Table No. 4.4: Activity – Impact Evaluation Matrix (Construction And

M/s. Solisom Healthcare LLP. Environmental Impact Assessment Report Survey No.: 99/P1, Rajpar – Nashitpar Road, Village:

Nashitpar, Taluka: Tankara,District: Morbi, Gujarat.

Table No. 4.4: Activity – Impact Evaluation Matrix (Construction and Operation Phase) Aspect Land Use Resource Air Water Noise Terrestrial Socio- Infrastructure Human & Depletion Quality Quality Level & Economic & Health Activity Soil Aquatic Ecology Status Services

Land Acquisition -3 -3 -1 -1 -4 +2 +1 -1 and Site Clearing

Construction/ -3 -2 -2 -2 -2 +2 +3 -2 Civil Work Material & Product -2 -1 -1 -2 Storage/Handling Fuel & Electricity -4 -2 +3 Consumption Gaseous -2 -4 -1 -3 -2 -2 Emissions Fugitive -2 -2 -2 Emissions Water -2 -3 -4 -3 -2 -1 Consumption Wastewater -2 -4 -2 -1 Generation Solid & Hazardous Waste Storage and -2 -2 +2 -1 Disposal

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Aspect Land Use Resource Air Water Noise Terrestrial Socio- Infrastructure Human & Depletion Quality Quality Level & Economic & Health Activity Soil Aquatic Ecology Status Services

Plant Operation -2 -4 -3 -3 -2 -2 +2 +4 -2

Equipment -3 -3 -2 -2 +1 -4 Failures

Transportation -3 -3 -2 -3 +2 +3 -2

TOTAL -18 -19 -19 -19 -10 -21 +2 +17 -20

Note: (+) = Positive and (-) = Negative impacts on attributes

Table No. 4.5: Cumulative Impact Matrix Environmental Attributes Cumulative Score for Relative Importance of Cumulative Significance each attribute, Si each attribute, Wi (%) ( Si x Wi ) / 100 Air Quality -19 20 -3.80 Water Quality -19 20 -3.80 Terrestrial & Aquatic Ecology -21 15 -3.15 Socio-Economic Status +2 10 +0.20 Human Health -20 15 -3.00 Resource Depletion -19 5 -0.95

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Environmental Attributes Cumulative Score for Relative Importance of Cumulative Significance each attribute, Si each attribute, Wi (%) ( Si x Wi ) / 100 Noise Level -10 5 - 0.50 Land Use & Soil -18 5 - 0.90 Infrastructure & Services +17 5 +0.85 Cumulative Score -15.05

As shown in Table No. 4.5, the cumulative value of significance of the project, in terms of the impact on the environment, with mitigation measures works out to be (-) 15.05

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4.6 Air Quality Modelling [Answer to TOR no. 7(i)]

A. Input data of Flue Gas Stack

The proposed unit will operate Steam Boiler to generate steam required during manufacturing process. The details of flue gas stack are given in Table 4.6.

Table 4.6: Details of Flue Gas Stacks Sr. Stack Fuel APCM Expected Stack attached to No. Height Requirement Pollutant Coal/ Cyclone Steam Boiler separator SPM  150 1 30 m Briquettes (1 TPH) followed by mg/Nm3 (1.2 MT/Day) Bag Filter SO2  100 ppm D.G. set Diesel Acoustic NO  50 ppm 2 6 m 2 (125 KVA) 50 Liters/Hr. Enclosure

Note: D.G. Set will be used only in case of power failure.

Input data: Stack Identification : Steam Boiler Stack Stack Height : 30.0 m Vent Diameter : 0.5 m Flow rate : 1.415 m3 / sec Exit stack gas velocity : 7.20 m/s Exit gas temperature : 140 oC Ambient temperature : 25 oC

Table 4.7: Expected Pollutants and its Emission Rate Expected Pollutants Emission Rate

Particulate Matters (PM10) 2.69 g/sec Sulfur Dioxide 0.11 g/sec Nitrogen Dioxide 0.55 g/sec

B. Primary Meteorological Data:

Primary meteorological data have been used for AERMOD View-9.0.0. The said primary data is attached as Annexure - 4.

Assessment of Impact on AAQ:

The AERMOD model is used to predict the centerline ground level concentrations of

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Particulate Matter, Sulfur Dioxide and Nitrogen Dioxide in the surrounding study area. The prediction is done in relation to the source strength and meteorological conditions for the study period.

The Ground Level Concentrations (GLCs) for Particulate Matter, Sulfur Dioxide and Nitrogen Dioxide in the study area for all the stability conditions are calculated for the maximum emission load. For the calculations, meteorological data like average wind speed, wind direction, relative humidity, temperature, precipitation, cloud cover and ceiling height for the period of 05/10/2018 to 27/12/2018 and emission rate of PM10,

SO2, NO2 & Ammonia and height & diameter of the stack is considered.

Predicted ground level concentrations of PM10, SO2, NO2 & Ammonia are presented in the Figure 4.1, 4.2, 4.3 & 4.4 and Table 4.8, 4.9, 4.10 & 4.11.

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Figure 4.1 Ground Level Concentration of PM10 [Answer to TOR no. 7(i)]

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Figure 4.2 Ground Level Concentration of SO2 [Answer to TOR no. 7(i)]

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Figure 4.3 Ground Level Concentration of NO2 [Answer to TOR no. 7(i)]

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Figure 4.4 Ground Level Concentration of Ammonia [Answer to TOR no. 7(i)]

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Table 4.8: Predicted 24 hourly short term incremental Concentrations of PM10 [Answer to TOR no. 7(i)]

Existing Total PM10 monitored Predicted PM Concentrations Sr. Monitoring Distance 10 Direction maximum PM Concentration after the No. Location (km) 10 concentration (µg/m3) proposed project (µg/m3) (µg/m3) 1 Project Site 0 - 86.45 0.30 86.75 2 Nesda 8.1 WSW 79.31 0.30 79.61 3 Tankara 8.5 South 82.30 0.08 82.38 4 Lajai 5.3 ESE 69.72 1.00 70.72 5 Nasitpur 2.8 SW 76.56 1.00 77.56 6 Thorala 5.1 NNW 73.19 0.30 73.49 7 Rajpar 4.4 NE 67.13 1.00 68.13 8 Shanala 8.7 NE 65.24 0.60 65.84

Table 4.9: Predicted 24 hourly short term incremental Concentrations of SO2 [Answer to TOR no. 7(i)]

Existing Total SO2 monitored Predicted SO Concentrations Sr. Monitoring Distance 2 Direction maximum SO2 Concentration after the No. Location (km) Concentration (µg/m3) proposed project (µg/m3) (µg/m3) 1 Project Site 0 - 18.28 0.003 18.283 2 Nesda 8.1 WSW 16.88 0.010 16.890 3 Tankara 8.5 South 14.88 0.003 14.883 4 Lajai 5.3 ESE 17.86 0.050 17.910 5 Nasitpur 2.8 SW 14.22 0.030 14.250 6 Thorala 5.1 NNW 12.55 0.010 12.560 7 Rajpar 4.4 NE 17.03 0.030 17.060 8 Shanala 8.7 NE 12.30 0.030 12.330

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Table 4.10: Predicted 24 hourly short term incremental Concentrations of NO2 [Answer to TOR no. 7(i)]

Existing Total NO2 monitored Predicted NO Concentrations Sr. Monitoring Distance 2 Direction maximum NO Concentration after the No. Location (km) 2 Concentration (µg/m3) proposed project (µg/m3) (µg/m3) 1 Project Site 0 - 38.54 0.05 38.59 2 Nesda 8.1 WSW 30.76 0.08 30.84 3 Tankara 8.5 South 35.95 0.01 35.96 4 Lajai 5.3 ESE 32.21 0.30 32.51 5 Nasitpur 2.8 SW 26.93 0.10 27.03 6 Thorala 5.1 NNW 20.71 0.05 20.76 7 Rajpar 4.4 NE 22.23 0.10 22.33 8 Shanala 8.7 NE 17.24 0.10 17.34

Table 4.11: Predicted 24 hourly short term incremental Concentrations of NH3 [Answer to TOR no. 7(i)]

Existing Total NH3 monitored Predicted NH Concentrations Sr. Monitoring Distance 3 Direction maximum NH3 Concentration after the No. Location (km) Concentration (µg/m3) proposed project (µg/m3) (µg/m3) B.D.L 1 Project Site 0 - 1.0 5.9 (DL= 5 µg/m3) B.D.L 2 Nesda 8.1 WSW 2.0 6.9 (DL= 5 µg/m3) B.D.L 3 Tankara 8.5 South 0.6 5.5 (DL= 5 µg/m3) B.D.L 4 Lajai 5.3 ESE 4.0 8.9 (DL= 5 µg/m3) B.D.L 5 Nasitpur 2.8 SW 5.0 9.9 (DL= 5 µg/m3) B.D.L 6 Thorala 5.1 NNW 10.0 14.9 (DL= 5 µg/m3) B.D.L 7 Rajpar 4.4 NE 20.0 24.9 (DL= 5 µg/m3) B.D.L 8 Shanala 8.7 NE 20.0 24.9 (DL= 5 µg/m3) T. R. Associates (Ahmedabad) Chapter-4: Env. Impacts & Mitigation Measures NABET Accredited 4.21

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After the establishment of the proposed project, these concentrations are found to be well below the permissible NAAQs norms for rural/residential zone and Industrial zone. Therefore, the proposed activity will not have any adverse impact on the air environment.

4.7 Mitigation Measures for Impacts on Environment during Construction Phase

During construction phase, major impacts anticipated will be increase in dust contamination and noise. However, these impacts will be localised and limited up to construction period only. Impacts during construction phase and its mitigative measures are given in Table 4.12.

Table 4.12: Construction Phase: Impacts & its Mitigation Measures Impacts causing Attributes Mitigative Measures factors/Impacts  Vehicular emissions – smoke, gaseous and PM  Specific control measures on vehicular  PM emissions from site movement, emissions and noise from activities and handling vehicles and storage of  Good practices for construction, loading Air construction materials and unloading of materials, Impact: Above said o Storage in pre-designated areas aspects may be impact to o Enclosures/barriers around site surrounding agriculture activities and storages land and reduce the crop yield.  Vehicular maintenance  Vehicular  Standard machinery  Construction machinery  Good construction practices and suitable  Activities enclosures/barriers Noise Impact: Above said o Avoid high noise generating aspects may be impact activities, vehicular movement and quality of life surrounding operation of machinery during night living people. time.  Slurry discharge from  Good construction practices will be construction activities adopted to minimize water wasting and  Sewage & grey water Water pollution. discharge  Sewage will be properly managed by Impact: It may impact on adequate designing of soak pit system. ground water quality.

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Impacts causing Attributes Mitigative Measures factors/Impacts Expectations/aspirations of local people Impact: Positive impact on Assessing local skills availability & the skills Socio- surrounding village people required for construction related activities economy due to hire local & giving preference to local persons for job construction agency for construction works. Impact: It may impact on  Control of noise & vehicular movement surrounding habitat and in pre-defined areas Ecology affect their food chain of  Avoid night time working. ecosystem.

4.8 Mitigation Measures for Impacts on Environment during Operational Phase

Impacts during operation phase and its mitigative measures are given in Table 4.13.

