dcm shriram limited

DCM Shriram Limited

(Unit: Shriram Alkali and Chemicals, Jhagadia)

COMPLIANCE REPORT– Environmental Clearance from MoEF

For the period of OCTOBER -17 to MARCH-18

[letter no. SEIAA/GUJ/EC/4(d) & 1(d) /3076/2015 dated 21st August 2015]

Sr. no.

CONDITIONS/RECOMMENDATION

STATUS

1 Fresh water requirement of 12233 KL/Day (12220 KL for Industrial & 13 KL for Domestic purpose) after the proposed expansion shall be met through the GIDC water supply only. Metering of water shall be done & its records shall be maintained. No ground water shall be tapped in any case for the project requirements.

Water meter for raw water consumption No ground water is tapped for the purpose.

Month WATER COMSUMPTION METER READING

WATER CONSUMED

(KL)

October-17 2025109 312547

November-17 2285620 260511

December-17 2616353 330733

January-18 2912415 296062

February-18 3232878 320463

March-18 3496320 263442

2 The Industrial waste water generation shall not exceed 861 KL/day after the proposed expansion.

At present, the industrial waste water generation is within the limit of 861 KL / Day. The bills from Narmada Clean tech for the period Oct'17 to March'18 are attached as Annexure-1 for reference.

Month EFFLUENT DISCHARGE (KL)

October-17 12636

November-17 16720

../Annexure-1_NCTL%20Bills.pdf

December-17 13222

January-18 15477

February-18 14720

March-18 14856

3 Waste water generated from the DM plant (240KL/Day) shall be reused in process plant for the preparation of Sodium hypochlorite.

Waste water generated from DM plant is reused in the process.

4 Boiler blow down (460KL/Day) shall be reused completely. 260KL/Day shall be reused for cooling towers and 200 KL/Day for soot blowers, Ejectors, steam traps etc.

Boiler blow down from power plant 280 KL/Day

5 After reuse/Recycle of 700 KL/Day waste water, remaining 861 KL/Day of treated effluent conforming to the GPCB norms shall be discharged into the GIDC drain for final disposal by the NCTL into the deep sea.

Presently, the effluent is being passed through RO unit ant permeate is recovered. RO reject & cooling tower blow down treated effluent up to 861 KL/day is discharged into existing NCTL pipeline as per GPCB directions.

Month EFFLUENT DISCHARGE (KL)

October-17 12636

November-17 16720

December-17 13222

January-18 15477

February-18 14720

March-18 14856

6 The ETP shall be operated regularly and efficiently so as to achieve the GPCB norms at the final outlet.

We have maintained ETP effectively , The result of ETP discharge pH, TSS & Temperature are monitored by on line meter and real time data transfer to CPCB & GPCB server. We also analyze our Effluent from GPCB approved laboratory . The result for the period October’17-March’18 are attached as Annexure-2

7 The domestic waste water generation shall be 13 KL/Day and it shall be disposed off through septic tank-soak pit.

The domestic waste water 13 KL/Day through Soak pit. We exploring this water treating by STP for further treatment and it is use for gardening. We have installed STPs at different location for further purification and its reuse in gardening.

8 The unit shall provide metering facility at the inlet and outlet of the ETPs and maintain the records of the same.

Metering facility at the inlet and outlet of ETP is available and NCTL continuously monitors the same.

The unit shall also provide on line pH meter and TOC meter for online monitoring of the treated effluent.

Flow meter pH meter TSS meter Online flow meter, pH meter & TSS meter have been provided in Effluent discharge line and the data is monitored through the DCS and transmitted to CPCB & GPCB server, as per the requirement. Final CCA for 861 KL/day discharge was issued by GPCB on 01.09.2017 with requirement of TOC meter. We are in the process of purchasing the same.

9 A proper logbook of ETP operation and also showing the quality of effluent generated, utilized for plantation / gardening etc. shall be maintained and furnished to the GPCB from time to time.

The reports are given in soft copy and hard copy to GPCB monthly through XGN. Log Book Report of ETP operation is attached as Annexure-3

10 Regular performance evaluations of the ETP shall be undertaken every year to check its adequacy through credible institute like L.D. college of Engineering, NPC or such other institute of similar repute and its records shall be maintained.

Yearly performance evolutions of ETP is done by GPCB authorised grade-I auditing institute. In 2017-18 by N.G.PATEL POLYTECHNIC, BARDOLI., In 2018-19 audit carried out by MANMADE TEXTILE FIBER RESEARCH CENTER, SURAT. After the audit institute upload report in GPCB website.

11 The unit shall join and participate financially and Technically for any common environment facility / infrastructure as and when the same is taken up either by the GIDC OR GPCB or any such authority created for this purpose by the Govt./GIDC.

We are one of the active members of Jhagadia Industrial association (JIA). We are support NCT whenever they seek our help. The constructions of Jhagadia pipe line project we deputed one mechanical engineer above six month for supporting .

AIR

12 Additional Blended coal (Indigenous/imported/lignite/biomass) to the tune of 54.338MT/hr (476000MT/Annum) shall be used for the proposed 300 TPH steam boiler of coal based power plant.

Additional blended coal 37 MT/hr. is used for 300TPH boiler

MONTH COAL CONSUMPTION (MT) October-17 53135

November-17 47828

December-17 58118

January-18 52740

February-18 43671

March-18 34788

13 Indigenous/imported coal, Lignite & Biomass shall be blended in such a way that the blended coal to be used shall have sulfur content and Ash content not exceeding 1% & 20% respectively.

Indigenous and Imported coal ratio for P60 power plant is 35% and 65% respectively. The Condition is being followed. Sulfur content and Ash content in the coal use by us are not exceeding 1% & 20% limits, respectively.

MONTH ASH CONTENT SULPHUR CONTENT

% % October-17 6.53 0.71

November-17 10.85 0.78

December-17 9.25 0.66

January-18 10.24 0.71

February-18 8.06 0.71

March-18 8.01 0.69

14 Additional Hydrogen gas to the tune of 34,000 NM3/Day shall be used as fuel for the proposed molten salt heater.

Hydrogen gas is a by-product from our caustic soda plant and green fuel. We have obtained permission for its use @34000nM3/day in 2nd flaker plant also. We are further exploring its use as fuel substitute in boilers also.

15 Additional HSD to the tune of 100MT/annum shall be used for startup & support of Boilers for proposed activities.

HSD is used for startup of boilers. The month wise consumption of HSD is as given below:

Sr. No. Month HSD Consumption data (MT)

1 October-17 2.195

2 November-17 14.08

3 December-17 0

4 January-18 0

5 February-18 860

6 March-18 2553.545

Caustic scrubber shall be provided with chlorine absorption unit - Hypo plant & water / Caustic scrubber shall be provided with HCl plants as air pollution control equipment

We are having caustic scrubber for waste chlorine neutralization and HCl fumes absorption in Hypo and HCl plants, respectively.

for control of Cl2 & HCl.

17 Adequate stack height as per prevailing norms shall be provided for the flue gas & process emissions.

For the flue gas height of stack is adequate for So2 emission. Process stack of Minimum height of 30 meter. We have two boiler stack, Five D.G. stack, Two Molten salt heater stack, Three HCl stack, Two Hypo stack is as per adequate height.

18 On-line monitoring system shall be installed on the flue gas & Process stacks to monitor the pollutant concentrations and arrangement shall also be made for reflecting the online monitoring results on the company's server, which can be accessed by the GPCB on real time basis.

Online monitoring system for the parameter PM,SOx and NOx have been installed in flue gas stack of boiler, online monitoring of HCl and chlorine is done in HCl stack, Online chlorine monitoring in Hypo stack and real time data is transfer to CPCB and GPCB server.

19 The air pollution control system shall be operated efficiently & effectively to achieve the norms prescribed by the GPCB at vent/stack outlets.

All air pollution control systems are operating efficiently and effectively and the outlet concentrations are within the GPCB norms. Copy of the analysis reports from October' 17 to March' 18 is attached as Annexure-4.

