RSPL LIMITED

Executive Summary of

Draft EIA/EMP Report for the Proposed Soda Ash Plant (1500 TPD Light Soda Ash & 770 TPD Dense Soda Ash) with Coal/Lignite based Captive Power Plant (50 MW)

At:

Village Kuranga, Taluka Dwarka,District Devbhumi Dwarka,

Gujarat

Prepared By:

Council of Scientific and Industrial Research (CSIR)

National Environmental Engineering Research Institute (NEERI) Nehru Marg, Nagpur 440 020 (Maharashtra)

December 2013

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1 Introduction M/s. RSPL Ltd. (RSPL) is a North India based reputed Company (registered office at Kanpur, U.P.) and is in the business of Detergent, Soaps, Leather Products and Milk Products (GHARI DETERGENT GROUP). The companys products are well accepted and appreciated by market because of consistent quality and timely delivery. It has about 27 detergent manufacturing units in various states of India with employee base of above 15000 Nos.

The company is the largest producer of Detergent Powder and Detergent Cake with a market share of 16%. Soda Ash being major raw material for detergent; a conscious strategic decision has been taken to diversify in the field of Heavy Chemicals i.e. Soda Ash for controlling the quality and cost of raw materials of detergent.

RSPL is proposing to set-up a Greenfield Soda Ash Plant (Light Soda Ash 1500 TPD and Dense Soda Ash 770 TPD) along with Captive Power Plant (50 MW) near village Kuranga, Taluka Dwarka, District Devbhumi Dwarka, Gujarat. The estimated cost of the project is Rs. 1800 Crores.

The proposed Soda Ash Plant falls under category A project and is listed at serial no. 4(e) where as Captive Power Plant is category B project and is listed at serial no. 1(d) of schedule of EIA Notification, 2006. Hence requires Environmental Clearance from Ministry of Environment & Forests, New Delhi. The proposed project also attracts CRZ Clearance under CRZ Notification, 2011 for sea water intake and effluent disposal facilities into the Arabian sea which is nearby the project site. The seawater intake and effluent disposal pipelines in the proposed project may pass through the forest area for which Forest Clearance may be required under Forest (Conservation) Act, 1980 and its subsequent amendments for right of use/right of way (ROU/ROW). Further, Gaga Wildlife Sanctuary is located within the 10 km radius of study area and hence requires National Board of Wildlife (NBWL) approval under Wildlife (Protection) Act 1972 and its subsequent amendments.

1.1 Location of Project The project is being planned near village Kuranga, Taluka Dwarka, District Devbhumi Dwarka, (earlier District Jamnagar), Gujarat State (Fig 1.1). The topographical features of the study area within 10 km stretch from the proposed plant boundary are shown in Fig 1.2. The total plot area is a combination of Government Wasteland and Private Agricultural land (mostly un-irrigated) considered has total area of around 576 Ha. (1423 acres). However effective area after observing the Environmental sitting criteria is worked out as about 400 Ha. (1000 acres). The proposed project land is well beyond 500 m of the High Tide Line (HTL) which is in compliance with CRZ regulations. The nearest Kuranga Railway station (abandoned) is located at a distance of 2.0 km (aerial distance).

1.2 Production Capacity The proposed project aimed to produce light soda ash (1500 TPD) and dense soda ash (770 TPD) with Captive coal/lignite based power plant (50 MW) and allied facilities like RO/DM plant, raw material handling, sea water intake and effluent outfall pipelines and emergency DG sets. The production capacity of the proposed project is given in Table 1.1:

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Table 1.1 Soda ash Production capacity and other facilities

Sr. No.

Product Name Proposed Production Capacity

1. Soda Ash Light Soda Ash Dense Soda Ash (Dense Soda Ash is conversion of Light Soda Ash)

1500 TPD 770 TPD

2. Power Steam (CFBC boilers)

50 MW 150 TPH x 3 Nos.

3. Emergency DG Set (total no. of sets can be 2/3) 6 MVA

Fig 1.1: Map Showing the Project Location

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Fig.1.2: Study area map of the project site (10 km radius)

The major raw materials required for soda ash production are solar salt

and chemical grade limestone. Other raw materials are ammonia, sodium sulfide, coal/coke. For Captive Power Plant (CPP), lignite and/or coal will be used as the fuel. Further, a very stable utility i.e. Steam, Power, Air, large amount of Cooling water (Seawater) and Process Water (Sweet Water) are the essential requirement. The seawater required for the plant of around 6 x 105 m/d shall be sourced through adequately sized Seawater Intake system from Arabian Sea. Approximate requirement of treated / process water, for various purposes is approx. 15000 m3/d for soda ash plant and associated facilities.

