Public Disclosure Authorized - All...

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Environmental Audit & Due Diligence Assessment Report

Contents

EXECUTIVE SUMMARY 3 - 11

+ PART 1: INTRODUCTION

+ PART 2 : OBJECTIVE AND SCOPE OF WORK

+ PART 3: COMPLIANCE ASSESSMENT

+ PART 4: POLLUTION PREVENTION AND CONTROL ASSESSMENT

+ PART 5: RESOURCE EFFICIENCY ASSESSMENT

+ PART 6: OCCUPATIONAL HEALTH AND SAFETY ASSESSMENT

+ PART 7: INSTITUTIONAL CAPACITY ASSESSMENT

+ PART 8: POTENTIAL RISK AND LIABILITY ASSESSMENT

+ PART 9: ENVIRONMENTAL HEALTH & SAFETY MANAGEMNT ACTION PLAN

ANNEXURES

DISCLAIMER

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Environmental Audit & Due Diligence Assessment Report

approximately INR 250 million. Alternately, KTPS may also consider replacement of existing bags in the BF with more efficient ones. However, the O&M cost for the same is higher than that of ESP due to requirement of regular change of bags (i.e. -every 3 years for cost of INR -120 million). Therefore, it is not recommended.

+ introducing ammonia to improve the efficiency of the ESP. The same is a plausible alternative and the cost for the same is expected to be INR 0.1 million per MW. The details of the ammonia system are given in section - 4.3.8 of the report.

P Water is one of the scarce commodities and should be utilized judiciously. Currently KTPS draws water from the Pench dam which is about 25 km from the plant. Most of the fresh water used in the plant is being recycled to reduce the quantity of fresh water intake.

P During the audit, water flow measurements were taken using tracer method and non-contact flow meters. Based on the current hydrological scheme of KTPS. the following were observed:

3 Raw water is used as makeup water in cooling tower as well as for ash slurry preparation.

+ DM water is used in the boiler. + Trade effluent is sent to the ETP, which is

basically a settling tank, from where it is sent t o the ash handling unit (AHU) for ash slurry

preparation which is pumped to the ash bund at Koradi and Khasara. The supernatant is recovered from the ash bund and pumped back into the AHU. Fresh water is used as make up water for ash slurry preparation. + Unit - 6 is equipped with a cooling tower from where it is circulated back to condenser. The makeup water to the system is received from Pond No. 3 and the over flow of the system is circulated to Pond no. 2 which is connected to the main raw water storage pond i.e. no. 3.

3 One of the ash water supernatant from Khasara ash bund is not being recovered by KTPS. The quantity of water is estimated to be 33,566 m3/day. However, part of the water is utilized back into the system. + Overflow water from Coal Handling Plant (CHP) and Booster Pump House (BPH) is being let out of the plant boundary with out treatment. The quantity of water being let out of the plant boundary is estimated to be 16,643 m3/day. KTPS has initiated work for installation of recovery system and tender has been floated.

3 Boiler blow down and cooling water discharge is being sent to the ETP for further treatment and used for the AHP.

P Based on the observations during the audit, the following recommendations are being made:

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d The ash water supernatant from Khasara ash bund should be recovered and recycled back into the system.

d Over flow water from CHP and BPH should be treated and recycled back into plant. A settling tank should be constructed near the outlet for treatment and recycling. Steps have been initiated by KTPS in this regard and tenders have been floated for the same.

9 Chemicals are used in the water treatment plant for making DM water which is fed into the boiler. Based on the historical data available with KTPS it was observed that the chemical usage has been increasing over the period.

P Chemicals such as caustic lye have shown increase in consumption due to increased chloride levels in the raw water near the raw water pump houses. Also, the holding capacity of the raw water pond no. 3 has decreased over the years due to increased anthropogenic activity around the pond. This has also resulted in increased organic load and vegetation along the banks of the pond.

9 Based on the chemical analysis carried out on the raw water at the source i.e. Pench and near the pumping house at KTPS it was observed that the chloride levels are 3-4 times more near the pumping house. The treatment using caustic lye to reduce the chloride levels has increased the financial burden on the KTPS.

P Considering the above scenario, the following recommendations are being made:

d The raw water pond no. 3 should be cleaned immediately which help in reducing the organic load in the pond as well as increase the holding capacity.

d MAHAGENCO should also see the feasibility of constructing a separate pipeline for tapping the intake water directly from Pench pipeline which would help reduce the chemical consumption for water treatment as well as avoid wastage of water such as tapping of water by local population for domestic use. + An estimated 3.0 million could be saved alone on reduction i n the caustic lye used for treatment of water.

P KTPS has provided automatic water sprinkler system at the wagon tipplers and advance fog system at conveyers to minimize dust emissions. However no dust collection system with dust suppressants is made available at CHP.

9 Based on the physical observation made during the audit, the following are the recommendations:

d Dust collection system should be installed at all transfer points in the conveyor system to avoid fugitive dust.

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Environmental Audit & Due Diligence Assessment Report

3 Reduced variation in SH/RH spray, hence steady SH / RH steam temperature. This results in improved efficiency of boiler and heat rate of overall cycle.

3 Reduced superheated steam consumption due t o reduced number of wall blowing.

3 The soot blower operation is reduces by about 55 - 60% compared to conventional wall blowing system.

3 Reduction in tube erosion due t o selective and reduced steam blowing

3 Annual energy saving of INR 5.25 mill ion was achieved.

> Introduction Of Super Cleaning Of Turbine 011: The introduction of super cleaning of turbine oil will result in following benefits:

3 Average Oil consumption has been reduced to 76 barrels from 145 per year.

3 Reduction in sludge formation at the bottom of Main Oil Tank.

3 No Governing problems are faced due t o chocking of governing components.

3 Installation of super cleaning system has resulted in many tangible and intangible benefits. Total cost saving of INR 7.196 million has been achieved.

Occupational Health & Safety Assessment:

& It was observed that the number of accidents have increased during 2002-04. During 2004-05, a declining trend has been observed in the number of accidents including minor injuries such as pin prick, sprained back or foot, slip on plain road. However, in the year 2006, the plant, on an average, witnessed one accident every second week.

& It was observed that unsafe acts have contributed t o more than half of the accidents that have occurred in the plant since 2004. However, the number of accidents and unsafe acts has shown a decline in the numbers over a period.

& A detailed root cause analysis for each of the observations has been provided in section - 6.2 of the report

& Some of the major observations and recommendations at KTPS with respect t o OHS are given below for ready reference.

3 EHS ~ol i t$ EHS policy is yet to be revised since the restructuring of MSEB in 2004. However, it was informed by MAHAGENCO that the same was being revised and will be circulated among all the plants once approved by the board.

3 Risk Analysis Study: KTPS has conducted a Risk Analysis study at the plant and detailed action

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plan is prepared and implemented through OHSAS.

+ Near Miss Reportinq: KTPS has put in place a near miss incident reporting system. The same has been communicated to various departments. KTPS is also taking steps to increase the workers participation in the system.

+ OHS Audit: As per the existing corporate policy, OHS audit is to be conducted every year. Though the OHS audit was not conducted every year, MAHAGENCO has carried out OHS audit during 2004 & 2007. Subsequently KTPS has also taken initiative to implement OHSAS 18001:2007 management system.

+ Fire Fiqhtinq Department: No deviations from scheduled standard test and examination of fire service equipment and fire protection system were observed during the site visit. However, some deviations were noticed with reference t o the recommendations by The Fire Advisor & Chief Fire Officer. The same are already been informed to and accepted / approved by the FA & CFO. + House Keepinq: During the site visit, housekeeping, lighting and ventilation were observed to be poor in the plant for safe working of occupant, specifically in the CHP area. At the time of site visit, the dust suppression system and fresh air system in CHP were found not in operation. Several gas cylinders were found without seal in the storage yard.

+ Training for contract workers: Contract worker participation is very limited in safety specific training and awareness programmes.

+ Rotation of Work: Comprehensive documentation with regard to classification of diseases based on occupational exposure was not found in place. + Comprehensive procedures for administrative controls such as rotating employees and imparting trainings on performing tasks in ways that reduce exposure to work place hazards were not found in place. It was informed that despite having medical problems, which may be aggravated due to occupational exposure, workers have not been keen on rotation of work.

+ Reportedly, the workers have resisted attempts by the top management to transfer workers from one department to the other. Workers interviewed during the site visits have also indicated their preference to continue working in the same department.

+ Safety / mock drills: Safety and mock drills with regard to acid leak, chlorine leak, fire and Disaster Management Plan (DMP) are conducted periodically to check the preparedness of the emergency response system, records of which are being maintained by the safety department. Observations and recommendations made during mock drill that required corrective measures have not been addressed promptly.

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+ Further, it was observed the responsibility of implementing these observations was not clearly assigned to any individual. Also, no comprehensive documentation was found in place with regard to action points / measures taken to address observations made during mock drills + At present, OHSAS 18001 system is being implemented at KTPS and it was informed by KTPS that the above observations are being improved upon as part of the management system.

+ Accident Investiqation: Accidents are investigated and recorded. However, a comprehensive Root Cause Analysis (RCA) of all the accidents is not carried out.

9 Some of the recommendations for OHS are as follows:

+ Safety specific training and awareness programs should be made mandatory for contract labors.

+ Classification of diseases based on occupational exposure should be documented.

+ The workers and worker unions should be sensitized towards the need and benefits of rotation of work. A rotation of work policy could be framed and workers at the time of recruitment should be informed about the policy and the probability of inter departmental transfers.

+ Observations made during mock drill, which require corrective measures, should be given priority and addressed immediately for improving the efficiency of the emergency preparedness and response. Specific individuals should be assigned the responsibility of ensuring these action points are addressed, as and when identified. Action points taken and status of the observations requiring corrective measures should be documented t o keep track of the performance of the system.

+ A comprehensive Root Cause Analysis (RCA) by the Safety Department would help in identifying the root cause for the accident and placing systemic controls and for ensuring avoidance of similar mishaps in future. During the audit, a sample accident case was taken and a RCA was carried out and provided to the safety department.

Institutional Capacity Assessment:

In order assess the institutional capacity at KTPS to handle the R&M of Unit -6, an assessment was carried out on the same. Based on the assessment, the following were the major observations and recommendations.

9 Institutional Setup: The environmental monitoring cell (EMC) is headed by section head of Water Treatment Plant (WTP) of stage - II.

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P The safety department and EMC report to different Section Engineers (SEs) of two different stages i.e. Staqe I and 11.

P Traininq: KTPS has an in-house training facility and trainings at various levels are provided with in- house experts from various departments.

P Feedback is given by the sectional heads to the trainers based on the information provided by the participants from their section.

P address in^ stakeholder Concerns: During the stakeholder consultation process, the gram sarpanch (village head) of Koradi village informed that their office does not have the proper quidancel information as to whom to approach within the KTPS to communicate the view or concerns of the villaqers. It was also informed that the lack of knowledge leads them to raise their issues with the local elected member of the Legislature who in turn communicates the same with the plant

> It was informed by KTPS that a Public Relations Officer (PRO) has been appointed and same was communicated to the villagers so that they can meet the PRO to put forth their grievances. A board has also been displayed at the entrance of the plant regarding the same.

Some of the recommendations for the observation made are given below:

P KTPS may bring the sectional heads of EMC and safety department under one supervisor which

would enable to inteqrate environmental issues with safety and health issues at the plant level leading a comprehensive EHS system.

P Feedback on the training sessions should be taken from the people attending the training at the end of the training session. The feedback should be concealed and the same should be directly submitted to the HR department for further action.

P KTPS should also inform the village panchayat office the procedure for lodging written complaints with KTPS or the concerned authorities responsible for environmental management.

P KTPS may also provide a drop box at the entrance (near security cabin), which is easily accessible by the local residents. It shall be used to submit concerns in writing. The drop box would be under the jurisdiction of PRO of KTPS.

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Risk and Liability Assessment:

In order to assess the impact of the plant operation on the local community and the risk and liabilities associated with the same, a local stake holder engagement was carried out during the audit period. The observations / findings durinq the same are summarized below:

9 Rehabilitation and Resettlement Programme: The Sarpanch and the villagers interviewed indicated their satisfaction with the resettlement and rehabilitation program of the erstwhile MSEB. The interviewed villagers indicated that they were amply compensated for their loss and were provided with land in lieu of their land acquired by MSEB and were provided with employment opportunity at the plant as well.

P Water pollution and access to potable water: During the interview it was informed that the surroundinq villaqes have access to potable water and do not face any problem in terms of water pollution due to the activities of the power plant. However, the resident of Mhasala village, which is located adjacent to the Khasara ash bund, indicated that during summer, due to scarcity of potable water, they are forced to drink the river water which has ash supernatant. In order to verify the aforementioned statement qround water and surface water samples were collected and analyzed during the audit period and the water was found to be adhering to the norms specified by the CPCB.

9 Community En~aqement: During the interaction it was mentioned by the sarpanch that KTPS does not have in place a structured process to enqaqe with the community. It was also informed durinq the interview that the village panchayat is not aware of a concerned person whom they can approach for assistance with issues related to the community and KTPS. However, officials from KTPS were interviewed, who informed that a Public Relations Officer (PRO) has been appointed by KTPS to collect grievances from the villagers and provide appropriate response. A board has also been displayed at the entrance of the plant which indicates whom one can meet to discuss their grievances. The same was also verified durinq the site visit.

P As mentioned above, a drop box can also be used to collect the concerns of local residents and the same can be addressed appropriately by the PRO / relevant departments of KTPS at regular intervals.

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PART 1.0: INTRODUCTION

1.1. PURPOSE

Government of India has launched a programme for Renovation and Modernization (R&M) of old coal fired power plants in the country. This programme, the Partnership for Excellence, includes a financing window, funded by the World Bank and GEF, for rehabilitation projects that prioritize energy-efficient outcomes.

Under this programme, 210 MW Unit - 6 of Koradi Thermal Power Station (KTPS), an existing thermal power station of Maharashtra State Power Generation Co. Ltd. (MAHAGENCO), was considered for R&M.

The following aspects have been covered as part of the overall EA-DDA

(a) Understanding the existing performance of the plant in terms of energy efficiency and environment

(b) Techno-economic aspects with respect too which the benefits would be achieved through R&M

In order to assess the energy efficiency and environmental performance of the plant being proposed for rehabilitation, an Environmental Audit, that would provide information about key environmental issues related to overall performance, as well as the state of compliance (with applicable regulations and industry best practices) in the plant in general and in the unit proposed (in case of plants

having multiple units) for rehabilitation in particular has been proposed. In order to carry out the EA-DDA of KTPS, MAHAGENCO has retained the services of Ernst & Young Pvt. Ltd.

1.2. KORADI THERMAL POWER STATION (KTPS)

In 2005, as per requirement of the Electricity Act of 2003, the Maharashtra State Electricity Board (MSEB) was split into three companies: Mahanirmiti or Mahagenco (Maharashtra State Power Generation Co. Ltd.); Mahavahan or Mahatransco (Maharashtra State Electricity Transmission Co. Ltd.); and Mahavitaran or Mahadiscom (Maharastra State Electricity Distribution Co. Ltd).

1.3. INSTALLED CAPACITY OF KTPS

KTPS has 7 units adding to a total generation capacity of 1100 MW. The ground breaking ceremony for KTPS was held on 25th December 1968 and the first unit (Unit -1) of 120 MW was commissioned in the year 1974. The following are the details of the installed capacities of KTPS, Nagpur:

Stage I - Units 1 to 4: 120 MW each (Boiler: ABL Kolkata; TG: ZAMECH, ELBLAG, Poland) Stage II - Unit 5: 200 MW (Boiler and TG: BHEL India); Unit 6 and 7: 210 MW (Boiler and TG: BHEL India)

Unit 1 to 4 have been de-rated to 105 MW each from its original capacity of 120 MW each by Central Electricity Authority (CEA).

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The plant is certified with IS0 14001:2004 and 9001 management systems. The plant is also implementing OHSAS 18001:2007 management system.

1.4. ENVIRONMENTAL SETTINGS OF KTPS

Koradi Thermal Power Station (KTPS), one of the power generation units of MAHAGENCO, is located in Koradi approximately 11 kms from Nagpur (The Orange City) on the Nagpur - Chindwara highway. Table - 1 provides the details of the environmental setting of KTPS.

1.5. SITE VISITS, DATA COLLECTION & REPORT DISCUSSIONS

An initial site visit was carried out during 18th July 2007 and 21st July 2007 by Ernst & Young Pvt. Ltd. (E&Y) team to collect all the necessary basic information to understand the EHS performance of KTPS.

The site visit included data collection and reconnaissance survey of the plant and its associated facilities. Prior to the initial site visit, E&Y had communicated to KTPS, the preliminary list of documents / information which would be required to carry out the Environmental Audit and Due Diligence Assessment (EA-DDA).

The E&Y team comprised of the followinq members:

9 Mr. Sujeet Kishen 9 Mr. Hemant Nandanpawar

9 Mr. R P Gokul 9 Mr. Raja Raghavan 9 Mr. Jayanth Chetlur 9 Ms. Shilpi Singh

During the site visit, the following officials of KTPS were contacted to discuss and understand the operations of KTPS with regard to Environmental Health and Safety performance as well as resource efficiency assessment. The key persons among them were:

Dr. V. V. Wanjari (Medical Superintendent) Mr. P. K. Khurana (Ex. Chemist, Stage 11) Mr. D. S. Dhakate (Exe. Engineer - POG) Mr. A. K. Kapoor (Safety Officer) Mr. Ajay G. Telang (Dy. Executive Engineer - R&M) Mr. M. N. Naisal (Dy. EE-CHP) Mr. Milind Dharmadhikari (Chemist, Stage 11) Mr. S. S. Bagchi (Chemist, Stage 11) Mr. Mongse (Chemist, Stage 11)

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TABLE 1: ENVIRONMENTAL SETTING

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PART 2.0: OBJECTIVE &SCOPE OF WORK

2.1. OBJECTIVE

The objective of the assignment is to establish and assess the baseline environmental performance of the KTPS with respect to:

9 compliance with regulatory requirements; 9 adequacy and effectiveness of pollution prevention

and control measures, waste minimization and resource conservation measures, and

9 occupational health and safety management systems;

with a view to identify appropriate technical, financial, institutional and management measures to improve the environmental performance of the plant including mitigation of potential / perceived environmental risks / liabilities as part of the proposed rehabilitation program.

2.2. SCOPE OF WORK

The scope of work for the Environmental Audit and Due Diligence Assessment (EA - DDA) as per the Work Order presented include the following aspects:

9 Compliance Assessment: Regulatory compliance assessment for the entire plant covering all the 7 units and its common facilities includes the following:

+ Assessment of environmental clearance / consents applicable under different environmental regulations Compliance with applicable environmental standards / stipulations for the various environmental aspects coal use, water use, stack emissions, noise generation, effluent generation, effluent quantity and effluent disposal, AAQ, ambient noise levels, pollution in water bodies receiving effluent from the plant, disposal / utilization of ash, and any other specific stipulations that are applicable to the plant. Assessment of the special requirements/conditions stipulated for the unit vide various consents / clearances.

+ Assessment against the applicable World Bank standards i.e. as per Pollution Prevention and Abatement Handbook guidelines.

9 Pollution Prevention and Control Assessment: This includes reviewing the adequacy and effectiveness of the pollution control equipments in reducing the pollution for the entire facility. The assessment includes:

Measures / systems to improve coal quality, combustion efficiency and heat recovery; ESPs / other particulate collection systems in different units NOx control systems

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Noise control systems Water recycling systems and effluent treatment systems Dust suppression systems Ash pond (ash water decanting and containment of ash slurry in the pond)

Based on the data collected, baseline pollution parameters for the following to be established: particulate matter (kglkwh), SO2 emissions (kgIkWh), NOx (kglkwh), mercury emissions (g/MWh) and ash generation (kg1kWh)

9 Occupational Health, Safety Assessment (OHS): This includes verifying the following with regards to OHS and emergency management aspects.

Regular protocols for safety of workers working in hazardous work place; Records of accidents and emergency responses; Systematic monitoring and maintenance of health records, etc; Evaluate readiness and capacity of the emergency management systems to cope with incidents varying from small spills to major accidents; Specific review with respect t o the following for evaluating their adequacy and effectiveness;

Workers safety equipments Safety drills Periodic health check up for workers Rotation of work and minimization of exposure Emergency management plans

9 Potential Liabilities 1 Risks: This includes consultation with the following stakeholders to identify potential environmental liabilities to the power plant:

Plant management, people living in the vicinity, project affected persons, PRls, local NGOs, and State Pollution Control Board (SPCB)

Pollution effects due to presence of Mercury (Hg) will also be studied as part of the risk and liability assessment.

9 Resource Efficiency Assessment: As part of the resource efficiency, the following shall be reviewed for a detailed resource efficiency assessment for Unit - 6 will be carried out which is proposed for R&M

Assessment of historical performance of efficiency parameters and comparison with

Fire fighting systems

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their design parameters. The parameters include

Primary fuel use Auxiliary fuel use Unit heat rate Specific water consumption Auxiliary power consumption

A detailed material and energy balance assessment will be carried out for different stages of power production to identify the losses which could be minimized.

P lnstitutional Capacity Assessment: This will review the institutional setup and resources available within the plant for ensuring sound environmental performance and assess their adequacy and effectiveness. The review would include the following:

lnstitutional setup for environmental management Systems and procedures Training Mechanisms for addressing public concerns

P Identification of interventions: This includes identification of interventions with regard to the following:

Ensuring compliance with the applicable national and state level regulatory requirements and any specific stipulation on the plant Meeting the requirements of applicable PPAH guidelines and an assessment of their feasibility Improving the various resource efficiency parameters of Unit - 6 towards their respective design parameters as well as towards the industry best practices, applicable to similar plant and technologies Preparing a matrix comparing the proposed interventions against their environmental benefits related to reduction in pollution, improvement in energy efficiency, reduction in greenhouse gas emissions and risk mitigation.

P Preparation of investment plan: Based on the measures identified to mitigate the potential risks and liabilities, a cost benefit analysis for different interventions to be made by developing a matrix. Any additional investments required to achieve the industry best practices to be specified and provided separately in the report.