20 High efficiency electro static precipitators (ESP) with efficiency not less than 99.9% shall be installed for control of flue gas emission from the power plant. The ESP shall be operated efficiently to ensure that particulate matter emission does not exceed the GPCB norms, the control system shall be designed & integrated in plant DCS in such a way that if emission from ESP exceed the specified standard, utilization of boiler capacity shall reduce so that flue gas emission from the stack meets with the specified norms of boiler shall shut down totally.

The ESPs installed are operating with adequate efficiency and the emission does not exceed the GPCB norms. The values are displayed in power plant DCS and realtime data being transferred to CPCB server also.

21 There shall be one extra field in the ESP to ensure that even though one field goes out of

The ESP of CFBC boiler is having five field and P.F boiler have seven field. Meanwhile four field are in line.

order, the prescribed standard of PM is met with, in case of failure of two or more fields of the ESP, the unit shall immediately shut down the power plant.

22 Third party monitoring of the functioning of the ESP along with its efficiency shall be carried out once in a year through a reputed institute / organization.

Monitoring of emission results being regularly conducted by 3rd party laboratory and GPCB authorized agency.

MONTH

P.F. BOILER C.F.B.C. BOILER

SPM SPM

50 mg/Nm3 50 mg/Nm3

October-17 5 11

November-17 7 10

December-17 9 12

January-18 6 9

February-18 5 11

March-18 8 Plant shut down

Minimum 5 9

Maximum 9 12

23 Lime stone injection technology shall be adopted to control SO2 & its shall be ensured that SO2 level in the ambient air do not exceed the prescribed standards.

Lime stone injection system has been incorporated in the CFBC boiler to control SO2.

24 The company shall prepare schedule & carryout regular preventive maintenance of mechanical & electrical parts of ESPs and assign responsibility of preventive maintenance to the senior officer of the company.

Preventive maintenance schedule exists and the maintenance manager is responsible for the activity.

25 Adequate storage facility for the Fly ash in terms of closed silos shall be provided at site. No ash pond shall be constructed.

Closed silos of 500 MT capacities exist for storage of the fly ash at site. We do not have any ash pond for the purpose.

26 Handling of the fly ash shall be

through a closed pneumatic system.

We use pneumatic system for handling of fly ash.

27 Ash shall be handled only in dry state.

We have only dry ash system and do not have any wet ashing facility at site.

28 The unit shall strictly comply with the Fly Ash Notification under the EPA and it shall be ensured that there is 100% utilization of fly ash to be generated from the unit.

100% utilization of fly ash being generated is ensured. The record of fly ash generation –vs-disposal for October-17 to March-18 is as under:

Sr. No. Month Fly Ash Dispatch (MT)

1 October-17 3709.2

2 November-17 8005.13

3 December-17 6109.26

4 January-18 7348.51

5 February-18 3959.27

6 March-18 3080.82

29 The fugitive emission in the work zone environment shall be monitored. The emission shall confirm to the standards prescribed by the concerned authorities from time to time (e.g. DISH) following indicative guideline shall also be followed to reduce

Fugitive emission monitoring from October-17 to March-18 is attached as Annexure-5

the fugitive emission. →All handling & transport of coal /Lignite /Bio-mass shall be exercised through covered coal conveyers only. →Enclosure shall be provided at coal /Lignite /Bio-mass loading & unloading operation. →Water shall be sprinkled on coal /Lignite /Bio-mass stock piles periodically to retain some moisture in top layer & also while compacting to reduce the fugitive emission. →All transfer point shall be fully enclosed. →Adequate dust suppression/Extraction system at crusher house as well as for the Coal /Lignite /Bio-mass stock yard & other vulnerable areas shall be provided to abate dust nuisance. →Accumulated coal dust /Fly ash on the ground & other surface shall be removed /Swept regularly & water the area after sweeping. →Internal roads shall be either concreted or asphalted or paved properly to reduce the fugitive emission during vehicular movement. →Air borne dust shall be controlled with water sprinklers

Water sprinkling arrangements have been made to control fugitive emissions

Dust suppression/extraction system exists at coal crusher house All internal roads are either concreted or asphalted Water sprinkler being done to suppress airborne dust Greenbelt has already been developed at site to mitigate the effect of fugitive emission all around the plant. Photograph of the greenbelt is

at suitable location in the plant. →Coal /Lignite /Bio-mass shall be transported through covered trucks only whereas fly ash shall be transported through closed truck only. →A green belt shall be developed all round the plant boundary & also along the road to mitigate fugitive transport dust emission.

attached as Annexure-6. Type of trees planted are silver oak, poppler, Neem, platform , palm etc. We have planted 1000 saplings during April-September and this year will be continuing plantation of saplings around the complex.

30 All the vessels used in the manufacturing process shall be closed to reduce the fugitive emission.

All the vessels used in manufacturing process are closed

31 Third party performance evaluation of the air pollution control system including ESP shall be carried out at least once in a year to check its performance & efficiency through a reputed institute / organization like NPC, L.D.College of engineering-Ahmadabad or such other institute of similar repute & its record shall be maintained.

Third party performance of Particulate matter emission carried out by N.G.PATEL POLYTECHNIC, BARDOLI in 2017-18 and MANMADE TEXTILE FIBER RESEARCH CENTER, SURAT in 2018-19.

32 Regular monitoring of ground level concentration of PM10, PM2.5, SO2, NOX, Cl2,& HCl shall be carried out in the impact zone & its record shall be maintained. Ambient air quality levels shall not exceed the prescribed limits. Necessary additional control measures shall be provided immediately. The location of the monitoring station & frequency of

Ambient Air report

Date of

Sampling

Area

100 60 80 80 200 100

SPM <10mic

SPM <2.5mic So2 NOx Hcl Cl2

mic.g/m3

mic.g/m3

mic.g/m3

mic.g/m3

mic.g/m3

mic.g/m3

11.10.17

Nr.salt yard 60 37 27.9 30.1 BDL BDL

Nr.main gate 54.9 35 25.1 28.5 BDL BDL

N.TSDF 54 41 29.6 33.9 BDL BDL

17.1

1.17


Nr.mai 58 37 27.9 30.1 BDL BDL

monitoring shall be decided in consultation with GPCB.

n gate

N.TSDF 56 43 31.2 34.1 BDL BDL

15.1

2.17



N.TSDF 61.0 40.0 33.9 36.2 BDL BDL

12.0

1.18

Nr.salt yard 58.0 40.0 29.8 31.7 BDL BDL

Nr.main gate 62.2 35.0 28.5 31.2 BDL BDL

N.TSDF 58.0 41.0 28.8 31.8 BDL BDL

09.0

2.18



N.TSDF 62.0 39.0 31.4 34.4 BDL BDL

14.0

3.18



N.TSDF 59.0 36.0 30.7 33.9 BDL BDL

Average 59 39 30 33

SOLID / HAZARDOUS WASTE

33 The company must strictly comply with the rules & regulation with regards to handling & disposal of hazardous waste in accordance with the hazardous waste (Management, handling & Transboundary movement) rules 2008, as may be amended from time to time. Authorization from the GPCB must be obtained for collection / treatment / storage disposal of hazardous wastes.

We are complying to the Hazardous waste imported, handling and storage rules’2016 Copy of CCA letter no.: GPCB/ANK/CCA-305(10)/ID-15672/422338 is attached as Annexure-7

34 ETP sludge & Brine sludge shall be stored in separate

ETP sludge and Brine sludge is disposed in the TSDF within the factory premises. The design of the facility is as per the recommendations of

designated hazardous waste storage facility with pucca bottom & leachate collection facility, before its disposal.

CPCB with pucca bottom & leachate collection facility.

35 Brine sludge shall be disposed off to their own TSDF site within premises.

Brine sludge is disposed in the TSDF within the factory premises. The design of the facility is as per the recommendations of CPCB with pucca bottom & leachate collection facility

36 ETP sludge shall be disposed off to their own TSDF site or common TSDF site based on its characteristics.

ETP sludge is disposed at our own SLF.

