1st To, Shri Hardik Shah (Secretary) State Level Expert...

1st March, 2016

To,

Shri Hardik Shah (Secretary)

State Level Expert Appraisal Committee (Gujarat)

C/o. Gujarat Pollution Control Board,

Paryavaran Bhavan,

Sector-10 A, Gandhinagar – 382 010

Kind Att. : Mr. Hardik Shah (Secretary)

Subject : Submission of additional details for Environmental Clearance of

our proposed manufacturing unit.

Reference : Minutes of the 256th meeting of the State Level Expert Appraisal

Committee held on 16/09/2015

Dear Sir,

Regarding the above mentioned subject and reference we would like to submit here

the desired information. The point wise clarification and details are mentioned and

attached as an Annexure A. We have also enclosed all other supporting documents

for your kind perusal.

We hope the above details are adequate as per the requirements and looking to this

we request you to process our application at the earliest.

We shall be obliged for your above consideration and also assure you of our all

possible efforts for the prevention of pollution and preservation of environment.

Yours faithfully,

For, Ascent Pharma.

(Authorized Signatory)

Encl:

Annexure – A : Point wise Clarification for Additional details

Annexure – 1 : List of Industries in Nearby Area

Annexure – 2 : List of by products & agreement for sale

Annexure – 3 : Membership Certificate for TSDF_CHWIF

Annexure – 4 : Report on Treatability and Adequacy of ETP

Annexure – 5 : Soil Report

Annexure – 6 : Solvent Recovery

Annexure – 7 : Report on Risk and Safety Management

Annexure – 8 : Undertaking by the project proponent and consultant

Annexure – 9 : Project Summary & Conclusion as per the generic structure of

EIA notification

ANNEXURE- A

Point wise Clarification for Additional details

Annexure A

Point wise Clarification for Additional details

1. Reasons for higher concentration of PM10

Reasons for higher concentration of PM

at project site, Ribda and Pipaliya

Pal Village in Baseline study of EIA report.

10

• The proposed project will be carried out in existing industrial premises

located in the Shapar-Veraval Industrial area, which is well-developed

industrial area comprises of more than 80 industries (List of the industries

of nearby area is enclosed as Annexure-1), which are mainly

pharmaceutical, chemical, cement industries,foundries etc. Therefore,

surrounding industrialization is the main reasonfor higher PM

at project site and villagesRibda

and Pipailya Pal are as follows,

10

• Ribda and Pipaliya Pal villages are located in the predominant down-wind

direction from project site as well as fromShapar-Veraval Industrial area.

concentration at project site.

Villages Distance (Km)

Shapar-VeravalIndustrial Area

Project Site

Ribda 0.92 2.67

Pipaliya Pal 4.55 6.27

• Also, Ribda and Pipaliya Pal village are in proximity of NH-8B by 20 m &

100 m respectively, where heavy traffic load is expected during the peak

hours.

2. Characteristics of by products, feasibility of their actual use as raw

material, management plan for By-products to be generated, along with the

name and address of end consumers to whom the by-product/s will be sold.

Copies of agreement / MoU / letter of intent fromthem, showing their

willingness to purchase said by-product/s from the proposed project.

Byproducts generated from the proposed project are Hydrochloric Acid,

Sodium Bisulphite and Phosphorus Acid. All the byproducts are readily

salable in the market.

Details of source of generation,characteristics and end use along with

agreement by end-users for their willingness to purchase byproducts are

enclosed in Annexure-2.

3. Copy of valid membership certificate for Common TSDF/CHWIF.

Membership certificate for common TSDF/CHWIF is given as Annexure-3.

4. Complete details about the characteristics and treatability of the effluent

with mode of disposal. A detailed treatability study vis-à-vis the adequacy

and efficacy of the treatment facilities proposed for the wastewater to be

generated. Give stage wise reduction in important parameters.

There will be no effluent generation from manufacturing process. However,

condensate water generated from process @ 0.4 KLD will be reused for

cooling make up.

Effluent generated from APCE, Cooling, Boiler and Washing @1.7 KLD will

treated in ETP comprising of primary, secondary and tertiary units andtreated

wastewater will be reused for greenbelt development. A detailed treatability

study report is enclosed as Annexure-4.

5. Submit the Soil analysis report of the proposed site. Soil analysis report of

proposed project location at different places covering response level of

contaminants including heavy metals. Ensure that there is no threat to

ground water quality by leaching of heavy metals and other toxic

contaminants.

There will not be any heavy metals and toxic raw materials used for

manufacturing of proposed products. Also, there will be no effluent generation

from proposed manufacturing process. Condensate water generated from

process will be reused for cooling. Therefore, treated wastewater from ETP,

used for greenbelt development, will not pose any threat to soil quality and

ground water contamination. Detailed Soil analysis report is enclosed as

Annexure-5.

6. Treated effluent management plan during monsoon season when utilization

of treated effluent for gardening & plantation purpose is not feasible.

Detailed study report considering Percolation rate of the land available for

gardening &plantation. Ensure that land is suitable for utilization of treated

sewage for plantation & gardening.

As stated above, there will be no effluent generation from manufacturing

process and condensate generated from process will be reused for cooling

make up. Treated effluent from ETP will be utilized for gardening & plantation

purpose.

In reference to the treatability study, existing ETP will be adequate to achieve

the discharge norms prescribed by GPCB. In addition, it is proposed to

provide 5 KL capacity of treated effluent collection tank, which will be

sufficient to store effluent up to 4 days in monsoon season.

Percolation test was carried out site and detailed soil report with the finding of

test carried out is enclosed here as Annexure-5.Percolation test results show

that soil is having high water holding capacity and moderate permeability

(97.5 mm/hr). However considering the effluent generation, greenbelt area

proposed will be more than required allowing water to percolate effectively to

avoid any water logging. Also the total water requirement for the greenbelt

development will be almost double then the wastewater generation from the

proposed project.

7. Name and quantity of each type of solvents to be used for proposed

production. Details of solvent recovery system including mass balance,

solvent loss, recovery efficiency feasibility of reusing the recovered

solvents etc. for each type of solvent. Ensure that Solvent recovery shall

not be less than 95 percent in any case. The unit intends to use various solvents like Mono Chloro Benzene, Acetone,

Methanol and Xylene. The spent solvent generated during the manufacturing

process will be separated and recovered up to 95% on average by two stage

distillation and reused in the process.

Details of solvent requirements & recovery system including measures for

achieving maximum solvent recovery are enclosed in Annexure-6.

During the distillation of spent solvent impurities will be removed along with

distillation residue and recovered solvent will be of 99.9% purity. Further each

lot of solvent will be tested and validate for further use as per Schedule M

Good Manufacturing Practices notified by Ministry Of Health And Family

Welfare, New Delhi. Therefore, it will be feasible to reuse recovered solvent

for the manufacturing.

8. Risk assessment including prediction of the worst-case scenario and

maximum credible accident scenarios should be carried out. The worst-

case scenario should take into account the maximum inventory of storage

at site at any point of time. The risk contours should be plotted on the map

clearly showing which of the facilities and surrounding units would be

affected in case of an accident taking place. Based on the same, proposed

safeguard measures including On-Site / Off-Site Emergency Plan should be

provided. There are total 17 chemicals proposed to use as a raw materials in the

manufacturing. Out of which, 5 nos. of raw materials are solid and non-

hazardous in nature. Out of remaining 12 hazardous chemicals, risk

assessment has been submitted along with EIA report for two of the major

hazardous chemicals considering worst-case scenario and maximum credible

accident scenarios. However, as per your requirement, we have carried out

MCA analysis for additional 9 hazardous chemicals. Detailed risk assessment

report including On-site / Off-site Emergency Plan is enclosed as Annexure-

7.

9. Records of any legal breach of Environmental laws i.e. details of show-

cause notices, closure notices etc. served by the GPCB to the existing unit

in last three years and actions taken then after for prevention of pollution.

There are no instances of any legal breach of Environmental laws in the past.

Unit has maintained full compliance for all the conditionals stipulated in the

CTE and CCA for existing unit and will maintain the same for proposed

expansion.

10. An undertaking by the Project Proponent on the ownership of the EIA

report as per the MoEF&CC OM dated 05/10/2011 and an undertaking by the

Consultant regarding the prescribed TORs have been complied with and

the data submitted is factually correct as per the MoEF&CC OM dated

04/08/2009.

Undertaking by the project proponent and consultant are given in Annexure-8.

11. Summary & Conclusion as per the generic structure given in Appendix III A

of the EIA Notification 2006.

Summary and conclusion as per the generic structure of EIA notification is

enclosed in Annexure-9

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Annexure- 1

LIST OF INDUSTRIES IN NEARBY AREA

Sr. No.

Name of Industry Type of Industry

1. Orchev Pharma Pvt. Ltd. Pharmaceutical

2. Endoc Lifecare Pvt. Ltd. Pharmaceutical

3. Espee Formulation Pvt. Ltd. Pharmaceutical

4. SNJ Labs Pvt. Ltd. Pharmaceutical

5. Creative Pharma Industries Pharmaceutical

6. Adani Pharmachem Pvt. Ltd. Pharmaceutical

7. Jagdish Chemicals Chemicals

8. Lamberty Hydro colloid Pvt. Ltd. Chemicals

9. Solgel Film Pvt. Ltd. Chemicals

10. Magpie Chemicals Chemicals

11. Patidar Silica Pvt. Ltd Chemicals

12. Revlovne Industries Chemicals

13. Shree Sadguru Chemicals Industries Chemicals

14. Gold Coin Foam Pvt. Ltd. Chemicals

15. Balaji Laminates Laminate Sheets

16. Decora Laminates Laminate Sheets

17. Vision Laminates Laminate Sheets

18. Advance Laminates Laminate Sheets

19. Decora Coatings Pvt. Ltd. Paints

20. Ideal Paints Paints

21. Kohinoor Paints Paints

22. Shree Krishna Biotech Pvt. Ltd. Agriculture

23. Everest Fertilizer & Chemicals Pvt. ltd. Agriculture

24. Ganesh Bio Control System Agriculture

25. Champion Agro Ltd. Agriculture

26. Ascent Crop Science Agriculture

27. Parmatma Enterprise Agriculture

28. Decora Cement Pvt. Ltd. Cement

29. Dhanraj Cement Pvt. Ltd Cement

30. Kishan Cement Pvt. Ltd. Cement

31. Major Cement Pvt. Ltd Cement

32. Marshal Cement Industries Cement

33. New Kishan Cement Pvt. Ltd Cement

of 3

Sr. No.


34. New Tech Cement Pvt. Ltd. Cement

35. Patel Cement Pvt. Ltd. Cement

36. Swastik Industries Cement

37. Rishi Cast Pvt. Ltd Casting- Foundry

38. Rajan Techno Cast Pvt. Ltd. Casting- Foundry

39. Jagdish Technocast Pvt. Ltd Casting- Foundry

40. Gravity Cast Pvt. Ltd. Casting- Foundry

41. Inovative Techno Cast Pvt. Ltd. Casting- Foundry

42. Rajeshwary Alloy Casting Casting- Foundry

43. Sanjivani Casting Pvt. Ltd Casting- Foundry

44. Gujarat Alloy Cast Pvt. Ltd. Casting- Foundry

45. Shree Rudra Techno Cast Pvt. Ltd. Casting- Foundry

46. Sumangal Casting Pvt. Ltd. Casting- Foundry

47. Wellmake Technocast Pvt. LTd. Casting- Foundry

48. AllwaysTechnocast Pvt. Ltd. Casting- Foundry

49. Uni Tech Casting Casting- Foundry

50. SanduriTechnocast Casting- Foundry

51. Plasma Alloys Pvt. Ltd. Casting- Foundry

52. Precision Technocast Pvt. Ltd. Casting- Foundry

53. Nova Technocast Pvt. Ltd. Casting- Foundry

54. Jay Gayatri Icecream / Dairy Pro Food & Beverages

55. Best Agro Foods Pvt. Ltd. Food & Beverages

56. Empire Floor Mills Pvt. Ltd. Food & Beverages

57. Ganga Agro Food Industries Food & Beverages

58. Max Health Foods & Beverages Co. Food & Beverages

59. Galaxy Cotton & Textile Pvt. Ltd Cotton Ginning Mill

60. Jaydeep Cotton Fibers Pvt. Ltd Cotton Ginning Mill

61. AvadhCotex Pvt. Ltd. Cotton Ginning Mill

62. Amit Cotton Industries Cotton Ginning Mill

63. Madhav Cotton Industries Cotton Ginning Mill

64. Casco International Valve

65. Kishan Soap Factory Soap Detergent & Oil Soap

66. Galaxy Soaps Soap Detergent & Oil Soap

67. Fishfa Rubbers Pvt. Ltd Rubber Product

68. Diamond Rubber Industries Rubber Product

69. Sapphire Reclaim Rubber Pvt. Ltd Rubber Product

of 3

Sr. No.


70. P.S. Plywood Products Pvt. Ltd. Plywood Manufacturers

71. Ajanta Plastic Plastic & Packaging

72. Alidhra Packaging Plastic & Packaging

73. AnupamPlastoEngg Pvt. Ltd. Plastic & Packaging

74. Essen Polybags PVT. Ltd. Plastic & Packaging

75. Rubi Plastics Plastic & Packaging

76. BalsonPolyplast Pvt. Ltd. Pipe & Pipe Fittings

77. Captain Polyplast Limited Pipe & Pipe Fittings

78. Godavari Pipes Pvt. Ltd. Pipe & Pipe Fittings

79. Kaveri Polymers Pvt. Ltd. Pipe & Pipe Fittings

80. Narmada Pipes Pipe & Pipe Fittings

81. Om Irrigation Pipe & Pipe Fittings

82. Jaydeep Oxygen Pvt. Ltd. Gases

83. Tirupati Oxygen Pvt. Ltd. Gases

84. MalwinPharma Pvt. Ltd. (Hadmtala) Pharmaceutical

85. Sam Fine Chem Ltd. (Hadmtala) Pharmaceutical

of 3

Annexure-2

DETAILS OF PROPOSED BY-PRODUCTS & CHARACTERISTICS

Sr. No.

Name of By-Product

Quantity (TPM)

Source Characteristic End Use

1. Hydrochloric

Acid (30%) 15.5

APCE-

Oxyclozanide

HCl: 25 %

Water: 75 %

Manufacturing of

Colloidal Silica

2. Sodium Bi-

Sulphite (25%) 26.0

APCE-

Oxyclozanide

NaHSO3Manufacturing of

Sodium Bi-Sulphite

: 25%

NaOH: 1 %

Water: 74 %

3. Phosphorous

Acid Aq.(54%) 3.3

Oxyclozanide

(Route-2; using

PCL3-Stage-I)

H3PO3Manufacturing of DAP

Fertilizer.

: 54 %

Water: 43.95 %

Impurities:0.05 %

of 3

AGREEMENT FOR PURCHASE OF BYPRODUCTS FROM END-USERS

of 1

Annexure-3

MEMBERSHIP CERTIFICATE FOR COMMON TSDF/CHWIF

ANNEXURE- 4

Report on Treatability and Adequacy of ETP

Report on Treatability Study and Adequacy of ETP

Proposed By,

Ascent Pharma Survey No. 163/9, Nr. Chintan Gas Godown, S. I. D. C. Road,Veraval,

(Shapar)- 360024. Ta: Kotada Sangani, Dist: Rajkot (Guj.). India.

Prepared By:

(QCI-NABET ACCREDITED EIA CONSULTANT

3)

rd

Nr. Parimal Underpass, Paldi, AHMEDABAD-380 007, Gujarat. Floor, Akashganga Complex, B/s. Suvidha Shopping Centre,

Telefax: (079) 2665 0473, 2665 0878; E-mail: [email protected]

mailto:[email protected]�

Treatability and Adequacy of ETP Proposed Project for Manufacturing of Synthetic Organic Chemicals

Page i

LIST OF CONTENTS

SR. NO. TITLE PAGE

NO.

1.0 Introduction 1

2.0 Aim of Study 1

3.0 Characteristics of Raw Effluent 2

4.0 Treatability Study- Physico Chemical Treatment 2

4.1 Methodology 2

4.2 Details Of Attempts 3

4.3 Summary of Analysis Results 3

4.4 % Reduction Obtained 3

4.5 Details Of Chemical Dosing 4

4.6 Rate of Chemical Dosing 4

5.0 Treatability Study- Biological Treatment 5

6.0 Treatability Study – Tertiary Treatment 6

7.0 Conclusion Of Treatability Study 7

8.0 Design Considerations 7

8.1 Introduction 7

8.2 Design Criteria 8

8.2 [A] Proposed Effluent Treatment Scheme 8

8.2 [B] Details of Proposed Effluent Treatment Units 10

8.2 [C] Schematic Flow Diagram of Proposed Effluent Treatment Plant

11

9.0 Conclusion 11


Page ii

LIST OF TABLES

SR. NO.

TITLE PAGE NO.

Table 1 Characteristics of Composite Effluent 2

Table 2 Details of Attempts 3

Table 3 Summary of Attempts & Results 3

Table 4 Results of % Reduction 3

Table 5 Details of Chemical Dosing 4

Table 6 Rate of Chemical Dosing 4

Table 7 Characteristic of Primary Treated Effluent 5

Table 8 General Details of Study 5

Table 9 Summary of Analysis Results 6

Table 10 Analysis Results after Tertiary Treatment 6

Table 11 Expected Characteristics of Effluent (Stage wise) 7

Table 12(a) Stage wise % Reduction 8

Table 12(b) Cumulative % Reduction 8

Table 13 Design Criteria for Effluent Treatment Scheme 8

Table 14 Hydraulic Flow rate for proposed ETP 10

Table 15 Details of Effluent Treatment Units 10


Page 1 of 12

1.0 INTRODUCTION

M/s. Ascent Pharma is an existing small scale unit located at Survey No. 163/9 & 11

on S.I.D.C. Road in Shapar-Veraval Industrial Area of Village Veraval (Shapar) in

Kotada Sangani Taluka of Rajkot District in Gujarat state. At present the unit is

manufacturing various Inorganic Chemicals with the total production capacity of 50

TPM. Now, considering the market demand, the unit intends to manufacture various

Bulk Drugs & Drugs Intermediates (Synthetic Organic Chemicals) with total

production capacity of 55 TPM within the existing premises by utilizing existing

infrastructure facilities with the addition of new machineries. The unit has already

applied for Environmental Clearance and obtained additional ToR from SEAC,

Gujarat.

For detailed treatability study for the effluent, proposed unit has appointed M/s.

Envisafe Environment Consultants, Ahmedabad. The sample of the composite raw

effluent from different streams has been collected and submitted by Ascent Pharma

for the lab scale treatability study.