Table 4.13: Operation Phase: Impacts & its Mitigation Measures Impacts causing Mitigation Measures Attributes factors/Impacts  It may be Land  Specific dust control measures degradation due to PM discussed under air & water from coal transport, environment in chapter no 2. spills, handling and  Specific dust control measures at storage, ash handling. source like paved roads, defined traffic Impacts: It may impact routes, etc. on surrounding Land Use agriculture land (Reduce crop yield) due to Deposition of PM and process emission from stack , coal handling, preparation & storage, vehicular movement on unpaved surfaces

 PM, SO2, NO2, CO  Provision of bag filters along with APC Air emissions from flue gas systems (i.e., cyclone separator Environment stacks followed by bag filter attached with  Ammonia gas and VOC boiler and scrubber attached with

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emission from process reactor and activated carbon column gas stacks. attached with dryer) to attenuate  PM from ash handling pollutant and keep it within the & storage prescribed standard.  Coal dust from coal  Condition of fly ash with water storage yard sprinkling while loading in trucks.  Coal dust from convey  Enclosed coal storage considering or transfer points, coal wind directions unloading & coal  Tarpaulin covered vehicles stockpile area  VOC emissions due to use of solvents from dryer. Impact: It may impact on surrounding agriculture land (Reduce crop yield), Biodiversity (degradation in food chain of ecosystem) due to dust and gas deposition.  Water:  Ash disposal area lined with  Resource depletion impervious liner to prevent seepage of  Wastewater: ash-water  Bottom ash  Provision of well-designed and well handling system maintained ETP and STP  Seepage of ash  Run off collection system, settling, water clarification, recycling/reuse of clear  w/w treatment water plant  Storm water collection & disposal  Floor washings network  Grey water from  Recharging Bore well Water equipment Environment washings  Sewage Impact: It may primarily impact on ground water quality if accidentally discharge on ground. And secondary impact on surrounding agriculture land using same ground water for irrigation.  Run off:

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 Coal pile area run off  Surface run off from plant premises  Storm water Noise from  Specific acoustic enclosures  Industrial equipments,  Good design & engineering practice pumps like specific foundations & mountings  Steam safety relief to control vibrations valves  Well design greenbelt may be act as Noise & Vibration from industrial barrier Vibration equipment’s. Impact: It may impact on the surrounding Ecosystem (disturb immediate surrounding project site living habitat)  Leakages and spillages  Provide pucca flooring in the process due to improper area as well as in chemical storage handling or raw area materials  Provide rain water harvesting system  Extraction of ground for ground water recharge purpose Geohydrology water for industrial usage Impacts: it may affect the natural drainage pattern during rainy season due to construction activities.  Inhibition of growth &  Specific control measures for drainage vegetation due to PM & & water quality, reduction in emission Ecology vehicular emissions of PM, reduction in noise & vibration and Impacts: It may impact  Enumeration of loss of flora & fauna, Biodiversity on food chain of and compensation measures, if surrounding area due to applicable developmental activities.  Gaseous emissions &  Specific control measures for gaseous PM in ambient air emissions and PM from stack &  Opportunity for local fugitive emissions Socio- population for  Beneficial for local population Economic employment based on  Inevitable, growth could be planned, their skills & to supply beneficial to land owners, increase in materials & services

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 Boost to real estate prices of real estate is unavoidable development & increase in prices of real estate Impacts: It may positive impact in surrounding villages due to employment generation. Addition to that small business (i.e. General stores, Mechanical stores etc.) will be developed.  Injuries from Occupational health & safety related equipments measures in accordance with the  Electrical hazards from applicable regulations like Factories Act switch gears and other to include. sources  Good work environment  Exposure to high  First-aid facilities temperature  Masks with suitable canisters Occupational  Exposure to high noise  PPEs Health &  Exposure to high levels  Fire extinguishing facility Safety of coal dust  Physical fall Impacts: It may impact on the workers’ health working in hazardous chemical handling area. (i.e. Solvents handling area)

4.9 Existing Traffic & Vehicular Pollution [Answer to TOR no. 7(ii)]

Traffic survey has been carried out on Rajpar – Nashitpar Highway. Based on the traffic survey hourly vehicular traffic has been calculated. Considering worst case scenario, average number of vehicles observed during 4 hours has been taken as hourly counts. Passenger Car Unit (PCU) has been calculated by applying PCU factor. Proposed load of trucks due to the movement of raw materials, fuel and products has been calculated. A design capacity of road has been taken from the Indian Road Congress. Assessment of proposed traffic load is given below in Table 4.14.

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From the table below, it can be concluded that even for considering the worst case; there will be minor increase in vehicular load due to the proposed project. However, the total traffic load even after the proposed project will be very low compared to the design capacity of roads. Adequate parking arrangements will be provided within the industrial premises. As no major increase in traffic due to the proposed project, there will be less chance of increase in vehicular pollution. However, unit will take adequate measures by instructing transporter for using only PUC certified trucks/vehicles and carrying out regular service and maintenance of them.

Table 4.14: Assessment of Proposed Traffic Load Rajpar – Nashitpar Highway PCU Factor as per Type of Vehicles Vehicles Per Hour Equivalent PCU (worst case) (Passenger Car Unit) Indian per hour Road Congress Large Trailer 06 27 4.5 Heavy Vehicle 25 75 3 (Bus, Truck, etc.) Medium Vehicle (Tractors, Light Commercial 56 84 1.5 Vehicles etc.) Light Vehicle 64 64 1 (Car, Jeep, Pickup Van etc.) 3 Wheeler 72 72 1 (Rickshaw) 2 Wheeler 120 60 0.5 (Scooter, Motorcycle etc.) Total PCU/hr 382

Width of Road (m)

Design PCU per hour 2500

Existing PCU per hour 382

Proposed Load (Trucks/day) 5

Proposed PCU per day 15

As a Worst Case Scenario taken Proposed PCU per day 15 as PCU per hour Total PCU per hour after the 397 Proposed Project

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CHAPTER – 5

ANALYSIS OF ALTERNATIVES

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CHAPTER - 5 ANALYSIS OF ALTERNATIVES

5.1 Introduction:

Alternative analysis is the process of analyzing the proposed location for suitability for basic necessities to operate the plant efficiently and safely. This analysis also covers the environmental aspect of pollution prevention and improvement in quality of life around the project vicinity. The project alternative is the course of action in pace of another, that would meet the same purpose and need, but which would avoid or minimize negative impacts and enhance project benefits. Such projects may result in specific impacts which can be avoided or mitigated by adherence to certain predetermined performance standards, guidelines or design criteria. Alternative approaches may therefore be more effective in integrating environmental and social concerns into the project planning process.

5.2 Project Details:

M/s. Solisom Healthcare LLP is proposing to manufacture Active Pharmaceutical Ingredients at Survey No.: 99/P1, Rajpar-Nashitpar Road, Village: Nashitpar, Taluka: Tankara, District: Morbi, Gujarat.

Proposed product manufacturing activities are falls under schedule 5(f) – Synthetic Organic Chemicals Industry (dyes & dye intermediates; bulk drugs and intermediates excluding drug formulations; synthetic rubbers; basic organic chemicals, other synthetic organic chemicals and chemical intermediates) as per EIA notification, 2006 and therefore prior Environmental Clearance (EC) is required.

5.3 Site Alternative: [Answer to TOR no. 4(iii)]

The project site is in proximity of Morbi District of Gujarat State. Project proponent is very well familiar with the surrounding environment; therefore, it becomes easy for the unit to set up the project on above stated location. The other supporting features are briefly summarized hereunder:

 Availability of adequate land;

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 Availability of all basic facilities like infrastructure, communication, transportation, medical facilities, fuel, water, power, unskilled & skilled manpower, raw materials, road network etc.  Proximity of market;  Nearest city - Morbi is around 8 km away from the project site which is very well connected with other parts of the country by road & rail;  No R & R will be required;  Easy availability of manpower;  No national park or wildlife habitats fall within 10 km radial distance from the project site.

The location of the project is best suited to start the proposed manufacturing activities. So, no alternatives for site are analyzed.

5.4 Alternative for Technologies:

Table 5.1: Details of Proposed Technology Alternatives

Sr. Conventional Proposed Technology Particular No. Technologies Alternatives Domestic wastewater can Domestic wastewater be disposed off through generation quantity is very soak pit system. minimal. So, the domestic Option:1 wastewater management Industrial wastewater through septic tank/soak pit can be treated in ETP system is adequate. having primary, NO common ETP facilities are Secondary, tertiary available in morbi to treat the treatment and waste water generated from concentrated stream will the API mfg. process. Wastewater 1 be treated through MEE Industrial wastewater will be Management Followed by ATFD and generated from mfg. process, maintain zero liquid RO reject, Scrubber, Boiler & discharge. Cooling Tower blow down and Option: 2 Washing activities. Therefore, Industrial waste water option 1 ETP having in-house can be treated in ETP primary, secondary, tertiary having primary treatment and concentrated effluent will and treated water will be be treated through MEE sent to CETP for further followed by ATFD is adequate treatment to achieve zero discharge.

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Sr. Conventional Proposed Technology Particular No. Technologies Alternatives Unit will utilise Coal/ Briquettes as a fuel. Therefore, Multi Cyclone Separator followed by bag filter will be used as an APCM for stack Cyclone Separator attached to Steam Boiler and it followed by Bag filter can is adequate to keep emission be provided as APCM for within the statutory limit. stack attached to 1 TPH Water scrubber followed by Air Pollution activated carbon column can be 2 Steam Boiler. Control provided as APCM for stack Water Scrubber followed attached to Reactors of by Activated carbon can Pregabalin and Rivaroxaban to be provided to control control the ammonia gas and the process gas emission. VOC generated during mfg process. In addition to that activated carbon column will be provided in the stack sttached to dryer to control the emission within the statutory limit. Solid & Hazardous Waste As proposed conventional solid can be stored in separate & hazardous waste Solid/ storage area and the management is adequate and Hazardous same can be finally also guided by authority. 3 Waste disposed off to approve Therefore, it is not required to Management TSDF/CHWIF site, reuse switching on other alternative. of waste & disposal by selling to registered recycler.

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CHAPTER – 6

ENVIRONMETAL MONITORING PROGRAMME

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CHAPTER – 6 ENVIRONMENTAL MONITORING PROGRAM

6.1 Introduction

Environmental monitoring describes the processes and activities that need to take place to characterise and monitor the quality of the environment. Environmental monitoring is an important step for conducting Environmental Impact Assessment as well as in many circumstances in which human activities carry a risk of harmful effects on the natural environment. All monitoring strategies and programs have reasons and justifications which are often designed to establish the current status of an environment or to establish trends in environmental parameters. In all cases the results of monitoring will be reviewed and analysed statistically.

Environmental monitoring program is designed to understand how the environmental changes over the time. Therefore, regular monitoring program of the environmental parameters is essential to take into account the changes in the environment. The objectives of environmental monitoring program are;

1. To verify the results of the impact assessment study in particular with regard to new development; 2. To follow the trend of parameters which have been identified as critical; 3. To check or assess the efficiency of the pollution control measures; 4. To ensure that new parameters, other than those identified in the impact assessment study, do not become critical through the commissioning of new installations; 5. To check assumption made with regard to the development and to detect deviations in order to initiate necessary measures; and 6. To establish a database for future Impact Assessment Studies for new projects.

Post project environmental monitoring programme will be conducted for various environmental components as per the conditions stipulated in Environmental Clearance letter issued by MoEF&CC, New Delhi & Consent to Establish / Consent to Operate issued by GPCB. Six monthly compliance reports will be submitted on regular basis to MoEF&CC, New Delhi. Compliance Report for conditions stipulated in Consent to operate will be submitted to GPCB on regular basis. Various environmental components and pollution sources, which will be monitored under environmental monitoring programme are stack emission,

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ambient air quality, water quality and noise levels.

6.2 Environmental Monitoring Program [Answer to TOR no. 7(xii)]

The various environmental components and pollution sources which would be monitored under environmental monitoring programme includes stack emission, ambient air quality, liquid effluent, soil, noise levels and meteorological data. Monitoring/sampling and analysis/measurement of various environmental parameters will be carried out as per national/international standard methods (IS/APHA/validated method). Details of the post project Environmental Monitoring programme which would be undertaken for various environmental components, listed in Table - 6.1.

All the data and reports of monitoring of all parameters as stated in monitoring program will be properly maintained and timely reviewed by management for taking corrective or preventive actions. Monitoring reports will be regularly submitted to the concerned authorities as per their requirements.

