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POLICIES AND LEGISLATION

2.1 BACKGROUND

The devastating floods of 1987 and 1988, and the reappearance of concern about

environmental issues, have been in improving environmental conditions of the country

through broadcasting of a numbers of policies and legislation in the country. All of the

policies or legislation aimed at the conservation and protection of the environment. The

existing policies and legislation, which are relevant to the environment, are described in the

following sections.

2.2 POLICIES

2.2.1 INDUSTRIAL POLICY, 1991

The Industrial Policy, 1991 contains the following clauses in respect of environmental

protection

To conserve ecological balance and prevent pollution during industrialization To take effective steps for pollution control and conservation of environment

during industrialization.

To ensure embodying or indispensable pollution control and preventive measures by

industrial investment project endangering environment.

2.2.2 NATIONAL ENVIRONMENTAL POLICY, 1992

Bangladesh National Environmental Policy, 1992 was approved in May, 1992 and made the

basic framework for environmental action, together with a set of broad action guidelines.

Environment Policy 1992 provides the broader framework of sustainable development in the

country. It also states that all major undertakings, which will have bearing on environment

including setting up of an industrial establishment, must undertake IEE/EIA before they

initiate the project. Environment Policy delineates Department of Environment (DoE) as the

approving agency for all such EMP/EIAs to be undertaken in the country.

Key elements of the policy are: (As objectives, Section 2).

Maintenance of the ecological balance and overall progress and development of the country through protection and improvement of the environment.

Protecting the country from any natural disaster.

Identification and regulation of all types of activities, which are polluting and degrading the environment.

Ensuring sustainable use of all natural resources. Active participation with all environment related international agencies.

ENVIRONMENTAL POLICY ADDRESSES THE FOLLOWING STRATEGIES FOR INDUSTRY: (SECTION 3.2).

To adopt corrective measures in phases in industries that causes pollution. To conduct Environmental Impact Assessments (EIAs) for all proposed public

and private industries. To ban the establishment of any industry that produces goods that cause

environmental pollution. To ensure sustainable use of raw materials in industries, and to prevent their

wastage/spillage etc.Section 3.7 “Forest, Wildlife and Biodiversity” of the same Policy requires:

Conserve Wildlife and “Biodiversity, strengthen related research and dissemination and exchange of knowledge in these areas.

Conserve and develop wetlands and protection of migratory birds.

Section 5 “Institutional arrangement” requires:

Department of Environment will review and approve all environmental Impact Assessments.

2.2.3 National Conservation Strategy

National Conservation Strategy (GoB/IUCN, 1992) was drafted in late 1991 and submitted to

the Government in early 1992. This was approved in principle; however the final approval of

the document is yet to be made by the cabinet. It underwent a number of modifications over

the last five years, and is waiting to be placed before the cabinet finally sometime in late

September 1997. For sustainable development in industrial sector, the report offered various

recommendations; some of those are as follows:

Industries based on nonrenewable resources should be made to adopt technology, which conserves raw materials, and existing industries should be given incentives to install technical fixed to reduce wastage rate.

All industries, especially those based on imported raw materials, should be subjected to EIA and adoption of pollution prevention/control technologies should be enforced.

No hazardous or toxic materials/wastes should be imported for use as raw material.

Import of appropriate and environmentally sound technology should be ensured. Complete dependence on imported technology and machinery for industrial

development should gradually be reduced, so that industrial development is sustainable with local skills and resources.

2.2.4 National Environmental Management Action Plan (NEMAP)

National Environmental Management Action Plan, also referred to as NEMAP (GoB, 1995)

is a wide-ranging and multi-faceted plan, which builds on and extends the statements set out

in the National Environmental Policy. NEMAP was developed to address issues and

management requirements during the period 1995 to 2005, and sets out the framework within

which the recommendations of the National Conservation Strategy are to be implemented.

NEMAP has the broad objectives of:

Identification of key environmental issues affecting Bangladesh; Identification of actions necessary to halt or reduce the rate of

environmental degradation; Improvement of the natural and built environment; Conservation of habitats and biodiversity; Promotion of sustainable development; Improvement in the quality of life of the people.

One of the key elements of NEMAP is that sectoral environmental concerns are identified. In

outline, the environmental issues of the industrial sector include the following:

Pollution arising from various industrial processes and plants throughout the country causing varying degrees of degradation of the receiving environment (Air, Water and Land).

There is a general absence of pollution abatement in terms of waste minimization and treatment.

Low level of environmental awareness amongst industrialists and entrepreneurs.

Lack of technology, appropriate to efficient use of resources and waste minimization leading to unnecessary pollution loading in the environment.

Economic constraints on pollution abatement and waste minimization such as the cost of new technology, the competitiveness of labor, and intensive production methods as compared to more modern methods.

Concentration of industry and hence pollution in specific areas which exacerbate localized environmental degradation and exceed the carrying capacity of the receiving bodies.

Unplanned industrial development has resulted in several industries located within or close to residential areas, which adversely affects human health and quality of human environment.

Establishment of industries at the cost of good agricultural lands and in the residential areas.

Lack of incentives to industrialists to incorporate emission/discharge treatment plant in their industries.

2.2.5 Conventions, Treaties and Protocols

Bangladesh has consented to be bound by the terms of some 21 of the 44 principal

international conventions, treaties and protocols relating to the environment (Islam, 1996).

Those with partial and indirect relevance to industrial projects are the Paris convention of

1972 concerning the protection of the World cultural and natural Heritage, Convention

concerning safety in the use of chemicals at work. Geneva 1990, Biodiversity convention,

Rio-de-Janeiro, 1992, Convention concerning occupational health services, Geneva 1985 etc.

2.3 National Legislation

2.3.1 Bangladesh Environmental Conservation Act, 1995 and Environmental Conservation Rule, 1997

Environment Conservation Act, 1995 (ECA ’95) is currently the main legislation document

relating to environment protection in Bangladesh. Under the Act, no industrial unit or project

shall be established or adopted without obtaining environment clearance, in the manner

prescribed by the Rules.

Environment Conservation Rules, 1997 has made categorization of industries and projects,

and identified the types of Environment assessments needed against respective category of

industries or projects.