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PART 3: COMPLIANCE ASSESSMENT

The applicable environmental laws and requlations for Koradi Thermal Power Station (KTPS) are presented below for reference. The compliance assessment of plant has been carried out takinq into consideration the below mentioned laws and requlations.

3.1. ENVIRONMENTAL (Laws & Regulations)

P Air (Prevention & Control of Pollution) Act & Rules P Water (Prevention & Control of Pollution) Act &

Rules P Water (Prevention & Control of Pollution) Cess Act

& Rules P Public Liability Insurance Act & Rules P National Environment Tribunal Act P CPCB Charter on CREP P Environment Protection Act

o Environment Protection Rules o Hazardous waste (Manaqement & Handlinq)

Rules o MSlHC Rules o Noise (Requlation & Control) Rules o Batteries (Manaqement & Handlinq) Rules o Bio-Medical waste (Manaqement & Handlinq)

Rules o Fly Ash Notifications o EIA Notification

3.2. OCCUPATIONAL HEALTH & SAFETY (Laws & Regulations)

P The Factories Act & Maharashtra Factories Rules P The Electricity Rules P Gas Cylinder Rules P The Petroleum Act & Rules P SMPV Rules P Boiler Act & Requlations P Danqerous Machines (Requlations) Act. P The Maharashtra Factories (Control of Industrial

Major Accident Hazards) Rules P The Maharashtra Safety Officers (Duties,

Qualifications and Conditions of Service) Rules

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3.3 ENVIRONMENTAL COMPLIANCE

The first unit of KTPS was installed in the year 1968 and the last unit (Unit -7) was commissioned in the year 1984. Since all the units of KTPS were installed prior to the formulation of the Environmental Protection Act, 1986, KTPS did not require a Environmental Clearance for establishment as well as operation from Ministry of Environment and Forest (MoEF), New Delhi. The first Consent to Operate was issued to the plant in the year 1989 by Maharashtra Pollution Control Board (MPCB). The latest Consent to Operate, was issued by MPCB, under the Air Act, Water Act and Hazardous Waste (M&H) Rules, on 28th December 2006 and is valid till 30th September 2011. The same document has been considered for assessing the compliance against the conditions specified in the consent order.

KTPS has been served Show Cause Notice thrice in the past, by the MPCB, for violation of the environmental regulations. The compliance to these notices was also given by KTPS to MPCB, which were accepted by MPCB. The details of the Notices issued has been given below:

P Show Cause Notice vide letter no. MPC/NR0/1653/2004 dated 16/09/04

P Proposed Directions under Section 33A of the Water (P&CP) Act, 1974 and Under Section 31A of the Air (P&CP) Act, 1981 vide letter no. MPC/NRO/Directions/52/2490/2004 dated 25/11/2004

P Show Cause Notice under Clause (b) of Sub-section (4) of Section 25 of the Water (P&CP) Act, 1974 vide letter no MPCB/PCI-II/TB/SCN/B-3660 dated 06/11/2006

3.3.1. Summary of Findinqs

During the audit it was observed that most of the conditions specified in the consent order are being followed by KTPS except a few. The detailed checklist of compliance assessment is provided below.

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Page 23 of 210

S. No.

4

5

6

Separate meters monitor consumption for STP and ETP

Flow meters forAs measurements of flow of the effluent

Daily waterAs consumption

Compiiance Requirement

toAs per the consent order, the factory enerqyauthorities shall install separate

showing consumption of enerqy for operation of domestic and industrial effluent treatment plants. The quarterly returns of the enerqy consumption be submitted to Board Office underthe intimation to respective Regional and Sub-Regional Officer on each 10th of January, April, July and October.

per the consent order, KTPS should provide flow meters for measurement of flow of the effluen

per the consent order, the daily waterThe consumption should not exceed as under

Consumption

Observations

Energy meters are provided to metermonitor the enerqy consumption of

the ETP.

The quarterly returns of the energy shallconsumption are being submitted to

Board as required by the Consent Order.

Flow meters have not been provided as required by the consent order.

quantities of water used for the givenaforementioned purposes were

found to be with in the limits prescribed in the consent based on he data made available by KTPS (Cess records). However, due to non-availability of flow meters, actual measurements were not possible.

S. NO. 1 2

3

Compiiance

Yes

N o

Partial Compliance Description

Domestic Industrial Process Industrial cooling/boiler

Quantity (m3/day) 12000 15000

90000

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S. No. 7

8

9

10

Dust collection system at CHP

Hooding andAs Ventilation arrangements for CHP

Installation continuous air quality micrometeorologicalair monitoring station

Disposal hazardous waste

Compliance Requirement

As per the consent order, KTPS shouldKTPS provide dust collection system at CHP to control the SPM from the crusherat units and other sources.

per the consent order. the handling system shall be covered proper hooding and ventilationsystem arrangements connected to dust suppression agent so as not to allow any fugitive emissions

ofAs per the consent orders datedDaily ambient22/11/2001 and 28/12/2006,

andshould install three continuous quality and micro-meteorologicalout

monitoring station a t location indicatedreported by SPCB. Also, as per consent orderthe dated 22/11/2001, KTPS shall installweek continuous ambient air quality monitoring station and in the event same cannot be provided, the AAQ will be monitoring every day and the daily report be submitted to the Regional Office.

ofAs per the consent order, KTPS shouldThe sell the usedlspent oil t o the authorized third party and wastebeing containing oil and chemical sludge ETP should be disposed off in the TSDF.

Observations

has initiated the work for theprovision of dust collection system

CHP.

coalKTPS has initiated the work for withprovision of hoods and ventilation

at CHP.

monitoring of AAQ with KTPSCAAQMS, as suggested in the

ambientconsent order, is not being carried and the same is not being

to State Board. However, AAQ is being monitored twice a

as per NAAQ standards.

theThe continuous AAQ monitoring system is being installed.

hazardous waste including ETP SPCBsludge containing chemical waste is

disposed as required by the fromMPCB norms.

Compliance

In-progress

In-Progress

In-Progress

Yes

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S. No.

11

12

13

14

Mixing of stormAs water and dischargenot from other with trade effluent

Factory License

Medical Check up

Medical Check up

Compliance Requirement

per the consent order, KTPS shouldThe allow mixing of storm water

premisesdischarge from other premises with trade effluent.

KTPS currently holds the license to employ 2500 employees. KTPS currently has 2141 employees on its rolls

KTPS currently has 2141 employees its rolls.

U/r 73-V (1) (b) of the MaharashtraThe Factories Rules, 1963, employed in a 'hazardous process' shall be medically examined by the Factory Medical Officer once in a period of 6 months to ascertain the health status of all the workers in respect of occupational

Observations

storm water from the storm andwater drains is being let into the theETP and mixed with the trade

effluent which is being used for preparation of ash slurry and then disposed off in the ash pond. It was informed that KTPS employs following numbers of contract labor a) 477 nos for cleaning, b) 1009 nos for annual maintenance, c) 1005 nos Plant maintenance.

Daily Attendance records t o demonstrate that the number of employees employed in a day has not exceeded the licensed number were not produced on request.

onThe health register in Form 7 provided indicated that Medical Checkup was conducted only for 1785 employees.

health register made available Workersindicated that the workers are being

examined once in a year.

Compliance

N 0

(Not practically feasible)

Partial Compliance

Partial Compliance

N o

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S. No.

15

1 6

1 7

Compliance

N 0

Medical Check up

Communication Chief Inspector about appointment of Factory Officer

Pre-employment Medical Check for Contract labour

Compiiance Requirement

health hazards to which they are exposed. Power Generation is included in the First Schedule to the Factories Act, 1948 as a hazardous process. U/r 73-V (1) (b) of the MaharashtraRecords Factories Rules, 1963, employed in a 'hazardous process' shall be medically examined by the Factory Medical Officer once in a period of months to ascertain the health status all the workers in respect of occupationalincluded health hazards to which they are exposed.

U/s 2 (I) of the Factories Act, 1948, worker means any person employed, directly or by or through any agency including a contractor.

Observations

for medical examination of Workerscontractor workers were not

provided on request.

6The number of workers employed ofthrough contractors were not

in the returns filed.

toU/r 73-W (2) of the Maharashtracertificates Factories Rules, 1963, the Factory Medical Officer (FMO) shall possess a

Medicalcertificate of Training in Industrial Health of minimum three month duration recognized by the State Government or possess a diploma in Industrial Health or equivalent. U/r 73 V (1) (a) of the MaharashtraRecords

upFactories Rules, 1963, Workersmedical employed in a 'hazardous process' shal.

for the said qualification were not produced on request.

N 0

for pre-employmen examination of contracto In progress

workers were not provided o

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S. No.

18

19

20

2 1

Testing of Pressure Vessels

Health & SafetyUIr Policy

Health & SafetyUIr Policy

Structural StabilityUIr Certificate

Compliance Requirement

be medically examined by the Medical Officer once before the employment to ascertain physical fitness of the person to do the particular job. U l r 6 5 (4) of the Maharashtra FactoriesTest Rules, 1963 Every pressure plant service shall be thoroughly examined by a competent person.

73-L (5) ( f ) of the MaharashtraThe Factories Rules, 1963, The Health Safety should specify its intention integrate health and safety in decisions including those dealing with purchase of plant, equipment, machinery and material as well as selection and placement of personnel.

73-L of the Maharashtra FactoriesKTPS Rules, 1963, the occupier shall the Safety Policy as often appropriate.

3-A of the Maharashtra FactoriesThe Rules, 1963, no manufacturing shall be carried out in any premises of a factory unless a fresh certificate of stability in Forml-A is obtained from a competent person.

Observations

Factoryrequest.

reports for the pressure invessels were produced on request.

health and safety policy of the andcorporate does not have the said

tocommitment. However, KTPS has allframed i ts own policy statement

with the above commitment.

has initiated the work for reviseobtaining OHSAS certification and

ashas prepared i ts plant level policy statement. However, the Safety Policy at the corporate level has not been updated since restructuring of MSEB.

said certificate for testing processconducted within the last five years

was produced on request.

Compliance

Yes

Partial

Partial Compliant

Yes

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S. No.

22

23

24

25

Compliance

N 0

Yes

Yes

Certificate of Training for Factory Medical Officer

Application Renewalof license

Data provided Annual Return

Register Pressure Vessels

Compliance Requirement

U/r 73-W (4) of the MaharashtraThe Factories Rules, 1963, Within one month of the appointment of the Factory Medical Officer (FMO), the occupier of the factory shall furnish to the Chief Inspector the particulars of the FMO.

forThe data provided in Column 4 against "Maximum number of workers to employed on any during the year" in application for the license in Form 3 t o be filed under Rule 8 for the renewal license was

inThe annual return filed U/r 119 (1) of the Maharashtra Factories Rules, for the year 2006 year indicated number of Male workers as 2104 and Women workers as 37. These were the permanent employees of Mahagenco.

U/s 2 ( 1 ) of the Factories Act, 1948, worker means any person employed, directly or by or through any agency including a contractor.

forU/r 65 (7) (1) of the MaharashtraThe Factories Rules, 1963, the manager shall maintain a register of.pressure plant or pressure vessels with its particulars.

Observations

said communication to the Chief Inspector was not provided on request.

Male: 1567.91 and Women: 28. 58. beThe register was produced as

therequested.

The numbers of workers employed 1963through contractors were not

theincluded in the returns filed.

said register was produced on request.

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u V) C TaJ C * 0 'c m % = 2: c V)? o m - 3 .- O U a J zunaJu; $ : F C S.2

E z 2 ' 3 ~ ; ~ - =.a,.!!! aJ 05 c > x m . = n .o E a, Z ' a J * a J V ) ~ ~ 2 o c m o 5" * L ,S,B c *

aJ c 0

a J o 0 U g U 5u:c a J a J m 2 z .= c a L a,",'= m ">a:: .-

a m u Y a J * w m 2 5 5 - m * > E t : z , ~ z o E m E 0 aJ: T 2 . E "7 5 : ; f ~ e o m u 2 2 * aJ L Z U Z 5.E m L m & V ) * n* caJcgEJ Z Z ~ Z E E

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APPROACH FOR POLLUTION PREVENTION AND CONTROL ASSESSMENT

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TABLE 2: STACK DETAILS (Source: Monitoring Report, VlMTA LABS)

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Pollution Control Equipment

ESP ESP

ESP / Bag Filter

ESP / Bag Filter

ESP

Flue gas veloclty (m/s)

Unit 2: 10.5 Unit 3: 11.2'

A: 16.70 B: 24.53 A: 23.14 B; 22.21 A: 14.4 B: 17.4

Stack Details (Unit)

Stack 1 (Unit 1 & 2) Stack 2 (Unit 3 & 4)

Stack 3 (Unit 5)

Stack 4 (Unit 6)

Stack 5 (Unit 7)

Stack Height (m)

7 6 7 6 9 0

9 0

90

Duct Dla(m)

2.98 x 6.50 2.98 x 6.50 2.80 x 4.00

2.80 x 4.20

3.15 x 3.15

Flue gas Temp(oC) Unit 2: 122 Unit 3: 129

A: 140 B: 141 A: 145 B: 143 A: 142 B: 145

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Z C C m a - z 0 % 0 w

r z O c m l n m a w m 6 C . V ) b L 0 m e 0 .= 5 .E C w rp Q W

r . 5 rpuu - w c z u g uJ= Q ; W = E u Z z z o r p

r p 2 * U L 0 z O ' = ' C w

w U 2 . 2 - yi .- > a rp * * - a * w.s 0 g L r p c E C a='* w . s 2 5 2% .k .= g

.IS," .I.- m 0 . E c 0 w.!!?

aJ (n5 E w ;,"a e % w

= ' C a J W C C m r p n c I C I c I

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Ambient Air Quality Monitoring Locations

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FIGURE - 2: AAQ (SPM) - AVERAGE ALL LOCATIONS

r herage SPM Level (PSI Locations)

C l u b No 1 L J 100

t +Standard "Y 0

2004-05 200506 200647 200748

Year

FIGURE - 4: AAQ (NOx) - AVERAGE ALL LOCATIONS

Average NOx Level (All Locations) 1

x04-05 200506 2l3E-07 200708

Year

140-

FIGURE - 3: AAQ (S02) - A VERAGE ALL LOCA TlONS

120-

FIGURE - 5: AAQ (SPM) - AVERAGE ALL LOCATIONS (SEPTEMBER 2007)

X " ,, x

Average SO2 Level (A1 Locations)

140 7

2 100- I R;ihuay Sidng

E, 80- : m -

Average SPM Levels (All Locations)

3 120 - Tn

100 - g 80-

'C 60-

Tlme Ofice Club - 2 Railway Siding KTC Koradi S F colony I Stage - 2

L

Railway Sidr

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FIGURE - 6: AAQ ( P M 1 0 ) - AVERAGE ALL LOCATIONS (SEPTEMBER 2 0 0 7 )

FIGURE - 8: AAQ (SOz) - AVERAGE ALL LOCATIONS (SEPTEMBER 2 0 0 7 )

Average PMIO Levels (All Locations)

Time Omce Club - 2 Raihvay Siding KTC Koradi STP colony I Stage - 2

PMIO I A Standard

FIGURE - 7: AAQ (NOx) - AVERAGE ALL LOCATIONS (SEPTEMBER 2 0 0 7 )

Average NOx Levels (All Locations)

Time ORce Uub - 2 R a i k y Siding KTC Koradl Stage - 2

Locations

I Average SO2 Levels (All Locations)

I Time ORce Club - 2 Railway KTC Koradi STP cdony I Slage - 2 Sid~ng

Locations

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4.3.2. Stack Emission Data Review

Stack Monitoring (All Units)

The stack monitoring was carried out twice a week every month by KTPS. Average monthly data and yearly data for all the units was reviewed to understand the stack emission level and overliers, if any, over a period of time. The stack emission levels were compared with the exiting local and statutory norms to check if there were any deviation and the reasons for the same have been recorded for reference.

Based on the monthly stack monitoring data conducted by KTPS for the year 2003-04 to 2006-07, the average emission levels of PM, SO2 and NOx were analyzed.

Based on the data it was found that the yearly average PM emission of units 1 through 4 (Stage I) were found to be within the prescribed limit. PM emission level for Unit - 7 was found to be higher than the limit. The PM emission level for Unit 5 was higher than the statute in the year 2003-04 and 2004-05. The same was within the limit for the year 2005-06 and 2006-07. The decrease in the PM emission is attributed to the installation of the bag filter. The PM emission level for Unit 6 was found to be within the limit for the year 2003-04 and 2006-07. The same was exceeding the limit for the years 2004 - 06. The higher levels during the said period was due to the inefficiency of the bag filters which was later changed during the shut down period in the year 2005-06. This contributed to the decrease in the PM emission.

As per PPAH, the maximum permission emission level for Particulate matter is 100 mg/Nm3 however the target should be 50 mg/Nm3. Based on the data analysis it was observed that the particulate matter emission of all the units are higher than the prescribed limit of 100 mg/Nm3. Figure 16 shows the average PM emissions of all the units during the years 2003-04 to 2006-07.

Considering that the air shed in the area is not degraded and the particulate matter levels are much below the prescribed limit, a target of 100 mg/Nm3 can be setting into

SO2 emission levels were monitored at the station level as the consent order has given a limit in metric tons per day. The SO2 emission of 3 years i.e. from 2004-05 to 2006-07 was considered for the analysis. During the years 2004 to 2006, the limit prescribed by the state pollution control board was 118 MT/Day which was later revised to 203 MT/Day in the renewed consent order issued during December 2006.

The average SOz emission at the plant level during the years 2004-05 and 2005-06 were 108 and 109 MT/day which was within the prescribed limit of 118 MT/day. During 2006-07, the SO2 emission was monitored separately for both Stage I and II. During the year, stage I recorded an average SO2 emission of 11.0 MT/day which was much below the prescribed limit of 203 MT/Day. The emission levels in Stage II were 23.60 MT/day which was

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aqain less than the prescribed limit. As per the PPAH, there is no SOz emission norms prescribed and the plantlunit should follow the local requlations.

NOx emission levels for all the units were found to be within the prescribed limit. No deviations were observed in the NOx emission levels durinq the period for which the data was reviewed.

FIGURE - 9: STACK EMISSION ( P M ) - ALL UNITS

Average PM Emission (All Units) I 600

;i E 500

% 400 - 3 300

zoo 2 100

0

Unil 1 Unit2 Unit3 Unit4 Unit5 Unit6 Unit7

Ullts

2 0 W - 0 5 E3200506 O K 0 6 0 7 + S t a m +PPAH +Targel as per PPAH

FIGURE - 10 : STACK EMISSION ( NOX) - ALL UNITS

Average NOx Emssion (All Units)

I Units I

FIGURE - 11: STATION LEVEL AVERAGE STACK EMISSION ( S 0 2 )

I SO2 Emission (Station Level)

2004-05 200506 200607 (Stg I) 200607 (Stg II)

Years

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4.3.3 Environmental Monitoring as part of Audit

Environmental monitoring is carried out by KTPS on a regular basis at the locations specified by the state pollution control board and the same is report t o the Board reqularly. As part of the environmental audit 5 days monitoring was carried out for various environmental aspects. This data provided an independent perspective on the existing status of environmental conditions in and around KTPS. The monitoring was carried out by an independent environmental lab M/s Vimta Labs, Hyderabad during 25th and 29th September 2007. Later the monitoring was repeated twice during September-2007 and January 2008 by M/s Mahabal Enviro engineers, Nagpur. The details of the monitoring location are provided in the Annexure - II. The locations are identified on the map given as Plate - 1. 4.3.3.1 Stack Emissions

Vimta Labs carried out the stack emission monitoring between 26th and 28th September 2007. The stack emission of Units 2, 3, 5, 6 and 7 were monitored during the period. Unit 1 and 4 were not monitored as Unit 4 was under shut down and oil firing was underway in Unit 1 and it was suggested by KTPS not to monitor the emissions during oil firing.

The stack emissions were monitored at the existing port holes provided on the duct of the outlet from ESP /Bag Filter. The results of the stack monitoring are as follows:

Particulate Matter: The stack emission monitoring showed that the particulate matter emissions of Units 5, 6 & 7 were much higher than the standard limit of 150 mg/Nm3. The emission levels of unit 2 & 3 were recorded below the standard limit.

As per PPAH, the maximum permission emission level for Particulate matter is 100 mg/Nm3 however the target should be 50 mg/Nm3. In rare cases, an emissions level of up to 150 mg/Nm3 may be acceptable. Based on the data analysis i t was observed that the particulate matter emission of all the units are higher than the prescribed limit of 150 mg/Nm3. Figure - 12 shows the emission levels of particulate matter.

Sulphur di-oxide (SO2): SO2 emissions were analyzed for the stack emissions. It was observed that the standard limitfor SO2 emissions is 203 MT/Day. As per PPAH, it is recommended that the SO2 emission levels meet regional load targets.

Based on the analysis of the stack emissions, the SO2 emission were observed to be with in the prescribed limit. The Figure - 13 shows the emission levels of SO2.

Oxides of Nitrogen (NOx): In order to determine the concentration of NOx emissions from stacks, flue gas analyzers were used and monitoring was carried out. The NOx emissions were higher than the prescribed limit of 150 PPM for Unit 6 (LHS) based on the readings based on one grab sample. However during other sets of readings NOx

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level found well within the prescribed limits. The NOx levels for remaining units were also found well within the prescribed limits. The NOx levels for the remaining units were found to be within the prescribed limit. Figure - 1 4 shows the emission levels of NOx.

Note: NOx conversion: mg/Nm3 to PPM (multiply by 0.487) [Source: PPAH]

FIGURE - 12: STACK EMISSION (PM)

Stack Emission (Particulate Matter)

2 3 5a 5b 6a

Unit (Dud) D SPM (mgINm3) +Standard (mdNm31

FIGURE - 13: STACK EMISSION (S02)

I Stack Emission (S02) I

3 5a 5b

Unit (Duct)

FIGURE - 14: STACK EMISSION (NOx)

1 Stack Emission (NOx)

5b 6a

Unit (Duct)

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4.3.4 Pollution Load

In order to determine the emissions per unit (kwh) of electricity generated, the plant load at the time of stack monitoring was recorded. Based on the plant load and the emission levels of particulate matter, SO2 and NOx, emission levels per unit of electricity generated was calculated. The same is presented as Table - 3 below for reference.

