D D r r a a f f t t E E I I A A R R e e p p o o r r t t Of Paragon Organics, Plot No- 582, ECP road, Village-Luna, Taluka: Padra, Dist.: Vadodara, Gujarat. Submitted by San Envirotech Pvt. Ltd. 424, Medicine Market Opp. Shefali Centre Paldi, Ahmedabad Email: [email protected]
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Collection, Storage, Transportation & final disposal at TSDF-NECL, Nandesari
2. Used carbon
- - 12.0 MT/year
12.0 MT/year
Disposed to common hazardous waste incinerator
3. Discarded Containers
33.3 200 Nos./year
1500 nos./year
1700 Nos./year
Collection, Storage & sale to registered authorized recycler
4. Distillation Residue
36.4 0.05 MT/year
4.0 MT/year
4.05 MT/year
Disposed to common hazardous waste incinerator
5. Used Oil 5.1 4 lit/year 100 lit/year
104 lit/year
reuse in workshop or sold to approved recycler
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 2-46
Table No.2.6 Fresh water required for the existing and proposed activities
Source Present In
m3/d
Proposed In
m3/d
Total In
m3/d
Domestic 2.0 4.5 6.5
Industrial
Process 0.0 4.6 4.6
Boiler 0.50 15.5 16
Cooling 0.25 3.25 3.5
Washing (floor) 0.70 11.3 12
Gardening 6.5 4.5 11
TOTAL 9.95 43.65 53.6
Table No.2.7
Wastewater generation from existing and proposed activities
Source Present In
m3/d
Proposed In
m3/d
Total In
m3/d
Domestic 1.80 3.5 5.3
Industrial
Process 0.0 5.5 5.5
Boiler 0.05 3.0 3.05
Cooling 0.05 1.5 1.55
Washing (floor) 0.20 10.5 10.7
TOTAL 2.1 24.0 26.1
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REIA of Paragon Organics 2-47
Table No.2.8
The compliance of the existing plant with CREP guideline is given in below table.
CREP compliances Sr. No.
Action point Compliance status
Segregation of waste streams: Waste streams should be segregated into high COD waste, low COD waste, Inorganic waste etc. for the purpose of providing appropriate treatment.
Presentably no wastewater generation from process hence not require.
1
Toxic steam to be collected separately & detoxify
Presentably no wastewater generation from process hence not require.
Detoxification and treatment of High COD 2 High COD stream should be detoxified and treated in ETP or thermally destroyed in incinerator
Presentably no wastewater generation from process hence not require.
Management of solid waste 3 Proper facilities should be provided for handling and storage of hazardous waste. For final disposal of hazardous waste, recycling and reuse should be given priority, either within the premises or outside with proper manifest system. In case of incinerable waste, properly designed incinerator should be installed within the premises or outside as a common facility. The non-incinerable hazardous waste should be disposed of in properly designed secure-landfill either within the industry’s premises or in a common facility – Implementation by March 2004 and action plan to be submitted to SPCB by June 2003.
We have developed the facility for segregation, collection, storage of waste and disposal as per the Hazardous waste Rule 2003/2008 ETP waste is categorized as non incinerable waste and disposed at TSDF site NECL-Nandesari.
Minimum scale of production to afford cost of pollution control 4 For new industries which are not connected with CETP & TSDF and which do not have the economics to install
Not applicable as we are member of common facilities
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 2-48
treatment facilities may not be considered for granting consent to establishment. Industry association shall submit proposal to SPCB / CPCB — implementation by December 31, 2003 and action plan to be submitted to SPCB by June 30, 2003. Long term strategies for reduction in waste 5 Consent for establishment and consent for operation under the Water Act will be based on pollution load and concentration of pollutants. Each industry will submit pollution load, concentration of final discharge alongwith water balance to SPCB/CPCB for formulation of strategy - action plan to be submitted to SPCB by June 30, 2003.
We have obtained CC & A on the basis of pollution load which derived from production, material balance/mass balance.
Control of air pollution 6 Industry will take up on priority, the control of hazardous air pollutants (such as benzene, carbon tetrachloride, 1-4 dioxane, methanol, toluene, methyl chloride etc.) and odorous compounds (mercapatan & hydrogen sulphide) - Implementation by Dec. 2004 and action plan to be submitted to SPCB by June 2003
We have installed closed handling system to transfer of low boil solvents. Presently no process emission hence not applicable.
Self-regulation by Industry though regular monitoring and environmental auditing
7
Industries on their own will carry out monitoring of environmental parameters, audit it at regular interval and submit the same to SPCB – Implementation by June 2003 Comment of BDMA - There shall be a policy for accreditating the auditors and the policy guidelines may be issued by MoEF.
Presently not applicable
8 Organizational restructuring and accreditation of Environmental Manager of Industry
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REIA of Paragon Organics 2-49
Environment management cell will be created for each industry reporting to CEO directly - Implementation by June 2003. There should be a certification system for the environmental managers at individual level and common facility level. BDMA may evolve the programme along with SPCB/CPCB - Implementation by March 31, 2004 and action plan to be submitted to SPCB by July 2003.