Table 6.1: Environmental Monitoring Program [Answer to Specific TOR no. 4]

Sr. Monitoring Location Particulars Parameters No. Frequency Air Pollution

A Stacks Monitoring (Flue gas Stacks) Once in a Month SO2, NO2, PM, NH3

B Stack Monitoring (Process Gas stack) Once in a Month VOC, Ammonia 1 Ambient Air Quality Monitoring PM , PM , SO , NO , C Twice in a year 10 2.5 2 2 (2 locations within premises) NH3, VOCs Work area monitoring D Twice in a year PM10, VOCs (2 locations in process plant) Water and Wastewater Quality A Raw water i Water from Bore well Once in a Month As per IS 10500 2 B Effluents pH, COD, TDS, TSS, Industrial effluent Daily i MLSS, MLVSS (Untreated & Treated) Monthly As per EC/CC&A 3 Ambient Noise Levels

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Sr. Monitoring Location Particulars Parameters No. Frequency

i All prominent places within premises Twice in a year --

Soil 4 (1 within the premises and 1 from the Once in a year General parameters vicinity) 5 ETP sludge and evaporation residue Twice in a year General parameters

6 Safety Audit Once in Two years All safety aspects All relevant test 7 Occupation health (medical checkups) Pre, post and regular according to working profile Survival rate and 8 Greenbelt development Periodic growth

6.3 Budget for Implementation of Environmental Monitoring Plan [Answer to TOR no. 7(xii)] GPCB approved agency or NABL accredited laboratory or MoEF&CC recognized Laboratory will carry out monitoring/sampling, analysis and charge/cost will be as specified by the GPCB. Annual budget allocated towards environmental monitoring with respect to the proposed project is approx. Rs. 13, 20,000/- per Annum as described in Table - 6.2.

Table 6.2: Budget for Implementation of Environmental Monitoring Plan [Answer to Specific TOR no. 4]

Frequency of Total Particulars Quantity Parameters Monitoring Budget (INR)

Stack All flue gas Once in Month PM, SO2, NO2, NH3 Approx. Monitoring stack or as per EC or specified by 1,95,000/year and CCA GPCB in their consent Stack All Process gas Once in Month Ammonia, VOC or Approx. Monitoring stack or as per EC specified by GPCB 2,55,000/ year and CCA in their consent

Ambient Air Minimum 2 Twice in a year PM2.5, PM10, SO2, Approx.

Quality location within or as per EC NO2, NH3, VOC or 89,800/year Monitoring the premises and CCA specified by GPCB

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Frequency of Total Particulars Quantity Parameters Monitoring Budget (INR) in their consent Work zone 2 Twice in a year SPM Approx. Fugitive locations VOC 46,200/year

Monitoring NH3 Wastewater ETP Inlet & Daily pH, COD, TDS, TSS, Approx. Analysis Outlet MLSS*, & MLVSS* 6,54,000/year Evaporation Monthly As per GPCB Inlet consent Water Intake water Once in a Month As per IS: 10500 Approx. Analysis source 12,000/year Ambient --- Twice in a year -- Approx. Noise 14,000/year Soil Analysis 1 within the Once in a year -- Approx. premises and 4,000/year 1 from the vicinity ETP Waste 1 sample Twice in a year -- Approx. 4,000/year Occupation 30 persons Pre, post and Medical Checkups Approx. Health regular 45,000/year Approx. 13,19,000/year TOTAL ~ 13.2 Lacs/Year *indicate check the efficiency of secondary treatment unit.

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CHAPTER – 7

ADDITIONAL STUDIES

M/s. Solisom Healthcare LLP. Environmental Impact Assessment Report Survey No.: 99/P1, Rajpar – Nashitpar Road, Village:

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CHAPTER - 7 ADDITIONAL STUDIES

[Answer to Specific TOR no. 13]

A. Public Consultation

All the aspects of the TORs are incorporated in the draft EIA report, the same has been submitted to the Gujarat Pollution Control Board (GPCB) for conducting public hearing/public consultation as per EIA Notification, 2006 and its subsequent amendments.

Minutes of Public Consultation / Public Hearing will be included in final EIA report with suggestions/recommendations, if any after public consultation.

B. Risk Assessment Study

The said study report is presented in subsequent section.

C. Social Impact Assessment, R & R Action Plan

The socio-economic study of the study area is carried out and details are presented in the Chapter-3/Section- 3.9. It may be noted that the proposed expansion project doesn’t involve land acquisition and it is to be established on available Non Agricultural land only. The project site is intended for the industrial purpose and thus no displacement of villagers/people will take place. Therefore, the R&R (Rehabilitation & Resettlement) policy/plan is not required and not undertaken.

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7.1 Risk Assessment

The risk assessment essentially includes hazards identification, consequence analysis, risk assessment/evaluation and risk mitigation. For chemical industries, risk assessment is used for determining the risk associated with use, handling, transportation and storage of chemicals and other hazardous substances. Quantitative Risk Assessments (QRAs) are done if dangerous substances are thought to be present at a location (e.g. industrial sites and transportation routes) in amounts that can endanger the environment.

Risk assessment studies essentially encompass;  Hazard identification using techniques like checklist, preliminary hazard analysis, what-if, and HAZOP.  Hazard analysis using techniques like fault tree analysis, event tree analysis and dispersion modeling.  Consequence analysis using relevant models like ALOHA & PHAST.  Mitigation measures including:  Risk reduction  Emergency preparedness – on-site as well as off-site

7.1.1 Risk Assessment Methodology

A typical risk assessment process consists of following tasks:  Obtaining detailed description of process and plant  Identification of hazards  Identification of vulnerable targets  Select Most Credible Scenario which can be converted into an accident out of several major and minor.  Select Worst Case Scenario which has the highest potential to cause an accident of maximum damage  Identification of mitigating measures  Estimation of consequences - in the plant in form of fire, explosion and toxic effects  Estimation of frequency of occurrence  Estimate Effect of Damage  Decision making

7.2 Hazard Identification and Risk Assessment (HIRA) [Answer to TOR no. 3 (ix)] The hazard identification and risk assessment is used to identify possible accidents and estimate their frequency and consequences. While identifying hazards only those areas of plants having potential risk are used further for risk analysis. Hazard is considered

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7.2.1 Hazard Identification Methods

Hazard identification method used for the proposed expansion project is given below.  Identification of major hazardous units based on Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989 of Government of India (as amended in 2000);  Hazard Indices: Identification of hazardous units and segments of plants and storage units based on relative ranking technique.

7.2.2 Identification of Hazardous Chemicals used within Premises

Following chemicals to be stored and utilized within the premises falls under Manufacture, Storage and Import of Hazardous Chemicals Rules, 1989 (as amended in 2000). List of Hazardous Chemicals is given below.

Amongst the below described raw materials and products, some are the hazardous chemicals as per the MSIHC Rules, 2000. Chemical and physical properties of raw materials are given in Table 7.1.

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Table: 7. 1- Chemical and Physical Properties of Hazardous Chemicals Toxicity Level Flammable Limit Chemical Sr. Class TLV/ Dermal Inhalation Class NFPA No. Chemicals (As per TWA Oral Toxicity Toxicity Toxicity LEL UEL FP BP (As per Ratting MSIHC LD50 (mg/kg) LD50 LC50 % % 0C 0C Petroleum Rules) (mg/kg) (mg/l) Classification) Health – 2 TWA: > 20 10,200 mg/kg ( 58 mg/l -4°C 75 - Flammability 1. Ethyl Acetate 400 mL/kg ( 2.0% 11.5% A Flammable Rat ) (rat; 8 h) 78 °C –3 ppm Rabbit ) Reactivity - 0 Health – 3 Ceiling: 1350 Sodium 1390 Flammability 2. 2 NA mg/kg ( NA NA NA NA - Hydroxide °C Toxic –0 mg/m3 Rabbit ) Reactivity – 1 Highly Health – 3 12000 26700 TWA: > 5000 mg/kg ( 111 Toxic, Flammability 3. Toluene mg/kg ( ppm ( Rat 1.1% 7.1% 4°C A 20 ppm Rat ) °C Highly –3 Rabbit ) ) 1 h Flammable Instability - 0 Health – 1 TWA: 13900 Isopropyl 5840 mg/kg ( 72.6 mg/L Highly Flammability 4. 200 mg/kg ( 2.0% 12.7% 18 °C 82 °C A Alcohol Rat ) ( Rat ) 4 h Flammable – 3 ppm Rat ) Reactivity - 0 Health – 3 9200 2000 Hydrogen TWA: 1 801 mg/kg ( Rat 108 Highly Toxic Flammability 5. mg/kg ( mg/m3 ( NA NA NA Peroxide ppm ) (~60% soln) °C Corrosive – 0 Rabbit ) Rat ) 4 h Reactivity - 2 Health – 3 117 - TWA: 3310 mg/kg ( > 40 mg/L Highly Toxic Flammability 6. Acetic Acid NA 4.0% 19.9% 40 °C 118 B 10 ppm Rat ) ( Rat ) 4 h Flammable –2 °C Instability -0

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Toxicity Level Flammable Limit Chemical Sr. Class TLV/ Dermal Inhalation Class NFPA No. Chemicals (As per TWA Oral Toxicity Toxicity Toxicity LEL UEL FP BP (As per Ratting MSIHC LD50 (mg/kg) LD50 LC50 % % 0C 0C Petroleum Rules) (mg/kg) (mg/l) Classification) Highly Health – 3 415 TWA: 1 460 mg/kg ( Rat 1250 ppm Toxic, Flammability 7. Triethylamine mg/kg ( 1.2% 8.0% -11 °C 90 °C A ppm ) ( Rat ) 4 h Highly –3 Rabbit ) Flammable Instability - 0 Health – 2 TWA: > 15800 Toxic 5800 mg/kg ( 76 mg/l, 4 Flammability 8. Acetone 250 mg/kg 2.5% 12.8% -20 °C 56 °C A Highly Rat ) h, (rat) –3 ppm (rabbit) Flammable Instability - 0 Health – 1 182 – Ethyl 1809 mg/kg ( Toxic Flammability 9. NA NA NA NA NA 92 °C 184 C Carbamate Rat ) Flammable –1 °C Instability – 0 Health – 2 TWA: 3000 48000 Toxic Flammability 10. N-Hexane 50 ppm 25 g/kg ( Rat ) mg/kg ( ppm ( Rat 1.1% 7.5% -22 °C 69 °C A Highly –3 Skin Rabbit ) ) 4 h Flammable Instability - 0 Health – 3 TWA: 85 - 103 290 - Sulphuric 2140 mg/kg ( Highly Toxic Flammability 11. 0.2 NA mg/m3 ( NA NA NA 338 Acid Rat ) Corrosive – 0 mg/m3 Rat ) 1 h °C Reactivity - 2 Health – 2 TWA: > 2000 Toxic 450-787 mg/kg 7551 ppm 81 - Flammability 12. Acetonitrile 20 ppm mg/kg ( 3.0% 16.0% 12.8 °C A Highly (Rat) ( Rat ) 8 h 82 °C –3 Skin Rabbit ) Flammable Instability - 0 Health – 1 TWA: 17100 128.2 0>1187– 64.7 Highly Flammability 13. Methanol 200 mg/kg ( mg/L ( Rat 6.0% 31.0% 12 °C A 2769mg/kg(Rat) °C Flammable –3 ppm Rabbit ) ) 4 h Instability - 0

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The Toxicity level of hazardous chemicals as per Manufacture, Storage and Import of Hazardous Chemical (Amendment) Rules, 2000 (MSIHC) is shown as below:

Table: 7.2 - Toxicity of Chemicals capable of producing MAHs [1] Oral Toxicity Dermal Toxicity Inhalation Toxicity Sr. No. Toxicity LD50 (mg/kg) LD50 (mg/kg) LC50 (mg/l) 1. Extremely Toxic >5 <40 <0.5 2. Highly Toxic >5- 50 >40-200 <0.5-2.0 3. Toxic >50-200 >200-1000 >2-10

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7.2.3 Storage Details of Raw Material and Products

Details of the raw materials and products with storage are given in Table 7.3 (A) and (B) respectively.