TABLE - 3: POLLUTION LOAD (PM, SOz & NOX)

As can be seen from the table above, Units 2 & 3 was operational at more than 90% load and the remaining less than 75%. Considering the load factors of all the units, it can be inferred that the pollution loads are much higher. The values presented as based on the grab sample collected at one instance and are not conclusive.

Mercury (Hq), which is one of the pollutants released into the atmosphere during the combustion of coal, was also analyzed in the stack emissions. The Hg levels in the stack emission unit wise are provided as Table - 4.

Based on the analysis and data presented, it can be seen that the Hg load ranges from 0.042 t o 0.126 g-HqIMWh. The highest was recorded in Unit 6 (Duct - b) and the lowest in Unit 7 (Duct - a). The analysis of Hg in the stack emission showed that the levels were in the range of 0.01 mq/Nm3 to 0.03 mg/Nm3.

There are no prescribed guidelines for the limit of Hg emission from stack by the local authority. The Central Pollution Control Board (CPCB), the governing body for environmental standards and guidelines, has also not provided any standard for Hg emission. Therefore, it is not possible to determine if the Hg emissions are within the limits.

Therefore, the following data presented is only indicative and can be treated as baseline for future monitoring purposes.

-.

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TABLE - 4: POLLUTION LOAD (Hg)

4.3.5 Air Pollution Control Systems

KTPS has installed ESP and Bag Filter as the pollution control equipment for control of stack emissions. Unit 1 through 4 has ESP as the pollution control system. The outlet duct from ESP is then attached to the stack. Unit 1 & 2 have 1 stack of 76 mts and Unit 3 & 4 have 1 stack of 76 mts. Unit 5, 6 & 7 have dual system of ESP and Bag Filter. The stack heights of Units 5,6 & 7 are 90 mts each respectively. The design details of the existing ESP and Bag Filters are provided as Annexure - I for reference.

The ESP along with BF is taken in service with 10% maximum opening, if Flue Gas APH Outlet temperature exceeds 160°C, or DP exceeds 200, or Furnace draft goes positive.

KTPS measures the efficiency of the pollution control equipment i.e. ESP/Bag filter by monitoring the flue gas parameters at ESP inlet and outlet. The same was carried out during 14th February - 1'' March 2007 for all the units. Based on the data available, the following was the efficiency recorded during the period as given Table - 5.

As can be seen from the table, the efficiency of the pollution control equipment is more than 99% w.r.t to all the units expect for Unit -7 where the highest outlet SPM level was recorded during a grab sample i.e. 910 mg/Nm3 as against the prescribed 150 mg/Nm3. The design of the present ESP with 99% efficiency is 248 mg/nm3 this is the design limitation of the present ESP (being designed at the time when present norms did not exist). In order to reduce the SPM levels using chemical dozing, the contract has been given to M/s Chemptrol Pvt Ltd. recently

TABLE - 5: EFFICIENCY OF POLLUTION CONTROL SYSTEM (Source : KTPS)

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I I I I I Note: Subsequently, KTPS had carried out stack monitori September 2007 and January 2008, during which, the average SPM levels at Unit -7 were recorded as 475 and 4 6 1 rng/Nm3 respectively.

Efficiency (%) )=(A- B)/A*100

Unit

Maharashtra Pollution Control Board (MPCB) had served a notice to KTPS for high PM emission from Unit 5, 6 & 7 durinq the year 2005. KTPS sent a detailed action plan against the notice on 2nd August 2005, where in it was informed that the retrofitting works for Unit - 5 were already completed and bag filter commissioned.

Partial replacement of bags for Unit - 6 was carried out during March 2008. New order was placed for 8022 baqs (PTFE membrane type) on 27/08/08 with temperature limit of 260°C. The guaranteed service hours for the proposed baqs was indicated as 32000 Hrs and the cost per bag is INR 12182.24. An additional cost of INR 2243.16 is required for providing suitable cage for above new design. Installation, testing & commissioning charges would be additional and costs INR 24 Lakhs. The baqs will be replaced in O/H of Unit 6 scheduled in Oct-08.

Rated Capacity (MW)

The retrofittinq work for ESP of Unit - 7 was delayed and an extension in the date was requested. The same was accepted by MPCB and time was extended till 31st March 2008.

Limitations

Load during stack monitoring

The efficiency of the pollution control equipments could not be carried out based on the monitorinq as it was observed that the portholes provided for the monitorinq of stack emissions was not as per the prescribed norms of CPCB. As per CPCB guidelines, to ensure laminar flow, sampling ports shall be located at least 8 times chimney diameter down stream and 2 times up stream from any flow disturbance.

This was not observed at the site where all the portholes were either placed close to the gate valve or close to the bends which leads to disturbance in the laminar flow and inaccurate results.

Average SPM inlet (mg/Nm3)

The CPCB norms as referred are applicable to the Power Stations after 1997 and these are not applicable to the Units erected prior to 1997. Also, for the existinq stack, it is practically not possible to make such arranqement.

Average SPM oulet (mg/Nm3)

4.3.6 Recommendations

The following recommendations are being proposed for increasing the efficiency of the pollution control system for Unit - 6:

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the ash particles, enables them to agglomerate better and results in improved collection efficiency at the ESP.

The ammonia injection system includes ammonia storage tank, ammonia vaporiser, knock out drum, steam system, instrumentation and controls. Ammonia is evaporated through a steam coil vaporizer and the ammonia vapor is maintained at a constant pressure through a pressure regulating and a pressure control system provided on the LP stream supply. A knock-out drum is provided to de- entrain any ammonia liquid droplets entering the system. Down stream of the ammonia knock-out drum, an auto regulating, pressure reducing valve with a pilot valve facility is provided in order to maintain a constant down stream pressure of 2.8 kg/cm2(g). The entire ammonia storage system is also provided with safety relieving devices, pressure and temperature gauges, and a vent header at an elevation of 22 meters in order to safely disperse ammonia in an unlikely emergency situation. The sample schematic of the ammonia dosing system is given as Figure - 15.

The ammonia is dosed at the inlet of each pass of the ESP through a fine control provided through a needle valve. Air is mixed through air blower system to maintain the concentration of ammonia in the

' Chemithon Engineers Ltd., (CEL)

technology has been proven and widely acceptable, the same is recommended for improving the ESP efficiency.

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inlet at a value of about 0.5% to 1.5% depending on the level of ammonia required for the system. This also helps in proper mixing of ammonia in the flue gas. The ammonia concentration in the flue gas can be varied from 2 0 ppm to 7 0 ppm. -- The dual flue gas conditioning technology offers cost effective solutions as the investments for the ammonia based dosing system is in the range of Rs. 1 lakh per MW1.

NOx Control system not in place

As per the Environmental Protection Act, 1986 and amendments thereon, the NOx emission limit is specified only for gas based power plant. However, as per the consent order issued by MPCB to KTPS, the NOx limit has been specified as 150 PPM and no specific NOx control system has been mentioned. KTPS has not put in place any specific NOx control system. KTPS has also requested MPCB t o relax the NOx limit vide a letter no. KTPS/CGM (Gen O&M)/WTP-II/ENV/1539 dated 24th Jan 2007.

In order t o further reduce the NOx emissions, KTPS may install low NOx burners. Low-NOx burners limit the formation of nitrogen oxides by controlling the mixing of fuel and air, in effect automating low- excess-air firing or staged combustion. Compared with older conventional burners, low-NOx burners reduce emissions of NOx by 40-60%.

As NOx levels are well below the prescribed limits by MPCB/CPCB, considering the unwarranted additional cost burden for R&M activity, Low NOx burners is not recommended.

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Figure - 15: Schematic of Ammonia Injection System

Others Recommendations:

k KTPS may consider providing portholes for monitoring of stack emissions at ESP inlets for all paths as per the CPCB norms during R&M.

k KTPS should complete the retrofitting activity of the unit 7 ESP at the earliest possible to reduce the PM emission from the unit which is exceeding the prescribed limit.

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4.4 ASH GENERATION & UTILIZATION TABLE - 6: ASH GENERATION (Source - KTPS)

Coal, the raw material for power generation at KTPS, was analyzed to determine the ash content. Both proximate and ultimate analysis was carried out on the bunkered coal for Stage I and II of KTPS. Based on the analysis it was found that the ash content in the coal is 35%. By considering the average ash content of 35% in the coal, the quantity of f ly ash generated during the years 2004-05, 05-06 and 06-07 is given in the Table - 6.

As the quantity of the fly ash and bottom ash cannot be KTPS has entered into an agreement with M/s Manikgad

quantified, a theoretical norm of 80:20 for fly ash and Cements (MC) for collection and utilization of f ly ash. As

bottom ash has been taken t o arrive at the quantities. per the agreement, the cement manufacturer would collect the entire quantity of f ly ash from Unit -5 and half quantity

As on date, KTPS has not installed any system where the captured fly ash can be utilized. All the fly ash is transported to the ash handling plant where the ash is mixed with treated effluent and raw water to prepare ash slurry and is sent t o ash pond. The ash slurry supernatant is partly recovered and recycled back into the AHU for preparation of ash slurry.

As per the Fly Ash Notification issued by Ministry of Environment and Forest (MoEF), New Delhi in 1999 (Draft Notification 2007 yet t o be finalized), all thermal power plants based on coal / lignite shall provide fly ash to cement / brick manufacturers free of cost t o for manufacturing concrete, bricks and use in other construction activity.

from Unit-6. The same is on a Built-Own-Operate basis. KTPS has also entered into an agreement with M/s Murli Agro for the collection and utilization of dry ash from Unit- 6 and Unit-7.

4.4.1 Ash Util ization Plan

Based on the aforementioned arrangement for fly ash utilization, the following ash utilization plan is provided below.

The ash generation for Unit 5 & 6 has been considered based on the average coal consumption in the respective units and the ash content of coal.

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4.5 WATER SOURCE AND RECYCLING SYSTEM

The source of water for KTPS is from the reservoir of Pench Dam located approximately 25 km from the plant. The water is supplied to the Pond No.3 throuqh qravitation flow. From pond no.3 the water is pumped into the plant. After in-house consumption, most of the water is circulated back into the pond - 3 for reuse. The schematic diagram of the water flow system at KTPS has been provided as Plate - Ila for ready reference.

4.5.1 Water Scheme

There are 2 Raw Water Pump Houses (RWPH) at Pond No. 3 for pumpinq of water to various units. RWPH I supplies water to Staqe 1 units and RWPH II supplies water to Staqe II units. Dalmia Pump House (DPH), which supplies water to both Khaperkheda power plant and KTPS, also draws water from pond - 3.

The water thus pumped is sent to the raw water tank at KTPS which is later sent to Water Treatment Plant (WTP) of staqe I1 where the water is treated and the DM water is used for power plant and chlorinated water is used for domestic purpose. Water from the raw water tank is also supplied to the Ash Handling Plant (AHP) for slurry preparation.

DM and Coolinq water system: After DM water is used at individual units for steam qeneration, the condensate extracted from the LP exhaust is sent to the coolinq

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towers. For Staqe I, all the units have coolinq towers. For Staqe II, only Unit 6 and 7 have coolinq towers. Unit 5 has a natural coolinq system i.e. pond - 2.

FIGURE - 16: DM & COOLING WATER SYSTEM

,I+, sI1 Fe-3 Domestic (Colony &Plant)

Dafmla pump Inflow from Pench Dam -

The return water from the coolinq tower flows back to condenser. Water in this close cycle is circulated with CW Pumps located at condenser inlet and Coolinq Tower Lift Pumps (CTLP) located near Coolinq towers. On return path of the water from the coolinq towers to the condenser is a tank i.e. junction box (JB). Overflow of this JB qoes to Pond No. 3. Unit 5 has a natural coolinq system where the hot water from condenser is let out to pond no. 2 for coolinq which later joins pond. -3.

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The water from pond - 2 joins the raw water source pond - (settling tanks) and no secondary treatment using 3 via two different channels. One channel from pond - 2 is chemicals is carried out. The treated water from the divided into 2 streams with a ratio of 60:40. The 60% settlers is sent to the effluent outlet sump from where it is stream joins pond - 3 after traveling a distance of about pumped to the new raw water pump of Unit 7, clear water 6.5 km through the villages surround the plant and the 40% pump of unit 5 and slurry tank of unit 6. stream after traveling a distance of approximately 1 km.

The solid waste from ETP mainly contains ash which is FIGURE - 17: COOLING WATER CIRCULATION SYSTEM recovered and supplied to local brick manufacturers.

rn b 1 The detailed schematic diagram of the ETP and waste

Unit 6 & 7 rn , Units l , 2 , 3 8

4 Rwm l

I

/ Ovefflow I

I ~ r m d ~ o . 3 1. I pond NO. 2 - 40% Channel u 60% Channel

Effluent Treatment Plant (ETP): An ETP has been provided at KTPS for treatment of trade effluents.

The waste streams from both stage I and II are collected in the settling tanks from where it is pumped into the settlers. The ETP at KTPS is only used for primary treatment

water flows is provided in Plate - IV of the report.

During the audit period, the process effluent analysis and treated effluent analysis was carried out to understand the characteristics of the effluent before and after treatment. Process effluent analysis and treated effluent analysis given as Annexure - 111.

The pH in the ETP outlet was recorded as 8.2. The suspended solid level in the ETP outlet was recorded as 106 mq/l and oil and grease as 5 mq/l. Chromium and Hq were found to be less than 0.01 mgll.

Sewage Treatment Plant (STP): KTPS has a residential colony about 2 kms from the plant boundary on the west side of the Naqpur - Chindwara highway. Domestic water supply to the colony is from the water treatment plant after filtration and chlorination.

The domestic sewage from the colony is sent to STP for treatment which is designed for a capacity of 100 cu.m/hr.

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The treated water is used for qardeninq. Overflow from the STP is discharged out of the colony area. Sludqe from the STP is used as manure for the qardens and plants in colony and plant.

The detailed schematic of the STP is provided in Plate 5 of the report. The inlet and outlet characteristics of the sewaqe have been qiven in Annexure - 111.

It is observed that the treated sewaqe meets the requirements of the on-land disposal standards set by CPCB. The pH was recorded as 7.4 and COD was recorded as 23.5 mq/l and BOD of (5 mq/l. The treated water is being used for qardeninq in plant and colony.

Ash water recyclinq system: The streams from the both the staqes are sent to ETP where the solids are settled usinq clarifiers. The treated water is pumped into the Ash Handlinq Unit (AHU). The ash collected from the ESPIbaq filter is mixed with the treated water to prepare slurry. The slurry is then pumped into the Booster Pump House (BPH) from where it is pumped to the ash pond.

Part of the supernatant from the ash pond is collected into the Ash Water Recovery (AWR) scheme and pumped back into AHU. The remaininq part of the supernatant is let out into open stream which joins a river. Another water stream from the ash pond is let out as open channel which is not recovered into AWR.

Additional raw water required for make up and preparation of the slurry is in AHU in pumped from pond - 3. The un- recovered water from ETP joins a stream from pond - 2 which later joins pond - 3.

FIGURE - 18: ASH WATER RECYCLING SYSTEM

runoffs. Pretreatment and boiler blow

owns I Water flow measurements were carried out to determine the quantity of water intake from Pond No. 3 and outlets from the plant.

Flow measurements were carried out usinq Non-Contact Flow Meters (NCFM) and Tracer Method. Durinq the measurement, the pump rated capacities and the runninq capacity was also noted to co-relate the flow measurements.

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4.5.1.1 Raw Water Pump House

RWPH I supplies water to stage I units and RWPH II supplies water to stage II. DPH supply water to the WTP II.

Using NCFM, water flows were measured from RWPH I and DPH. At the time of the measurement, 3 pumps were in operation at RWPH I and 1 pump was operational at DPH. Of the three pumps, water from 2 pumps at RWPH were being pumped to one header. From the header, water is pumped to the units. From the third pump, water is pumped directly to units. The pumps at RWPH were running at full capacity where as the pump at DPH was at 75% capacity.

The flow measurements were as follows:

RWPH l : Pipe I - 1314.25 (31542 cu.m/day) :Pipe l l - 0

Dalmia : 567 cu.m/hr (13604.8 cu.m/day)

Tracer method was used for measuring the flow from RWPH II as the channels were underground. In order to avoid inconsistency, 12 reading were taken at each channel to arrive at a agreeable average flow rate. The average flow rate at each channel which supplies water t o individual units is as follows:

P Unit 5: 287719 cu.m/day P Unit 6:326021 cu.m/day P Unit 7: 294645 cu.m/day

4.5.1.2 Ash Disposal

The ash slurry from the Booster Pump House (BPH) is sent to the ash pond at Khasara. The supernatant from the ash pond is collected in the pond and pumped back into the plant for ash slurry preparation. The AWR scheme is provided in Plate - II. At the time of monitoring, the pumps at Khasara AWR were not in operation (as cleaning of ash from the collection pond was underway). Only one pump was in operation at the Koradi AWR which was pumping water back to the plant.

Tracer method was used to measure the flow of ash water discharge from the ash bund at khasara ash pond. The ash water supernatant flows as two different streams. The flow rates of both the streams has been measured and presented below:

P Stream 1 (Left) - 10,703.8 cu.m/day P Stream 2 (right) - 33566.4 cu.m/day

The stream - 1 is partly recovered. The quantity of water which is not being recovered could not be quantified as the pumps at AWR Khasara were not in operation during the monitoring period. Stream - 2 does not join the AWR and is let out without recovering as an open channel which later joins the river.

Waste water from the Coal Handling Plant (CHP) and overflow from BPH, is not treated is let out of the plant premises.

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In order to estimate the quantity of waste water being discharged out of the plant without treatment, flow measurements were taken using the tracer method and the same was recorded as 693.5 cu.m/hr (16,643 cu.m/day). In order to estimate the recovery of the waste water which is being recovered at the AWR Koradi, NCFM was used to measure the flow of the water. At the time of measurement only one pump was operational. Based on the requirement 213 pumps are operated at a time. The flow measured at Koradi AWR was 704 cu.m/hr (i.e. 16,917 cu.m/day).

4.5.1.3 Cooling Water System

As mentioned in the report earlier, all units under Stage I have cooling tower and the water recovered in circulated back into the system. For stage II, only Units 6 & 7 has cooling towers.

As mentioned in the earlier section,-during the monitoring, the 60% stream was closed due to expansion work on the highway. All the water was diverted into the 40% channel. Tracer method was used to estimate the flow rate. The flow of the stream was recorded as 9,63,965 cu.m/day.

4.5.1.4. Effluent Treatment Plant

Treated water from the ETP is pumped to the AHU for ash slurry preparation. In order to estimate the amount of water being pumped, flow measurements were taken at the pump house of ETP.

During the time of measurement, only one pump was in operation running at 75% load. The flow measurement recorded at the ETP pump house was 461 cu.m/hr (i.e. 11,076 cu.m./day).

4.5.2 Water Consumption

The water consumption details of KTPS, for the year 2007- 0B4, has been presented below to understand the quantity of water recycled / un-recovered.

Based on the details, the water balance has been prepared. The following are the details of the same:

I WATER BALANCE (All auantities in cu.m / vear) - - 7 - - . - I A I TOTAL WATER INTAKE (RWP) 1 309735592

The details of the water consumption and reuse are given in the Annexure-IX for ready reference.

Source : KTPS, Water Cess Rewrds for 2007-08

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Limitations of flow measurements

The following flow measurements were not recorded during the study period:

> Un-recovered water from ETP joining pond - 2 stream which later joins pond - 3 due to inaccessibility.

> 2nd stream from pond - 3 joining pond - 3 due to inaccessibility

> Cooling water joining pond - 2 from cooling tower of unit 6 & 7 as there was no straight open channel for measurement

> Over flow from JB as there was no straight open channel for measurement

P AWR Khasara as the pumps were shutdown for maintenance of the water recovery pond

Considerinq the aforementioned limitations, the water balance of KTPS could not be arrived upon. However, based on the data provided bv KTPS for the year 2007-08, the water balance has been provided.

4.5.3 Recommendations

Based on the study of the water cycle at KTPS and flow measurements where possible to estimate the quantity of water being used 1 recycled, the following recommendations are being made.

> Water flow meters are to be installed at major inlet and outlet points such as Raw Water Pump house, WTP I & II Inlets, DM water and Softener Water outlets, inlet to cooling tower, inlet and outlet of ETP and STP, inlet to AWR, outlet of AWR, inlet and outlet of AHP. The points where the flow meters are to be installed are shown on the schematic diagram in Plate - II B.

P Runoff water from CHP and overflow water BPH is presently being discharged without treatment which is approximately 16,643 m3/day. The construction of a primary treatment facility i.e. a settling plant be constructed at the outlet point to remove suspended solids in the overflow water and the entire quantity be recycled back into the system.

P Ash water supernatant from Khasara ash bund which does not join the AWR scheme should be recovered. Based on the measurements carried out during the audit period using tracer method, approximately 33,566 cu.m/day of water is being let out without recovery which can be recycled back into the system.

--

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4.6 CHEMICAL USE FOR WATER TREATMENT (DM TABLE - 9: CHEMICAL USE (Source - KTPS) WATER)

Raw water from pond no. 3 is pumped to Water Treatment Plant (WTP) of stage I and II for treatment using chemicals for preparation of DM water used for steam generation at the power plant and domestic water for colony and plant.

The chemicals used for treatment are HCL, Caustic Lye, Hydrazine (used to eliminate the residual oxygen in the feed water), Lime, Alum, Salt and Poly Aluminium Chloride ( PAC).

