Additional Information to Eac Industry-2
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ADDITIONAL INFORMATION TO EAC INDUSTRY-2 (MoEFCC) Installation of Polypropylene unit at Rasayani, Khalapur Taluka, Raigad District, Maharashtra and interconnecting pipelines from M/s BPCL Mumbai Refinery to Rasayani Query 1: Details of protected area/ESA/ESZ within 10 km of the project area/pipeline route. Details of NBWL clearance and its updated status. Reply: The pipeline route is falling within the deemed ESZ area of Thane Creek Flamingo Sanctuary and it is located at a distance of 5.5km from Protected Area of Thane Creek Flamingo Sanctuary. The pipeline route is falling outside of ESZ of Karnala Bird Sanctuary and the nearest distance is 1 km from ESZ boundary. Draft Notification for Thane Creek Flamingo Sanctuary ESZ areas has been published by MoEFCC on 06/11/2019. Online application was submitted on Parivesh Portal for Wildlife Clearance for the pipelines passing through Thane Creek Flamingo Sanctuary on 09/08/2019 (Annexure I). Wildlife Clearance is not required for Karnala Bird Sanctuary as the pipelines falls outside of the ESZ areas. The Wildlife proposal has been forwarded by DFO, Wildlife (Kurla) on 06/12/2019 to APCCF (Mangrove Cell), Mumbai for onward processing. Copy of the same is attached for reference (Annexure II). Query 2: Details of pipeline route passing through mangrove area, details of area to be diverted and conservation plan. Reply: The proposed pipeline is passing through mangroves of 7.8012 Ha (5.3200 Ha Mangrove Forest (not Notified) & 2.14812 Ha – u/s 4 of IFA 1927) in Mahul region. The pipeline is also passing through 14.4658 Ha mangrove areas in Alibaug region. Divisional Forest Officer, Mumbai Mangrove Conservation Unit has recommended the proposal for further approval. Letter from Additional Principal Chief Conservator of Forests, Mangrove Cell, Mumbai is attached for reference (Annexure III). The pipeline is passing through CRZ-IA (Mangroves) for a length of 2644.93 m as per CRZ Report prepared by M/s Institute of Remote Sensing, Anna University, Chennai. A detailed mangrove conservation plan is attached in Annexure IV. Query 3: Details of raw material/product taken through pipeline with quantity. Reply: The proposed Rasayani Polypropylene complex project also envisages feed material pipelines from BPCL-Mumbai Refinery to Rasayani plant. To feed the petrochemical plant BPCL envisages laying following pipelines to Rasayani (District Raigad) Maharashtra. The details of pipelines are as below: 1 Pipelines From BPCL-MR to Rasayani Plant Diameter Capacity Propylene Pipeline 8” 0.45 MMTPA Multi product Pipeline (MS/ HSD/ SKO/ATF/Naphtha) 18” 6.4 MMTPA Lube Oil Pipeline 10” 0.45 MMTPA Unconverted Oil (UCO)/ Light Gas Oil (LGO) Pipeline 10” 1 MMTPA Query 4: Action plan vis-à-vis CRZ recommendations/conditions from the SCZMA needs to be submitted. Reply: The proposed pipelines, which are feed to proposed PP Plant at Rasayani are passing through coastal area and marine spread and hence as per TOR we had conducted CRZ Study through Anna University and Marine EIA Study from NIO. Subsequently after conducting EIA & RRA for entire project, BPCL applied to MCZMA, Mumbai on 18.07.2019 for CRZ clearance. MCZMA discussed our proposal vide their 138th Meeting held on 10.10.2019 had approved the project under CRZ Notifcation’2011. MCZMA recommended the proposal vide letter no. CRZ 2019/CR 153/TC 4 dated 19/11/2019. The action plan to the recommendations from the MCZMA is provided below. BPCL undertake the responsibility for fulfilment of all 10 conditions mentioned in MOM and they are mentioned below in seriatim. 1. BPCL undertakes the responsibility that it shall be carrying out pipeline laying works strictly as per the provisions of CRZ Notification ’2011 (as amended from time to time) and guidelines/clarifications given by MoEF from time to time. 2. BPCL undertakes the responsibility that it shall be obtaining prior Hon. High Court of Bombay permission before commencement of pipeline laying activities, as the project involves removal of mangroves. We wish to inform that we had already applied to Forest Clearance (involving mangroves) on 31.03.2019 vide our application ref. FP/MH/Pipeline/39455/2019 and after obtaining approval from MoEFCC, we shall be applying to Hon. High Court for permission to disturb mangroves as per the laid down procedure by Hon High Court of Bombay. 3. BPCL undertakes the responsibility to obtain NOC from Mangrove Cell and shall be doing compensatory mangrove afforestation as advised by MoEFCC or / and Mangrove Cell, Mumbai. We wish to inform that while processing Forest Clearance for the project Mangrove Cell has already recommended BPCL proposal and forwarded proposal to DCF, Alibag for onward processing. Copy of same is enclosed herewith. 4. BPCL undertakes the responsibility to obtain Forest Clearance, under Forest Conservation Act, 1980. An application in this regard is already filed to Forest Department vide application ref. FP/MH/Pipeline/39455/2019 on 31.03.2019. 