We have functional EHS Cell and also appointed qualified manager reporting to the managing partner.
9 Optimizing the inventory of hazardous chemicals The information shall be
submitted to SPCB regularly alongwith rational - action plan to be submitted to SPCB by May 31, 2003
Complied
10 Proper operation of incinerator Industry will check the design
and will adopt sound engineering practices for proper operation of incinerators. Continuous monitoring will be done for operational parameters and specific parameters in tail gas to ensure the efficient functioning. This will be implemented within 3 months.
We are member of common Incineration facility approved by GPCB.
Optimizing the inventory of hazardous chemicals 12 Efforts will be made to optimise the inventory, particularly of hazardous chemicals. Such information will be made available to the Regulatory Agencies (SPCBs, Inspector of Factory & District
Complied
Self-regulation by industry through regular monitoring and environmental auditing
13
Industry will go for self-assessment and regulation by conducting environmental auditing regularly, besides having regular monitoring of
A system is in existence.
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 2-50
pollutants in air emission, liquid effluent and receiving
14 Organizational restructuring and accreditation of environmental manager of industry
For self-evaluation, organizational restructuring will be done and the environmental manager of the industry will be accredited to bring professionalism in environmental management.
We have functional EHS Cell and also appointed qualified manager reporting to the managing partner.
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 2-51
Fig. 2.1 Flow Diagram of Effluent Treatment plant
Collection tank
Neutralization tank Intermediate Collection tank
Pump
Final Collection tank
Pump
Filter Press
Sludge Drying Bed
Solid Waste Storage Area
Pump
Carbon & Sand Filter
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REIA of Paragon Organics 2-52
Reactor
Primary condenser Secondary Condenser
Receiver
Utility supply
Utility Return
Utility Return
Utility supply
Vent
vent
Trap 1
Trap 2
Scrubber
Fig. 2.2 Flow Diagram of Solvent recovery system
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REIA of Paragon Organics 2-53
Fig. 2.3 Flow Diagram of scrubbing system
Exhaust
1st Stage Media Water
2nd StageMedia
Caustic
1st stage Scrubber
2nd stage Scrubber
Inlet
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REIA of Paragon Organics 2-54
Fig. 2.4 Plant layout
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 3-1
CHAPTER-3
Description of the Environment 3.1 Prelude
Any development activities related to industrial sector are expected to
cause impacts on environmental quality in surrounding area of the
respective project locations. However, the intensity of environmental
impacts from a specific project depends on several factors such as
type of process (Physical, chemical, fuel combustion etc.) involved in
the project, processing capacity (scale/size of the project), type and
extent of pollution control measures, project location, surrounding
geomorphology etc.
To assess environmental impacts from proposed project at a specific
location, it is essential to understand the environmental quality
prevailing in the surrounding area prior to implementation of the
proposed project. The environmental status within the impact zone is a
useful tool for identification of significant environmental issues. Hence,
studies are conducted to determine the baseline status.
The impacts from proposed industrial project on its surrounding
environment are mainly regulated by the nature and quantities of
pollutants discharged to the environment, existing environmental
quality, and assimilative capacity of the surrounding environment,
topography and terrain of the project site (its location) as well as the
surrounding area.
In order to identify and establish the extent of likely impacts, it is
essential to gather information on existing environmental quality with
regard to various components of the environment.
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 3-2
The following sections detail has been made to collect for the
environmental settings surrounding the Paragon Organics.
3.2 Air Environment
The impact on air environment would depend and has been identified
on the basis of identification of sources of air pollution from various
process operations; the nature of pollutants and their quantities likely
to be discharged to the atmosphere; and the baseline data on air
quality. The baseline data on air quality and micrometeorological
conditions of the area surrounding the project site have been
generated through an appropriately designed network for and
monitoring of ambient air quality (AAQ) within the zone of likely
impacts.
3.2.1 Design of Network for Ambient Air Quality Monitoring Stations
The following criteria were taken into account while designing the
ambient air quality-monitoring network:
Topography/Terrain of the study area
Populated areas within the region
Prediction of maximum concentrations and distances of their likely
Occurrence under prevailing meteorological conditions
Representation of regional background
Representation of valid cross sectional distribution in downwind
Direction
Availability of infrastructure facilities like electricity, approach, safety of equipments etc.
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 3-3
3.2.2 Reconnaissance
Reconnaissance survey was undertaken to establish the baseline
status of air environment in the study region. The prime objective of
the AAQ survey, within 10 -km radial study area around the industry
Annual* 01 01 Solvent extraction followed by HPLC/GC analysis
Arsenic (As), µg/m3
Annual* 06 06 AAS/ICP method after sampling on EPM 2000 or equivalent filter paper
Nickel (Ni) µg/m3
Annual* 20 20 AAS/ICP method after sampling on EPM 2000 or equivalent filter paper
*
Annual Arithmetic mean of minimum 104 measurements in a year taken twice a week 24 hourly at uniform interval.
**
24 hourly/8 hourly or 01 hourly values, as applicable, shall be complied with 98% of the time in a year. 2% of the time the time, they may exceed the limits but not two consecutive days of monitoring.