37 Discarded containers / barrels / bags / liners shall be either reused or sold only to authorized recyclers after decontamination.

Discarded barrels are disposed to GPCB approved recycler M/s.BEIL. Bags are use for making tarpaulin after decontamination.

38 Used oil shall be sold only to the registered recyclers /refiners.

Used oil is sold to authorized recyclers M/s. R.K.Steel, Bharuch. Copy of manifest is attached as Annexure-8

39 For storage of Fly ash closed silos of adequate capacity shall be provided. no ash pond shall be constructed in the project.

We have closed silos for fly ash, no other facility available for storage of fly ash

40 The fly ash shall be supplied to the manufacturers of fly ash based products such as cement, concrete blocks, bricks, panels, etc.. The unit shall strictly comply with the fly ash notification under EPA & it shall be ensured that there is 100% utilization of fly ash to be generated from the unit.

The fly ash is supplied to the manufacturers of fly ash M/s Ambuja cement, M/s JK Lakshmi cement and M/s MAA KHODIYAR MATEL

BRICKS based products such as cement, concrete blocks, bricks, panels, etc..

41 All possible effort shall be made for Co-processing of the Hazardous waste prior disposal into TSDF/CHWIF.

We have dispatched ETP sludge sludge in our own SLF and bags are use for making tarpaulin after decontamination. We use spent oil for greasing purpose of the heavy machinery.

42 Provision of the manufacture, storage & import of hazardous chemicals rules, 1989 & Factory act 1948 shall be strictly

We are complying to the Hazardous waste imported, handling and storage rules’1989 & Factory Act, 1948 and there amendment.

complied with

43 Recommendations made in the risk assessment study report submitted by the project proponent shall be vigorously followed

Our organization is OHSAS-18001 certified recommendation have made by . We already been implemented, risk analysis being done on annual basis for each plant and they are implemented based on the risk

potential. Procedure of Hazard identification and risk assessment is attached as Annexure-9

44 Unit Shall strictly comply with the provision made in manufacture storage and import of hazardous chemicals rules 1989, as amended in 2000 for handling of hazardous chemicals, All necessary approvals from the concern govt. authorities shall be obtained before expansion of the project.

We have obtained the approval from the Directorate of Factory for Factory operation and Chief controller of explosive for storage of Chlorine, Chlorine tonner and Hydrogen. The latest approval from CCE are as under:

Chlorine Cylinders 2016 nos License no: G/HO/GJ/05/203 (G1346)

Chlorine Storage tanks

05 tanks (492.5 MT)

S/HO/GJ/03/320 (S 1605)

Hydrogen

Cylinders 744nos License no: G/HO/GJ/05/350 (G1545)

Petroleum- ClassB Class-C

Tanks 665 KL 1950 KL

45 All necessary precautionary measures shall be taken to avoid any kind of accident during storage and handling of toxic/hazardous chemicals especially chlorine, hydrogen etc

Necessary engineering control have been provided, PPE’s are used by the person handling the chemical and we have one On site Emergency plan with defined rolls and responsibility to handle Incident & accident . The last date of revision of plan is November-2017.

46 Stringent safety norms shall be adopted for storage handling and safe conveyance of chlorine to the nearby costumers through the pipeline

We have provided chlorine sensors with on/off valves for conveyance of chlorine through pipelines. Safety norms adopted during design stage for safe conveyance of chlorine to the nearby costumers through the pipeline. The same is being monitored at periodic intervals

47 Chlorine sensors and hydrogen sensors with alarm system shall be provided at various locations within plant premises.

32 nos of Chlorine sensors and 16nos of Hydrogen sensors have been provided at strategic locations within the plant premises. The alarm is provided in DCS for the values above TLV of each gas. The map showing the locations of the sensors is attached as Annexure-10

48 All the materials especially

chlorine, hydrogen etc. shall be stored in optimum quantity and all necessary permissions in the regard shall be obtained before commencing the expansion activities

We have obtained permission for storage of Chlorine and Hydrogen from CCE. We maintain a dummy tank for chlorine transfer in case of emergency. The stock quantity is maintained much below the licensed capacity.

49 A well designed fire hydrant system shall be installed as per the prevailing standards.

We already have a well laid fire hydrant network in the premises.

50 Storage and use of Hazardous

chemicals shall be minimized to the extent possible and all necessary precautions shall be taken to mitigate the risk generated out of it. Storage of hazardous chemicals

We are maintaining minimum stock levels of hazardous chemicals within the campus. We have considered small storage tanks for storage of hazardous

shall be in multiple small capacity tanks/ containers instead of one single large capacity tank for safety purpose.

chemicals. the details of storage facilities are as under:

Sr.

No.

Chemicals / Items

State Hazard

Involved Means of Storage

No. of Vessels/Bags

/ Tons

Existing

1

Chemicals (including Barium Carbonate, Sodium Carbonate, Sodium Sulphite)

Solid Corrosive

stored in chemical storage shed

400 MT

2 H2SO4 (98%) Liquid Corrosive Tank 1 no.

3 Blended Coal Solid Flammable Coal Yard 7,31,000 MT

4 Furnace Oil Liquid Flammable Tank 600 MT

1 Caustic Soda

Lye Liquid

Corrosive Tanks 5

2 Caustic Soda

Flakes

Solid Crystal

Corrosive

Stored in chemical storage shed

1200

3 Chlorine

Liquid Toxic, Corrosive

Tanks 5

Liquid Toxic, Corrosive

Tonners 2016 nos

4 Hydrochloric

Acid Liquid Corrosive Tanks 4

5 Sodium

hypochlorite Liquid Corrosive Tanks 2

6 Dilute Sulphuric

Acid Liquid Corrosive Tank 1

7 Hydrogen gas Gas Flammable Gas Holder 1

51 During material transfer, Spillage shall be avoided and garland drain be constructed to avoid mixing of accidental spillages with domestic wastewater or storm water

We have installed collection and recovery pits in each section. All precautions taken to avoid contamination due to spillage. The collection pits with recovery system photo is as below:

52 All the storage tank shall be fitted with appropriate controls to avoid any leakages, bund / dyke walls shall be provided for storage tank for hazardous chemicals. Close handling system for chemicals shall be provided.

Dyke walls have been provided around the storage tanks of hazardous chemicals

Our process is closed operation and there is no open drains, etc.

53 Tie up shall be done with nearby health care unit for seeking immediate medical attention in the case of emergency, regular medical checkup of the workers and keeping its records etc.

We maintain a Occupational Health Centre within our complex for immediate first aid. The OHC is manned by a regular qualified doctor and qualified male nurses. Besides that we have tied up with the nearest health care unit at Bharuch, Ankleshwar, Jhagadia and Vadodara for immediate medical support. The six monthly medical checkup of the employees are conducted at our OHC, as per the requirement.

54 Personal protective equipments shall be provided to workers and its usage shall be ensured and supervised

All necessary PPEs have been provided to workers and they are continuously encouraged for their use. PPE boxes are kept in different sections of the plant with all necessary PPEs.

55 First aid box and required

antidotes for the chemicals Used in the unit shall be made readily available in adequate quantity.

Provision of First aid box with antidotes for the chemicals are kept in strategic locations in the plant

List of First Aid Box Location

Sr. First Aid box location

1 Occupational Health Centre

2 Ambulance

3 Fire Tender

4 Process Plant Control Room

5 Bottling Plant Process 1

6 Bottling Plant 2

7 Tank Farm

8 Old Material Gate

9 Canteen

10 Power Plant Control Room

11 P60 - 11KV Switchgear Room

12 CHP MCC Room

13 Old PMCC 2nd Floor

14 AAC Project Site

15 New Material Gate

56 Training shall be imparted to all the workers on safety and health aspects of chemicals handling.

We regularly impart internal and external training to our employees and other stakeholders on safety aspects of chemical being handled.

57 Occupational health surveillance of the workers shall be done and its records shall be maintained. re employment and periodical medical examination for all the workers shall be undertaken as per the factories act & rules.