2.3.1.1 Environment Conservation Act, 1995

The Environment Conservation Act, 1995 is officially known as the ‘Bangladesh

Environment Conservation Act 1995’, promulgated for environmental conservation,

environmental standard development and environment pollution control and abatement. This

act repealed the Environment Pollution Control Ordinance, 1977. The ECA ’95 is currently

the main legislative framework document relating to environmental protection in Bangladesh.

The main objectives of ECA ’95 are –

Conservation and improvement of environment, and Control and mitigation of pollution of environment.

The main strategies of the act can be summarized as –

Declaration of ecologically critical areas and restriction on the operation and process, which can or cannot be carried/initiated in the ecologically critical areas.

Regulation in respect of vehicles emitting harmful smoke for the environment. Environmental clearance. Regulation of the industries and other development activities’ discharge permit. Promulgation of standards for quality of air, water, noise and soil for different

areas for different purposes. Promulgation of standard limit for discharging and emitting waste. Formulation and declaration of environmental guidelines.

The Department of Environment (DoE) is executing the Act. Director General (DG) heads

DoE. The power of DG, as given in the Act, may be outlined as follows:

Identification of types and causes of environmental degradation and pollution. Integrating the investigation and research regarding environmental

conservation, development and pollution. Power to close down the industries/development works considered harmful to

human life or the environment. The operator does have the right to appeal and procedures are in place for this. However, if the incident is considered an emergency, there is no opportunity for appeal.

Power to declare an area affected by pollution as an ecologically critical area. DoE governs the types of work or process, which can take in such an area.

Similar to an aforementioned clause, if any part of the environment is polluted/damaged by operations, the DG can request or force the operator to make rectifying arrangements.

Operators must inform the DG of any pollution incident or ‘near miss’.

In the case of an accidental (pollution) event, the DG may take control of an operation and

the respective operator is bound to help. The operator is responsible for costs incurred (and

possibly compensation).

Before new project can go ahead as stipulated under the rules, they must obtain an Environmental Clearance from the Director General. An appeal procedure does exist for those promoters who fail to obtain clearance;

Failure to comply with any part of this Act may result in punishment by a maximum of 5 years imprisonment or a maximum fine of Tk.100, 000 or both.

2.2.2.2 Environment Conservation Rules, 1997

These are the first set of rules, promulgated under the Environment Conservation Act, 1995.

Among other things, these rules set (i) the National Environmental Quality Standards for

ambient air, various types of water, industrial effluent, emission, noise, vehicular exhaust etc.

(ii) requirement for and procedures to obtain environment clearance (iii) requirement for

IEE/EIA according to categories of industrial and other development interventions.

According to the rules, any project/development intervention of the Amber/Orange-B and

Red Category is to obtain environmental clearance in two steps – first to obtain site/location

clearance (based on the application along with necessary papers, including the Initial

Environmental Examination (IEE) which will contain the scope of work of the proposed EIA,

if required) and then to obtain Environmental Clearance (by submitting the application along

with necessary papers including the EIA). The DoE may take up to sixty days to issue the site

clearance (from the date of receiving the application), sixty days to approve the EIA and

thirty more days to issue the Environmental Clearance, provided everything goes well. For

projects of Amber/Orange-B category this is also a two-stage process, with or without the full

scale EIA.

This may be quite a lengthy process if (DoE) uses the full extent of the time limits. The rules

however provide the DG a discretionary authority to grant ‘Environmental Clearance’ to an

applicant exempting the requirement of site/location clearance, if DG considers it

appropriate. [Section 7(4), 2nd Paragraph, Page 3105 of the Bangladesh Gazette of 27 August

1997].

2.3.2 Other Legislation

Bangladesh legislation contains numerous laws, which are indirectly related to the

environment. A compendium of these laws has been prepared recently (Farooque & Hasan,

1996). Other legislation, which is relevant, to various aspects of industrial project in general

include:

The workman’s Compensation Act of 1923, which provides legal basis for the payment by certain classes of employers to their workmen of compensation for injury by accident.

The Forest act of 1927 (amended in 1989), which provides legal protection for wild flora and forest.

The Factories Act of 1965, which insists to keep clean and hygienic environment within the factories.

2.4 Bangladesh Environmental Standards

At present there are environmental standards in operation in Bangladesh also Promulgated

under the Environment Conservation Rules 1997. There are standards prescribed for varying

water sources, ambient air, noise, odor, industrial effluent and emission discharges, vehicular

emission etc.

The Bangladesh standards intend to impose restrictions on the volume and concentrations of

wastewater/solid waste/gaseous emission etc. discharged into the environment. In addition a

number of surrogate pollution parameters like Biochemical Oxygen Demand (BOD), or

Chemical Oxygen Demand (COD); Total Suspended Solids (TSS) etc. are specified in terms

of concentration and/or total allowable quality discharged in case of waste water/solid waste.

Additionally specific parameters depending on the manufacturing process are specified such

as Phenol, Cyanide, Copper, Zinc, and Chromium etc. Air emission quality standards refer

mostly to concentration of mass emission of various types of Particulates, Sulfur Dioxide,

and Oxides of Nitrogen and in some cases Volatile Organic Compounds and other

substances.

The Bangladesh standards in general are less stringent compared to the developed countries.

This is in view to promote and encourage industrialization in the country. The Bangladesh

standards are not for any specific period of time. There is no provision for partial compliance

too.

The standards that are commonly known as Environmental Quality Standards (EQS) are

legally binding. There is a separate schedule on industry specific standards, other than the

general industrial emission and effluent standards. This schedule covers a wide range of

industries fertilizers, tannery, integrated textile, food, cement etc. In the present case, the

surface water standards for liquid discharge, noise and ambient air of the EQS will

apply mostly. The present project under consideration is to comply with these and if

necessary with other related standards during its operation.

For ready reference, the Bangladesh standards for ambient air, noise and inland surface water

standards have been attached herewith as separate Tables; Table – 2.1 to Table- 2.5. These

are all in very authentic translation from original Bengali citing the very specific source.