Historical data for the use of chemicals was collected from KTPS for the years 2005-06 and 2006-07. The quantity of

TABLE - 10: SPECIFIC CHEMICAL CONSUMPTION (Source - KTPS)

chemicals used for the treatment of water is given below in Tabie - 9. In order to estimate the specific chemical consumption interms of total DM water used during the particular year, the historical data of DM water consumption at the plant level was collected from KTPS. The quantity of DM water used during the year 2005-06 was 8,00,234 cu.m and during the year 2006-07 was 833,427 cu.m.

Based on the data made available regarding the total chemical consumption and the quantity of DM water used, the quantity of chemical used for treatment of 1 cu.m of Excess usage of chemicals in the WTP is due to the high water was determined and presented in the Table - 9 for turbidity and organic load of the raw water from Pond No.3. reference. This is due to the increased activity in the surrounding

areas of the pond by villages and agricultural activity. Also, heavy siltation in the banks of the pond has increased the

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vegetation in the banks and physically reduced the areas of the pond and water holding capacity.

The PAC consumption durinq the year 2006-07 was more durinq 2006-07 compared to 2005-06 by 0.0146 kgs. The consumption of other chemicals was less than the previous year.

4.6.1 Recommendations

The following are the recommendations for improving the water quality of Pond No. 3 which will also help reduce the > The cost benefit was calculated considering the

use of chemicals for treatment: above data.

> Chlorine levels in the Pench intake water and at the TABLE - 12 : Cost Analysis(Source - KTPS)

raw water pump house were analyzed. It was observed that the total chlorides as ppm of CaC03 ranged between 10-20 in Pench intake water and 70-100 near the raw water pump house (please refer table - 11).

TABLE - 11: Water Characteristics (Source - KTPS)

Savinqs in caustic soda( 23-10 = 13 MT

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Stg - ll RWP Water

120 - 150

300 - 400

-

Dalmia Pumphouse for KTPS (Present) 130 - 150

300 - 450

S. No.

1

2

Pench intake water

110 - 130 200 - 300

Parameters

M. Alkalinity

Conductivity

Unit

ppm as CaC03 Micro mhoslcm

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> Considerinq the aforementioned cost analysis, it is recommended that pond no. 3 should be cleaned immediately which would also help in increasinq the holdinq capacity of the pond and reduce the orqanic load and turbidity caused by the anthropoqenic activity.

consumption (MT) Considerinq 80% efficiency Rate of caustic soda (Rs. / MT Saving per month Savings per year

k A separate pipeline directly from the Pench intake channel should be established which will ensure supply of qood quality water directly to the plant. This will also help reduce the quantity of chemical used to treat the water there by reducinq the cost on chemicals; The proposed scheme has been provided as Plate - 111.

- 1 0 MT 25,000/-

2.5 Lakhs -30 Lakhs

4.7 NOISE CONTROL SYSTEM

The major sources of noise at KTPS are the Turbine Generators, Boilers, Cooling Water Pumps, Air Compressors and Transformers. Diesel Generators which are used only during total qrid failure are also sources of noise, however, this is limited to the period of operation.

Durinq the audit period, noise levels were monitored at 4 locations. The ambient noise monitorinq was carried out continuously for 24 hours with one hour interval. Durinq each hour parameters like L10, L50, L90 and Leq were directly computed by the instrument based on the sound pressure. The monitorinq was carried out at 'A' response and fast mode.

The ambient noise level at location monitored durinq the study period has been provided below in Table - 16.

As can be seen from the table, the ambient noise levels were monitored at the boundary of the plant, at the hospital in the colony and commercial complex at the nearest village outside the plant boundary.

The perusal of the ambient noise level shows that the Lday ranqed between 43.5 dB (A) to 58.6 dB (A). The highest was recorded at the plant boundary and the lowest at the hospital. The Lniqht ranqed between 41.1 dB (A) t o 52.1 dB (A). The hiqhest aqain was recorded at the plant boundary.

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minimize dust emissions. However no dust collection system with dust suppressants is made available at CHP.

Also, water sprinkling / spraying is done on roads to reduce the dust levels.

All the roads in the plant and colony are tar roads. The movement of vehicles in the plant is restricted and hence there in no dust from the roads.

KTPS had also carried out a study of air quality in the CHP premises during May 2007. The study was carried out by an independent consultant. Certain recommendations were provided based on the study which includes:

P Improvement in the dust control system installed at crushers;

P Sprinkling/spraying of water usinq neutrapit waste which contains dissolved CaC12 and MgC12 which are typical dust suppressants; and

P Tippers moving in the CHP should be covered.

4.8.1 Recommendations

The following recommendations to improve the air quality in the plant premises are provided below for consideration by KTPS management:

P Spraying / sprinkling of water in CHP area can be done usinq dust suppressants for retention of moisture for longer duration of time.

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PART 5: RESOURCE EFFICIENCY ASSESSMENT

The key objectives of the resource efficiency assessment includes:

P Historical performance of efficiency parameters such as primary fuel use, auxiliary fuel use, specific water consumption and auxiliary consumption;

P Establishment of heat and energy balance of the major energy guzzlers in the plant; and

P Discuss and finalize the energy conservation measures and best practices being followed by other thermal power plants in India with the appointed R&M consultant;

Our approach for resource efficiency assessment has been provided in the subsequent pages of the report.

5.1 HISTORICAL ANALYSIS OF POWER, COAL AND WATER

During the site visit, the data pertaining to historical analysis of the plant (Unit-6) such as power generation, water consumption and coal consumption have been collected for the previous 2 years and the graphs were drawn for the same.

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In addition, the pattern pertaining to specific coal consumption and specific water consumption were also drawn and peak points were highlighted. The data related to the breakdown of the plant was collected and analysis of the same was carried out.

The power generation, coal consumption, water consumption and specific coal consumption data were presented on year wise basis and the explanation of the graphs is presented in the following sections of the report.

All the data collected from the plant is enclosed as annexure at the end of the report.

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APPROACH FOR RESOURCE EFFICIENCY ASSESSMENT

Page 62 of 21 0 # ~ ~ ~ i i ~ l n ERNST& ~ ~ ~ f i b h g YOUNG w DO

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FIGURE - 20 : UNIT - 6 : COAL CONSUMPTION PATTERN FOR THE YEAR 2005-06

Coal Consumption pattern for the financial year 2005-2006

140000 - 120000 -

e 0 .L = 60000 - Planned overhaul

f maintenance

20000 -

-20000 - Month

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FIGURE - 22 : UNIT - 6 : AUXILIARY POWER GENERATION PATTERN FOR THE YEAR 2005-06

Auxiliary consumption for the year 2005-06

16.00 -

12.00 --

2.00 --

Ape-05 May-05 Jun45 Ju145 Aug45 Sep-05 Oct45 Nova5 Dec-05 Jan46 Feb46 Mar-06

-2.00 - Month

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FIGURE - 23 : UNIT - 6 : SPECIFIC DM WATER CONSUMPTION FOR THE YEAR 2005-06 -

Specific DM water consumption for the financial year 2005-2006 for Unit - 6

0.60 -

0.50 -- a .- 0 .- L C

$ 0.40 -- - W + 0

- k C m 3 0.20 -- + 0

Apr-05 May-05 Jun-05 Aug-05 SepOS Oct-05 Nov-05 Dec-05 Jan-06 Feb06 Mar-06

Month

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5.1.1 Analysis of Graphs

9 The total electricity generation in the year 2005-2006 was 1,302.966 Million units.

9 The total coal consumption in the year 2005-2006 was 984,994 Metric tonnes.

9 The total DM water consumption in the year 2005-2006 was 117,295,810 litres.

9 The average calorific value of the coal for is taken as 4,292 kcallkq.

9 During the site visit, KTPS break down records were analyzed and some of the major observations are listed below:

9 The plant was shutdown on 20 occasions, of which 19 were forced shutdowns and one was a planned shutdown.

9 The total number of hours for which the plant was shut down is 1,843 hours, out of which, the plant was shutdown for approximately 1349 hours during July and August and it was under forced shutdown for the remaining 494 hours.

Monthly downtime of the plant are mentioned below and the peak portions are marked in the graphs above.

April 2005 - 4.25 Hours May 2005 - 2.45 Hours June- August 2005 1,534 Hours September 2005 37.4 Hours October 2005 55 Hours

November 2005 0 Hours December 2005 147 Hours January 2006 6.9 Hours February 2006 2.35 Hours March 2006 53.57 Hours

The plant was under forced shutdown due t o various reasons. Some of the main reasons are listed below:

Fire a t GCR Boiler tube leakage High pressure in the furnace Boiler air ingress High drum pressure

9 As per the analysis based on the records, the plant shutdown happened because of Boiler tube failure for nearly 75 % of 494 hours.

9 On an average it takes 50-60 hours to arrest or retrofit the boiler tube leakage. The leakage of the boiler tubes was either in water tube / reheater tubes, etc. Because of these stoppages, abnormalities were found in power generation.

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FIGURE 25 : UNIT 6 : COAL CONSUMPTION PATTERN FOR THE YEAR 2006-07

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Coal Consumption for the financial year 2006-2007

120000 - . - - - - - - --. . .-. ..-.. . - - - - . . - - - - -

- -

80000 z c 0

'Dp 60000 E I

40000

20000

0

- -

--

.............................................................

--

I I I I I I I I I I I I I I I I 1 I I I

Apr-06 May-06 Jun-06 Jul-06 Aug-06 Sep06 Oct-06 Now06 Dec-06 Jan-07 F e w 7 Mar-07

Month

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FIGURE - 27 : UNIT 6 : SPECIFIC COAL CONSUMPTION PATTERN FOR THE YEAR 2006-07

Specific Coal Consumption pattern for the Year 2006-07

1 .oo

0.90

0.80 ' 0.70 a" cr O 0.60

$ 0.50

\ - m 6 0.40 cr 0

$!' 0.20

0.1 0

0.00

Apr-06 May-06 Jun-06 Jul-06 Aug-06 S e p 0 6 Oct-06 Now06 Dec-06 Jan-07 Feb07 Mar-07

Month

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A A A A A

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5.2 COAL HANDLING PLANT AND MONITORING

KTPS is facilitated with a centralized Coal Handling plant t o supply coal t o both Stage I and Stage II.

A conveyor is being operated to supply coal from the coal yard to another conveyor from where coal is being fed into the bunkers. At present there is no measurement to weigh the coal before feeding into bunkers.

5.2.1 Coal receipt - A Brief Introduction

KTPS receives coal in two modes: P Rope P Rail

The road transport is used only in case of emergency.

The following companies supply coal to KTPS.

P Mahanadi coal fields P Western coal fields P South eastern coal fields

The coal requirement for the plant is worked out considering the previous coal factor. The coal factor is determined based on the expected generation and calorific value of the coal. The anticipated coal requirement will be compiled and will be submitted to Head Office (H.O.) for approval.

Rakewise receipts are maintained by KTPS and S E Nagpur. KTPS prepares the bills and submits the same to the HO.

H.O. will release the payment on receipt of coal. The cost of coal a t the time of receipt includes basic charges, royalty charges and sizing charges. Transit losses are allowed upto 0.8% of the total.

After the receipt of coal, the entire wagon is weighed with and without coal. The tare weight of the wagon is deducted from the total weight of the coal t o get the actual receipt of the coal. The weighed coal is stored in the coal yard for supply. At present, there is no online weighment of coal supply to the individual units.

The typical ultimate or elemental analysis of coal is given below:

TABLE 18 : ELEMENTAL ANALYSIS OF COAL

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Elements Carbon Hydrogen Nitrogen Sulphur Ash & Moisture Total

Value 42.6 2.5 0.9 0.8 53.2 100

Unit % %

% % % %

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The coal sample was taken at each mill and the proximate TABLE - 20 : SIEVE ANALYSIS OF COAL analysis was carried out for the same on 10th November 2007. The results of the analysis are qiven below:

TABLE 19 : PROXIMATE ANALYSIS OF COAL

5.2.2 Sieve Analysis (Crusher)

Belt No. 101 Belt No. 106

Sieve analysis of the coal is regularly carried out by KTPS to find out the size of the coal. A sample of 1 kg or 2 kg after crusher and after coal mill is taken out to carry out the sieve analysis. The sieve analysis results are qiven below:

--

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AD6

AFB

AD6

AFB

As per the analysis, 78% of the coal was crushed close to 20 mm size before beinq fed into the coal mill and 16% of the coal size was less than 2 mm. Though 94% of the coal was of desired size, 6% of i t was more than the required size. As the size of the coal is hiqh, the power consumption in the coal mill will be hiqh. Therefore, 6% of the coal will have direct impact on the coal mill power consumption which requires immediate attention.

3.04

12.94

2.19

13.22

KTPS is equipped with six coal mills better known as Coal Mill A, 6, C, D, E & F. Coal from the bunker is made to pass through the feeders and is beinq fed into the coal mill. The rate of coal fed into the mill is directly proportional to the speed of the feeders. The coal feeder is controlled with Dynodrive by varying speed.

After Crusher % 0 6 3 2 46 16

Sleve Gradation +lo0 + 50 +20 +2 -2

Once the coal is crushed, primary air from the PA fan will carry the crushed coal to the boiler.

Before Crusher % 18 16 2 0 3 8 8

36.1

32.41

41.81

37.1

In order to carry out the sieve analysis, the coal sample was taken after the crusher and before feeding to the

26.6

23.88

25.96

23.03

34.26

30.77

30.04

26.65

4715

4234

4301

3816

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boiler. The samples are taken from four sides and the results are given in Table - 20.

Two types of sieves are used by KTPS to conduct sieve analysis. Size of one sieve mesh is -200 mm and that of the other is +SO mm. Based on the analysis, on an averaqe 70% of the coal fed into the boiler is of required size as per the design.

But, specific to the coal mill A, 3.5% of the coal crushed from the mill is more than 50 mm. This clearly envisaqes not only the production of unburnt carbon durinq combustion in the boiler but also shows the poor performance of the mill.

Even in other mills, 1.4 - 1.6% of the coal size was more than 50 mm. As the size of the input coal is high, the unburnt carbon generation durinq combustion will be hiqh. In order to analyze the same, unburnts testing are carried out and the results are qiven below:

5.2.3 Unburnt carbon in the fly ash and bottom ash

The tests for unburnt carbon in the fly ash and bottom ash were carried out during the site visit and the results of the same are given in Table-21.

Unburnt carbon is being generated because of the following reasons

P lmproper sizing of coal before feeding into the boiler

P Hiqher flow rate of coal compared to the design value

P Lower air flow rate P lmproper design of boiler and furnace

As per the analysis carried out by KTPS, the unburnts are qenerated because of improper sizinq of coal and hiqher fuel input due to lower calorific value of coal.

On an averaqe, 6.5% unburnts in the bottom ash and 1% unburnts in the fly ash were measured which is significantly on the hiqher side. The qeneral acceptable limits of unburnts are < 4% for bottom ash and < 1% for fly ash. This is one of main concern where immediate attention from KTPS is required.

--

Page 77 of 21 0 =ERNST& YOUNG C@d+ln Eswrytbiq l4k Ve

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TABLE - 21 : SIEVE ANALYSIS OF COAL AFTER COAL MILL

TABLE - 22 : UNBURNTS IN BOTTOM AND FLY ASH

DATE I FLY ASH I BOTTOM I

Corner 1 2 3

I I ASH 1 n11 n13nn7 n

During the site v i s i M ~ & ~ were not in operation

C M - F

Unburnts more than ~r

(+SO) 1 1.1 1.6 1.8 1.38

Page 78 of 21 0 ERNS ST& YOUNG Quality In Fswyfbhg We ire

(-200) 7 6 76.8 65.8 76.1 73.68

CM - A (+SO)

4 4.4 0.8

Average 7 3.5)

C M - B ( -200) 62.9 64.5 73.1 65.4 66.48

(+SO) 1.6 0.9 1.7 1.4 1.4

C M - E (-200) 67.8 72.8 69.8 71.8 70.55

(+SO) 0.9 3 1.6 0.8 1.58

(-200) 75.8 69.6 64.8 76.4 71.65

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5.2.4 Auxiliary Systems

During the site visit, the power consumption of the individual auxiliary units was made available by KTPS. There are two types of auxiliaries in the power plant.

P Auxiliary systems exclusively for Unit 6 h Common auxiliary for stage II (Unit 5, 6 & 7)

The power consumption, voltage, current and power factor of the equipments which were under operation were given. The data exclusively for Unit 6 is given below:

TABLE - 23 : AUXILIARY POWER CONSUMPTION DATA

.-

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The total auxiliary power consumption is around 15 MW. The total auxiliary consumption of the Unit 6 works out to 10.1%. During the site visit, it was requested to perform an exclusive study to measure coal consumption, power generation and auxiliary power consumption. The measurements were carried out and based on the data, heat rate, efficiency, % auxiliary consumption and plant load factor are calculated. The results of the same are given below:

Eli E R N ~ ~ & YOUNG

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TABLE - 24 : AUXILIARY CONSUMPTION AND PLF DURING THE AUDIT PERIOD

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- - 0 0-i s : 2 c $ % " ' a % = t Z q 3 a Q m

- ( n o 0 3 " 3 p a - ; 3 3 n . " ' - a

2 9 2 % - !%: z 2 z 'D 0 cis I D 3 2

3 0 , % g 3 % ~ g z ' ~ 4 %

$ g m ,m - 5. g g 59.

4 2. z 28. 2 ~ - " ' z -0 2 3 z 3 g E " ' 2 %. "'s. q 3 0 < s s s m g 0 Q q 3 8 2 O Z W :s 5 3 3 m 0 0 0 3 " ' 3 - 4 b E n o n . P m m s rn: 5 . 7 c 3 5. ;P" =+-i m a . 4

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5.4 THERMAL EFFICIENCY OF UNIT - 6 BOILER TABLE - 27 : EFFICIENCY OF BOILER

The thermal efficiency of the boiler has been calculated using Indirect Method i.e., loss deduction method.

In this method, losses from the boiler are identified and the same is deducted from 100% to calculate the efficiency. It is one of the best methods recommended by Bureau of Energy Efficiency to calculate the efficiency of the boiler.

The secondary and primary data required to calculate the efficiency were collected from the plant. The following losses are calculated using the data collected from the plant.

P Heat loss in flue gas P Heat loss due to moisture in fuel P Heat loss due to moisture in air P Heat loss due to Hz in fuel P Heat loss due to radiation P Heat loss due to partial conversion of C to CO P Heat loss due to bottom ash P Heat loss due to fly ash P Heat loss due to unburnts in fly ash > Heat loss due to unburnts in bottom ash

The efficiency of the boiler is calculated and found to be 81.04%

- - --. -- - - -- -- --

Page 82 of 210 El! ~ V S T & YOU& Qualifyh F~wytLhg W Uo

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FIGURE - 29 : HEAT DISTRIBUTION CHART

Heat Distribution chart

81.0%

W Heat Lost due to flue gas I Heat loss due to hydrogen in fuel

Loss due to moisture m fuel Loss due to moisture m air

W Loss due to radration assumed W Unbumt losses in bottom ash

¤ Unbumt losses in Fly ash Heat loss due to partial conversion of C to CO

W Heat losses m bottom ash W Heat losses in Fly ash

Useful heat

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5.5 HEAT ADDITION DUE TO SUPER HEATER, FIGURE - 31: HEAT ADDITION BY ACCESSORIES ECONOMISER AND AIR PREHEATER

Superheaters, economiser and air preheater are used to increase the useful heat by recovering the waste heat from the flue gas. The flue gas temperature a t the boiler exit is close to 900°C. The flue gas at 900°C is made to pass through series of heat exchangers to extract heat from the flue gas. Superheater is used to increase heat of the steam coming out from the boiler.

Economiser is used to increase the temperature of the water entering into the boiler after the water is heated through heaters.

Air preheater, as the name indicates is used to preheat the air entering into the boiler.

TABLE -28 : HEAT ADDITION BY ACCESSORIES

Heat addition by accessories

11.9%

- "'0 7.5-/.

flea1 addtion by Super huater 8 Ilcaladdhton by Erommlscr

Heat add tan by A r prchcarcr

Though there is a significant heat addition by accessories, there is a considerable loss in the air preheater circuit. In order t o determine the losses in the air preheater, flue gas analysis is carried out before and after air preheater. The result of the same is given below:

As per the analysis, it is found that there is an increase in O2 in the flue gas. This clearly indicates that there is air ingress in air preheater. Immediate measures needs t o be taken to arrest this leakage, if the leak is lesser than the design.

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% %

0 2 % at Air preheater inlet 0 2 % at Air preheater Outlet

4.4 5.1

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The energy balance across the LP heaters, HP heaters, condensers and reheaters were evaluated with the help of the following details:

P Pressure across each heaters P Temperature across each heaters h Pressure and temperature across condensers P Pressure and temperature across reheaters

Currently, the steam flow rate across each heater is not measured or monitored by KTPS. Due to unavailability of instruments at the site, the same was not included in the report.

Steam flow rate is used to evaluate the overall performance of the boiler and turbine.

5.5.1 Turbine Efficiency Based on the pressure and temperature across each cylinder, the efficiency of the individual cylinders and the overall efficiency of the turbine are calculated. The efficiency details are given below:

and LP inlet are not functioning properly. It is recommended to replace the sensor immediately. LP cylinder efficiency and the overall efficiency are not established due to the non-availability o f dryness fraction a t the LP exhaust.

5.5.2 Heat addition due to reheater KTPS is equipped with a single stage reheating system which reheats the steam coming out from the HP turbine to 535°C. The reheat pressure during the audit period was 22 kg/cm2. The steam flow in the reheater is calculated by deducting the steam extracted in the HP heaters to the total steam supplied to the HP cylinder inlet. Steam extracted in each HP heater is calculated using the following formula :

Heat gained by Feed water = Heat lost by the steam. The drip temperature measured physically at various points, steam pressure across the heater and feed water flow is used to calculate the steam extracted in each heater.

TABLE - 3 0 : REHEATER EFFICIENCY

Page 87 of 21 0 B! ERNST& YOUNU C&ali(vh € e k i n g W Do

- - -

TABLE - 29: TURBINE EFFICIENCY HP turbine efficiency

kW

%

Heat addition due to reheater Heat addition in percent compared the useful heat output per kg of fuel

IP cylinder efficiency

81494

82.14

5.5.3 Condenser The efficiency of the IP cylinder is more than the design Condenser is one of the pertinent equipment in any power value. This is due to the fact that the temperature sensors plant. The condenser will always be maintained in vacuum displaying the temperature of the steam leaving the IP exit and the performance of the condenser is based on the

% 96.9 %

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altitude of the plant and the temperature of the water available in the near-by location.

