOSED FOR THE ONLINE MONITORING OF THE POLLUTANTS FROM THE PROCESS STACKS AND ITS MONITORING PLAN.

• Unit will provide handy monitoring instrument to monitor H2SiF6 having alarm

system to identify concentration of H2SiF6

gases.

• Details of the online H2SiF6

Sensor type online detector will be installed on process vent having minimum

traceability value of 0.01 mg/m

detector:

3. As and when HF value reach the limit 25% below

the permissible limits of the mg/m3

prescribed by GPCB alerts will be given

through alarm to minimize or take preventive actions against it to limit it to statutory

norms.

• Routine maintenance & periodical calibration of it will be carried out.

• Unit will also carry out monthly environmental monitoring from third party and will

submit analysis results for the same to R.O. GPCB.

5.2 DETAILS OF PROVISIONS FOR THE WORK AREA AIR QUALITY MONITORING AS PER GUJARAT FACTORIES RULES.

• Unit will carry out indoor work environment monitoring on quarterly basis to check

working condition of our employees. If any abnormalities observed, we will take

corrective actions for the same.

• Moreover unit proposes to install LUX meter for the monitoring of the illumination

level as well Noise Level Meter for monitoring the Noise level within the premises.

5.3 WASTEWATER MANAGEMENT

• T. J. Agro will not generate any wastewater from the process.

• Sewage (domestic wastewater and sanitary waste water)

Domestic wastewater will be generated from domestic requirements. It will be

disposed through soak pits.


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5.4 SOLID WASTE MANAGEMENT

5.4.1 Details of Solid Waste Generated

With respect to the mfg. process to be carryout, Unit process & operation to be involved

from the proposed Project, there will be a Solid Waste to be generated. The source of the

waste generation will be from the process. The solid waste generated during the

manufacturing of each product for the each batch is summarized below in Table 5.1.

Quantity of Hazardous and Solid wastes disposed by various methods is shown in Table.

5.1(A&B)


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TABLE 5.1 (A) TOTAL SOLID WASTE GENERATION

Sr. No. Waste Stream Waste Cat. No.

As per- 2008

Qty. Total

Qty. Produce Source Existing

Proposed

1. Used oil

5.1 150 lit/year 50 lit/year 200 lit/year Air Compressor

2. Discarded containers/barrels/

Liner

33.3 60 Kg/Month 240 Kg/Month 300 Kg/Month Raw material & Finished product packing material

3. Silica/Sand -- Nil 10 Kg/month 10 Kg/month Process


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TABLE 5.1 (B) DETAILS OF HAZARDOUS WASTE MANAGEMENT

Sr. No

Waste Stream

Waste Cat. No. As per-

2008

Total Qty.

Produce

Total Qty.

Recycled/ Reused

Total Qty.

Disposed

Method of packing

Method of recycling /Reuse Disposal Method

1. Used oil

5.1 200 lit/year

100 lit/year

100 lit/year

PP Carba / Drum

Lubrication in machineries & Lift

Collection, Storage, Transportation and disposal by selling to registered refiners enlisted by GPCB /MoEF.

2. Discarded containers/

barrels/Liner

33.3 300 Kg/Month

150 Kg/Month

150 Kg/Month

PP Bag

Good quality packing material will be reused in finished product packing - Teared liners will be stitched & reused for packing.

Collection, Storage, Transportation and disposal by selling to registered refiners enlisted by GPCB /MoEF.

3. Silica/Sand -- 10 Kg/month

10 Kg/month

--- PP Bag

Collection, storage & Reuse as filler in product

--


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• Following steps shall be adopted during handling of hazardous chemicals.

o For powder material, the material allowed in a vessel through closed loop.

o Transportation from raw material storage to process plant shall be carried out

by trolly.

o Each activity shall be improved/done in such a way that minimum risk of gas

exposure to be occurred.

• The unit has provided scientifically designed H.W.S.A. having impervious layer .We

will store each type of hazardous waste separately in this storage area. The capacity

of our storage area is 15 M

5.4.2 Methodology of De-Contamination and Disposal of Discarded Containers and Its

Record Keeping.

3

• The unit will send back maximum quantity of drums / carboys to its actual supplier.


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5.5 SUMMARY OF THE ENVIRONMENTAL MONITORING PROGRAM

Environmental Monitoring program shall be as mentioned in Table 5.2

Table 5.2: Environment Monitoring Plan

Sr. No. Activity Schedule

Air Pollution Monitoring 1. Ambient air monitoring of parameters specified

by GPCB in their air consents from time to time within the T. J. Agro Fertilizers Pvt. Ltd. premises

Once every Quarter

2. Ambient air monitoring of parameters specified by GPCB in their air consents from time to time at four stations outside T. J. Agro Fertilizers Pvt. Ltd. premises

Once every season at each station

Flue Gas Emission Monitoring 3. Stack monitoring of prescribed parameters as

given in air consent from time to time Once every month

Ground Water Monitoring 4. Sampling & Analysis of the ground water of bore

well within premises will be done. Once in Six months

Solid Waste Generation Monitoring / Record Keeping

5. Records of generation of used liner, bags and records of their dispatch to suppliers for refilling

Daily To be comply as per Haz. Waste [MPH] rules, 2003

6. Records of generation of waste oils and their treatment

Daily

7. Records of generation, handling, storage, transportation and disposal of other solid, aqueous and organic hazardous wastes as required by hazardous waste authorization

To be updated daily

Environmental Audit & Annual return

8. Environmental statement under the EP (Act) 1986 & annual return of hazardous waste generation, handling & disposal.

Once in a year

M/s. T. J. Agro Fertilizers Pvt. Ltd. Envirocare Engineers & Consultant, Surat February-2011 CHAPTER 6 ADDITIONAL STUDIES

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SAFETY & RISK ANALYSIS

6.1 OBJECTIVES An emergency is considered to be a situation of process deviation that may lead to or

actually leads to a major accident/disaster with potential short term and/or long term risk

and damage consequences to life and property in and/or around the factory.

A Disaster is a catastrophic consequence of a major emergency/accident that leads to, not

only extensive damage to life and property but also disrupts all normal human activity for a

pretty long time and requires a major national and international effort for rescue and

rehabilitation of those affected.

Since the occurrence of a disaster is very remote for this project, the report focuses on

emergency situations and discusses the contents of an Emergency Plan (EP).

EP is a guide, giving general considerations, directions and procedures for handling

emergencies likely to arise from deviations to planned operations.

6.2 EMERGENCY PLAN: STRUCTURE The EP is supposed to be a dynamic, changing, document focusing on continual

improvement of emergency response planning and arrangements. A structure working on a

Plan, Do, Check & Review (PDCR) cycle has been therefore suggested. Another advantage

of doing this is to have a system that is in synchronicity with commonly used EHS systems

such as ISO 14001 and OHSAS 18000.

6.3 POLICY M/s. T. J. Agro Fertilizers Pvt. Ltd. will have Environment, Health and Safety Policies

which guides the Emergency Response Plan. These policies will be made accessible to all

at site. The policies have been framed considering legislative compliance, stakeholder

involvement, continual improvement, and management by objectives.


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6.4 PLANNING

6.4.1 Event Classification and Modes of Failure Hazards that can lead to accidents in operations are discussed in this section. Important

hazardous events are classified in below Table 6.1.

Table 6.1: Event Classification

Type of Event Explanation

Spill Release ‘Loss of containment’. Release of fluid or gas to the surroundings from unit’s own equipment / tanks causing (potential) pollution and / or risk of explosion and / or fire

Structural Damage Breakage or fatigue failures (mostly failures caused by weather but not necessarily) of structural support and direct structural failures

6.4.2 Methodology of Risk Assessment

The scope of work has been framed as per standard requirements for risk and safety studies and includes the following:

• General description of project. Level 1: Hazard Identification

• Study of operational information, including safety concepts used in design of plant, equipment and storages

• Listing of key plant equipment • Listing of hazardous inventory and identification of key hazardous substances to be

used. • Identification of Maximum Credible Loss Scenarios (MCLS) using standard

techniques. Level 2: Hazard Assessment • Estimate loss quantities for given scenarios and conditions. • Analysis and quantification of primary effects (consequences) of identified MCLS, in terms of distances to toxic endpoint. • Analysis and quantification of secondary effects (damages) of identified MCLS in terms of fatalities, injuries and property damage. • Estimation of probability of occurrence of MCLS’ based on standard techniques for the purpose.

Level 3: Development of DMP • Development of DMP report based using standard procedures for the purpose.


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Level 4: Recommendations • Recommendations to reduce the probability or consequence of hazards studied and for

implementation of the DMP. These are given on the basis of the study findings and professional judgment.

6.4.3 Study Methodology The methodology of the study for development conforms to national and international

rules, regulations, standards, guidelines and codes of practices. It involves the following:

• Identification of hazardous material

• MCLS Development

• Development of yardsticks

• Incorporation of results in development of DMP reports

6.4.4 Identification of Possible Emergency Situations Broadly, two situations can arise:

• Emergency situations involving loss of containment of hazardous materials. For the

proposed facility, the following containment loss scenarios may be envisaged:

• Loss of Extremely toxic like Sulphuric Acid & Fluorosilisilic Acid due to catastrophic

rupture of M. S. tank & HDPE tank – an incredible event.

Consequence analysis of all the above mentioned containment loss scenarios has been

discussed as below.

Emergency situations not involving loss of containment are generally more likely to occur

and the following are possible:

• Falls due to working at heights (during construction/repair and maintenance).

• Electric shock caused by contact with faulty electrical equipment, cables, etc.

• Chronic health issues related to inhalation or ingestion of dust.

• Falls on floors made slippery by aqueous solutions.

• Burns by splashes of liquids, by steam or hot vapors, by contact with hot surfaces.

• Exposure to adverse environmental factors (for e.g. high temperature).

With respect to emergencies situations not involving loss of containment, general

recommendations are given at the end of the chapter.


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6.4.5 Consequence Assessment Toxic substances released from sources of storage as a result of failures or catastrophes,

can cause losses in the surrounding area in the form of:

• Toxic release.

Toxic releases are caused due to leakage and dispersion of toxic chemicals in air & on soil. Consequences of toxic release are influenced by wind speed, weather condition, leak rate or mass released at particular place.

Consequences of Toxic Release

6.5 CONSEQUENCES OF CONTAINMENT FAILURE AND RELEASE OF MATERIAL INTO ENVIRONMENT

6.5.1 Release of Sulphuric Acid (98%) & Fluorosilisilic Acid into Environment

It is expected that M/s. T. J. Agro Fertilizers Pvt. Ltd. will store sulphuric acid in M.S.

rubber lined storage tanks.

The consequence scenarios considered are loss of Sulphuric acid due to leakage in bottom

valve of storage tank or corrosion of tank, which is an extremely unlikely event.

The consequence scenarios considered for loss of Fluorosilisilic acid in the atmosphere due

to break down of Ventury water scrubber, which is an extremely unlikely event.

In case of leakage in bottom valve (Diameter: 50 mm) of storage tank, Flow rate of

Sulphuric Acid will be 5 Liter/minute.


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6.6 INDIVIDUAL RISK ANALYSIS 6.6.1 Introduction The results of the QRA study can be utilized in the effective management of the risks

presented by the facilities to the employees and the surrounding community. In evaluating

these risks to the offsite population, it is important to address the question of whether the

risks are serious enough to warrant concern. Awareness of the approaches by the regulatory

authorities throughout the world has taken to address the issue of risk acceptability as a

useful guide.

HSE (UK) Industrial Criteria

HSE Industrial Criteria

The risk criteria used by the UK Health and Safety Executive (HSE), 1992 was originally

published in 1987 for nuclear power stations, but the 1992 revision of the document

indicates that they should apply to any large industrial plant in any industry.

Individual risk criteria are:

Maximum tolerable risk for workers: 10-3

Maximum tolerable risk for public: 10

per year -4

Broadly acceptable risk: 10

per year -6

per year

INTOLERABLE

TOLERABLE IF ALARP

BROADLY ACCEPTABLE

1 x 10-4 per year

1 x 10-6 per year


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To the region between the maximum tolerable and broadly acceptable levels, the ALARP

(As Low As Reasonably Practicable) principle is applied, taking into account of the costs

and benefits of any risk reduction. For the risk levels within ALARP region, it is necessary

to consider further reduction of risk level through review of the following:

a) Selection of the best available technology, design and construction

b) Changes to operating philosophy

c) Additional safety features and protection devices

d) Improved maintenance, inspection and testing schedules.

The HSE appears not to use societal risk criteria, since no upper envelope of acceptable

societal risk emerged from several cases in which QRA was used in a decision making

process.

6.6.2 Acceptability Criteria for Risks in India Acceptability criteria for risks due to industrial activities have not been defined by

regulatory authorities in India. At present acceptability criteria, ALARP, prescribed by

Health and Safety Executive (HSE), U.K.

6.6.3 Assumptions for Fatality Risk Calculations

Since, no pool fire to be occurred, thus it is not required.

6.6.4 Probability of Exposure

No exposure expected to be analyzed.

6.6.5 Vulnerability Analysis

A Vulnerability Analysis gives quantitative estimates of the people, property and

environment in the vicinity of the proposed activity that are vulnerable due to the proposed

activity. It follows the risk and consequence assessment.

Based on the proposed activity and results of the consequence analysis for the modeled

scenarios, vulnerable receptors would include the following:

The summary of the vulnerability analysis is provided in below Table 6.2.


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Table 6.2: Vulnerability Analysis

Vulnerable Area Maximum Impact

Distance (mtr) from leakage area

Number of People covered

under area

Occurrence (Frequency)

Sulphuric Acid Storage Area

4 2 Once in three years

6 Nil

Process Vent (H2SiF6

40 ) 07 Once in three years

6.6.6 Safety Measures to be adopted

The following safety measures will be observed at the site:

• All storage tanks will be made out of Boiler quality plates.

• All storage tanks will be stress relieved after fabrication.

• All storage tanks should be hydraulically tested for 72 hours duration and leakage

checked.

• All storage tanks will be kept at separate place having acid proof lining work with high end level to collect spillage acid & no acid over flow on open land.

• All pipelines will be Corrosion resistant having minimum joint and adequate supported.

• All pipeline joints will be stress relieved.

• Regular checking of leakage should be done.

• Regular training will be provided to operators for safe plant operations & emergency shutdown procedures.

• Scheduled regular monitoring of storage tank & pipeline thickness measurements will be done using Ultrasonic thickness measuring instruments.

• Annual inspections of storage tanks will be done.

• Mock drills for handling emergency will be conducted.


[6-8]

6.7 DETAILS OF HAZARDOUS CHARACTERISTICS AND TOXICITY OF RAW MATERIALS AND PRODUCTS

Details of hazardous and toxicity of raw materials and products to be handled and their control measures proposed are as summarized in the Table 6.3.

TABLES 6.3 Details of Hazardous and Toxicity of Raw Materials and Products

Type of Activity Risk Involved Mitigation Measures

Raw Material Storage & Handling

1: Urea • May cause allergic reactions

• Harmful on inhalation

• Causes Eye irritation

• Causes Skin irritation

• Wear appropriate Protective clothing to prevent contact with skin & Eyes

• Wear Dust mask

• Adequate ventilation

• Use PPE’S

2: DAP

3: MOP (potash)

4: Rock Phosphate

5: Filler

6: SSP

7: Fluorosilisilic Acid • Spillages / Leakages

• Harmful on inhalation

• Causes Eye irritation

• Causes Skin irritation

• Stored in closed shed

• For small fire, use dry powder, Carbon Dioxide, Water Spray

• Do not inject

• Wear Safety glasses

• Wear Cotton or Rubber gloves

• Proper collection system will be provided for the leakage & spillage of acids by preparing dyke wall & acid proof RCC flooring with spillage collection tank

8: Diluted Sulphuric Acid (70%) 9: Conc. Sulphuric Acid (98%)


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Product Storage & Handling

1: Single super phosphate powder • May cause mild eye irritation

• May cause skin irritation

• Harmful if swallowed

• Skin contact may cause dermatitis

• Stored in well ventilated dry place

• Flush eyes/ Skins with plenty of water for at least 15 minutes

• Remove from exposure and move to fresh

air immediately • Use proper PPE’s while handling & wash

hand properly after handling • Use water spray, dry chemical, carbon

dioxide, or chemical foam. • Vacuum or sweep up material and place

into a suitable disposal container. • Do not breathe dust, vapor, mist or gas

2: Single super phosphate granulated

3: NPK mixed Fertilizer

4: Filler (By product)

5: Magnesium Sulphate

6: Fluorosilisilic Acid (By product)


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6.8 DETAILS OF POSSIBILITIES OF OCCUPATIONAL HEALTH HAZARDS

Details of occupational health hazards from the proposed manufacturing activities are summarized below in Table 6.4.