Form no-32 being maintained for record of Occupational health of employees. Pre employment medical checkup is conducted for all the employees and six monthly medical checkup being done. Records of the above being maintained.

58 Handling and charging of the chemicals shall be done in such a manner that minimal human exposure occurs.

Handling and charging of chemicals being done in closed circuits. Wherever possibility of exposure is perceived, necessary PPEs provided.

59 Transportation of hazardous chemicals shall be done as per the provisions of the motor vehicle act & rules.

TREM card and MSDS are provided with each vehicle transporting the hazardous chemicals. Copies of sample TREM card and MSDS are attached as Annexure-11

60 The following noise control measures to be adopted: > Selection of any new plant equipment shall be made with specification of low noise levels. > Manufacturers / suppliers of major noise generating machine / equipment like air compressor, feeder pumps, turbine generator, etc. shall be instructed to make required design modification wherever possible before supply and installation to mitigate the noise generation and to comply with the national / international regulatory norms with respect to noise generation for individual units > Regular maintenance of machinery & vehicle shall be undertaken to reduce the noise impact. > Noise suppression measure such as enclosures, buffer &/ or protective measures shall be provided. > Employee shall be provided with ear protection measures like earplug or earmuffs. > Proper oiling, lubrication & preventive maintenance shall be carried out of the machineries & equipments to reduce noise generation. > Construction equipment generating minimum noise & vibration shall be chosen. > Ear plug / muff shall be made compulsory for the construction workers working the noise generating activities/ machine/ equipment. > Vehicle & construction equipment with internal

Being complied Being complied Being complied Being complied Ear plug and earmuff have been provided to all the employees Regular preventive maintenance for machines being done by expert departments existing within the facility Noted Being followed Noted and complied with Noted Being complied Being complied with Being followed Noted and complied with

combustion engines without proper silencer shall not allowed to operate. > Construction equipment meeting the norms specified by the EP Act, 1986 shall be used. > Noise control equipment & baffling shall be employed on generators especially when they are operated near the residential & sensitive areas. > Noise level shall be reduced by the use of adequate mufflers on all motorized equipments.

Noted Being complied Being complied with

61 The overall noise level in & around the plant area shall be kept well within the prescribed standards by providing noise control measures including acoustic insulation, hoods, silencers, enclosures, vibration dampers etc. on all sources of noise generation. The ambient noise level shall confirm to the standards prescribed under the environmental (Protection) Act & rules. Workplace noise level for workers shall be as per the factories Act & rules.

All possible noise control measures as explained above have been adopted. Ambient noise level measurement record is as under:

DATE Turbine Generator Hall

Cooling tower Pump House

Compressor area -BFP

Coal Mill

Coal Crusher

FD Fan

ID Fan

PA Fan

CEP

Noise Level - One meter away from the source of generation

11.10.17 69.5 68.7 70.4 68.1 70.8 67.3 69.2 68.1 70.1

17.11.17 68.7 67.7 69.3 71.1 68.9 65.8 67.9 68.1 68.9

15.12.17 69.1 69.7 70.2 66.9 69.1 68.3 68.2 72.4 70.2

12.01.18 70.2 68.2 72.3 67.1 70.2 67.5 70.1 68.1 69.3

09.02.18 71.3 70.2 71.1 68.2 71.4 66.3 69.3 67.1 71.2

14.03.18 68.3 71.4 68.9 70.2 67.7 69.1 70.3 71.2 68.4

Average 69.52 69.32 70.37 68.60 69.68 67.38 69.17 69.17 69.68

62 The project proponent shall install energy efficient device & appliances confirming to the Bureau of Energy Efficiency norms.

We have installed energy efficient appliances complying to BEE norms, wherever possible. The zero gap new electrolyzers are highly energy efficient as compared to their older versions.

63 The energy audit shall be conducted at regular intervals & the recommendation of the audit report shall be implemented.

We conduct the Energy audit of our plant and equipments through 3rd party at regular intervals. The last audit was conducted by A-Z Energy Engineers Pvt. Ltd., Delhi. The recommendations have been implemented.

64 The project proponent shall implement the application of solar energy which shall be utilized as solar lighting for illumination of common areas, lighting of internal roads & passages in addition to utilization of solar water heating system.

We have installed solar lights on internal roads.

We are further planning to install solar lights and heaters at the following areas:

Proposed Solar Lights Installation in 2018-19 with 300 lumens

I Installation of sky pipe lights in following Areas

1 Power Plant Control Room 300 Lumens 12 nos

2 Old PMCC 10 Nos

3 Canteen 10 Nos

II

Solar street lights in P60 and P48 Raw water and fire pump area (35 Watts) 8 Nos

III Installation of Solar Panel On roof top of

1 TG control Room (50 kWp) 1 Set

2 Store (100 kWp) 1 Set

65 The transformers & motors shall have minimum efficiency of 85%

Transformers and motors efficiency are maintained >85%. The efficiency range varies from 85.6 -95.2%.

66 Variable frequency drives shall be installed.

Total 133 nos of VFDs have been installed in the complex. out of which, 65 VFDs are in chlor alkali and 68 are in power plant. List of VFD is attached as Annexure-12

67 Energy conservation measures shall include use of electronics lighting system, use of CFL tubes to minimize energy use. Use of programmable timers for pumping system & lighting, water level controller for water pumps, centralized cooling etc.

We are using LED s and CFL tubes for minimization of energy consumption. Total of 1100 fittings have been installed. Our control rooms of chlor-alkali, power plant and the administration block are centrally air conditioned. We have provided the float valves in water tanks and flow controllers/ sensors in water taps for conservation of water.

68 Energy saving practices as follows shall be practiced : * Constant monitoring of energy consumption & defining targets for energy conservation. * Adjusting the setting & illumination level to ensure minimum energy used for desired comfort level. * Use of solar cells for lighting. *Use of solar water heater for canteen & washing area. *Proper load factor shall be maintained by the unit. *Provision of the day light roof to utilized maximum natural light in the production plant instead of electrical lighting. *Use of electronics ballast to save energy. *Automatic switch system for lighting & water tank pumping shall be used. *To the maximum extent possible & technically feasible, energy efficient equipment like motors, pumps, air conditioning system shall be selected. *Gravity flow shall be preferred wherever possible to save pumping energy. *Promoting awareness on energy conservation. *Training to the staff on

Constant monitoring of energy consumption being done at the unit for all processes/ equipments. Regular illumination level is monitored and lighting is adjusted accordingly We have installed solar light at strategic location in plant. we installed the solar heaters in canteen and OHC in 2018-19 Load factor>95% being maintained All workplaces and offices are exposed to sunlight and day light is used in plant to the maximum extent LED lightings have been provided water tanks , booster pumps and equipments are provided with automatic switch.

we use all such equipments that are either BEE certified or proven certificate of energy efficient

We prefer gravity flow in liquid transfers, wherever feasible Employees are educated on energy conservation measures and encouraged to implement such schemes Energy conservation poster banners displayed in the plant. Regular competitions and suggestion schemes are conducted and employees are encouraged by giving suitable awards for participation

method of energy conservation & to be vigilant for this.

There are 05 nos of certified Energy managers. They provide training to the employees. Employees are also nominated for External trainings /seminars

CLEANER PRODUCTION & WASTE MINIMISATION

69

The unit shall undertake the cleaner production assessment study through a reputed institute / organization & shall form a CP team in the company. The recommendations thereof along with the compliance shall be furnished to the GPCB.

Cleaner product team already exists. As per their recommendations, We have adopted membrane technology process for caustic production & Fluidised Bed combustion in boiler, using hydrogen for caustic concentration purpose, which are cleaner production method available as on date

70

The company shall undertake following waste minimization measure : • Metering & control of quantities of active ingredient to minimization waste. • Reuse of by-product from the process as raw material or raw material substitutes in other process. • Use of automated & enclosed filing to minimize spillage. • Use of close feed system into batch reactor. • Dry cleaning / mopping of floor instead of floor washing. • Use of high pressure hoses for cleaning to reduce waste water generation. • Regular preventive maintenance for avoiding leakage, spillage etc.