The following parameters are monitored by the plant on a regular basis.

Pressure in the condenser = 665 mm of Hg or Absolute pressure = 7 5 mm of Hg Temperature of the condenser = 48.9 C Cooling water inlet temperature = 33.4 C Cooling water exit temperature = 42.9 C

Based on the above parameters, the heat rejected and effectiveness of the condenser are calculated and the details of the same are furnished below:

The heat rejected from the condenser are cross-checked with cooling water pump flow rate and the temperature difference across cooling water system.

TABLE - 31 : CONDENSER EFFICIENCY

Temperature being maintained in It he condenser

k8 .9 1 Main steam flow Range of the cooling water

eatr rejected in the condense based on water flow rate

kW

663 8.5

Effectiveness of the condenser Maximum possible effectiveness Rated flow rate of the ~ u m ~ s

5.6 HEAT RATE AND EFFICIENCY OF PLANT

TPH " C

Heat rate is one of the most important parameter which reflects the performance of the plant with the assistance of major equipments, auxiliaries and accessories.

58.6 7 0 28560

Lower the heat rate, better will be the performance of the plant and vice versa. Heat rate can be calculated exclusively for major individual equipments and also for combination of equipments.

% % m3/h

Heat rate is calculated based on the fuel flow rate, quality of the steam generated in the boiler and power generated by the turbine.

In this report, three different heat rates are derived with the help of the instantaneous data and secondary data collected from the plant. They are:

Boiler heat rate Gross turbine heat rate Gross unit heat rate

As these three rates are very important to find out the performance of the plant, the same are calculated and furnished below

Boiler heat rate (Heat supplied by the fuel)/(Heat generated in the boiler + heat added in the reheater)

-- - - -

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Turbine heat rate = (Heat generated in the boiler + heat P Power generated by the boiler = 175000 kW added in the reheater) / Power generated by the turbine or 150 Million kCal/h

P Heat supplied by the fuel = 542 Million kCal/h Unit heat rate = Heat supplied by the fuel / Power generated by the turbine The overall efficiency calculation of the plant is given below

The heat rates are also used to calculate the efficiency of TABLE - 33 : OVERALL EFFICIENCY OF THE PLANT the plant. (parameters hlalues l ~ n i t s I

TABLE - 32 : HEAT RATE I ~ a i n steam flow 1 663 ~ P H I l ~ a i n steam flow 1 184.2 I kds I Main steam pressure Main steam temperature Main steam enthalpy Main steam entropy

Instantaneous Overall Efficiency

Heat inlet to the turbine Power output Power output Heat inlet to the turbine

5.6.1 Efficiency of the plant 5.6.2 Benchmarking of KTPS

130 533

3425.3 6.5531

In general, the efficiency of any equipment will be CEA along with CII carried out energy efficiency study in 19 calculated as output upon input. As per formula, the power thermal units. The comparison of best figures in each generated by the turbine upon the heat supplied by the parameter achieved by Indian thermal power plant over last

boiler will give the efficiency of the plant. five years (2001-2005) have been collected and the same are compared with KTPS.

kgIcm2 C kJ/kg kJ/kq K

630826 175000

150500000 542386888

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kW .

kW kCal/h kCal/h

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TABLE - 34: BENCHMARKING KTPS WITH OTHER POWER PLANTS

5.6.3 Recommendations

During the site visit, the observations were made in terms of log book maintenance practices, operational practices, data retrieved from DCS system, availability of water flow and steam flow meters etc. Based on the observations, majority of the places had relevant instrumentation but the

same can be improved. Some of the suggestions are given below to improve the monitoring and recording system:

P Online power measurement of BFP pumps, ID and FD fans, CEPs and Coal mills. At present, total auxiliary consumption is monitored but by measuring individual power consumption, the exact loading of the equipments can be found out. Therefore measurement of power can be included in the log book as a part of regular practice

P Online power measurement of coal feeders. At present, feeders are operated with the help of RPM and Amps which is an old practice. Though measurement of amperage suffices the purpose, it will have direct impact on the efficiency of the motor as it is inversely proportional to the power factor. Therefore, power measurement can be included in the log book.

P Arresting of steam leakages. The steam leakage checks can be carried out regular intervals. Steam leakage arrest the same as much as possible to save energy.

P Measurement of boiler surface temperature at regular intervals. It is recommended to measure the temperature of the boiler at regular intervals to check whether the surface temperature is well within the limits. In case of abnormalities, the quality of insulation in the area can be improvised.

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> Measurement of coal consumption. Though it is well known that very few power plants in India have the facility to measure the coal, but online monitoring of the bunkered quantity of coal shall be carried out by installation of the belt weigher to the conveyor belts going to the bunker.

5.6.3.1 Major observation for Energy Savings:

5.6.3.1.1 Quality of coal The boiler installed in KTPS is designed to handle the coal with a calorific value (CV) of 5000 kcal/kg. But the coal received by the plant has a calorific value of 3800 - 4200 kcallkg. The receipt of low CV coal has a direct impact on the electricity generated by the plant. As per the elemental analysis, this coal has nearly 15% moisture and 33% Ash. As there is high moisture and ash quantity, KTPS plant personnel are utilizing higher quantity of coal compared to the rated capacity to maintain the load factor. Due to higher coal feed rate, incomplete combustion takes place inside the boiler. Due of this, the unburnts are produced and is observed in the ash analysis. The unburnts in the bottom ash are around 6 - 7%. During R&M, this issue should be considered.

The alternative option for KTPS is to avail the usage of washed coal in the boiler. The washed coal has comparatively higher calorific value and lesser ash content compared to that of conventional coal. Therefore, it is recommended to expedite available washed coal and use the same in the boiler.

5.6.3.1.2 Continuous usage of attemperation

During the visit, it was observed that there is a continuous attemperation. Attemperation or de-superheating of the steam will be carried out to reduce the inlet temperature of the, steam to the turbine when it is higher than the designed temperature. Though attemperation is a regular practice in power plants and as it does not lead to loss of steam or water, it is not necessary to increase the temperature of the steam to such a high temperature and reduce it to the design temperature.

In order to achieve high temperature, it is necessary to feed more fuel and during de-superheating, there is reduction in temperature of the superheated steam which is a loss of energy. Attemperation on an intermittent interval is healthy but not when done continuously. Therefore, during R&M, consideration should be given to address this issue.

5.6.3.1.3 Oxygen level in the flue gas and flue gas temperature During the site visit, the flue gas analysis was carried out to identify the oxygen level in the flue gas to determine the excess air level. Based on the flue gas analysis, the nitrogen balance was carried out to determine the excess air & air ingress and it was calculated and found to be 20%. Further, flue gas analysis was also carried out before and after Air preheater. There is a difference of 0.7% observed across the Air preheater. Though it is less than the design

--

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as mentioned by the plant personnel, reduction in air inqress will reduce the power consumption of ID fan. Therefore necessary measures can be carried out to arrest the air inqress.

In addition, the flue gas temperature was also observed to be hiqher than the desired value. On an average, the flue gas temperature of the thermal power plant lies in between 145 - 150°C. But the flue gas temperature was measured as 169°C. It is anticipated that the flue gas temperature will be much hiqh compared to 169°C as there is an air inqress in the flue gas path and even in the air preheater. Because of the addtion of fresh air having low temperature, temperature of the flue gas was observed to be lower. Otherwise, the actual flue gas temperature will be close to 200°C which is very hiqh compared to the normal standard of any thermal power plant.

Therefore, i t is highly recommended to take immediate measures to reduce the flue gas temperature.

5.6.3.1.4 Sieve analysis The sieve analysis is carried out by the plant personnel after crusher and before coal mill. During the site visit, different types of sieves were observed and the plant personnel were requested to undergo sieve analysis for a maximum range before crusher, after crusher and after coal mill. Based on the analysis for a specific sample, the following results were observed.

In practice, KTPS is monitoring and recording the analysis of the coal before the crusher. Durinq the visit, it was requested to carry out the sieve analysis before and after the crusher.

As per the analysis after crusher, it is observed that nearly 80% of the size of the coal after crushinq lies between 2 mm to 50 mm and only 16% of the size of the coal lies between -2 mm to 2 mm.

But before crusher, it is observed that nearly 58% of the size of the coal lies between 2 mm to 50 mm, 8% of the size of the coal lies between -2 mm to 2 mm and 34% of coal is having size hiqher than the 50 mm.

Sieve Gradation + 100 + 50 +20 + 2 -2

16% fines would be possible because of two main reasons: 1. Coal would hake been received with lot of fines or

smaller size 2. Improper functioning of Crusher

Therefore, if the sieve analysis was conducted before crushinq, nearly 64% of the coal in that particular rake

Before Crusher % 18 16 2 0 3 8 8

-

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After Crusher % 0 6

32 46 1 6

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would have been directly sent to the bunker without crushing. This not only saves the power consumption in the crusher but also increases coal crushing rate.

Therefore, it is recommended to carry out sieve analysis before crusher and to install a classifier t o separate fines or required size of the coal before feeding into the crusher.

In addition to this, sieve analysis has been conducted after coal mill. It is observed in the coal mill A that nearly 3.5% of the size of the coal lies above 50 mm and 67% of the size of the coal is less than -200mm and rest of the % size lies between -200mm and +50mm. Because of feeding higher size coal in the boiler, unburnts are coming out in the bottom and fly ash.

The discharge of higher size from the coal mill is mainly due to two reasons:

1. Inefficiency of coal mill 2. Receipt of higher size coal from the crusher

Both the issues are possible, therefore necessary measures needs to be carried out to maintain 100% size of the coal to be less than -200 mm.

Because of the unburnts in the ash, nearly 2% loss in the efficiency is observed. In addition, there is a subsequent loss in the power consumption in the coal mill. Therefore, it is highly recommended to install a classifier before crusher

to ensure 100% size of the coal to be less than the desired size for the boiler.

5.6.3.2 Install Smart Wall Blowing System for Optimizing Wall Blowing and Improving Heat Rate

The boiler performance including its ability to meet full load, auxiliary power consumption, net plant heat rate, availability of the unit, operation and maintenance cost etc. are significantly affected by the fuel characteristics. Coal firing in the furnace forms different kinds of deposits on the boiler tubes.

To improve the performance and thermal efficiency of the boiler, it is important to remove these deposits periodically and maintain a clean heating surface.

Boilers are designed such that the radiation and convective zone heat transfer surfaces absorb the released heat proportionately. Any deviation in heat transfer in radiation and convection zone will affect the function of feed water preheating in the economiser, steam super heating in LTSH, platen super heater and final super heater. This will result in reduction in boiler operating efficiency.

Smart wall blowing system (SWBS) is a selective wall blowing system, operating on auto mode. The operation is controlled based on super heater spray flow and furnace heat absorption at different zones. The system helps to maintain the furnace heat absorption at optimum level

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thereby maintaining the super heater and reheater sprays within limits.

5.6.3.2.1 Present Status

The conventional wall blowing systems are operated sequentially once in 8 hrs. All soot blowers will be operated 3 times a day.

In conventional blowing system, the furnace condition is not taken into consideration. The changes in fuel characteristics and boiler load are also not taken into account for controlling the soot blowing.

Periodical operation of the soot blowing system leads to significant variation in super heater and reheater spray. Soot blowing requires about 3.3 tons of steam per cycle.

In addition operating blowing system on a clean boiler tube surfaces leads to increase in erosion rate. This leads to increase in boiler tube failures.

5.6.3.2.2 Project Recommended:

SWBS consists of an electronic logic system interfaced with existing normal blowing system. The system consists of water wall heat flux sensors installed in between the wall blowers. The sensors have built in thermo couples.

The heat flux sensors are installed in between the wall blowers in four elevations. There are eight heat flux

sensors in each wall and totally 32 sensors are mounted on four sides of the water wall. The arrangement of heat flux sensor is shown in Figure - . The two ends of the sensors are exposed to the flame radiation and the stable cooling water side respectively. Sensors continuously give output proportional to the absorbed heat flux.

-. - .-

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The sensors are connected to the remote SWBS control panel positioned in the control room through transmitters. The SWBS control panel is connected to the conventional soot blowing system. It is an add on facility to the existing soot blowing system.

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FIGURE - 33: HEAT FLUX SENSOR

5.6.3.3 Operation of SWBS

The heat flux changes continuously depending upon the thickness and heat transfer properties of the deposits. The actual heat flux is measured continuously by the heat flux sensor and monitored with the dynamic set point.

The super heater spray requirement triggers the operation. The High and low SH sprays are set to desired values. The system either starts or stops the blowing sequence when

the spray crosses the highest / lowest set points respectively.

When there is a reduction in the heat flux below the dynamic set value of a particular sensor the adjacent two blowers are actuated automatically. The sequence of heat flux comparison with the set values and the blower by passing/ blowing continues in a sequential manner from wall to wall till the SH spray flow reaches the low set point.

The blowing operation resumes in auto mode when the SH spray flow crosses the high set point with a comparison of heat flux with the set point. The system maintains super heater spray flow within a narrow band.

The trend of super heater spray control with conventional blowing system and SWBS is shown in Figure -

Each blower operates once / twice or thrice in a day depending on the heat flux value. Blowers, which are not operated in the first two cycles, are operated compulsorily in the third cycle, irrespective of their heat flux value. Hence each blower operates atleast once in a day and avoids permanent adherence of the deposits on water wall surface.

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FIGURE - 34: SUPER HEATER SPRAY CONTROL WITH CONVENTIONAL BLOWING SYSTEM AND SWBS

. , a

? IME IN MINUTES

5.6.3.3.1 Benefits

Installation of SWBS results in following benefits.

Reduced variation in SH/RH spray. Hence steady SH / RH steam temperature. This results in improved efficiency of boiler and heat rate of overall cycle. Reduced superheated steam consumption due to reduced number of wall blowing.

The soot blower operation is reduces by about 55 - 60% compared to conventional wall blowing system.

Reduction in tube erosion due to selective and reduced steam blowing

5.6.3.3.2 Financial Analysis

Annual energy saving of Rs 52.50 Lakhs was achieved. The break up of savings achieved is as below.

RH spray reduction Rs 43.50 Lakhs Reduction in steam consumption - Rs 7.50 Lakhs Material saving due to reduction in erosion Rs 1.50 Lakhs

5.6.3.4 Introduction Of Super Cleaning Of Turbine Oil

5.6.3.4.1 Background

Lubrication oils are being used in various equipments, out of which turbine lubrication system is very important and critical application. Servo prime-46 of MIS. IOC make is used for turbine bearing lubrication and governing system. The major parameters of the lube oil like viscosity, moisture, and mechanical impurities, TAN etc. Are being maintained within limits, by inbuilt centrifuging and top-up.

However the oil in use picks up contamination from wearing parts and the wear debris further pass through the system and in turn generate more contaminants, which can be described as a self-escalating snow balling process.

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Smaller contaminant particles are larger in number than larger contaminant particles. Only these smaller particles can enter clearances and cause damage to mating parts.

The super-cleaning initiated to reduce wear tear of equipment components and increase the life of lubricating oil by keeping check on contamination by dedicating two units of electrostatic liquid cleaner -elc 1001p.

5.6.3.4.2 Present Status

The Filtration particle size of Duplex filter element & Main oil tank filter element is 3 7 pm and 250 pm respectively. This indicates that particles size up to 37 pm can onlybe filtered on line.

Turbine oil is supposed to maintain IS0 1119 to 13/10 level of cleanliness, which is equivalent to 'NAS 7' and below. However it was observed that NAS level of oil in use is 12+ with present on line cleaning system.

P The frequent chocking of Duplex Filter was noticed with the existing on line filtration & centrifuging system.

P The thick sludge of observed at the bottom of Main Oil Tank during overhauls.

P Governing problem faced resulting in two tripping of the unit.

P Scratching and scouring marks were observed on the turbine and generator bearings and journals during overhauls.

5.6.3.4.3 Project Recommended

Electrostatic Liquid cleaner-ELC-100LP is been recommended to each Main oil Tank (MOT) to super clean the Turbine oil. The oil supply is taken from MOT and outlet is connected back to MOT.

5.6.3.4.4 Principle of Operation Of Electrostatic Liquid Cleaner

€LC is an Electro static liquid cleaner and works similar to the principle of ESP (Electro Static Precipitator), Contaminants in oil such as magnetic / nonmagnetic, organic/ inorganic, resinous matter or sludge etc are either positively or negatively charged due to the contact potential difference with oil.

When oil is passed through an electric field, positively charged particles are drawn to the negative pole and vice versa. Neutral contaminants are drawn and deposited by gradient force to the edge of the die electric media where the intensity of the deformed electric field is highest.

When corrugated die electric media (collectors) are inserted between electrodes, the electric field is deformed and die electric polarisation occurs at the tips of the corrugation. The electric field is the strongest at the tips and particles are drawn and deposited on opposite electric poles and removed from oil.

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FIGURE - 35: WORKING PRINCIPLE

Page 98 of 210

5.6.3.4.5 Benefits

Two nos of ELC-100LP Machines are dedicated for the cleaninq of Turbine oil. The oil cleanliness level of NAS 7 has been maintained. This has resulted in following benefits.

Duplex Filter chocking has been reduced considerably. Loss of oil from the system has reduced due to reduced cleaning of Duplex Filter, there by less draining of oil from the filter. Average Oil consumption has been reduced to 76 barrels from 145 per year. Reduction in sludge formation at the bottom of Main Oil Tank. No Governing problems are faced due to chocking of governing components.

5.6.3.4.6 Cost Savlng Due To Saving In Spares (Turbine Bearings & Duplex Filter Strainer) and Oil

Conservation of oil and better environment due to lesser need for disposal of used oil. The reduction in oil consumption pattern is shown in the graph:

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FIGURE - 36: OIL CONSUMPTION PATTERN 5.6.4 ENVIRONMENT AND ENERGY

The mapping of the resources and emissions chart is given below:

Any resource efficiency assessment leads to increase in efficiency of the power plant and i t will have direct impact

200 on the environment. An exercise has been carried out to

U) 1 arrive at the impact of R&M activity over the environment.

i 150 1 The main objective of carrying out this exercise is to

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4 100 b p so

establish the month wise baseline emissions and what would have happened after the R&M activity. In order to arrive the same, the resources have been identified and emissions because of utilizing the resources have been

0 , calculated based on the data received, emissions measured 2000 2001 2002 2003 2004 2 0 0 5 ~ during the site visit and some assumptions.

lEAR i The following resources have been identified:

5.6.3.4.7 Financial Analysis 1. Coal 2. Light Diesel Oil

Installation of super cleaning system has resulted in many 3. Furnace oil tangible and intangible benefits. 4. Water

5. Chemicals for water treatment Total cost savinq of Rs. 71.96 Lakhs has been achieved .The break up of saving is as below. The major emissions from the plant are:

1. coz Cost savinq due to Turbine spares - Rs 38.00 Lakhs. 2. CO Cost saving due to reduction in oil top up - Rs 14.21 Lakhs. 3. SOX Cost saving due to tripping of unit due to chocking of 4. NOx governing components - Rs 19.75 Lakhs 5. SPM

6. Industrial effluents

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5.6.4.1 Monthly Baseline emissions

The following parameters have been calculated to establish the baseline emissions.

1. Efficiency of the plant : The efficiency of the plant have been calculated with the help of coal consumption, calorific value and electricity generation

2. C02 emissions: C02 emissions are calculated with the use of percent carbon and coal consumption

3. SOX emissions: SOX emissions are calculated with the use of SOX measured, Flue gas temperature (180 C), flue gas flow rate and Coal consumption

4. NOx emissions: NOx emissions are calculated with the use of NOx measured, Flue gas temperature (180 C),

Since the consumption Light Diesel Oil and Furnace oil is -

flue gas flow rate and Coal consumption

comparatively much lowerthan the consumption of coal the same has not been included in the calculation. 5. CO emissions: CO emissions are calculated with the use

of CO measured in PPM (18-21 ppm and 19.5 ppm is

The major water consumption areas in the power plant are assumed for calculation), flue qa; temperature .(180

coolinq towers, Boiler feed and ash (bottom ash) slurry C), flue gas flow rate and coal consumption

mixing. Since the make up water consumption in the coolinq tower and boiler feed are comparatively lesser than 6. SPM emissions: SPM emissions are calculated with the

the water being used for Ash slurry mixing, the water use of SPM measured in mq/m3, Ash % in coal, Ratio of

consumption cooling tower and boiler feed have not been Bottom ash to Fly ash (20:80), flue gas flow rate and

considered for calculations. Coal consumption

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7. Water consumption: It is assumed that in order to generated in the last financial year would be dispose one tonne of ash three tonnes of water shall be generated in the future. used.

For these above mentioned scenarios, coal consumption Based on the calculations, the graphs were drawn to and other emissions pattern have been calculated. The identify the pattern of the emissions in month wise. emissions pattern of the KTPS before R&M activity is given

below: It is assumed as well as anticipated that because of the R&M activity, there would increase or decrease in the FIGURE - 37: COz Emission Levels before R&M emissions based on the type of activities which would have carried out R&M. The following two scenarios have been identified and emissions patterns have been forecasted for the unit 6.

Scenario 1.

The scenario one possess has adopted two conditions:

1. If the efficiency of the unit 6 is increases by 1% after R&M activity.

2. If KTPS would operate the unit in such a manner so that the monthly maximum electricity that had been generated in the last financial year would be qenerated in the future.