Table 6.4 Details of Occupational Health Hazards

Type of Activity Risk Involved Mitigation Measures

During Production

• Handling Operation for Transfer, Charging of Raw Materials, and Final Product Spillages/leakages

• Inhalation during Top cap remove

• Due to tearing of conveyor belt

• Suffocation due to grinding & acidification

• Regular checking of dosing tank level

• Regular inspection & maintenance of all process equipment

• Proper collection system will be provided for the leakage & spillage collection of acids by preparing dyke wall & acid proof RCC flooring with spillage collection tank

• The Management should Ensure Proper usage of PPE’s

• Use Dust Mask near grinding area

• Process area should be proper RCC flooring

• Adequate ventilation should be provided at top of roof

During Packing • Spillages / Leakages

• Inhalation

• Ensure good quality packing material.

• Use Dust mask

• Proper PPE’s & Apparel shall be provided to the work force.

• Packing area should be well ventilated & illumination should be kept high

• Store product in original containers & clearly labeled


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During Handling, Loading & Unloading of Product & Raw Material

• Spillages/ Leakages occurred

• Top cap removed & cause inhalation problem

• Skin irritation

• Proper collection system will be provided for the leakage & spillage of acids by preparing dyke wall & acid proof RCC flooring with spillage collection tank

• Buffer solution shall be used for highly acidic material which will immediately create suffocation problem

• Loading & Unloading equipments should be inspected & maintained regularly

• The cargo tank motor vehicles as well as their attachments including the hose pipes used for loading and unloading the acid should be inspected

• Conduct external and internal visual inspections, leakage and

pressure tests • Adequate PPE’s shall be provided to all employee

• Work job training should be given to employee

• Adequate ventilator shall be provided on top of roof • All the MSDS of raw materials & products should be available &

work force should aware of its nature


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During operation of Utility

• Bag Filter & Multi Cyclone Separator

• Working at height

• Dustness at bottom

• Burning of Bags

• Safety belt should be provided to those working at height

• Safety guards shall be provided at bottom of rotary valve

• Use dust mask

• Routine inspection of Bags

• Adequate ventilation should be provided at top of roof

• Check pressure difference of bag filter

• Proper insulation shall be carried out

• Air compressor

• Human injuries in belt

• Safety guards should be provided

• Regular removal of tank oil & keep as a used oil in HWSA

• Pressure tank should be regularly checked

• Scrubber

• Human injuries due to spillages

• Regular inspection & maintenance of all scrubber pipelines & its joints

• Regular inspection & maintenance of scrubber & vent supports


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6.9 PLANS FOR PERIODIC MEDICAL CHECKUP

• Monthly local doctors will be hired to check health of each employee. • Records will be maintained in prescribed format as per Gujarat Factory Act Rules.

6.10 DETAIL MSDS OF THE IMPORTANT HAZARDOUS RAW MATERIAL & PRODUCT:


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M/s. T. J. Agro Fertilizers Pvt. Ltd. Envirocare Engineers & Consultant, Surat February-2011

CHAPTER 7 PROJECT BENEFITS

[7-1]

7.1 GREEN BELT DEVELOPMENT

7.1.1 General Principles in Greenbelt Design

Plants grown in such a way so as to function as pollutant sinks are collectively referred as

greenbelts. These plants should also provide an aesthetic backdrop for persons using the site and

for the surrounding community.

7.1.2 General principles in greenbelt design considered for this study are:

• Type of pollution (air, noise, water and land pollution) likely from the activities at the site

• Semi arid to dry sub humid and sub-zone where the greenbelt is located (and hence the

plant species which can be planted in the area).

• Water quantity and quality available in the area

• Soil quality in the area

• Greenbelt is designed to minimize the predicted levels of the possible air and noise pollutants. While designing the scheme the following facilities are considered:

• Site perimeter and approach road

• Along the internal roads

7.1.3 Types & Numbers of Trees to Be Planted:

It is presumed that the selected plants will be grown as per normal horticultural practice and the

authorities responsible for the plantation will make adequate provisions for water and protection

of the saplings. A budgetary cost estimate is also prepared for greenbelt development.

The total area over which the industries is located is 30,831 square meter. The existing

gardening area is approximately about 750 square meters and proposed gardening area will

be about 2969.00 square meters.

M/s. T. J. Agro Fertilizers Pvt. Ltd. Envirocare Engineers & Consultant, Surat February-2011 CHAPTER 7 PROJECT BENEFITS

[7-2]

TABLE 7.1 TYPES & NUMBERS OF TREES TO BE PLANTED:

Sr. No. Tree Species Existing Proposed Total

1. Neem 02 12 14

2. Asopalav 08 40 48

Layout of the greenbelt has been shown in plot layout attached as FIGURE 1.1

To ensure a permanent green shield around the periphery planting is recommended in two

phases.

• In the first phase one row of evergreen and fast growing trees (which grows up to 10-15 m)

with maturity period of around three years shall be planted at 3.0 meter interval along with

fast growing ground covers to enhance the water holding capacity, improve the organic

content and check the soil erosion.

• In the second phase after eighteen months, second row of trees with large leaf surface area

with large ever green canopy and longer life span shall be planted at 6.0 meters intervals.

• A green belt has been proposed within the premises. Thus, the proposed project will have

significant positive impact on the floristic component.

• The development of proposed green belt will provide habitat, food and breeding areas to

birds, small animals and insects. Thus a positive impact is envisaged on this count.

7.2 Expenditure on Green Belt Development

• The project proponent will incur about Rs.1.5 lacs for the green belt development in and

around units project site.

• We hereby committed that we will born any expenses to be occur in future for green belt

development with our areas by society/association.

M/s. T. J. Agro Fertilizers Pvt. Ltd. Envirocare Engineers & Consultant, Surat February-2011 CHAPTER 7 PROJECT BENEFITS

[7-3]

7.3 Socio-Economic Benefits

With respect to the Socio Economics this project will result into employment for workers as well

as the staff. Moreover it will result into the improvement in the economy of the local vendors.

About 20 direct jobs and 12 jobs to contracted workers are envisaged. Further, jobs will be

created indirectly. Thus a significant benefit to the socio-economic environment is likely to be

created.

Thus a significant benefit to the socio-economic environment is likely to be created.

• Local people will be employed as much as possible depending on the capabilities & job

requirements.

• 1 computer will be donated to the nearby local school.

• 1 Rain water recharge structure will be constructed in nearby Village.

• Yearly Medical checkup camp will be conducted in nearby Village.


CHAPTER 8 ENVIRONMENTAL MANAGEMENT PLAN

[8-1]

=

8.1 ENVIRONMENTAL MANAGEMENT PLAN

8.1.1 Introduction

The Environment Management Plan (EMP) is required to ensure sustainable development in

the area of the proposed project. Hence it needs to be an all encompass plan for which the

industry, Government, Regulating agencies like Pollution Control Board working in the

region and more importantly the population of the area need to extend their co-operation and

contribution.

It has been evaluated that the project area will not be affected significantly with proposed

project. Mitigation measures at the source level and an overall Management Plan at the site

level are elicited so as to improve the surrounding environment.

The following mitigation measures are recommended in order to synchronize the economic

development of the project area with the environmental protection of the region. The

construction phase impacts are mostly short term, restricted to the plot area and not

envisaged on the larger scale. In the operational phase the environmental impacts are due to

continuous operation of the project, hence, the emphasis in the Environment Management

Plan (EMP) is to minimize such impacts. The emphasis on the EMP development is on the

following:

• Mitigation measures for each of the activities causing the environmental impact

• Monitoring plans for checking activities and environmental parameters and monitoring responsibilities

• Role responsibilities and resource allocation for monitoring

Following sections describes the environment management plan proposed for construction

and operation phases.

8.1.2 Details of Hazardous Processes & Their Engineering Controls and Details of Alarm Provision with Interlocking DCS System To Control Run Away Reaction:

The unit will adopt following engineering practices during unfavorable process condition

• Each vessel should be equipped with temperature indicator with its sensor, pressure

indicator, pressure relief valve and rupture disc. If any abnormality will occur, than

temperature & pressure sensor will alarm for immediate attention of Incharge, who will

immediately stop steam supply to the vessel to control runaway reaction.

M/s. T. J. Agro Fertilizers Pvt. Ltd. Envirocare Engineers & Consultant, Surat February-2011 CHAPTER 8 ENVIRONMENTAL MANAGEMENT PLAN

[8-2]

8.1.3 Plans for Management and Disposal of Waste Streams To Be Generated From Spillage, Leakages Etc.

• If any spillages/ leakages occurred than the said material will be collected in such a way

that maximum quantity can be recycled/ reuse and minimum quantity can be disposed for

incineration/ TSDF site.

Note: During above activity, the workers to be engaged after wearing adequate PPE’S & another, kept as a stand by having flame proof material / extinguishers & water sprayer.

8.2 ENVIRONMENT MANAGEMENT CELL

An environment management cell is already created to manage all environmental issues. The

Manager (Operations) will be responsible for environmental issues at plant.

STRENTHENING OF HSE:

For strengthening of HSE following steps will be taken:

• To develop a logbook history of work related accident.

• To conduct a mock drill through another agency once in a year.

• To invite expert to evaluate the policy of HSE and implement it periodically.

• To carry out safety audit once in a year.

The responsibilities of the various members of the environment management cell are given in Table 8.1 as follows:

TABLE – 8.1 ENVIRONMENT MANAGEMENT CELL

Sr. No. Designation Proposed Responsibility

1. Executive Director • Environmental policy and directions

2. Manager (Operations)

• Overall responsibility for environmental management and decision making for all environmental issues

• Ensuring legal compliance by properly undertaking activities as laid down by various regulatory agencies from time to time and interacting with the same

3. Asst.Manager (Utilities) • Secondary responsibility for environmental

management and decision making for all environmental issues

4. Safety Manager

• Conduct mock drill once in a month. • To keep records related to safety/accident. • To aware employees working in manufacturing &

Utility department about the risk involved and precautions to be taken to avoid accidents


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• To identify safety aspects in how to do & what to do manner.

• To identify possibility of risk involved in each activity, prepare plan to mitigate it and take a step to avoid its repetation.

5. Plant Incharge

• Ensure environmental monitoring as per appropriate procedures

• Ensures scrubber efficiency for effective control of emissions

• Ensure correct records of generation, handling, storage, transportation and disposal of solid hazardous wastes.

8.3 FOLLOWING MEASURES WILL BE TAKEN TO CONSERVE WATER

• Use of double nose flushing • Unit will keep a provision to install aerated coke in washbasin, low flush water closet

in toilet and pressure reducing valve in water line. • Rain water harvesting system will be adopted.

The ground water used by the unit will be mitigated through adopting the rain water harvesting technology.

8.3.1 Unit Will Provide Rain Water Harvesting System As Under:

• The net plot area is 30,831 m2

TABLE 8.2 DETAILS OF RAINWATER HARVESTING PITS

. The site will be divided into 08 pockets varying from 4000 square meters depending upon site layout. The details of the rain water harvesting pits are as mentioned in Table 8.

Number of pits 08 Nos.

Size pf pits 4 m x 3 m x 3 m

Size of Bore 350 mm dia

Size of pipe 150 mm dia

• Annual rainfall of the city was observed to be 922.7 mm. • Rainwater recharge calculation using Rational Formula is as under

Rain Water Harvested = Area in m2

• Each pocket will have independent harvesting well. A de-silting chamber and Oil & Grease removal trap will be provided to de-silt and remove floating material through bar screen. The details of the maximum storm water generated are as shown in Table 8.3.

× rainfall (mm/yr) ×run off coefficient.


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TABLE- 8.3 DETAILS OF MAXIMUM STORM WATER GENERATED:

Description Area in m Annual Rainfall in mm

2 Runoff coefficient

Total storm water in l/yr

Roof area 6368.63 922.7 0.8 47,01,067.92 Green & Open area 23142.69 922.7 0.3 64,06,128.01

Paved area 1319.68 922.7 0.6 7,30,601.24 Total 30831 1,18,37,797.17

Depth of bore pipe will kept 5 meter above than U/G water level.

FIGURE 8.1 RAIN WATER HARVESTING PIT


[8-5]

8.4 WASTE MANAGEMENT

Looking to our product profile, we have think possibilities of recycling/ reuse wastes as

under.

Air: H2SiF6

8.5 EXPENDITURE ON ENVIRONMENTAL MATTERS

gas generated from SSP powder process will be totally scrubbed in water scrubber and recovered as a by-product.

Solid Waste: Solid waste (Silica/Sand) generated will be reused after sun drying as a filler in the process.

The following Table 8.4 gives the expenditure incurred by T. J. Agro Fertilizers Pvt. Ltd. on

environmental matters.

TABLE – 8.4 EXPENDITURE ON ENVIRONMENTAL MATTERS

Sr. No. Topic

Approximate recurring cost per

annum (Rs. In Lacs)

Approximate Capital cost (Rs. in Lacs)

1. Noise pollution control 0.1 2.0

2. Air Pollution Control 2.5 17.0

3. Water Pollution Control -- 0.5

4. Solid and hazardous waste management

0.5 1.0

5. Environment monitoring and management

0.9 0.75

6. Occupational health 0.25 0.25

7. Green belt 0.5 1.5

Total 4.75 23.0


[8-6]

8.6 DISASTER MANAGEMENT PLAN

The Disaster Management Plan (DMP) is a guide, giving general considerations, directions

and procedures for handling emergencies likely to arise from planned operations. Site

specific documentation contingent to – and demonstrating suitable implementation of the

DMP is described in the annexure to the DMP. The annexure, being site specific, will require

to be updated once the actual site operations are underway.

The DMP must also be revaluated prior to start of operations and it is the responsibility of the

Plant Manager to do this. The DMP has been prepared for M/s T. J. AGRO FERTILIZER

Pvt Ltd on the basis of the consequence assessment and related findings covered in the earlier

chapter of this report.

8.6.1 Disaster Management Plan: Structure

The DMP is supposed to be a dynamic, changing, document focusing on continual

improvement of emergency response planning and arrangements. A structure working on a

Plan, Do, Check & Review (PDCR) cycle has been therefore suggested. Another advantage

of doing this is to have a system that is in synchronicity with commonly used EHS systems

such as ISO 14001 and OHSAS 18000.

The DMP is covered in further detail in the remaining sections of this Chapter.

8.6.2 Policy

The Environment, Health and Safety (EHS) policies are to be made accessible to all at site

and to other stakeholders. The policies must be framed considering legislative compliance,

stakeholder involvement, continual improvement, and management by objectives.

8.6.3 Planning

8.6.3.1 Identification and Prevention of Possible Emergency Situations

Identification of Emergencies

Possible emergency situations can broadly be classified into toxic release, fire or explosion.

While doing so, it is stressed that these results are only for the modeled scenarios and, that

the distances as well as damages can change depending upon the actual development of a

scenario. Additional emergency situations can be developed on the basis of audit / HAZOP

or other procedures prior to commencement of operations.


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Emergency Prevention

Some of the ways of preventing emergencies are as follows:

• Preparation of a Preventive Maintenance Schedule Programme based on

recommendations given and also covering maintenance schedules for all critical

equipments and instruments as per recommendations of the manufacturers user manuals,

• Establishment of a Non Destructive Testing (NDT) system as necessary. This may not be

feasible in-house but there are specialized organizations who undertake the work, and the

same may be used.