2.0 AIM OF STUDY

The aim of the treatability study is to find out feasibility of effluent treatment for the

proposed unit to achieve quality as per GPCB norms and to design the adequate

treatment scheme for the proposed effluent generation. GPCB norms are given

below.

pH : 6.5 –8.5

TSS : ≤ 100 mg/L

TDS : ≤2100 mg/L

COD : ≤100 mg/L

BOD : ≤30 mg/L


Page 2 of 12

3.0 CHARACTERISTICS OF RAW EFFLUENT

The industrial water consumption will be for Process, Boiler, Washing and Cooling.

The major quantity of wastewater generation will be from APCE, Boiler, Washing and

cooling make up. The composite sample of wastewater stream likely to be at the inlet

of the ETP coming from all section of the plant area is synthesized for lab scale

treatability study. The characteristic of composite raw effluent is given in Table-1.

Table-1: Characteristics of Composite Effluent

Sr. No. Parameters Unit Concentration

1. pH -- 8.5

2. Total Suspended Solid (TSS) mg/L 210

3. Total Dissolved Solid (TDS) mg/L 1250

4. Chemical Oxygen Demand (COD) mg/L 665

5. Biological Oxygen Demand (BOD) mg/L 208

4.0 TREATABILITY STUDY- PHYSICO CHEMICAL TREATMENT

4.1 Methodology

The composite sample was undertaken for the laboratory scale treatability study.

Based on treatment scheme adopted, it was decided to give the effluent Physico

Chemical treatment followed by Biological treatment and Tertiary treatment.

One liter of composite effluent sample was taken into four different beakers and

placed on jar test apparatus.

First, hydrated lime was added into the effluent to neutralize the effluent and

then to raise the pH up to 9.5 - 10.0. Then, inorganic flocculating chemical Alum

or Ferrous Sulfate or Hydrogen Peroxide(H2O2)was added to lower the pH up to

7.0 - 7.5. The addition of PAC powder and Polyelectrolyte was also tried to

accelerate the flocculation and coagulation.

After addition of each treatment chemicals rapid mixing for one minute at 100

RPM was carried out. Then after the addition of all chemicals, slow mixing at 20

RPM for a period of 20.0 minutes was done to facilitate flock formation.

Uniformly mixed and flocculated effluent sample was allowed to settle for 30

minutes and then clear supernatant effluent was taken for analysis.


Page 3 of 12

4.2 Details of Attempts

Various attempts were carried out in physicochemical treatment by addition of

various chemicals with different dosage to know the optimum dosing and pollution

reduction. COD & BOD reduction in each attempt during the study is focused. The

details of attempts in first stage are given in Table-2.

Table-2: Details of Attempts

Attempt No. Details

I. : Addition of Lime and Alum

II. : Addition of Lime, FeSO4 and H2O2

III. : Addition of Lime and PAC

IV. : Addition of Lime, Alum and Poly Electrolyte

4.3 Summary of Analysis Results

The Parameters like pH, COD, BOD were analyzed during study in each attempt and

result of all the parameters are summarized in Table-3.

Table-3: Summary of Attempts and results

Sr. No. Parameters Concentration

I II III IV

1. pH 7.2 7.2 7.3 7.1

2. COD 472 518 484 297

3. BOD 165 180 178 97

All parameters are expressed in mg/L except pH

4.4 % Reduction Obtained

The Percentage reduction has been worked out by comparing all the results with raw

effluent for COD, BOD and pH which is given in Table–4.

Table-4: Results of % Reduction

Sr. No. Parameters I II III IV

1. COD 29.0 22.1 27.2 55.3

2. BOD 20.7 13.5 14.4 53.4

From the above table, it can be concluded that maximum % reduction can be

obtained from Attempt–IV and it is the optimum dosing scheme for the primary

treatment.


Page 4 of 12

4.5 Details of Chemical Dosing

The desired solution was made for all the chemicals viz. Hydrated Lime, Alum,

Polyelectrolyte, Hydrogen Peroxide (H2O2), PAC Powder and Ferrous Sulphate

(FeSO4).Various trials were conducted by addition of treatment chemical with

different dosage for physicochemical study during treatability study.The details of

chemical dosing in each attempt of first stage are given in Table-5.

Table-5: Details of chemical dosing

Sr. No.

Name of Solution Concentration,

%

Chemical dosing in ml for one liter of effluent

I II III IV

1. Alum 10 1.60 0.00 0.00 1.60

2. Hydrated Lime 10 2.10 2.50 2.10 2.10

3. Polyelectrolyte 0.1 0.00 0.00 0.00 2.20

4. PAC Powder/ Liquid 5 0.00 0.00 1.20 0.00

5. FeSO4 10 0.00 3.10 0.00 0.00

6. H2O2 30 0.00 1.20 0.00 0.00

4.6 Rate of Chemical Dosing

From the solution used for the study and dosing of solution as listed in above table

rate of chemical dosing in mg per liter of effluent has been work out in first stage

which is given in Table-6.

Table-6: Rate of chemical dosing

Sr. No. Name of Chemical Chemical dosing in mg/L of effluent

I II III IV

1. Alum 160.00 0.00 0.00 160.00

2. Hydrated Lime 210.00 250.00 210.00 210.00

3. Polyelectrolyte 0.00 0.00 0.00 2.20

4. PAC Powder/ Liquid 0.00 0.00 60.00 0.00

5. FeSO4 0.00 310.00 0.00 0.00

6. H2O2 0.00 360.00 0.00 0.00

TOTAL 370.00 920.00 270.00 372.00


Page 5 of 12

5.0 TREATABILITY STUDY – BIOLOGICAL TREATMENT

To carry out biodegradability study, the effluent sample of about 20.0 Liter was

prepared in laboratory by giving physicochemical treatment, as per Trial-IV, to the

raw composite sample of industrial effluent. The characteristics of primary treated

effluent taken for further biological study is given in Table–7.

Table-7: Characteristics of Primary Treated Effluent

Sr. No. Parameters Unit Concentration

1. pH -- 7.1

2. Chemical Oxygen Demand (COD) mg/L 297

3. Biochemical Oxygen Demand (BOD3 at 270 mg/L C) 97

For the lab scale biological treatability study, 10.0 Liter of primary treated sample was

taken in a laboratory scale acrylic aeration tank and mixed with the adequate quantity

of active biomass, obtained from similar type of industry. Nutrients like Urea and DAP

were also added as per requirement in to the aeration tank.

Oxygen required for the biological activity was supplied by means of aquarium type

aerators and lab scale membrane diffuser to maintain desired level of Dissolved

Oxygen throughout study. The sample from container was collected after several

detention times and analyzed to find out the concentration of COD and BOD. The

general detail of study is given in Table-8.

Table–8: General Details of Study

Sr. No.

Particular Unit Value

1. Sample Taken Liter 10.0

2. Air Supplied CFSTR, Conventional Aeration: 1 kg COD = 1.0 Lit.

Liter/min 1.53

3. MLVSS Level mg/L 2500

The summary of analysis results for the Biological treatment and % reduction

obtained is summarized in Table-9.


Page 6 of 12

Table-9: Summary of Analysis Results

HRT in AT, Hrs.

Concentration, mg/L % Reduction

COD BOD COD BOD

0 297 97 0.0 0.0

10 271 84 8.8 13.4

12 245 73 17.5 24.7

18 190 57 36.0 41.2

24 130 39 56.2 59.8

30 102 28 68.0 71.1

36 86 26 71.0 73.2

42 78 24 73.7 75.3

48 72 23 75.8 76.3

From the above table, it can be concluded that optimum reduction can be obtained

for the retention time of 36 hrs in the biological treatment.

6.0 TREATABILITY STUDY - TERTIARY TREATMENT

The supernatant obtained after the end of aeration of 66 hrs from biological treatment

is passed through Sand & Carbon filter on the laboratory scale. Then finally tertiary

treated effluent is taken and analyzed. The details Analysis Result is given here

under in Table- 10.

Table-10: Analysis Result after Tertiary Treatment

Sr. No. Parameters Unit

Concentration %

Reduction Secondary Outlet

Tertiary Outlet

1. COD mg/L 86 78 9.3

2. BODat27 0 mg/L C 26 24 7.7

From the above mentioned table it can be seen that all parameters of finally treated

effluent is well within the limit prescribed by GPCB for disposal in undergraound

drainage system.Thus primary treatment, biological treatment followed by tertiary

treatment is the most optimum line of treatment to treat the industrial effluent likely to

be generated from the unit.


Page 7 of 12

7.0 CONCLUSION OF TREATABILITY STUDY

Physico Chemical Treatment

• From Table-4, it can be seen that the percentage organic removal in Attempt-IV

is highest. Finally, it can be concluded that Attempt-IV with addition of Lime,

Alum and Poly Electrolyte shall be adopted for the Physico-Chemical

treatment.

Biological Treatment

• The treatability study shows that the wastewater under consideration is having

biodegradability characteristics. With 36Hours of aeration at 2500mg/L MLVSS,

the maximum COD and BOD removal is obtained of @ 71% and 73.2%

respectively.

Tertiary Treatment

• The treatability study shows that the wastewater passed through Pressure Sand

Filter and Activated Carbon Filter, the maximum COD and BOD removal is

obtained by 9.3% and 7.7% respectively.

8.0 DESIGN CONSIDERATIONS

8.1 Introduction

Looking to the above treatability study, the unit is suggested to give physico-

chemical, biological treatment and tertiary treatment to meet the GPCB Norms. For

the design purpose, hydraulic load of the effluent taken is 2 KL/Day and the COD

concentration in the raw effluent taken is 665 mg/lit considering the shock loading if

any. The expected characteristics of effluent after each stage of treatment are given

in Table–11 and % reduction after each stage of treatment and cumulative %

reduction is given in Table-12(a) & 12(b).

Table-11: Expected Characteristics of Effluent (Stage wise)

Sr. No.

Parameter Unit Composite

Effluent Primary Outlet

Secondary Outlet

Tertiary Outlet

1. COD mg/L 665 297 86 78

2. BOD mg/L 208 97 26 24


Page 8 of 12

Table-12(a): Stage wise % Reduction

Sr. No.

Parameter % Reduction

Primary Outlet

Secondary Outlet

Tertiary Outlet

Overall

1. COD 55.34 71.04 9.30 88.27

2. BOD 53.37 73.20 7.69 88.46

Table–12(b): Cumulative % Reduction

Sr. No.

Parameter % Reduction

Primary Outlet

Secondary Outlet

Tertiary Outlet

Overall

1. COD 55.34 87.07 88.27 88.27

2. BOD 53.37 87.50 88.46 88.46

8.2 Design Criteria

Based on the results of the Treatability study and the theoretical assumptions for the

design of ETP units, the basic design criteria were finalized for the proposed effluent

treatment scheme which would to be most adequate to achieve desired norms of

GPCB for discharge of treated effluent. These design criteria are listed in Table–13.

Table–13: Design Criteria for Effluent Treatment Scheme

A Primary Units

1. Collection Cum Equalization Tank : Retention Time: 8 Hours

2. Primary Settling Tank (Hopper Bottom) : Retention Time: 4.0 Hours, SOR:30 m3/m2/Day

B Secondary Units

3. Aeration Tank : Retention Time: 36Hours MLVSS: 2500 mg/L

4. Secondary Settling Tank (Hopper Bottom)

: Retention Time: 4.0 Hours, SOR:12.0 m3/m2/Day

[A] Effluent Treatment Scheme:

The wastewater shall be treated in the following stages:

Collection cum Treatment tank

The wastewater generated from APCE, Boiler, Washing and Cooling will be collected

in the collection tank. Here, effluent will be thoroughly mixed with constant supply of

compressed air through grid aeration pipeline.

Chemical Dosing Tank


Page 9 of 12

The chemical dosing tanks are provided for the preparation of chemical solution

required for the physicochemical treatment such as hydrated lime and alum.

Primary Hopper Bottom Settling Tank

The effluent from flocculation tank will be led to Primary Settling Tank. Here the

effluent will be retained for the certain period in a relatively quiescent state. Thus,

chemical flocs having higher specific gravity then the liquid tends to settle to the tank

bottom. The settled sludge at the bottom will be transferred into the sludge drying

bed. The clear supernatant effluent from tank overflow will be taken for the further

treatment.

Aeration Tank

After the primary settling tank, effluent will be taken to the aeration tank. The fix

microbial culture will be developed and maintained by recirculating the active

biomass form the secondary clarifier. The microbes oxidize the organic matter

present into the wastewater and use it as a food and form their own cell mass. Thus

the organic load present in the wastewater in the form of BOD & COD will be

converted in to simple products as CO2 and H2O. The oxygen required for bacterial

growth will be supplied by blowers through means of aeration grid at the bottom of

the aeration tank. The wastewater overflow from aeration tank will be taken to the

secondary settling tank.

Secondary Settling Tank

The mix liquor from aeration tank will be carried to the Secondary settling tank and

retained for the certain period in a relatively quiescent state. Thus microbial mass

having higher specific gravity than the liquid tends to settle to the bottom. The part of

biological sludge settled in to the tank hopper will be recycled to the aeration tank to

maintain desired level of microbial population and excess sludge is drained to the

sludge drying bed. The clear supernatant effluent will be sent for Tertiary treatment.

Sludge Handling

Sludge drained from Primary and Secondary settling tank will be transferred to

sludge drying bed for further treatment. Leachate from sludge drying bed will be

recycled back into collection cum treatment tank. Remaining sludge will be

transferred to designated hazardous waste storage area for safe disposal to TSDF

site.


Page 10 of 12

Pressure Sand Filter

The treated wastewater is pumped from the tertiary treatment tank through the

pressure sand filter to remove excess suspended solids. Pressure sand filter is

cleaned periodically to remove accumulated solids. This is done by backwashing the

filter using fresh water in reverse flow sequence. The backwash water flows back to

collection cum equalization tank for treatment.

Activated Carbon Filter

The effluent from the outlet of pressure sand filter is passed through activated

carbon filter where final polishing of the effluent is done to reduce the suspended

solids, colour, odor and other organic impurities. Activated carbon filter is cleaned

periodically to remove accumulated solids. This is done by backwashing the filter

using fresh water in reverse flow sequence. The backwash water flows back to

collection cum neutralization tank for treatment.

[B] Details of proposed Effluent Treatment Units:

The details of proposed effluent treatment plant will be adequate to treat wastewater

generation @ 2.0 KL/day is given in Table-14 and Table-15.

Table-14: Hydraulic flow rate for proposed ETP

Treatment Units Primary

Settling Tank Aeration

Tank Secondary

Settling Tank

Actual Flow rate KL/Day 1.7 1.7 1.7

Design Flow Rate, KL/Day 2.0 2.0 2.0

Operation, Hrs 8 24 8

Design Flow Rate, KL/Hour 0.25 0.083 0.25

Table–15: Details of Effluent Treatment Units

Sr. No.

Units

No

s.

Len

gth

,

m

Wid

th,

m

Liq

uid

Dep

th, m

Liq

uid

Vo

lum

e, m

3

Rete

nti

on

Tim

e, h

rs

Remarks

1. Collection cum Treatment Tank

2 1.10 1.10 1.70 4.11 16.46 --

2. Lime Solution Tank 1 0.75 0.75 0.75 0.42 - --

3. Alum Solution Tank 1 0.75 0.75 0.75 0.42 - --

4. Polyelectrolyte Solution Tank

1 50 Liter 0.05 - --

5. Flocculation Channel 1 1.10 0.50 0.50 0.28 1.10 --

6. Primary Settling Tank (Hopper Bottom)

1 1.00 1.00 2.00 2.00 8.0 SOR = 6 m

3/m

2/hr

(Adequate)

7. Aeration Tank 1 1.50 1.50 2.50 5.63 67.50 MLVSS = 2500 mg/L


Page 11 of 12

Sr. No.

Units

No

s.

Len

gth

,

m

Wid

th,

m

Liq

uid

Dep

th, m

Liq

uid

Vo

lum

e, m

3

Rete

nti

on

Tim

e, h

rs

Remarks

(Adequate)

8. Secondary Settling Tank (Hopper Bottom)

1 1.20 1.20 2.00 2.88 11.52 SOR = 4.17 m

3/m

2/hr

(Adequate)

9. Treated Water Collection Tank - 1

1 1.10 1.10 1.70 2.06 8.23 --

10. Treated Water Collection Tank - 2

1 5.0 KL HDPE 20 Proposed Tank

11. Pressure Sand Filter 1 0.3 Dia. X 1.5 HOS --

12. Activated Carbon Filter 1 0.3 Dia. X 1.5 HOS --

13. Sludge Drying Beds 2 1.00 1.00 0.50 1.00 -- --

[C] Schematic diagram of proposed Effluent Treatment Plant


Page 12 of 12

9.0 CONCLUSION:

From the above treatability study, it can be seen that the required retention time for

Primary Settling Tank is 4 hrs, for Aeration Tank is 36 hrs and for Secondary Settling

Tank it is 4 hrs. However, the unit has provided retention time of 8 hrs for Primary

Settling Tank, 67.5 hrs for the aeration tank and 11.5 hrs for the Secondary Settling

Tank, which is more than adequate.

In addition to this, the required SOR for primary settling tank is 30 m3/m2/d and for

Secondary Settling Tank it is 12 m3/m2/d. However, the unit has provided SOR of 6

m3/m2/d to the Primary Settling Tank and of 4.17 m3/m2/d to the Secondary Settling

Tank, which is adequate than the desired one.

Treated water collection tank of 5 KL capacity has been proposed in addition to

existing 2 KL treated water collection tank. It will be sufficient enough for storage of

treated water up to 4 days in case if it cannot be utilized for gardening purpose

during monsoon season.

Hence, the existing ETP along with additional treated water collection tank will

be adequate to the handle the total effluent load after proposed expansion and

achieve the desired norms of final discharge.

ANNEXURE- 5

Soil Report

Soil Report

Proposed By, Ascent Pharma Survey No. 163/9, Nr. Chintan Gas Godown, S. I. D. C. Road,Veraval (Shapar)- 360024. Ta: Kotada Sangani, Dist: Rajkot (Guj.). India.

(QCI-NABET ACCREDITED EIA CONSULTANT3rd Floor, Akashganga Complex, B/s. Suvidha Shopping Centre,Nr. Parimal Underpass, Paldi, AHMEDABAD-380 007, Gujarat.Telefax: (079) 2665 0473, 2665 0878; E-mail: [email protected]

)

Prepared By,

Soil Report

Proposed Project for Manufacturing of Synthetic Organic Chemicals

Page i

LIST OF CONTENTS

SR. NO. TITLE PAGE NO.