Scenario 2

1. If the efficiency of the unit 6 is increases by 1% after R&M activity.

2. If KTPS would operate the unit in such a manner so that the monthly average electricity that had been

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FIGURE - 38: CO Emission Levels before R&M

FIGURE - 39: SPM Emission Levels before R&M

FIGURE - 40: SO2 Emission Levels before R&M

SPhl Emirsbns h hl l '

80.00 - 70.01) - 60.00 - 50.00 - 40.00 - 30.01) - 1U.UU - 10.00 - 0.IIU 7

FIGURE - 41: NOx Emission Levels before R&M

SO2 Emirrbrs in M 1

I

400 -

201)

150 I00 50 -

0 7

Apr.06 hla)-l16 .lun-06 .lul-06 Aug-l)6 Svp-06 Ocl-116 Yor-U6 Drc-U(, Jm-1)7 FcLU7 Msr-117

Month

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! NOX Enissiols in M I

Apr-06 May-06 JurtU6 JuI-06 AUK-06 Sep-06 Oct-U6 Yo>-06 Drc-U6 .Inn-07 F r M 7 hlnr-07

Month

50 - 45 - 35

3U

25

2U IS I 0

5 - 0 7

-_; Apr-06 May-06 Ju-06 Jul-U6 A u ~ - 0 b Sep-06 Ocr-06 Yor-06 Dec-06 Jan-117 Fch-07 hlnr-U7

Month

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FIGURE - 42: Water Consumption Levels before R&M

The following patterns show the emissions level after carrying out the R&M activity.

\Vslrr rnnvunptionn lor .ash S l u m Prppanrion in M T

FIGURE - 43: COZ Emission Levels after R&M

300U0 - 15000 - 10000 - 15000 - 10000 - 5000 0 i

FIGURE - 44: CO Emission Levels after R&M

.-'----r FIGURE - 45: SPM Emission Levels after R&M

Apr46 M a 4 6 Jun46 Jul-06 .\ue46 SepOh -146 Nn>dh Dcc4h Jan47 F e M 7 M d 7

Month

SPXl Enissionc in hlT

90.00 - 80.00 - 70.UU -

40.uv - 30.00 - 20.00 - 10.00 - 0.00 7 I

Apr-06 May-U6 Jun-06 Jul-06 .\up06 Sop46 Orl-06 Yov-06 Doc-06 Jan-07 Frb-07 Msr-U7

hlonlh

Accualrlectricily y c r r n l e d --c M n x l m m ckcrr lc i ly g c a o n a d A v c r q e r k r l r i r i l ) gemernled

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COz emissions

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Percent in emissions

-1 5 -1 0 -1 6

-5.725

9 10 1 1 12

Total

sox emissions

363.4 341.2 365.1

3658

SOX emissions with average electricity

generation Data not taken for calculation

308.8 305.5 306.8

3449

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SPM emissions with Percent in

Months e m k s h s average electricity emissions eneration

62.22 55.70 71.94 60.45

Total 62 1 585 -5.844

In nut shell, if the unit generates maintain average electricity that had been generated in the last financial year, there is an emission reduction of more than 5%.

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APPROACH FOROH&SASSESSMENT

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6.1 Safety Analysis 6.1.1. Safety Performance

FIGURE - 50: SAFETY PERFORMANCE OF KTPS PLANT (SOURCE: KTPS)

The performance of the plant with regard to safety has been analyzed for a five year period between 2002 and 2006. Table 35 provides a summary of the number of accidents and fatal accidents as against the total number of workers (permanent & contract) employed in the plant.

From Figure 50, it may be observed that the number of accidents has risen from 2002 to 2004. Since 2004, a declining trend has been observed in the number of accidents in spite of including minor accidents such as pin prick, sprained back or foot, slip on plain road. In the year 2006, the plant, on an average, witnessed one accident every second week.

TABLE - 35: SAFETY PERFORMANCE OF KTPS PLANT (SOURCE: KTPS)

0 lo 0 2002 2000 2004 BQ5 2305

Ymrr

-+ NumberofEnplops ('00) +Nuher of Acrldents i r N u ~ r o f f a t a l a o c ~ d e W

TABLE - 36: SAFETY STATISTICS OF KTPS PLANT (SOURCE: KTPS)

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0 --a, -2.c - 0 2.s 5 - =! m ID 3 9

ID E n - g - , + r c n ID 3 m q "": s n rr ID 5 q : ' O m 5 m c n s s 2 m m 3 3 = g

ID Z s o - n c = 5 C2.gzz 9 3 1 ~ 2 s

- 5 m - 0 ID - 5,- ID

=! 0 ID 5 ' 0 < -. < ID =! ID: yncn - Cr I. 5'Dgn m m m I D 5 g s = n z iT " 5. ;;; ClJg z0 - m O - 3 s 2 3-0 m ID I D I D c n n

8 m - . c n n z C N 0 3 I D

==I <g=!,,,cn P g m m - m m * n 3 8 " ~ ~ 3 % E E = m s m O n

-.=!6 o m g : z o - s 3 c n 0 - ID 0 p c n

-.ID 3 5n- -.ID 2.0 q c n g 2 cg5 ' m , O S 7 5 n s x 5 - 7 ^

UI 5 - 0 3 5

QnJEcn 7 m p g':-s;;gH - n

E 3 ID . 5 g $ g I D 3 o e m m e 2 2 - 0 C r s m 5.p 3 nsiTUI

u y = s E . q z 3 m o m 0 0 3 g 3 g s Q J P q-n-.. - < ' a - z = ! m e c r o < = c n p m < ID 3

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TABLE - 37: CAUSE-WISE ACCIDENT STATISTICS OF KTPS PLANT (SOURCE: KTPS)

6.2 Occupational Health & Safety System Recommendations

The following section details the observations made with regard to the existing OH&S system of the plant and recommendations suggested to improve the performance for each of those aspects.

Particular

Total No of Accidents Unsafe Act Unsafe Condition Combined Total Number of Unsafe Acts

6.2.1. Environment, Health and Safety (EHS) Policy

Background

2005

The EHS policy of the erstwhile MSEB has been displayed at multiple locations within the plant premises in English as well as local language.

2006 2002 No 29 15 9 5 20

The EHS policy should be updated and endorsed by the top management of MAHAGENCO as it conveys the commitment and attitude of the management towards ensuring safe and healthy work environment in the plant premises.

No 2 6 15 5 6 2 1

No 2 7

%

51.7 31.0 17.2 68.9

It was informed by KTPS that the EHS policy is being amended as per the requirement and same shall be part of the health and safety management once it is approved by the corporate EHS Unit.

%

57.7 19.2 23.1 80.7

% 2003

6.2.2. EHS Audit

No 33

2004

Observation The EHS policy makes a commitment towards carrying out annual audits for its EHS performance to determine

MAHAGENCO, has not revised the policy since the compliance with the policy. However, it was observed that restructuring of MSEB in 2004. the audits pertaining to the Health and Safety performance

% No 39 2 1 14 4 25

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%

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of the plant, as committed in the policy, are not being carried out on an annual basis. OH & S audit by an external agency has not been carried out since November / December 2002. The latest EHS internal audit was carried out in the September 2005 but the report is yet to be shared with KTPS personnel.

k Assess the likelihood of each of the hazardous situations occurring (Risk Assessment);

k Identify and effectively implement appropriate control measures to prevent the occurrence of such hazardous situations (Risk control); and finally

k Review measures continually to ensure their effectiveness

Recommendations Observation

OH&S audit should be carried out at the frequency committed in the policy. Regular audits would help in tracking and improving the performance of the existing OH & S system.

KTPS has conducted a Risk Analysis study at the plant and detailed action plan is prepared and implemented through OHSAS.

6.2.3 Hazard Identification & Risk Assessment Recommendations

Background

A hazard identification and risk assessment study helps an organization in identifying, evaluating and controlling of OH&S risks on an ongoing basis, hence contributing to making the work place safer. Hazard Identification, risk assessment and risk control processes are identified as key components of such a study. To effectively manage the health and safety of its employees, it is essential for an organization to:

k Identify any potentially hazardous situations (which may cause injury, illness or disease) in workplace on an ongoing basis (Hazard Identification 1;

While planning for control measures the Hierarchy of Control indicated in the Figure 5 1 below should be considered. Controls closer to the top of the hierarchy are preferable to those lower down the hierarchy such as PPE as they are less dependent on human behavior. Elimination should be given priority in controlling hazards, wherever possible and practical. Isolation and engineering controls should be next considered. Administrative controls and PPE may be useful in addition to other control methods.

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FIGURE - 51: HIERARCHY OF RISK CONTROL

I

ENGINEERING

LOSS.

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6.2.4. Personal Protective Equipment

Background

PPE are useful in eliminating and reducing injuries to workers due to hazards, which cannot be controlled adequately through other control methods such as elimination, substitution, and engineering.

Observations

PPE such as shoes, helmets, goggles, belts and masks have been provided to the workers in KTPS. The appropriateness and specification for the PPE to be used for performing various work activities is decided in consultation with the safety officer. The list of PPE t o be used in the plant is maintained with the safety department. The workers and contractors have been communicated about the type of PPE to be used based on the nature of the work activity. The safety department and sectional heads are reportedly responsible for ensuring that workers are provided and use appropriate PPE.

The management has initiated efforts for ensuring increased use of PPE by the workers by denying entry to workers without safety shoes and helmets. During the site visit, however, multiple workers were observed working without using basic PPE.

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Root Cause

Further investigation revealed the non-adherence to use of PPE is due to the following reasons:

P Discomfort (in carrying out certain tasks while wearing PPE)

P Lack of awareness of potential hazards and PPE to be used specific t o minimizing risk due t o those hazards

P Behavioral issues such as carelessness and lack of motivation -"A few workers indicated that they have been doing the same job for several years and do not require PPE"

P Efforts should be initiated to understand the negligence of the workers towards the usage of PPE. For effective use of the PPE, the first line supervisory personnel should also be imparted training and such personnel may be held accountable for effective use of the PPE. These supervisors need to set an example by wearing PPE themselves and ensure effective use of the PPE by others as well. Awards and recognition should complement on-going training and awareness programs.

6.2.5 Near Miss Incident Reportinq

Backqround Recommendations

P Selecting the right PPE requires careful evaluation of the hazards associated with each task being performed at KTPS. While performing Hazard Identification & Risk Assessment, individual employee tasks should be studied to determine the duration and frequency of the task, the degree of dexterity required and the worker's exposure to various hazards.

P Training and awareness program may be arranged for unskilled workers and contract labor on the hazards associated with regard to why, how, when and which PPE is to be used.

A near miss is an unplanned event that does not result in injury, illness, or damage - but has the potential t o do so. Near-miss reporting helps in tracking as well as correcting situations 1 circumstances that could potentially lead t o serious accidents.

Observation

KTPS has put in place a near miss incident reporting system. The same has been communicated t o various departments. KTPS is also taking steps to increase the workers participation in the system. The near miss incident reporting format has been provided as Annexure - V.

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6.2.6 Safety Committee

Background

KTPS has three numbers of apex safety committees i.e, one each for Stage-I, Stage-ll and CHP. Each safety committee is chaired by General Manager from the corresponding section and consists of management representative, workers representatives and safety monitors. There is a Sectional Safety Committee in the Maintenance Section. The workers' representatives are not nominated by the workers but are nominated by the Sectional Heads.

Safety department indicated that Minutes of safety committee meetings (MOMS) are circulated to all members of the committee and section heads, who in turn communicate the key safety decisions to the workers

Root Cause

P Further investigation revealed lack of interest from workers is due to behavioral issues such as lack of self-motivation.

P Further investigation revealed safety committee meetings and decisions could not reach all workers due to the following reasons:

1. Lack of direct representation of workers in safety committee meetings

2. Behavioral issues such as lack of motivation - Limited efforts from employees end to exchange safety related information communicated to them

3. Lack of contract labor representation in safety committee meetings

Recommendations Observations

P It was reported that the workers have not evinced interest in either being a member of the safety committee or in nominating a colleague for the membership to the safety committee.

P Some of the workers (including contract workers) indicated that that they are not aware of safety committee meetings and the decisions taken by the committee.

P The number of safety committee members, as compared to the number of workers is low and hence the communication of key safety initiatives, measures and interventions to all levels may be impeded. Appropriate number of sub-safety committees may be formed at departmental levels with the sub-safety committee heads representing those departments in the Safety Committee. The sub-safety committee representatives can be entrusted with the responsibility of facilitating communication between the management and the

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workers. Floor level safety meetings should also be institutionalized.

P Initiatives such as institutionalizing of a near miss incident reporting system, encouraging worker participation in safety management, accident investigation and training need identification can be driven through the sub-safety committees

P These committees may be extended to include contract labor representation. This may help communication of key safety decisions to contract laborers also.

P The formation of the sub-safety committees would also help in involvement of higher number of workers in the safety initiative of the plant

6.2.7 Safety & Fire Fighting Department

Manager (Stage-I). GM (Stage-I) reports to Chief General Manager.

Observations

No deviations from scheduled standard test and examination of fire service equipment and fire protection system were observed during the site visit. However, some deviations were noticed with reference to the recommendations by The Fire Advisor & Chief Fire Officer. The same are already been informed to and accepted / approved by the FA & CFO.

Root Cause

Reportedly, these deviations have been due to the shortage of manpower.

Background Recommendations

The structure of the safety and fire-fighting department has been provided as Figure - 4. The plant employs over 2000 workers in three shifts but has only one Safety Officer with two subordinates. Safety Management at the CHP is handled by an Executive Engineer who reports to the Safety Officer. Additionally, there are twelve members in the fire fighting department. Eight firemen are outsourced through an external agency.

Currently, the Safety Officer reports to the Superintendent Engineer (Operations), who in turn reports to General

Staff-strength of the safety and fire-fighting department may be increased for improving the efficiency and effectiveness of the safety department.

6.2.8. Housekeeping, Lighting and Ventilation

Observation

During the site visit, housekeeping, lighting and ventilation were observed to be poor in the plant for safe working of occupant, specifically in the CHP area. At the time of site

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visit, the dust suppression system and fresh air system in CHP were found to be out of order. Several gas cylinders were found t o be stored without caps.

Root Cause

P Some of the workers indicated that poor housekeeping, lighting and ventilation issues have been brought to the management's notice several times but have received a slow response from the management

P Behavioral issues such as thefts and negligence in housekeeping, are also being faced from the workers and contract labor with regard to maintaining the system

Recommendations

P Specific team comprising of individuals from each section could be formed for supervising proper housekeeping and ensuring lighting and ventilation systems are operational at all times.

P Measures such as training and awareness programs on good housekeeping practices, safety and health impacts of poor housekeeping, may help in addressing the behavioral aspects of workers.

6.2.9. Training

Background

In-house Annual Training Calendar indicating annual training & awareness programs schedule is maintained by the HRD. OH&S specific programs included in the annual calendar for the year 2007-08 are: Disaster Management Plan, Awareness about Heart Disease, Awareness about Hypertension, Stress Management, Awareness about Diabetes, Awareness about Asthama, Awareness about Occupational Diseases and Health, Use of Safety and Fire Fighting Equipment. The participants' profiles for these programs as indicated in the calendar consisted of Engineers, Chemist and Technicians. In addition, as informed, a few other safety specific training and awareness programs are conducted by the safety department on a need-basis.

It was also informed that the following activities have been taken up since the initial site visit for EA-DDA:

P 28 Employees were sent t o Koradi Training Center for training programme from 1 6 to 1 9 Oct 2007.

P About 8 0 employees and contract workers attended a seminar on 'Safety' held at Hotel Tuli International Nagpur on 16th and 17th Nov 2007.

It was also informed that the training for use of Portable Fire Extinguisher is imparted to staff at their location by

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Recommendations

Classification of diseases based on occupational exposure should be documented.

6.2.11. Rotation of Work and Minimisation of Exposure

Observations

Comprehensive procedures for administrative controls such as rotating employees and imparting trainings on performing tasks in ways that reduce exposure to work place hazards were not found in place. At present, rotation of work is only considered in cases where workers specifically request for it. It was informed that based on the medical condition and willingness of the worker, the doctor may recommend rotation of work for consideration by the top management. The final decision lies with the top management. However, no comprehensive documents with regard to the same were available.

It was informed that despite having medical problems, which may be aggravated due to occupational exposure, workers have not been keen on rotation of work. Reportedly, the workers have resisted attempts by the top management to transfer workers from one department to the other. Workers interviewed during the site visits have also indicated their preference to continue working in the same department.

Root Cause

Further investigation revealed workers resist such programs due to the following reasons:

P Reluctance in adapting to change P Unwilling for medical check-ups thinking that if

diagnosed with a disease, they may become unfit for the job

Recommendations

The workers and worker unions should be sensitized towards the need and benefits of rotation of work. A rotation of work policy could be framed and workers at the time of recruitment should be informed about the policy and the probability of inter departmental transfers.

6.2.12. Safety Drills

Observations

Safety 1 mock drills with regard to acid leak, chlorine leak, fire and Disaster Management Plan (DMP) are conducted periodically to check the preparedness of the emergency response system, records of which are being maintained by the safety department.

Observations and recommendations made during mock drill that required corrective measures have not been addressed promptly. For instance, a few observations that were

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recommended by the safety officer in August 2005 mock drill for chlorine leak were not addressed and have been carried over to February 2007 mock drill.

Further, it was observed the responsibility of implementing these observations was not clearly assigned to any individual. Also, no comprehensive documentation was found in place with reqard to action points 1 measures taken to address observations made during mock drills.

Recommendations

Observations made durinq mock drill, which require corrective measures, should be given priority and addressed immediately for improving the efficiency of the emergency preparedness and response. Specific individuals should be assigned the responsibility of ensuring these action points are addressed as and when identified. Action points taken and status of the observations requirinq corrective measures should be documented to keep track of the performance of the system.

spray system for cable galleries and boiler burners, high velocity water spray for main oil tanks, foam pouring system for fuel oil tanks, and fire alarm and smoke detection system.

Mobile facilities cover fire tender units and portable fire extinguishers. On receipt of information, fire fightinq staff on duty responds to the situation. Fire report forms are documented by the fire officer.

Fire drills are carried out periodically by fire fighting officer under the guidance of safety officer. List of fire fighting equipment is maintained by fire-fighting station in-charge. Fire fighting station in-charge is also responsible for inspection and testing of portable fire extinguisher.

Pumps, size of mains, no. of hydrants, hose pipes and medium velocity water spray system maintained with in the plant premises meet or exceed the minimum regulatory requirements. For Stage-l oil handling plant, foam pouring system has not been provided for storage tanks. Only fire hydrants and water monitors have been provided.

6.2.13. Fire Fighting System Observation

Background

The firefighting system in the plant consists of fixed installations and mobile facilities. Fixed installations consist of fire hydrant system, automatic high velocity water spray system (for oil storage tank and coal conveyors), manually operated medium velocity water

Frequent incidents of minor fire occurrences on turbine floor have been reported. Oil leakage and turbine heat were informed to be the prime causes for these incidents. However, the response times to such fire alarms were observed to be qood and the fire was brought under control within reasonable time during all such alarms raised. Fire

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extinguishers are being maintained as per the requirement. audit, a sample accident case was taken and suggestions Fire blankets are also reportedly due for replacement. were provided on how a RCA should be carried out and

provided to the safety department. The same is provided Recommendat ions below for reference.

9 Steps should be taken to address the recurrence of turbine floor fire incidences.

9 The planned schedule for standard testing and examination of fire fighting equipment should be strictly adhered to and on completion should be promptly updated

6.2.14. Accident Investigation

Observations

As discussed earlier, the number of accidents in the plant has shown a declining trend since 2004. However, the number of accidents occurring the plant may still be considered high as the plant on an average witnessed one accident every second week in the year 2006. Accidents are investigated and recorded. However, a comprehensive Root Cause Analysis (RCA) of all the accidents is not carried out.

Recommendations

A comprehensive Root Cause Analysis (RCA) by the Safety Department would help in identifying the root cause for the accident and placing systemic controls and for ensuring avoidance of similar mishaps in future. During the

Case Study:

An accident was reported at the CHP area during maintenance work which involved a contract worker. It was reported that the accident led to fracture of the lower leg and the patient was rushed to the hospital for further treatment.

The accident report reviewed during the audit showed that only the cause of the accident was reported along with the recommendations to avoid such accidents. However, no detailed RCA was carried out.

An RCA should be carried out in these lines:

k Was there a proper work permit for the work to be carried out

k Was the worker aware of the hazardous condition and was he trained for such maintenance work

k Is a SOP available for the maintenance work and was the worker aware of the procedures

k Was the supervisor available during the maintenance work?

k Was he provided with the appropriate PPE before entering the work and was the same checked by a supervisor

k Was the worker using the PPE during the work? k How often is such maintenance work carried out?

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Based on the outcome of the RCA, recommendations should be provided to prevent such accidents in future. The accident report has been provided as Annexure - 6 for reference.

6.2.15. Work Permit System

Background

The Work Permit is a formal written statement used to control certain type of potentially hazardous activities. It is also a means of communication between site management, supervisors, operators and the workers enabling co- ordination among various activities to ensure safe working environment. The Work Permit itself does not make the job safe, but helps in ensuring that proper consideration is given to the risks and that they are dealt with prior to commencement of the work. KTPS has instituted a Work Permit System for working in various hazardous workplaces in the plant including the CHP.

Observation

It was observed during documentation review that an instance of non-adherence to the Permit System by one of the workers had led to a fatal accident. A comprehensive RCA was not carried for the accident and impatience on the part of the worker was attributed as the reason for his non- adherence to the set operating procedure.

Recommendat ions

The workers should be sensitized about the importance of adhering to the Work Permit System. The first line supervisory personnel should also be held accountable for adherence to the system. Use of technology and better communication facilities, wherever possible, will help in expediting the process of obtaining the permit from the authorized personnel.

6.2.16. Standard Operating Procedures

Observation

It was informed that standard operating procedures (SOP) with regard to safe working conditions have been in place but were not made available with the exception of that for bunker scrapping. Reportedly, comprehensive standard operating procedures with regard to working from heights were not available.

Recommendat ions

SOPS for working from heights should be developed

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6.2.17. HAZMAT and Management

KTPS has part of the water treatment plant and hydrogen generation plant uses various chemicals such as listed below:

Chlorine Cylinders Caustic Soda Poly Aluminum Chloride Acids and Bases Hydrogen Cylinders

KTPS also stores fuel oils such as FO, LDO, lubricating oil which is used in the plant operations.