Metering of quantities of each active ingredient being done and optimized to reduce waste Hydrogen is reused in making HCl, and as fuel substitute. Waste chlorine is reused for making Sodium Hypochlorite caustic lye is filled by automatic filling and chlorine tonners are also filled with automatic filling with cut-off adjustment and overfilling alarm NA Dry cleaning of floor is done Cleaning is done with high pressure hoses only Preventive maintenance schedule is in place and being followed

GREEN BELT & OTHER PLANTATION

71 The unit shall develop green belt within premises as per CPCB guideline.

We have developed a green belt all along the boundary as per the CPCB guidelines and directions issued by GPCB. Type of trees planted are silver oak, poppler, Neem, platform , palm etc...

However, if the adequate land is not available within the premises, the unit shall take up adequate plantation on road side & suitable open areas in the GIDC estate, nearby schools, gram panchayat areas & other open areas in consultation with the GIDC/ local bodies/ GPCB & submit an action plan of plantation for next three years to the GPCB.

We have further expanded the greenbelt in GIDC estate and have planted 5000 saplings in GIDC area close to our boundary in 2017-18. Copy of the certificate of plantation issued by GIDC is attached as Annexure-13

OTHER CONDITIONS

72 In the event of failure of any pollution control system adopted by the unit, the unit shall be safely closed down & shall not be restarted until the desired efficiency of control equipment has been achieved.

Noted and complied with

73 The project authorities must strictly adhere to the stipulation made by the GPCB, state government & any statutory authority.

Noted and complied with

74 The company shall strictly follow all the recommendation mentioned in the charter on Corporate Responsibility for Environment Protection (CREP) published by CPCB ,as may be applicable.

We are in compliance with the applicable provisions of CREP guidelines for Chlor-alkali plant and thermal power plant

Ours is a membrane cell based chlor-alkali plant. So, as applicable to us, in the guideline, we have adopted the pollutional and safety aspects for CI2 handling to prevent any accident/ release of CI2

In our captive power plant, we provide dry ash to the users outside the premises

75 Pucca flooring/ impervious layer shall be provided in the work areas, chemical storage area & chemical handling areas to minimize soil contamination.

All roads and working areas are either of RCC or asphalt cover to make it impervious for prevention of soil contamination.

76 Leakages from pipes, pumps shall be minimal & if occurs, shall be arrested promptly.

There are minimal/ negligible leakages in the plant because of its construction. If any occurs, it is attended immediately

77 All the recommendations made EIA/EMP recommendations have been implemented. The list of

in the EIA/ EMP & other documents submitted by the project proponent shall be strictly implemented.

recommendations is attached as Annexure-14

78 A separate environment Management Cell equipped with full fledge laboratory facilities & qualified personnel shall be set up to carry out the environment management function & a separate budget shall be allocated for this purpose.

Separate environment cell and well equipped laboratory with all necessary arrangement has been formed under Addl. GM (EHS), who is a doctorate having more than 30 years experience in the field. The organization structure of EHS department is given below:

Monitoring is being done by 3rd party recognized laboratories. Separate budget has been earmarked for Environment management and also there is no constraint of funds for any such developmental activity.

79 The funds earmarked for environment protection measures shall be maintained in a separate account & there shall not be any diversion of these funds for any other purpose. A year-wise expenditure on environmental safeguards shall be reported.

Noted and complied with. The year wise environmental expenses are given in the following table:

Sr. Year Environment funds Amount (Rs/lacs)

1 2016-17 164.7

2 2017-18 223.35

80 The project proponent shall also comply with any additional condition that may be imposed by the SEAC or the SEIAA any other component authority for the purpose of the environmental protection &

Noted

management.

81 The company shall undertake all relevant measures for improving the socio-economic condition of the surround area. CSR activities shall be undertaken by involving local villages & administration.

We encourage local people for engagement in the jobs in the factory and its supplies. We carry out regular CSR activities involving local villages and administration for improvement of socio economic condition of the surround area CSR activities carried out in 2017-18 is as under:

82 No further expansion or modification in the plant likely to cause environment impact shall be carried out without obtaining prior environment clearance from the concerned authority.

Noted. We have applied for prior Environmental Clearance for expansion of our chlor-alkali plant from 342000 MTPA caustic to 508000 MTPA caustic

83 The above condition will be enforced, inter-alia under the provision of the water (preservation & control of pollution act,1974, Air (prevent & control of pollution) Act,1981. the Environment (protection) Act,1986. Hazardous waste(Management, Handling & Transboundary movement) rules,2008. & the public liability insurance Act,1991. along with their

Noted

Unit Sector Program NameProgram Description -

proposedBudgetProgram Description ActualMonth Amount

Preventive Health Program

2.5

Eye Camp

Nov-17 76226

Safe drinking water RO plant in Fulwadi village

7

For Toilet construction @

Fulwadi Nov-17 17000

Scholarship Merit scholarship in two

schools 2

Scholarship Distribution

programme @ Kapalsadi May-17 104263

Scholarship Cost May-17 0

Skill development program

Technical skills 2

Distribution of Tablets to

Jhagadia SDM Jul-17 206000

Sweet Distribution on 15th

Aug Aug-17 9450

Infrastructure development Renovate schools,

community buildings 9

to Social function at Boridra

May-17 12100

Vehicle for Farmers meeting

@ Gandhinagar Apr-17 5000

Community development Contribution to JIA 28

Environment SustainabilityWater conservation Rainwater harvesting 10

Subtotal SAC 60.5 430039

CSR Outlay 2017 - 18

SAC

Preventive

health,

Sanitation &

safe drinking

water

Education &

Skill

development

Rural development

amendments & rules.

84 The company shall undertake socio-economic developmental / community welfare activities in consultation with the District development officer / District Collector.

Being done. We have distributed scholarship cheques to local meritorious students of nearby villages through the SDM on dated 16.06.2017

85 The project authorities shall

earmark adequate funds to implements the condition stipulated by SEIAA as well as GPCB along with implementation schedule for all the condition stipulated herein. The funds so provided shall not be diverted for any other purpose.

We do not have any fund constraint for carrying out the Environment jobs. In case of any emergent requirements not considered in the budget also, our management sanctions the fund for such jobs. Environment funds are not diverted for any other purpose

86 The applicant shall inform the public the project has been accorded environmental clearance by the SEIAA & that the copies of the clearance letter are available with the GPCB & may also be seen at the website of SEIAA/ SEAC/ GPCB. This shall be advertised within seven days from the date of the clearance letter, in at least two local news paper that are widely circulated in region, one of which shall be in the Guajarati language & the other in English. A copy each of the same shall be forwarded to the concerned Region office of the ministry.

Public has been informed about this through local news papers. Copy of the paper cuttings have been submitted to your office, vide letter no.SAC-SHE-E-FL-08, dated:28.05.2016

Copies of the above have been submitted to RO of the ministry, vide our letter no. SAC-SHE-E-FL-11 , dated on 30.11.2015.

87 It shall be mandatory for the project management to submit half-yearly compliance report in respect of the stipulated prior environmental clearance terms & condition in hard & soft copies to the regulatory authority concerned, on 1st June & 1st December of each calendar year.

Regular Half yearly compliance report is submitted to MoEFCC-RO, CPCB-ZO, SEIAA(Gujarat) and GPCB by mail and hardcopies as per the requirement. Last report for the period April-Sept’17 was submitted, vide our letter no. SAC-SHE-E-FL-08/17-18/02 dated 30th November,2017

88 Concealing factual data or submission of false/ fabricated data & failure to comply with any of the condition mentioned above may result in withdrawal of this clearance & attract action under the provision of Environment (protection) Act,1986.

Noted

89 The project authorities shall also adhere to the stipulation made by the GPCB.

Noted

90 The SEIAA may revoke or suspended the clearance, if implementation of the above condition is not found satisfactory.

Noted

91 The company in a time bound manner shall implement these conditions. The SEIAA reserves the right to stipulate additional condition, if the same is found necessary.