1.0 Background 1

2.0 Objective 1

3.0 Soil 3

3.1 Logging of soil strata 3

3.2 Soil type in Rajkot District 3

3.3 Physico-Chemical Analysis of Soil 4

3.4 Percolation Test 5

4.0 Ground Water Quality at Project Site 7

5.0 Major Findings 7

6.0 Conclusion and Mitigation Measures 9

LIST OF TABLES

TABLE NO.

TITLE PAGE NO.

Table 1 Physico- Chemical characteristics of soil 4

Table 2 Percolation Test at different Trail Pit 6

LIST OF FIGURES

FIGURE NO.

TITLE PAGE NO.

Figure 1 Location Map of the project site 2

Figure 2 Geological map of Gujarat 3

Figure 3 Soil Map of Gujarat 4

Soil Report Proposed Project for Manufacturing of Synthetic Organic Chemicals

Page 1 of 9

Soil Report

Soil Investigation and percolation tests 1.0

M/s. Ascent Pharma is an existing small scale unit located at Survey No. 163/9 &

11 on S.I.D.C. Road in Shapar-Veraval Industrial Area of Village Veraval (Shapar) in

KotadaSanganiTaluka of Rajkot District in Gujarat state and involved in the

manufacturing of various Inorganic Chemicals with the production capacity of 50

TPM. Now the unit proposes to manufacture various Bulk Drugs & Drugs

Intermediates (Synthetic Organic Chemical) with total production capacity of 55

TPM.

The stated project will be carried out within the existing premises. Location map of

the project site is given in Figure 1.

In order to ensure compliance of the additional TOR obtained from SEAC-

Gandhinagar,here under conducted soil investigation and percolation tests to check

permeability of soil.

BACKGRAOUND

2.0

This report is part of an Environmental Impact Assessment (EIA) report being

prepared for the proposed project. Its main objective is to present the soil conditions

that pertain to the site. The vulnerability to pollution as a consequence of the effluent

discharge from the proposed plant and mitigation measures necessary has also

been suggested.

OBJECTIVE

Soil Report


Page 2 of 9

Figure 1: Location Map of the project site


Page 3 of 9

3.0 SOIL

3.1 Logging of soil strata

The soil survey has been done to know soil characteristics of the area. Figure 2

shows that in and around the study area comprises of Deccan Trap Basalts. This

trap rocks appears gently tilted at places, flows comprises massive, hard and tough

Amygdaloidal Basalt, Vesicular fine grained basalts; Porphyritic basalts,Geodes with

Zeolite, Chalcedony, Agate and Calcite are often in Amygdaloidal types. The traps

are invariably jointed by all kinds of joints in Basalt.The area is almost flat and

ground gradients are mild and sloping from West to East.

Figure 2:Geological map of Gujarat

3.2 Soil Type in Rajkot District

The soil strata consist of thin inorganic soil overlaying basaltic layer of varying

degree of weathering.

Soil type in the KotadaSanganiTaluka of Rajkot district is shallow medium black as

shown in Figure 2.

Soil Report


Page 4 of 9

The structure of the soil found in the region is predominantly clayey having high

water holding capacity and moderate permeability.

Figure 3: Soil Map of Gujarat

3.3 Physico- Chemical analysis of soil

To determine the exact impacts of any proposed activity, existing status of soil

quality through a study of soil quality assessment has been done. Considering this,

surface soil samples were collected from two trail pits of project site, which signifies

that the soil of the area is fertile. This is given in below table 1.

Table 1:Physico- Chemical characteristics of soil

Sr.

No. Parameters Unit Trial Pit 1 Trial Pit 2

1 Bulk Density gm/cm 1.19 3 1.14

2 Moisture content % 6.17 5.86

3 Water Holding Capacity % 39 38

4 Specific gravity -- 1.99 2.02

5 Particle Size Distribution


Page 5 of 9

Sr.

No. Parameters Unit Trial Pit 1 Trial Pit 2

i Sand % 22 20

ii Clay % 52 54

iii Silt % 26 26

6 Texture Class -- Loamy clay Loamy clay

7 pH (10% Solution) -- 7.20 7.00

8 Electrical Conductivity ms/cm 2.4 2.6

9 Cation Exchange Capacity meq/100 gm 32 36

10 Calcium gm/Kg 1.5 1.3

11 Magnesium gm/Kg 0.5 0.8

12 Sodium gm/Kg 2.3 2.1

13 Potassium gm/Kg 0.6 0.8

14 Chloride gm/Kg 2.2 1.8

15 Phosphorous gm/Kg 0.06 0.10

16 SAR -- 2.30 2.28

17 Available Nitrogen gm/Kg 1.2 1.4

18 Total organic matter % 3.9 4.1

19 Iron as Fe gm/Kg 1.5 1.2

20 Zinc as Zn gm/Kg 0.2 0.2

21 Nickel as Ni gm/Kg 0.18 0.14

3.4 Percolation test

The total greenbelt area of 760 sqmt (existing 340 sqmt+ proposed 420 sqmt) is

investigated to assess the suitability of the proposed mode of effluent disposal. As

the total greenbelt area is 0.076 ha which is less than 4ha, hence only one trail pit is

adequate for the soil study. However, two trial pits were excavated at project site for

the logging of soil strata and percolation test.

1. Trial pit 1 (0. 5m x 0.5m x 0.45m deep)

Soil depth (m) Soil Characteristics

0- 0.15 Topsoil

0.15- 0.35 Completely weathered basalt with inorganic soil layers

0.35- 0.45 Weathered basaltic layer

2. Trial pit 2 (0. 5m x 0.5m x 0.45m deep)

Soil depth (m) Soil Characteristics

0.00- 0.13 Topsoil

0.13- 0.32 Completely weathered basalt with inorganic soil layers

0.32 – 0.45 Weathered basaltic layer

Soil Report


Page 6 of 9

Percolation tests have been design to determine suitability of the soil for a

subsurface effluent disposal system. More specifically, the percolation tastes will

measure the ability of the soil to absorb the effluent discharge. The rate at which the

effluent is absorbed isnot only used to calculate the surface area required for

effective discharge of the effluent, but also indicates the degree of filtration and

hence the degree of treatment achieved.

Two percolation tests were carried out at bottom of each trail pit. The methodology

adopted can be summarized as follows;

a) A hole0.5 x0.5 m square to a depth 0.45 m was excavated for each pit.

b) A 60 mm level of gravel (10-14 mm size) was placed at the bottom of the base.

c) The hole was filled with water and allowed to soak overnight.

d) About 3 hours before carrying out the test the hole was again filled with water

and allowed to drain out to achieve saturated conditions.

e) The test was carried out by filling the hole with water upto 0.3 meter and time

recorded for the water to drain through. This was repeated two times.

Details of the results obtained and the corresponding computation of the soil

permeability is given here under:

Table 2: Percolation Test at different Trail Pit

Sr. No.

Parameters Unit Trial Pit- 1 Trial Pit- 2

PT-1 PT-2 PT-1 PT-2

1 Dimension of trail pit m 0.5 x 0.5 x 0.45 0.5 x 0.5 x 0.45

2 Level of water from bottom of the pit

mm 300 300 300 300

3 Time taken for complete infiltration of water

min 196 163 218 171

4 Percolation rate mm/hr 91.8 110.4 82.6 105.3

5 Average Permeability mm/hr 101.1 93.9

Average Permeability of soil mm/hr 97.5


Page 7 of 9

4.0 GROUND WATER QUALITY AT PROJECT SITE

These are hard rock area. Ground water is occurring in the zone of secondary

porosity. Ground water is occurring under unconfined condition. Ground water

sample was also collected and analyzed to assess the present status of ground

water quality. The depth to water level of unconfined aquifer in this area is ranging

from 3.0 to 16.0m. The depth of well in this area is ranging from 16.9 to 21.0 m.

From the ground water development point of view, this area falls in safe category.

Apparently, one may feel that it is not necessary to plan recharge scheme in such

area but it is not so. Ground water quality is good (MAP). The total dissolved solids

content in ground water is ranging from 1,000 to 3,000 ppm.

5.0 MAJOR FINDINGS

1. This area comprises of Deccan Trap Basalt. The weathering of this rock type

gives rise toblack cotton soil.

2. The depth of water level near close proximity of this plant site is about 16.9 to 21

m below ground level.

3. From the ground water development point of view this area falls in safe zone

category. 4. Physico- chemical analysis predicts that soil type is loamy clay and fertile in

nature.

5. Thissoil is having average permeability of 97.5 mm/hr and having characteristics

of high water holding capacity.

6. Considering actual percolation rate exits at project site, Land suitability for

discharge of treated effluent at project site is good.

Average Permeability of soil 97.5 mm/hr (2.34 m/Day)

Effluent Generation 1.7 m3/Day

Land Area Required 0.726 m2

Land Available 760 m2

Land area required is much lesser than the area available for greenbelt

development. Therefore, there are negligible chances of water logging and water

will effectively percolate through the soil.

Soil Report


Page 8 of 9

7. The total water requirement for the greenbelt development will be more than the

total treated effluent generation and will be met from additional freshwater.

Total greenbelt area after proposed project : 760 sqmt

Water requirement for greenbelt development : 4 Lit/sqmt

Total water requirement : 3040 Liter

Treated effluent for greenbelt development : 1700 Liter

Fresh water requirement for greenbelt development : 1340 Liter

Treated effluent generated @ 1.7 KLD and freshwater @ 1.3 KLD will be used for

greenbelt development.


Page 9 of 9

6.0 CONCLUSION&MITIGATION MEASURES

• From the above inherent field condition, it appears that there are remote

chances for ground water contamination. However, there are no heavy

metals or toxic chemicals used as raw materials. Also, there will be no

wastewater generation from manufacturing process which may pose threat to

reuse of treated wastewater for greenbelt development. Effluent generated

from APCE, boiler, washing and cooling will be treated in ETP comprising of

Primary, Secondary and Tertiary unit and treated effluent will be reused for

plantation and gardening.

• The total water requirement for the greenbelt development will be almost

double then the wastewater generation from the proposed project. Also

percolation testresults show that soil is having high water holding capacity and

moderate permeability allows water to percolate effectively avoiding any water

logging on proposed greenbelt area.

• Soil analysis report shows that soil quality is good, fertile and adequate for the

utilization of treated effluent for plantation & gardening.

• Over the period of time salinity of soil may increase for which unit will explore

effective chemical treatments by applying Gypsum as and when required.

• However,threat to ground water contamination can be taken careof bygrowing

following high water absorbing trees &plants in green belt area;

1) Tamarixgallica (French tamarisk) 2) Buteamonosperma (Kesudo)

3) Casuarinaequisetifolia (Saru) 4) Ailanthesexcelsa (Arduso)

5) Pongamiapinnata (Karanj) 6) Cocusnucifera (Nariyal)

7) Azadirachtaindica (Neem) 8) Albizzialebbeck (Shirish)

of 3

Annexure-6

After the completion of the reaction, the spent solvent/mother liquor will be

separated by centrifuge and pumped to distillation reactor. It will be subjected to

distillation to separate and recover solvent.

SOLVENT REQUIREMENTS & RECOVERY SYSTEM

The industry proposes to manufacture synthetic organic chemicals (Bulk Drugs &

Drugs Intermediates), which require solvents during various unit processes. The unit

intends to use various solvents viz. Mono Chloro Benzene, Acetone, Methanol and

Xylene. The spent solvent generated during the manufacturing process will be

recovered by way of distillation and reused in the process. The process of the

solvent recovery system is described hereunder;

Firstly, the mass will be distilled at required temperature where pure solvents will

be distilled out depending on their boiler points and it will be collected in the

recovered solvent storage tank and reused in the process and then residue will

be sent to TSDF site for the disposal by incineration.

Vacuum will also be applied during distillation.

The overall requirements and mass balance for the solvent based on mass

balance of each product has been worked out. The schematic diagram of the

solvent recovery system is shown in the Figure 1.

The entire manufacturing activities & distillation process will be carried out in the

totally closed system.

Measures for achieving maximum solvent recovery:

Maintenance of the pipeline and valves & fittings will be carried out regularly to

avoid any leakages.

Reactor will be connected with two numbers of condensers where cooling water

and chilled water will be used as media and also equipped with vacuum system

as per requirement.

The condenser will be provided with the sufficient HTA and residence time to

achieve more than 95% recovery.

The fresh solvent requirement will be depended on generation of distillation loss. The

details of solvent consumption and mass balance are given below in Table 1 &

Table 2.

of 3

Figure 1: Schematic Diagram of Solvent Recovery System

Table 1: Details of Solvent Requirement and Recovery

Sr. No.

Name of Solvent

Product Group

Fresh, MT/Month Recovered, MT/Month

Product wise

Group Max

Total Product

wise Group Max

Total

1. Acetone I (a/b) 4.00 4.00

9.00 64.43 64.43

144.43 2 5.00 5.00 80.00 80.00

2. Methanol 2 15.00 15.00 15.00 235.00 235.00 235.00

3. Mono Chloro Benzene

I (a) 4.50 4.50 4.50

98.00 98.00 98.00

I (b) 4.50 98.00

4. Xylene 3-A 0.80

0.80 0.80 19.60

21.60 21.60 3-B 0.80 21.60

of 3

Table 2: Summary of Solvent Requirement and Recovery

Sr. No.

Name of Solvent

Solvent Requirement, MT/Month

Solvent Requirement,%

Fresh Recovered Total Fresh Recovered Total

1. Acetone 9.00 144.43 153.43 5.87 94.13 100.00

2. Methanol 15.00 235.00 250.00 6.00 94.00 100.00

3. Mono Chloro Benzene

4.50 98.00 102.50 4.39 95.61 100.00

4. Xylene 0.80 21.60 22.40 3.57 96.43 100.00

Total / Average 29.30 499.03 528.33 4.96 95.04 100.00

ANNEXURE- 7

Report on Risk and Safety Management

RISK AND SAFETY MANAGEMENT

Ascent Pharma Survey No. 163/9, Nr. Chintan Gas Godown, S. I. D. C. Road, Veraval (Shapar) -

360024. Ta: Kotada Sangani, Dist: Rajkot (Guj.). India.

(QCI-NABET ACCREDITED EIA CONSULTANT3rd Floor, Akashganga Complex, B/s. Suvidha Shopping Centre,Nr. Parimal Underpass, Paldi, AHMEDABAD-380 007, Gujarat.Telefax: (079) 2665 0473, 2665 0878; E-mail: [email protected]

)

Prepared By,

Risk and Safety Management Proposed Project for Manufacturing of Synthetic Organic Chemicals

Page i

LIST OF CONTENTS

SR. NO. TITLE PAGE NO.

1.0 Preamble 1

2.0 Objective, Phylosophy & Methodology 2

2.1 Objective 2

2.2 Phylosophy 2

2.3 Methodology 2

3.0 Hazardous Material, Process and Safety Management 3

3.1 Hazardous Chemicals 3

3.2 Safety Measures for Transportation, Storage & Handling of chemicals

5

3.3 Critical Safety Measures for Process Units 5

3.4 Safety Measures For Preventive Maintenance 7

3.5 Safety measures to prevent spillage / leakage of toxic chemicals

7

4.0 Occupational Health & Safety Program 8

5.0 Risk Assessment Study 9

5.1 Identification of High Risk Areas 12

5.2 Models of Failure 12

5.3 Maximum Credible Accident Analysis and Its Mitigation Measures

13

5.4 Consequences Analysis 14

5.4.1 Definitions & Explanation of Terms Used 15

5.4.2 Possible Accident Scenario 17

6.0 Onsite Emergency Plan and Disaster Management Plan 78

6.1 Pre-emergency activity 79

6.2 Emergency Time Activities 81

6.3 Post – Emergency Activities 83

7.0 Off Site Emergency Plan 83


Page ii

LIST OF TABLES

TABLE NO.

TITLE PAGE NO.

Table 1 Details of Hazardous Chemicals per the MSIHC rules 1989 & 2000

4

Table 2 Storage details of Hazardous Chemicals 14

Table 3 Threshold values of the Hazardous Chemicals 15

Table 4 Atmospheric Conditions Assumed 17

Table 5 Source Strength considered for Methanol 18

Table 6 Threat zone of toxic liquid concentration 19

Table 7 Falmable area of vapor cloud 19

Table 8 Source Strength in case of Methanol escapes (pool fire) 21

Table 9 Threat zone of thermal radiation from BLEVE 22

Table 10 Source Strength considered for Ammonia gas 24

Table 11 Toxic Threat zone 25

Table 12 Flammable area of vapor cloud 26

Table 13 Threat zone of thermal radiation from jet fire 29


Table 15 Source Strength considered for Ammonia 32



Table 18 Source Strength considered for Acetone 35


Table 20 Flammable area of vapour cloud 37

Table 21 Threat zone of thermal radiation from pool fire 39


Table 23 Source Strength considered for Cyclo Hexyl Isocynate 42




Table 27 Source Strength considered for Formic Acid 48



Page iii



Table 31 Source Strength considered for Hydrazine 52




Table 35 Source Strength considered for Mono Chloro Benzene 58





Table 40 Source Strength considered for Phosphorus Trichloride 65


Table 42 Source Strength considered for Thionyl Chloride 68


Table 44 Source Strength considered for Xylene 72





LIST OF FIGURES

FIGURE NO.

TITLE PAGE NO.

Figure 1 Risk Assessment Methodology 11

Figure 2 Source Strength in case of Methanol escape 18

Figure 3 Isopleths result of Toxic threat at a point for Methanol 20

Figure 4 Source Strength in case of Methanol escapes (pool fire) 21

Figure 5 Thermal radiation at a point in case of Methanol escapes (pool fire)

22

Figure 6 Isopleths result of threat zone of thermal radiation from BLEVE

23

Figure 7 Source Strength in case of ammonia gas escapes 25

Figure 8 Isopleths result of toxic threat zone for Ammonia Gas 26


Page iv

FIGURE NO.

TITLE PAGE NO.

escaping

Figure 9 Isopleths result of flammable threat zone for Ammonia Gas escaping

27

Figure 10 Isopleths result of Toxic threat at a point for Ammonia Gas 28

Figure 11 Source Strength in case of Ammonia Gas escapes (pool fire)

29

Figure 12 Isopleths result of Thermal radiation from jet fire 30


31

Figure 14 Source Strength in case of Ammonia escape 32

Figure 15 Threat zone of toxic liquid concentration 33

Figure 16 Isopleths result of Toxic threat at a point for Ammonia 35

Figure 17 Source Strength in case of Acetone escape 36

Figure 18 Isopleths result of Toxic threat at a point for Acetone 38

Figure 19 Source Strength in case of Acetone escapes (pool fire) 39

Figure 20 Thermal radiation at a point in case of Acetone escapes (pool fire)

40


41

Figure 22 Source Strength in case of Cyclo Hexyl Isocynate escape 43


Figure 24 Isopleths result of Toxic threat at a point for Cyclo Hexyl Isocynate

46


47

Figure 26 Source Strength in case of Formic Acid escape 48


Figure 28 Isopleths result of Toxic threat at a point for Formic Acid 50


51

Figure 30 Source Strength in case of Hydrazine escape 53


Figure 32 Isopleths result of Toxic threat at a point for Hydrazine 55


56

Figure 34 Source Strength in case of Mono Chloro Benzene escape 58



Page v

FIGURE NO.