Chlorine and Hydrogen cylinders and fuel oils are considered t o be the most hazardous materials with a potential to cause damage both on-site and off-site. The quantities of the aforementioned chemicals and fuel oils and their storage areas are provided as Annexure - 8. KTPS has displayed the Material Safety Data Sheets at all the storage locations and has also prepared a Disaster Management Plan which identifies the potential risks due to storage of hazardous materials and the action plan to be taken during a disaster such as Chlorine Gas Leak, Explosion of Oil Tankers, etc. The DMP also identifies the key individuals responsible for the smooth implementation of DMP.

6.2.18. Emergency Management Plan 1 Disaster Management Plan

Observation

Emergency preparedness and response plan has been displayed a t several locations. Emergency telephone numbers have been displayed at several locations and have been tested on a random sample basis. During interviews with workers, the awareness on emergency telephone numbers and muster points was found t o be poor.

Recommendations

Measures should be adopted to increase awareness on emergency preparedness and response among employees and contract labor

6.2.19. Worker Awareness and Involvement

Observation

While the top management is ultimately accountable for health and safety issues the workers also play an important role in ensuring successful implementation of the EHS policy. It is important for all levels of employees t o understand the dangers existing in the workplace, build the right attitude, always maintain a 'safety first' approach and obey the rules.

The EHS policy recognizes awareness building through

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training and other means of communication as an important contribution towards the successful implementation of the safety policy.

A review of the accident statistics between the years 2004 and 2006 indicates that unsafe acts have been responsible for majority of the accidents. Although the number of accidents at KTPS has been declining since 2004, the number of accidents due to unsafe acts have not decreased.

I t has been understood through the interaction with the plant personnel and workers that the level of awareness and the degree of involvement of the workers in issues pertaining to safety is low

It was observed during the review of the areas pertaining to use of PPE, effectiveness of Work Permit Systems, worker involvement in Safety Committees, participation in safety drills and the Emergency Management Plan that the workers' involvement, co-operation and awareness with regards to safety related issues has been low. The workers have also shown resistance to health related programs such as rotation of work and minimization of exposure and have not participated in the plant's medical check up programs.

Recommendations

9 Measures should be taken to involve higher number of workers in the safety initiatives through

formation of safety sub committees or smaller safety groups.

9 Efforts should be made to institute programs which promote two way communications between the management and the workers. Such efforts may include organization of competition at unit level or departmental level, encouraging and inviting suggestions for improving working conditions in their individual workplaces.

9 Multidisciplinary team of workers evincing interest in safety initiatives may be formed and given intensive training inputs. These teams, post education and empowerment should be encouraged to drive safety initiatives in their respective departments.

9 The workers making a contribution towards safety initiative should be given due recognition. Such recognition may be provided at an individual, group and/or sectional level.

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7.2.1. System and Procedure for Budget Allocation

As per the legal procedure, all the budget allocations for individual plants, which are part of MAHAGENCO, are done by Maharashtra Electricity Regulatory Commission (MERC) . Individual plant first assesses the requirements of funds and prepares a budget for the financial year, which is to the HO. HO submits the total budget for all the power stations to MERC for approval. The total budget is finalised by MERC and the allotment of budget to the individual TPS is communicated to the plant by HO. Based on the allotted funds, the plant head, i.e. CGM, would again revisit the budget prepared and on the priority basis the funds are disbursed to each department / section (s). The final decision on the distribution of funds is taken by CGM.

For Eq: If the plant assesses the fund requirement as 100 crores and prepares a budget for the same. MERC may only allocate 80 crores. Based on the priority of the department /section (s) requirement, the budget is redrafted and funds are accordingly distributed.

Observations

P The final allocation of funds at the plant level is the decision of the CGM. Corporate EHS Unit has no hold on the fund allocation at the plant level for environmental management.

P There is no fixed percentage for fund allocation for Environmental Management Cell and is done based on the need assessment.

7.3 TRAINING

Training on the environmental management has been identified as one of the key performance indicators as part of the Environmental Management System (IS0 14001) at KTPS. All the staff members including the section heads . and regular employees are trained on environmental management including aspects, legal requirements and management system implementation.

Training calendar is prepared by the HR department for the entire year. The training calendar is circulated to the Superintendent Engineers (SE's) and General Managers (GM's) for the approval and finalization.

Upon receiving the approval, the training calendar is circulated to the respective Section Heads (SH's) of each department to nominate the participants as per the training needs and requirements.

Training needs are identified by the SH's for their employees and a list is sent to the HR department for the concerned training programme which has been prepared for the year. Training on environmental management is part of the induction training programme. Trainings are mostly provided in-house. The faculty members are the SHs / SEs.

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Feedback on the training sessions are taken from the respective SH's.

KTPS as part of the management system has circulated booklets on environmental policy and awareness to the educational institutions, industries and local governing bodies in the surrounding villages.

7.3.1. Observations

> MAHAGENCO has independent training department with two institutes situated at Nasik and Koradi to cater training needs of MAHAGENCO. The employees are also deputed for trainings outside the organization by MAHAGENCO HR Department.

> KTPS has started taking feed back on the training sessions from the people attending the training at the end of the training session following the comments made by E&Y in this regards during the course of the initial reports.

> The participants' profiles for these programmes as indicated in the calendar consist of Engineers, Chemist and Technicians (including unskilled labourers). No documentation was made available to validate if such trainings are imparted to, contract labors. However, documentation related to safety trainings for Contract Laborers are available.

7.3.2. Recommendations

> KTPS should invite experts from other plants (either belonging to MAHAGENCO or other state owned generation companies) for conducting training programmes along with in-house faculty. This would enhance the training module as well as improve the knowledge sharing process. HRD should also take initiatives to send plant personnel to external training programmes.

> Feedback on the training sessions is being taken from the people attending the training at the end of the training session. However, the feedback should be concealed and the same should be directly submitted to the HR department for further action.

7.4 MECHANISM FOR ADDRESSING PUBLIC CONCERNS

KTPS as part of their environmental management system has a written procedure to address the external communication on concerns / issues with respect to environmental performance or management of KTPS.

As per the procedure, the stakeholder with his concern / issue shall contact the SE (Co-ordination) at the CGM's office, who upon receiving the stakeholders comments would direct the person to the concerned department / section of the plant to get appropriate reply.

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Environmental Audit 8 Due Diligence Assessment ~ e ~ 0 r - t

If the stakeholder requested the plant to provide any information within the purview of the Riqht To Information (RTI) Act, an application shall be deposited with the SE (Co-ordination) who would collected the information from the concerned department and submit to the stakeholder.

Stakeholder can also write letters directly to the CGM's office to qet information from the plant on the concerns raised.

7.4.1. Observations

P Durinq the stakeholder consultation process, the qram sarpanch (villaqe head) of Koradi villaqe informed that their office does not have the proper quidancel information as to whom to approach within the KTPS to communicate the view or concerns of the villaqers. It was also informed that the lack of knowledqe leads them to raise their issues with the local elected member of the Leqislature who in turn communicates the same with the plant.

P It was informed by KTPS that a Public Relations Officer (PRO) has been appointed and same was communicated to the villaqers so that they can meet the PRO to put forth their qrievances. A board has also been displayed at the entrance of the plant reqardinq the same.

7.4.2. Recommendations

P KTPS should also inform the villaqe panchayat office the procedure for lodqinq written complaints with KTPS or the concerned authorities responsible for environmental manaqement.

> KTPS may also provide a drop box at the entrance (near security cabin), which is easily accessible by the local residents. It will be used to submit concerns in writinq. The drop box would be under the jurisdiction of PRO of KTPS.

Page 134 of 210

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However, the resident of Mhasala village, which is located adjacent to the Khasara ash bund, indicated that during summer, due to scarcity of potable water they are forced to drink the river water which has ash supernatant.

It was also informed during the interview that diseases such as Jaundice, Diahorrea and Dysentery were prevalent in the area. This was due to non availability of potable water during summer season. The residents of Naanda and Mhasala interviewed during the visit indicated that there were no dispensaries in their village and they either visited the neighboring villages or travelled t o Naqpur for accessing medical facilities. Residents of the other villages also indicated that they visited Nagpur city for the treatment of major ailments.

In order to cross check the interviewees comments, the water quality of ground water and surface water was sampled and tested. Ground water sample was collected from Mashala village on the downstream of the ash pond at Khasara. Surface water samples were collected from water bodies receiving ETP discharge and ash pond discharge near railway station. The details of the analysis are provided as Table - 38.

The surface water analyzed was compared with the drinking water standard IS32296 Class 'C' Limits for any variations. It was observed that the surface water drains were meeting the prescribed standards and all the parameters monitored were found to be well within the limits.

Ground water sample was analyzed and compared with the IS : 10500 Limit. The ground water sample showed that the turbidity was 3 2 NTU as against the standard of 5 NTU with a relaxation up to 1 0 NTU. Sulphates was recorded as 449 mq/l which was found to be higher than the prescribed limit of 400 mq/l. Fluoride was recorded as 1.29 mg/l which was higher than 1 mq/l but less than the 1.5 mq/l which is the permissible limit. Nitrate content in the water was recorded as 7.5 mg/l.

8.1.3. Air Pollution

None of the other residents interviewed indicated any problems on account of air pollution.

8.1.4. Community Engagement

In order to qauge the effectiveness of the interaction with the community by KTPS, a sample number of villagers were interviewed during the audit. During the interview, the sarpanch (head of the village) was also interviewed.

During the interaction it was mentioned by the sarpanch that KTPS does not have in place a structured process t o engage with the community. It was also informed during the interview that the village panchayat is not aware of a concerned person whom they can approach for assistance with issues related t o the community and KTPS.

In order to substantiate the claim, officials from KTPS were interview, who informed that a Public Relations Officer

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TABLE - 38 : SURFACE WATER ANALYSIS

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TABLE - 39: GROUND WATER ANALYSIS

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.- --

Page 141 of 21 0 =ERNST& ~OUNC' C&alitvln F~wythiag W LYa

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Environmental Audit & Due Diligence Assessment Report

8.2 MERCURY (Hg) MASS BALANCE

As part of the overall risk and liability assessment, Hg mass balance was carried to gauge the risk to the community due to the presence of Hq in the environment.

The main source of mercury at KTPS is the raw material 'coal'. After the coal is fed into the boiler, Hg is released into the environment in the form of air emissions, trade effluent and bottom and fly ash. A schematic Diagram of the flow of Hg in the system is presented in Annexure - II.

At KTPS, the bottom and fly ash are mixed with the treated trade effluent prepare ash slurry. The ash slurry thus formed in sent to the Booster Pump House (BPH) from where it is sent to the ash pond. The supernatant from the ash pond is collected in the Ash Water Recovery (AWR) unit which is then pumped back into the plant to use for ash slurry preparation along with treated effluent.

In order to carry out a mass balance of Hg at KTPS, and considering the aforementioned cycle of Hg, samples were collected for analysis.

consecutive days i.e. 2nd January 2008 to 4th January 2008. The analysis report showed that the average Hg content in coal was 0.81 mglkg for stage - I and 0.83 mglkg for stage - II.

Coal after burning is converted into ash. Bottom ash and fly ash samples were collected and analyzed for Hg content. The average Hg content in bottom ash was 0.40 and 0.48 mglkg in stage - I and stage - II respectively. The average Hg content in fly ash was 0.38 & 0.33 mglkg in stage - I and stage - II respectively.

The Table - 40 below provides the total Hg balance.

TABLE -40 : Hg Balance

8.2.1. Analysis for Hg 8.2.2. Recommendations

Coal, being the source of Hg, was analyzed. Bunkered coal > KTPS to continue monitoring of Hg in air emissions was collected and analysis was carried out which showed and ash (both bottom and fly ash) to estimate the that there was presence of Hg in coal being used by KTPS. quantity of Hg not being accounted and take further Bunkered coal was collected from both the stages of the action to reduce the impact of Hg on the plant i.e. I & II separately and analyzed for three environment.

Unaccounted

0.03 0.03

Page 142 of 210

Stage

1 11

Input

Coal

0.81 0.83

Output

Total

0.78 0.80

Fly Ash

0.38 0.33

Bottom Ash

0.40 0.48

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PART 9: ENVIRONMENTAL HEALTH & SAFETY MANAGEMENT ACTION PLAN

This part of the report consolidates the analysis of EHS issues and recommendations of EADD in the form of EHS Management Action Plan (EMAP). The EMAP includes brief on EHS issues, agreed mitigation measures with Koradi TPSIMAHAGENCO, estimated cost for implementation of the mitigation measure, and the implementation schedule of each measure. For ease of implementation, the EMAP is segregated in to three levels of actions, including: (a) mitigation measures to be implemented as part of R&M activities for the 6th Unit (210 MW); (b) measures proposed to be integrated as part of Institutional strengthening and capacity building for Koradi TPS; and (c) measures to be taken up by Koradi TPS for the power station as a whole. The EMAP has explicitly integrated the action plans committed by Koradi TPS to Maharashtra Pollution Control Board (MPCB) for complying with the conditions of "Consent to Operate". The EMAP also specifies the environmental monitoring requirements (including monitoring specified by MPCB) and the reporting mechanism. The final EADD, including EMAP has been disclosed for public by MAHAGENCO at their corporate office in Mumbai and on their website, and at Koradi TPS.

In case of 6th Unit, the proposed measures will be integrated as part of the R&M design specifications and the costing. In this regard, it is important to highlight that certain measures such as choice of pollution control

options will be confirmed as part of the design configuration of R&M activities (especially considering the operational difficulties of current arrangement of combination of ESP and bag filters).

The proposed measures for institutional strengthening and capacity building, and measures for overall station level improvements are focused to: (a) enhance overall environmental performance and thereby minimize potential environmental risks and liabilities; (b) achieve 100% regulatory compliance; and (c) achieve better performance on Occupation Health and Safety aspects.

The Table below provides the EMAP details.

- -

Page 143 of 21 0 #ERNST& YOU& UolliV kJ €mything I&! iro

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Page 144 of 21 0 HERNST& YOUNG C,@alityln Fwrytbing W Da

Time Frame

Environmental Management Measures to be Integrated as Part of R&M Deslgns/Activltks for Unit - 6, Koradl Thermal Power Station

Estimated Cost (Rs.

Mil.)*

Sr. No.

Coterminous with implementat ion of R&M activities

- As Above -

- As ~ b o v c

,

1

2

3

,

Environmental Issue (EADD analysis reference in pranthesi~)~

Agreed Mitigation Measure

250.00 ( incaseof Swith:",g,z'erto

40.00 ( incaseof

Design Specs. to

be conf,,.,,,ed

10.00 (Design

Specs. and cost to be

confirmed) 2.50 ( to be

confirmed as part of design

, soecs.)

Particulate emissions from the Unit VI of the plant are above the prescribed standards as the current pollution control system of combination of ESP and Bag filters is not efficient (Ref No. 4.3)

KTPS currently employs a soot blower system for soot removal which is not energy efficient. (Ref No. 5.2)

No oil cleaning system has been employed at the plant resulting in deposition of small particle contaminants into clearances in the turbine and causing damage t o the mating parts (Ref No. 5.2)

P Pollution Control measures for Unit - 6 ESP t o be either retrofitted by moving to either complete ESP system or maintain the current combination of ESP + Bag filters with necessary Operation and maintenance mechanism t o achieve design PM emission standard of 100 mg/Nm3 but not exceeding 150 mg/Nm3.. As may be applicable, these measures shall explicitly consider current MPCB consent conditions.

P Ammonia injection in ESP to use as additional PM control measure

Above measures t o be reconfirmed as part of design details for the R&M activities P A Smart wall blowing system, is t o be installed to

maintain the furnace heat absorption at optimum level thereby maintaining the super heater and reheater sprays within limits, helping in conservation of energy

P A Turbine oil super cleaning system is to be introduced t o reduce chocking of governing components.

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-0 r c n 5 t 8 (

$JZ"- a 22;

g z m L a x

a ' " ' > z z s m g z ai > U,.;

0 , L Cn o P O m g .g 2 m c &.I- U s- .E g a n o .- n o n

VI VI '- C at, 2 c 5 = 2 3 - 3 Q C O u ggz; " 2 "2 a=:?

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I k Use of dust suppressants/chemicaIs as part of water I O&M Costs I March, 2009 1

Buyers t o incur cost as

Per

Continuous Ambient Air Quality Monitoring (CAAQMS) complying with consent conditions of MPCB (Ref. No. 3.3)

Compliance with utilization with dry fly ash as per Fly Ash Utilization Notification, April 3, 2007 is not achieved. (Ref. No. 4.4).

CAAQMS by March 2009.

AAQM to

sprinkling to retain moisture during summer season. Feasibility t o be ascertained by KTPS

KTPS has placed Work order with Enviro Tech Pvt. Ltd., New Delhi for installation, testing, commissioning of CAAQMS. Till such time, KTPS t o continue AAQM complying with NAAQS k KTPS to comply with Flyash notification

requirements through relevant agreements with cement manufacturers by entering in t o relevant

continue June 2009

Currently water consumption is assessed I Water flow meters are to be installed at all major inlet I 7.02

Compliance with this requirement is also one of the consent conditions of MPCB

based on pumps capacities. Thus there is no and outlet points. The points where the flow meters are precise mechanism to assess water balance t o be installed are detailed in Plate-ll B of the EADD

offtake agreements. k Establishing dry ash silo scroew conveyer system in

Unit-3 P Awareness generation in villages around KTPS for

utilization of fly ash for different purposes

and there by limited opportunity for efficiency improvements in water savings. MPCB consent condition for installation of flow meters for monitoring plant water

December 1

agreements 1.00

Cost by KTPS

report. KTPS has already placed work orders: (a) KTPS/PUR/2008-o~/ I&c-I I /z~~ dt. Sept 04. 2008; and (b) KTPS/PUR/Z008-09/l&C-II/3911dtd. Sept 29.2008

balance under Water (Prevention and Control) Act, 1974 (Ref. No. 3.3). Water discharqes from Khasara Ash pond is partly recycled and partly discharged in to stream, causing pollution in monsoon season. Further, the bund overflows and failure of slurry pipelines causes pollution of local streams. Similarly, CHP toe drain discharqes are causing pollution (Ref. No.

Page 147 of 21 0

May 2009

Ongoing and continual

k The ongoing works for raising Khasara Ash bund will be completed on priority

k Replacement of couplings by welding of the joints t o be completed on priority

k Further, maintenance of the pipelines to be made effective based on the completed study on "Slurry Thikness"

Costs already budgeted and

under implementatio

n

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4.5). Referred water pollution abatement is also one of the MPCB consent conditions (Ref. No. 4.5)

P KTPS issued work order ( K T P S / C ~ V ~ I . ~ G / O ~ ~ / W R - ~ ~ dtd.

08/26/08) for rearranging of stone filters percolation wells and bund drains

P Ongoing work for recovery of CHP toe drain as well as Booster Pumping House (BPH) to ash water

I I preparation and/or any other plant housekeeping I n due by KTPS I

recovery scheme and subsequent reuse through settling tank t o be completed on priority ( ~ e f :

KTPS/Civi1.02G/Oll/PUR-5642/W0/498/7381 dtd. 09/15/08) P The current water recycling to be extended for rest

of the discharges from ash pond for ash slurry

The Raw Water from Pench Dam is conveyed t o Intake Pond N0.3 through open channel. This results on higher levels of chlorides leading to higher chemical consumption for treatment in WTP-I and II.

Estimates and implementatio

purposes In view of the EADD analysis and preliminary feasibility, KTPS has agreed to for the option of construction of a separate pipeline from Pench Dam to the Raw Water Pumping (RWP) sump. Detailed feasibility of this option will be established and implemented by KTPS

resulting in high chemical consumption for

(Ref No. 4.6) Intake pond No. 3 is infested with aquatic weed and high organic load and turbidity

water treatment (Ref. No. 4.6) .

Disposal of Hazardous Waste (Ref. No.

Capital investment for cleaning of Pond No. 3 and securing bunds with subsequent measures to establish regular cleaning mechanism I Based on MPCB consent conditions and EADD observations, KTPS has made an agreement with MIS V EPL, Nagpur for Hazardous waste disposal at Common Hazardous Waste Treatment Storage and Disposal Facility (CHWTSDF) located at Buttibori. The

Cost has been budgeted and incurred by

KTPS

January 2009

Annual Occupation Health and Safety (OHS) internal audits as per EHS policy are currently not conducted (Ref. No. 6.2)

Only Annual medical checkups are conducted for workers as against biannual

January 2009

January 2010

arrangement is valid up to 07/25/2012 Mandatory Annual OHS audit as committed in EHS policy to be complied by KTPS regularly on Annual basis

Regular biannual medical checkups for permanent as well as contract workers complying with the

-- December

2010

Internal Audit -cost

internalized - OHS function

3.2 (Annum)

August 2009

Compliance Review by

Envt. Cell of KTPS on Monthly

basis First OHS audit by

March 2009

First compliance

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checkups as per Maharastra Factories Rules. Also the checkups are not conducted for contract labour (Ref. No. 3.3.) Poor housekeeping, lighting and ventilation in the plant (Ref. No. 6.2)

Maharashtra Factories Rules

Adoption of good practices especially housekeeping, ------------- lighting in CHP area; and ventilation and lighting facilities in the plant area, complying with the factories 1 act

*Estimates are subject t o review by design consultant

by March 20091 basis

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Page 151 of 21 0

S. No.

1 2

3

4

5

6 7

8 9

10

11

No. of Samples

5 5

4

2

2

1 2

1

5

2

Environmental Attr ibute

Stack Emission Ambient Air Quality

Process Effluent

Treated Process Effluent

Sewage Effluent from Plant and Colony

Treated Sewage Surface Water Quality

Ground Water Source Noise

Ambient Noise

Coal Quality

Location Details

Stack 2, 3, 5 ,6 & 7 (1&4 not operational) Time Office Stage - 2 Club - 2 Railway Siding STP - Colony KTC Koradi Condenser Cooling Cooling tower blow down Boiler blow down Ash Slurry BPH ETP Outlet Ash Pond Overflow Plant Colony

STP Outlet Ash Pond Discharge (Rly. Station) Water body receiving STP/ETP Discharge

Borewell at Mashala Villaqe near GP School Generator Noise DG Sets (1- 5) TF (1 & 2) Stage 1 Gate Stage 2 Gate Hospital Commercial Complex Shivaji Naqar Bunkered Coal (Stage 1&2)

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Unit - 1 (105 MW):

During the review of the monthly data for Unit 1, i t was found that the stack emission were within the prescribed norms over a period of 4 years. However, during June 2004-05, the SPM level in the stack emission was recorded as 170 mg/Nm3 and a second highest level was recorded during March 2005-06 which was 151 mg/Nm3.