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1.3 Manufacturing Process Soda Ash: Solvay process also known as ammonia soda process was developed in 19th century and has been developing using for the past 140 years. The important Process steps are Brine Preparation & Purification, Lime Kilns and gas cleaning, Lime Grinding, Absorption & Distillation, Carbonation and Compression, Filtration & Calcinations, Densification of Soda Ash, Product storage & handling.

Captive Power Plant: CFBC technology based boilers is adopted for the proposed captive power plant. The turbo-alternators will be double extraction cum condensing type. Lignite/Coal will be used as Fuel. Initial startup power will be by setting up of 66.0 KV substation with Gujarat Electricity Board grid connection.

2 Baseline Environmental Quality The baseline environmental quality has been carried out between November-2012 to January 2013 in the study area of project site for various environment components namely air, water, land, soil, ecology and socio-economics.

2.1 Ambient Air Quality The PM10 concentration range was 33-69 g/m while PM2.5 levels

were in the range of 12-39 g/m during the study period. The particulate matter concentrations observed were below stipulated standards of NAAQS (24 h; PM10=100g/m3 and PM2.5=60g/m3).

The concentrations of SO2 and NOx were observed in the range of 8-21 g/m3 and 12-23 g/m3 during study period respectively. The levels were below the stipulated CPCB standards (24 hourly SO2 is 80 g/m3 and for NOx is 80 g/m3).

The concentration of total hydrocarbons was ranged between 1.06 -1.33 mg/m3 during study period.

The observed concentration range of benzene was between 0.16-0.32 g/m3 during study period; which is below the NAAQS 5 g/m3.

2.2 Noise Quality The equivalent noise levels of villages varied in the range of

45-65 dB (A) and 34-53 dB(A) during day and night, respectively.

Noise levels in residential areas are observed between 46-58 dB (A) in day time and 34-44 dB (A) in night time. The noise levels during day and night were below the stipulated noise levels in residential areas except Bhatiya due vehicular traffic (day time= 55 and night time 45 dB (A)).

Noise levels in commercial zone, silence zone and Industrial zone were within the CPCB standards for respective areas.

2.3 Water Quality To determine the water quality, six surface water samples and four ground water samples were collected from the study area. In addition, one coastal water sample was also analyzed. The important findings are listed below:

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The physico-chemical characteristics of surface water was pH 7.1-8.4, turbidity

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The zooplankton standing stock in terms of biomass (0.04-1.4 ml/100m3) and population (0.3 - 19.6 10 no/100m3) was indicative of an overall moderate secondary production and varied widely.

The intertidal area was investigated for the presence of corals. The seawater intake system corridor is free from corals. Isolated corals namely Porites compressa, Favia Favus and Zoanthus sp. reported. Live turtles and eggs were not sighted during the visit. Transect VI was free from corals. Assessment by remote sensing study did not reveal presence of corals in the pipeline corridors including the subtidal area.

An intake system with a submarine pipeline has been proposed for drawing seawater from the sea. Seawater intake site at two locations was studied at IT1 & IT2. In both the cases the impact of the tide regime is similar, insignificant and limited to small well defined area around the intakes. The location IT1 is recommended on the basis of minimal area and volume of excavation required to lay the pipeline and consequent reduction in the benthic losses.

Effluent disposal was studied at two sites i.e. OF1 and OF2. The effluent if released at OF1/OF2, the levels of critical parameters namely temperature, SS and ammonia in the effluent around the location and small central patch attain the ambient levels within 300m (max) from the outfall. The output clearly shows that behavior of the effluent released at OF1 and OF2 was similar. Presence of soft mud at OF1and OF2 negates the possibility of presence of sub tidal corals. Hence both the location OF1 and OF2 are recommended suitable for the effluent release.