• Importantly, it is of great importance to collect and analyze information pertaining to

minor incidents and accidents at the site, as well as for recording near-misses or

emergencies that were averted. This information gives an indication of how likely or

unlikely it is for the site to face actual emergencies and what should be further done to

prevent them from occurring.

• Establishment of an ongoing training and evaluation Programme, incorporating the

development of capabilities amongst employees about potential emergencies and ways

and means of identifying and averting the same. Most emergencies do not occur without

some incident or an abnormal situation. So there is always some time of few seconds to

few minutes to arrest an incident of abnormal situation from turning in to an emergency.

This is the role of the shift in-charge who is the incident controller (IC) along with his

shift team.

8.6.3.2 Identification and Compliance with Legislative Requirements

The following EHS regulatory requirements are applicable to the activities being planned,

and the checklist given in below Table No:8.5 may be taken into consideration prior to

actual commencement of operations. This checklist requires to be reviewed at quarterly

intervals.



[8-8]

Table 8.5: Applicable EHS regulatory requirements – M/s T. J. Agro Fertilizers Pvt. Ltd.

Sr. No.

Applicable Legislation / Rule / Permit Requirement Action Required / Timing of Action

1. Amendment in Consent to Establish/ NOC from the GPCB

A general permit to establish facilities for adds new product or equipments of plant operations.

NOC to be applied for along with the completed EIA report

2. Authorization to generate, transport and dispose hazardous wastes from the GPCB

Permit to generate and dispose hazardous wastes Application to be filed with the GPCB once the NOC is obtained

3. The Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989 (as

amended till date)

Listing of hazardous materials; thresholds against which Safety Audit and Safety Report has to be

maintained; Requirements of disclosure of information; Availability of MSDS’;

If required, safety audit and safety report to be prepared.

4. The Public Liability Act, 1991 (PLI) Insurance to be taken out Check whether M/s T. J. Agro Fertilizers Pvt. Ltd. insurance under PLI covers the

project under consideration

5. Chemical Accidents (Emergency Planning, Preparedness and Response) Rules, 1996

Preparation of Local/District Level Crisis groups, for management of offsite emergencies.

Identify whether Local or District Level Crisis Groups exist at site and take

proactive part in preparing Offsite DMP.

6. Factory License from the DISH (Department of Industrial Safety Health)

A basic safety license to run the Factory Application prior to construction



[8-9]

8.6.3.3 Identification of, and Communication with, Relevant Stakeholders

This includes identifying, communicating and developing working relations with relevant

offsite agencies that have an interest (either due to regulatory requirements or otherwise) in the

continued safe operations of the site. Identified Stakeholders are as follows:

On the basis of the Chemical Accidents (Emergency Planning, Preparedness and Response)

Rules, 1996, (referred to as The Chemical Accidents Rules), the following persons may be

considered as relevant stakeholders with regards to the maintenance of M/s T. J. AGRO

FERTILIZERS Pvt Ltd. emergency response at the district level:

• District Collector

• Inspector of Factories

• District Energy Officer

• Chief Fire Officer

• District Information Officer

• Controller of Explosives

• Chief, Civil Defence

• Deputy Superintendent of Police

• District Health Officer/Chief Medical Officer

• Commissioner, Municipal Corporations

• Representative of the Department of Public Health Engineering

• Experts (Industrial Safety & Health)

• Commissioner (Transport)

The following persons may be considered as relevant stakeholders at the local level:

• Sub-divisional Magistrate

• Inspector of Factories

• Representative of Industries in the District

• Transporters of Hazardous Chemicals


[8-10]

• Fire Officer

• Station House Officer (Police)

• Block Development Officer

• One Representative of Civil Defence

• Primary Health Officer

• Editor of local News paper

• Community leader / Sarpanch / Village

• Non-Government Organization representatives

• Eminent Doctors in the Local area,

The above groups of persons, between themselves, respectively form the District Level Crisis

Group and Local Level Crisis Group for mitigation of chemical accidents as per the Chemical

Accidents Rules. Consequently, it is suggested that M/s T. J. AGRO FERTILIZERS Pvt Ltd

consider opening a dialogue with them and soliciting their assistance in management of onsite

& offsite emergencies associated with its activities. These may be considered as inputs to other

planning activities.

8.6.3.4. Formation of Emergency Plan Objectives

Specific objectives of the Emergency Response Plan are to be clearly listed with regards to the

responses desired for successful management of the possible emergency situations. Suggested

Objectives could, initially include:

• Formulation of suitable onsite / offsite toxic release response

• Formulation of suitable onsite / offsite fire release response

• Improved awareness of safety issues amongst site personnel.

• Training of key persons in cardio-pulmonary resuscitation.

The objectives are suggested currently are generic in nature. However, they will evolve and

become more specific as the project develops further. Responsibilities, resources and

timeframes require to be allocated for implementing the objectives.


[8-11]

8.7 IMPLEMENTATION

8.7.1 Allocation of Resources

M/s. T. J. Agro Fertilizers Pvt. Ltd. will require allocation of suitable resources for effective

implementation of the DMP. Resources include both human and financial resources.

8.8 EMERGENCY STRUCTURE AND RESPONSIBILITY

8.8.1 Emergency Organization Structure

The emergency organization is a network system with focus on the Emergency Control Centre

(ECC), the Incident Controller (IC), and the Incident Site (IS). The following are office bearers

of the Emergency Organization:

• Site Main Controller: Operations Manager, in-charge of the unit.

• Incident Controller: The respective HOD /shift in-charge. The shift in-charge(s) have to be

present in each shift.

• Essential Workmen: Shift personnel from various operational units within the facility

• Safety Officer: In-charge of controlling fire

• Security officers / guards

Accordingly, the following will have to be done initially:

Identification and appointment of key officials who will take up the roles of Site Main

Controller,

Incident Controller and Essential Workers.

Informing each concerned official of their authorities and responsibilities, which are listed in

the Subsequent paragraphs and keeping records of the same.


[8-12]

8.8.2 Emergency Organization: Responsibilities of Key Personnel

Immediately being aware of the emergency, the Site Main Controller (SMC) will go to the

Emergency Control Center. His main role is to control emergency in required time. On arrival

he will:

1. Get effective briefing from the Incident Controller and take charge as Site Main

Controller relieving the Incident Controller for concentrating on his role as Incident

Controller.

2. In consultation with the Incident Controller decide whether major emergency exist and

on declaration of a major emergency, ensure that the outside emergency services and

mutual help are called, the off site activated and if necessary, nearby factories and

population are informed.

3. Ensure that key personnel are called in.

4. Exercise direct operational control of those parts of the works outside the affected area

leaving the affected area to be directly controlled by the Incident Controller in close

coordination and direction of the Site Main Controller.

5. Continually review and assess possible developments to determine the most probable

course of events.

6. Coordinate the safe shut down and evacuation of the plant in consultation with the

Incident Controller and key personnel if these decisions and actions have not yet been

taken by the Incident Controller till the arrival of the SMC. If necessary, arrange for

evacuation of neighboring population.

7. Ensure that casualties are receiving adequate attention. Arrange for hospitalization of

victims and additional help if required. Ensure that the relatives are advised.

8. Inform and Liaise with the Chief Officers of the Fire and Police Services, District

Emergency Authority and experts in the field of Health and Safety. Provide advice on

possible effects on areas outside the Site.

9. In the case of prolonged emergencies involving risk to outside areas by wind blown

materials as in case of Toxic gas releases and toxic and volatile liquid spills, contact the

local Meteorological office to receive early notification of impending changes in weather

conditions and alert new onsite/offsite areas likely to be affected by the weather changes

likely in the short span of time of the likely duration of the emergency.

10. Ensure the accounting for personnel and rescue of missing persons.


[8-13]

11. Control traffic movement within the Site.

12. Arrange for a chronological record of the emergency development and consequences for

later review.

13. Where the emergency is prolonged, arrange for the relief of personnel and the provision

of catering localities.

14. Issue authorized statements to the news media-where necessary and keeps in constant

touch with Head Office.

15. Ensure that proper consideration is given to the preservation of evidence. Arrange

for photographs/video recording as soon as the same is feasible.

16. Control rehabilitation of affected areas and victims on cessation of the emergency. He

will not initiate restart of the work at the worksites unless it is ensured safe to start and

cleared by the authorities.

Role of Incident Controller (IC):

Immediately being aware of the emergency and its location he will proceed to the scene. On

arrival he will:

1. Assess the scale of emergency and decide if a major emergency exists or is likely to

develop into one. On his decision, he will activate the on-site plan and if necessary, the off-

site emergency plan.

2. Assume the duties of the Site Main Controller pending the latter's arrival. For this purpose

he will depute his deputy Incident Controller on the scene and he will go to the control

center. Particularly he will:

3. Direct the shutting down and evacuation of plant and areas likely to be affected by the

emergency,

4. Ensure that the outside emergency services, including mutual aid, have been called, and:

• Ensure that key personnel have been called in.

• Direct all operations within the affected area with the following priorities:

• Secure the safety of the personnel,

• Minimize damage to site, property and environment, and

• Minimize loss of material.

• Direct rescue and fire fighting operations until the arrival of the outside Fire Brigade, when

he will relinquish control to the Head of the Fire Brigade.


[8-14]

• Search for casualties.

• Evacuate non-essential workers to the assembly points.

• Set up a communications point and establish radio (telephone/messenger) contact as

appropriate with the Emergency Control Center.

• Give advice and information as requested to the Head of the fire Brigade and other

emergency services.

• Brief the Site Main Controller (SMC) on the latter's arrival at site and keeps the SMC fully

informed of the developments.

• Preserve evidences that will be necessary for subsequent inquiry into the cause of the

emergency and concluding preventive measures.

Role of Key Workers, Medical Services:

M/s. T. J. Agro Fertilizers Pvt. Ltd. can have sufficient first-aid centers and first-aiders

properly trained. The staff shall be available round the clock. Tie-up with nearby hospital &

medical shops. It should have sufficient space, capacity and situated in a safe place (avoiding

normal down wind direction). The statutory provisions shall be met with.

8.8.3 Setting up of Emergency Infrastructure

To enable the key persons to implement the DMP, the following infrastructure will require to

be set up:

8.8.4 Site Map with Escape Routes and Safe Assembly Points marked on it

Site layouts have to be put up at key areas where assembly is to be done. These points could

vary depending upon the atmospheric stability and location and intensity of the emergency.

With the onset of emergency, all non-essential workers (those workers not assigned emergency

duty) shall evacuate the area and report to the specified emergency assembly point.


[8-15]

8.8.5 Wind Sock

It is required to install wind sock at the top of any tall structure in the vicinity of the site. In

case there is a risk of the structure getting damaged during the emergency, it is desirable to

have alternate wind sock(s) as required. At least one wind sock should be visible from any part

of the site. Site personnel have to be trained in reading the atmospheric conditions on the basis

of the status of the wind sock.

8.8.6 Evacuation, Escape and Rescue (EER) Plan

In a major emergency, it will be necessary to evacuate personnel from effective areas and as a

precaution / measure to further evacuate non-essential workers from areas likely to be affected

should the emergency escalate. Whether evacuation is required or not can be decided by the

Incident Controller, and arrangements made to communicate with employees in this regards.

Arrangements could include announcements over the public address system, or through other

suitable means.

On evacuation, employees should be directed to pre-determined assembly points already

explained earlier. If they are required to be evacuated outside the site and at a remote place,

their transportation will be necessary for which vehicles will be required. At remote shelters

their care and welfare will also be through beforehand. Employees should use own vehicles

first and then use, if necessary, the mutual aid system or hired vehicles from elsewhere. The

vehicle may be needed to warn public also.

The safe passages/routes for escape shall be decided and marked by arrows in the plans as

explained in the details of Emergency Control Center in this chapter.

8.8.7 Safe Assembly Points

In affected and vulnerable locations, all non-essential workers (who are not assigned any

emergency duty) shall evacuate the area and report to a specified assembly point. The various

assembly points are shown in the layout plan. The selection is done based on the safety and its

location in downwind direction. The need to evacuate non-essential workers from non-affected

areas will be determined by the foreseeable rate at which the incident may escalate.

Each assembly point must be situated in a safe place, well away from areas of risk and least

affected by down wind direction. It may be in the open or in a building depending on hazard

involved. More than one assembly point is needed:


[8-16]

• To ensure that employees do not have to approach the affected area to reach the assembly

point;

• In case any assembly point lies in the path of wind-blown harmful materials, e.g. toxic gas,

burning brands, thrown (expected) materials and;

Before reaching an assembly point, or subsequently, if it is required to pass through an effected

area or the release of toxic substance, suitable personal protective equipment (PPE) including

respirator, helmets etc., should be available to the people.

8.8.8 Emergency Control Centre

An Emergency Control Centre (ECC) is the primary area from where emergencies are handled.

An ECC should contain various items as listed. The Main Control Centre, or any structure on

the site, at sufficient distance from the affected area, and that is designed to withstand

overpressure and radiation stress should be designated at the ECC.

For communication:

• Siren, or other suitable alarm system

• Public address system

• Intercom sets

• External phone sets

• Telephone directory

• Company Directory

• List of Important phone numbers

• Mobile phone

Documents for ready reference:

• Site Plan

• Layout plan with hazard zones, assembly points marked and location of siren, safety/fire

system shown (Display)

• Stock list of Fire extinguishers

• Fire-water system and additional sources of water

• Emergency Response Plan


[8-17]

• Copy of First Aid

• Mutual Aid Members,

• List of employees and addresses and phones

Wall display:

• Site plan

• Layout plan

• Emergency Organization.

Stationary:

• Note pads

• Pens/pencils

• Erasers

8.8.9 Fire Extinguishers

All equipment should be regularly inspected and tested for adequacy. Personnel should be

trained in the use of the same, where special training is required. Records of the same are to be

maintained.

8.8.10 Fire Fighting

These include the following facilities:

• The internal wide road of 6m is constructed around the periphery of the factory for easy

unobstructed movement of fire tender.

• Sufficient water supply

• Dedicated, above ground fire water storage of approximate 100m3

• Dedicated fire pumps to pump the water, connected to the DG Set as well as the GEB

supply.

capacity

• The system should be designed such that when half the aggregate pumping capacity has

been discharged at the hydraulically most remote point and the other half in the most

vulnerable area enroute, a minimum running pressure of 7 kg/cm2

(g) is available at the

former point and the velocity of water does not exceed 5m/sec anywhere in the system.


[8-18]

The following fire fighting equipment shall be required at the site.

• Water buckets: 9 lit of water buckets for 100 m2

• Shovels: 2 Nos.

of the floor area

• Fire Detection & Alarm system : At key locations

M/s. T. J. Agro Fertilizers Pvt. Ltd. might have fire accidents as mentioned in Table 8.6:

TABLE 8.6 TYPE OF FIRE ACCIDENTS

Sr. No Class Extinguisher

Medium SI code Nos.

1. Type A Water Type

A. Soda Acid 934 5

B. Gas pressure 940 5

2. Type B Chemical Foam 933 3

Carbon Dioxide (CO2

5507, 2878,

10474, 8149 ) 3

Sand Bucket --- 5

3. Type E Carbon Dioxide (CO2

2878 )

4

Dry Chemical Powder

2171,4308 4

Fire Extinguisher Calculation:

Total Area of Fire Hazard: 6368.63 m2

Capacity of fire extinguisher : 600 m

2

Total Nos of fire extinguisher required: 14 nos.

Nearest fire station from the project site is Fire Station of Mandvi, Vadodara which is 31.5 km

away from project site and fire brigade can reach to the site within 40 minutes.

Note: Vadodara is major town near the project site having fire fighting facilities.