Table - 2.1: Standards for Inland surface water

[See Rule 12]

Best Practice based Parameter

Classification pH BOD (mg/l) DO (mg/l) Total Coliform number/100

1.Source of drinking water for supply only after disinfecting

6.5-8.5 2 or less 6 or above 50 or less

2.Water usable for recreational activity 6.5-8.5 3 or less 5 or more 200 or less

3.Source of drinking water for supply after conventional treatment


4.Water usable by fisheries 6.5-8.5 6 or less 5 or above -

5.Water usable by various process and cooling


6.Water usable for irrigation 6.5-8.5 10 or less 5 or above 1000 or less

NOTE:1. In water used for pisiculture, maximum limit of presence of ammonia as Nitrogen is

1.2 mg/l.2. Electrical conductivity for irrigation water –2250 micro mhos/cm (at a temperature of

250 C); Sodium less than 26%; boron less than 0.2%.

PARTICULATE MATTER

Steam Generation Capacity (ton/hour)

Not to exceed, mg/Nm3

Less than 2 t/h 1200 mg/Nm3

2 t/h to less than 10 t/h 800 mg/Nm3

10 t/h to less than 15 t/h 600 mg/Nm3

15 t/h and above 150 mg/Nm3

Source: Bangladesh Gazzet (Thursday, August 28, 1997), Ministry of Forest & Environment.

Table - 2.2 : Standards for Ambient Air[See Rule 12]

Sl. No.

Area Class Particulate Matter (SPM)

SO2 CO NOx

a. Industrial & mix area 500 120 5000 100b. Commercial & mix area 400 100 5000 100c. Residential & rural area 200 80 2000 80d. Sensitive area 100 30 1000 30

Note:

(1) Sensitive area: National Monument, Health complex, Hospital, School, Govt. define area if exists.

(2) Industry situated near residential, rural and sensitive area should not emit may has which exceed the limit of item (c) & (d).

(3) Particulate matter means diameter of air particles of size 10 micron or less.

Source: Bangladesh Gazzet (Thursday, August 28, 1997), Ministry of Forest & Environment.

Table - 2.3 : Standard for Noise

[See Rule 12]Sl. No. Area Class Day Time

(dBA)Night Time(dBA)

a. Silent area 45 35b. Residential area 50 40c. Mix area (mainly residential and

commercial & industrial area)60 50

d. Commercial area 70 60e. Industrial area 75 70

Note:(1) Daytime start from 6:00 am morning and end at 9:00 pm night.(2) From night 9:00 pm to 6:00 am morning; identify as nighttime.(3) Silent areas identify as a 100-meter radius from the location of any hospital, school or

any special area. In silent all types of vehicle horn or any loudspeaker use are restricted.

Source: Bangladesh Gazette (Thursday, August 28, 1997), Ministry of Forest & Environment.

Table – 2.4: Standard for OdorSCHEDULE-8[See Rule 12]Sl. No. Parameter Unit Valuea. Acetaldehyde Ppm 0.5-5b. Ammonia Ppm 1 – 5c. Hydrogen sulfide Ppm 0.02 – 0.20d. Methyl disulfide Ppm 0.009-0.10e. Methyl mercapted Ppm 0.02-0.20f. Methyl sulfide Ppm 0.01-0.20g. Styrene Ppm 0.4-2H Tri-methyl-amin Ppm 0.005-0.07

Note:(1) Those discharge stack height above 5 meter; for those case control value are given

below:Q = 0.108 x He2 ppm (where Q = gas discharge rate Nm3/hour)He = discharge stack height (meter)

(2) For warning purpose minimum parameter value will be consider and for judiciary action maximum parameter value will be consider.


3. PROJECT DESCRIPTION

3.1 LOCATION OF THE PROJECT AND ITS SUITABILITY

The project is located at Rupatoli, Barisal. The factory is in a growing industrial area. The project is located on the east side of Dhaka-Barisal Highway and around 5 Km far from zero point. It enjoys all kinds of infrastructural facilities like Electricity, Gas, Telecommunication, Transportation and others due to the developing industrial zone. In this sense the project site is suitable for this kind of industry. The plant location is shown in the location map.

Fig: Location Map of Opsonin Pharma (source: delineation of the map from Google Ma, Open Street Map, 2015)3.2 TYPE OF THE PROJECT

The project in the name and style of Opsonin Pharma Ltd. is a medicine producing industry, which is a private Limited Company. The project has been designated on the basis of local and imported equipment. The total fixed cost of the project has been estimated at Tk. 450 core.

3.3 PROJECT JUSTIFICATION

The project, Opsonin Pharma Ltd. at Rupatoli, Barisal, and Bangladesh is a medium scale industrial unit in regard to both capital investment and size of the plant.

The project envisages setting up of a medicine manufacturing plant. At 100% capacity utilization, it would be capable of producing 100 TPM. In a year there will be 330 working days. Based on market demand the production will vary. Setting up of the project has become very essential due to price competitiveness of these products.

3.4 PRODUCTION CAPACITY

At 100% capacity, it would be capable of producing 100 TPM.

Table – 3.1: Brief Description of the Project.

1. Name of the project : Opsonin Pharma Limited2. Project type : Medicine Manufacturing Unit3. Project proponent : 4. Project location : Rupatoli, Barisal, Bangladesh5. Final product : Best quality medicine7. By product, if any : Nil8. Plant Capacity (100 % capacity)

: 100 TPM

9. Raw materials : Section – 3.610. No. of employees : 2000 including all11. Project cost : Tk 250 crore12. Power Requirement : Consumption 850KW; Source – PDB & Own

Generator.13. Water requirement : 20,000 liter per day; Source – Kriton Khola River 15. Total area of land : 400 Acars16. Total covered area : Almost full

3.5 RESOURCES REQUIREMENT

3.5.1 LAND REQUIREMENT The total plot area of the project site is 4500 acre. The site layout is shown in Table 3.3.

S. No. Description Area in acre % of Occupancy 1. Existing building 57.32 14.33 2. Storage yard 13.56 3.39 3. ETP (Proposed) 20.92 5.23 4. Open space 168.00 42.51 5. Greenbelt area 138.04 34.54 Total 400 100

3.5.2 POWER & BACK-UP POWER REQUIREMENT

The total power requirement by the proponent is 112 kVA supplied through PDB. As backup power, 1 D.G set of 110kVA will be installed on site. Details on the D.G set are shown below,

Table 3.4 Details on D.G setS. No. Capacity Stack height (m) Stack dia (mm) 1 110 kVA 2.5 100

3.5.3 MANPOWER REQUIREMENT

The proposed facility will employ 2000 personnel including administrative, technical & contract workers.

3.5.4 WATER REQUIREMENT

Water requirement during the operation phase will be sourced from Kriton Khola River.Water demand can be categorized as, i. Process requirement – 5 KLD fresh water ii. Domestic requirement – 3.4KLD fresh water Breakup of water requirement has been detailed below,

Table 3.5 Breakup of water consumption in the facilityS. No.