Based on modeling studies, it can be concluded that there will not be significant impact due to intake facilities and will be limited to small well defined area around intake. Further, due to outfall facilities water quality of the coastal area off Kuranga would not deteriorate w.r.t. temperature, salinity and ammonia except in the immediate vicinity of the outfall. The impacts of proposed development, mitigation measures and the recommendations for the general monitoring of the area and the parameters to be monitored are incorporated in detailed Marine EIA/EMP report.

2.5 Soil Quality Nine (09) sampling locations were taken for soil quality assessment. Physical characteristics of soil are delineated through specific

parameters, viz., particle size distribution, texture, bulk density, porosity and water holding capacity.

The texture of the soil is clay and clayey loam. The clay contain in the soils of the study area varies from 38-52%.

The soil being of friable consistency, the bulk density of the soil is in the range of 0.96 to 1.13 g/cm whereas the porosity and water holding capacity are in the range of 47.1- 51.1% and 48.2-53.4% respectively.

The pH of the soil in the study area is slightly to moderately alkaline, having pH in the range of 6.4-7.9. Electrical Conductivity of the soil extract in the study area ranges from 0.15-0.36 dS/m.

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Organic carbon, available nitrogen, phosphorous and potassium of the soil samples are found to be in the range of 0.1-0.16%, 11.5-30.7, 34.3-71.5 and 119.4-161.5 kg/ha respectively. The soil in the study area has poor fertility level with respect to available nitrogen and phosphorus but the soil with respect to available potassium comes under poor to medium level.

2.6 Ecology To study ecology, the field observations were taken in villages, forest

area, Gaga Wildlife Sanctuary and non-forest area (agriculture field, plain area, village wasteland etc.) in the study area. Additionally, secondary data for this study area was collected from Forest and other departments of State Government.

The proposed site falls in the semi-arid climatic condition. It is represented by sparse thorny scrub vegetation in between the fallow agriculture land. The major part of the project area is devoid of large trees and mainly consists of scattered and sparse shrubs i.e. Prosopis juliflora, Euphorbia neriifolia, Casia auriculata and Zizyphus numularia.

Field survey suggests that there are no endangered, endemic, rare plant species present within the project boundary.

Total species of reptiles, birds and mammals identified were 6, 56 and 8 respectively in project site whereas 16, 136 and 14 respectively within the study area.

No forest land is involved in the plant area. Forest plantation are located in study area (4 reserved forests and one patch of unclassified forest exists) which mainly consists of cactus and scrub vegetation. Some of these reserve forests have been planted with Commiphora wightii (Gugal), which is a medicinal plant.

Gaga Wildlife Sanctuary (an area of 332.87 ha.- divided in two parts) is located approx. 6.4 km (from nearest survey no.) from project site. No mangrove eco-system is observed in the study area.

2.7 Socio-economic Status Total area in hectare 35490 and Population density is 91. Total population of the region as per 2011 census is 38772 out of

which 19395 are male and 19377 are female.

Sex ratio (number of male per thousand female) in the region is 999, this shows that male and female population are comparable.

Out of the total population Scheduled Caste 2501 (6.45%) and Scheduled Tribe population is 239 (0.61%)

Total main worker population is 11612(29.94%), 3297(8.50%) comes under marginal worker category and 32863 (61.54%) belongs to non workers category

Literacy rate in the study area is 22132 (57.08%) The average QoL index values are estimated as:

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- QoL (s) = 0.49

- QoL (o) = 0.60

- QoL (c) = 0.54

The average QoL Index value for the study area is leaning towards neutral and satisfactory level due to good economic status like income, employment, educational facilities and also availability of basic needs, viz. food, clothing, and housing.

3 Anticipated Environmental Impacts and Mitigation

The anticipated environmental impacts due to the proposed project and the suggested mitigation measures are given below:

3.1 Air Impacts Air pollution dispersion modelling and determination of ground level

concentrations of air pollution indicator parameters during construction phase, operational phase.

During construction phase, 24 hourly average maximum GLCs of PM10 will be around 28.6 g/m3. A marginal increase in the levels of oxides of nitrogen, carbon monoxide and hydrocarbons is envisaged due to the movement of vehicles for transportation of construction materials and operation of diesel generators required during construction phase.