[8-19]

8.8.11 First Aid Basic items in a first aid kit consist of following items.

• First aid leaflet, including CPR

• Sterilized finger dressing

• Sterilized hand or foot dressing

• Sterilized body or large dressing

• Sterilized burns dressing - small

• Sterilized burns dressing - large

• Sterilized burns dressing – extra large

• Sterilized cotton wool (25 gms)

• Cetavolon (28 gms)

• Eye pads

• Adhesive plaster

• Assorted roller bandage

• Triangular bandages

• Safety pins

• Scissors, ordinary, 12.7cms, both sides sharp

• Savlon liquid, 150 ml, or equivalent

• Cotton wool for padding, 100 gms

• Eye Ointment of sulphacetamide preparation

• Loose woven gauze (28”x8”), Compressed pack

• Scribbling Pad, 4”x 6” with a pencil in a plastic cover

• Adhesive dressing strips

• Field dressing of modified army pattern

• Record cards in a plastic cover

• Torch, medium size

• Eye wash

• Wooden splints, small

• Wooden splints, big


[8-20]

8.8.12 Personnel Protective Equipments (PPE)

• Gloves of different types

• Helmet

• Masks of different types

• Safety Spectacles

• Ear Muff/ Ear Plug/ Caps/ Shocks/ Uniforms

• Eye Showers

8.9 AWARENESS, TRAINING, AND COMPETENCE

8.9.1 Awareness General awareness is to be invoked in all site personnel (including contractor’s employees)

with regards to the importance of safety in general and emergency procedures in particular.

Awareness can be generated in a number of ways, some of which are:

• Awareness of Environment, Health and Safety Policies, and the role of each employee in achieving what are covered under the policies.

• Awareness of the importance of carrying out tasks as mentioned in the Standard Operating Procedures and the potential impacts of not doing so.

• The importance of wearing personal protective equipment • Awareness with regards to relevant recommendations issued in this report • Awareness about relevant portions of the safety instructions covered in equipment manuals

used at site.

8.9.2 Training

Specific training requires to be given to key employees. Examples of such training include:

• Testing of critical equipment and controls • Provision of Cardio-Pulmonary Resuscitation • Use of fire fighting equipment • Emergency Evacuation and Rescue (EER) procedures. • Training in use of communication procedures to be followed in case of emergencies.

Training needs identification exercises should be undertaken prior to commencement of

operations and the same must cover environment, health and safety issues.


[8-21]

8.9.3 Competence Competence is a function of training, experience and education. Key persons involved in

administering the DMP, should be competent. The level of competence can be decided for each

key task and a clearly defined competence chart should be prepared.

8.10 COMMUNICATION

Communication is vital during emergencies. Under the Factories Act, as well as the MSIHC

Rules, communication is important and it is required to divulge the potential emergencies that

could arise out of the operations related to hazardous units.

After undertaking an assessment of risks and their possible environmental impacts, and setting

up an organization for the preparedness to control the emergency, including related

infrastructure, the next step is operationalizing the communications system. Depending upon

the severity of the event, communications may have to be made with:

• Persons inside the site premises • No person to be allowed enters or exits inside or outside the plant at security gate. • Key personnel outside the site premises during their non-working hours • Outside emergency services and authorities, and • Neighboring businesses, industries and general public.

Requirements pertaining to communication during emergencies are covered in this section.

8.10.1 Levels of Emergency

Three levels of emergencies are to be recognized:

• First level: Confined to a particular unit of the entire site,

• Second level: A spreading emergency, that requires outside help, and

• Third level: A major emergency requiring neighboring population to be alerted.

Suitable alarms require to be made for each of these potential emergencies. The alarm should

be audible in every part of the site. In areas of high noise levels, an alternative to an audible

alarm, such as flashing lights may be installed.


[8-22]

8.10.2 Raising the First Level Emergency Alarm

Any person noticing an emergency should be able to raise or cause to be raised, the First Level

Emergency Alarm (FLEA). All employees must be trained to operate such emergency alarms.

There should be adequate places within the site, where provision to raise an alarm is available.

This could be an audible warning, individual signal or message to a manned location. Major

emergencies can be avoided by doing this.

8.10.3 Raising the Second and Third Level Emergency Alarms

In case there is a risk of the event spreading beyond the original unit and / or outside the site

premises, then a second level emergency alarm can be raised. This could be across the entire

site, as opposed to the first which could be at a part of the site.

In case a third level or (major) emergency is to be declared, telephonic information to members

of the local crisis group, or in case of failure of power and formal communication systems, and

non-availability of mobile phone signals, a big bell or a messenger can be deployed.

8.10.4 Declaring a major emergency:

Declaration of a major emergency should never be done on whims, immature judgement or

without proper thought. Further, because of the scale of activity that will commence due to

declaration of a major emergency, it is advisable to restrict the authority to declare it, and a

limited number of persons may be invested the authority to declare such an emergency,

although care should be taken to ensure that at least one such person is always at site.

8.10.5 Identifying the Type of Emergency through an Alarm

Alarm systems vary and will depend upon the size of individual sites. The person noticing the

incident should warn all those in the site vicinity to either evacuate or take other immediate

action according to a predetermined plan. Automatic alarms may be considered. Audible

alarms include sirens or other alarms over public address systems.

Alarms for a particular type of emergency (toxic leak or fire) can be raised separately enabling

different emergency plans to be put in motion. However, this must be done after giving due

thought about avoiding confusion in the minds of the site personnel.


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Use of alarms can be carried out to communicate different information such as:

• Declaration of a first level emergency by an alarm in a particular area

• Declaration of an advanced emergency situation by sounding of an alarm in the entire site

• Declaration of a major emergency by sounding of a hooter, alarm or by communication

through phone, bell or messenger.

8.10.6 Communication of Emergency

There should be an effective system to communicate emergency:

Inside the factory, i.e. to the workers including key personnel and essential workers on duty,

and inside normal working hours,

To the key personnel and essential workers not on duty and outside during normal working

hours

To outside emergency services and the government authorities, and

To the neighboring businesses, and public in general

8.10.7 Use of telephones and the role of the telephone operator

After hearing the emergency alarm and emergency declaration, or even while fast receiving the

emergency message on phone, a telephone operator (or communication officer) has to play an

important role. He should be precise, sharp, attentive and quick in receiving and noting the

message and then for immediate subsequent action of further communication.

8.10.8 Communication inside with Personnel inside the Site during the Incident

Relevant statutory information pertaining to the site must be made available beforehand,

preferably in the form of a booklet, to workers so that they can prepare themselves to prevent

or control the emergency. Such information includes:

Statutory requirements under section 41-B, 41-C, and 41-H of the Factories Act

Hazard Information, including

• A list of hazardous processes carried on in the factory • Location and availability of all MSDS’ • Physical and health hazards arising from the exposure to or handling of substances • Measures taken to ensure safety and control of physical and health hazards


[8-24]

• Measures taken by workers to ensure safe handling, storage and transportation of hazardous substances

• Personal Protective Equipment required to be used by the workers employed in hazardous processes or dangerous operations

• Meaning of various labels and markings used on the containers of hazardous substances • Signs and symptoms likely to be manifested on exposure to hazardous substances and to

whom to report • Measures to be taken by the workers in case of spillage or leakage of hazardous substances • Role of worker vis-à-vis the emergency plans of the site and in particular evacuation

procedures. • Any other important health and safety related information.

In all cases, once the communication of emergency is done, through an alarm, all personnel

should be ready to undertake their roles in the same.

8.10.9 Communication with Personnel outside the Site during the Incident

Because of the suggested planning covered in Section 0, key personnel will typically be

available in all shifts or on short call. But due to some reason, if some are outside or not on

duty and if their help is required, their updated details should be kept in the ECC for

communication.

As far as possible, names should be listed in the order or priority. Communicators should be

told to call in the personnel in the order given, but not to waste time and call the next in line,

returning to those who could not be contacted later.

On making contact, the communicator should give a short pre-arranged message to the effect

that an emergency has been declared at the site. While coming to the site, they should be

instructed to carry with them their identity cards in case they are stopped at road blocks.

8.10.10 Communication inside with external Emergency Services and Relevant

Authorities

Communication with external agencies is important and essential, both to control the

emergency and as per regulatory compliance requirements. This is specially so for reportable

(lost time) accidents. In such cases, it is essential that the outside emergency services as well as

relevant outside agencies be informed in the shortest possible time. Liaison at the local level

will help determine the best means for achieving this.


[8-25]

Relevant agencies that provide emergency services include the fire brigade, nearby hospitals

and doctors, and the police, besides senior local and district administration personnel. Statutory

information, given to such agencies in advance will help them in arranging emergency

services.

8.10.11 Communication with neighboring firms and the general public

Telephone can be used for contact with industries in the study area with a view of receiving

mutual aid. However, the public in the area, in some circumstances, may require to be

informed about the emergency, which as stated earlier, should be done after careful evaluation.

The general public requires to be informed of the precautions to be taken in case of emergency

situations arising out of hazards posed by units near them.

These include:

• Common names of hazardous substances used which could give rise to an accident likely to affect them, with an indication of their principal harmful characteristics.

• Brief description of the measures to be taken to minimize the risk of such an accident in compliance with its legal obligations under relevant safety requirements

• Salient features of the approved emergency management features of the site • Details of the emergency warning system that will be deployed by the site for emergency

action by the general public • General advise on the steps to be taken by the general public on hearing or becoming aware

of the warning • Brief description of arrangements in the site including liaison with emergency services to

deal with foreseeable accidents of such nature and to minimize their effects • Details of where additional information may be collected.

8.10.12 Communication with District Crisis Group and the Local Crisis Group

• In addition to the general public communication will require being provided to the district

administration and this may be done by liaisioning with different agencies.

8.11 EMERGENCY DOCUMENTATION AND DOCUMENT CONTROL 8.11.1 Documentation Emergency documentation consists of:

• The Disaster Management Plan (this chapter) and its annexure duly completed. • Related Formats and Records showing compliance with these documents.


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The DMP needs to be approved by the Site in-charge prior to use. All documents should be

easily accessible at individual sites.

8.11.2 Document Control

• Documents should be legible. • All documents should be protected against damage, deterioration and loss. • Changes, if any, should also be approved by the Site in-charge. • Copies of the approved DMP are to be kept with the Site in-charge at the office in the

Emergency Control Centre, with the Site Main Controller. • Obsolete documents should be marked as such, and copies of such documents are to be

collected and prevented from being used.

8.11.3 Emergency Control

In case of emergencies, actions can broadly be categorized into the following activities:

• Saving of human lives

• Controlling the spread of the emergency and ultimately stopping it from further developing

On the basis of the issues covered in this chapter, the following are required to be incorporated

into the site’s DMP annexure.

8.11.3.1 Onsite Emergency Control

• Shut down and Isolation: Raising the alarm, followed by immediate safe shut down and

isolation of effected areas.

• Escape, Evacuation and Rescue: Safeguarding human lives at site by commencement of

the Emergency Evacuation and Rescue Plan. Ensuring that all personnel are accounted

for and carrying out a head count of persons evacuated. Notification and commencement

of offsite emergency plan in case offsite impacts are possible.

• Stopping the development of the emergency: Control or response to the emergency

depending upon its nature (fire OR toxic release). Fire can be somewhat better controlled

through fire fighting, while toxic release impacts can be partially controlled through

proper communication with affected population.

• Treatment of injured: First aid and hospitalization of injured persons.

• Protection of environment and property: During mitigation, efforts should be made to

prevent impacts on environment and property to the extent possible.


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• Welfare of the personnel managing the emergency: Changeover, first aid and

refreshments for the persons managing the emergency.

• Informing and collaborating with statutory, mutual aid and other authorities including

those covered in the Local Crisis Group.

• Informing and assisting relatives of the victims.

• Informing the news and electronic media.

• Preserving all evidences and records: This should be done to enable a through

investigation of the true causes of the emergency.

• Investigation and follow up: This requires to be carried out to establish preventive

measures for the future and a review of the DMP & its annexure to fill up the deficiencies

in the emergency planning procedures.

• Ensuring safety of personnel prior to restarting of operations: Efforts require to be made

to ensure that work environment is safe prior to restarting the work.

8.11.3.2 Off-site Emergency Response Plan

An emergency may affect areas offsite of the works as for example, fire can spread burning

brands of gases through wind. Perhaps the most significant risk to the outside areas is that

associated with a large release of toxic vapors. Management will usually need expert advice in

drawing up plans so that if such a release occurs, they will be able to collaborate with

Emergency Services to estimate as far as practicable which downwind areas are at risk. It may

be necessary to prepare in advance simple charts or tables relating the likely spread of the

vapors cloud taking into account its expected buoyancy, the local topography and all possible

weather conditions during the time of release. Advice on all these matters can be obtained

from the Meteorological Office. Any such advice will include the recommendation that if a

release occurs the local Meteorological Office (whose address is in the telephone directory)

should be contacted for the current state of the weather over a somewhat wider area and, in

the case of prolonged emergencies, information on imminent changes in weather which

may alter the areas at risk. Such information is likely to be more specific if prior consultation

has been made.

M/s. T. J. Agro Fertilizers Pvt. Ltd. obligations for generating the Offsite Emergency Plan

Offsite emergency preparedness is covered in the Chemical Accidents (Emergency Planning,

Preparedness and Response) Rules, 1996.


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The following are the responsibilities towards generation of the Offsite Emergency Plan:

• To provide basic information on Risk and Environmental Impact Assessment to the

Local/District Authority, Police, Fire Brigade, Doctors, surrounding industries and the

public and to appraise them on the consequences and the protection/prevention

measures and control plans and seek their help to manage the emergency.

• To assist the District Authorities in preparing the Off-site Emergency Plan.

An off-site emergency plan organization has essentially two parts:

1. Formation of the Local Crisis Group: This Group is headed by the Deputy Collector or the

Magistrate of the Industrial area and is responsible for the management of any industrial

emergency confined to the local area.

2. Formation of the District Crisis Group: This Group is headed by the District Collector of the

District and is responsible for any major Industrial emergency affecting Local and beyond

any industrial area of the District.

The composition of the Off-Site Crisis Group is covered in. Since, the actual offsite plan

requires the participation of outside agencies; this report does not dwell further on the issue.

The typical structure of the offsite emergency planning group is provided vide Table 8.7 given

below.


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Table 8.7: COMPOSITION OF OFFSITE CRISIS GROUP

District Collector

Off-Site EMP Teams

Each Team has:

• A Chair Person / Director • Secretary • Coordinator • Members

Local Crisis Groups

(For each Industrial Area Headed by

the Deputy District Collector or

Magistrate)

Off-Site EMP Teams

1 Fire Brigade Team, 2 Experts, 3 AMC-Team, 4 IC-Team, 5 Toxic Gas Containment team, 6 Communication Team, 7 Transport and Evacuation Team, 8 Traffic Control Team, 9 Medical Team, 10 Mass Media and PR-Team.


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8.12 CHECKING AND CORRECTIVE ACTION

8.12.1 Monitoring and Measurement

Monitoring of the planned arrangements and the implementation of the DMP are essential to

deliver the required output and enhance emergency preparedness. This includes:

• Provisions for NDT, FMECA and other tests to identify failure of critical equipment,

before it actually takes place.

• Monitoring compliance to permits and statutory requirements lay down by regulatory

authorities.

• Conducting mock drills (including fire drills and toxic release drills) to check whether the

planned arrangements are working as per the required norms or not.

• Testing of critical equipment, and

• Identifying minor leaks, accidents, near misses and others incidents that can lead to

emergencies.

A detailed monitoring checklist requires being prepared and the required actions carried out,

prior to start of work.

8.12.2 Records

Records are a means of evaluating performance. Records include (but are not limited to):

1. Regulatory records, such as permits and related documents

2. Monitoring and test records

3. Correspondence with relevant offsite and onsite agencies

Site management will ensure that records are properly maintained and available. It is desirable

to keep copies of all records at the site as well at the project sites, to prevent their loss. The

retention time for these records will depend upon their criticality and an ultimate decision will

require to be taken by Head Office in this regards. Legal records should be kept permanently.

8.12.3 DMP Audit, Non Conformance and Corrective Action and Preventive Action

Since this DMP has been designed as a dynamic document, it is required that its performance

be audited at regular intervals. Ideally, persons auditing the DMP should be external auditors

(i.e. not employed at the site being audited). The audit should result in a set of findings that are

put before the site management for review.


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Audits will be periodic, at intervals that are decided by the Head Office. Audit reports shall

state the exact non-compliance with the particular clause of this DMP, and should include steps

to be taken to attain compliance, through corrective and preventive actions.