Table: 7.3 (A) - Storage Details of Raw Materials Total Consumpti Capacity of No. of Units / Mode of Storage Storage Sr. Name of Raw on per Consumption Physical Storage 1 Nos. to be Storage / Capacity Inventory No. Material Month per Day (MT) State Unit stored @ a MOC (MT or days (MT) (kg or lit) time KL) 2-(2- hydroxyphenyl)- HDPE 1. 4H- 3.44 0.115 Solid 200 2 0.4 4 Drum benzo[e][1,3]oxazi n-4-one

4- HDPE 2. hydrazinylbenzoic 2.4 0.080 Solid 200 2 0.4 5 Drum acid HDPE 3. Ethyl acetate 178.98 5.966 Liquid 200 120 24 4 Drum

4. Activated Carbon 1.56 0.052 Solid Bag 25 8 0.2 4

S-(-)N-Methyl-N- benzyl-3-hydroxy- HDPE 5. 3 0.100 Solid 200 2 0.4 4 3-(2-thienyl) Drum propanamine

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Total Consumpti Capacity of No. of Units / Mode of Storage Storage Sr. Name of Raw on per Consumption Physical Storage 1 Nos. to be Storage / Capacity Inventory No. Material Month per Day (MT) State Unit stored @ a MOC (MT or days (MT) (kg or lit) time KL) 1- HDPE 6. 1.8 0.060 Solid 200 2 0.4 4 Fluoronaphthalene Drum HDPE 7. Sodium hydroxide 44.9 1.497 Solid 50 120 6 4 Bag 8. Hydrogen 0.15 0.005 Gas Cylinder 50 1 0.05 10 9. Toluene 436.25 14.542 Liquid MS Drum 200 219 43.8 3 10. Isopropyl alcohol 124.6 4.153 Liquid MS Tank 5000 2 10 2 2-chloromethyl-4- methoxy 3,5- HDPE 11. 12 0.400 Solid 200 8 1.6 4 dimethylpyridine Drum Hydrochloride 5-Methoxy-1H- HDPE 12. benzimidazole-2- 10.4 0.347 Solid 200 8 1.6 4 Drum thiol 13. Methanol 402.5 13.417 Liquid MS Tank 5000 3 15 1 HDPE 14. Hydrogen peroxide 4 0.133 Liquid 50 12 0.6 4 Carboys Ammonium.Molyb HDPE 15. 0.6 0.020 Solid 200 1 0.2 10 date tetrahydrate Drum HDPE 16. Sodium carbonate 0.84 0.028 Solid 50 2 0.1 4 Bag 17. Acetic acid 4.04 0.135 Liquid MS Drum 200 3 0.6 4 Dichloromethane 18. 150.55 5.018 Liquid MS Drum 200 100 20 4 (DCM)

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Total Consumpti Capacity of No. of Units / Mode of Storage Storage Sr. Name of Raw on per Consumption Physical Storage 1 Nos. to be Storage / Capacity Inventory No. Material Month per Day (MT) State Unit stored @ a MOC (MT or days (MT) (kg or lit) time KL) 19. S- Binol 17.2 0.573 Solid HDPE Bag 25 92 2.3 4 20. Cyclohexane 54.4 1.813 Liquid MS drum 200 36 7.2 4 Magnesium acetate 21. 3.4 0.113 Solid Bag 25 20 0.5 4 tetrahydrate 1- Carbomoylmethyl 22. 8 0.267 solid HDPE Bag 25 44 1.1 4 cyclohexyl- acetic acid Sodium HDPE 23. 103.5 3.450 Liquid 200 72 14.4 4 hypochlorite drum Methylene 24. 170.5 5.683 Liquid MS drum 200 116 23.2 4 Dichloride 25. Hydrochloric acid 128.59 4.286 Liquid FRP Tank 5000 1 5 1 1-[(4-Chloro- HDPE 26. phenyl)-phenyl - 1.95 0.065 Solid 200 1 0.2 3 Drum methyl]-piperazine HDPE 27. Chloro ethanol 0.6 0.020 Liquid 200 1 0.2 10 Drum 28. Triethyl amine 3.515 0.117 Liquid MS drum 200 2 0.4 4 Sodium mono 29. 0.78 0.026 Solid HDPE Bag 25 4 0.1 4 chloro acetate Di methyl 30. 3.96 0.132 Liquid MS drum 200 3 0.6 4 formamide HDPE 31. Acetone 10.5 0.350 Liquid 200 8 1.6 4 Drum 32. 3,5 – Dimethyl 11.04 0.368 Liquid HDPE 200 8 1.6 4

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Total Consumpti Capacity of No. of Units / Mode of Storage Storage Sr. Name of Raw on per Consumption Physical Storage 1 Nos. to be Storage / Capacity Inventory No. Material Month per Day (MT) State Unit stored @ a MOC (MT or days (MT) (kg or lit) time KL) Phenol Drum 33. Epichlorohydrine 8.4 0.280 Solid MS Drum 200 8 1.6 4 Aqueous Potassium 34. 6.12 0.204 Solid Bag 50 16 0.8 4 hydroxide 35. Ethyl carbamate 4.8 0.160 Solid Bag 25 28 0.7 4 Isovaleraldehyde 36. 9.08 0.303 Solid MS drum 200 6 1.2 4 (KSM) HDPE 37. Ethyl cynoacetate 12.26 0.409 Solid 200 8 1.6 4 Drum HDPE 38. Di-N-propyl amine 0.86 0.029 Liquid 200 1 0.2 7 Drum 39. Di-ethyl malonate 18.64 0.621 Solid SS drum 200 12 2.4 4 40. N-hexane 30.34 1.011 Liquid MS drum 200 20 4 4 41. Urea 27.22 0.907 Solid Bag 50 72 3.6 4 R-(+)-1-Phenyl Aluminium 42. ethyl amine fresh / 9.48 0.316 Liquid 200 6 1.2 4 carboys Recover Hypochlorite 43. 3.6 0.120 Gas Cylinder 900 1 1.2 8 (Chlorine Gas) HDPE 44. Sulphuric Acid 9.9 0.330 Liquid 50 28 0.9 4 carboys 45. n-Butanol 22.6 0.753 Liquid MS drum 200 16 1.4 4 Dibenzo- HDPE 46. [B,F][1,4]Thiazepin 2 0.067 Solid 200 1 3.2 3 Drum e-11(110 H)-one

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Total Consumpti Capacity of No. of Units / Mode of Storage Storage Sr. Name of Raw on per Consumption Physical Storage 1 Nos. to be Storage / Capacity Inventory No. Material Month per Day (MT) State Unit stored @ a MOC (MT or days (MT) (kg or lit) time KL) (KSM-I) 1-[2-(2- Hydroxyethoxy)Eth HDPE 47. 1.12 0.037 Solid 200 1 0.2 5 yl] piperazine Drum (KSM-II) Potassium 48. 3.8 0.127 Solid Bag 25 20 0.2 4 carbonate 49. Fumaric acid 1.04 0.035 Solid Bag 25 6 0.5 4 Phosphorousoxych 50. 3.04 0.101 Liquid MS Drum 200 2 0.4 4 loride 2-(chloromethyl)- 4-(3- HDPE 51. methoxypropoxy)- 6 0.200 Solid 200 4 0.8 4 Drum 3-methylpyridine hydrochloride 2- HDPE 52. Mercaptobenzimid 3.54 0.118 Solid 200 2 0.4 4 Drum azole Sodium 53. 1.5 0.050 Solid HDPE Bag 50 4 0.2 4 hypochlorite Di-isopropyl ether 54. 38.22 1.274 Liquid MS drum 200 26 5.2 4 (DIPE) 4-(4-Amino- HDPE 55. phenyl)- 0.87 0.029 Solid 200 1 0.2 7 Drum morpholin-3-on Potassium tert- 56. 0.51 0.017 Solid Bag 25 6 0.15 4 Butoxide

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Total Consumpti Capacity of No. of Units / Mode of Storage Storage Sr. Name of Raw on per Consumption Physical Storage 1 Nos. to be Storage / Capacity Inventory No. Material Month per Day (MT) State Unit stored @ a MOC (MT or days (MT) (kg or lit) time KL) 57. Glycidyl butyrate 0.66 0.022 Solid HDPE Bag 25 4 0.1 4 58. Lithium chloride 0.195 0.007 Solid HDPE Bag 25 1 0.025 4 HDPE 59. Acetonitrile 4.5 0.150 Liquid 200 6 1.2 4 Drum Methane sulphonyl HDPE 60. 0.51 0.017 Liquid 200 1 0.2 12 chloride Drum Potassium 61. 0.78 0.026 Solid Bag 25 4 0.1 4 Phthalimide HDPE 62. Hydrazine Hydrate 0.21 0.007 Liquid 200 1 0.2 10 Drum 5-Chloro thiopene- HDPE 63. 0.72 0.024 Liquid 50 6 0.3 4 2-carbonyl chloride Carboys N-(4-(4- fluorophenyl)-5- (hydroxymethyl)- 6- HDPE 64. 1.95 0.065 Solid 200 1 0.2 3 isopropylpyrimidin Drum -2-yl)-N- methylmethanesulf onamide HDPE 65. HBr (48 %) 1.68 0.056 Liquid 200 1 0.2 3.5 Drum Tri Phenyl 66. 1.56 0.052 Solid Bag 25 8 0.2 4 Phosphine Sodium 67. 1.41 0.047 Solid Bag 25 8 0.2 4 Thiosulphate 68. Tert-Butyl (4R-cis)- 2.25 0.075 Solid HDPE 200 1 0.2 2.5

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Total Consumpti Capacity of No. of Units / Mode of Storage Storage Sr. Name of Raw on per Consumption Physical Storage 1 Nos. to be Storage / Capacity Inventory No. Material Month per Day (MT) State Unit stored @ a MOC (MT or days (MT) (kg or lit) time KL) 6- Drum [(acetyloxy)methyl ]-2,2-dimethyl-1,3- dioxane-4-acetate Sodium Hypo HDPE 69. Chloride 10% to 3.18 0.106 Liquid 200 2 0.4 4 Drum 12% 70. KBr 0.18 0.006 Solid HDPE Bag 25 1 0.025 4 Sodium 71. 1.38 0.046 Solid HDPE Bag 25 8 0.2 4 Bicarbonate 72. Tempo Redical 0.0018 0.000 Solid Bag 5 0 DMSO (Dimethyl HDPE 73. 12.6 0.420 Liquid 200 8 1.6 4 sulphoxide) Drum NaOH Flakes / 74. 0.84 0.028 Solid HDPE Bag 25 8 0.2 4 Pallets HDPE 75. Calcium Chloride 0.42 0.014 Solid 50 1 0.05 3.5 Carboys Chloroform fresh HDPE 76. 104 3.467 Liquid 200 72 14.4 4 /Recover Drum

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Table 7.3(B) - Storage Details of Products

Capacity of

Sr. No. Description Physical Form Mode of storage Storage Transportation

1. Deferasirox Solid HDPE liner drum 4 2. Duloxetine Hydrochloride Solid HDPE liner drum 3 Esomeprazole Magnesium 3. Solid HDPE liner drum 4 Trihydrate 4. Gabapentin Solid HDPE liner drum Sale quantity will 5 5. Levocetirizine Dihydrochloride Solid HDPE liner drum be transported 3 by road, rail & 6. Metaxalone Solid HDPE liner drum 6 ship 7. Pregabalin Solid HDPE liner drum 6 8. Quetiapine Fumarate Solid HDPE liner drum 2 9. Rabeprazole Sodium Solid HDPE liner drum 3 10. Rivaroxaban Solid HDPE liner drum 1.5 11. Rosuvastatin Calcium Solid HDPE liner drum 1.6 12. R & D Activity -- -- 2 Total 41.1

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Table 7.4 - Identification of Hazards associated with Storage of Raw Materials

Sr. Name of Hazard Type of hazard Causes Effect Control Measures proposed No. material Rating / Risk involved stored Systems 1. Isopropyl TWA: 200  Fire  Glands/seal  Causes Fie / alcohol ppm /Explosion leaks in valves, Explosion and  Fire hydrant system shall be (5 MT MS NFPA Ratings: pumps burns. installed Tank X 2) Health – 1  Toxic Hose/pipe  Safety shower and eye washer Flammability failure, leakage shall be installed near storage – 3 area Reactivity - 0  Overflow from  Flame proof Electrical fittings storage tanks shall be provided at flammable storage area  Proper selection of MOC for chemicals storage tank.  Flame arrestor shall be provided on flammable material storage tank vent  Lightening arrestor on all chimney and building shall be provided  Hazardous material should be stored away from the plant and safe distance shall be maintained  Safety permit system shall be followed for loading, unloading of hazardous chemical  Fencing, caution note, hazardous identification board should be provided  Only authorized person shall be

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Sr. Name of Hazard Type of hazard Causes Effect Control Measures proposed No. material Rating / Risk involved stored Systems permitted in storage tank area and register will be maintained.