The predicted 24 hrly incremental concentrations of SO2, NOx and PM10 (considering CPP emissions using 100% lignite as fuel) will be 16.9 g/m3, 7.1 g/m3 and 1.0 g/m3 occurring at a distance of 1.5 km for SO2 and NOx and 1.1 km for PM10 in ESE - SSE sector respectively due to proposed RSPL units.

The predicted 24 hrly. incremental concentrations of SO2, NOx and PM10 (considering CPP emissions using 100% coal as fuel) will be 1.5 g/m3, 4.9 g/m3 and 0.9 g/m3 occurring at a distance of 1.5 km for SO2 and NOx and 1.1 km for PM10 in ESE - SSE sector respectively due to proposed RSPL units.

The predicted 24 hrly incremental concentrations of NH3 will be 4.5 g/m3 occurring at a distance of 0.7 km in ESE - SSE sector due to proposed RSPL units.

The modelling studies suggest that after commissioning of plant the incremental GLCs due to vehicular traffic would be 20 g/m3, 4 g/m3, 6 g/m3 and 4 g/m3 respectively of CO, HC, NOx and PM10 at about 100 m from the road near the proposed plant.

From the baseline data and the maximum incremental GLCs in respect of all the pollutants, it is evident that the ambient air quality shall be well below the NAAQS given by CPCB with respect to SO2, NOx, PM10 and NH3.

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3.1.1 Mitigation Measures By adopting suitable measures and use of appropriate equipments, air

quality impacts would be reduced. Some of the important mitigation measures are given below to be followed during project construction and operational phase.

Dust suppression arrangements or sprinklers shall be regularly used to avoid dust emission.

All construction machines shall be well maintained and use appropriate air pollution control equipment as required.

Most of these activities shall be undertaken through contract work. Therefore, authorities should put such clauses in the contractual agreement and ensure their implementation during construction work.

Development of green belt shall be started along with the construction activities itself.

High efficiency ESPs shall be provided in the CFBC boilers for control of particulate matter.

Finely ground limestone will be added to the boiler combustion zone together with coal/lignite to arrest the SO2 formed during combustion.

The stack details alongwith proposed air pollution control systems are given below.

The Proposed Stacks Details

No. Attached to Air Pollution Control Systems

Stack Height (m)

Expected Pollutants

1 5 Nos. Lime Kilns (each kiln provided stack individually.)

Scrubbers and drop trap

68.0 SPM, SO2, NOx

2 Ammonia Recovery System

Water Scrubbers

42.0 Ammonia in traces

3 Lime Grinding System Bag Filter 65.0 SPM 4 Filtration /Calcination Scrubber 37.0 Ammonia in

traces 5 Densification Scrubber 43.0 SPM 6 CFBC Boilers- 03 Nos.

(Common Stack) Individual ESPs 122.0 SPM, SO2, NOx

7 Emergency DG Set -- 30.0 SPM, SO2, NOx

3.2 Noise Pollution Computer-aided models were used for prediction of noise propagation and attenuation in the study area.

The plant work area will be able to maintain noise levels below 85 dB(A) during operations.

The in-plant workers, particularly working near higher noise sources, may be exposed to higher level up to 75 dB (A) for longer durations These exposures are well below the exposure limits of occupational

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safety and health administration, (OSHA) i.e. 90 dB (A) for 8 hour shift and 6 working days.

There will be an increase in noise levels in residential areas situated close to the road due to movement of trucks. However, the impact of truck movements on noise level in residential areas situated at 50 meter and beyond from the road will be insignificant considering the excess attenuation and will be below the stipulated standard of CPCB.

3.2.1 Mitigation Measures Some of the important mitigation measures are given below to control noise pollution:

Proper maintenance of construction equipment/machinery for controlling excessive noise levels.

Use of acoustic enclosures/silencers/mufflers for high noise generating equipments.

All the workers engaged at and around high noise generating sources shall be provided with ear protection devices like ear muffs/plugs. Their place of attending the work will be changed regularly so as to reduce their exposure duration to high levels.

Employees/workers will be regularly subjected to check-up for detecting any adverse impact on their hearing.

3.3 Water Requirement and Wastewater Management

The water requirement for the proposed project will be met from the Arabian Sea located nearby the proposed area. Total seawater drawl will be around 6 x 105 m/d. Since groundwater abstraction is not proposed for the project, impact on groundwater quality and quantity is not envisaged. RSPL has made provision of once through circulation of seawater to facilitate the heat-transfer.