8.12.4 Safety Committee and Safety Meeting

Safety committee is an organizational structure where members represent a group. This gives

everyone a voice but keeps the meeting size to an effective number of participants.

8.12.5 Functions of Safety Committee

A safety committee can be very helpful, especially when they are allowed to do the following.

1. Discuss safety polices and recommended adoption

2. Help management to correct unsafe conditions and unsafe acts.

3. Create more disciples of safety

4. Help evaluate safety suggestions

5. Arouse Interest in safety

8.12.6 Safety Committee Procedure

When a committee is formed, a procedure should be written describing its function and

activity.

1. Extent of committee authority

2. Scope of Committee activity

3. Order of business

4. Record Keeping

5. Attendance

8.12.7 Review of Emergency Performance

The site / head office management will review the findings of the audit and the non-

compliances. It will consider whether the DMP is providing adequate safety assurance to the

management, delivering performance as desired, and whether it continues to be in the spirit of

Environment, Health and Safety Policies, and changing requirements. On the basis of these, the

management will record its decisions and consider modifying the DMP, as deemed

appropriate.


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8.12.9 Contents of the Annexures

The contents of the DMP Annexures are listed. The annexure should first be completed in

respect of the names, addresses and contact phone numbers of all the members of the

emergency organization. In addition, the names, addresses and phones numbers of nearest

police station, local authorities, media, doctors, hospitals, fire brigade, voluntary organizations,

and home guards also require to be collected. Once this, (and other) updating of DMP has been

done for the site, the same may be got printed and kept with each officer, work sites and

security, and other relevant persons as may be needed. The items covered in the annexure are:

• Emergency organization

• Siren code

• Site map with escape routes and safe assembly points

• Emergency control centers

• Role of site main controller

• Role of incident controller

• Role of fire safety service

• Medical services

• Engineering services

• Welfare services

• Security services

• Replenishment services

• Mutual aid

• Internal emergency reporting and communication system

• Safe assembly points

• Evacuation, escape and rescue (EER) plan

• MCLS

• Mutual aid organizations

• Mock drill and review procedure

• Offsite plan components


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8.13 RECOMMENDATIONS Recommendations are made for different aspects of the project and are given in subsequent paragraphs.

8.13.1 Hazardous Material Storage and Handling

8.13.1.1 Storage of Hazardous Chemicals in Drums and other Containers • The drums should never be filled full with the liquid chemical. There should be sufficient

space to take care of thermal expansion.

• The drums should preferably be stored in a well ventilated shed (preferably away from

process units) with impermeable floor sloping away from drums.

• Periodic site inspection should be carried out to ensure that there is no leakage from any of

the drums..

8.13.1.2 Storage and Handling of Extremely toxic or highly toxic

• Store in a segregated and approved area. Keep container in a cool, well-ventilated area and

tightly.

• Keep away from heat, from sources of ignition. Ground all equipment containing material.

Do not ingest. Do not breathe gas/fumes/ vapor/spray. Wear suitable protective clothing.

• Avoid contact with skin and eyes. Keep away from incompatibles such as oxidizing agents.

• Avoid all possible sources of ignition (spark or flame).

8.13.1.3 Storage and Handling of Fuel

In case heating is to be provided to HSD in winter, then steam heating is suggested as opposed to

use of heating coils for heating purpose.

• Fuel storage roofs and interface of vapour and liquid levels have shown heavy corrosion and nitrogen bleed helps in preventing corrosion and also fire and explosions. This provision should be kept. Fuel does not statutorily require a flame arrester at the vent line of storage tank, but it is desirable to provide one as fires and explosions have taken place.

• Dyke below the overhead HSD tank be provided to contain spills and for good house keeping around.

• For draining of water from the HSD tank, a drum be kept with bottom and side outlets, instead of draining in the open to maintain good house keeping and draining of water be done


[8-34]

in a jug and throw away the water and the drum should retain any drippings of HSD that can be pumped to overhead tank when filled.

8.14 UNLOADING OF TANK TRUCKS

• Before the tanker enters the industry premises, the tanker is to be inspected for authorized

entry and safe & sound condition of the tanker, its contents and that of the prime mover.

Tankers entering plant are to be fitted with flare arresters on their exhaust.

• The quality of the chemical in the tanker should be ascertained before unloading to avoid

contamination of chemical already at storage.

• Coupling used for connecting hose to tanker must be leak proof.

• For flammable chemicals, the tanker and the hose are to be properly earthed before starting

unloading operation.

• Unloading should be done under personal supervision of responsible staff authorized by the

management.

• Provision of sample quantity of water / neutralizing medium to take care of leakage / spillage

must be made. Also steam and inert gas hose stations must be available at unloading point.

• Fire alarm and fire fighting facility commensurate with the chemical should be provided at

the unloading point.

8.15 HAZARDOUS WASTE TRANSPORT

The occupier of hazardous substance shall prepare six copies of the manifest (transporting

documents) in Form 9 comprising of Colour code indicated below (all six copies to be signed by

the transporter):

• Copy 1 (white): to be forwarded by the occupier to the State Pollution Control Board or

Committee

• Copy 2 (yellow): to be retained by the occupier after taking signature on it from the transporter and rest of the four copies to be carried by the transporter

• Copy 3 (pink): to be retained by the operator of the facility after signature

• Copy 4 (orange): to be returned to the transporter by the operator of facility after accepting

waste


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• Copy 5 (green): to be returned by the operator of the facility to State Pollution Control Board / Committee after treatment and disposal of wastes.

• Copy 6 (blue): to be returned by the operator of the facility to the occupier after treatment and disposal of wastes

The occupier shall forward copy number 1 (white) to the State Pollution Control Board or

Committee and in case the hazardous waste is likely to be transported through any transit State,

the occupier shall prepare an additional copy each for such State and forward the same to the

concerned State Pollution Control Board or Committee before he hands over the hazardous waste

to the transporter.

No transporter shall accept hazardous wastes from an occupier for transport unless it is

accompanied by copy numbers 2 to 5 of the manifest. The transporter shall return copy number

2 (yellow) of the manifest signed with date to the occupier as token of receipt of the other four

copies of the manifest and retain the remaining four copies to be carried and handed over to

respective agencies as specified in sub-rule (4).

8.16 GENERAL SAFETY PRACTICES

8.16.1 Work Permit System

• It is recommended that plot plans of the installation and the operating blocks should be

displayed in the fire and concerned unit control rooms respectively and site of hot jobs under

progress should be indicated on these plot plans with red pins.

• No hot/cold work shall be undertaken without a work permit except in the areas pre-

determined and designated by the owner-in-charge.

• Permit should be issued only for a single shift and its validity should expire at the termination

of the shift. However, where the work has to be continued, the same permit may be

revalidated in the succeeding shift, by authorized person after satisfying the normal checks.

• Equipment or area where work is to be conducted should be inspected to ensure that it is safe

to carry out the work and assess other safety requirements / stipulations.

• Unsafe conditions for performance of work may arise from surrounding area. It should be

cleaned-up to remove flammable material such as oil, rags, grass etc.


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• Other activities (routine / non-routine) being carried out near-by which can create conditions

unsafe for performance of the permit work, should be taken into consideration and the

concerned persons should be alerted accordingly.

• Running water hose and portable fire extinguisher are required respectively to flush / dilute

in case of release of any hazardous chemical or to quench sparks and to put out small fires

immediately.

• In order to meet any contingency, it should be ensured that the fire water system including

fire water pumps, storage, network etc. is checked and kept ready for immediate use

• Equipment / Vessel, on which the work permit is being issued, should be completely isolated

from the rest of the plant with which it is connected during normal operation, in order to

ensure that there is no change in the work environment with respect to presence of toxic /

flammable gases, liquids, hazardous chemicals etc. in the course of the work.

• Equipment under pressure should be depressurized after isolation. This will be followed by

draining / purging / water flushing etc. as the case may be.

• Proper means of exit is required in case of emergencies developed on account of the work or

otherwise. Availability of an alternate route of escape should be considered.

8.16.2 Contractor Safety

Duties & responsibilities of the contractor should include the following:

• To implement safe methods and practices, deploy appropriate machinery, tools & tackles,

experienced supervisory personnel and skilled work force etc. required for execution.

• To prepare a comprehensive and documented plan for implementation, monitoring and

reporting of Health, Safety and Environment (HSE) and implement the same after its

approval.

• To nominate qualified & trained Safety Engineers / Officers reporting to the Site in charge,

for supervision, co-ordination and, liaison for the implementation of the safety plan

• To arrange for fire protection equipment as per the advice of owner

• To ensure that its employees have completed appropriate health and safety training as

required by the statute / regulation and also as per requirements of the Owner / Consultant


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• To comply with all the security arrangements of owner.

• To ensure availability of First Aid boxes and First Aid trained attendant.

• To ensure that all incidents including near misses are reported to all concerned immediately.

• To ensure strict compliance with work permit system by carrying out work only with

appropriate work permits and after ensuring that all safety precautions / conditions in the

permit are complied with and closing the same after job completion.

• To ensure that the workers likely to be exposed to hazardous chemicals/materials have access

to appropriate Material Safety Data Sheets (MSDS), wherever applicable, and provide

necessary mitigation measures.

• To ensure that appropriate warning signboards or tags are displayed.

• To ensure that workers have proper training for their job assignments, including use of

appropriate PPE and first aid fire fighting equipment.

• To comply with all applicable safety and health standards, rules, regulations and orders

issued by competent authority pertaining to the assigned activities.

• To conduct daily inspections to ensure compliance with safety standards, codes, regulations,

rules and orders applicable to the work concerned.

8.16.3 Static Electricity

• Ensure no metal objects/appurtenances projecting from roof/shell plates, which will attract

highly charged spots in fuel for dissipation.

• Ensure reduced rate of flow initially into tank/vessel until fill point/nozzle is completely

submerged in fluid.

• Ensure periodic checking and recording of earthing test for tanks and piping systems are

maintained.

• Agitation with air, steam gas, jet nozzle or mechanical mixtures should be avoided.

• Ensure no personnel are allowed on tank roof for gauging / sampling during product transfer

unless dip pipes extend to bottom of tanks. Use only mechanical gauges for ascertaining

product transferred during transfer operations otherwise.


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• Protective bonding is required when fill open containers where the product to be handled has

a flash point below 54.5 Deg.C (130 Deg.F) or, in the case of a higher flash point product,

when it is heated to within 6.0 Deg. C (15 Deg.F) of its flash point. The purpose is to keep

the nozzle and container at the same electrical potential, thus avoiding a possible static spark

in the area of a flammable mixture.

• Small containers made up of plastic or other non-conductive materials should not be used for

filling of fuels.

• Water washing is safe from a static electricity stand-point. However, there should be no

insulated conductive objects within the tank.

8.16.4 Lightning Protection

• Measures to control fugitive emission from storage tanks should be given special

consideration.

• Structures of exceptional vulnerability by reason of explosive or highly flammable contents

need special consideration and every possible protection need to be provided even against

the rare occurrence of a lightning discharge.

• A lightning protection system (Conventional Air Terminal System) consists of the following

three basic components - Air terminal, Down conductor and Earth connection

• Non-conducting chimneys whose overall width or diameter at top is upto 1.5m shall be

provided with one down conductor, and chimneys with overall width or diameter at top

more than 1.5m shall be provided with 2 no. down conductors

• Metal stacks shall be properly earthed at the bottom.

• Flammable liquids shall be stored in essentially gastight structures.

• Openings where flammable concentrations of vapour or gas can escape to the atmosphere

shall be closed or otherwise protected against the entrance of flame.

• Structures and all accessories e.g. dip-gauge hatches, vent valves shall be maintained in good

and sound operating conditions.

• Flammable air-vapour mixtures shall be prevented to the greatest possible extent from

accumulating outside storage tanks.


[8-39]

• Potential spark-gaps between metallic conductors shall be avoided at points where flammable

vapors may escape or accumulate.

• A properly designed / constructed gas tight storage tanks considered to be self-protected

against lightning provided it is properly earthed and bonded. Such a structure may not

require any additional means of lightning protection.

8.17 PERSONNEL SAFETY

8.17.1 Personnel Protective Equipment

• Protective equipment should be inspected frequently to ensure that it is in good condition.

Frequency of checking can be decided depending upon the usage.

• After the use of protective equipment, it should be cleaned and disinfected before being

issued to another person

• Know about MSDS of hazardous chemicals used.

• A person not-familiar with MSDS and trained in use of appropriate shall not commence any

work with hazardous chemicals.

• Frequently refer to the MSDS and use of appropriate PPE

• Display prominently requisite information on MSDS and use of PPE through illustrations

• It is essential that right type of PPE and in sound condition be used.

• All stocks of PPEs should be periodically inspected, serviced and maintained and unusable

ones removed from stock of usable PPEs and sent for disposal.

• All PPEs should be cleaned for personal hygiene and kept packed in poly bags.

• All PPEs should be inspected before and after each use.


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8.17.2 Training and Development

• Participant’s reaction should be obtained in respect of the course content; training

methods/techniques used by the faculty, quality of course material etc.

• It should be ascertained whether participants’ learning in terms of knowledge and skills in

specific areas or activities e.g. safe operating and maintenance procedures, fire prevention

and control etc. have improved after the training.

• It should be checked in what ways and to what degree/extent the attitude of the participants

(values or beliefs) have been influenced by the training programme. An evaluation of their

behavior on the job is necessary for this purpose.

• Change in participants’ performance at their place of work as a result of the training, should

be evaluated.

• The effectiveness of faculty in each training programme should be evaluated and necessary

changes if need be, should be made in subsequent training programmes.

• The impact of the training programmes on the performance standards of the organisation and

attainment of tangible results with respect to safety should be evaluated.

• Records of training should be maintained in respect of every employee indicating the types

and the period of training programmes attended, performance evaluation and the need for

future training.

• The impact of training programmes should be evaluated in terms of overall safety objectives

achieved.

8.18 SAFETY OF PLANT EQUIPMENT

8.18.1 Thermal Insulation

• PUF, Rock wool insulating material will be used.

• Frequency of Visual Inspection shall be once a year for plants and mobile equipment. This

visual inspection shall be preferably carried out before monsoon, to check for any

damage/deterioration, and record the same.


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• Like equipment, insulation also shall be checked and maintained at regular intervals.

Preventive maintenance of insulation is very much necessary for safe and economic

operation.

8.18.2 Electrical Equipment

• Before initiating the inspection of electrical equipment and associated circuits, Inspector

should familiarize himself with the complete previous history of the equipment/circuits,

design parameters, service, and likely areas of concern, manufacturer’s recommendations

and such other pertinent data to arrive at the appropriate inspection procedure.

• The field inspection of electrical equipment in an operating unit is classified into following

three types as follows:

8.18.3 OnStream Inspection

• This covers audio visual inspection items (instrument aided or otherwise) for checking of

general equipment conditions, while the equipment is in operation. (e.g. an abnormal nose

or vibration of motor, leakage of transformer oil or overheating of equipment etc., can be

assessed through such inspections).

8.18.4 Shutdown Inspection

• This covers those inspection items for checking conditions of equipment and systems which

cannot be revealed through on-stream inspection (such as internal condition of equipment).

This inspection shall be carried out after taking the shutdown of the related equipment after

obtaining the Electrical Line Clearance and Work Permit requirements

8.18.5 Inspection of Standby Equipment and Spare Parts

• The standby electrical equipment shall be inspected on the same basis and schedule

applicable under shutdown inspection, so that changeover from normal to standby equipment

shall be possible without any downtime of unit operation.


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8.19 Reactors

Reactors will be designed such that the safe working pressure of the reactors is never exceeded.

As per the American Society of Mechanical Engineers (ASME), the safe working pressure of a

vessel should always be higher of the two conditions mentioned:

• 10% higher than the maximum operating pressure, or

• 2 kg/cm2

Minimum statutory requirements include:

more than the maximum operating pressure

• Safety relief valves or rupture discs

• Pressure gauges

• Isolation valves or valves to prevent connected equipment over-pressurization

• Drain valve at the bottom to drain of condensates

Vents of pressure relief systems should lead to a surge tank whose vent should lead to a

scrubbing system that should have reserve overhead water tank with interlock with critical

operating parameters such as pressure. Other safety devices that may be considered include:

• High / low pressure alarms, and

• Interlocking equipment to prevent over-pressurization; such as between compressors and

connected equipment.