2. Methanol TWA: 200  Fire/  Glands/seal (5 MT MS ppm NFPA Explosion leaks in valves,  Causes burns.  Fire hydrant system shall be Tank X 3) Ratings: pumps  Limited evidence installed Health – 1 Hose/pipe of a carcinogenic  Safety shower and eye washer Flammability failure, leakage effect. shall be installed near storage –3 area Instability - 0  Overflow from  Flame proof Electrical fittings storage tanks shall be provided at flammable storage area  Proper selection of MOC for chemicals storage tank.  Flame arrestor shall be provided on flammable material storage tank vent  Lightening arrestor on all chimney and building shall be provided  Hazardous material should be stored away from the plant and safe distance shall be maintained  Safety permit system shall be followed for loading, unloading of

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Sr. Name of Hazard Type of hazard Causes Effect Control Measures proposed No. material Rating / Risk involved stored Systems hazardous chemical  Fencing, caution note, hazardous identification board should be provided  Only authorized person shall be permitted in storage tank area and register will be maintained.

3 Hydrochloric Ceiling: 2 ppm  Toxic  Glands/seal  In case of  Ventilate area of leak or spill. acid ACGIH TLV leaks in valves, contact,  Wear appropriate personal (5 MT FRP NFPA Ratings: pumps immediately protective equipment. Tank X 1) Health – 3 Hose/pipe flush skin with  Isolate hazard area. Keep Flammability failure, leakage plenty of water unnecessary and unprotected –0  Overflow from for at least 15 personnel from entering. Instability - 0 storage tanks minutes while  Contain and recover liquid when removing possible. Neutralize with alkaline contaminated material (soda ash, lime), then clothing and absorb with an inert material (e. shoes. Wash g., vermiculite, dry sand, earth) if clothing before possible, and place in a chemical reuse. waste container. Thoroughly clean shoes before reuse.  Immediately

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Sr. Name of Hazard Type of hazard Causes Effect Control Measures proposed No. material Rating / Risk involved stored Systems flush eyes with plenty of water for at least 10- 15 minutes, lifting lower and upper eyelids occasionally. Get medical attention immediately 4. Hypochlorite TLV (ACGIH)  Toxic  Glands/seal  A person with  If breathed in, move person into – Chlorine 0.5 ppm leaks in valves, chlorine gas fresh air. Gas NFPA Ratings: pumps poisoning may  If not breathing, give artificial (900 kg Gas Health – 3 Hose/pipe also have respiration. Cylinder X 1) Flammability failure, leakage nausea,  Consult a physician. –0  Overflow from vomiting, or a  In case of skin contact, wash off Instability - 0 storage tanks headache. with soap and plenty of water.  Chronic Take victim immediately to exposure to hospital. relatively low  In case of eye contact, rinse levels of thoroughly with plenty of water chlorine gas for at least 15 minutes. may cause pulmonary problems like acute wheezing attacks, chronic

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Sr. Name of Hazard Type of hazard Causes Effect Control Measures proposed No. material Rating / Risk involved stored Systems cough with phlegm, and asthma. 5. Hydrogen TLV (ACGIH)  Flammable  Glands/seal  Causes  Hydrogen collects under roofs and Gas Cylinder 0.5 ppm leaks in valves, Explosion at overhangs, where it forms an (50 kg X 1) NFPA Ratings: pumps low flow rates explosion hazard; any building Health – 1 Hose/pipe as low as 4 that contains a potential source of Flammability failure, leakage micrograms/s. hydrogen should have good –4  Overflow from ventilation, strong ignition Instability - 0 storage tanks suppression systems for all electric devices, and preferably be designed to have a roof that can be safely blown away from the rest of the structure in an explosion.  It also enters pipes and can follow them to their destinations. Hydrogen pipes should be located above other pipes to prevent this occurrence.  Hydrogen sensors allow for rapid detection of hydrogen leaks to ensure that the hydrogen can be vented and the source of the leak tracked down.  As in natural gas, an odorant can be added to hydrogen sources to enable leaks to be detected by

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Sr. Name of Hazard Type of hazard Causes Effect Control Measures proposed No. material Rating / Risk involved stored Systems smell.  While hydrogen flames can be hard to see with the naked eye, they show up readily on UV/IR flame detectors. Chemo- chromic indicators can be added to silicone tapes for hydrogen detection purposes.

Table 7.5 – Identification of Process Hazards Type of hazard Name of possible toxic Material in the hazardous gas release / fire process / Causes Control Measures to be provided process and / explosion / run operation operation away reaction / rupture, etc. Regular replacement of thermic fluid  Flash point variation of thermal Monitoring of flashpoint of thermic fluid fluid/oil over a period of time heater regularly  Thermal fluids which were not Installing fluid conditioning equipment in the  Fire/Explosion flammable at the operating Thermic thermal fluid system Bio Coal or LDO  Heat burns temperature when they were Fluid Heater Reduce the extent of mist formation by fitting initially installed but over time mist guards become flammable at the

operating conditions Following type of control instrumentation are suggested:  Mist Formation around leak Install temperature indicator cum controllers to

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Type of hazard Name of possible toxic Material in the hazardous gas release / fire process / Causes Control Measures to be provided process and / explosion / run operation operation away reaction / rupture, etc. points such as flagged joints, indicate temperature and prevent undesired around valves and connection overheating at the inlet and outlet of the points in the pipe line. These may system create explosive atmospheres Photo cell to sense flame failure, give alarm being formed outside the and switch off the burner pipework where ignition sources Magnetic level switch in the deaerator cum such as motors pumps and expansion tank to cut off the burner if the electrical equipment are present thermic fluid level falls below the minimum  Lagging Fire – leak and level dispersion of oil within insulation leads to fire  Raw Materials quantity must be controlled either volumetrically or gravimetrically.  Release of heat and flammable  All the  Process control devices must be installed gases chemicals which includes the use of sensors, alarms, trips  Toxic release  Fire, toxic gas release and Reactor described in and other control systems that either take  Fire explosion Vessel Raw material automatic action or allow for manual  Explosion  Failure of agitator, heating and storage intervention to prevent the conditions for cooling system in the reactor inventory uncontrolled reaction occurring.

 High Temperature indicator valve and alarm system must be provided. Auto cut off system

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Type of hazard Name of possible toxic Material in the hazardous gas release / fire process / Causes Control Measures to be provided process and / explosion / run operation operation away reaction / rupture, etc. must be provided after reaching of predetermined maximum safe temperature.  Pressure gauge must be provided. Safety Control valve is must be provided.  The Vessel Emergency Relief vent should discharge to a suitably designed catch pot or should be so positioned that people working in the area and members of the public will not be in danger if the contents of the vessel are discharged.  Use skilled worker  Mechanical seal in all pumps and reactors  Transportation of finished product from vessel to storage tank through close pipe system

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7.2.4 Credible Accident Sources / Worst Case Scenarios

Maximum Credible Accident (MCA) scenario indicates most believable, reasonable, likely or possible accident scenario and damage distance based on it. MCA scenario takes into account the effect of existing control measures also. It considers the malfunctioning of the control system, opening of safety valve/failure of safety valve, leakages from flange joint, pipe line etc. and failing of some safety devise.

Worst-case scenario (rarely possible) is defined as the release of the largest quantity of a regulated substance from a single vessel or process line failure that results in the greatest distance to an end point, e.g. catastrophic failure. It considers the failure of all control systems and release of the whole mass resulting in maximum damage.

Based on the storage and properties of the chemicals at the proposed resin manufacturing unit, the some typical scenarios relevant for MCA analysis is given in the following Table 7.6.

Table 7.6 - Scenarios Considered for MCA Analysis Worst Sr. Storage Pool Flash Toxic Chemical case No. Quantity Fire fire Dispersion scenario Isopropyl 5 MT MS 1. - alcohol Tank 5 MT MS 2. Methanol - Tank 900 kg 3. Chlorine Gas - - - tonner 5 MT MS 4. Hcl - - - Tank

7.3 Consequence Modeling Hazardous incidents start with a discharge of a flammable or toxic material from its normal containment. Discharge can take place from a crack or fracture of process vessels or pipe work, an open valve or from an emergency vent. The release may be in the form of gas, liquid, or two phase flashing of gas-liquid.

7.3.1 Damage Criteria

The storage and unloading at the storage facility may lead to fire and explosion hazards. The damage criteria due to an accidental release of any hydrocarbon arise from fire and explosion.

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A. Fire Damage

Table 7.7 tabulates the damage effect on equipment and people due to thermal radiation intensity whereas; the effect of incident radiation intensity and exposure time on lethality is given in Table 7.8.

Table 7.7 - Damage Due to Incident Radiation Intensities [2] Incident Type of Damage Intensity Sr. Radiation No. (kW/m2) Damage to Equipment Damage to People

. 100% lethality in 1 min. 1% 1 37.5 . Damage to process equipment lethality in 10 sec. . Minimum energy required to . 50% lethality in 1 min. 2 25.0 ignite wood at in definitely long Significant injury in 10 sec. exposure without aflame

. Maximum thermal radiation

3 19.0 intensity allowed on thermally --- unprotected adjoining equipment

. Minimum energy to ignite with a 4 12.5 . 1% lethality in 1 min. flame; melts plastic tubing

. Causes pain if duration is longer than 20 sec. However 5 4.5 --- blistering is un-likely (First degree burns)

. Causes no discomfort on long 6 1.6 --- exposures

Table 7.8 - Radiation Exposure and Lethality

Radiation Exposure Intensity Time Lethality (%) Degree of Burns (kW/m2) (seconds ) No discomfort even 1.6 -- 0 after long exposure 4.5 20 0 1st 4.5 50 0 1st 8.0 20 0 1st 8.0 50 <1 3rd

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Radiation Exposure Intensity Time Lethality (%) Degree of Burns (kW/m2) (seconds ) 8.0 60 <1 3rd 12.0 20 <1 2nd 12.0 50 8 3rd 12.5 -- 1 -- 25.0 -- 50 -- 37.5 -- 100 --

B. Damage due to explosion

Explosion is a sudden and violent release of energy accompanied by the generation of pressure wave and a loud noise. The rate of energy release is very large and has potential to cause injury to the people, damage the plant and nearby property etc.

BLEVE - fireball A Boiling Liquid Expanding Vapor Explosion (BLEVE) occurs when there is a sudden loss of containment of a pressure vessel containing a superheated liquid or liquefied gas. It is sudden release of large mass of pressurized superheated liquid to atmosphere. The primary cause may be external flame impinging on the shell above liquid level weakening the vessel and leading to shell rupture. Calculations are done for diameter and duration offer ball and the incident thermal flux.

Pool Fires and Jet Fires

Pool fires and jet fires are common fire types resulting from fires over pools of liquid or from pressurized releases or gas and/or liquid. They tend to be localized in effect and are mainly of concern in establishing potential for domino effects and employee safety. ALOHA Models are used to calculate various components - burning rate, pool size, and flame height, in jet fire modeling the steps followed for the thermal effects are calculation of the estimated discharge rate, total heat released, radiant fraction/source view fraction, transmissivity and thermal flux and thermal effects.

Vapor Cloud Explosion

When gaseous flammable material is released a vapor cloud forms and if it is ignited before it is diluted below its lower explosive limit, a vapor cloud explosion or a flash fire will occur. Insignificant level of confinement will result in flash fire. The vapor cloud explosion will result in over pressures. Table 7.9 tabulates the damage criteria as a result of peak over

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Peak Over Peak Over Type of Damage Type of Damage Pressure (bar) Pressure (bar)

5 -8 100% lethality 0.3 Heavy(90% damage) 3.5 –5 50% lethality 0.1 Repairable (10% damage) 2 -3 Threshold lethality 0.03 Damage of Glass 1.33 - 2 Severe lung damage 0.01 Crack of Windows 1 - 11/3 50% Ear drum rupture - -

C. Effect due to toxic gas release Various approaches are used to determine the consequences of toxic gases: • IDLH • ERPG

IDLH (Immediate Danger to Life or Health) is the maximum concentration from which escape is possible within 30 minutes without any escape-impairing symptoms or irreversible health effects.