The soda ash effluent streams, brine preparation/purification rejects, boiler blow-down from captive power plant, RO/DM plant rejects etc. will be mixed with once through return cooling seawater/fresh seawater to meet the criteria laid down by GPCB/CPCB/MoEF for releasing the treated effluent in the sea i.e. in Marine Coastal Zone. The effluent will be transported within the plant premises and thereafter in closed above/ underground pipelines up to land fall point (LFP). From there through submarine pipeline it will be released at a designated point having diffuser system in the sea waters off Kuranga to achieve further dispersion/dilution in the Arabian Sea in conformity to the CRZ Notification, 2011 by ensuring the requirements of minimum depth and the exit velocity. Domestic wastewater will be treated with septic tank and soak pit system. However, if required, STP will be established.

3.3.1 Mitigation Measures

Proper seawater intake and treated effluent disposal (ensure maximum dilution) shall be done as per Marine EIA report prepared by NIO

Surface run-off during construction should be suitably embanked so that it does not go to the course of any water body in the study area.

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During rainy seasons, maximum rain water should be harvested; and well-designed water flow paths/drainage should be prepared to avoid water clogging.

The surface water run-off should be collected and used for plant activities; the proposed rainwater harvesting near the percolation tank should be constructed.

3.4 Land Use and Greenbelt The land chosen for the proposed project comprises Government

wasteland and private un-irrigated agricultural land. The existing land is almost barren land with only shrubs/bushes and some agriculture fields present on the land. During construction, the site will be leveled and prepared for construction.

The possible sources of solid waste generation from the project activities include undersized limestone from the lime kilns, Fly ash/Bottom ash from boilers, and used/waste oil. The hazardous waste generated will be handled, transported and managed as per HWM Rules 2008 and its subsequent amendments. The details of solid/hazardous wastes and its mode of disposal are summarized in the below.

Waste Generation and Disposal

Sr. No.

Waste Approx. Quantity,

Mode of Disposal/Management

1 Used /Waste Oil

5 KL/yr Collection, Storage, Transportation and disposal by selling to Authorized Recycler as per GSPCB

2 Ash (Fly ash & Bottom ash)

550 TPD The boiler ash of coal as fuel will be used for Cement Manufacturing/ Brick Manufacturing units. If from lignite only, it will be used for road making, pavement & flooring etc.

3 Limestone rejects

5% of limestone consumption

Will be used in boilers for desulphurization and if excess as a sweetener in cement industry, road and pavement making

Potential sources of impacts on soil are accidental discharge of effluents, handling of raw materials, storage of raw material, disposal of solid wastes generated in the plant. There is no effluent discharge on to the soil, hence impact on soil is not envisaged.

By developing green belt / green cover in the plant premises (about 33% of the total area) will mitigate soil erosion and the soil will be fully stabilized without any adverse change in erosion potential of the area.

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4 Risk Assessment Risk assessment was carried out for the proposed plant operations under

abnormal conditions. Maximum Credible Accident (MCA) analysis has been worked out at various wind velocities and atmospheric stability classes to estimate the maximum effective distances in case of partial and Catastrophic rupture scenarios. The risk has also been quantified in terms of iso-contours and F/N curves. Risk has been quantified in terms of individual and societal risk contours for process equipment and storage tanks for partial and full rupture scenarios. The maximum individual risk generated in the plant site is of 10-6 level. The risk is acceptable according to the international standards. The F/N curves for Liquid Ammonia Storage, Ammoniated Brine Tank, Free Ammonia Still Tank, Weak Liquor Tank, A Liquor Tank, Carbonation Column Production, Mother Liquor Tank, Diesel Storage and Chlorine Tonner are in the broadly acceptable region. The societal risk from other process equipment is also within the acceptable region. Mitigative measures have been recommended to tackle the emergencies. Disaster Management Plan (DMP) has been delineated including the roles and responsibilities of key persons.

5 Environmental Management Plan 5.1 Construction Phase

Carryout a proper site selection for the location of the camp for the construction workforce, taking into account environmental and social constraints, so that intrusion into the existing lifestyle of the villagers is minimized.