Particulars

Water consumption (KLD)

Wastewater generation (KLD) Disposal method

Domestic 1. Personnel 3.4 2.7 Septic tank

followed by soak Subtotal 3.4 2.7 Industrial

2. Process 2 0.4 Effluent treatment plant 3. APCE 0.5 0.5

4. Cooling 2 0.3 (blow down) 5. Washing 0.5 0.5

Subtotal 5 1.7 Disposal

Treated effluent quantity for greenbelt development 1.7

Greenbelt development

3.6 RAW MATERIAL REQUIREMENT AND STORAGE DETAILS

S.No

Name of the Raw material

Purity grade (%)

Physical State

Quantity consumed (TPD)

Maximum storage capacity (MT)

Storage method

1. Anisoyl chloride* 99.5% Liquid Respective quantities have been shown in the mass balance table for each product manufactured

1.0MT HDP drum 2. 2-butyl-5-

nitrobenzofuran* 98-99% solid 1.0MT HDP drum

3. AlCl3* 99.9% solid 1.0MT Fiber drum

4. Dichloromethane* 99.5% Liquid 2.0MT G-8drum

5. K2CO3* 98-99% Solid 1.0MT Polythen bag

6. Toluene 99.5% Liquid 2.0MT MS drum

7. 1-chloro-3-di-n-butylaminopropane*

98-99% liquid 1.0MT HDP drum

8. 1-tosyl-1H-indole-5-carbonitrile*

98% solid 1.0MT HDP drum

9. 4-chlorobutyrylchloride* 99.5% liquid 0.5MT HDP drum 10.

NaBH4* 98%

solid 0.5MT Fiber drum

11.

Trifluroacetic acid* 99.5% liquid 0.5MT HDP drum

12.

4- methoxyphenylacetonitrile*

99.5% solid 1.0MT

Fiber drum

13.

Sodium methoxide* 28% liquid 0.5MT HDP drum

14.

Cyclohexanone* 99.5% liquid 1.0MT MS drum

15.

IPA 99.0%

Liquid 1.0MT HDP drum

16.

Methylamine 40% liquid 0.5MT MS drum

17.

H2SO4 98%


18.

2-aminopyridine 99%

Liquid 0.5MT

19.

Ethylacrylate 98% Liquid 0.3MT HDP drum

20.

Acetic acid 98%


21.

Ethyl acetate 99%

Liquid 1.0MT MS drum

22.

4-(methylamino)-3-nitrobenzoicacid

98% Solid 0.5MT

HDP drum

23.

Ethyl3-(pyridine-2-ylamino) propanoate

98% Solid 0.5MT

HDP drum

24.

Thionyl chloride 99%

liquid 0.3MT GI drum

25.

Triethylamine 99%


26.

Hexane 99%

liquid 1.0MT MS drum

27.

Methyl 4- Bromo benzoate


28.

3- Butyn-1 -ol 98% Liquid 0.5 HDP drum

29.

Cuprous Iodide 95% solid 0.05MT HDP drum

30.

Palladium (II) chloride 95% solid 0.05MT HDP drum

31.

Diethylamine 99%

liquid 0.5MT HDP drum

32 Triphenylphosphine 99% Solid 0.2MT HDP drum

. 33.

Sodium sulfate 98% Solid 0.5MT Poly bag

34.

Silica gel 98% Solid 0.5MT Poly bag

35.

Deloxan THP 95% Solid 0.05MT Poly bag

36.

Heptanes 99% liquid 1.0MT MS drum

37.

Potassium Bromide 98% Solid 1.0MT HDP drum

38.

Sodium hypochlorite 12% liquid 1.0MT HDP drum

39.

Potassium Iodide 95% solid 0.5MT Poly bag

40.

Hydrochloric acid 30%

liquid 0.5MT HDP drum

41.

Sodium thiosulphate 98% solid 0.5MT Poly bag

42.

Sodium Chloride 98% solid 0.5MT Poly bag

43.

5, 5 – Dibromobarbituric acid


44.

30 % HBr in Acetic acid 30% liquid 0.5MT HDP drum

45.

Sodium bicarbonate 95% solid 0.5MT Poly bag

46.

Acetonitrile 99%


47.

2, 4- Diamino -6- Hydroxy pyrimidine


48.

Sodium Hydroxide 98%

solid 0.5MT HDP drum

3.7 MANUFACTURING PROCESS

Raw Herbs Selection

Weighing & Measuring Raw Herbs

Decoction & Extraction

Separation

Concentration

Granulation

Flowchart of medicine manufacturing

3.8 GENERATION OF WASTE

3.8.1 LIQUID WASTE

Effluent generated from process unit (1.7 KLD) and sewage (2.7 KLD) will be treated through ETP of capacity 4.4 KLD. The inlet & outlet characteristics of effluent are shown below,

Table 3.6 Inlet & outlet characteristics of effluent

Effluent parameter Inlet (mg/L) Outlet (mg/L)

pH >8 ~7

Spray DryingFluid Bed Granulation

Medicines (Tablets, Capsule, Syrup etc.)

Packaging

BOD 2615 ≤100

COD 6070 ≤250

TSS 1442 ≤200

TDS 9605 ≤2100

3.8.2 SOLID WASTE / BY PRODUCTS

Industrial waste generated from the manufacture of pharmaceuticals will be in the form of byproducts, residues & spent acid / water which will be sent to ETP. Dried sludge from sludge drying beds will be collected & disposed to TNPCB authorized TSDF facility.

3.8.3 GASEOUS EMISSIONS

Solvent recovery will be carried out in two stages, 1. From reaction mixture – distilled directly from reactor 2. From extraction solvents – distilled after loading to reactors

Each reactor is fitted with a condenser and each condenser has 2 stages / traps. Solvents are extracted in the first stage and passed on to second stage where remaining solvents are recovered. Cooling medium is chilled water (15-20oC) or brine solution as per requirement. The solvent recovery will be >95%. Emissions from reaction vessels will be directed to scrubbers (2 nos.). The list of scrubbers proposed for the respective products manufactured are shown below.