ERPGs (Emergency Response Planning Guidelines) are airborne concentrations of chemicals that have been evaluated for three levels of emergency response.

7.3.2 Details of Model Used for Consequence Analysis

ALOHA provide output as amount of chemical discharged from the source as well as its concentration in air it takes into account different levels of concentrations for a specified chemical.

Software used for calculation is ALOHA (AREAL LOCATIONS OF HAZARDOUS ATMOSPHERES) which is a computer program designed especially for use by people responding to chemical accidents, as well as for emergency planning and training. ALOHA can predict the rates at which chemical vapors may escape into the atmosphere from broken gas pipes, leaking tanks and evaporating puddles. It can then predict how a hazardous gas cloud might disperse in the atmosphere after an accidental chemical release.

ALOHA provides output as amount of chemical discharged from the source as well as its concentration in air it takes in to account different levels of concentrations for a specified chemical. Different concentration levels are given below:

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ERPG 1: is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing other than mild transient adverse health effects or perceiving a clearly defined, objectionable odor.

ERPG 2: is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action.

ERPG 3: is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to 1 hour without experiencing or developing life- threatening health effects.

IDLH: The Immediately Dangerous to Life or Health (IDLH) level. A chemical's IDLH is an estimate of the maximum concentration in the air to which a healthy worker could be exposed without suffering permanent or escape-impairing health effects.

Input data for ALOHA are as below: Weather Data:  Average Wind Speed: 5 m/sec & 1.5 m/sec  Average Ambient Temperature: 40 °C, 22 °C  Average Humidity: 25 %, 68 %  Atmosphere Stability Class: D (windy day time), F (Extreme calm, night time).

Chemical Properties: Chemical properties of each hazardous chemical stored within premises are given in Table 7.1.

Storage Details: Storage quantity and type of storage of chemicals is given in Table 7.3 (A) & (B).

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Table 7.10 - Consequence analysis and Damage Distance (Failure of raw material storage tanks) Flammable (Distance in meter) Toxic Dispersion Flash fire Fire Ball (BLEVE) Type of Impact (Flammable Area Pool Fire Worst Case Scenario of Vapor Cloud) (meter) (meter) (meter) Name of Radiation ERPG(3)/ Chemical 37.5 25 4.5 37.5 25 4.5 UEL LEL ERPG(2) ERPG(1) Intensity(kW/m2) IDLH 100 Fatalities 50% - 100% 50% - - - % Wind Stability

Speed Class *16 meters *16 meters - *24 meters ------(12000 -- (2000 5 D <10 10 17 70 102 255 16 16 (400 ppm = ppm = ppm = PAC- Isopropyl alcohol PAC-1) PAC-3) 2) (5 MT MS Tank X 48 meters 75 48 meters 2) 48 meters -- 137 meters ------(2000 meter-- --- (2000 1.5 F <10 <10 15 78 101 253 - (2000 ppm (400 ppm = ppm = - (1000 ppm = = PAC-2) PAC-1) 10% LEL) ppm) IDLH) 45 17 meters 33 meters -- 119 meters --- 28 meters meters --- (7200 - (2100 ppm (530 ppm = 5 D <10 <10 14 44 67 184 --- (5000 --- ppm = = AEGL-2 AEGL-1 [60 ppm) (2000 AEGL-3 Methanol [60 min]) min]) ppm) [60 min]) (5 MT MS Tank X 90 38 meters 3) 38 meters 87 meters -- 218 meters --- meters --- (7200 --- (7180 - (2100 ppm (530 ppm = 1.5 F <10 <10 14 54 77 205 --- ppm = ppm = = AEGL-2 AEGL-1 [60 (2000 AEGL-3 10% LEL) [60 min]) min]) ppm) [60 min])

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19 meters 44 meters -- 164 meters ------(100 - (22 ppm = (1.8 ppm = 5 D N.A. N.A. N.A. N.A. N.A. N.A. N.A. N.A. ppm = AEGL-2 [60 AEGL-1 [60 AEGL-3 Hydrochloric acid min]) min]) [60 min] (5 MT FRP Tank X 35 meters 1) 81 meters -- 301 meters ------(100 - (22 ppm = (1.8 ppm = 1.5 F N.A. N.A. N.A. N.A. N.A. N.A. N.A. N.A. ppm = AEGL-2 [60 AEGL-1 [60 AEGL-3 min]) min]) [60 min]) 528 999 meters - 1.8 kilometers - meters --- 5 D N.A. N.A. N.A. N.A. N.A. N.A. N.A. N.A. -- (3 ppm = -- (1 ppm = (Hypochlorite) (10 ppm = ERPG-2) ERPG-1) Chlorine Gas IDLH) (900 kg Gas 907 2.1 4 kilometers --- Cylinder X 1) meters --- kilometers 1.5 F N.A. N.A. N.A. N.A. N.A. N.A. N.A. N.A. (1 ppm = (10 ppm = (3 ppm = ERPG-1) IDLH) ERPG-2) * Threat zone was not drawn because effects of near-field patchiness make dispersion predictions less reliable for short distances.

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Figure 7.1 – Isopropyl Alcohol BLEVE- Worst Case Scenario (5 m/s weather condition – stability class D)

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Figure 7.2 – Isopropyl Alcohol Flash Fire (Threat Zone) (1.5 m/s weather condition – stability class F)

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Figure 7.3 – Isopropyl Alcohol Toxic Dispersion (1.5 m/s weather condition – stability class F)

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Figure 7.4 - Isopropyl Alcohol BLEVE- (1.5 m/s weather condition – stability class F)

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Figure 7.5 - Methanol BLEVE Worst Case Scenario (1.5 m/s weather condition – stability class F)

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Figure 7.6 - Methanol BLEVE (5 m/s weather condition – stability class D)

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Figure 7.7 – Chlorine Gas Toxic Dispersion (5 m/s weather condition – stability class D)

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Figure 7.8 – Chlorine Gas Toxic Dispersion (1.5 m/s weather condition – stability class F)

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Figure 7.9 – Hcl Toxic Dispersion (5 m/s weather condition – stability class D)

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Figure 7.10 – Hcl Toxic Dispersion (1.5 m/s weather condition – stability class F)

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7.4 Failure Frequency

Fire under a tank may lead to the instantaneous release of the complete inventory of the tank. Various causes of failure may lead to a fire under a tank:  Leakage of the connections under the tank followed by ignition. This event only occurs for tanks loaded with flammable substances. The frequency is equal to 1 × 10-5 per year for atmospheric tanks [4].  The best available estimates of leak frequencies for atmospheric tanks are summarised in Table 7.11.

Table 7.11 - Atmospheric Storage Tank Leak / Tank Fire Frequencies [5]

Type of Tank Type of Release Leak Frequency (per tank year )

Liquid spill outside tank 2.8 × 10-3 Fixed/ Floating roof Tank rupture 3.0 × 10-6 Atmospheric Storage Tank Fire Frequency Fixed Roof Tank (per Type of Fire tank year)

Internal explosion & full surface fire 9.0 × 10-5

Internal explosion without fire 2.5 × 10-5

Vent fire 9.0 × 10-5

Small bund fire 9.0 × 10-5

Large bund fire 6.0 × 10-5 (full bund area)

7.5 Estimation of Effect of Damage / Impact Identification

From the dispersion modeling of IPA, Methanol, HCl and Chlorine Gas It is observed that the threat zone is maximum for Chlorine Gas from Tonner and HCl from storage tank. Percentage fatality from different incident outcome cases and level of concerns are given below:

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Incident Level Treat % Likely hood Magnitude of Chemical outcome of zone fatality of Impact/ case concern distance occurrence Damage Isopropyl 37.5 78 Very BLEVE 100 High Alcohol kW/m2 meters Unlikely 37.5 54 Very Methanol BLEVE 100 High kW/m2 meters Unlikely Hydrochloric Toxic 35 Very AEGL -3 100 High Acid Dispersion meters Unlikely Toxic 907 Very Chlorine Gas IDLH 100 High Dispersion meters Unlikely

All the threat zones in the proposed unit are super imposed on Google image. Figure 7.1 to 7.6 shows the map of vulnerable areas corresponding to different individual outcome cases. Figure 7.1 gives the location, where individual risk is found to be a maximum at locations within premises. A broadly acceptable level of individual risk as per the ALARP (AS LOW AS REASONABLY PRACTICABLE) concept of HSE, UK is 10- 6/year.

7.6 Summary

 It may be noted that in dispersion modeling, the wind direction and air temperature, atmospheric stability are found to be the deciding factors for the threat zones.

 The present risk assessment study shows that existing unit of M/s. Solisom Healthcare LLP having storages of hazardous chemicals mainly IPA, Methanol, Hcl, Chlorine Gas and other chemicals (warehouse drum storage) could have potential for damage to those inside and outside the industry. Workers working within premises of industry as well as of adjoining small unit may affect in case of accidental leakages from Chlorine Gas & Hcl.

 Fire modeling shows that the hazardous distances for IPA 78 meters in worst case scenario, In case of pool fire it is within 17 meters which might prevent effective fire-fighting arrangements to be provided .

 A maximum threat zone of approximately 907 meters is observed in the case of release of Chlorine Gas in very calm weather condition. This threat zone can be shortened by segregate storage for chlorine tonner and having adequate control measures in case of leakage.

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7.7 Proposed Risk Reduction Measures

 Storage tank of Methanol, IPA and HCl should be installed away from the plant area.  There is only one chlorine tonner will be stored in the unit. However unit has to take adequate control measures for chlorine i.e. Chlorine kits should be located in strategic locations such that they are easily accessible and are away from the affected area, in case of an emergency. Additionally Chlorine gas cartridge masks for small leaks and Self-Contained Breathing Apparatus (SCBA) sets for handling emergency, should be readily available and well maintained to enable the emergency team to provide a prompt response.  Inspection of the storage tanks as per prefixed inspection schedule for thickness measurement, joint and weld efficiency etc.  Visually inspect hoses and fittings prior to use and replace worn, corroded, or damaged parts.  Fire hydrant system shall be installed  Safety shower and eye washer shall be installed near storage area  Flame proof Electrical fittings shall be provided at flammable storage area  Hazardous material should be stored away from the plant and safe distance shall be maintained  Safety permit system shall be followed for loading, unloading of hazardous chemical  Fencing, caution note, hazardous identification board should be provided  Only authorized person shall be permitted in storage tank area and register will be maintained  Wind indicator should be provided at the highest level of the plant to know the wind direction.  Automatic sprinkler system for the flammable material tanks (over ground tanks only) may be provided as knock on effect in case of fire is possible.  Containment dykes with proper sloping and collection sumps should be provided so that any spillages in the bulk storage and other handling areas shall not stagnate and shall be quickly lead away to a safe distance from the source of leakage. This reduces the risk of any major fire on the bulk storages and the risk to the environment shall be minimized/ eliminated.  Inspection of the storage tanks as per prefixed inspection schedule for thickness measurement, joint and weld efficiency etc.  Provision of flameproof electrical fittings / equipment’s.  Proper maintenance of earth pits.