TITLE PAGE NO.

Figure 36 Isopleths result of Toxic threat at a point for Mono Chloro Benzene

61

Figure 37 Source Strength in case of Mono Chloro Benzene escapes (pool fire)

62

Figure 38 Thermal radiation at a point in case of Mono Chloro Benzene escapes (pool fire)

63


64

Figure 40 Source Strength in case of Phosphorus Trichloride escape 65


Figure 42 Isopleths result of Toxic threat at a point for Phosphorus Trichloride

67

Figure 43 Source Strength in case of Thionyl Chloride escape 69


Figure 45 Isopleths result of Toxic threat at a point for Thionyl Chloride 71

Figure 46 Source Strength in case of Xylene escape 72

Figure 47 Isopleths result of Toxic threat at a point for Xylene 74

Figure 48 Source Strength in case of Xylene escapes (pool fire) 75

Figure 49 Thermal radiation at a point in case of Xylene escapes (pool fire)

76


77


Page 1 of 84

1. PREAMBLE

Increasing use of hazardous chemicals as raw materials, intermediates and finished

products has attracted attention of the Government and the public at large in view of

the chemical disasters. The serious nature of the accidents, which cause damage to

the plant, personnel and public, has compelled industries to pay maximum attention

to the safety issues and also to effectively manage the hazardous material and

operations. It is mandatory for the industries handling hazardous chemical to

maintain specified safety standards and generate an on-site emergency plan and

keep it linked with off site emergency plan.

The Risk Assessment Study and safety management for the proposed project of

M/s. Ascent Pharma has been carried out and the details are elaborated in this

chapter. Based on the findings & recommendations of RA report management plan

for the proposed project has also been prepared and included.

Risk Assessment is defined as a continuous and integrated process of identification,

evaluation and measurement of risks, along with their potential impact on the

organization.

The benefits of risk assessment include the following:

• Prevention or reduction in occurance of accidents.

• Mitigation of the severity and/or consequences by way of improved process

techniques, fire protection systems, arrangements of storage, inventory

monitoring to fit production requirements.

• Development of confidences in employees by improving competency.

• Preparedness and prompt response to deal with any accident.

The safety management includes the implementation of preventive methods or

accident prevention methods to avoid incident or accident and handling of

emergency in case of accident.


Page 2 of 84

2. OBJECTIVE, PHILOSOPHY AND METHODOLOGY OF RISK ASSESSMENT

2.1 Objective

The principle objective of this study is to identify major risks in the manufacturing

process and to evaluate on-site & off-site consequences of identified hazard

scenarios. Pointers are then given for effective mitigation of hazards in terms of

suggestions for effective disaster management, suggesting minimum preventive and

protective measures & change of practices to ensure safety.

2.2 Philosophy

The following aspects and areas have been covered in this study;

• Identification of major risk areas.

• Hazard identification / Identification of failure cases.

• Consequential analysis of probable risks / failure cases;

o Determination of the probable risk by Releasing of chemical due to leakage

of storage tank and catastrophic failure.

o Risk assessment on the basis of the above evaluation & risk acceptability.

o Minimum preventive & protective measures to be taken to minimize risks to

maximum possible extent.

• Giving pointers for effective disaster management.

• Suggesting measures to further lower the probability of risk.

2.3 Methodology

Design data, built in safety systems are studied. Discussions are held with officials.

Safety related individual system is discussed. Hazard identification exercise is

conducted taking into consideration of materials, material handling methods,

operating procedures, built in safety in reactors, operating parameters and safety

measures to be taken in proposed plant. Few areas like process building, storage of

hazardous chemicals, to evaluate safety systems in the event of any abnormalities

occurring. Containment failure scenario related to storage area is considered for

hazard Analysis and consequences of such containment failures are considered in

detail. Thus, this study is mainly oriented towards actual risks rather than chronic

risks.


Page 3 of 84

3.

The proposed project includes manufacturing of various bulk drugs and drug

intermediates along with the existing products. Manufacturing of these synthetic

organic chemicals required raw materials are listed in Chapter-2, Section-2.8 with

hazardous identification of EIA Report. Physical characteristic as well as hazardous

details of raw materials and products in form of MSDS are enclosed in Appendix-1.

HAZARDOUS MATERIAL, PROCESS AND SAFETY MANAGEMENT

3.1 Hazardous Chemicals

None of the product is defined as hazardous in MSIHC rules but may fall under the

definition of hazardous material/chemicals either due to flammability or toxicity.

Certain raw materials fall under the definition of hazardous chemical. The details of

hazardous chemicals are given in Table 1.


Page 4 of 84

Table 1: Details of Hazardous Chemicals per the MSIHC rules 1989 & 2000

Sr.

No.

Name of

Chemicals State Colour Odor

Sp.

Gravity

Vapour

Density

Melting

Point ºC

Boiling

Point ºC

Flash

Point ºC

Explosive

limit Solubility in

water

Hazardous

Characteristics LEL UEL

% %

1. Acetone Liquid Colourless Fragrant Mint 0.791 2 -94.7 56.48 -20 2.6 12.8 Miscible Corrosive,

Flammable

2. Ammonia Gas Gas Colourless

gas with sharp

Strong Similar to

smelling Salts

0.59 --- -77.7 -33.4 --- --- --- 0.848 Toxic &

Flammable

3. Caustic Soda

Flakes Liquid

White Flakes

/Pellets Odourless 2.12 --- 318.4 1390 --- --- --- Soluble Corrosive

4. Formic Acid Liquid

Clear

Colourless

Liquid

Characteristic

Pungent Odor. 1.22 1.6 8 101 50 18 57

Infinitely

Soluble ---

6. Hydrochloric

Acid (Gas)

Liquefied

Gas Colourless Pungent --- --- -114 -85 --- --- --- Hydrolyses

Toxic,

Corrosive

7. Methanol Liquid Colourless,

waterly Alcoholic Odour 0.79 1.1 -97.8 64.5 16.1 6 36.5

20°C

(Liu) q

Corrosive,

Flammable

8. Phosphorous

Trichloride Liquid

Colurless to

Light Yellow Pungent, Irritant 1.574 4.75 -112 76 --- --- --- Insoluble Toxic, Explosive

9. Mono Chloro

Benzene Liquid

10. Thionyle

Chloride

Fuming

Liquid

Colurless to

Light Yellow Suffocating 1.638 4.1 -104.5 76 --- --- ---

Insoluble in

Cold Water

Corrosive,

Poisonous

11. Xylene Liquid Colourless Sweet Odour 0.864 --- - 134-140 37.7 --- --- insoluble Corrosive,

Flammable


Page 5 of 84

3.2 Safety Measures for Transportation, Storage & Handling of chemicals

Solvent will be received by road tankers / in drums and stored in designated

storage area.

Standard procedure for solvent unloading will be in place and will be

implemented for safe unloading of road tanker.

Static earthing provision will be made for tanker unloading.

Fixed pipelines with pumps will be provided for solvent transfer up to reactors.

NRV provision will be made on all pump discharge line.

Drum handling trolleys will be used for transportation of drums up to plant.

Muffler on the silencer of the tanker during entering in factory premises.

Display Boards will be provided on all storage tanks which includes the name of

the chemicals, storage Material of construction, Calibration of tanks and date of

Painting.

In order to avoid the accident due to spillage or overflow, the level indicators will

be placed which helps to know the exact liquid level inside the tank.

All the storage tanks will be provided with Dyke wall and transferring pumps

which will help to reduce the risk of tank leakages.

Water showering system (Automated sprinkling system) will be provided to the

flammable liquid storage tanks, wherever required to avoid the vaporization due

to increase in atmosphere temperature.

Proper earthing will be provided to all storage tanks to prevent the firing due to

static charges.

Breather Valves and Flame arrestors will be provided on flammable liquid storage

tanks to prevent the firing.

On-site detectors for fire based on heat &/or smoke detection with alarm system

will be provided as required.

Fire fighting system will be provided as required.

First aids boxes will also be provided at prominent places in the plant.

Area will be declared as “NO SMOKE ZONE”.

3.3 Critical Safety Measures for Process Units

Critical safety measures are the most important aspect of selection of process

technology to ensure safety in production unit. For the safety in production area


Page 6 of 84

some important critical safety measures will be provided within the process

technology/ equipment itself & will put continue efforts for developing new

technology/equipment. Company will ensure such provision in the technology

/equipment /machineries at time of purchase. The details of the critical safety

measures for process unit are as below;

• Any reaction upsets will be confined to the reaction vessel itself as defined

quantity of raw materials will be issued to the reaction vessel by metering

pumps/load cells.

• Process parameters control will be provided vide Standard Operating

Procedures.

• Materials will be transferred by pumping through pipeline or by vacuum from

drums.

• All reaction vents will be connected to vapor condensers system.

• Hazardous materials will be transferred by pipelines and in control manners.

• Trained person will be engaged for handling of hazardous materials.

• Proper safety precautions will be taken during handling of hazardous materials.

• All solvents and flammable material storage area away from the process plant

and required quantity of material will be charge in reactor by pump or by gravity.

• Further all the vessels will be examined periodically by a recognized competent

person.

• All the vessels and equipments will be well earthed appropriately and well

protected against Static Electricity. Also for draining in drums proper earthing

facilities will be provided.

• Temperature indicators will be provided near all reactor and distillation systems.

• Caution note, safety posters, stickers, periodic training & updation in safety and

emergency preparedness plan will be displayed and conducted.

• Flame proof light fittings will be installed in the plant.

• All the Plant Personnel will be provided with Personal Protection Equipments to

protect against any adverse health effect during operations, leakage, spillages or

splash. PPE like Helmets, Safety Shoes and Safety Glasses will be provided to

the employees.


Page 7 of 84

• Material Safety Data Sheets of Raw Materials & Products will be kept readily

available at the shop floor.

3.4 Safety Measures For Preventive Maintenance

The safety measures in form of the general Do's & Don'ts for safety in process &

other plant area are as below:

• Do not work on equipments without permission from plant head and maintenance

head.

• Make sure equipment is empty and fluxed with nitrogen and air.

• Check VOC content for flammable and make sure that no flammable vapour

contents.

• Keep proper and adequate fire extinguisher near work area.

• Use proper PPE.

• Do not allow any employment without pre-medical check-up or without checking

fitness.

• Check all motors are disconnected and fuse pulled out before maintenance.

• Work in any equipment must be conducted in presence of supervisor.

• Make sure all process lines are disconnected.

• Additional safety measures in form of the checklist covering Do's & Don'ts of

preventive maintenance, strengthening of HSE, manufacturing utility staff for

safety related measures will be updated timely and will be made available to all

concern department & personnel.

3.5 Safety measures to prevent spillage / leakage of toxic chemicals

The preventive maintenance will be planned and carried out as per plan to avoid the

failure of valve, pipe lines and other component of transferring line. The spillage will

be confined to the dyke area underneath the vessel. The resultant splash of such

chemicals will result in exposure of toxic chemicals to employees. Decontamination

facilities (Safety shower and eye wash fountains) will be provided in the plant area,

which can be used to decontaminate the affected employees.

Suitable decontamination procedure will be used to decontaminate the spilled or

leaked material. The SOP for decontamination will be reared with all related


Page 8 of 84

department. The followings are some measures to be taken for handling the toxic

chemicals safely;

• The installation of all the equipment will be as per guidelines of provision of

Gujarat Factories Rule 1963.

• The storage of corrosive and toxic chemicals will be segregated from each other.

• The piping will be examined thoroughly every year for finding out any defects;

and a defect will be removed forthwith. The record of such examination will be

maintained.

• Smoking will be prohibited inside the factory. Train employees will be employed

for handling of toxic and corrosive chemicals.

• All pipe joints will be provided with heavy duty champion gaskets to prevent any

leakage.

• Self breathing apparatus will be provided and workers will be trained about their

use also.

• Dyke wall will be provided to area where hazardous chemicals are stored.

• Spare barrels of sufficient quantity will be kept ready for any emergency spillage

or leakage.

• Drum trolley will be used for the movement of drums of hazardous chemicals.

• VOC detectors will be installed to implement LDAR

4.

The main effects of chemicals especially VOCs are anticipated in proposed project.

No other source of adverse effects on occupation health & safety is likely to occur.

However, MSDS of hazardous chemicals will be made available with the

management as well as concern personnel working with the materials or area likely

to be affected by the materials. In general following are the key safety measure

which has been recommended with the project.

OCCUPATIONAL HEALTH & SAFETY PROGRAM

• Provision of all necessary equipment like portable detector, online detectors and

other laboratory equipments as mentioned above for regular monitoring of

workplace air and other conditions (VOC, Temperature, Humidity and Light

Intensity etc.).


Page 9 of 84

• Establish the safety policy.

• Compulsory use of necessary PPES

• Installation of Fire extinguishers at required places.

for all workers.

• Regular work place monitoring.

• Protection of storage area with Dyke wall.

• Separate area provision for container decontamination.

• Provision of part time qualified medical officer as per factories act guidelines.

• Pre-medical checkup at the time of employment and maintain form 33 as per

factories act guidelines.

• Regular medical check of employees by qualified medical officer and maintain

health records in prescribed format.

• Monitoring of occupational hazards like noise, ventilation, chemical exposure

should be carried out at frequent intervals.

• Provision of proximity suits and self-breathing apparatus.

• Display various instruction boards, cautionary notices etc. at different locations.

5.

Chemical process industries have undergone tremendous changes during last five

decades. Process conditions such as Pressure & Temperature have become severe;

concentration of stored energy has increased. The scale of possible fire, explosion,

toxic release, body injuries and occupational diseases has grown considerably.

These factors have greatly increased the risk for major industrial disasters, involving

loss of human lives, plant & property and environmental degradation.

Identification analysis and assessment of hazard and risk are very useful in providing

information to risk management. It provides basis for what should be the type and

capacity of its on-site and off-site emergency plan also what types of safety

measures are required. Risk and consequence analysis is carried out considering

storage and handling of various hazardous raw materials, intermediates and

products as well as manufacturing process. The objectives considered for Risk

Assessment study are as follows;

RISK ASSESSMENT STUDY

• To assess the risk involved in transporting, storing & processing raw material up

to final product.


Page 10 of 84

• To define Emergencies including risk & Environment impact assessment.

• To evaluate the risk and to get the complete view of the available facilities.

• To take appropriate action to control the incidents.

• To safe guard employees and people in vicinity.

• To minimize damage to property and neighboring environment.

• To inform the employees, general public & Government authority

aboutvarious type of hazards, assessed risk, safe guards provided, residual

riskif any, and role to be played by them in the event of emergency.

• To inform Police, fire brigade, District authority and statutory authority for

providing help during emergency.

• To work out a plan with all provisions to handle emergencies and to provide

training to employees through mock rehearsals.

• To rescue and give treatment to the casualties and to count the number ofinjured

persons.


Page 11 of 84

Figure 1. Risk Assessment Methodology

Following matrix summarizes methodology adopted for Risk Assement study

START

Facility, process and meteorological data collection

Listing out hazardous operations & storage details

Identification of failure scenarios & quantification of probable hazard associated for risk assessment

Defining parameters for each chemical and each hazard

Defining release type (continuous / instantaneous) & determine release rate

Simulation of different credible scenario for consequence modeling

Prepare Summary of Credible Scenario

Evaluate potential risk associated to the surrounding

Suggest mitigation measures for the risk associated

END


Page 12 of 84

5.1 Identification of High Risk Areas

It is observed that the storage areas pose fire/explosion hazards which may lead to

major accident event. In the process areas it is observed that inventories of

chemicals are very low & so there are not deemed to pose major off-site hazards.

Thus, the quantitative risk assessment studies are limited to unit and some extent in

vicinity.

5.2 Modes of Failure

Storages system can fail in different ways depending on the materials stored,

storage conditions & may involve systems in their vicinity. Conditions such as over

filling, over pressure, missile, lightening or bomb attack, earthquake & resultant

replier or release scenarios have been identified. Outcomes of such incidents are

determined by presence of ignition either immediate or delayed. As can be seen

depending upon modes of failure different scenarios are possible viz:

1. Continuous release

2. Instantaneous release

This may be of gas / liquid depending upon type of material stored/released & its

characteristics. More examples, a liquid boiling at ambient conditions, will

immediately be converted to gas upon exposure to atmosphere.

An instantaneous release is any release occurring for a period less than 15 seconds.

Failure mode responsible for instantaneous releases may be catastrophic failure of

road tanker. For an instantaneous gas release important parameters are release

height & quantity released whereas for instantaneous liquid release, important

parameters are amount spilled, spill area & pool temperature, evaporation rate,

vapour mass etc.

Continuous release occurs when the material is released over a period greater than 15 seconds. For a continuous gas release, important parameters include height of leak above ground, emission rate & total time of release. For continuous liquid release important parameters are spill rates, duration, area & pool temperature, evaporation rate and vapor mass or Gas mass.


Page 13 of 84

5.3 Maximum Credible Accident Analysis and Its Mitigation Measures

A Maximum Credible Accident (MCA) can be characterized as the worst credible

accident. In other words: an accident in an activity, resulting in the maximum

consequence distance that is still believed to be possible. A MCA-analysis does not

include a quantification of the probability of occurrence of the accident. Another

aspect, in which the pessimistic approach of MCA studies appears, is the

atmospheric condition that is used for dispersion calculations.

The Maximum Credible Loss (MCL) scenarios have been developed for the Facility.

The MCL cases considered, attempt to include the worst “Credible” incidents-what

constitutes a credible incident is always subjective. Nevertheless, guidelines have

evolved over the years and based on basic engineering judgment, the cases have

been found to be credible and modeling for assessing vulnerability zones is prepared

accordingly.

The objective of the study is Emergency planning, hence only holistic & conservative

assumptions are used for obvious reasons. Hence, though the outcomes may look

pessimistic, the planning for emergency concept should be borne in mind whilst

interpreting the results.

This has been done for weather conditions having wind speed 1.0 m/s. In

Consequence analysis, geographical location of the source of potential release plays

an important role. Consideration of a large number of scenarios in the same

geographical location serves little purpose if the dominant scenario has been

identified and duly considered.