Table 3.7 Gaseous emissions expected during production processes

S. No. Product Stream Remarks

1

HCl Scrubber APCE Sale as by product(HCl)

SO2 Scrubber APCE Sale as by product (NaHSO3)

2 HCl Scrubber APCE Sale as by product(HCl)

SO2 Scrubber APCE Sale as by product (NaHSO3)

4. ENVIRONMENT SETTING:

4.1 EXISTING ENVIRONMENT CONDITION 4.1.1 PHYSICAL CONDITION

The location of the plant is a designated industrial area. There are some industrial units existed nearby but most of them are small. There are some government office, bank situated nearby. The revering routes is also used for transportation of raw materials and finished products to and from the plants. There is no sensitive installation of environmental concern exists in close proximity of the existing plant.On the east side of the plant is Barisal – Patuakhali road, cement factory, agricultural land and bridge.On the west side of the plant is Basic Chemical project, gas turbine power project and some industries.On the north side of the plant is under construction Opsonin Chemical Industries Plant and Kirtonkhola River.On the south side of the plant is bus stand and agriculture land.The project side is enjoying all the infrastructures facilities like electricity, transportation in road and river ways and telecommunication etc.Some of the note able features of the surroundings are:

There are number of trees of various species, as has been seen in the area, some trees are quite old

There are no moments or features of historic interest around the plant side but there exists five storied residential quarters in the immediate vicinity

Like other parts of Bangladesh a few common birds are seen around the plants side There are no development of science or recreation facility for tourism attraction in the

vicinity as you. There are no wildlife present in the surrounding area of the plant

Table 3.2 Environmental Settings of Project Site

S. No. Particulars Details 1 Site Latitude 12°41'39.7"N 2 Site Longitude 80°11'10.3"E 3 Site Elevation above MSL 9 m 4 Nearest highway 5 km 5 Nearest railway station No

6 Nearest airport Barisal National Airport - 10 km (N)

7 Nearest town/ city Barisal town – 5 km (N) 8 Topography Plain 9 Archaeologically important

places 10 National parks/ Wildlife

Sanctuaries Nil within 15 km radius

11 Reservoir Nil within 15 km radius 12 Reserved/ Protected Forests Sunderbanes

13 Seismicity The area under study falls in Zone III according to the Bangladesh Standard Seismic Zoning Map.

14 Defense Installations Nil within 15 km radius 15 Nearest Port Paira Port 75 km

4.1.2 AIR QUALITY

The air quqlity of the area still seems reasonably good. As mentioned earlier, there are no significant industrial in the close vicinity of the plant which are air polluting in nature. Further the area is near to the river with considerable open space and vegetation which may effect dispersion of the pollutants. Air quality in terms of SOx & NOx have been observe to be within acceptable limit.

Table 4.1 Air QualityDate Sample Location Ambient Pollutant

Concentration (Ugm.m3)Remarks

SPM SOx NOx Wind Direction need to consider

4.1.3 WATER QUALITY

Identification of Major Environmental Issues Water quality of the Kirtonkhola river is of paramount importance to the growing industrial town of Barisal & river port of Barisal. The water quality of the river is in good condition. It appears from the the monitoring data that water quality of the Kirtonkhola and is still within acceptable limit. Water quality of the river in the below table.

Table4.2 Water QualitySample location date pH EC

uS/cmDOMg/L

BODMg/L

CODMg/L

SSMg/L

Nera the OPL, Barisal 19.9.15 6.0 1000 6.0 25.0 35.0 70

From monitoring data it appeared that quality of effluent of plants does comply with the environmental quality of Bangladesh.

Table4.3 Effluent QualitySample location date pH EC

uS/cmDOMg/L

BODMg/L

CODMg/L

SSMg/L

Water sample ol effluent 19.9.15 6.53 600 5.4 35 95 55Water sample ol ditch/ canal

19.9.15 6.0 650 5.0 90 100 65

ENVIRONMENTAL IMPACTS AND MITIGATION MEASURES

Checklist:

Project PhaseAction Affecting Environmental Resources and Values None Minor Medium Major

Construction Stage

River Encroachment xWorker accident xErosion control xNoise hazard xTraffic congestion xAccess Roads and Tracks x

Employment X

Waste Disposal and Recovery x

Transportation x

Installations x

Revegetation x

Labor Force x

Equipment x

Utilities x

Services x

Site Clearing x

OperationPollution from liquid discharge

x

Stage

Raw material handling and transportation x

Pollution from solid waste x

Storage of fuels xAir quality xStorage of Raw Material xOccupational Health hazard x

Storage of raw materialsOdor hazard xOperational FailureTraffic congestion xProcess Water xCooling Water x

Gas/ Vapor emissions xWaste Disposal and Recovery x

Accidents xPest Control xDust Control xNoise hazard xEmployment x

Construction StageWaste Disposal Impact

The site is currently half of the construction is completed, so there may present only a

relatively small number of trees and shrubs present, insignificant quantities of waste will be

generated as a result of site clearance. Nevertheless, vegetable matter produced will be

incinerated and any residue land filled at appropriate sites. Other waste materials likely to

generate as a result of construction activities include timber offcuts and waste concrete and

cement. All combustible waste is not appropriate for reuse will be incinerated at the site.

Mineral waste will be either removed, or land filled at the site. There is an ETP plant to treat

the waste materials but its size is inappropriate to treat the whole waste materials that

produced in the construction of the project.

Socio-economic ImpactTraffic Flow

In the construction phase additional numbers of buses, minibuses, trucks, vans cars and jeeps

associated with transporting the workforce to and from the site. Construction of the proposed

infrastructure will also involve the transport of various quantities of materials, aggregates,

plant and equipment to the site throughout the construction period. The construction materials

will be supplied by local suppliers. During construction phase there are high load in traffic,

which may create traffic jam. But this impact is a reversible and short term.

Resettlement

For the construction of the extended infrastructure of OPSONIN Pharmacuticals Ltd. A

number of 130 households resettle in the others area. Some of them migrate in Barisal city

slum areas and increase the population density as well as amount of malnutrition.

Employment and Income:

Income should increase if employment is provided to local people. But most of the poor local

people fail to engage themselves in construction activities because of their experience

lacking.

Infra Structural Traffic Impacts:

The impact of the construction traffic is significantly impact on the existing traffic flow at the

road. But this impact is reversible and short term.

Air Quality Impact

With regard to the construction phase air quality impacts will be potential for dust generation

from increased vehicular emissions, transportation and construction activities and related to

the transportation of materials to and from site. Construction equipment such as earth movers

and excavators will contribute towards atmospheric emissions.