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 Strict compliance of security procedures like issue of identity badges for outsiders, gate passes system for vehicles, checking of spark arrestors fitted to the tank lorries etc.  Strict enforcement of no smoking.  Periodic training and refresher courses to train the staff in safety firefighting.  Employee training and education is carried out.  Structural fireproofing in the process area could be considered as a safety measure in the light of probable spill and fires in the area.  Emergency drills should be carried out periodically to ensure preparedness must continue.  Wind indicator should be provided at the highest level of the plant to know the wind direction.  Many operations involve use of highly toxic/flammable materials and these needs to be documented as SOPs. These must be made and kept updated on priority.  Extensive training on use of Self Contained Breathing apparatus (SCBAs) must be ensured for emergency control.  Many of the raw materials used for resin are either toxic or flammable. It is therefore important to ensure that these materials are stored in closed, well ventilated totally safe areas. A fire alarm system (heat and smoke detection) should be provided for the storage area where the material is stored as toxic fumes arise on combustion.  Loose drums of waste materials, often solvent laden, must be removed from the working areas and close watch kept.  Proper earthing needs to be provided through plug type systems or through the agitators/liquid.  Ventilation should be provided for any enclosed are where hydrocarbon or toxic vapors may accumulate. Several such areas were noticed- these may be surveyed and tackled accordingly.  All personnel should be trained in handling emergency situations and should be apprised of their role in handling emergency situation and to ensure adequacy of the emergency procedures simulated exercise should be carried out. This was found wanting.  Flame arrestor should be provided.  Adequate number of caution boards highlighting the hazards of chemicals should be provided at critical locations.  Monitoring of occupational hazards like noise, ventilation, chemical exposure etc. is carried out regularly and its record is maintained.  Good housekeeping, use of PPE, Engineering controls, Enclosure processes, scrubber system, display of safety boards, SOP of loading / unloading, local

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exhaust ventilation, safety shower etc. are important safety measures have taken to keep these chemicals within TLV.  Appropriate personal protective equipment is to be provided & ensure the usage of them.  Workers are trained for safe material handling of hazardous chemicals.  Prepare & display the safe operating procedure for hazardous chemicals storage, handling & transporting or using.  Local Exhaust ventilation and scrubber should be installed where it is required to reduce fumes, vapors, temperature and heat stress.  Reduce the level of physical activity by sharing workload with other or by using mechanical means.

 Following FIRE safety devices will be PROVIDED to protect from any malfunctioning of plant equipment. Following fire protection systems is suggested.

 Water storage of adequate capacity to meet the requirements of water for firefighting purposes.  Fire hydrants and automatic sprinkler system. Diesel driven pumps and headers to supply water to fire hydrant network.  Adequate Portable fire extinguishers, sand bucket, wheeled fire & safety equipment should be provided at the required places.  Equipment required for personal safety like blankets, gloves, apron, gum boots, face mask helmets, safety belts, first aid boxes etc. are provided. Proximity suits and self-contained breathing apparatus to be provided.

7.8 Occupational Health Surveillance Program

 Introduction

Medical surveillance program (also termed as medical surveillance for workers) can aid in the early recognition of a relationship between exposure to a hazard and disease, in the assurance of the safety of new substances, and as an indicator of the effectiveness of existing control measures. It is the systematic collection, analysis, and dissemination of disease data on groups of workers and is designed to detect early signs of work-related illness.

The Factories Act, 1948 and the rules framed there under provide for pre-employment and periodical medical examinations of workers employed in industries with hazardous processes and dangerous operations under section 41-C and section 87 respectively. Chemicals Exposed to Workers Directly or indirectly are Hcl, IPA, Chlorine, Methanol

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and other chemicals as described in raw material storage inventory. Pre-employment medical checkup and periodically medical examination will be done. Liver function testis will be carried out during pre-placement and periodical examination. In addition to the above, following safety equipment will be provided.  Action plan for Occupational Health and safety of workers

 Monitoring of occupational hazards like noise, ventilation, chemical exposure etc. will be carried out regularly and its record will be maintained.  Good housekeeping, use of PPE, Engineering controls, Enclosure processes, display of safety boards, SOP of loading / unloading, local exhaust ventilation, safety shower etc. All necessary safety measures will be taken to keep all chemicals within TLV.  Appropriate personal protective equipment will be provided & ensure the usage of them.  Workers will be trained on safe material handling of hazardous chemicals.  Prepared & display the safe operating procedure for hazardous chemicals storage, handling & transporting or using.  Periodical medical examination of the workers & Liver Function Testes will be done.  Register (Form no.37) for work place air monitoring will be done regularly.  Employee training and education will be carried out regularly.  Control the noise at source by substitution, isolation, segregation, barriers will be done.  Local Exhaust ventilation will be installed where it is required to reduce fumes, vapors, temperature and heat stress.

7.8.1 Treatment Facilities Provided to Workers affected by accidental Spillage of Chemicals

The first aid treatment facilities will be provided at the factory site. The first aid box with requisite drugs for burn, etc. will be provided at the production site to meet any eventuality.

Hazards with Acute Exposure  Contact with skin may cause severe burns or systemic poisoning.  Systemic effects may occur from any route of exposure, especially after skin absorption. Hazards with Chronic Exposure  Repeated or prolonged exposure may harm the respiratory system. Can irritate and inflame the airways.

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 Special Safety Precautions  Prevent contact with skin by wearing neoprene gloves, lab coat, and resistant apron.  Wear safety glasses or a face shield if splashing may occur.  Store in a cool, dry, well-ventilated area, away from heated surfaces or ignition sources.  Skin contact requires immediate washing of the affected area with soap and water.  Remove contaminated clothing and launder before wearing again.  Procedure for treating workmen after skin contact:  Skin contact requires immediate flushing of the contaminated area with soap and water at a sink or emergency shower for a good fifteen minutes. Remove contaminated clothing. In case of eye contact, promptly flush the eyes with copious amounts of water for 15 minutes (lifting upper and lower lids occasionally) and obtain medical attention. It is recommended to provide the safety shower and eyewash station in plant.

7.8.2 Minimization of the Manual Handling of Hazardous Substance

Employers and employees should examine their workplaces to detect any unsafe or unhealthful conditions, practices, or equipment and take corrective action. Provide flameproof electrical motor & transfer chemicals through the pipelines. Use specially designed pallets to hold, move raw materials, finished products through work areas. Minimize lifting of raw materials, heavy loads by using appropriate platforms, trolleys, etc. Avoid the moving, manual handling of hazardous material. The automatic material transfer systems will be provided wherever possible.

7.8.3 DO’S and DONT’S

Handling of Chemicals Do’s Don’ts  Know the hazards of the chemical before  Do not store the chemicals that are handling. incompatible with other chemicals.  Know the antidotes for chemical, which you  Do not spill the chemicals. are handling.  Do not dispose chemical without  Do keep material safety data sheet in neutralizing. locations where chemicals are being  Do not keep large inventory of handled and study it. chemicals.  Use appropriate personal protective  Do not allow empty containers of equipment like gloves, aprons, and hazardous chemicals to be used by respirator; face shield etc. depending upon others.

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Do’s Don’ts nature of the work.  Do not use compressed air for  Label every chemical that you use and transferring chemicals. tightly close the container.  Do not stand near chemical transfer  Use eye wash fountain / safety shower in pump while it is in operation with case of splash of chemicals in the eye or temporary hose connection. body for at least 15 minutes.  Pouring of chemicals by hand or doing  Segregate toxic, flammable chemicals and siphoning by mouth should never be keep them under control. adopted.  In addition to draining and closing valves,  Chemicals drums should never be lines should be blanked before taking up moved without protection. maintenance work.  Do not attempt to neutralize the acid /  Provide proper ventilation at the chemical alkali on the skin. Use water only. handling area to limit their concentration  Do not use solvent for cleaning hands. within prescribed level.

Material Handling Do’s Don’ts  Use proper lifting tool and tackle having  Do not use the equipment for the adequate capacity. purpose other than its design  Only authorized persons should operate intention. material handling equipments.  Do not allow personnel to move  Each tool, tackle or equipment should have underneath lifted load. number and safe working load (SWL)  Do not load the equipment above its marked on it. safe working load.  Assess weight of the material, distance to be  Do not use makeshift arrangements carried and hazards etc. before lifting the for lifting equipment without load. inspection and test.  Inspect and test all the lifting tools and  Do not use defective tool and tackles. tackles regularly as per Factory Rules.  Keep the tools & tackles free from  Wear Personal Protective Equipments while adverse effect of atmosphere by handling of material. applying suitable protective coating.  Wherever possible, mechanized material  The angle between the legs of two leg handling shall be adopted. sling should not exceed 90 degree.  While lifting a load physically, keep the load  Do not allow male and female adult to as near as possible to the body with feet lift a load manually higher than 55 kgs properly placed for body balance. and 30 kgs respectively.  Bend knees, keep back straight, keep the  Do not hold the load with tip of the load closed to the body and lift the load. fingers; grasp the load firmly with palm.

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Fire Prevention Do’s Don’ts  Follow ‘NO SMOKING’ sign.  Do not leave flammable material  Deposit oily rags and waste combustible like acetone, kerosene etc. used as material in the identified containers and cleaning agent at the work area. dispose them suitably.  Do not over tighten fire hydrant  Fire Hose used for any other purpose should valves with F-lever. be permanently marked and taken out of fire  Do not allow wild grass growth hydrant system. around storage of the gas cylinders  Keep minimum inventory of flammable and and switchyard. combustible substances.  Do not obstruct accessibility to the  Take permission before breaking or removal fire related equipment. of fire barrier and ensure subsequent  Do not destroy the inspection tag relocation of fire barrier. provided with the fire equipment.  Check periodically the operability of fixed  Do not misuse fire-fighting firefighting system. equipment other than intended  Attend any abnormality / deficiency with fire purpose. protection system promptly.  Do not store the flammable  Provide earthling or bonding to prevent material in the open container. accumulation of static charges to tanks where  Do not use instruments that are not flammable chemicals are stored / handled. intrinsically safe in the explosive  Use instruments that are intrinsically safe in atmosphere. explosive atmosphere.

House Keeping

Do’s Don’ts  Assign places for everything and maintain  Do not leave combustible materials things at assigned places. in the work area.  Clean the area after completion of work.  Do not smoke in the area of work.  Use aisle space free for personnel and material  Do not allow dust bin to overflow. movement.  Do not generate extra waste.  Ensure adequate illumination and ventilation  Do not disturb the safety for the job. equipment from assigned location.  Drop paper, plastic, glass, metal and bio-  Do not block emergency switches medical waste in a separate bin kept for this and on/off switches of the purpose. equipment by storming of materials  Know the location where emergency in front of work. equipment such as first aid box, firefighting  Do not leave cleaning agent like

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equipment, SCBA, Stretchers are kept. acetone, isopropyl alcohol,  Arrest all types of spills such as chemical, kerosene etc. at the work area after water, oil, air / gas, steam etc. and clean up the completion of work. area immediately.  Do not block fire exit point by  Ensure exits are indicated / painted for use storing materials or by means. during emergency.  Do not leave a spillage unattended.

7.9 Disaster Management Plan

[Answer to TOR no. 8 (iii) & Specific TOR no. 14]

7.9.1 Disaster

A disaster is a catastrophic situation in which the day-to-day patterns of life are, in many instances, suddenly disrupted and people are plunged into helplessness and suffering and as a result need protection, clothing, shelter, medical and social care and other, necessities of life.

There are two types of emergency control plans (1) On site emergency plan and (2) Off site emergency or disaster plan.

7.9.2 On-Site Emergency Plan

Objectives of the Plan 1. To protect persons and properly of your factory in case of all kinds of accidents, dangerous occurrences (Rule 103, Gujarat Factories Rules), emergencies and disasters happening in or affecting your plant at any time. 2. To inform people and surroundings about above happening if it is likely to adversely affect them. 3. To inform authorities including helping agencies (doctors, hospitals, fire, police, transport etc.) in advance, and also at the time of actual happening. 4. To identify, assess, foresee and work out various kinds of possible hazards, their places, potential and damaging capacity and area in case of above happenings. Review, revise, redesign, replace or reconstruct the process, plant, vessels and control measures if so assessed. 5. To work out a plan with detailed instructions to cope up with above happenings, based on your personnel, equipment and records. Levels of hazardous substances shall be minimised to the extent possible. Establish machinery for rescue and recuperation operations, total loss control and prevention of harms and

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recurrence of above happenings. Ensure that absolute safety and security is achieved within the shortest time.

7.9.3 Site Plan of the Factory and Surrounding

Proposed unit has prepared a plan of the factory premises and surroundings showing therein the areas of various hazards such' as fire, explosion, toxic release etc., and also location of assembly points, equipment room, personal protective equipment room, telephone room, first aid or, emergency control room, main gate, emergency gates, normal wind direction, north direction. The same has been given in Chapter No.2- Figure No. 2.6 of EIA report.