NOx emissions were also recorded to be with in the prescribed limit of 150 PPM.

Figures 2 and 3 show the trend in the stack emission of Unit 1 for the year 2003-04 to 2006-07. The unit was shut down during July - Auqust 2003-04 and Auqust 2004-05.

FIGURE - 2: STACK EMISSION (SPM) - UNIT 1

PM Emission (Unit I)

;i 180 160 f 140

m 120 200445

g loo r 80

60 0 200647

5 40 x Standard

FIGURE - 3: STACK EMISSION (NOXI - UNIT 1

-.

NOx Emission (Unit 1) 1 - P m 3 60 x 40 g 20 --n+ Standard

0

I Months

Unit - 2 (105 MW):

Particulate Matter (PM) emission of Unit - 2 was found to be within the prescribed norm except for the months of August 2004-05 and October 2006-07 where the PM was recorded as 159 and 161 mg/Nm3 respectively.

NOx emissions for Unit 2 were within the limit of 150 PPM.

Figures 4 and 5 show the trend in the stack emission of Unit 2 for the year 2003-04 to 2006-07. The unit was shit down during January - March 2004, September to November 2005 and February - March 2006.

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Unit - 5 (200 M W ) : FIGURE - 10: STACK EMISSION (PM) - UNlT 5

Particulate Matter (PM) emission of Unit - 5 was found to be higher than the statutory limit of 150 mgINm3. During r PM Emissions (Unit 5)

the 2003-04 and 2004-05 the PM emksions were at the peak and the emissions ranged between 400 and 700 mgINm3. The emissions were 4 to 5 times higher than the prescribed limit. The unit went through a shutdown period of 7 months starting from December 2004-05 till June 2005-06. The emission level recorded after this period was found to be within the prescribed limit.

The PM levels were found to be less than 100 mg/Nm3 which is also the prescribed limit according to PPAH. The high levels of particulate matter during the years 2003-04 and 2004-05 is due to non functioning of the ESP. During the 7 months shut down period, KTPS had installed the bag filter in addition to the existing ESP for Unit - 5. This contributed in the reduction of the PM emissions from the unit.

SO2 emissions were also found to be within the prescribed limit. NOx emissions for Unit 5 were also found to be within the prescribed limit.

FIGURE - 11: STACK EMISSION (NOx) - UNlT 5

I NOx Ernission (Unit 5) I

Months

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Unit - 6 (210 MW):

Unit - 6 of the KTPS has been chosen for the R&M. Therefore, special emphasis has been laid to review the existing data for Unit - 6 of the plant.

Review of the data on stack emission for Particulate Matter (PM) of Unit - 6 has shown that the PM emission has increased from February 2003 till June 2005. The highest during this period was recorded in June 2005 when the PM level went has high as 549 mg/Nm3. During the year 2004- 05, the PM emission level was recorded in the range of 180 to 220 mq/Nm3 which was higher than the limit of 150 mg/Nm3. The PM level decreased after a shutdown period of July 2005. The highest PM level recorded after this period was in the month of October 2006.

The decrease in the PM emission of Unit - 6 is attributed to the partial replacement of bag filters during the shut down period.

SO2 emissions were also found to be within the prescribed limit. NOx emissions for Unit 6 across the years for which the data was reviewed showed that the emission levels were within the prescribed limit of 150 PPM.

Figures 12 and 13 shows the trend in the stack emission of Unit 6 for the year 2003-04 to 2006-07.

FIGURE - 12: STACK EMISSION (PM) - UNlT 6

1 PM Emissions (Unit 6)

I Months

FIGURE - 13: STACK EMISSION (NOx) - UNlT 6

r NOx Emission (Unit 6)

l Months

Page 157 of 21 0

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Unit - 7 (21 0 M W ) :

Particulate Matter (PM) emission of Unit - 7 recorded the highest emission level compared to any other unit within KTPS. The PM emission level from the year 2003-04 to 2006-07 was found to be in the range of 304 to 1001 mglNm3 with the highest being recorded in the month of June 2005 and the lowest in the month of May 2006.

The high level of PM emissions is attributed to the inefficiency of the existing ESP for the Unit. At present, the ESP has 20 fields and all the twenty fields are operated during the unit operation. However, due to high ash content in the coal procured from local a colliery (which is about 35 - 38%), the particulate matter emission, is high. The present ESP is not capable to handling such high particulate matter emission. KTPS has requested the state pollution control board to relax the norms for this particular unit till 2008 after which KTPS is planning to changelmodify the existing ESP.

NOx emissions for Unit 7 are within the limit of 150 PPM.

Figures 1 4 and 15 shows the trend in the stack emission of Unit 7 for the year 2003-04 to 2006-07.

FIGURE - 14: STACK EMISSION (PM) - UNlT 7

PM Emissions (Unit 7)

Months

FIGURE - 15: STACK EMISSION (NOx) - UNlT 7

r NOx Emission (Unit 7)

I Months

Page 158 of 210 W€UNST& You& Walitvln hwythhg W Do

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ANNEXURE - 111

ETP and STP (Waste Water Analysis)

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yodau Juawssassv ama6!l!a ana 3 l!pnv IeJuawuoA!Au3

L 9 S P E Z 1

ON *S

03 > S'EZ O'E 91 E O'P 8 Z

P'L WIWO d ls

0.5 E'S E 0'6 89E 6

0 € E'L

A U O ~ O ~

O'OP E'SZE O'P PZE E T 9 Z Z'L

aue~d

I/~'"J I / ~ W

1/6w l/bw l/bw

3 0

won

aoa a03

aseaJ9lg I!O 2008T W sP!los PaAloss!P l e W l

2OSOT l e sP!loS ~ a ~ u a d s n S a ~ n q e ~ a d u a l

H d s~aaawered Jsak

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ANNEXURE - IV

Data analyzed during REA

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Historic Analysis for the Year 2006-07

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UNIT VI - THERMAL EFFICIENCY OF BOILER

steam (assumed it saturated) into t

Page 165 of 21 0

heater

Thermal energy transfer from Flue gas to the steam Percentage heat addition in superheater

1307

11.88

kJ/kg of coal

%

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I [an4 u! a~nas!our oa anp ssoi I

3 )I by / l e3~ 2

6 9 ~ LtrZTtr6LSZ'O

ST

- %

leo3 10 ~ J Y / ~ Y

3 3

n by/ry

yodaa juaussassv a9ua6!l!a ana rg ypnv leluauuoJ!Au3

a~nqe~adwaq seb an l j Pawnsse se6 an14 40 d 3

lan j u! a~nqs!oyy

%

40 by/f y

3

3

leo3 40

seb an14 A J ~ aqq lo ~ q b ! a ~

seb an11 03 anp $so1 3eaH

tE'9

ESZT8S'OEOT

81 691 8 0 ' ~

seb anld u! ssol Ab~aug

seb anld Ul SSOl Ab~aua leUlJar(1

a~nqe~adwaq quajqwy seb an14 lo a~nqe~adwaq q!x3

pawnsse seb anll lo d3

2 s ' ~

Lg'LZ8

E8Z

8EZ

~as!urouoaa u! u o l ~ p p e Wall a beaua3~ad

Ab~aua IeurJaq? u! JalsueJl

~ a q e ~ paa j 40 a ~ n ~ e ~ a d w a q qalqno

~ a q e ~ paa j 40 a~nqe~adwaq qalui

seb

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percent in coal ~ :%:in

Heat loss due to hydrogen in fuel

Ratio of w I Bottom to

Flv ash 1 20:80

% kcal lkg K C C

kcal lkg of coal %

Hydrogen in Fuel Cp of flue gas assumed

Flue gas temperature Ambient dry bulb temperature GCV of coal

Loss due to Hydrogen

kg of Ash / 100 kg of coal

3.655 0.257941247

169 28

3881

5.26

kg of C / 100 kg of bottom ash

kJ/kq of carbon

kg of Carbonlkg of coal

I kg of Carbon Unburnt carbon Heat value by burning of 1 kg of carbon Loss due t o bottom ash

kJ/kg of coal I

33820

0.00398061

135

1.22

Page 167 of 21 0

Unburnt losses in Fly ash Ash percent in coal Unburnt carbon in

32.05

0.96

kg of Ash / 100 kg of coal

kg of C / 100 kg of fly ash

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Fly ash Ratio of Bottom to Fly ash I kg of Carbon Unburnt carbon Heat value by burning of 1 kg of carbon Loss due to f ly ash

Heat loss due to partial conversion of C to CO

--

Page 168 of 210

20:80

33820

0.00246144

83

0.76

Heat losses in bottom ash

kJ/kg of carbon

kg of Carbonlkg of coal

kJ/kg of coal

%

PPm kg/h kCal/h kCal/h %

CO % in f lue gas Mass f low ra te of fuel Loss due to CO Heat input Loss due to CO in %

REHEATERS AND CONDENSERS

Cp of Silica Temperature of the ash Ambient temperature Heat loss Heat loss %

21.00 143000 482978 554983000 0.087

kg of Ash / 100 kg of coal

kg of ash/ kg of coal

Ash percent in coal Ratio of Bottom t o Fly ash

Bottom l ~ a r a m e t ers hlalues lunit I

32.05

20:80 0.0641

0.5

1400 28

43.97 1.13

kcallkg C

C C kca l lkg of coal %

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per kq of coal

reheater 21.7

-

Page 169 of 210 ERNS ST& YOUNU wal$h Fmy(bn# W Do

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REGENERATION The calculation is carried out based on the data made available during the visit

Effectivness of the condenser Maximum possible effectiveness

Feed water flow rate Net heat taken away by feed water

Extracted steam 76.52 TPH

58.6 70

Page 170 of 21 0

%

%

Feed water flow rate Net heat taken away by feed water Therefore steam flow rate Extracted steam Total HP extraction quantity

184.1667

11566.59

5.46

19.67

2797

kgls

kW kqls TPH

kJ/kg

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OVERALL EFFICIENCY

TURBINE EFFICIENCY

Page 171 of 21 0

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THEORlTlCAL AIR REQUIREMENT AND FG ANALYSIS

32.045 Total

gas in at 17 MW

1100 I I % by I Molecular I kmol 1 kmol of 0 2 1 I weight I weight ( 1 required for 1

complete

Page 172 of 210

C H

38.86 3.655

12 2

3.238333 1.8275

combustion 3.238333333 0.91375

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0 8.715 - Excess air supplied 1.53 kg of air / kg of Moisture 15 - coal Ash 32.05

I Total 1 100.0 1 (LUE GAS ANALYSIS

Molecular Weight F h T -

--

Weight 23.2 kmol flue gas 31.23

Quantity of generated

b u a n t i t y of flue*6.77 1 kg of air / kg of I coal

m v e 5.77 kg of air / kg of supplied coal Excess air percent 26.5 kg of air / kg of

coal

Page 173 of 21 0

Thereoritical air required

4.24 kg of air / kg of coal

OPERATIONAL DATA given from the plant personnel

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BOILER SURFACE TEMPERATURE in OC

Range of the cooling tower Approach Effectiveness

-

Page 174 of 21 0 m % N s ~ & YOUIVC' Wrlityh Ftwythkg Mk Do

6 14 30

C C %

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STEAM EXTRACTION

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Page 176 of 210

150

120 Feed Water Inlet Press. Feed Water out let Press.

Kg/cm2

Kq/cm2

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Flue Gas Analysis (used for calculating emissions)

Page 178 of 210

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- -

Environmental Audit & Due Diligence Assessment Report

Before R&M - Efficiency of Power Plant and Emission Levels

Page 179 of 21 0

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After R&M - Efficiency of Power Plant and Emission Levels

Page 180 of 210

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Ref, NE. - ICTFS:CSM

Dl- SEC-TIi>N l ~ < : t I A R C . l 7 _ ! -- ; 1 Itua.71e cf +ECTICN I - i ! 2 i'3are 8 .@-our ot Near 4Xiss

li~c.cel3t. 3 IAdcraui ol ~rerni6er where Npar

IUIISS ? i c i i l w r f i tlappcmrti

. . j-. . .. i

urhe iw N=sr M%se 'nriasnr

5 N a m e of per6011 w a L e s f i n c i I experienced the Near Kss Incjdent. I

, 'FLII b13me in Capitals 1 Desigration sed.iun -- ]Aee I I i

--

Page 182 of 210 M€RN~T& YOUNG

wality &I F~f lb iag W DO

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2 .

a* . '

U N M C D I ( D I 1 ~ - ur- I . L Y Y W I L . (

- . - IUWS>X COTI2J4t !G-,

u r e m P ~ T C P . - n c m ~ z a s ~ ~ ~ u ~ ~ r i - ~ - ' - . . Y P ~ C W ~ CYIU~O d..- - t . V L l * lC..LLL IW-l'rr

- Y m m - : I P - E . I . --" LU.JCi CaTEI

.- . . - .I

YvP-eP muas - - UYECI*E. L C O ~ R Lxrr+b.a P~.W:LLCIIP.U~ CYiClvi-02,s

3 . .

~u imcnc -.P:S..T ~ i n n r d m n r=

wi*ue eLrm.vccc -1 . H.-

UUM?. ACTION. -FACTOR¶ WS<TW wlw&rw.mc=ar' COUfRUHTIIIC ACCIMNT 40RdLCM ICI'IIC. iYUSW>2L[*IYLCtAl relm- i ~ 1 9 ~ ~

- 1YLUI I I IDIPC - L - X T l 5 S m S * i W n I S ~ W - @ W T : 7- II&=E W V D : X t W (ry' uu;Lurrunru 7 %.-(I.#UZ LUYW m-LI ~ L . J . ~ W . V c lSART'AS. * raS

A

U ? . C O . . % b 1 4 U I A S ' 1 ~ 4 1 9 F 8 4 rn *- u ~ r q 0bCnb-c I- * m m ~ e s :hm1;1)-ma

-I us- wQS1*m> - r im$ '--i a.wn.. 8 - 3 M n c c n a rc*tv.rr.t - - ua:scm ,r,".,W ig-.;.- Y W : ~ .%rIc.:rmumr; 'F.:.c~J

-- . . :,eq2sernui E', w e a : m - ~ ID - - I I v x a I C L u1 \*I= I= Ur'ui NU ~ c ~ r t m ~ r i m m t * -* * m n z r L - : m l -

C L C I ~ S b m f'!4;'tC fi PI?L(' .*i[llh . . .. . - - L ~ ~ c ~ l . l , ~ l ~ l ~ ~ .'-~~tqr; dtC* MO 2 :b >... - N*.WZ ;f :- LI m - i s - - -m Pi: L y . ur, " , , . , W A ~ ~ * ~ ~ ~ ~ , , ~ ~ ~ ~ ~ ~ ~ ~ ,,-,,? .% ~-r, &J! A*> kl,

. : AC 1 ,.PIP

Page 185 of 21 0

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~ ~ o d a ~ Juawssassy a~ua6!ya ana 9 ypny leJuawuoJ!AuI

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Chlorine

Hydrogen Cylinders

Location Domestic Water Plant St I Domestic Pre-Treatment Plant St-l Soft water pre treatment plant St-l Cooling tower St I

FO and LDO

Quantity 1 Cylinder 1 Cylinder 3 Cylinder 3 Tonner

Type Cylinder of 100 Kg Cylinder of 100 Kg Cylinder of 100 Kg Tonner of 900 Kg

TY pe Cylinder of 5.4 & 5.94M Cylinder of 5.4 & 5.94 M

Location H 2 generating plant St I H 2 generating plant St 11

Lubricant Oil and Transformer Oil

Quantity 350 Nos 500 Nos

TY pe Furnace Oil Low Diesel Oil Furnace Oil Low Diesel Oil High Speed Diesel

Location Oil handling plant St I

Oil handling plant St II

CHP Vehicle Maintenance

Page 188 of 210 #ERNST& YOUNG C&rlityln Fsw;ytlh# W Uo

Quantity 3440 KL 1720 KL 3600 KL 1800 KL 140 KL

Location Boiler Maint. Oil Store St I

Quantity 1 Barrel 15 Barrels 13 Barrels 1 Barrel

Type Servo Gem-2 Grease Servo Mesh SP 320 Servo Mesh SP 257 Servo premium XHP 15W-40

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Paae 189 of 210 HERNST& YOUNG

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ANNEXURE - Vlll

Details of Person Interviewed (Potential Liability & Risk Assessment)

Page 190 of 21 0

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... .

Page 191 of 210 #ERNST& YOUNG C.&l)ify ln F w y t M n ~ Hir Uo

Name of the village

Suradevi

Mhasala

Khasar

Koradi

Naanda

Name of the person interviewed

Ramdas

Pyarelal Ladke

Mahadev Shambarkar Bandu Shambarkar

Neha Vasudev Bhoyar

Rajesh Mishra

Occupation

Farming

Farming

Farming

Employed

Sarpanch of Koradi Gram Panchayat (includes Paanjra, Koradi, Naanda, Khapri, Adarsh Nagar & Shriyas Nagar) Laborer

Residence of the village since

58 years

50 years

50 years

20 years

20 years

Relation with MSEB

Neither he nor anybody else from his family is employed with the state utility. Neither he nor anybody else from his family is employed with the state utility. 2 sons of Mr. Mahadev Shambarkar including Mr. Bandu were provided employment by MSEB. They were also provided land as a part of the rehabilitation program. Her parents were provided land during the rehabilitation program and her brother was provided employment.

Neither he nor anybody else from his family is employed with the state utility.

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ANNEXURE - IX WATER CONSUMPTION & DISCHARGE DETAILS (2007-08)

Page 192 of 21 0

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Page 193 of 210

Effluent Gen.m3

8 1227628 1247894 1199564 1220666 1248630 1202113 1245509 1202460

1224410 1236555 1152509 1226774

14634712

Ash Disposal tons. m3

7 1227628 1247894 1199564 1220666 1248630 1202113 1245509 1202460

1224410 1236555 11 52509 1226774

14634712

C.W. Cons.(m3)

3 2338582 2229097 1611435 2066040 2083321 2241743 2 109465 1911322

1923837 1924770 1982054 1998794

24420460

Effluent Gen. <m3)

4 472694 483600 468000 531300 531300 486000 500774 486000

520219 286124 485100 520800

5771911

Effluent Recovered <m3)

5 472694 439725 456300 493350 494325 469300 463840 465400

475800 271050 445250 468845 5415879

Dlschargd to Pond3

(Recovered)

6 0

43875 11700 37950 36975 16700 36934 20600

44419 15074 39850 51955

356032

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Note: Apart from the unrecovered water of 7142186 m3 as mentioned in the cess recoreds, it was also observed that 18326431 m3 (from Stream 2 of Khasara ash bund (12251736 m3) and CHPBBPH outlet (6074695 m3)) is also unrecovered and unaccounted for in the cess records. Therefore, the water recovered would not match with the cess records and the water balance statement.

Page 194 of 21 0 Quality h Ftwythiing W Do

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Colour Coding for Monitoring Locations on the Layout Map

I I Coolina Water Blowdown I

Ash Pond Overflow I I Surface Water (1) I

Surface Water (2) I Note: Ground Water Location cannot be identified on the layout as it is out of the boundary

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Supernatant (not joining AWR) 33566.4 cum /day

10703.76 cu.m/day

r' l-

461.5 cu.mlhr

. - , Ash S l w y Line

66.86 cu.mlhr

Pond No. 2

4 (963.964.29 cu.mldav) 40% Channel 60% -1

1 Un - recovered from ETP I 1 Over flo- 1

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+ I 1euueu3 % o t u e a

0 2 'ON Pwd E 'ON PUOd (D

t qJUad WOlJ

MoUul

3

~ ~ o d a u luaurssassv ama6!l!a ana g ypnv (ejuawuoyAu3

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Plate - IV

ETP Schematic

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Garden pumps 1.2.3

OUTLET Clarifier Tank CHAMBER A

I Sludge sump Aeration

overflow

. . SP-1 SP-2 AERATING TANK

PUMP HOUSE Inlet

INTAKE TANK

Chamber b

LABORATORY

COLONY END

I - SLUDGE DRYING BEDS

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Environmental Audit & Due Diligence Assessment Report

DISCLAIMER

As it is practically not possible t o study all the required aspects in its entirety thorouqhly during the limited time period of the study, based on our methodology, we carried out the study throuqh review of related documents provided by the management of MAHAGENCO, discussions with the management personnel and other key people, physical observations at the site, which helped us in identifying issues and concerns, if any, associated with KTPS. Consequently, this report may not necessarily address all related matters perceived as important by the management.

The information provided in this report is based on site reconnaissance, data and information made available to Ernst & Young during the site visit, interviews and investiqations during the site visit, and therefore, the finding of this report are valid as of the time period of the site visit. Conclusion drawn from information available from documents /information made available to Ernst & Young Pvt. Ltd., pertain to the time of generation of the respective documents and significance or accuracy of the same at the time of the site reconnaissance has not be verified. Ernst & Younq Pvt. Ltd., does not own the responsibility of information collated from interviews or discussion in the course of the environmental audit and due diligence assessment.

The assessment was performed with the degree of care and skill ordinarily exercised under similar conditions by reputable, qualified EHS professionals practicinq the same or similar locality. The conclusions and recommendations represent professional judgments and are based on the interpretation of such data / information made available to Ernst & Young Pvt. Ltd.

Limitations on Use of Report

This report is solely for the information of MAHAGENCO and should not be used, circulated, quoted or otherwise referred t o for any other purpose, nor included or referred t o in whole or in part in any document without our prior written consent.

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