Pressure relief devices and rupture discs are always the last resort. Engineered design should

include high / low pressure alarms, auto trips that are set up at pressure above the operating

pressure but below the relief systems.

In general, all reactors and pressure vessels will conform to rules laid down in The Static and

Mobile Pressure Vessels (Unfired) Rules 1981.


[8-43]

8.20 Equipment Safety

\

8.20.1 Pumps

Pre-starting procedure • Equipment: Pump shall be thoroughly cleaned.

• Piping: Assembly of all piping shall be checked to ensure that they are as per the design

drawing. Piping shall be thoroughly flushed to remove rust preventive/foreign material.

• Support: Relevant pipe supports shall be checked to ensure that they are as per design

drawing.

• Alignment: Alignment of pump and prime mover shall be carried out.

• Bearing: Bearings shall be lubricated with correct lubricant wherever applicable.

• Prime mover: The prime mover shall be prepared for operation as manufacturer’s instruction.

In case of Electric Drive correct direction of rotation shall be ensured in decoupled

condition. Insulation value of motor and cable shall be checked and recorded.

• Packing: For gland packing and mechanical seal, cooling and flushing shall be ensured.

Mechanical Seals (if applicable) shall be installed as per manufacturer’s recommendations.

• Heating up before startup: Pumps on high temperature service shall be heated up gradually to

an even temperature before putting on service.

• Balancing drum leakage: For pumps equipped with balancing drums, any valve in the line

shall be locked open for ensuring leakage return to pump suction or to the vessel.

Start-up Procedure

• The free rotation of the pump shall be checked.

• Ensure all instruments are installed as per P&I diagram.

• Ensure that strainer is provided in the suction line.

• Discharge valve shall be closed (if not already closed).

• On pumps having externally sealed stuffing boxes, the injection line valves shall be opened

and sealing fluid allowed flowing to the seal cages.

• Pump shall be properly primed.

• Prime mover shall be started as per prescribed recommendation.


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Post-start Checks

• All instrument readings shall be checked and recorded periodically.

• Vibration readings shall be checked and signature shall be taken as necessary.

• Stuffing box packing shall be checked for overheating.

• Temperature rise, vibration and any abnormal sound from bearings shall be checked.

• Cooling water flow shall be checked frequently.

• Suction and discharge pressure shall be monitored to ensure proper operating condition.

8.20.2 Diesel Engines

• Fuel, oil, water and exhaust shall be checked for leaks.

• Air cleaner oil level shall be checked.

• Oil level in hydraulic governor shall be checked, if provided.

• The following checks shall be carried out after every 250 hours - condition of entire oil, the

filter elements for metal particles and oil sludging, element holes and tears, oil in aneroid

control, if provided, belts, fan hub and drives.

8.20.3 Fans, blowers, gear boxes and agitators

Fans and Blowers

• Bearing Temperature, Bearing cooling water flow & cooling water temperature and motor

amperage should be checked daily

• After every 2000 hrs, the gear boxes should be inspected for condition of the gear and

bearings, coupling and alignment and oil level

• In the case of side entry or bottom entry agitators the shafts are sealed by using stuffing box

or mechanical seals. In the case of long shafts steady bearings may be used. Therefore,

agitators can be subdivided for the purpose of preventive maintenance schedule into Gear

boxes and sealing arrangements.


[8-45]

Rotating equipment components

• Check the set of belts for exact length ranges i.e. the belts should be in matched sets.

• Check the sheave groove with a template for ensuring the tight fit.

• Always ensure that the set of belts is from one manufacturer only.

• All the bolts must have manufacturers’ original mark imprinted on it.

• Ensure replacement of belt in full set whenever required.

• During operation belts is checked for to see the belts have become loose, the ply threads have

started coming out, the belts are touching the guards, the guards are properly bolted with

main frame or a separate support, black dust started coming off from the belts etc.

8.20.4 Mechanical Seals

Inspection of Seal Components Prior to Installation:

• It should be ensured that all parts are kept clean; especially the running faces of the seal ring

and insert.

• The seal rotary unit should be checked to ensure that the drive pins and/or spring pins are

free in the holes or slots.

• The set screws in the rotary unit collar should be checked to ensure that they are free in the

threads.

• The thickness of all gaskets should be checked against the dimensions shown on the

assemble drawing. Improper gasket thickness will affect the seal setting and the spring load

imposed on the seal.

• The fit of the gland ring to the equipment should be checked to ensure that the gland ring

pilot enters the bore with a reasonable guiding fit for proper seal alignment. It should be

ensured that there is no interference or binding on the studs or bolts or other obstructions.

• It should be ensured that all rotary unit parts of the seal fit over the shaft. ‘V’ ring should be

placed on the shaft individually, and never be installed on the shaft while they are seated in

the seal ring or rotating assembly.


[8-46]

• Both running faces of the seal should be checked to ensure that there are no nicks or

scratches. Imperfections of any kind on either of these faces will cause seal leakage.

Fixing of mechanical seal

• The complete seal assembly drawings and instructions should be carefully studied before

starting installation.

• All burrs and sharp edges should be removed from the shaft or shaft sleeve including sharp

edges on key-ways and threads. Worn shaft or sleeves should be replaced.

• The stuffing’s box bore and stuffing box face should be checked to ensure that they are clean

and free of burrs.

• The shaft or shaft sleeve should be marked with various reference marks required for

installation of seal as per assembly drawings.

• The shaft or sleeve should be oiled lightly prior to seal assembly to allow the seal parts to

move freely over it.

• The rotary units should be installed on the shaft or sleeve in proper sequence.

• The back of the collar should be set at the proper distance from the original reference mark

on the shaft or sleeve. Tighten all set screws firmly and evenly.

• The seal faces should be wiped clean and a thin oil film applied prior to completing the

equipment assembly.

• The gland ring should be inserted with insert over the shaft carefully. Complete the

equipment assembly taking care when compressing the seal into the stuffing box.

• The gland ring and gland ring gasket should be seated to the faces of the stuffing box by

tightening the nuts or bolts evenly and firmly enough to affect a seal at the gland ring gasket.

8.20.5 Rotating equipment (Den & Mixture)

• Maintenance work on any rotating equipment should be started only after obtaining the work permit from the concerned department. Ensure that the equipment is electrically isolated.

• During opening of equipment such as pumps and compressors, it is a good practice to treat

the equipment as if it were under considerable pressure even though all steps have been

taken to relieve the pressure.


[8-47]

• Vehicle entry permit should be obtained from the concerned authority before bringing any crane or

any other equipment for removing the pump.

8.20.6 Inspection of storage tanks

• Inspection of tanks during fabrication shall be carried out as per the requirements of the

applicable codes, specifications, drawings etc. This inspection requires regular checks on

the work at various stages as it progresses. During fabrication, a thorough visual check

should be undertaken and the tank should be checked for foundation pad and slope, slope of

the bottom plates, proper welding sequence and external & internal surfaces etc.

• Roof plates shall be inspected for defects like pin holes, weld cracks, pitting etc., at water

accumulation locations

• Tanks pads shall be visually checked for settlement, sinking, tilting, spalling, cracking and

general deterioration

• Anchor bolts wherever provided shall be checked for tightness, and integrity by hammer

testing.

• All open vents, flame arrestors and breather valves shall be examined to ensure that the wire

mesh and screens are neither torn nor clogged by foreign matter or insects.

• If a tank is insulated, the insulation and weather proof sealing shall be visually inspected for

damage

• Grounding connections shall be visually checked for corrosion at the points where they enter

earth and at the connection to the tank.

• The tanks shall be inspected for any obvious leakage of the product. Valves and fittings shall

be checked for tightness and free operations.

• The tanks shell shall be visually examined for external corrosion, seepage, cracks, bulging

and deviation from the vertical.

8.20.7 Pipes, valves and fittings

• The inspection of piping during fabrication shall be carried our as per the requirement of

applicable codes, specifications, drawings, etc. This inspection requires regular checks on

the work at various stages as it progresses. The inspection shall include Identification and


[8-48]

inspection of material, approval of welding procedures in accordance with code and tender

requirement, carrying out of performance qualification test and hydrostatic testing.

• Visual inspection shall be made to locate leaks. Particular attention should be given to pipe

connections, the packing glands of valves and expansion joints.

• Pipe supports shall be visually inspected for condition of protective coating or fire proofing if any. If fireproofing is found defective, sufficient fireproofing should be removed to determine extent of corrosion.

• If vibrations or swaying is observed, inspection shall be made for cracks in welds,

particularly at points of restraint such as where piping is attached to equipment and in the

vicinity of anchors.

• Line shall be checked for bulging, bowing and sagging in between the supports.

• Conditions of paint and protective coating shall be checked.

• Pipelines shall be inspected for cracks. Particular attention should be given to areas near the

weld joints.

• Externally coverts lined piping shall be visually inspected for cracking and dislodging of

concrete.

• All piping, which cannot be checked on the run, shall be inspected during shutdown. These

are mostly high temperature piping. During shutdown inspection, hammer-testing and

hydrotesting as applicable should be carried out in addition to visual, ultrasonic and

radiographic inspections.

• Pipelines in some of the services like water, phenol and steam are prone to pitting corrosion.

Neither ultrasonic nor radiographic testing will reveal the actual internal condition of the

pipes in such service. In such cases samples shall be cut for thorough internal examination,

at scheduled comprehensive inspections. The samples shall be spilt open in two halves and

internal surfaces inspected for pitting, grooving, etc.

• Piping shall be opened at various locations by removing valves at flanged locations to permit

visual inspection. When erratic corrosion or erosion conditions are noted in areas accessible

for visual examination, radiographic examination or ultrasonic testing shall be performed to

determine thickness.


[8-49]

• The gasket faces of flange joints, which have been opened, shall be inspected visually for

corrosion and for defects such as scratches, cuts and grooving which might cause leakage.

Ring gaskets and joints shall be checked for defects like dents, cuts, pitting and grooving.

• Inspection shall be made for hot spots on internally insulated piping. Any bulging or scaling

shall be noted for further inspection when the equipment is shut down.

8.20.8 Hot Air Generator

At the time of fabrication:

Inspection of new Hot Air Generator at the time of fabrication shall be done as per applicable

codes and statutory requirements and shall include the following:

• Study of the tender document and all the technical specifications.

• Identification and inspection of the materials.

• Approval of the welding procedures.

• Approval of welder’s performance qualification test.

• Check to ensure that the welding is carried out as per approved welding sequence and

procedures with approved electrodes and qualified welders.

• Inspection of the weld joints for proper quality during welding.

• Check for proper insulation over hot metal surfaces.

• Ensure high durability, tensile strength & resistivity to adverse condition.

At the time of operation:

• Hot air lines should be checked for any leakages from flanges, valves and fittings using

foam.

• The hot air generator and the blower should be checked for any abnormal noise and

vibrations.

• Internal inspection of hot air generator and its auxiliary equipment should be done regularly.

• Visual inspection for the external surface of shell column for pitting, corrosion and cracks

shall be done.


[8-50]

• Regular inspection & maintenance of air pollution control equipment like Bag Filter &

Multicyclone Separator attached to hot air generator should be done.

8.20.9 Pressure relieving devices

• All pressure relieving devices shall be bench tested for set pressure, blow down and leakage

as applicable prior to installation.

• The following inspection checks shall be carried out once in every six months for breather

valves on storage tanks - discharge opening should be checked for obstruction, flame arrestor

wherever provided shall be inspected for fouling, bird nests or clogging, element shall be

inspected for mechanical damage, deposits, scaling etc. and cleaned before onset of

monsoon, oil filled type liquid seal valve shall be inspected for oil level, fouling, bird nests,

foreign material etc. and free movement of pallet shall be checked.

• Visual inspection of different parts of safety valve shall be done after dismantling to check

the condition of flanges for pitting, roughening, decrease in width of seating surface etc.

8.21 EMERGENCY MANAGEMENT

8.21.1 Emergency Prevention

• Preparation of a Preventive Maintenance Schedule Programme covering maintenance

schedules for all critical equipments and instruments as per recommendations of the

manufacturers user manuals,

• Establishment of a computerized Failure Modes Effects and Criticality Analysis (FMECA) or

similar procedure to generate data on failures of critical equipments and instruments based

on mode wise failures and their criticality. This requires codification of equipments,

instruments and their modes of failure and their criticality. Consideration may be given to

the use of appropriate software for processing FMECA data for review of the Preventive

Maintenance Schedule and for improvement of the same to ensure critical failures,

• Establishment of a Non Destructive Testing (NDT) system as necessary. This may not be

feasible in-house but there are specialized organizations who undertake the work, and the

same may be used.


[8-51]

• Importantly, it is of great importance to collect and analyze information pertaining to minor

incidents and accidents at the site, as well as for recording near-misses or emergencies that

were averted. This information gives an indication of how likely or unlikely it is for the site

to face actual emergencies and what should be further done to prevent them from occurring.

• Establishment of an ongoing training and evaluation Programme, incorporating the

development of capabilities amongst employees about potential emergencies and ways and

means of identifying and averting the same. Most emergencies do not occur without some

incident or an abnormal situation. So there is always some time of few seconds to few

minutes to arrest an incident of abnormal situation from turning in to an emergency. This is

the role of the shift in-charge who is the incident controller (IC) along with his shift team.

• Material Safety Data Sheets (MSDS) or chemical information sheets (CIS) should be kept

handy.

• Fire and emergency alarms should be provided; alarm recognition training should be given to

every employee.

• Regular mock drills should be conducted on a specific potential disaster scenario as

determined through risk assessment study

• Safe operating procedures including safe emergency and normal shut down procedures and

safe maintenance procedures should be adopted.

• The roles and responsibilities of all responsible for the control of emergency should be

clearly defined.

• List of key personnel and authorities (including police, factory inspector, district magistrate,

state and central level authorities, experts, doctors, village leaders) along with their location

should be kept handy.

• Personal Protective Equipments (PPEs) and safety torches should be made available.

• Liaison with outside agencies, home guards and civic authorities for co-operation in

mitigating the emergency consequences.


[8-52]

8.22 EMERGENCY RESPONSE

8.22.1 Onsite Emergency Response

• Shut down and Isolation: Raising the alarm, followed by immediate safe shut down of the

power supply, and isolation of effected areas.

• Escape, Evacuation and Rescue: Safeguarding human lives at site by commencement of the

Emergency Evacuation and Rescue Plan. Ensuring that all personnel are accounted for and

carrying out a head count of persons evacuated. Notification and commencement of offsite

emergency plan in case offsite impacts are possible.

• Stopping the development of the emergency: Control or response to the emergency

depending upon its nature (fire, toxic release or explosion). Fire can be somewhat better

controlled through fire fighting, while toxic release impacts can be partially controlled

through proper communication with affected population. Impacts of explosions impacts can

not be controlled once they occur, hence efforts will require focusing on provision of relief

or control of secondary impacts (such as property damage or fires) resulting from explosions.

• Treatment of injured: First aid and hospitalization of injured persons.

• Protection of environment and property: During mitigation, efforts should be made to prevent

impacts on environment and property to the extent possible.

• Welfare of the personnel managing the emergency: Changeover, first aid and refreshments

for the persons managing the emergency.

• Informing and collaborating with statutory, mutual aid and other authorities including those

covered in the Local Crisis Group.

• Informing and assisting relatives of the victims.

• Informing the news and electronic media.

• Preserving all evidences and records: This should be done to enable a through investigation

of the true causes of the emergency.

• Investigation and follow up: This requires to be carried out to establish preventive measures

for the future and a review of the DMP & its annexure to fill up the deficiencies in the

emergency planning procedures.


[8-53]

• Ensuring safety of personnel prior to restarting of operations: Efforts require to be made to

ensure that work environment is safe prior to restarting the work.