Project is already implemented and commissioned on 08.11.2016

92 The project authorities shall inform the GPCB, regional office of MoEF & SEIAA about the date of financial closure & final approval of the project by the concerned authorities & the date of start of the project.

Date of start of the project, approval by concerned authorities and date of commissioning of the project informed to GPCB.

93 This environment clearance Is valid for seven years from the date of issue.

Noted. The project has been executed and the plant commissioned on 08.11.2016

94 Any appeal against environment clearance shall lie with the National Green Tribunal, if preferred within a period of 30 days as prescribed under section 16 of the National Green Tribunal Act,2010.

Noted

Annexure-1

ANNEXURE: 02

SHRIRAM ALKALI & CHEMICALS: JHAGADIA

EFFLUENT WATER ANALYASIS REPORT – CHLOR ALKALI PLANT

OCTOBER-17 TO MARCH-18

Parameter GPCB LIMIT Unit 11.10.17 17.11.17 17.12.17 12.01.18 09.02.18 14.03.18

pH 6 -9 ~~ 7.76 7.76 7.75 7.77 7.78 7.74

Temp. Shall not exceed more than 5° C above Ambient water temperature

° C 32 33 32 33 33 31

Color Odor

All effort shall be made to remove colour & unpleasant odour as far as possible

~~ 27 24 20 Unobjectioable

25 Unobjectioable

23 Unobjectioable

26 Unobjectioable

TSS 100 mg/L 40 49 53 44 47 49

Oil & grease 10 mg/L BDL BDL BDL BDL BDL BDL

COD 100 mg/L 36.6 42.1 40.3 37.6 41.4 44.3

BOD 30 mg/L BDL BDL BDL BDL BDL BDL

Ammo.Nitrogen

50 mg/L BDL BDL BDL BDL BDL BDL

Sulphide as S 0.5 mg/L BDL BDL BDL BDL BDL BDL

Phenolic comp.


Total residual chlorine


*Bio-Assay test done ones in quarter.

Hexavalant chromium

0.1 mg/L BDL BDL BDL BDL BDL BDL

Flourides 1.5 mg/L 0.21 0.23 0.18 0.21 0.24 0.16

Total Kjeldahl Nitrogen (TKN

50 mg/L --- --- 0.06 0.09 0.04 0.81

Nitrate - Nitrogen

50 mg/L --- --- 0.71 0.68 0.67 0.72

Zinc 15 mg/L --- --- 0.0015 0.0011 0.0011 0.0014

Iron 3 mg/L --- --- 0.0024 0.0019 0.0019 0.0016

Copper 3 mg/L --- --- 0.0013 0.0009 0.0011 0.0081

Trivalent Chromium

2 mg/L --- --- 0.03 0.05 0.008 0.07

Manganese 2 mg/L --- --- <0.01 <0.01 <0.01 <0.01

Nickel 3 mg/L --- --- 0.0002 0.0004 0.0004 0.0033

Arsenic 0.2 mg/L --- --- ND ND ND ND

Cyanide, as CN 0.2 mg/L --- --- ND ND ND ND

Vanedium 0.2 mg/L --- --- ND ND ND ND

Lead 0.1 mg/L --- --- 0.0003 0.0007 0.0001 0.0012

Selenium 0.05 mg/L --- --- ND ND ND ND

Cadmium 0.05 mg/L --- --- 0.0004 0.0006 0.0003 0.0057

Mercury 0.01 mg/L --- --- <0.01 <0.01 <0.01 <0.01

Insecticides / Pesticides

Absent ~~ --- --- Absent Absent Absent Absent

Bio-Assay 90% survival of fish in 100% Effluent

~ ~ OK ~ ~ OK ~

ANNEXURE-3

ANNEXURE : 04

SHRIRAM ALKALI & CHEMICALS : JHAGADIA

STACK EMISSION DATA – CHLOR ALKALI PLANT

Oct-17 TO Mar-18

HCL-I HCL-II HCL-III Hypo-I Hypo-II Molten Salt heater-I Molten Salt heater-II

Date of Sampling

HCl Cl2 HCl Cl2 HCl Cl2 Cl2 Cl2 SPM SO2 NOx SPM SO2 NOx

mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3 mg/Nm3

ppm ppm mg/Nm3 ppm ppm

11.10.17 1.02 BDL 1.18 BDL 1.24 BDL BDL BDL 9 8.1 9.2 8 5.4 7.6





14.03.18 1.09 BDL Plant Shut down BDL BDL BDL BDL 6 5.9 8.1 Plant shut down

*Below Detection limit of Chlorine : 0.2 mg/m3


STACK EMISSION DATA – P.F.BOILER AND C.F.B.C.BOILER OF COAL BASED POWER PLANT

OCTOBER-17 TO MAR-18

Date of Sampling

P.F. BOILER C.F.B.C. BOILER

SPM NOx SPM NOx

50 mg/Nm3 50 ppm 50 mg/Nm3 50 ppm

11.10.17 5 4.6 11 7.1

17.11.17 7 6.5 10 5.5

15.12.17 9 4.9 12 4.3

12.01.18 6 5.8 9 7.1

09.02.18 5 2.7 11 3.2

14.03.18 8 4.1 Plant Shut Down

ANNEXURE : 05


AMBIENT AIR MONITORING EMISSION DATA Oct-17 TO Mar-18

Date of

Sampling Area

100 60 80 80 200 100

SPM <10mic

SPM <2.5mic SO2 NOx Hcl Cl2

mic.g/m3 mic.g/m3 mic.g/m3 mic.g/m3 mic.g/m3 mic.g/m3

11.10.17



N.TSDF 54 41 29.6 33.9 BDL BDL

17.11.17


Nr.main gate 58 37 27.9 30.1 BDL BDL

N.TSDF 56 43 31.2 34.1 BDL BDL

15.12.17



N.TSDF 61.0 40.0 33.9 36.2 BDL BDL

12.01.18



N.TSDF 58.0 41.0 28.8 31.8 BDL BDL

09.02.18



N.TSDF 62.0 39.0 31.4 34.4 BDL BDL

14.03.18



N.TSDF 59.0 36.0 30.7 33.9 BDL BDL

ANNEXURE :06

ANNEXURE-7

Annexure#8

MANIFEST COPY OF HAZARDOUS WASTE DISPOSAL

Annexure#9

Hazard Identification , Risk Assessment & Determining Controls.

1.0 PURPOSE:

To identify potential hazards in the work place / work activity. To evaluate & document the severity rating / factor of the risk involved. To develop a system that implements and monitors control measures and

ensures that activities are carried out in a safe manner.

2.0 PROCEDURE:

Sr. No.

Activity

Responsibility

2.1

This procedure deals with the following objective :

1. Methodology to identify hazards

2. Awareness / training of hazards identification

3. Team identification

4. Basis for Hazard identification & Risk assessment

5. Hazard identification & Risk assessment

6. Corrective measures / control measures

7. Review mechanism

--

2.2 Methodology to identify hazards :

In SAC , hazards identification and risk assessment is done in the following manner :

1. External : Hazop study by competent agency.

2. Internal : Hazop : by internal trained

professionals team.

HIRA : by internal trained

professionals team.

HOD/ Section In-Charge / In–

Charge -SHE

2.3 Awareness / Training :

( IOSHR / HAZOP / HIRA )

Training sessions are conducted by external competent agency for employees.

Refresher training sessions are conducted by our internal trainer.

HOD/ Section In-Charge / In–

Charge -SHE

2.4 Core team selection :

Core team from the trained employees is appointed by HOU in consultation with Sr.safety resource and SHE – in charge.

Prescribed format for HAZOP study as well as HIRA is available as per Annexure-3

Core group members carryout field assessment / interactions / consultations / records review in their respective departments (discussing with a cross section of employees at all levels) for identification of OHS Hazards / Risks

HOD/ Section

In-Charge / In–Charge -SHE

2.5 Basis for Hazop / HIRA :

Broadly , for carrying out Hazop / HIRA covers the following :

All routine and non-routine activities carried out in SAC.

Any change / modification in process / equipment / installation

Any reporting of accident.