Dust Generation

Dust generation by traffic movements represents a potential problem, particularly during the

months of November and February month in the Construction site and outside area of

construction. This dust generation affects the air quality of the site.

Vehicular Emissions:

The main products of the combustion of hydrocarbon fuel engines are CO2, nitrogen and

water vapor resulting in CO, unburned carbon, HC and other organic species produced by the

compression and spark ignition. At the high pressures and temperatures by the engine

cylinders, produced NOx. Therefore, machinery and vehicles like earth moving equipment

will impact upon ambient air quality in the locality of the site.

Here presents the data of the Environmental Quality Standards for Ambient Air Quality in

Bangladesh

Sl. No.

Area Class Particulate Matter (SPM)

SO2 CO NOx

a. Industrial & mix area 500 120 5000 100b. Commercial & mix area 400 100 5000 100c. Residential & rural area 200 80 2000 80d. Sensitive area 100 30 1000 30

Note:(1) Sensitive area: National Monument, Health complex, Hospital, School, Govt. define

area if exists.(2) Industry situated near residential, rural and sensitive area should not emit may has

which exceed the limit of item (c) & (d).(3) Particulate matter means diameter of air particles of size 10 micron or less.

Source: Bangladesh Gazzet (Thursday, August 28, 1997), Ministry of Forest & Environment.Air quality will be monitor under the guidance of data of DoE & report will be prepared by Opsonin Pharmacuticals Limited, Barisal

Date Sample Location Ambient Pollutant Concentration

Remarks

SPM SOx NOx Wind Direction need to consider

Noise Impact

Noise is generated from construction equipment and vehicular activities of the construction

site. Sometimes noise is getting unbearable to tolerate.

Standard for Noise in Bangladesh

Sl. No. Area Class Day Time(dBA)

Night Time(dBA)

a. Silent area 45 35b. Residential area 50 40c. Mix area (mainly residential and

commercial & industrial area)60 50

d. Commercial area 70 60

e. Industrial area 75 70

Note:(1) Daytime start from 6:00 am morning and end at 9:00 pm night.(2) From night 9:00 pm to 6:00 am morning; identify as nighttime.(3) Silent areas identify as a 100-meter radius from the location of any hospital, school or

any special area. In silent all types of vehicle horn or any loudspeaker use are restricted.


Noise levels limit 75 dB during daytime and 70 dB in the night time. The current baseline noise levels within impact zone around Opsonin Pharmacuticals Ltd varied from 56.7 – 76.6 dB during daytime and 42.6 -65.6 dB in the night time

Ecological ImpactsConstruction has most potential for the following types of ecological impacts:

Impacts as a result of habitat loss Impacts arising as a result of physical disturbance or noise.

The project is in only 70 Bighas of land and the site is not within any ecologically or

biodiversitically rich area. So, the impact of the project on the ecology is not significant.

Operational ImpactsImpact on Water Quality

Water quality is affected by the sewage disposal and effluent generated by the machineries of the company. The industrial effluent directly discharges the Kirtonkhola River besides the construction site.The water quality of the river is in good condition. It appears from the monitoring data that water quality of the Kirtonkhola and is still within acceptable limit.Water quality of the river in the following-

Sample location

date PH ECuS/cm

DOMg/L

BODMg/L

CODMg/L

SSMg/L

Near the OPL, Barisal

19.7.03 6.00 1000 6.0 25.0 35.0 70

Table: Water data of kirtonkhola river

The quality of the effluent of ETP does fulfill with environmental quality of Bangladesh. So the water quality of the Kirtonkhola River will not deteriorate. Effluent monitoring data of Opsonin Pharmacuticals Ltd, Barisal in the following-

Sample Location

PH ECuS/cm

DOMg/L

BODMg/L

CODmg/L

SSmg/L

Water sample of the effluent

6.53 600 5.4 35 95 55

Water sample of ditch/canal

6.00 650 5.0 90 100 65

Table: Effluent monitoring data of Opsonin Pharmacuticals Ltd, Barisal

Thermal Impact

Hot air will be produced from the boiler. Thermal impact will happen whether the hot water

is sent to the surface water body from the condenser directly. This will distress the aquatic

flora and fauna of the water body.

Solid Waste Impact

Solid waste can be generated by paper, bags, boxes, office wastes, pallets, empty drums etc

used by the people working at the construction site.

Socio-economic Impacts:

An evaluation of the impact of the pharmaceuticals industry on the socio-economic

conditions of the inhabitants of that area has done through visualization and people

perception. There is a significant effect on the socio economic life of local people. A positive

change may occur through employing local residence permanently or long time contract. This

would provide a stable income to improve themselves, their living standards and resilient

community as well as removing the poverty and malnutrition. Similarly, the workers from

another areas or outside region may also improve the economic status of that area through

their services which may be in the form of tea stalls, shops, markets where the daily needs

will buy and sell. Thus the economic development will be developed through the positive

change.

Impact on Air Quality

Engine and generator produce emission may distress the ambient air quality. Unburned gases

may distress the air quality from the engine operation. The situation worsens when gas holds

high percentage of sulfur, hydrocarbon layers. The flue Gases produce high temperature that

create impacts the air quality in terms of thermal pollution. The combustion of fossil results

gaseous emission to the Atmosphere creates pollution. The pollutants like sulfur dioxide (SO2),

Oxides of Nitrogen (NOX), carbon monoxide (CO) and carbon dioxide (CO2) cause pollution.

Since the location of the construction site is near to the urban so it is expected to cause great

hamper to the urban residential areas air quality.

In order to be able to assess the environmental impact that the power station's atmospheric

emissions may be having over a period of time, it is necessary to set up an emissions

inventory. Initially this is expected to include carbon dioxide; the principal greenhouse gas

emitted and oxides of nitrogen; the principal gas release.

Sulfur dioxide (SO2) Emissions

The emissions of SO2 are dependent on the sulfur content of the gas. For the purpose of this

assessment the sulphur content of the gas is assumed to be 0.002%.

Nitrogen Oxides (NOx) Emissions

The production of NOx depends on the Nitrogen in the fuel Temperature of combustion. The

Nox originate from both the fuel and the air. NOx from the fuel is usually referred to as ‘Fuel

NOx’ and NOx from the air is generally referred to as ‘Thermal NOx’. The proportion of

Fuel NOx to Thermal NOx depends on the temperature of combustion. With an increase in

combustion temperature, there is an increase in thermal NOx emissions, and hence overall

NOx emissions.