8.22.2 Off-site Emergency Response Plan

An emergency may affect areas offsite of the works as for example, an explosion can scatter

debris over wide areas and the effects of blast can cover considerable distances, wind can spread

burning brands of gases. In some cases e.g. as the result of an explosion, outside damage will be

immediate and part of the available resources of the emergency services may need to be

deployed in the affected areas. In any case, the possibility of further damage may remain, e.g. as

the result of further explosion or by the effect of wind spreading burning brands of hazardous

material.

It will be necessary to prepare in advance simple charts or tables relating the likely spread of the

vapours cloud taking into account its expected buoyancy, the local topography and all possible

weather conditions during the time of release. It may also be desirable to install instruments

indicating wind speed and direction, which could be done jointly with surrounding industries.

8.22.3 Inspection of firefighting equipment and systems

• The internal and external surfaces of the cylinder body shall be coated with Zinc or lead-tin

alloy

• Material used for the cylinder shell shall be identified to ensure conformity with

manufacturing standard.

• Extinguisher (DCP Vessel) is prone to internal corrosion at the interface between the dry

powder top level and empty space; periodic inspection should therefore be undertaken.

• The shell of the DCP extinguisher shall be visually inspected externally once a month and

internally once every three months to check for any mechanical damage or corrosion.

• A DCP extinguisher body shall be removed from service and destroyed when it is corroded

or damaged to such an extent at repair is required, when the shell threads are damaged, when

it has failed in hydro testing or when the extinguisher has been exposed to high temperatures

due to proximity of fire.


[8-54]

• The internal coating and external painting shall be checked for damage/deterioration once in

three months.

• The safety valve shall be visually inspected for corrosion or damage once every three

months. The safety valve shall be bench tested at rated test pressure once every three years.

• All DCP extinguishers shall be permanently punched at the bottom ring with Manufacturer’s

name, year of manufacture, manufacturer’s Sr. No. and Inspectors stamp.

• Equipment, which will automatically detect heat, flame, smoke, flammable gases, or other

conditions likely to produce fire or explosion and cause automatic actuation of alarm and

protection equipment should be provided.

8.23 DETAILS OF THE SEPARATE ISOLATED STORAGE AREAS FOR TOXIC MATERIALS AND FLAMMABLE CHEMICALS. DETAILS OF FLAME PROOF ELECTRICAL FITTINGS AND OTHER SAFETY MEASURES PROPOSED

• The unit is not using any toxic or flammable material. Only Sulphuric acid is used which

is hazardous material. Unit has provided separate storage area for the same.

• As there is no any use of flammable liquid to be used as a raw material, no flame proof

electrical fittings needed.

• A toxic gas detector will be provided to identify any toxic gas to be released.

• One D.G. set will be provided for alternative power source.

8.24 CHECKLIST IN THE FORM OF DO’S & DON’TS OF PREVENTIVE

MAINTENANCE, STRENGTHENING OF HSE, MFG. UTILITY STAFF FOR

SAFETY RELATED MEASURES.


[8-55]

TABLE 8.8 CHECKLIST OF DO’S & DON’TS

Activity DO’s Don’ts

Mfg. Process

All pump motors are earthen -

Housekeeping of the plant is as per the prescribed norms. Floors, Platforms, staircases and passages are kept free from

any obstruction

- Don’t put any raw material /maintenance part other than its specified place.

All hazardous operations are explained to the workers. They are periodically trained on the hazardous processes. - Don’t use unskilled man power

All the equipments of the plants are periodically tested as per standard and results are documented. All equipments

undergo preventive maintenance schedule.

-

Transportation of raw material Transfer the minimum quantity of material as per requirement.

- Excess quantity should be avoided.

Charging solid material Charging of solid material by closed loop system only - Don’t charge directly.

Stored material Proper labeling shall be done -

Temperature and pressure instrumentation

Calibrated at every six month and maintain records. -

Employee working Monthly health inspection shall be carried out and maintain its records

-


[8-56]

8.25 COMPLIANCE STATUS OF THE EXISTING UNIT WITH RESPECT TO VARIOUS CONDITIONS GIVEN IN NOC (CTE) AND CONSENT OF GPCB.

Compliance report of CTE conditions is attached herewith as per Table 8.9

SR. NO. DESCRIPTION OF CONDITION COMLIANCE

STATUS

CORRECTIVE & PREVENTATIVE ACTION

TAKEN 1.0 Consent Order No. 31288 date of issue : 16/12/2008 Complied valid up to 03/09/2013

2.0 Production Capacity:

Sr. No.

Product Quantity (MT/MONTH)

1. Magnesium Sulphate 600 MT/month 2. Filler 60 MT/month

Complied

----

3.0 CONDITION UNDER WATER ACT 3.1 There shall be no disposal of industrial effluent from the manufacturing

process and other ancillary industrial operations.

3.2 The quantity of sewage effluent from the factory shall not exceed 1000 lit/day.

Complied ----

3.3 TRADE EFFLUENT 3.3.1 Sewage shall be disposed of through septic tank/soak pit system 4.0 CONDITIONS UNDER THE AIR ACT 4.1 There shall be no generation of flue gas emission from the manufacturing

activities and other ancillary industrial operation as you have submitted undertaking dtd. 09/07/2008 for no applicability of Air Act-.

Complied ----


[8-57]

4.2 There shall be no generation of process emission from the manufacturing activities and other ancillary industrial operation. You have submitted undertaking dtd. 09/07/2008 for no applicability of Air Act.

Complied.

--

4.3 The concentration of the following parameters in the ambient air within the premises of the industry shall not exceed the limits specified hereunder.

Parameter Permissible Limit,g/m3 SPM 200 SOx 80 NOx 80

RSPM 100

Complied.

--

4.4 The industry shall take adequate measures for control of noise levels from its own sources within the premises so as to maintain ambient air quality standards in respect of noise to less than 75dB(a) during day time and 70dB(A) during night time. Daytime is reckoned I between 6a.m. and 10 p.m. and nighttime is reckoned between 10 p.m. and 6 a.m.

Complied --

5.

GENERAL CONDITIONS

5.1 Any change in personnel, equipment or working conditions as mentioned in the consents form/order should immediately be intimated to this Board.

Complied If any change than we will intimate to the board.

5.2 Applicant shall also comply with the general condition given in Annexure-I. Partly Complied. We will try our best to comply it. 6. AUTHORISATION FOR THE MANAGEMENT & HANDLING OF HAZARDOUS WASTES Form-2 [See rule 3 (c) & 5 (5)]

6.1 Number of authorization: 31288, Date of issue : 16/12/2008

Complied


[8-58]

6.2 M/s. T. J. Agro Fertilizers Pvt. Ltd. is hereby granted and authorization to operate facility for following hazardous wastes on the premises situated S. No. 41, 42, Mahapura, Tal – Savli, Dist – Vadodara.

Sr. No. Waste Quantity Schedule

process No. Facility

1. Process Residue

60 MT/Year

7.2 Collection, storage, transportation, disposal at TSDF

2. Used Oil 150 Lit/Year

5.1 Collection, storage, transportation disposal by selling to registered reprocess.

3. Discarded Container

60000 nos./Year

33.3 Collection, storage, Decontamination

Complied

6.3 The authorization is granted to operate a facility for collection, storage, within the factory premises, transportation and ultimate disposal of Hazardous wastes at nearest authorized TSDF

Complied We will strictly comply all the conditions of H.W. authorization.

6.4 The authorization shall be in force for a period up to 03/09/2013. 6.5 The authorization is subject to the conditions stated below and such other

conditions as may be specified in the rules from time under the Environment (Protection) Act-1986.

6.6 TERMS AND CONDITIONS OF AUTHORIZATION 6.6.1 The applicant shall comply with the provisions of the Environment (Protection)

Act- 1986 and the rules made there under. Complied

--

6.6.2 The authorization shall be produced for inspection at the request of and officer authorized by the Gujarat Pollution Control Board.

Complied

--


[8-59]

8.26 DETAILS OF FATAL/NON-FATAL ACCIDENTS OCCURRED IN PAST IN THE EXISTING UNIT:

As per the records there is no fatal / non- fatal accidents reported since starting of the unit.

8.27 RECORDS OF ANY LEGAL BREACH OF ENVIRONMENTAL LAWS

Also there is no any legal breach of environmental laws in form of show cause, closure etc reported.


CHAPTER 9 ALTERNATIVES (TECHNOLOGY & SITE)

[9-1]

p

9.1 ALTERNATIVES:

During the scoping period, no necessity for the alternative analysis of the technology was observed as the technology/process mentioned for manufacturing of the proposed product are best suitable.

Moreover the unit is already running production of the existing product has enough space for expansion so the proposed site is best suitable for the manufacturing of the proposed product.


CHAPTER 10 ENVIRONMENTAL COST BENEFIT

[10-1]

10.1 ENVIRONMENTAL COST BENEFIT

During the study period it was revealed that the environmental cost benefit can’t be recommended at the scoping stage.


CHAPTER 11 SUMMARY & CONCLUSION

[11-1]

11.1 INTRODUCTION & PROJECT JUSTIFICATION

T. J. Agro Fertilizers Pvt. Ltd. is a private limited company formed in 1986. The promoters are

highly qualified and have global experience. T. J. Agro Fertilizers Pvt. Ltd. is one of the

renowned fertilizers trading and manufacturing organizations.

Proposed plant is located at Village-Mahapura, Taluka-Savli, Dist. Baroda (Gujarat). Unit is

producing Magnesium Sulphate (MgSO4) & Filler (by product) at above location from 2008.

To expand their business strength in middle of Gujarat, they intend to produce new products

namely NPK Granulated Mixed Fertilizers, Single Super Phosphate Powder, Single Super

Phosphate Granulated & Fluorosilisilic Acid (by product) in addition of old products.

For the manufacturing of the new products the company has applied for the Environmental

Clearance of the project under the latest Notification for EC. Form 1 was submitted to the Sate

Level Expert Appraisal Committee on dated 03.06.2010.

First Presentation for the Terms of Reference was conducted on the 28.09.2010 following

which the terms of reference were issued to us.

This report has been prepared based on the Terms of Reference vide the letter Project No. EIA-

10-2010-700-E, 63217 Dated 16.11.2010 issued to us by the SEAC committee.

The Total Investment for the proposed project will be 1.225 Crores.

Total area of the site is 30,831 m2

11.2 PURPOSE OF STUDY

Environmental Impact Assessment Report & Environmental Management Plan have been

Prepared for obtaining Environmental Clearance for T. J. Agro Fertilizers Pvt. Ltd. for the

proposed project for Manufacturing of Products- NPK Granulated Mixed Fertilizers, Single

Super Phosphate Powder, Single Super Phosphate Granulated & Fluorosilisilic Acid (by

product) in addition of old products.

M/s. T. J. Agro Fertilizers Pvt. Ltd. Envirocare Engineers & Consultant, Surat February-2011 CHAPTER 11 SUMMARY & CONCLUSION

[11-2]

11.3 EXTENT OF STUDY AND AREA COVERED

The baseline status of environmental quality in the vicinity of project site serves as the basis

for identification, prediction and evaluation of impacts. The baseline environmental quality is

assessed through field studies within the impact zone for various components of the

environment, viz. air, noise, water, land and socio-economic. The baseline environmental

quality has been assessed in the winter season (December 2010 – February 2011) in a study

area of 10 km radial distance from the project site.

11.4 METHOD OF STUDY

The study is based on guidelines of MoEF and identifies the nature of activities involved and

their impacts caused on various environmental parameters. It subsequently suggests mitigation

measures to be executed for safeguarding against any environmental degradation. Finally, it

suggests methods of implementing the environmental management plan.

11.5 PROJECT DETAILS

The product proposed to be manufactured along with their capacities is shown in following

Table 11.1.


[11-3]

TABLE 11.1 PROPOSED PRODUCT LIST:

The Raw material proposed to be used along with their consumptions is shown in following

Table 11.2.

Sr. No. Name of Products

Existing Quantity

(MT/Month)

Proposed Quantity

(MT/Month)

Total Quantity

(MT/Month)

1. NPK Granulated Mixed Fertilizers Nil 6,000 6,000

2. Single Super Phosphate Powder Nil 10,000 10,000

3. Single Super Phosphate Granulated Nil 6,000 6,000

4. Fluoro Silisilic Acid (by product) Nil

Total : 340 120 Reuse : 220

Sale : 120

5. Magnesium Sulphate (MgSO4) 600 Nil 600

6. Filler (by product) 60 Nil 60


[11-4]

TABLE 11.2 PROPOSED RAW MATERIAL LIST

11.6 ENVIRONMENTAL SETTING

11.6.1 Landuse of the study area:

Landuse within 10 km radius of the study area is determined with the help of satellite image.

Landuse of study area can broadly be classified in to categories such as habitation, habitation

with dense vegetation, water body, vegetation, land with shrub, land without shrub, industrial

area, sandy area and agricultural land etc.

Sr. No. Name of Raw Material

Existing Quantity

(MT/Month)

Proposed Quantity

(MT/Month)

Total Quantity

(MT/Month) (A) NPK Granulated Mixed Fertilizers

1. Urea Nil 2760 2760 2. DAP Nil 360 360 3. SSP (Single Super Phosphate) Nil 480 480 4. MOP (Potash) Nil 1626 1626 5. Filler Nil 1800 1800

(B) Single Super Phosphate Powder 6. Fluorosilisilic Acid Nil 220 220 7. Rock phosphate Nil 6000 6000 8. Diluted sulphuric acid (70%) Nil 3000 3000 9. Concentrated sulphuric acid (98%) Nil 1562.5 1562.5

(C) Single Super Phosphate Granulated 10. Single Super Phosphate Powder Nil 6000 6000

(D) Magnesium Sulphate (MgSO4)

11. Diluted Sulphuric acid (70%) 375 Nil 375

12. Light Calcined Magnasite 150 Nil 150


[11-5]

11.6.2 Climate of the Study Area:

The general agro-climatic zone of the study area is Semi- arid.

11.6.3 Wind:

The predominant wind direction during the study period is observed to be from NE direction.

11.6.4 Rainfall:

The total rainfall in year is observed to be 922.7 mm. Distribution of rainfall by season is 7.5

mm in winter (December, January, February), 7.5 mm in summer (March, April, May), 870.8

mm in monsoon (June, July, August, September) and 38.2 mm in post monsoon (October,

November).

11.6.5 Cloud Cover:

The area remains cloudy between June-September, which is the active period of the monsoon

season. Generally cloud cover ranges from 4 to 7 Oktas during this monsoon season.

11.6.6 Humidity:

Most humid conditions are found in the monsoon, followed by post monsoon, winter and

summer in the order. Mornings are more humid than evenings and humidity ranges from a high

of 76-90% in monsoon mornings to a low of 20-27% in summer evenings. During post

monsoon season, in morning humidity remains between 64-72 % and in the evening it remains

between 41-44 %.

11.7 FUEL/ENERGY REQUIREMENTS

• The main sources of power of M/s. T. J. Agro Fertilizers Pvt. Ltd. will be utilized energy from existing provider M/s. Madhya Gujarat Vij Company Limited. The total existing connected load of the energy is about 80 HP.

• Additional 600 HP will require for expansion project which would be applied to MGVCL as & when required.

• Fuel for Hot air Generator 1& 2 : Bio Coal @ 16 MT/ day.

• Fuel For Proposed DG Set 125 KVA : HSD – 15 Liters/hr


[11-6]

11.8 WATER REQUIREMENT

• Total Water Requirement: 32.5 KL/day

• Source: Borewell

• Wastewater Generation: Domestic: 2.5 KL/day

Industrial: Nil

TABLE 11.3 (A) TOTAL WATER REQUIREMENTS FOR THE PROJECT:

Categories Existing (KL/day)

Proposed (KL/day)

Total (KL/day)

(A) Domestic 1.0 3.0 4.0

(B) Industrial

(i) Process 7.0 16 23

(ii) Utility (For scrubber )

-- 05 05

(iii) Washing 0.5 -- 0.5

Total (B) 7.5 21 28.5

Total (A+B)

8.5 24 32.5

TABLE 11.3 (B) TOTAL WASTEWATER GENERATIONS FOR THE PROJECT:

Categories Existing (KL/day)

Proposed (KL/day)

Total (KL/day)

(A) Domestic 1.0 1.5 2.5

(B) Industrial

(i) Process Nil Nil Nil

(ii) Utility -- -- --

(iii) Washing -- -- --

Total (B) Nil Nil Nil

Total (A+B) 1.0 1.5 2.5


[11-7]

11.9 BASELINE ENVIRONMENT

Has been displayed in Chapter No. 3 of the EIA Report

11.10 ENVIRONMENT IMPACTS & MITIGATION MEASURES

Has been displayed in Chapter No. 4 of the EIA Report

11.11 ENVIRONMENTAL MONITORING PROGRAMME

TABLE 11.4 ENVIRONMENTAL MONITORING PROGRAMS

Sr. No.