Legal requirement etc.

Detailed information on the basis is explained in Annexure – 1

Core group / HODs and section in charges

2.6 2.7

Hazard identification & Risk assessment

Please refer Annexure- 2 for procedure followed for HIRA.

Control measures / corrective actions : Based on the risk rating , priority is decided for taking corrective

actions. Activities showing highest risk rating is given top priority. All resources are sanctioned and provided by the management to

work on the activities as mentioned above. While deciding the corrective actions , the following hierarchy of

controls is considered :

1. Elimination 2. Substitution 3. Engineering control 4. Administrative control 5. Use of personal protective equipments

Corrective actions / control measures are listed and circulated with responsibility, target dates and discussed with HOU / Sr. safety resourse / In-charge-SHE / HODs. These actions are implemented and reviewed.

All supervisors ensure that all workmen, while carrying out various jobs follow applicable Safe work Procedures.

Based on RA , safe working procedures / OCPs are made by all departments and kept on server , accessible to all for reference and use.

Job safety analysis is conducted for critical jobs and necessary training is provided to concerned people. Corrective measures taken / control measures are monitored and discussed reviewed through various mechanisms such as :

Plant safety inspections Plant safety audits Safety committee meetings Plant rounds by SR / SC.

Core group / HODs and section in charges

Annexure -1

BASIS FOR IDENTIFICATION OF HAZARDS & RISK ASSESSMENT

Hazard identification team considers the following types of hazards while identifying OHS Risks

of all Activities / products and services of SAC.

Chemical

Physical

Ergonomic

Biological

Psychological

Monotonous

Work at predetermined rate

Influence of shift work

Overtime loading and fatigue

Heat exposure

Accidental

Unsafe conditions & unsafe practices

Any other relevant aspect

Activities done by lone workers.(Buddy system to be introduced)

During IOHSR (Initial Occupational Health & safety review ) the following have been considered:

Records of previous incidents/ accidents including results of investigation. Inputs from safety audits. All routine & non-routine activities where hazards & risks are involved. Existing OHS procedures and practices. Facilities (infrastructure, equipment & material) available at work place. People having access to the work place (employees, contractor’s workers and visitors).

Human behavior, capabilities and other human factors. Identified hazards originating out side the work place capable of adversely affecting the

health & safety of persons under the control of the SAC within the work place. Hazard created in the vicinity of the work place by work related activities under the control

of SAC.

Changes or proposed changes / temporary changes in SAC’s activities or materials. Any applicable legal obligations relating to risk assessment and implementing the necessary

control.

The design of work areas, process, installations, machinery/equipment, operating procedures and work organization, including their adaptation to human capabilities.

Hazards which can be controlled by SAC Hazards where SAC can influence the control. Hazards / Risks associated with standard operating procedures Hazards / Risks associated with deviation from normal condition / SOP Risks which are contained or mitigated by invoking emergency procedure and have potential

for foreseeable incidents/ accidental situations.

Annexure - 2

RISK ASSESSMENT

Risk Assessment is estimation of the Hazard Potential existent in the Workplace. This tool gives

an idea of the Severity of the Hazard and allocates preferences for remedial actions.

Risk Assessment involves Hazard identification in the Workplace and evaluation of the severity

factor for the risks involved. The Hazard Potentials are identified and actions are initiated to

eliminate / control/ reduce the Risks.

RA is carried out by a group of trained personnel.

Characteristics of Risk Assessment

The Structure of the Risk Assessment based on the above, is as follows:

a) Identification of the Hazard.

b) To decide: who might be affected and how.

c) Evaluation of Hazard :

The findings are recorded in the Risk Assessment Form (SAC/deptt./ No.) attached as annexure–

1.

Instructions to fill the Form No.( SAC/deptt./ No.) are as follows :

RA Form No. (SAC/deptt./ No.) is department specific for the purpose of tracking. Work equipment / Activity is the specific area where Risk Assessment is carried out (e.g.

Cell house) Process/ location where the specific activity for which the Risk Assessment is carried is filled

appropriately (e.g. Operation of membrane welding machine). The date of current Risk Assessment and next review (review once in a year or if any

incident occur than review the activity with hazard & associated Risk) The name & signature of the person carrying out & checking of the Risk Assessment form. The hazards are identified on the basis of the list of work activities of each department &

are filled in the column "Hazard Identification". The hazards are filled in the column "Hazard Identification". The possible accident / ill health & persons at risk are in the column "Hazard Identification". Control measures, which already exist in the workplace for minimizing the risk arising from

the identified hazard, are listed in the “Risk Evaluation” column in existing control measures column.

To determine control / reduction of the risk, the following hierarchy of controls is followed :

a) Elimination b) Substitution c) Engineering controls d) Signage/Warnings,& / or Administrative controls e) Personal protective equipments.

The Likelihood of the hazard occurrence is filled in accordance with the table no.1 (Likelihood) in the “Risk Evaluation” column.

The Frequency of Exposure of persons is filled in accordance with table no.2 (Frequency) in the “Risk Evaluation” column.

The Extent of injury as a possible consequence due to the identified hazard is filled in accordance with table no.3(Possible Consequence – Severity) in the “Risk Evaluation” column.

The Extent of Property Damage as a possible consequence due to the identified hazard is filled in accordance with table No. 4(Possible Consequence - Property Damage) in the “Risk Evaluation” column.

The risk rating of the event, which may occur due to the identified hazard, is filled in accordance with table no.5 in the “Risk Evaluation” column.

The lowest number from Possible Consequences i.e. Extent of Injury, Property Damage & Severity is considered for plotting on the Nomogram

Procedure for plotting a Nomogram

Plot the likelihood and exposure points on the nomogram. Connect these two points and extend the line to tie line using a scale. Plot the lowest number from possible consequence on the nomogram. Connect the tie line point to the possible consequence point and extend to the risk factor line using a scale.

The point of intercept on the risk factor line gives the risk factor.

The risk rating classification (from table no. 5) is recorded in the risk rating column assessment form in risk rating in the “Risk Evaluation” column.

The priority of the job is known from the table 5 based on the risk rating. Actions :

o The possibility of elimination of hazard by engineering measures is first evaluated. o If it is not possible to eliminate the hazard, then engineering control procedures are

applied to minimize risk. o Based on the above the action to be taken is noted along with responsibility and

target date in the Risk control column in Risk assessment form. o The risk assessments carried out are recorded in risk assessment file. o The risk assessments are also circulated to In-charge SHE for discussion in the

safety committee meeting. o Safe work procedures are written and followed.

Annexure - 3

Shriram Alkali & Chemicals : Jhagadia

Activity Based - Risk Assessment Form

Risk Assessment Form # :

Department /

Section :

Activity / Work Equipment : Process / Location :

Date of Assessment : Next Review Date :

Risk Assessment Carried out by :

Risk Assessment Checked by :

Hazard Identification Risk Evaluation Risk Control

Sr.

No.

Work

Activity Hazards

Possible

accident/ill

health &

persons at

risk

Existing

Risk

Control

Measures

(if any)

Lik

eli

ho

od

(R

ef.

Ta

ble

1)

Ex

po

su

re (

Ref.

Ta

ble

2)

Possible Consequences

Ris

k R

ati

ng

( R

ef.

Ta

ble

5) Additional Risk

Control Actions

to reduce risk

severity & / or

likelihood

Resp

on

sib

ilit

y

Ta

rge

t D

ate

Ex

ten

t o

f in

jury

(R

ef.