Carbon Monoxide

The emissions of CO are generated by the incomplete combustion takes place. Bangladesh

limits for carbon monoxide 5000 ppm for industrial area.

Carbon Dioxide

The emissions of CO2 depend on the fuel burn and the carbon content of the fuel. CO2

emissions to the atmosphere are related with ‘global warming’.

Impact from Liquid Waste

Process waste water may contain un-reacted chemicals, spillages and leakage’s of intermediates and finished products, unrecovered organic solvents, acid alkalis and laboratory discharges etc. Most pollutants present in the waste are biodegradable. Bangladesh Standard for Sewage Disposal in the following-

ParametersUnit Value

BOD mg/l 40Nitrate mg/l 250Phosphate mg/l 35Suspended Solid mg/l 100Temperature oc 30Coliforms Number/100ml 1000

According to the report, waste water quality partially observes with Bangladesh standard before discharging in to environment.

Lubricating Oil Impact

Insignificant amount of used lubricating oil would be generated from the plant. The generated

waste oil will be stored in a sealed tank.

Noise and Vibration Impact

There would be moderate noise and vibration from the pharmaceuticals machine. As this is an

industrial mix rural area and there is not enough settlement around the industrial area, so this

effect would not be so acute.

Occupational Health

The workers who work inside the chemical plant will face occupational health hazards due to

different operational processes. Safe and good occupational health status of the employees and

workers is important for both the persons working in the plant and for better plant operation

and maintenance.

Impacts on Flora and Fauna, Ecosystem and Habitats

Fisheries:

- Roads prevent longitudinal and lateral migration of fishes in the flood plain

- Obstruct movement of fishes onto natural feeding and breeding grounds in the flood plain.

Forest:

-Roads running through forest area and plantations may be the cause of destruction of trees

and alteration of ecology of the pharmaceuticals area.

Plantation:

- The roadsides may be used for plantation of trees which is favorable impact of internal or

outside industrial road construction.

Wetland and Wetland Habitant:

- The road may encroach wetlands which may alter the ecology of wetlands and may cause

destruction of wetland habitat.

Nuisance Plant/Eutrophication:

-The Roads running through agricultural land area and plantations may be the cause of

destruction of trees in the forest and alteration of ecology of the forest.

ENVIRONMENT MANAGEMENT PLAN

The purpose of the Environmental Management Plan (EMP) is to identify project specific actions for mitigation of the impacts identified in the proposed project. The EMP describes both good practice measures and site specific measures, the implementation of which is aimed at mitigating potential impact associated with the project activity.

The objectives of the EMP for all the environmental attributes are as:

To create good working conditions for employees. To achieve highest performance and response from individual employees. To search new technologies for a cleaner and better environment. To ensure sustainable development. To achieve environment standards and to improve methods of environment management

Construction phaseDiscipline Potential Negative Impacts Mitigation measures

Water River erosionWater born disease

Rain water harvestingInstallation of ETP

Loss of biodiversity Green belt development

Air Respiratory & heart problemsHazardous gas emissionDust emissionIncrease of CO2

Use of plastic cover sheet while transporting raw material at site.Storage of sand covering with tarpaulin sheet.Use of water sprinkling system at site for dust suppressionUpwind portion of the project will be constructed first.During high wind condition, construction activities will be restricted. The construction activity will be carried out during day time only.Existing greenbelt will have significant impact in reduction of dust dispersion. Proposed Greenbelt development will be started from the construction phase.

.Land Soil erosion.

DeforestationTop soil to be generated during Construction activity will be preserved and used for the green belt development.Greenbelt development will havesignificant impact in reduction of the soil erosion.

Noise Hearing problemSleeping disorder

The construction activity will be carried out during day time only.Silencer and Vibrating pad would be used. The noise generated from construction machinery will be kept low by keeping the moving parts serviced and properly lubricated.Greenbelt development will have significant impact in reduction of the noise.

Socio -economicenvironment

Temporary employment will begenerated due to construction activitiesand related services like transportationof construction materials, mechanicalerections etc.

Ecology Loss of biodiversity Green belt development for flora fauna

Operation Phase

Discipline Potential NegativeImpacts

Source Mitigation Measures

Air Quality

Emission of gaseouspollutants in air

Diesel generatorProduction activities

Stacks of adequate height will be provided for DG set.A leak detecting system will be used.Scrubber will be provided to separate acidic fumes from reactors.

Fugitive emissions Vehicular traffic Well-developed internal roads are present at the siteAdequate greenbelt has been established at the site

Noise Increase in noise levels

Diesel generators The DG shall be provided with acoustic enclosure.

Water Quality

Groundwater, soilpollution & odournuisance

Sewage generation Sewage will be disposed thorough septic tank & soak pits.

Trade effluent generation

Trade effluent will be treated through proposedETP.

Solid waste Leaching to groundwater,soil pollution & odorsnuisance

Municipal solid waste MSW will be segregated at source and disposed through local body.

Hazardous waste Hazardous wastes generated onsite shall be pyrolysis.

Terrestrial Ecology

Impact on plant species

Emissions from VehiclesDiesel generators Production activities

Stacks of adequate height will be provided for DG setsNecessary air pollution control devices will be installed.Industry will be required to allot 33% of plot area for

greenbelt development.Acoustic enclosures will be provided for DG setsNecessary noise pollution control devices will be installed.

Storm water Control

Water logging within the site

During monsoon season

Efficient storm water & rainwater harvesting structures will be set up within the site.

Fire and Safety

Accidents / disasters related to fire and safety

Production activities Use of “Dry Chemical Powder” fire extinguisher.There will be multiple fire extinguishers located at different parts of the laboratory.

GREENBELT DEVELOPMENT PLAN

Development of a greenbelt mitigates the potential negative impact of dust, air emissions, fugitive emission and noise. A green belt makes climate and soil quality balancing, by retaining of soil moisture. It not only improves the aesthetic value of the area, but also provides the natural habitat of various bird species. We should identify locally available trees which can abate pollution. The general considerations involved while developing the green belt are:

Local/native fast growing trees should be planted. Planting of trees should be undertaken in appropriate encircling rows. The trees should be protected from animals by planting of non palatable shrub

species. Minimum leaf fall trees. It should maintain ecological, land and hydrological balance of the region.