7.9.4 Types of Overall Emergencies

Fire (small and big), explosion, toxic exposure, strike, storm, flood and other hazardous possible situations shall be described with reasons. Sources of hazard from outside or neighboring plants, tanks, structure etc. shall be mentioned.

Table 7.12 - Types of Emergencies Type of emergency People and Sr. including disaster May arise due to At (Place) area likely to No. (Major Class) be affected Spillage or leakages at storage tank Storage area of 1 Fire Leakages/ reactor raw materials leakages

Failure of the safety valve/pressure relief valve, corrosion of Thermic Fluid 2 Explosion critical parts of the Heater Plant Operator, Thermic Fluid Heater, Labors, workers or low water level. Admin staff Release of Toxic Leakages from Tank farm area, 3 Gas/Vapor tank/pipes/valves process area

Spillage of flammable Loading and Tank farm area, 4 liquid/gas unloading process area

Deliberate Sabotage, 5 - - Terrorism, Air Raid

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Type of emergency People and Sr. including disaster May arise due to At (Place) area likely to No. (Major Class) be affected etc. Natural Calamities: - 6 Lightening, Storm, - - Earthquake, Flood etc. Collapsing of structure Overturning of tanker 7 containing - - flammable/toxic substances

7.9.5 Assessment of In-plant Hazards

Detailed hazard assessment of in-plant and control measures provided in Section 7.3, Table No. 7.3 & 7.4 of EIA report. Storage Hazards and Controls, Process Hazards and Controls are described in same topic.

7.9.6 Emergency Control System

Emergency Organizations and Functions

The organizational set-up is necessary for chain of commands during emergency situation, which may arise in the premises. The system is described in following Subsections.

Organizational Set-up Director

Plant Manager

Plant Supervisor Chemist Skilled Security workers staff

Members of above teams will be available during all shifts and holidays. Protective equipment, lifting gears, fire control points etc.; will be provided in sufficient numbers and their locations will be well informed. Necessary vehicles will be kept ready to shift persons in case of emergency.

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A. Emergency Control Room

The facilities available at the Emergency Control Center shall include: I. Internal Telephone & External Telephone: II. Address and Telephone numbers of the Factory Inspectorate, Gujarat Pollution Control Board, Police, Fire Brigade, Hospitals and OEP Team Members III. Manual Fire/Emergency Siren IV. Siren Actuation Switch V. Important Address and Telephone Numbers VI. Emergency Vehicles VII. Confined Space Entry Procedure VIII. List of Antidote/actions to be taken in case of hazardous chemical/materials. IX. Material Safety Data Sheets of chemicals X. A copy of On-Site Disaster Management Plan XI. Plant layout-indicating storage of hazardous materials, layout of fire Hydrants/extinguishers, entrances/exits, roads etc. XII. Portable P.A. System, Manual Siren, flood lights, Torches, Pickaxe, Saw, Nylon Ropes. XIII. Fire Blankets / Fire Proximity Suit, Breathing Apparatus, First Aid Box etc. XIV. List of employees with address, telephone number, blood group etc.

B. On – Site facilities for emergency control

Fire Emergency: Trained personnel will be employed in all the shifts. The responsibilities and duties include:  To fight the fire with available internal firefighting equipment and to stop leakage of liquid etc.  To provide personal protective equipment to the team.  To cordon the area and inform incident controller or site main controller about the development of emergency.  To train the persons (essential workers) to use personal protective equipment and fire-fighting equipment.

C. Fire Fighting Facilities to be provided on - site 1. Fire Buckets / Fire Extinguishers Fire buckets and portable fire extinguishers will be provided in all the areas depending upon the specific needs of the area. Some spare equipment will also be maintained in the inventory at an identified fire & safety equipment store.

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2. Fire Alarm Sirens It will be provided to alert all the employees inside the premises about the situation of an emergency.

3. Sand Buckets 5 nos. of sand buckets will be provided within the industrial premises in case of emergency fire.

4. Oxygen Cylinder Oxygen cylinder will be provided for emergency.

5. Safety Equipment All types of personnel protective equipments required for handling the emergency will be arranged in the proposed unit. Some of the protective equipments are as follow: Canister/Cartridge type masks Dust Masks PVC suits, Aprons Safety showers/ Eye Wash fountains Other personnel protective appliances, like safety glasses, gumboots, helmets, hand gloves, face shields, safety belts, safety ladders, safety torches, blankets.

6. Details of Fire Extinguishers Table 7.13 - Details of Fire Extinguishers Sr. No. Type Capacity Qty.* 1. Jockey Pump 250 RPM 1 2. Dry Chemical Powder 5Kg. 12 Nos. 3. Capacity CO2 type Fire Extinguisher 2 Kg 20 Nos. 4. Water storage tank (For Fire) 1 Lakh Litre 1 No Note: * Quantity of is assumed, however these number of cylinders may changes after commissioning of project D. Assembly Points

The assembly points for gathering workers / Admin staff is fixed and clearly marked as per the wind direction on plant layout as well as on site. In case of emergency some locations are considered as Assembly Points. Depending on the wind direction and location of emergency, Assembly Point is declared. The employees should run across the wind direction and not against the wind direction.

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E. Medical Arrangement

First Aid Boxes will be provided at various strategic locations. Requisite numbers of employees are trained about First Aid, Liaison with nearest hospitals.

F. General Procedures and Responsibilities

Mock drill: Mock drills will be carried out regularly to familiarize the staff with their roles, fire protection equipment/system installed in the plant and use of personnel protective equipment.

Wind Socks: Wind direction will be determined with the help of installed windsocks.

Procedure on Noticing an Emergency

 If anybody notices any situation, which may lead to a disaster, should be immediately inform the Shift In-charge / site controller / Incident Controller / Fire & Safety Supervisor / Security.  Take charge of the situation as Incident Controller.  Rush to the site of emergency to get the correct picture and then to Emergency Control Center for speedy control over the situation by making an arrangement for raising the alarm.  On arrival of Team members, he shall assign duties as required and activate the On- Site Emergency Plan.  Ensure safety of the plant and the personnel in the plant. He will make an assessment of the emergency and decide on external assistance.  Communicate and Coordinate among the Incidents Controller/ Site Controller/ Factory manager/ fire safety supervisor etc. and is final authority on all matters related with management of emergency such as:  Firefighting  Welfare and rescue operations.  Arrange for Civil/Mechanical/Electrical work during emergency.  Transport.

Plant Supervisor & Security Staff

 Rush immediately to the scene of the fire/emergency, select and set out appropriate fire/emergency equipment. He will take the below mentioned actions at the earliest opportunity, if the fire/emergency is not controlled.

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 He will, Call the security personnel from their residences for additional manpower if required.  Regulate entry and exit of personal required for controlling the fire/emergency.  Restrict exit of personal required for controlling the fire/emergency.  Arrange for Personnel Protective Equipment required for the emergency.  Call, the local Fire Brigade, Police in case of necessity in consultation with the Incident controller.  Arrange transport facilities for removal of causalities to dispensary / hospital.  Take responsibility of law and order.  Keep detailed records of the incident and progress of operations to fight the emergency.

Plant Manager

He will rush to the Emergency Control Centre and collect the information from the Incident Controller. Further he will,  Announce the location of the Assembly Point after getting information from Incident Controller / site controller.  Take the list of persons to be communicated internally and externally.  Maintain liaison with the press, government agencies i.e. Police, Fire Brigade etc. and the neighborhood regarding the emergency under instructions from Incident Controller.  Courteously Receive officers from the State Government or neighbors to the Administration Block only and inform to Incident Controller that they can be taken care off.  Take all the steps required for the welfare such as providing tea, snacks, emergency temporary Medical Center in consultation with the incident controller/site controller.  Disclose all the necessary information in the plant and media so as to avoid rumors and Confusion.  Also be responsible for the head counts at the Assembly Points.

Supervisor/ Shift in Charge & Security

Proceed to the scene; establish contact with firemen and incident controller to supplement efforts in firefighting. Assist in searching casualties and help to remove them to the medical center. Organize outside assistance in firefighting and rescue operations if required. Mobilize personal protective equipment and safety appliances and assist personnel handling emergency in using them.

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Keep and check on any new development of unsafe situation and report the same to Site Main Controller. Effectively cordon off the emergency area and will prevent unauthorized people entering the scene. Permit the Fire tenders or Ambulance requisitioned by Incident Controller to the plant. Ensure that vehicles and trolleys are sent out of the plant premises. Ensure that all the employees are conducted out of plant and assembled at Assembly Point. Control Traffic Movement. Remove tankers, tanker drivers outside. Entry of unauthorized person is to be prevented. Arrange for vehicles for shifting casualties and essential workers to safe assembly points. Collect and preserve evidence to facilitate future inquiries.

7.9.7 Offsite Emergency Preparedness Plan

Offsite emergency plan would follow the onsite emergency plan. When the consequences of an emergency situation go beyond the plant boundaries, it becomes an offsite emergency. As the off-site emergency plan is to be prepared by the Government, a Central Control Committee or Group shall be formed under the Chairmanship of the area head. For example, we assume a district structure and District Collector (is the Chairman of the District Control Committee (DCC).

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Figure 7.8 - Off-Site Emergency Plan

Table 7.14 - Off-site Action Plan Action required to be taken to Responsible Equipment/material Sr. mitigate disaster by aid giving agencies for facilities required at site No. agency taking action to mitigate emergency Arrangements for evacuation A Rescue of persons from zone of Self-Breathing apparatus 1 influence to predetermined With spare cylinder camps

Caution to public by 2 Chemical gas mask announcement Police with spare canister Traffic control by cordoning of 3 Department the area Vehicle with PA system 4 Law & order

Request to railway authority for Transportation for keeping the nearest railway 5 evacuation of people gate open & to stop the train sat the nearest railway station B Control of fire Self-breathing apparatus Scrubbing of the flashed off gas with spare cylinders 1 Cloud with water curtain Foam / water fire tenders 2 To rescue trapped persons Gas mask with spare If fire is big, keep surrounding canisters Limewater 3 Area cool by spraying water District Fire Neck to toe complete Communication to State Brigade asbestos suit, PVC, hand 4 Electricity Board to continue or gloves, gumboots, safety cut off electric supply goggles Communication to water supply Mobile scrubbing system 5 Department for supplying along with suction water arrangement. Medical facilities for affected Ambulance with on Hospital and C Persons (first aid and board resuscitation unit, Public health treatment) first aid, stretchers Pollution Identification of concentration D Control Gas detector of Gas in zone of influence Board Removal of debris and damaged Municipal Provide bulldozers E structures corporation Provide cranes F Monitor the incoming and out Transport Provide traffic police at

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Action required to be taken to Responsible Equipment/material Sr. mitigate disaster by aid giving agencies for facilities required at site No. agency taking action to mitigate emergency 1 Going transports department site Arrange emergency shifting of Provide emergency affected persons and shifting vehicles at site 2 non-affected person to Provide stock of fuel for specified area vehicles. Arrange diesel/petrol for 3 needed vehicles Give all information related to Provide wind direction G Meteorological aspects for safe and velocity instruments 1 handling of affected area for Meteorologic with temperature living beings al measurements Department Mobile van for Forecast important weather 2 Meteorological parameter changes, If any measurements Representatives of all Departments are in the local crisis group; therefore they are expected to render services Must have all resources at available with them. Since it is a hand, specially disaster H group of experts with authority, management plan and its 1 the mitigating measures can be implementation method. implemented speedily. The All relevant information representative’s from locals are Local Crises Related to hazardous also there so that Group industry shall available communication with local with crisis group people is easy and quick. Newspaper editor shall be The district emergency or a part of the group so that disaster control officer/ right and timely media collector shall be the president release can be done 2 and he shall do mock drill etc. so that action can be taken in right direction in time Collector shall be the President All necessary facilities Of District Crisis Group District available at district can be I therefore all district Crisis made available at affected 1 infrastructure facilities are Group zone Control of law and diverted to affected zone order situation

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