Activity Schedule

Water Pollution Monitoring 1. Ground water quality of borewell within premises Once in six month

Air Pollution Monitoring 2. Ambient air monitoring of parameters specified by GPCB

in their air consents from time to time within the T.J Agro Fertilizers Pvt. Ltd. premises

Once every Quarter

3. Ambient air monitoring of parameters specified by GPCB in their air consents from time to time at four stations outside T.J Agro Fertilizers Pvt. Ltd. premises .

Once every season at each station

4. Stack monitoring of process as given in air consent from time to time

Once every month

Solid Waste Generation Monitoring / Record Keeping 5. Records of generation of used drums, bags and records of

their dispatch to suppliers for refilling Daily

6. Records of generation of waste oils and their treatment Daily 7. Records of generation, handling, storage, transportation

and disposal of other solid, aqueous and organic hazardous wastes as required by hazardous waste authorization

To be updated daily

Environmental Audit & Annual Return 8. Environmental statement under the EP (Act) 1986 and

annual return of hazardous waste generation, handling & disposal.

Once in a year


[11-8]

11.12 AMBIENT AIR

The source of Flue gas Emission from the proposed production activity is from Hot air

Generator. For Hot air Generator Bio Coal will be used as fuel.

Flue gas will be released through stacks of 11 m height. The Hot air Generator will be

provided with Multi Cyclone Separator & Bag Filter.

Another Source is Den & Mixer exhaust gas which will be provided with Ventury Water

Scrubber followed by rock phosphate absorption tank to scrub H2SiF6

Stack Attached To

gas. Hence, it can be

concluded that the production activities will not adversely impact the ambient air quality.

TABLE 11.5 (A) PROPOSED DETAILS OF STACK, APCS & ITS EMISSION

ESTIMATE

Height & Top Dia. of Stack

Type of Fuel & Qty. Proposed Air Pollution

Control System

Final Concentration

Existing

Proposed

Hot Air Generator

1 & 2

11 Meter &

500 mm

Nil Bio Coal

16 MT/Day Multi Cyclone

Seperator & Bag Filter

in series

SPM < 150 mg/NM3

SO2 < 100 ppm NOx < 50 ppm

D. G. Set (Stand By)

(Capacity: 125 KVA)

8 Meter Nil HSD 15 Lit/hr

Not Applicable

SPM < 150 mg/NM3

SO2 < 100 ppm NOx < 50 ppm

TABLE 11.5 (B) PROPOSED EMISSION RATE

Sr. No. Stack Attached to Parameter

Emission Estimate in Kg/hr Existing Proposed Total

1. Hot Air Generator 1&2

(Flow: 3000 M3

PM

/Hr.)

Nil 0.225 0.225

SOx Nil 0.15 0.15

NOx Nil 0.075 0.075


[11-9]

TABLE 11.5 (C) PROPOSED DETAILS OF PROCESS VENT, APCS & ITS EMISSION

ESTIMATE

Process Vent Attached To

Height & Top Dia. of Stack

Air Pollution Control System Final Concentration

Den & Mixture 35 Meter &

600 mm

Ventury Water Scrubber

SPM < 150 mg/NM3

SO2 < 40 mg/NM3 NOx < 25 mg/NM3

Fluorine < 0.5 mg/NM3

TABLE 11.5 (D ) PROPOSED EMISSION RATE

Sr. No. Stack Attached to Parameter

Emission Estimate in Kg/hr Existing Proposed Total

1. Den & Mixture (Process Vent)

(Flow: 7500 M3

PM

/Hr.)

Nil 0.40 0.40

SOx Nil Nil Nil

NOx Nil 0.05 0.05

HF Nil 0.01 0.01

Fluorine Gas Nil 0.001 0.001

The ambient air quality monitoring was carried out in accordance with guidelines of Central

Pollution Control Board (CPCB) of June 1998 and National Ambient Air Quality Standards

(NAAQS) of CPCB of November 2009. Ambient Air Quality Monitoring (AAQM) was carried

out at five locations during winter season. The maximum numbers of sampling locations were

selected close to the project site and in the study area of 10 km radial distance around the plant

site. The monitoring was carried out 24 hours a day twice a week per location in the study area

except the project site, where continuous monitoring was carried out. Twelve numbers of

observations were taken at each monitoring location except the project site.

The conventional and project specific parameters such as PM10, PM2.5, SO2, NOx & HF were

monitored at site.

The values for mentioned concentrations of various pollutants at all the monitoring locations

were processed for different statistical parameters like arithmetic mean, minimum

concentration, and maximum concentration and percentile values.


[11-10]

11.13 WATER RESOURCES

Water will be used from Existing Bore wells in the premises. No new bore wells are to be dug.

Rain water recharging scheme will be incorporated hence the impact on ground water will be

minimized.

11.13.1 Ground Water Quality

• The unit is a Zero Discharge Unit. Sewage will be allowed in Septic Tank.

• M/s. T.J.Agro Fertilizers Pvt. Ltd. will take all precautions to make its solid waste areas impervious to water and leachate migration.

Hence it follows that ground water quality is not adversely impacted by M/s. T. J. Agro

Fertilizers Pvt. Ltd. activities.

11.14 NOISE LEVELS

Noise levels envisaged shall be within prescribed limits of GPCB at plant boundary, after

implementation of the mitigation measures. DG Sets will be Acoustically Enclosed type. Green

belt development will be made. Hence there will be no adverse impacts on existing noise levels

due to the proposed production activities.

11.15 SOIL / LAND QUALITY

M/s. T. J. Agro Fertilizers Pvt. Ltd. will take all precautions to make its Raw Material Storage,

Product Storage, hazardous waste and effluent storage / treatment areas impervious to water

and leachate migration. This will prevent soil contamination.

It follows that soil quality will not be adversely impacted by proposed production activity.

11.16 ENVIRONMENTAL MANAGEMENT PLAN

An environment management plan has been proposed in this report to implement the mitigation

measures. The plan will ensure that the adverse environmental impacts are minimized and the

beneficial impacts are maximized. Detailed plan is discussed in Chapter No-8 of EIA report.


CHAPTER 11 SUMMARY & CONCLUSION

[11-11]

11.17 SOLID & HAZARDOUS WASTE MANAGEMENT

The details of the solid and hazardous waste management is as given in the Table 11.6

TABLE 11.6 SOLID AND HAZARDOUS WASTE MANAGEMENT REQUIREMENT:

Sr. No. Waste Stream

Waste Cat. No.

As per- 2008

Existing Qty.

Proposed Qty.

Total Qty. Source Method of

Packing Disposal Method

1. Used oil

5.1 150 Lit/year

50 Lit/year

200 Lit/year

Air Compressor

PP Carba / Drum

Collection, Storage, Transportation and disposal by selling to registred refiners enlisted by GPCB / MoEF.

Qty. to be Reused

100 Lit/year Qty. to be Disposed

100 Lit/year 2. Discarded

containers / barrels / Liner

33.3 60 Kg/month

240 Kg/month

300 Kg/month

Raw material & Finished

product packing material

PP Bag Collection, Storage, Transportation and disposal by selling to registred refiners enlisted by GPCB / MoEF.

Qty. to be Reused

150 Kg/month Qty. to be Disposed

150 Kg/month 3. Silica / Sand -- Nil 10

Kg/month 10

Kg/month Process PP Bag Collection, Storage &

Reuse as Filler in product


[11-12]

11.18 GREEN BELT DEVELOPMENT

Total plot area of the project is 30,831 m2. Greenbelt & Plantation is proposed in approximately

12% of the plot area. Hence the total Proposed Green Belt will be 3719 m2

• Due to the plant operation no adverse impacts envisaged on Ambient Air, Noise, Ground

water, Land & Soil.

. This development

has been already started. This will attune noise levels and dust levels by acting as a barrier

between the outside environment and the inside environment of the premises.

11.19 MONITORING SCHEDULE

A monitoring schedule has been prepared to ensure effectiveness of the environmental

management plan.

11.20 EXPENDITURE FOR ENVIRONMENTAL ACTIVITIES

M/s. T. J. Agro Fertilizers Pvt. Ltd. will spend Approximately Rs. 23.0 Lacs as capital expenditure on environmental management. The recurring cost is Approximately Rs. 4.75 lacs per annum.

11.21 CONCLUSION

The following can be concluded based on the study:

• Risk to soil is negligible due to effective management and handling of hazardous wastes

and wastewater.

• Socio-economic benefits due to generation of direct / indirect employment.

Thus, it can be concluded on a positive note that after the implementation of the mitigation

measures and Environmental Management Plan the activities of M/s. T. J. Agro Fertilizers Pvt.

Ltd. will have negligible impact on environment and will beneficial to the nearby residents.


CHAPTER 12 DISCLOSURE OF CONSULTANTS ENGAGED

[12-1]

12.1 CONSULTANT ENGAGED

M/s. T. J. Agro Fertilizers Pvt. Ltd. has engaged M/s Envirocare Engineers & Consultant as an

EIA consultant.

12.2 BRIEF PROFILE OF CONSULTANT

M/s. Envirocare Engineers & Consultant (EEC) is one of the leading firms in the field of

environment since last 13 years. EEC is enlisted with Gujarat Pollution Control Board (GPCB)

as well as with Rajasthan Pollution Control Board as Consultant and schedule II auditors.

Acquainted with well experienced and knowledgeable staff EEC accomplished various turnkey

projects, Environmental Monitoring projects as well various EIA Projects of various well

renowned companies as well as various small scale industries. Moreover EEC is engaged with

various consultancy works as well as audit works.

12.3 SCOPE OF WORK

M/s. T. J. Agro Fertilizers Pvt. Ltd. has engaged EEC for studying the Environmental Impact

Assessment of its proposed project at R.S. NO: 41/42, P.O. Mahapura, Tundav Rania Road,

Taluka Savli, District Vadodara of Gujarat State. The scope of work includes study of current

environment status with environmental monitoring, assessing the impact of project on

environment and preparation of EIA report along with technical assistance work consideration

for the approval of the project from the state Level Expert Appraisal Committee.

Compliance of the CREP Guidelines SR. NO. CREP GUIDELINES OUR COMPLIANCE

Wastewater Management 1 Efforts will be made for conservation of water, particularly

with a target to have consumption less than 8.12 and 15 m3 /tone of urea produced for plant based on gas, naphtha and fuel oil, respectively. In case of plants using Naptha and Gas both as feed stocks, water consumption target of less than 10m3

Not Applicable

/ tone will be achieved. An action plan for this will be submitted by June 2003 and targets be achieved by March 2004.

2 Use of arsenic for CO2 Not Applicable absorption in ammonia plants and chromate based chemicals for cooling system, which is still continuing in some industries, will be phased out and replaced with non- arsenic and non- chromate systems by December 2003. In this regard, action plan will be submitted by June 2003.

3 Adequate treatment for removal of oil, chromium (till non- chromate based cooling system is in place) and fluoride will be provided to meet the prescribed standards at the source (end respective process unit) itself. Action plan will be firmed up by June 2003 for compliance by March 2004.

Not Applicable

4 Proper and complete nitrification and de-nitrification will be ensured wherever such process used for effluent treatment, by September 2003.

Not Applicable

5 Ground water monitoring around the storage facilities and beyond the factory premises will be carried out at regular intervals particularly for pH. Fluoride CPCB will finalize the guidelines for groundwater monitoring by December 2003.

Pucca RCC flooring is provided to prevent any percolation of any hazardous contamination. Ground Water Monitoring will be done as per Scheduled of Monitoring Proposed in EIA report Chapter No: 5 Page No.5-6.

Compliance of the CREP Guidelines

6 No effluent arising from process plants and associated facilities will be discharged to the storm water drain. The quality of storm water will be regularly monitored by all the industries.

Strictly Complied Storm water monitoring will be carried out. Unit does not generate any trade effluent.

7 The industries, where waste water/ effluent flows through the storm water drains even during the dry season will install continuous systems for monitoring the storm water quality for pH, ammonia and fluoride. If required, storm water will be routed through effluent treatment plant before discharging. An action plan will be submitted by June 2003 and necessary action will be taken by June 2004.

Not Applicable Unit does not generate any trade effluent

Air Pollution Management 1 All the upcoming urea plants will have urea prilling towers

based on natural draft so at to minimize urea dust emissions.

Not Applicable

2 The existing urea plants particularly, the plants having forced draft prilling towers will install appropriate systems (e.g. scrubber. etc.) for achieving existing norms of urea dust missions. In this regard, industries will submit action plan by June 2003 and completion of necessary actions by June 2004.

Not Applicable

3 The sulphuric acid plants having SCSA system will switch over to DCDA system by March 2004 to meet the emission standard for SO2 as 2 Kg/tone of H2SO4

Not Applicable

produced. An action plan for this will be submitted by June 2003.

4 Sulphuric acid plants having DCDA system will improve the conversion and absorption efficiencies of the system as well as scrubbers to achieve SO2 emission of 2 Kg/ tone of acid produced in case of plants having capacity above 300 TPD and 2.5 Kg/ tone in case of plants having capacity up to 300TPD. An action plan will be submitted by June 2003 and emission

Not Applicable

Compliance of the CREP Guidelines levels will be complied with by September 2004.

5 Stack height for sulphuric acid plants will be provided as per the guidelines and on the basis of normal plant operations (and not when the scrubbers are in use) by June 2003. The scrubbed gases are to be let out at the same height of the stack.

Not Applicable

6 An action plan for providing proper dust control systems rock phosphate grinding unit in phosphoric acid plants/ single super phosphate plants, so as to achieve particulate emission of 150 mg/Nm3

• A Dry dust Type Bag Filter will be installed to recover Phosphate dust & reuse it again in Process. Ventury water scrubber followed by Dry Rock Phosphate bed will be installed to minimize the concentration of H

will be submitted by September 2003 and complied with by March 2004.

2SiF6.

7 Particulate as well as gaseous fluoride will be monitored and adequate control systems will be installed by June 2004 to achieve the norms on total fluoride emissions (25 mg/Nm3

• Particulate & Gaseous fluoride monitoring will be done as per Scheduled of Monitoring Proposed in EIA report Chapter No: 5 Page No.5-6. ).

8 Continuous SO2 Not Applicable emission monitoring systems will be installed in sulphuric acid plants (having capacity 200 TPD and above) by March 2004. Action plan for this will be submitted by June 2003.

9 Regular monitoring of ambient air quality with regard to SO2 NOx, PM, SO3

Regularly Ambient Air Monitoring will be will be done as per Scheduled of Monitoring Proposed in EIA report Chapter No: 5 Page No.5-6.

, fluoride and acid mist will be carried out.

Solid Waste Management 1 Gypsum will be effectively managed by providing proper

lining, dykes with approach roads and monitoring of groundwater quality around storage facilities. Accumulated gypsum will be properly capped. In this regard, action plan will be submitted by June 2003 and for compliance by December 2003.

Not Applicable

Compliance of the CREP Guidelines

2 An action plan for proper handling, storage and disposal of spent catalyst having toxic metals will be submitted by June 2003 and implemented by September 2003. The industry will also explore recovery/buy-back of spent catalyst by September 2003.

Not Applicable

3 Carbon slurry, sulphurmuck and chalk will be properly managed and disposed of in properly designed landfill either within premises or in common facility. Action plan on this will be submitted by June 2003 and implemented by March 2004.

Not Applicable

4 Existing stock of chromium and arsenic bearing sludge will be properly disposed by December 2003. Industries will also explore recovery of chromium from the sludge. CPCB will provide guidelines for proper disposal of the sludge.

Not Applicable

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