The Consequence Analysis has been done for selected scenarios by ALOHA

(version 5.4.5) of EPA.The details of software used for MCA analysis are described

below.

A computer based version ALOHA 5.4.5 is used to calculate toxic and explosive

effect of the accidental release of liquid chemicals within the plant area.

ALOHA (Areal Locations of Hazardous Atmosphere) is a computer program

designed especially for use by people responding to chemical release as well as

for emergency planning and training.


Page 14 of 84

ALOHA was jointly developed by the National Oceanic and Atmospheric

Administration (NOAA) and the Environment Protection Agency (EPA).

The mathematical model is based on the Emergency Response Planning

Guidelines (ERPGs) which gives Toxic Levels of Concern (LOCs) to predict the

area where a toxic liquid concentration might be high enough to harm people.

ALOHA models key hazards-toxicity, flammability, thermal radiation (Heat), and

over pressure (expansion blast force)-related to chemical releases that result in

toxic gas dispersion, fire and/or explosion.

5.4 Consequences Analysis

From the proposed raw materials Methanol and Ammonia Gas have been taken for

the consequences analysis considering their hazardous nature. Storage condition

and threshold value of these chemicals are mentioned in the Table 2 & 3. MSDS of

these chemicals are enclosed as Appendix-1.

Table 2: Storage details of Hazardous Chemicals

Sr. No.

Hazardous chemicals

Physical form

Type of storage

Size of Storage

Unit

Qty. of Storage

Unit

Maximum Storage

Capacity (MT)

Storage Pressure Kg/cm

2

Storage Temp.

ºC

1. Methanol Liquid HDPE

Barrel 170 Kg 58 10.0 ATM At RT

2. Ammonia

Gas Gas Cylinder 50 Kg 10 0.5 ATM At RT

3. Ammonia

Liquid Liquid

HDPE Barrel

50 Kg 10 0.5 ATM At RT

4. Acetone Liquid HDPE Barrel

170 Kg 58 10 ATM At RT

5. Cyclo Hexyl

Isocynate Liquid

HDPE Barrel


6. Formic Acid Liquid HDPE Barrel

200 Lit. 10 2.0 ATM At RT

7. Hydrazine Liquid HDPE Barrel

200 Lit. 10 2.0 ATM At RT

8. Mono Chloro

Benzene Liquid

HDPE Barrel

235 Kg 42 10.0 ATM At RT

9. Phosphorus

Tri Chloride Liquid

HDPE Barrel


10. Thionyl

Chloride Liquid GI Barrel 300 Kg 10 3.0 ATM At RT

11. Xylene Liquid HDPE Barrel

190 Kg 15 3.0 ATM At RT


Page 15 of 84

Table 3: Threshold values of the Hazardous Chemicals

Sr. No.

Chemicals Threshold Value (ppm)

ERPG-1 / AEGL-1

ERPG-2 / AEGL-2

ERPG-3 / AEGL-3

1. Methanol 530 2100 7200

2. Ammonia Gas 30 160 1100

3. Ammonia Liquid 30 160 1100

4. Acetone 200 3200 5700

5. Cyclo Hexyl Isocynate - 0.034 0.1

6. Formic Acid 3 25 250

7. Hydrazine 0.1 13 35

8. Mono Chloro Benzene 10 150 400

9. Phosphorus Tri Chloride 0.34 2 5.6

10. Thionyl Chloride - 2.4 14

11. Xylene 130 920 2500

ERPG: Emergency Response Planning Guidelines AEGL: Acute Exposure Guideline Levels

5.4.1 Definitions & Explanation of Terms Used

EPRG-1 : The maximum concentration in air below which it is believed nearly all individuals

could be exposed for up to one hour without experiencing other than mild

transient adverse health effects or perceiving a clearly defined objectionable odor.

EPRG-2 : The maximum airborne concentration below which it is believed that nearly all

individuals could be exposed for up to 1 hour without experiencing or developing

irreversible or other serious health effects or symptoms which could impair an

individual's ability to take protective action.

ERPG-3 : The maximum airborne concentration below which it is believed that nearly all

individuals could be exposed for up to 1 hour without experiencing or developing

life-threatening health effects.

AEGL-1 : The airborne concentration of a substance above which it is predicted that the

general population, including susceptible individuals, could experience notable

discomfort, irritation, or certain asymptomatic nonsensory effects. However, the

effects are not disabling and are transient and reversible upon cessation of

exposure.


general population, including susceptible individuals, could experience

irreversible or other serious, long-lasting adverse health effects or an impaired

ability to escape.


general population, including susceptible individuals, could experience life-


Page 16 of 84

threatening health effects or death.

IDLH : IDLH is an estimate of the maximum concentration in the air to which a healthy

worker could be exposed without suffering permanent or escape-impairing health

effects.

LEL : LEL is the minimum concentration of fuel in the air needed for a fire or an

explosion to occur if an ignition source is present. If the concentration is below

the LEL, there is not enough fuel in the air to sustain a fire or an explosion -- it is

too lean.

UEL : UEL is the maximum concentration of fuel in the air that can sustain a fire or an

explosion if an ignition source is present. If the concentration is above the UEL,

there is not enough oxygen to sustain a fire or an explosion -- it is too rich (much

like an engine that cannot start because it has been flooded with gasoline).

STEL : The concentration to which workers can be exposed continuously for a short

period of time without suffering from (1) Irritation

(2) Chronic or Irreversible tissue damage

(3) Narcosis of sufficient degree to increase injury, impair self-rescue or materially

reduce work efficiency and provide that the daily TLV-TWA is not exceeded.

TWA : The time-weighted average concentration for a normal 8-hour workday and a 40-

hour workweek, to which nearly all workers may be repeatedly exposed, day by

day, without adverse effect.

Source

Strength

: The source strength is either the rate the chemical enters the atmosphere or the

burn rate, depending on the scenario. A chemical may escape very quickly (so

that source strength is high), as when a pressurized container is ruptured, or

more slowly over a longer period of time (so that source strength is low), as when

a puddle evaporates.

Threat zone : It represents the area within which the hazard level (toxicity, flammability, thermal

radiation, or overpressure) is predicted to exceed the Level of Concern (LOC) at

some time after a release begins.

Evaporation

Puddle

: Choose Puddle from the Source submenu under the set up menu to model a

liquid that has spilled and formed a puddle on the ground. ALOHA can model the

puddle either as an evaporating puddle or, if the chemical is flammable, as a Pool

Fire.Choose Puddle when a puddle has already formed on the ground and is not

changing in area. If liquid is continuing to leak from a tank and spilling into a

puddle (so that the puddle's area and volume are increasing) choose Tank from

the Source submenu instead. Check the "Tank source" help topic to learn more

about this option.

Toxic

Threat zone

: A Toxic Level of Concern (LOC) is a threshold concentration of an airborne

pollutant, usually the concentration above which a hazard may exist.

Flammable

Threat zone

: A Flammable Level of Concern (LOC) is a threshold concentration of fuel in the

air above which a flammable hazard may exist. Generally, this LOC will be some

fraction of the Lower Explosive Limit (LEL).


Page 17 of 84

Threat zone

of thermal

radiation

from jetfire

: The thermal radiation effects that people experience depend upon the length of

time they are exposed to a specific thermal radiation level. Longer exposure

durations, even at a lower thermal radiation level, can produce serious

physiological effects. The threat zones displayed by ALOHA represent thermal

radiation levels; the accompanying text indicates the effects on people who are

exposed to those thermal radiation levels but are able to seek shelter within one

minute.

Below are some effects at specific thermal radiation levels and durations (on bare

skin):

• 2 kW/(sq m) -- people will feel pain after 45 seconds and receive second-

degree burns after 3 minutes;

• 5 kW/(sq m) -- people will feel pain after 13 seconds and receive second-

degree burns after 40 seconds; and

• 10 kW/ (sq m) -- people will feel pain after 5 seconds and receive second-

degree burns after 14 seconds.

Threat at

point

: It represents the specific information about the hazards at point of interest (such

as schools and hospitals) in and around the threat zones.

5.4.2 Possible Accident Scenario

Different possible ways of occurrence of any accidents due to storage/usage of

above hazardous chemicals are prescribed here below;

Scenario-A: Release of chemical due to leakage and form evaporating puddle (Not

burning)

Scenario-B: Release of chemical due to leakage and form burning puddle (Pool fire)

Scenario-C: Release of chemical due to catastrophic failure (BLEVE)

Atmospheric conditions assumed at the time of accidents are mentioned in Table 4.

Table 4: Atmospheric Conditions Assumed

Particulars Details

Wind (Max) 3.0 meter/second

Ground Roughness Open Country

Cloud Cover 4 tenths

Air Temperature 32° C

Stability Class D

Relative Humidity 50%


Page 18 of 84

1)

The possibilities of source strength considered at the time of accidents due to

leackage of Methanol from hole of 0.5 inches diameter at bottom of barrel are

mentioned in Table 5.

METHANOL

Table 5: Source Strength considered for Methanol

Particulars Value

Barrel diameter 0.5 m

Barrel height 1.1 m

Barrel volume 0.22 m3

Opening diameter 0.5 inches

Opening from tank bottom 0 m

Internal temperature 18.2 ºC

a) Source Strength

Scenario-1A: Release of Methanol due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Methanol escape from barrel by a hole of 0.5 inch, then maximum average

sustained release rate will be 874 gms/min and hence approx. 40.7 Kg of methanol

will be released in about 1 hour. Isopleths results are given in Figure 2.

Figure 2: Source Strength in case of Methanol escape


Page 19 of 84

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Methanol release is given in Table 6. Threat

zone was not drawn because effects of near-field patchiness make dispersion

predictions less reliable for short distances.

Table 6: Threat zone of toxic liquid concentration

Threat Zone Concentration, ppm

Threat Zone, m

Horizontal Direction

Vertical Direction

Red 5000 (ERPG-3) < 10

Orange 1000 (ERPG-2) < 10

Yellow 200 (ERPG-1) 28

Model output of the flammable threat zone for chemical release is given in Table 7.

Flammable threat zone:

Table 7: Flammable area of vapor cloud

Threat Zone

Concentration, ppm

Threat Zone


Vertical Direction

Red 43,800 (60 % LEL) < 10 m

Yellow 7,300 (10 % LEL) < 10 m

Isopleths result of flammable threat zone showing area of vapor cloud at LEL value

was not drawn because effect of near field patchiness make dispersion prediction

less reliable for short distance.

c) Threat at Point

In case of leakage of Methanol from barrel, the significant effects will be upto 28

meter in case of toxic threat zone with concentration of 200 ppm. Effect has been

worked out at a point in downwind direction within the premises at about 100 meters

distance from the source. Maximum concentration of Methanol estimated at

described point is 17.9 ppm at outdoor and 2.54 ppm in indoor and Isopleths for the

same is shown in Figure 3.


Page 20 of 84

Figure 3: Isopleths result of Toxic threat at a point for Methanol

a) Source Strength

Scenario-2B: Release of Methanol due to leakage & form burning puddle (pool

fire)

When methanol escaped from barrel as a liquid and forms a burning puddle,

maximum burn rate in this case will be 5.88 Kg/min considering maximum attentive

time of 33 min. Moreover, puddle will be spread to a diameter of 2.7 m. Isopleths

results are given in Figure 4.


Page 21 of 84

Figure 4: Source Strength in case of Methanol escapes (pool fire)

b) Threat zone of thermal radiation from pool fire

Model output of the threat zone of thermal radiation from pool fire is given in Table 8.

Table 8: Threat zone of thermal radiation from pool fire

Threat Zone

Thermal Radiation from fire ball, kw/m2

Threat Zone Radial Distance

Red 10 (Potentially lethal within 60 sec.) < 10 m

Orange 5 (2nd < 10 m degree burns within 60 sec)

Yellow 2 (Pain within 60 sec) < 10 m

c) Threat at point

Effect has been worked out at a point in downwind direction within the premises at

about 100 meters distance from the source. Maximum thermal radiation will be

0.00403 kw/m2. Isopleths results are given in Figure 5.


Page 22 of 84

Figure 5: Thermal radiation at a point in case of Methanol escapes (pool fire)

a) Source Strength

Scenario-2C: Release of chemical due to catastrophic failure (BLEVE)

When methanol will be released from barrel as a liquid and forms a fire ball, diameter

of fire ball will be 32 m and burn duration will be 3 seconds.

b) Threat Zone of thermal radiation

Model output and Isopleths result of the threat zone of thermal radiation is given in

Table 9 & Figure 6.

Table 9: Threat zone of thermal radiation from BLEVE

Threat Zone

Thermal Radiation from fire ball, kw/m2 Threat Zone Radial

Distance

Red 10 (Potentially lethal within 60 sec.) 53 m

Orange 5 (2nd 76 m degree burns within 60 sec)

Yellow 2 (Pain within 60 sec) 120 m


Page 23 of 84

Figure 6: Isopleths result of threat zone of thermal radiation from BLEVE

c) Threat at point


about 100 meters distance from the source. The maximum thermal radiation

estimated at point will be 2.9 kW/m2.


Page 24 of 84

2)


ammonia gas are mentioned in Table 10.

AMMONIA GAS

Table 10: Source Strength considered for Ammonia gas

Particulars Value

Cylinder Diameter 0.33 m

Cylinder Height 0.955 m

Cylinder volume 0.082 m3

InternalTemperature 18.2° C

Chemical Mass in cylinder 50 Kg

Scenario – A & B

Circular Opening Diameter 0.5 inches

Opening from Drum bottom 0 m

Ground Type Concrete

Scenario – C

Internal Pressure at Failure 1 atm

Percentage of Tank Mass in Fireball 100%

a) Source Strength

Scenario-2A: Release of Ammonia Gas due to leakage and form evaporating

puddle (Not burning)

When ammonia gas will escapes from cylinder as a gas and formed an evaporating

puddle, Maximum average sustained release rate in this case will be 833 gms/sec

considering maximum attentive time of 1 min. Isopleths results are given in Figure 7.


Page 25 of 84

Figure 7: Source Strength in case of ammonia gas escapes

b) Threat Zone

Model output of the Toxic threat zone and isopleths for chemical release are given in

Table 11 and Figure 8.

Toxic threat zone

Table 11: Toxic Threat zone

Threat Zone Concentration

(ppm)

Threat Zone

Horizontal

Direction

Vertical

Direction

Red 1100 (AEGL-3) 222 m

Orange 160 (AEGL-2) 478 m

Yellow 30 (AEGL-1) 903 m


Page 26 of 84

Figure 8: Isopleths result of toxic threat zone for Ammonia Gas escaping

Model output of the flammable threat zone for chemical release is given in Table 12

and isopleths are given in Figure 9.



Threat Zone

Concentration, ppm

Threat Zone


Vertical Direction

Red 96,000 (60 % LEL) 26 m

Yellow 16,000 (10 % LEL) 67 m


Page 27 of 84

Figure 9: Isopleths result of flammable threat zone for Ammonia Gas escaping

c) Threat at point

In case of leakage of ammonia gas, the significant effects will be upto 67 m in case

of toxic threat zone with concentration of 16000 ppm. Effect has been worked out at

a point in downwind direction at about 2.87 km distance (Village Ribda) from the

source. Maximum concentration of Ammonia estimated at described point is 1.14

ppm at outdoor and 0.046 ppm in ondoor and Isopleths for the same is shown in

Figure 10.


Page 28 of 84

Figure 10: Isopleths result of Toxic threat at a point for Ammonia Gas

a) Source Strength

Scenario-2B: Release of Ammonia Gas due to leakage and form burning

puddle (pool fire)

When ammonia will escape from cylinder as a gas and forms a burning puddle,

maximum burn rate in this case will be 2.36 Kg/sec considering maximum attentive

time of 22 seconds. The chemical will escape from the cylinder and burn as a jet fire.


Page 29 of 84

Figure 11: Source Strength in case of Ammonia Gas escapes (pool fire)

b) Threat zone of thermal radiation from Jet fire

Model output of the threat zone of thermal radiation from jet fire is given in Table 13

and isopleths results are given in Figure 12.

Table 13: Threat zone of thermal radiation from jet fire

Threat Zone







Page 30 of 84

Figure 12: Isopleths result of Thermal radiation from jet fire

c) Threat at point

Effect has been worked out at a point in downwind direction at about 2.87 km

distance (at Village Ribda) from the source. There will be no significant concentration

or effect at given distance.

a) Source Strength


When ammonia will escape from cylinder as a gas and forms a fire ball, diameter of

fire ball will be 21 m and burn duration will be 2 seconds.



Table 14 & Figure 13.


Page 31 of 84


Threat Zone


Distance





c) Threat at point

Effect has been worked out at a point in downwind direction at about 2.87 km

distance (At Village Ribda) from the source. The maximum thermal radiation



Page 32 of 84

3)


leackage of Ammonia from hole of 1 cm diameter at bottom of barrel are mentioned

in Table 15.

AMMONIA LIQUOR

Table 15: Source Strength considered for Ammonia

Particulars Value

Puddle Diameter 1 m

Mass in the Puddle 35 kg

Internal temperature 32 ºC

a) Source Strength

Scenario-A: Release of Ammonia due to leakage and form evaporating puddle (Not burning)

In case of Ammonia escape from barell and forms an evaporating puddle, maximum

average sustained release rate will be 320 gm/min and hence approx. 4.15 Kg of

Ammonia will be released in about 1 hour. Isopleths results are given in Figure 14.

Figure 14: Source Strength in case of Ammonia escape


Page 33 of 84

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Ammonia release is given in Table 16. Toxic

Threat zone is given in Figure 15.



Threat Zone, m


Vertical Direction

Red 1100 (AEGL-3) 14

Orange 160 (AEGL-2) 41

Yellow 30 (AEGL-1) 98

Figure 15: Threat zone of toxic liquid concentration


Page 34 of 84




Threat Zone

Concentration, ppm

Threat Zone (m)


Vertical Direction

Red 90,000 (60 % LEL) <10

Yellow 15,000 (10 % LEL) <10

Flammable threat zone was not drawn because effect of near field patichiness

makes the dispersion less reliable for short distance.

c) Threat at Point

In case of leakage of Ammonia from barrel, the significant effects will be upto 98



distance from the source. Maximum concentration of Ammonia estimated at




Page 35 of 84

Figure 16: Isopleths result of Toxic threat at a point for Ammonia

4)


leackage of Acetone from hole of 0.5 inch diameter at bottom of barrel are


ACETONE

Table 18: Source Strength considered for Acetone

Particulars Value


Barrel height 0.85 m

Barrel volume 200 Lit

Opening diameter 0.5 inch



a) Source Strength

Scenario-1A: Release of Acetone due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Acetone escape from barrel by a hole of 0.5 inch, maximum average

sustained release rate will be 4.12 kg/min and hence approx. 157 Kg of Acetone will

be released in about 1 hour. Isopleths results are given in Figure 17.