Sprinkle unpaved roads with water to minimize dust generation. Implement proper maintenance of construction machinery and vehicles to

limit exhaust emissions and noise generation.

Development of green belt shall be started along with the construction activities.

Strict instructions will be given to contractor/construction agency to maintain construction vehicles and other materials transport vehicles with minimal pollution with proper/ up to date PUC certification. Vehicles carrying solid raw materials / fuels should be covered to avoid fugitive dust.

No construction materials like earth, stone, ash or appendage disposed off to prevent any blockage in the flow of water of any water course, and cross drainage channels. Proper drainage system (open or closed) shall be prepared.

Road transport will be planned properly with due regard for traffic congestion and road hazards.

For vehicular transportation, the existing road system will be used for transport of materials to the maximum extent possible.

To implement the occupational health and safety related aspects. All the workers engaged at and around high noise generating sources shall be provided with ear protection devices like ear mufflers/plugs. Their place of attending the work will be changed regularly so as to reduce their exposure duration to high levels.

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5.2 Operational Phase It shall be ensured that all the pollution control / environment management

systems are commissioned as part of main plant equipment, before the commencement of operation of the project. Regular performance evaluation of the control systems shall be undertaken to ensure their optimum performance.

The EMP suggested by NIO will be strictly followed to mitigate marine impacts due to the project activities.

The surface water run-off should be collected and used for plant activities; the proposed rain water harvesting near the percolation tank should be constructed.

The water monitoring results of (terrestrial and marine) should be carefully evaluated to identify significant changes, if any, from the baseline and accordingly, corrective measures to reverse the trend would be necessary.

Proper hazardous waste handling practices will be followed as per the Hazardous Wastes Management Rules and its amendments.

Provision of Personal Protection Equipments (PPEs) need to be arranged and their proper usage should be ensured for protection from high noise for the workers as well as visitors.

Adopt proper housekeeping procedures and devices, including dedicated (covered) skips for different types of domestic wastes.

Used/waste oil generated to be carefully handled and stored in an environment friendly manner and disposed-off by way of sale to the reprocessing units approved by the MoEF/GPCB for its further processing and reuse.

Implement Health Safety & Environment (HSE) awareness/information programs for the nearby communities in collaboration with the local administration. Issues to be dealt with may include HSE aspects of project, environmental conservation and sustainable development, personal hygiene and sanitation awareness programs etc.

6 Post-Project Monitoring The post-project environmental quality will be carried out in the impact

zone with suitable sampling stations and frequency for environmental parameters with respect to different environmental components.

Conventional parameters will be monitored in line with the MoEF Clearance /GPCB Consent letter conditions.

Environment Management Cell of RSPL will be also be responsible for all environment management activities including environmental monitoring, greenbelt development, ensuring good housekeeping, ensuring statutory compliance as well as creating environmentally aware work forces for proposed project. The cell will form short term & long term plans for environmental issues, which require monitoring and effective implementation.

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Compliance to statutory provisions, norms of State Pollution Control Board, Ministry of Environment and Forests and the conditions of the environmental clearance as well as the consents to establish and consents to operate will be ensured.

7 Project Benefits

The proposed project has a potential for employment of skilled, semi-skilled and unskilled employees during construction phase as well as operational phase. The plant will create employment for about 650 (operational phase) skilled as well as semi-skilled staff directly. The proposed project would generate indirect employment opportunities as daily wage labours during construction, transportation activities, supply of raw materials, auxiliary and ancillary works.

The project will contribute additional revenue to the State and Central exchequer in the form of royalty, cess and other taxes etc.

The CSR activities will strengthen the bond between the project authorities and the local population in the vicinity. RSPL will carry out community welfare activities in the areas such as Education, Health, Community Welfare, Ecology and Environment.

8 Conclusion In view of state of the art technology adopted for manufacturing processes,

present status of the environment established through field studies (primary data) and secondary sources, and the control/mitigation measures proposed for environmental management during construction and operation phases, it is concluded that the project will not have any significant negative impact on environment. All emissions, discharges and disposals will be in conformity with the statutory norms. Further, in view of creation of direct as well as indirect additional employment opportunities during construction and operation phase, the project would have positive impact on the economy of the area, the state, the nation and the company.