Ta

ble

3)

Pro

pe

rty D

am

ag

e (

Re

f. T

ab

le 4

)

SAC-MR-F-31 (1.0) Signature of Risk Assessment Leader

Key to Risk Assessment

Table 1

Code # Likelihood

1 Imminent / Certain Expected to occur at least once per week or more

often (> 50 occurrences per year)

2 Very Likely Expected to occur on an average once per month (10

occurrence per year)

3 Likely Expected to occur on an average once per year (1


4 Unlikely Expected to occur several times during the life of the

equipment/facility, typically once every ten years (0.1


5 Very Unlikely Not likely to occur during the life of the

equipment/facility, but possible - typically once every

100 years (0.01 occurrence per year)

6 Practically Impossible Not likely to occur during the life of the facility, but

possible - typically once every 1000 years (0.001


Table 2

Code # Exposure

1 Very Rare Yearly or less

2 Rare A few per year

3 Unusual Once per month

4 Occasional Once per week

5 Frequent Once per day

6 Continuous Continuously

Table 3


Code # Extent of Injury

1 Many Fatalities Event causes >10 fatalities

2 Multiple Fatalities Event causes >1 fatalities

3 Single Fatality Event causes single fatality

4 Major Injury Event causes major disability (>5 days LTI)

5 Loss Time Event causes moderately injury (<5 days LTI)

6 Minor Injury Event causes first-aid injuries

Table 4


Code # Property Damage

1 > Rs. 10,000,000/- Damage

2 > Rs. 1,000,000/- Damage

3 > Rs. 100,000/- Damage

4 > Rs. 10,000/- Damage

5 > Rs. 1,000/- Damage

6 > Rs. 100/- Damage

Table 5

Risk Rating

Risk Rating

Code Risk Factor Risk Level Priority of Action /

Frequency of Monitoring

1 > 325 Very High Risk Immediate

2 > 160 High Risk Within a Week

3 > 70 Medium Risk Within a Fortnight

4 > 18 Low Risk Within a Month

5 < 18 Trivial Risk Within two Months

ANNEXURE: 10


Location of Chlorine detectors:

Sr. No. Location of Chlorine detectors

1 Chlorine storage tank A

2 Chlorine storage tank C

3 Chlorine storage tank D

4 Chlorine storage tank E

5 Old Bottling shed Filling post

6 Old Bottling shed De-gassing area

7 Cell house, Electorlyser A

8 Cell house Electorlyser D

9 Between Electorlyser E & F

10 Between Electorlyser G & H

11 Between Electorlyser J & K

12 Between Electorlyser L & M

13 Between Electorlyser N & O

14 Old Chlorine Bottling Shed

15 Old Bottling shed De-gassing area

16 HCl Unit-1 Top

17 HCl Unit -2 Top

18 HCl Unit -3 Top

19 HCl Unit -4 Top

20 Hypo Stack(Old)

21 Hypo Stack(New)

22 Garo Compressor

23 Opposite to post 15(New shed)

24 At post 13(New shed)

25 Opposite to post 07(Plant-C)(New shed)

26 Opposite to Degassing point(Plant-D)(New shed)

27 At Degassing point(New shed)

28 Opposite to Degassing point(Plant-C)(New shed)

29 Old Material gate

30 Power plant control room

31 Near Chlorine Pump t Storage area

32 Near to Switch yard

For Monitoring and detection of Hydrogen leakage, sensors are installed at

strategic location in Chlor-Alkali plant. Alarms are provided on DCS for quick

response.

Hydrogen Sensors

Sr. No. Location of Hydrogen sensor

1 Hydrogen compressor A

2 Hydrogen compressor B

3 Hydrogen compressor C

4 Hydrogen compressor D

5 Hydrogen compressor E

6 Hydrogen compressor F

7 Hydrogen compressor G

8 Hydrogen compressor H

9 Hydrogen compressor I

10 Hydrogen Aarti Bank A

11 Hydrogen Aarti Bank B

12 Hydrogen compressor J

13 Hydrogen compressor K

14 Hydrogen compressor L

15 Hydrogen compressor M

16 Hydrogen compressor N

ANNEXURE-11

ANNEXURE-12

ANNEXURE-13

Annexure-14

EIA - ENVIRONMENT MANAGEMENT PLAN RECCOMENDATION

STATUS

Sr. No.

Expected Aspect due to proposed activity

Management Plan Status

Air Environment

1 PM, SO2 & NOx emissions from Power Plant

Provision of adequate stack height ~ 115 m will be ensured.

115 M stack height provided

Provision of adequate capacity with additional one field ESP will be ensured

Provided

Provision of online PM will be ensured Provided Ensure Ash management plan is in place and followed

Followed

Ensure periodic monitoring of stacks for PM, SO2, NOx concentrations

Online monitoring done & data link with cpcb server.

2 HCl & Cl2 emissions from HCl & Hypo plant Operation.

Provision of adequate stack height ~ 30 m will be provided and scrubbing system will be attached to vents

Caustic scrubber provided

Ensure periodic monitoring of stacks for HCl and Cl2 concentrations.

Online monitoring done & data link with cpcb server

3 Cl2 emissions during Chlorine Liquefaction, Storage, Filling & Dispatch.

Ensure SOP's, OCP, Onsite emergency plan and Offsite emergency plan is followed during emergency

Followed

Ensure Fire fighting & emergency response team will be at place

Deputed

Water Environment

4 Generation of depleted brine

The depleted brine will be recycled back into the process

Complied

5 Generation Caustic and Brine leakage from Electrolyser assembly

Proper floor slope & connection to the recovery system made to recover leaked caustic / brine back to system

Complied

6 Disposal of wash water during Hydro testing of Chlorine tonners

Generated waste water will be reuse in the process

Generated waste water reuse in the process

7 Leachate generation from Secured Landfill facility

Leachate will be reused in the process Complied

8 Waste water generation from Cooling tower blow down

Waste water will be discharged into GIDC drain for deep sea disposal.

Complied

9 Waste Water discharge from final discharge tank of ETP

Online pH monitoring system with control valve will be provided.

Provided

10 Acidic and Alkyl waste water form operation of DM plant

Recovery of segregated alkaline and acid effluent will be implemented.

Implemented

11 Workforce requirement for proposed plants

Septic tank and Soak pit will be Provided.

Provided

12 Mixing of contamination form Process, chemical fuel storage and handling area Effluent treatment plant and Salt yard with storm water

All Process, chemical fuel storage and handling area will have proper bunds so that contaminated run-off cannot meet the storm-water drainage system Separate drainage will be provided for storm water and effluent water Parapet wall and bumps to prevent wash out of salt from salt yard and also separate storm water line will be provided to collect salt water which will reused in the process

Provided Provided Provided

13 Wash out of coal in storm water drain

Coal yard will be covered during monsoon

Complied

Land Environment

14 Generation of Debris and scraps during site Preparation.

Debris will be used in filling of low lying area and scraps will be sold to registered and authorized vendors.

Debris will be used in filling of low lying area and scraps are sold to registered and authorized vendors.

15 Domestic food waste generation

Reused as manure in green belt development after vermiculture

Complied

16 Generation of brine sludge

Brine sludge will be disposed off to landfill facility within the premises as per MSW Rules

Complied

17 Generation of Discarded Chlorine tonners

Tonners will be cut and given to authorized vendors for sale as scrap

Complied

18 Emission of Cl2 and HCl

Scrubbers will be provided to control the emission of Cl2, HCl within norms

Provided

19 Generation of Fly ash Proper storage facilities (Storage Silos) will be provided and will be given to brick / cement industries as per Fly Ash Notification

Complied

20 Generation of Sludge from sump cleaning of cooling tower and ETP sludge

Sludge will be disposed into landfill facility within the premises as per MSW rules

Complied

21 Generation of discarded bags / barrels / containers

Will be given to GPCB authorized vendors

Complied

22 Generation of used oil, lubricants etc

Will be given to authorized Refineries as per HW rules.

Complied

Noise Environment

23 Vehicular movement for transportation of materials and equipment

PUC Certified vehicles will be ensured during construction and operation phase.

Complied

24 Start-up and shutdown activities like operation of equipment for all the proposed plants (Chlor- Alkali and Captive Power Plant

Proper maintenance of equipment will be done. Inbuilt acoustic enclosures will be ensured. Proper PPE like Ear Plugs & ear muffs will be provided.

Done as per schedule Provided Provided

25 Operation of Turbine receiving steam from boiler

Proper acoustic enclosures will be provided. Proper PPE like Ear Plugs & ear muffs will be provided

Provided Provided

dcm shriram limited

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