Page 36 of 84

Figure 17: Source Strength in case of Acetone escape


Page 37 of 84

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Acetone release is given in Table 19. Toxic

threat zone was not drawn because effects of near-field patchiness make dispersion

prediction less reliable for short distances.



Threat Zone, m


Vertical Direction

Red 5700 (AEGL-3) <10

Orange 3200 (AEGL-2) <10




Table 20: Flammable area of vapour cloud

Threat Zone

Concentration, ppm

Threat Zone (m)


Vertical Direction

Red 15,600 (60 % LEL) <10

Yellow 2,600 (10 % LEL) <10

Threat zone for flammable area of vapor cloud is not drawn because effects of near-

field patchiness make dispersion predications less reliable for short distances.

a) Threat at Point

In case of leakage of Acetone from barrel, the significant effects will be upto 34



distance from the source. Maximum concentration of Acetone estimated at described

point is 28 ppm at outdoor and 8.22 ppm in indoor and Isopleths for the same is

shown in Figure 18.


Page 38 of 84

Figure 18: Isopleths result of Toxic threat at a point for Acetone

a) Source Strength

Scenario-2B: Release of Acetone due to leakage & burns as a Pool fire

When Acetone escaped from barrel as a liquid and forms a burning puddle,

maximum burn rate in this case will be 5.82 Kg/min considering maximum attentive

time of 28 min. Moreover, puddle will be spread to a diameter of 1.6 m. Isopleths

results are given in Figure 19.


Page 39 of 84

Figure 19: Source Strength in case of Acetone escapes (pool fire)


Model output of the threat zone of thermal radiation from jet fire is given in Table 21.


Threat Zone



(m)

Red 10 (Potentially lethal within 60 sec.) < 10

Orange 5 (2nd < 10 degree burns within 60 sec)

Yellow 2 (Pain within 60 sec) < 10

c) Threat at point





Page 40 of 84

Figure 20: Thermal radiation at a point in case of Acetone escapes (pool fire)

a) Source Strength


When Acetone will be released from barrel as a liquid and forms a fire ball, diameter






Threat Zone


Distance (m)

Red 10 (Potentially lethal within 60 sec.) 58

Orange 5 (2nd 83 degree burns within 60 sec)

Yellow 2 (Pain within 60 sec) 130


Page 41 of 84


c) Threat at point





Page 42 of 84

5)


leackage of Cyclo Hexyl Isocynate from hole of 0.5 inch diameter at bottom of barrel

are mentioned in Table 22.

CYCLO HEXYL ISOCYNATE

Table 22: Source Strength considered for Cyclo Hexyl Isocynate

Particulars Value


Barrel height 0.7 m

Barrel volume 49.5 Lit




a) Source Strength

Scenario-1A: Release of Cyclo Hexyl Isocynate due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Cyclo Hexyl Isocynate escape from barrel by a hole of 0.5 inch, maximum

average sustained release rate will be 35.8 gm/min and hence approx. 2.04 kg of

Cyclo Hexyl Isocynate will be released in about 1 hour. Isopleths results are given in

Figure 22.


Page 43 of 84

Figure 22: Source Strength in case of Cyclo Hexyl Isocynate escape

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Cyclo Hexyl Isocynate release is given in Table

24. Toxic Threat zone is given in Figure 23.



Threat Zone, m


Vertical Direction

Red 0.1 (AEGL-3) 107

Orange 0.034 (AEGL-2) 185

Yellow NA (AEGL-1) No recommended LOC

value


Page 44 of 84



Page 45 of 84



Threat zone was not drawn because effects of near-field patchiness make dispersion

results less reliable for short distances.


Threat Zone

Concentration, ppm

Threat Zone (m)


Vertical Direction

Red 6,600 (60 % LEL) < 10

Yellow 1,100 (10 % LEL) < 10

c) Threat at Point

In case of leakage of Cyclo Hexyl Isocynate from barrel, the significant effects will be

upto 185 meter in case of toxic threat zone with concentration of 0.034 ppm. Effect

has been worked out at a point in downwind direction within the premises at about

100 meters distance from the source. Maximum concentration of Cyclo Hexyl

Isocynate estimated at described point is 0.114 ppm at outdoor and 0.047 ppm in

indoor and Isopleths for the same is shown in Figure 24.


Page 46 of 84

Figure 24: Isopleths result of Toxic threat at a point for Cyclo Hexyl Isocynate

The chemical is below its flash point and is unlikely to catch on fire.

Scenario-2B: Release of Cyclo Hexyl Isocynate due to leakage & burns as a

Pool fire)

a) Source Strength


When Cyclo Hexyl Isocynate will be released from barrel as a liquid and forms a fire

ball, diameter of fire ball will be 94 m and burn duration will be 2 seconds.





Threat Zone


Distance (m)





Page 47 of 84


c) Threat at point





Page 48 of 84

6)


leakage of Formic Acid from hole of 0.5 inch diameter at bottom of barrel are


FORMIC ACID

Table 27: Source Strength considered for Formic Acid

Particulars Value







a) Source Strength

Scenario-1A: Release of Formic Acid due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Formic Acid escape from barrel by a hole of 0.5 inch, maximum average

sustained release rate will be 1.73 kg/min and hence approx. 78.7 Kg of Formic Acid


Figure 26: Source Strength in case of Formic Acid escape


Page 49 of 84

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Formic Acid release is given in Table 28. Toxic




Threat Zone, m


Vertical Direction

Red 250 (ERPG-3) 14

Orange 25 (ERPG-2) 75

Yellow 3 (ERPG-1) 227



Page 50 of 84




Threat Zone

Concentration, ppm

Threat Zone (m)


Vertical Direction

Red 72,000 (60 % LEL) <10

Yellow 12,000 (10 % LEL) < 10



c) Threat at Point

In case of leakage of Formic Acid from barrel, the significant effects will be upto 227

m in case of toxic threat zone with concentration of 3 ppm. Effect has been worked

out at a point in downwind direction within the premises at about 100 meters

distance from the source. Maximum concentration of Formic Acid estimated at



Figure 28: Isopleths result of Toxic threat at a point for Formic Acid


Page 51 of 84


Scenario-2B: Release of Formic Acid due to leakage & burns as a Pool fire

a) Source Strength


When Formic Acid will be released from barrel as a liquid and forms a fire ball,

diameter of fire ball will be 32 m and burn duration will be 3 seconds.





Threat Zone


Distance (m)






Page 52 of 84

c) Threat at point



estimated at point will be 0.726 kW/m2

7)

.


leakage of Hydrazine from hole of 0.5 inch diameter at bottom of barrel are


HYDRAZINE

Table 31: Source Strength considered for Hydrazine

Particulars Value








Page 53 of 84

a) Source Strength

Scenario-1A: Release of Hydrazine due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Hydrazine escape from barrel by a hole of 0.5 inch, maximum average

sustained release rate will be 494 gm/min and hence approx. 22.9 Kg of Hydrazine



Page 54 of 84

Figure 30: Source Strength in case of Hydrazine escape

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Hydrazine release is given in Table 32. Toxic




Threat Zone, m


Vertical Direction

Red 35 (AEGL-3) 36


Yellow 0.1 (AEGL-1) 843


Page 55 of 84





Threat Zone

Concentration, ppm

Threat Zone (m)


Vertical Direction

Red 28,020 (60 % LEL) <10

Yellow 4,670 (10 % LEL) <10




Page 56 of 84

c) Threat at Point

In case of leakage of Hydrazine from barrel, the significant effects will be upto 843 m

in case of toxic threat zone with concentration of 0.1 ppm. Effect has been worked

out at a point in downwind direction within the premises at about 100 meters

distance from the source. Maximum concentration of Hydrazine estimated at



Figure 32: Isopleths result of Toxic threat at a point for Hydrazine


Scenario-2B: Release of Hydrazine due to leakage & burns as a Pool fire

a) Source Strength


When Hydrazine will be released from barrel as a liquid and forms a fire ball,

diameter of fire ball will be 34 m and burn duration will be 3 seconds.


Page 57 of 84





Threat Zone


Distance (m)





c) Threat at point






Page 58 of 84

8)


leakage of Mono Chloro Benzene from hole of 0.5 inch diameter at bottom of barrel


MONO CHLORO BENZENE

Table 35: Source Strength considered for Mono Chloro Benzene

Particulars Value







a) Source Strength

Scenario-1A: Release of Mono Chloro Benzene due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Mono Chloro Benzene escape from barrel by a hole of 0.5 inch, maximum

average sustained release rate will be 1.17 kg/min and hence approx. 53.5 Kg of

Mono Chloro Benzene will be released in about 1 hour. Isopleths results are given in

Figure 34.

Figure 34: Source Strength in case of Mono Chloro Benzene escape


Page 59 of 84

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Mono Chloro Benzene release is given in

Table 36. Toxic Threat zone is given in Figure 35. However, Toxic threat zone was

not drawn for Red and Orange zone because effect of near-field patchiness made

dispersion predictions less reliable for short distances



Threat Zone, m


Vertical Direction

Red 400 (AEGL-3) <10

Orange 150 (AEGL-2) <10




Page 60 of 84



Threat zone was not drawn because effects of near-field patchiness made dispersion

predictions less reliable for short distances.


Threat Zone

Concentration, ppm

Threat Zone (m)


Vertical Direction

Red 7,800 (60 % LEL) <10

Yellow 1,300 (10 % LEL) <10

a) Threat at Point

In case of leakage of Mono Chloro Benzene from barrel, the significant effects will be

upto 61 meter in case of toxic threat zone with concentration of 10 ppm. Effect has

been worked out at a point in downwind direction within the premises at about 100

meters distance from the source. Maximum concentration of Mono Chloro Benzene

estimated at described point is 4.02 ppm at outdoor and 1.37 ppm in indoor and

Isopleths for the same is shown in Figure 36.


Page 61 of 84

Figure 36: Isopleths result of Toxic threat at a point for Mono Chloro Benzene

a) Source Strength

Scenario-2B: Release of Mono Chloro Benzene due to leakage & burns as a

Pool fire)

When Mono Chloro Benzene escaped from barrel as a liquid and forms a burning

puddle, maximum burn rate in this case will be 6.9 Kg/min considering maximum

attentive time of 33 min. Moreover, puddle will be spread to a diameter of 1.6 m.

Isopleths results are given in Figure 37.


Page 62 of 84

Figure 37: Source Strength in case of Mono Chloro Benzene escapes (pool fire)


Model output of the threat zone of thermal radiation from pool fire is given in Table

38.


Threat Zone



(m)

Red 10 (Potentially lethal within 60 sec.) <10

Orange 5 (2nd <10 degree burns within 60 sec)

Yellow 2 (Pain within 60 sec) <10


Page 63 of 84

c) Threat at point




Figure 38: Thermal radiation at a point in case of Mono Chloro Benzene escapes (pool fire)

a) Source Strength


When Mono Chloro Benzene will be released from barrel as a liquid and forms a fire

ball, diameter of fire ball will be 35 m and burn duration will be 3 seconds.





Page 64 of 84


Threat Zone


Distance (m)





c) Threat at point





Page 65 of 84

9)


leakage of Phosphorus Trichloride from hole of 0.5 inch diameter at bottom of barrel


PHOSPHORUS TRICHLORIDE

Table 40: Source Strength considered for Phosphorus Trichloride

Particulars Value


Barrel height 0.8 m





a) Source Strength

Scenario-1A: Release of Phosphorus Trichloride due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Phosphorus Trichloride escape from barrel by a hole of 0.5 inch,

maximum average sustained release rate will be 2.84 kg/min and hence approx. 100

Kg of Phosphorus Trichloride will be released in about 1 hour. Isopleths results are

given in Figure 40.

Figure 40: Source Strength in case of Phosphorus Trichloride escape


Page 66 of 84

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Phosphorus Trichloride release is given in

Table 41. Toxic Threat zone is given in Figure 41.



Threat Zone, m


Vertical Direction

Red 5.6 (AEGL-3) 122

Orange 2.0 (AEGL-2) 206




Page 67 of 84

c) Threat at Point

In case of leakage of Phosphorus Trichloride from barrel, the significant effects will

be upto 515 m in case of toxic threat zone with concentration of 0.34 ppm. Effect has

been worked out at a point in downwind direction within the premises at about 100

meters distance from the source. Maximum concentration of Phosphorus Trichloride

estimated at described point is 8.26 ppm at outdoor and 2.31 ppm in indoor and

Isopleths for the same is shown in Figure 42.

Figure 42: Isopleths result of Toxic threat at a point for Phosphorus Trichloride


Page 68 of 84

10)


leakage of Thionyl Chloride from hole of 0.5 inch diameter at bottom of barrel are


THIONYL CHLORIDE

Table 42: Source Strength considered for Thionyl Chloride

Particulars Value


Barrel height 0.8 m





a) Source Strength

Scenario-1A: Release of Thionyl Chloride due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Thionyl Chloride escape from barrel by a hole of 0.5 inch, maximum

average sustained release rate will be 2.84 kg/min and hence approx. 100 Kg of

Thionyl Chloride will be released in about 1 hour. Isopleths results are given in

Figure 43.


Page 69 of 84

Figure 43: Source Strength in case of Thionyl Chloride escape

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Thionyl Chloride release is given in Table 43.

Toxic Threat zone is given in Figure 44.



Threat Zone, m


Vertical Direction

Red 5.6(AEGL-3) 122




Page 70 of 84


c) Threat at Point

In case of leakage of Thionyl Chloride from barrel, the significant effects will be upto

515m in case of toxic threat zone with concentration of 0.34 ppm. Effect has been


distance from the source. Maximum concentration of Thionyl Chloride estimated at




Page 71 of 84

Figure 45: Isopleths result of Toxic threat at a point for Thionyl Chloride


Page 72 of 84

11)


leakage of Xylene from hole of 0.5 inch diameter at bottom of barrel are mentioned in

Table 44.

XYLENE

Table 44: Source Strength considered for Xylene

Particulars Value







a) Source Strength

Scenario-1A: Release of Xylene due to leakage from Barrel and form evaporating puddle (Not burning)

In case of Xylene escape from barrel by a hole of 0.5 inch, maximum average

sustained release rate will be678 gm/min and hence approx. 31.8 Kg of Xylene will

be released in about 1 hour. Isopleths results are given in Figure 46.

Figure 46: Source Strength in case of Xylene escape


Page 73 of 84

b) Threat Zone

Toxic Threat Zone

Model output of Toxic threat zone for Xylene release is given in Table 45. Toxic

Threat zone is not drawn because effects of near-field patchiness make the

dispersion less reliable for short distances.



Threat Zone, m


Vertical Direction

Red 1000 (PAC-3) <10

Orange 200 (PAC-2) <10

Yellow 150 (PAC-1) <10




Threat Zone

Concentration, ppm

Threat Zone (m)


Vertical Direction

Red 6,600 (60 % LEL) <10

Yellow 1,100 (10 % LEL) <10



c) Threat at Point

In case of leakage of Xylene from barrel, the significant effects will be upto <10 m in

case of toxic threat zone with concentration of 150 ppm. Effect has been worked out

at a point in downwind direction within the premises at about 100 meters distance

from the source. Maximum concentration of Xylene estimated at described point is

2.46 ppm at outdoor and 0.862 ppm in indoor and Isopleths for the same is shown in

Figure 47.


Page 74 of 84

Figure 47: Isopleths result of Toxic threat at a point for Xylene

d) Source Strength

Scenario-2B: Release of Xylene due to leakage & burns as a Pool fire)

When Xylene escaped from barrel as a liquid and forms a burning puddle, maximum

burn rate in this case will be 6.16 Kg/min considering maximum attentive time of 29

min. Moreover, puddle will be spread to a diameter of 1.3 m. Isopleths results are

given in Figure 48.


Page 75 of 84

Figure 48: Source Strength in case of Xylene escapes (pool fire)

e) Threat zone of thermal radiation from pool fire

Model output of the threat zone of thermal radiation from pool fire is given in Table

47.


Threat Zone



(m)

Red 10 (Potentially lethal within 60 sec.) <10

Orange 5 (2nd <10 degree burns within 60 sec)

Yellow 2 (Pain within 60 sec) <10

f) Threat at point





Page 76 of 84

Figure 49: Thermal radiation at a point in case of Xylene escapes (pool fire)

a) Source Strength


When Xylene will be released from barrel as a liquid and forms a fire ball, diameter






Threat Zone


Distance (m)





Page 77 of 84


c) Threat at point





Page 78 of 84

Risk Mitigative Measures

Layout and location of hazardous chemical storage are will be based on natural

and mechanical ventilation.

For any case of fire emergency, standard type of Fire extinguishers will be

provided in the storage area as well as required places in the plant.

Regular inspection of all barrels/ drums of hazardous chemicals will be carried

out before it will be taken to the storage area and damaged drums will be

separated and disposed to avoid the possibility of catastrophic rupture.

All equipments related to hazardous chemical storage will be maintained and

calibrated regularly.

A trained person will be deployed for handling operation.

First-aid facility and first-aid trained person will be available at the time of

handling operation.

The adequate and suitable personnel protective equipments will be provided to

the operating workers.

SOP for handling will be displayed in local language for safe operating procedure.

6.

As emergency is said to have risen when operators in the plant are not able to cope

with a potential hazardous situation i.e. loss of an incident causes the plant to go

beyond its normal operating conditions, thus creating danger. When such an

emergency evolves, chain of events which affect the normal working within the

factory area and / or which may cause injuries, loss of life, substantial damage to

property and environment both inside and around the factory takes place and a

DISASTER is said to have occurred.

Various steps involved in Disaster Management Plan can be summarized as follows:

ONSITE EMERGENCY PLAN AND DISASTER MANAGEMENT PLAN

1. Minimize risk occurrence (Prevention)

2. Rapid Control (emergency response)

3. Effectively rehabitate damaged areas (Restoration)

Disaster Management Plan is evolved by careful scrutiny and interlinking of

a. Types and causes of disaster

b. Technical know-how


Page 79 of 84

c. Resource availability

Types of Disaster:

a. Due to Fire and Explosion

b. Due to Vapour Cloud

c. Due to Toxic Gas Release from:

i. Within the Unit

ii. External Sources

d. Hurricane, Flood, Cyclone and other Natural Calamities

This plan is developed to make best possible use of resources to:

• Reduce possibilities of accident.

• Contain the incident and control it with minimum damage.

• Safeguard others

• Rescue the victims and treat them suitable.

• Identify the persons affected/ dead.

• Inform relatives of the causalities.

• Provide authorative information to the news media.