List of plants for a green belt

SL NO COMMON NAME SCIENTIFIC NAME1 Bottle Palm Hyophorbelagenicaulis2 Sissoo Dalbergia sissoo3 Neem Azardorachta Indica4 Amloki Embelica officinalis5 Jarul Lagerstroiemia speciosa6 Narikel Cocos nucifera7 Krisnochura Delonix regia

8 Kathal Artocarpus heterophyllus9 Aum Mangiera indica10 Jhaue Casuarina equisetifolia

RAINWATER HARVESTING SYSTEM

Rain water harvesting is the technique of collection of rain water and recharging of ground water artificially by means of recharge structure. Recharge structure includes recharge pits, check dams, recharge well, nala bunding and recharge tank construction. It may be possible to collect rainwater through necessary infrastructure construction. If planned properly and designed scientifically, it may aid in improving recharge availability and opportunity. Rainfall is one of the important parameters that contribute water for the purpose of recharge into ground water reservoir. The average annual rainfall in the district is …. mm. Unit has total plot area of ….. m2 for rain water harvesting and based on the average rainfall in the study area and effective area available for rain water harvesting, quantity of yearly runoff has been derived as …..m3.

Estimation of availability of yearly runoff

SL No

Particulars Area availablefor rain waterharvesting, m2

RunoffCoefficient

Storage coefficient

Long TermAverageRainfall, mm

Estimated yearlyrunoff, m3

1 Roof top area2 Greenbelt &

other areaTotal

APPLICATION OF CLEANER PRODUCTION (CP) TECHNOLOGY

Nowadays Cleaner Production has emerged as an attractive proposition to tackle the environmental problems caused by rapid industrialization and it is accepted worldwide. It not only reducing pollution but also improving the process efficiency, thus reducing the cost of production. Applications of CP mainly focus on preventing or minimizing the generation of waste and gaseous emission. The basic idea of cleaner production is to find remedial measure by adopting proactive approach of waste management. To obtain fruitful results of CP we should implement concept of product modification, source reduction and recycling. Existing as well as proposed implementation of techniques of CP is described below:

Pollution Prevention

To minimize material waste. The Unit will manufacture products by using high-quality of raw material. The unit will maintain the hazardous chemicals and keeping the buffer stock as

minimum as possible. The unit will use jute bags because it reduces the solid waste. Sufficient disposable bins are clearly marked to put the waste.

Water Conservation

High Pressure Jet Pump will be used for the cleaning of equipment, vessel & rector etc. Flow meter will be installed at raw water intake and outlet of Effluent Treatment plant. Excess service water taps is not provided in the plant premises. For the green belt development, water sprinkle system will be used instead of hose pipe.

Energy Conservation

First step to conserve energy is to identify source of energy utilization. Use of low loss transformer instead of conventional transformer. As far as possible the unit should use solar street lights in the factory premises which is

the renewable energy. Proper air to fuel ratio is maintained for the maximum efficiency of boiler. Good insulation practice has been adopted to prevent heat losses. Regular cleaning to the lamps to get better illumination in the plant. Unit is planning to conduct energy audit regularly as a tool for monitoring purpose.

Good HousekeepingGood housekeeping means changing existing practices or introducing new ways of operating and maintaining equipment. Proper good housekeeping can prevent accidents, spillages and leakages, raw material & product loses.For Good housekeeping following practices are adopted. All the materials are stored in compatible group. All pits are properly covered or securely fenced. Appropriate tools are provided for handling of all the materials. Regular training is given to all workforces. All the passages, floors and stairways are maintained in good condition. Sufficient disposable bins are clearly marked and these are suitably located in the plant. In the plant, precaution and instructions are displayed at strategic locations.

Proper working instructions are given to all the workers in factory. Roads/walkway within the plant is maintained neat and clean.

Reduce, Recycle and ReuseA number of measures are proposed to achieve high yields and reduce generation of wastes such as-

The mother liquors from the first crop shall be reused and treated effluent shall be reused for cooling the system.

The solvent used in the manufacturing process will be recovered through vaporization by heating and condensation and reused again in the manufacturing process.

Used oil from the plant & machineries will be reused as a lubricant.

Effluent Treatment System

The Effluent management system is developed to ensure `Zero Liquid Discharge’. The purpose establishing a Effluent Treatment Plan (ETP) is to minimize water contamination through waste water discharge from pharmaceuticals research, pharmaceuticals development and pharmaceuticals production activities

There are four process involved in treatment of effluent.

1. Physical treatmenta) Reverse osmosis (RO):

Based on pressure application Removal of dissolved solids Depends on concentration and pH

b) Dialysis: Based on the chemical activity of the solute Recovery of specific material from aqueous solution Depends on the molecular weight and dialysis coefficient.

c) Filtration:d) Sedimentation:

Suspended particles are allowed to settle and supernatant removed2. Chemical Treatmenta) Ion-exchange:

Reversible interchange of ions between a solid and a liquid phase Used for the removal of trace metals, fluorides, nitrates, and manganese

b) Neutralization: A process utilised to prevent excessively acidic or alkaline wastes discharge 1 out of 2 pharmaceutical plants use neutralization to treat their wastewater

c) Reduction: Treatment with sulphur dioxide to reduce the oxidants to less noxious

materialsd) Precipitin:

separation of solid from aqueous waste chemically3. Thermal Treatmenta) Incineration:

Controlled heating processes to covert a waste to less bulky, less toxic or less noxious

b) Pyrolysis: Thermal decomposition of waste at high temperature in the absence of

oxygen4. Biological Treatment

Used to remove biodegradable organic matter Microorganisms converts organics into: CO2 and H2O (aerobic) CO2, CH4, and H2O (anaerobic)

BUDGETARY ALLOCATION FOR ENVIRONMENT PROTECTIONA capital investment towards the environmental protection, control & mitigation measures will be about …….Lac after the proposed project.The unit keeps provision for adequate funds aside to meet with regular expenses for the environmental control measures. Recurring cost for environmental management for the existing as well as proposed project is given in

Recurring Cost for Environmental Management

Sr.No.

Description Recurring Cost, lacs per Annum

Existing Proposed Total

1 Water Pollution Control2 Air Pollution Control3 Hazardous Waste

Management4 Hazardous Waste

Management5 Green Belt development6 Rain water harvesting7 Fire and Safety

eia rrrrr

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