2 5. BPCL undertakes the responsibility to carry out site preparation, installation of pipeline and site restoration without damaging the coastal–geomorphological features, mangrove vegetation present in CRZ area. 6. BPCL confirms that the two end points of pipelines across coastal water body are in Non CRZ area. 7. BPCL undertakes the responsibility that the pipelines shall be laid at a depth of 2.5 m (approx. 10 feets), wherever mangroves are present / in intertidal area. 8. BPCL undertakes the responsibility that natural course of coastal water bodies should not be hampered due to proposed activities and BPCL shall undertake proper measures to avoid contamination of creek water. 9. BPCL undertakes the responsibility to implement all safety measures during construction and operation phase of project. 10. BPCL undertakes the responsibility to obtain all other required permissions from various statutory authorities, as applicable prior to commencement of work. MCZMA recommended letter dated 19/11/2019 with Specific and General Condition is attached in Annexure V. Query 5: The Committee noted that the project involves forest land. However PP is unable to explain to provide the details of status of forest clearance and accordingly PP needs to be submitted the details of FC proposal and its status. The pipeline is passing through 26.0494 Ha forest areas of Mumbai Sub-urban district (7.8012 Ha) and Raigad (18.2482 Ha) district of Maharashtra. Out of which, 7.8012 Ha mangrove area falls in mahul division and 14.4658 Ha in Alibag division. A total of 3.7824 Ha of other forest areas also falls in Alibag division. Online application was submitted on 31/03/2019 (Parivesh Portal) for Forest Clearance the pipelines passing through forest areas. The submitted Form A for Forest Clearance is attached in Annexure VI. The Forest proposal for Mahul areas mangroves (7.8012 Ha) has been recommended by APPCF (Mangroves), Mumbai on 08/11/2019. Joint Field Survey by Divisional Forest Office, Alibag is under progress for Alibag forest area. Query 6: Details of rivers in the vicinity of the project site and details of mitigation measures to avoid pollution of rivers. Reply: Patalganga river is 800 m from the proposed project site at Rasayani. The pipeline is crossing the Ulwe and Kirki rivers on the way to Rasayani. 3 This will be a Zero-Liquid Discharge (ZLD) plant. The treated water will be reused as cooling tower make up. So, it can be noted that there is no impact on account of the waste water generation on the nearby Patalganga river. The pipeline is crossing the rivers through Continuous Concrete Weight Coating (CCWC) method. There is no process emission from pipelines. Hence, there will be no impact on the rivers on which the pipelines are crossing. Query 7: Details of map as per requirements under CRZ Notification needs to be submitted. Reply: The CRZ mapping is carried out by M/s Institute of Remote Sensing, Anna University, Chennai. The CRZ report and maps are attached Annexure VII. Query 8: Onsite emergency plan as per MSIHC Rules. Reply: BPCL has developed a comprehensive Emergency Response and Disaster Management Plan (ERDMP) for their Mumbai Refinery. The document is prepared in line with the Petroleum and Natural Gas Regulatory Board (PNGRB) guidelines which defines and specifies roles and responsibilities, classification of emergencies, coordination within and outside agencies etc. The document is strictly in compliance with the PNGRB guidelines and no deviation from the guidelines. ERDMP for proposed Rasayani project shall also be developed in line with the existing ERDMP for BPCL Mumbai Refinery and as per MSIHC Rules. For proposed Rasayani Polypropylene project the emergency response plan guidelines are discussed below. The project manager shall ensure that suitable instructions are issued to both BPCL and contractors personnel, identifying the action to be taken by each one in an emergency. This shall be achieved by display of organization chart/posters not only for firefighting but also other emergencies of large magnitude. A detailed Emergency/Disaster response plan (or DMP) will be drawn out in co-ordination with police authorities, fire brigade, hospitals, and neighboring industries. The plan considers organization set up, communication cell for information exchange, availability and mobilization procedure of resources for emergency situation and provision of mutual aid. The best way to manage any emergency is to prevent it. The guidelines to be ensured for emergency prevention shall be as follows: Sound engineering practice in the design fabrication, installation and maintenance of facilities: • Careful selection and correct use of equipment • Observance of safety and security requirement • Proper and constant training and guidance to all personnel working in the plant, with particular reference to product knowledge and maintenance practices 4 • Good house keeping • Constant supervision BPCL will develop integration of existing on-site Emergency Response Plans (ERPs) with the proposed facilities to enable it to respond effectively to an emergency.