• Preserve relevant records and equipment needed as evidence incase of any

inquiry.

• Rehabilitate the affected areas.

The primary purpose of the on-site emergency plan is to control and contain the

incident and so as to prevent from spreading to nearby plant. It is not possible to

cover every eventuality in the plan and the successful handling of the

emergency will depend on appropriate action and decisions being taken on the spot.

Following three staged activities are suggested as they are co-related and

provide better points for emergency preparedness, emergency action and

subsequent follow up.

6.1 Pre-emergency activity

The following are the details of Pre-emergency plan:

Internal Safety Survey

It is conducted by Safety department.

To identify various hazards in plant area.


Page 80 of 84

To check protective equipment of workability.

To check various Safety installations.

To check fire system, fire water pumps, water shower etc.

To suggest extra modification required.

Third Party Survey

Experts of consultants conduct Third Party Survey.

To identify various hazards inside the factory.

To conduct survey on available Safety equipments.

To check built in safety system for its efficiency.

To suggest modification/new additions in the system.

Non-Destructive Testing (NDT)

To prepare a list of equipments/pipe lines for non-Destructive testing.

To prepare a plan for replacements/repairs as per testing reports.

To maintain Plant wise record to compare with the last period.

Safety valve Testing

To prepare a list in the plant.

To prepare a periodic schedule for their testing & maintaining record.

To prepare a plan for replacements/repairs.

Fire Fighting system Testing

To prepare a list of fire hydrants, Fire Fighting appliances, Fire water pumps and

other available appliances and maintain the record.

To plan for testing schedule.

To replace defective equipments/accessories.

To check fire water pumps capacity.

To check all fire fighting equipments/appliances under fire services for operability.

Mock drills

To conduct Internal mock drill for training the workers.

To conduct drills to check the performance of workers and equipments.

To know the draw backs/defects of the system and its corrective actions.

Training

To operate regular training of employees for handling various safety equipments.

To train workers for fire emergency.

To educate workers for different type of emergency.


Page 81 of 84

Personal Protective Equipments (PPE)

To arrange for sufficient quantity of personal protective equipments.

To train workers to use each PPE.

To maintain them in good condition.

Communication

To maintain internal/external communication system in good working condition.

To modify the siren sound for emergency.

To install wind-sacks to indicate wind direction.

Emergency Lights

To check and maintain the emergency lights in control room and selected areas.

To keep sufficient number of torches in supervisor’s cabin/plant and in each

department.

Emergency Control Room

To identify the place of emergency control room.

To identify the alternative emergency control room.

To keep sufficient quantity of PPE in control rooms.

To provide proper telephone system in emergency control room.

To provide plan of the factory showing hazardous points and emergency control

point in emergency control room.

Assembly Points

To identify the location for assembling the plant emergency staff and co-ordinate

in case of emergency

To utilize the services of others to fix assembly points for non essential workers

and to assemble in case of emergency.

Liaison with State Authorities

To keep liaison with police, fire brigade, Factory Inspector, Collector, local

hospital and keep them informed.

To inform them about the requirement in advance.

To keep them informed about mock drills.

6.2 Emergency Time Activities

Under these activities, the staff in the plant at various levels with pre-assigned duties

is expected to work in a coordinated manner to meet emergency situation, remove


Page 82 of 84

the emergency conditions and bring the plant to normal with the help of resources

available within and out side the plant. Availability and correct use of different means

of communication and control is an important time activity. Sequence of action in

case of various types of emergencies (Fire and Leakage of chemicals):

Any person noticing fire or explosion or leakage of chemicals from pipeline or

other equipment, should attract attention of nearby personnel by using or siren

available within premises.

The area should be checked clear of people and organize emergency shut down

of the plant/ equipment.

The total quantity of chemical leaked should be ascertained and discharge of Air

pollutants through stack should be stopped.

Other persons in the area will help the injured persons to go out of the

place i.e. at open area and immediately arrange for first aid.

Simultaneously by Telephone he will contact the emergency control centre.

He will inform the Incident controllers and key personnel depending upon the

nature of emergency.

He will also guide the out side agency emergency aid services till the Incident

Controller/ Site Main Controller reaches to the site of Incident.

As soon as Incident controller/Site Main Controller reaches to the site of incident

he will take charge of the situation and guide/advice in tackling the emergency.

It is necessary to know that every one on the site should be accounted for and

that the relatives of causalities will be informed. It is necessary to have an up

dated list of the names of people at site on Holidays and weekly off days.

If the situation is not likely to be controlled by the available sources incident

controller/Site Main controller will assess the situation and declare the emergency

as “OFF SITE EMERGENCY”.

The incident controller/Site Main Controller will continue to do the available

resources to control and contain the emergency till the outside authorities and aid

services reaches to the incident site.

After District Authority reaches to the site, he will extend all the necessary help,

assistance and give required information/data as when required to control &

contain the emergency.


Page 83 of 84

6.3 Post – Emergency Activities

A post-emergency base activity of steps taken after the emergency is over so as to

establish the reasons of the emergency and preventive measures to be taken.

The main steps involve:

Collection of records

Conducting inquiries and preventive measures.

Making Insurance claims

Inquiry reports and suggestions Implementations

7.

The Off site emergency plan is made based on events, which could affect people

and Environment out side the premises. The off site plan is largely a matter of

ensuring the co-ordination of proposed services and their readiness as far as

possible, for the specific hazards and problems, which may arise in as incident.

Briefly two main purposes of the plan are as under:

OFF SITE EMERGENCY PLAN

To provide the local district authorities, police, fire brigade, doctors etc. the basic

information of risk and environmental impact assessment and to appraise them of

the consequences and the protection / prevention measures and control plans

and to seek their help to communicate with the public in case of major

emergency.

To assist the district authorities for preparing the off site emergency plan for the

district or particular area. We have made our key personnel and other fully aware

about this aspect. The function of the off site plans are as under:

Structure of the off site emergency plan includes the following:-

Organizational set up-Incident controller /Site main controller, Key personnel, etc

Communication facilities - List of important telephones

Specialized emergency equipment - Fire fighting equipment

Specialized Knowledge - Trained people

Voluntary Organization - Details of organization

Chemical information - MSDS of hazardous substances

Meteorological information - Weather condition, Wind velocity etc

Humanitarian arrangement - Transport, First aid, Ambulance


Page 84 of 84

Role of the factory management

The on site and off site plans are come together so that the emergency services are

call upon at the appropriate time and are provided with accurate information and a

correct assessment of situation.

Role of local authority

Generally the duty to prepare the off-site plan lies with the local authority. They may

have appointed an emergency planning officer (EPO) to prepare whole range of

different emergency within the local authority area.

Role of fire authority

The control of a fire is normally the responsibility of the senior fire brigade officer who

would take over the handling of fire from the Incident Controller on arrival at the site.

Role of police

The overall control of an emergency is normally assumed by the police with a senior

officer designated as emergency coordinating officer. Formal duties of the police

during emergency include protection of life and property and controlling traffic

movements.

Role of health authorities

Health authorities, including doctors, surgeons, hospitals, ambulances etc. have a

vital role to play following a major accident and they should form an integral part of

the emergency plan. Major off site incidents are likely to require medical equipments

and facilities in addition to those available locally.

Role of the “mutual aid” agencies

Some types of mutual aids are available from the surrounding factories, as per need,

as a part of the on site and off site emergency plan.

The role of the factory inspectorate

In the event of an accident, the factory inspector will assist the District Emergency

Authority for information and help in getting mutual aid from surrounding factories.

Unit maintains the records of details of emergency occur, corrective preventive

measures taken and in future the same practice will be continue. Unit has displayed

the details like list of assembly points, name of the persons involve in the safety

team like site controller, incident controller etc.

ANNEXURE- 8

Undertaking by the project proponent and consultant

REGO. OFF.: 3rd Floor, Aka8h Ganga Complex, B/8. Suvidha Shopping Centre, EnvisafeNr. Parimal Underpass, Paldi, Ahmedabad-380 007. Gujarat, INDIA. Tele/Fax: +91 7926650878, 26650473 E·mail : [email protected] Environment Consultants

Environmental Consultancy & laboratory

UNDERTAKING

I THE UNDERSIGNED; PUSHPIN V. SHAH AS A PROPRIETOR OF MIS. ENVISAFE

ENVIRONMENT CONSULTANTS HAVING OFFICE AT 3rd Floor, AKASH GANGA COMPLEX,

BESIDES SUVIDHA SHOPPING CENTRE, NEAR PARIMAL UNDERPASS, PALDI,

AHMEDABAD-380007; DO HEREBY UNDERTAKE AS FOLLOWS;

(1) OURS IS AN ORGANIZATION ACCREDITED AS AN EIA CONSULTANT

ORGANIZATION BY NATIONAL ACCREDITATION BOARD FOR EDUCATION AND

TRAINING, QUALITY COUNCIL OF INDIA (NABET/QCI), NEW DELHI.

(2) WE HAVE BEEN ASSIGNED RESPONSIBILITY AS AN EIA CONSULTANT TO CARRY

OUT EIA STUDY FOR PROPOSED PROJECT OF MIS. ASCENT PHARMA LOCATED

AT SURVEY NO. 163/9 & 11 ON S.I.D.C. ROAD IN SHAPAR-VERAVAL INDUSTRIAL

AREA, TALUKA KOTADA SANGANI, DISTRICT RAJKOT.

(3) THE EIA STUDY IS CARRIED OUT AS PER THE GUIDELINES OF THE MINISTRY OF

ENVIRONMENT, FOREST AND CLIMATE CHANGE (MoEF&CC), NEW DELHI AND

THE EIA REPORT IS PREPARED CONSIDERING THE GENERIC STRUCTURE

PROVIDED IN THE APPENDIX III AND lilA OF THE EIA NOTIFICATION, 2006

(4) TORs ISSUED BY MOEF VIDE LETTER NO. J-11011/210/2013-IA-1I (I) DATED

07/11/2013 HAVE BEEN ADDRESSED AND INCORPORATED IN ALL RESPECTS IN

THE EIA REPORT SUBMITTED HEREWITH.

(5) ALL THE DATA SUBMITTED IN THIS ENVIRONMENTAL IMPACT ASSESSMENT

REPORT IS FACTUALLY CORRECT.

I SOLEMNLY AFFIRMED THAT THE ABOVE STATED DETAILS ARE TRUE TO THE BEST

OF MY KNOWLEDGE AND BELIEF.

DATE: Oi \ O~ 12-016' w· NAME: PUSHPIN V. SHAHPLACE: AHMEDABAD

Branch: 27, Akash Villas, Near 500 Quarters, G.I.D.C, New Colony, ANKLESHWAR - 393 002. Dist : Bharuch Mob. : +91 9328961241

mailto:[email protected]

Annexure-8

Undertaking by Proponent

ANNEXURE- 9

Project Summary & Conclusion as per the generic structure of EIA notification

Project Summary & Conclusion Proposed Project for Manufacturing of Synthetic Organic Chemicals

Page | 11.1

PROJECT SUMMARY & CONCLUSIONS

11.1

M/s. Ascent Pharma is an existing small scale unit located at Survey No. 163/9 & 11 on

S.I.D.C. Road in Shapar-Veraval Industrial Area of Village Veraval (Shapar) in Kotada

Sangani Taluka of Rajkot District in Gujarat state. At present the unit is manufacturing

various Inorganic Chemicals with the total production capacity of 50 TPM. Now, considering

the market demand, the unit intends to manufacture various Bulk Drugs & Drugs

Intermediates (Synthetic Organic Chemicals) with total production capacity of 55 TPM within

the existing premises by utilizing existing infrastructure facilities with the addition of new

machineries.

PROJECT DESCRIPTION

Unit has applied for grant of EC for the proposed expansion at MoEF under 5(f)-A category

since the project site is located outside the notified industrial area. Hence, ToR was issued

by MoEF vide file no. J-11011/210/2013-IA.II (I) dated 7th November 2013. Public Hearing

for the proposed project was conducted by Gujarat Pollution Control Board on 15th October

2014 and EIA report was submitted on 10th

Now, as per the amendment to EIA Notification 2006 vide SO 1599 (E) dated 25

November 2014.

th June

2014, small scale units are categorized under Category B projects. Meeting the criteria of

water consumption less than 25 m3/day, fuel consumption less than 25 TPD and not covered

in the category of MAH units as per MSIHC Rule, 1989, MoEF has transferred the

application vide file no. J-11011/108/2013-IA II (I) dated 23rd February 2015 to SEIAA,

Gujarat which was received on 9th

The EIA Study has been carried out by M/s. Envisafe Environment Consultants,

Ahmedabad, Gujarat which is based on one season field data collected from the study area

during December 2013 to February 2014 (Winter Season) and the same data has been used

in assessment of impacts due to the proposed project.

March 2015 by SEIAA.

Status

DETAILS OF PROPOSED PROJECT

: Small Scale Unit; Proposed Project for manufacturing

of various Bulk Drugs & Drugs Intermediates within

the existing premises

Product & Capacity :

Sr. No.

Name of Product Capacity TPM

Existing Proposed Total

Products

1 Potassium Nitrate 10.0 Nil 10.0

2 Potassium Sulphate 10.0 Nil 10.0

3 Magnesium Hydroxide 10.0 Nil 10.0

4 Potassium Chloride 10.0 Nil 10.0


Page | 11.2

5 Potassium Iodide 10.0 Nil 10.0

6 Oxyclozanide Nil 25.0 25.0

7 Glibenclamide Nil 20.0 20.0

8 A. 1,2,4 Triazole

Nil 10.0 10.0 B. 4-Amino -1,2,4 Triazole

Total 50.0 55.0 105.0

By-Product

1 Hydrochloric Acid (30%) Nil 15.5 15.5

2 Sodium Bi-Sulphite Nil 26.0 26.0

3 Phosphorous Acid Aq. Nil 3.3 3.3

Use of Products : The products are widely used in pharmaceutical

industries for manufacturing of medicines and drugs.

Land Type & Availability

General Information:

: Proposed project will be carried out within the

existing industrial premises having an area of 2,292

sq.m. and no additional land will be required for the

proposed project.

Capital Investment, (Lacs) : Existing: 48.57, Proposed: 36.50 & Total: 85.07

Capital Investment for EMP, Lacs

: Proposed: 5.5

Recurring Cost for EMP, Lacs/Annum

: Existing: 2.10, Proposed: 4.65 & Total: 6.75

CSR Cost, Lacs/Annum : 0.5

Raw materials

Resources requirements:

: After proposed project, about 18 raw materials will be

required including 5 solvents. All the raw materials

are available in the local market.

Source of water supply : Water supply by Veraval (Shapar) Gram Panchayat

through tanker OR private water supply through

tanker

Fresh Water Requirement, KLD

:

Existing: 1.7, Proposed: 6.51, Total: 8.21

Industrial:


Domestic:


Gardening:

Power Source : Pashchim Gujarat Vij Company Ltd. (PGVCL)

Power Requirement : Existing:45 KVA, Proposed: 15 KVA, Total: 60 KVA

Fuel Requirement : FO/ LDO (KL/Month)

Existing:1.5; Proposed:1.5 ; Total: 3.0

:

Manpower Requirement, Nos.

: Existing: 11; Proposed: 27 & Total: 38


Page | 11.3

11.2 POLLUTION POTENTIAL & CONTROL MEASURES

Effluent Generation &

Management

Water Pollution:

: Source of Effluent

Process, APCM, Boiler, Cooling, Washing

:

Existing: Industrial: Nil; Domestic: 0.40

Effluent Generation (KLD)

Proposed: Industrial: 1.70; Domestic: 1.20

Total: Industrial: 1.70; Domestic: 1.60

Presently there is no effluent generation form the

existing unit and unit maintains the Zero Effluent

Discharge. The industrial effluent generation from

the proposed project will be @ 2.10 KLD, from which

0.40 KLD of condensate water from process will be

recovered & reused in cooling make-up and for

remaining 1.7 KLD effluent, the unit has proposed to

install an effluent treatment plant (ETP) comprising

of primary, secondary & tertiary treatment which will

be adequate to achieve the discharge norms

prescribed by GPCB. After treatment into ETP, the

total quantity of effluent will be used for gardening

and plantation within the premises.

Management:

The Domestic wastewater after the proposed project

will be increased from 0.40 KLD to 1.60 KLD, which

will be discharged in to soak pit through septic tank

as per the current practice.

Flue gas emission

control

Air Pollution:

: Unit has installed steam boiler of 0.8 TPH wherein

LDO/Furnace Oil is used as fuel. The same boiler

will be utilized after the proposed project.

Existing fuel requirement is 1.5 KL/month which will

be increased upto 4.5 KL/month after the proposed

project.

Adequate stack height of 12 m is provided for proper

dispersion of pollutant from the steam boiler. Hence,

there will be no requirement to provide any

additional air pollution control system for flue gas

emission for the proposed project.


Page | 11.4

Process gas emission

control

: There is no any process emission from the existing

manufacturing unit. The only source of process gas

emission from the proposed manufacturing activity

will be HCl & SO2 gas generated from the

manufacturing of Oxyclozanide. Hence, The

adequate water scrubber followed by alkali scrubber

will be provided for the control of process gas

emission

: Hazardous Waste

Management:

All the hazardous waste will be collected, stored,

handled, transported and disposed as per the

Hazardous Waste (Management, Handling

&Transboundary Movement) Rules, 1989 as

Amended in 2008.

The unit has obtained membership of GPCB

approved TSDF/ CHWIF of M/s. Saurashtra Enviro

Projects Pvt. Ltd. for the disposal of hazardous

waste.

: Noise & Vibration: There is no major source of noise and vibration from

the existing as well as proposed manufacturing

activity. Also, there is no D.G. set in existing unit and

will not provided after proposed project and no other

source of noise and vibration from the proposed

project. However, adequate precautionary measure

for noise and vibration control measures as

described below will be taken by the unit.

11.3

The baseline environmental quality of air, water, soil, noise, socioeconomic status

and ecology has been assessed in the winter season (December 2013 to February

2014). For the EIA study, the area falling within 10 km radial distance from project

site has been selected for preparing the site map along with infrastructure setup and

administrative map, land use/land cover map and socio-economic study whereas the

area falling within 5 km was considered to monitor the base line environment quality.

Baseline study was conducted as per the approved TORs issued by MoEF and

guidelines of MoEF/CPCB.

BASELINE ENVIRONMENT, IMPACTS ASSESSMENT & MITIGATION MEASURES

11.3.1 Topography & Geology

The area is almost flat. The ground gradients are mild and sloping from West to

East. In and around the study area comprises of Deccan Trap Basalts. This trap


Page | 11.5

rocks appears gently tilted at places. This Deccan Trap flows comprises massive,

hard and tough Amygdaloidal Basalt, Vesicular fine grained basalts; Porphyritic

basalts, Geodes with Zeolite, Chalcedony, Agate and Calcite are often in

Amygdaloidal types. In and around the study area is covered by thick Mantle of soil.

11.3.2 Seismology

Study area falls in Zone III as per IS 1893 (Part-I):2002, which is referred as

Moderate Damage Risk Zone. The area is liable to earthquakes of Modified Mercalli

Intensity Scale VII.

11.3.3 Micro Meteorology

The site-specific micrometeorological data was collected continuously during the

study period by installing automatic weather station at project site. During the study

period wind was blowing mostly from NNW with average speed of 0.85 m/s and

maximum speed of 7.1 m/s. Average temperature recorded was 20.1°C with

maximum temperature of 34.3°C and minimum of 12.1°C. The average relative

humidity was recorded as 46% and maximum as 83%.

11.3.4 Ambient Air

Baseline Scenario

The ambient air samples were collected from six locations and analyzed for PM

:

10,

PM2.5, SO2, NOx, HCl, NH3, CO & VOC. All the parameters are well within the

NAAQS except PM10 at three locations including project site. HCl concentration at

project site was also well within the GPCB norms prescribed for industrial area. It

was below detectable limit at other locations. VOC and NH3

PM

concentration (as

isobutylene) was below detectable limit (BDL) at all locations.

10 concentration at project site was higher due to surrounding industrialization in

Shapar-veraval industrial estate. Also, villages Ribda and Pipaliyapal are located in

predominant downwind direction from project site & Shapar-Veraval industrial area

and proximity to the NH 8B being the main reason for higher PM10 concentration.

• The maximum 24-hourly average ground level concentration for pollutants due to

proposed project calculated using mathematical model (ISCST3) for PM

Impacts Assessment:

10, SO2,

NOx and HCl. Maximum Incremental concentration for PM10, SO2, NOx and HCl


Page | 11.6

is 0.0798, 0.2786, 0.2778 and 0.0004 respectively even for the worst case

scenario.

• There will be the fugitive dust emissions due to the manufacturing activities, raw

materials handling, loading and unloading of raw materials and finished goods,

conveying and feeding point, vehicular movements, etc.

• An adequate stack height of 12.0 meter is provided for proper dispersion of

pollutant, which will also be adequate after proposed expansion.

Mitigation Measures to be Adopted:

• The adequate scrubbing system like water scrubber followed by alkali scrubber is

proposed to control the process gas emission of SO2

• In addition to the above, unit will take adequate measures for the control of

fugitive emissions after the proposed expansion.

and HCl from

manufacturing activity after the proposed project.

11.3.5 Water Environment

• Ground water samples were collected from the five locations and pipe water was

collected from project site once during the study period. TDS was higher than the

permissible limit at Pardi Village. Total Hardness was found higher than the

permissible limit at Pardi, Veraval (Shapar) and Ribda Village. Heavy metals and

other parameters except specified above were well within the permissible limit at

all locations and water collected from all the location is fit for the drinking

purposes except the ground water of Pardi Village.

Baseline Scenario:

• Presently the entire water requirement of unit is met through water supply by

Veraval (Shapar) Gram Panchayat through tanker and same source will be

utilized after proposed expansion. Unit also sources water from Private water

supplier through tankers in case of non-availability of main source. After

proposed expansion also, this will be kept as stand by source. Hence, there will

not be any direct impact envisaged on the ground water.

Impacts Assessment:

• There may be risk of ground water and surface water contamination due to

wastewater generation, handling and treated wastewater utilization for Greenbelt

development.


Page | 11.7

• The unit will explore the opportunities for rainwater harvesting and groundwater

recharge. Hence, there will not be any adverse impact on water environment due

to water availability and water requirement of the proposed activity.

Mitigation Measures to be Adopted:

• For effective treatment; safe handling and disposal of effluent, the unit has

proposed to install their own effluent treatment plant (ETP) comprising of primary,

secondary & tertiary treatment which will be adequate to treat proposed effluent

load.

• Treated effluent after confirming norms prescribed by GPCB, will be used for

gardening and plantation within the premises.

• Domestic wastewater will be discharged through septic tank into soak pit.

• Thus, there will not be any adverse impact on water environment.

11.3.6 Noise

Noise level monitoring has been conducted at project site and 6 surrounding villages.

The monitored noise levels have been compared with the standards prescribed by

MoEF which indicates that Noise levels at project site were found well within the limit

for day & night time. Noise levels at surrounding villages were found slightly higher

during day time.

Baseline Scenario:

Due to proximity of NH-8B to the surrounding villages, traffic load is observed high

during day as well as night time being the reason for increasing level of Noise.

During operation phase of the proposed project, the impact on noise environment will

be due to manufacturing activities, utilities and transportation activities

(transportation of raw materials and finished products).

Impacts Assessment

The noise pollution management will be taken up by selecting low noise generating

equipment, Isolating the noise generating equipments and working area and by

administrative & safety measures, providing noise level monitoring, remedial

measures, providing noise safety appliances to the working personnel.

Mitigation Measures to be adopted


Page | 11.8

11.3.7 Soil Quality

Soil samping has been carried out for project site and surrounding 5 villages. Water

Holding Capacity of soil samples were in range of 32% (Veraval (Shapar) Village) to

40% (Gundasara Village). The texture of soil is observed mainly Sandy Clay Loam in

the study area. The concentration of available Nitrogen, Phosphorous and

Potassium were in the range of 0.3 to 1.2 gm/Kg, 0.04 to 0.1 gm/Kg and 0.5 to 1.0

gm/Kg respectively, which signifies that the soil of the area is fertile. The organic

matter in the soil ranged from 1.2 to 3.9 mg/Kg.

Baseline Scenario:

• During operation activity the impact of air, water and hazardous waste pollution

will cause direct / indirect effect on soil.

Impacts Assessment

• In operational phase there will be chances of soil contamination due to improper

working of machineries or during transportation of raw materials or finished

products.

• Soil quality may be affected by use of treated wastewater for gardening purpose.

• Effluent treatment plant with primary, secondary and tertiary units is proposed for

adequate treatment of effluent generated. Treated effluent meeting GPCB

prescribed norms will be utilized for greenbelt development.

Mitigation Measures to be adopted

• An adequate stack height of 12.0 meter is provided for proper dispersion of

pollutant to avoid any soil contamination by air pollutants.

• Regular maintenance of plants and machineries will be carried out and proper

care taken while loading, unloading and transfer of materials to avoid any soil

contamination.

11.3.8 Land Use Pattern

Classification of land use/land cover was derived using GIS software from satellite

image. About 68.96% of the study area is covered under agricultural land. There is

3.55% land acquired for the industrial purposes in the study area. 0.96 % area is

water body consists of lake/pond and river.

Baseline Scenario:


Page | 11.9

Also, there is no protected area notified under the Wild Life (Protection) Act (1972) &

Eco - sensitive area notified under Section 3 of the Environment (Protection) Act-

1986 exists within 10 Km radius areas from the Plant Site. As per census 2001,

Naranka Reserve Forest falls within the study area and unit has obtained No

Objection Certificate from the Forest Department, Rajkot for the proposed project.

As the proposed project will be carried out within the existing premises, there will not

be any change in land use pattern, forest cover or vegetation in surrounding area.

Impacts Assessment:

11.3.9 Socio-Economic Study

As per the 2011 census, the study area of 10 km from the project site comprises of

total four Talukas of Rajkot District namely Rajkot, Kotada Sangani, Gondal and

Lodhika. There are 41 villages falling within the study area having total population of

around 1,06,313 indicating that the area is sparsely populated with scattered

settlements. Overall literacy rate in the study area is 68.6%, which show that literacy

rate in the study area is comparatively high. The overall employment ratio for the 41

villages in the study area is 44.0%, which shows that employment ratio is low.

Baseline Scenario:

• The proposed project will help to improve the economical status in the study area

by providing more employment opportunities. The area is well developed in terms

of education, communication, health services and banking facilities.

Impacts Assessment

• Unit will increase in employment from existing 11 to 38 workers, based on the

requirement the local people will be given priority.

• Unit will allocate fund up to Rs. 50,000/- for carrying out various CSR activities.

11.3.10 Biological Environment

It is observed during site visit that all flora and fauna species encountered are quite

common and found everywhere. No endangered and rare species were observed.

Also, there are no zoological parks or sanctuaries in the study area.

Baseline Scenario:

Pollutants of air, water and hazardous waste can interfere with the biotic and abiotic

components of the ecosystem and may include injurious effects when concentrations

Impacts Assessment


Page | 11.10

exceed permissible limits. All necessary pollution control measures will be provided

and operated efficiently for proposed expansion. Hence, there will not be any

adverse impact of pollution potentials on the surrounding ecology after

commissioning of the proposed project.

Also, existing and proposed green belt area will help in inviting small birds & animals

and other creatures to proliferate.

11.3.11 Greenbelt Development

Unit has already developed green belt in 340 m2 within the premises and this will be

increased up to 760 m2 (33.16% of total area) after the proposed project.

Green belt will not only improve the soil condition but will also prevent soil erosion

and the landscape & give slight beneficial impact on the land usage.

Impacts Assessment

11.4

The environmental management plan is proposed with respect to the all proposed activities

considering affected environmental attributes and impact zone which is summarized here

under:

ENVIRONMENTAL MANAGEMENT PLAN

Sr. No.

Activity Management Plan

1. Manufacturing

activities and

operations of

utilities

Ensure provision of Environmental Management system (EMS) as

proposed / committed for environmental pollution control.

Ensure the efficient operations of provided EMS.

Ensure proper treatment and reuse of treated effluent for greenbelt

development.

Regular monitoring w.r.t. EMS, ambient air quality, work area,

noise, water quality as per the monitoring program.

Review the monitoring reports and take corrective measures as

required.

Ensure the submission of monitoring reports to the concerned

authority as per the norms.

Ensure compliance of stipulated conditions by concerned

authorities.

Ensure optimum use of resources.

Regular monitoring of water consumption.

Maintain proper record of resources utilization.

Ensure the close manufacturing systems in order to minimize

fugitive emissions.

Ensure the regular maintenance of reactors and other process

equipments.

Ensure regular usage of proper PPE's by workers in the plant.


Page | 11.11

Sr. No.

Activity Management Plan

Ensure the collection, storage, handling, transportation & disposal

of all the hazardous wastes as per the Hazardous Waste

(Management, Handling & Transboundary Movement) Rules, 1989

as Amended in 2008.

Proper and timely oiling, lubrication, preventive maintenance of all

plant machinery & equipments.

Explore the technology for cleaner production, waste minimization,

treatment/ reuse / recycle / co-incineration of wastes.

2. Storage &

handling of

hazardous

chemicals and

hazardous

waste

Ensure the storage and handling of all the chemicals in a proper

manner to avoid any spillages and also to prevent runoff

contamination in monsoon.

Ensure collection & treatment of spillages, if any ensure good

housekeeping to maintain clean and orderly working environment.

Provide training to the persons handling chemicals & hazardous

wastes.

Ensure the provision of designated hazardous waste storage area

with proper roofing and leachate collection.

Ensure the disposal of hazardous wastes at approved TSDF with

manifest only.

Ensure availability of MSDS of all the Hazardous materials to the

on-site emergency team.

3. Domestic

activities

Regular monitoring of water consumption and ensure optimum use

of water.

Ensure proper discharge of sewage to soak pit through septic

tank.

4. Green belt

development

Maintain existing green belt by regular watering, soil enrichment

work (applying manure) weeding and provide proper protection.

Ensure the further development of greenbelt as proposed.

5. CSR activities Give preference to local people for the recruitment.

Ensure to carry out CSR activities as proposed.

6. Transportation

of hazardous

chemicals and

hazardous

waste

Vehicles must be PUC certified.

Ensure vehicular movement only during day time.

Ensure the transportation only by covered vehicles.

Ensure availability of manifest/TREM card with driver during the

transportation of Hazardous Waste / hazardous chemicals.

Ensure regular maintenance and optimum use of the vehicles.

Educate driver about the characteristics of wastes/ chemicals and

immediate actions in case of any spillage or accident.

Ensure availability of MSDS of all the Hazardous materials to the

Off-site Emergency team.

11.5

From the monitoring point of view, the important components are air, water, soil,

noise and occupational health & safety. Regular monitoring will be carried out after

ENVIRONMENTAL MONITORING PROGRAMME


Page | 11.12

the proposed project as per the monitoring program. Unit will establish a small scale

laboratory at ETP area for regular wastewater monitoring. Untreated and treated

wastewater of ETP will be daily analysed with respect to pH, TDS and COD. Flow

meters will be provided at the outlet of ETP for regular monitoring of wastewater

quantity. Unit has already made necessary tie-up with nearby hospitals for the

medical assistance in case of any emergency. Unit will establish a well organized

Environmental Management Cell (EMC) which will perform all the environmental

management activities.

Unit will also prepare EHS policy to adhere with standard operating process in order

to comply with the statue and bring into focus any infringement of any norms and

directives with regards to the Environment, Health & Safety and to take further

corrective actions. Voluntary reporting of environmental performance with reference

to EMP will be undertaken. Plant In-charge will co-ordinate all monitoring programs

at site and data generated will be submitted regularly to the statutory agencies.

Frequency of reporting shall be as per the requirement of GPCB and MoEF.

11.6

The proposed project will be carried out within the existing premises and existing

infrastructure facilities will also be utilized with the addition of new machinery for the

proposed project. Thus, no alternative for the site was considered due to the

availability of infrastructure, land, water sources, fuel transportation, power etc.

ANALYSIS OF ALTERNATIVES (TECHNOLOGY & SITE)

For the proposed products i.e. various Bulk Drugs & Drugs Intermediates (Synthetic

Organic Chemical), unit will adopt latest and best technology available so far in the

market. Moreover, the unit is very concerns and conscious about the product quality

and equally about the environmental protection and resource conservation; and

hence they put their efforts for replacing/upgrading their existing plant and

machineries from time to time with the best available technology.

11.7

The unit is very much aware of their obligation to protect all persons at work and

others in the neighborhood that may be affected by an unfortunate and unforeseen

incidence occurring at the works. Unit has provided all the adequate safety

measures in the existing plant. After proposed project also, any hazard either to



Page | 11.13

employees or others arising from activities at the plant site shall as far as possible,

be handled by the personnel of the company and prevented from spreading any

further. In the case of eventuality the on-site and off-site emergency plan proposed

by the unit will be adequate and may be able to control the situation. After the

proposed project all the required safety measures will be taken and unit will also

carry out safety audit through authorized agency/organization.

11.8

Unit has contributed reasonably as part of their CSR and carried out various

activities in nearby villages. Unit is spending annually about Rs. 25,000 for such

activities. In addition to this employment opportunity for 27 persons and for many

other skilled-unskilled labors during construction and other ancillary activities during

operation will be generated after the proposed project. Unit has planned to carry out

various activities for the upliftment of poor people, welfare of women & labors,

education of poor students as part of Corporate Social Responsibility (CSR) in the

nearby villages and therefore unit will make additional provision of Rs. 25,000.

Therefore, after proposed project, unit will spent at least Rs. 50,000 every year

towards CSR activities.

PROJECT BENEFITS

11.9

It can be concluded on a positive note that after the implementation of the mitigation

measures and environmental management plans, the proposed project activities

during the construction and operation phase would have manageable & largely have

reversible impacts on the environment and on balance the project would be

beneficial to surrounding communities and the region.

CONCLUSION


Page | 11.12

the proposed project as per the monitoring program. Unit will establish a small scale

laboratory at ETP area for regular wastewater monitoring. Untreated and treated

wastewater of ETP will be daily analysed with respect to pH, TDS and COD. Flow

meters will be provided at the outlet of ETP for regular monitoring of wastewater

quantity. Unit has already made necessary tie-up with nearby hospitals for the

medical assistance in case of any emergency. Unit will establish a well organized

Environmental Management Cell (EMC) which will perform all the environmental

management activities.

Unit will also prepare EHS policy to adhere with standard operating process in order

to comply with the statue and bring into focus any infringement of any norms and

directives with regards to the Environment, Health & Safety and to take further

corrective actions. Voluntary reporting of environmental performance with reference

to EMP will be undertaken. Plant In-charge will co-ordinate all monitoring programs

at site and data generated will be submitted regularly to the statutory agencies.

Frequency of reporting shall be as per the requirement of GPCB and MoEF.

11.6

The proposed project will be carried out within the existing premises and existing

infrastructure facilities will also be utilized with the addition of new machinery for the

proposed project. Thus, no alternative for the site was considered due to the

availability of infrastructure, land, water sources, fuel transportation, power etc.

ANALYSIS OF ALTERNATIVES (TECHNOLOGY & SITE)

For the proposed products i.e. various Bulk Drugs & Drugs Intermediates (Synthetic

Organic Chemical), unit will adopt latest and best technology available so far in the

market. Moreover, the unit is very concerns and conscious about the product quality

and equally about the environmental protection and resource conservation; and

hence they put their efforts for replacing/upgrading their existing plant and

machineries from time to time with the best available technology.

11.7

The unit is very much aware of their obligation to protect all persons at work and

others in the neighborhood that may be affected by an unfortunate and unforeseen

incidence occurring at the works. Unit has provided all the adequate safety

measures in the existing plant. After proposed project also, any hazard either to



Page | 11.13

employees or others arising from activities at the plant site shall as far as possible,

be handled by the personnel of the company and prevented from spreading any

further. In the case of eventuality the on-site and off-site emergency plan proposed

by the unit will be adequate and may be able to control the situation. After the

proposed project all the required safety measures will be taken and unit will also

carry out safety audit through authorized agency/organization.

11.8

Unit has contributed reasonably as part of their CSR and carried out various

activities in nearby villages. Unit is spending annually about Rs. 25,000 for such

activities. In addition to this employment opportunity for 27 persons and for many

other skilled-unskilled labors during construction and other ancillary activities during

operation will be generated after the proposed project. Unit has planned to carry out

various activities for the upliftment of poor people, welfare of women & labors,

education of poor students as part of Corporate Social Responsibility (CSR) in the

nearby villages and therefore unit will make additional provision of Rs. 25,000.

Therefore, after proposed project, unit will spent at least Rs. 50,000 every year

towards CSR activities.

PROJECT BENEFITS

11.9

It can be concluded on a positive note that after the implementation of the mitigation

measures and environmental management plans, the proposed project activities

during the construction and operation phase would have manageable & largely have

reversible impacts on the environment and on balance the project would be

beneficial to surrounding communities and the region.

CONCLUSION

1st To, Shri Hardik Shah (Secretary) State Level Expert...

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