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 3-25
Table -3.7: Results of Ground Water Quality in the Study Area
34. Radioactive Materials a. Alpha Emitters, Bq/I, Max. b. Beta Emitters, Bq/I, Max
- -
0.1 1
Note: * Applicable only when water is chlorinated ** Provided magnesium (as Mg) does not exceed 30 mg/l Source: IS 10500: 1991, Fourth Reprint, July 1999
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 3-29
Table -3.10: Ambient Noise Levels in the Study Area
Date of Monitoring: 10/02/2010-11/02/2010 Sr. No. Location Ld/Ln Applicable
Standard Db(A)
Noise Level
Ld 75.00 59.0 1 Project Site Ln 70.00 54.4 Ld 65.00 54.1 2 Bus stop of Luna village Ln 55.00 43.1 Ld 55.00 51.9 3 Nr. Temple of Luna Ln 45.00 42.9 Ld 55.00 52.0 4 Primary School Mujpur Ln 45.00 41.6 Ld 55.00 52.7 5 Dhabasa ECP Cross Road Ln 45.00 42.0 Ld 55.00 51.7 6 Nr. Temple of Bhayli Ln 45.00 43.8 Ld 55.00 50.7 7 Primary School Ekalbara Ln 45.00 40.2 Ld 65.00 55.2 8 Bus stop of Umaraya village Ln 55.00 49.0
Table -3.11: Ambient Air Quality Standards with respect to Noise
Category of Area Limits Leq, dB(A) Day Time Night Time
Devapura P(2),H,PUC PHS,D,FPC,RP93),CHW(3) T,W,TW,R PO, Phone BS PR,KR Borsad-28 EA
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 3-40
Abbreviations: Educational
P - Primary School M - Middle School
H - Matriculation/High School PUC - Higher Secondary/Pre P University/Junior College/ Inter. C - College, Any college (Graduate level & above) I - Industrial School AC - Adult Literacy Class/ Centre
Medical Facility H - Hospital CWC - Child Welfare Centre HC - Health Centre PHC - Primary Health Centre PHS - Primary Health Sub-Centre RP - Registered Private Practitioner D - Dispensary MH - Maternity Home NH - Nursing Home FPC - Family Planning Centre TB - T.B Clinic SMP - Subsidized medical Practitioner
Drinking Water T - Tap Water W - Well Water TW - Tube well Water TK - Tank water HP - Hand Pump R - River water C - Canal L - Lake N - Nallah
Post and Telegraph PO - Post Office TO - Telegraph office PTO - Post & Telegraph Office P - Phone
Transportation BS - Bus RS - Railway Station
Approach to Village PR - Pucca Road KR - Kachcha Road
Power Supply ED - Electricity for domestic EAG - Electricity for Agriculture
Land Use R - River TWE - Tube well
T - Total
San Envirotech Pvt. Ltd-Ahmedabad
REIA of Paragon Organics 3-41
Table No-3.16: List of Tree Species found in the study area SR. NO. BOTANICAL NAME FAMILY VARNACULAR
Assessment of environmental and social impacts arising due to
implementation of the proposed project activities is at the technical
heart of EIA process. An equally essential element of this process is
to develop measures to eliminate, off set or reduce impacts to
acceptable levels during implementation and operation of projects.
The integration of such measures in to project implementation and
operation is supported by clearly defining the environmental
requirements within an Environmental Management Plan (EMP).
From the previous chapter it can be said that the proposed project of
M/s. Paragon Organics has significantly less pollution potential. For
abatement of environmental pollution, the unit would adopt several
measures, which are summarized in this chapter.
M/s. Paragon Organics is a new unit and has done the homework to
develop the efficient Environmental Management Plan. This will be
put in to existence as per the requirement after the execution of the
proposal.
5.2 OBJECTIVES OF ENVIRONMENTAL MANAGEMENT PLAN
The objectives of the Environmental Management Plan are
summarized here under,
• To limit/reduce the degree, extent, magnitude or duration of
adverse impacts
• To treat all the pollutants i.e. liquid effluent, air emissions
and hazardous waste with adoption of adequate and
efficient technology
• To comply with all the norms and standards stipulated by
Gujarat Pollution Control Board / Central Pollution Control
Board
• To create good working conditions
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-2
• To reduce any risk hazards and design the disaster
management plan
• Continuous development and search for innovative
technologies for a cleaner and better environment
5.3 COMPONENTS OF EMP
EMP for the proposed project of M/s. Paragon Organics covers
following aspects:
• Description of proposed mitigation measures for proposed
operation phase only
• Description of monitoring program
• Institutional arrangements
• Implementation schedule and reporting procedures
All above aspects and objectives are kept in the view and considering
the same EMP is prepared for two major fields.
5.3.1 Environmental Management systems
M/s. Paragon Organics is well aware of environmental requirements
for planning and implementation of the project and set up a
department with trained personnel headed under the qualified
manager. As indicated in the impact and mitigation chapter of this
report, the environmental impact due to the proposed project is very
marginal release of pollutants.
5.3.2 Environmental, Health and Safety Management System
Chemical Industries prefer an integrated approach and make
environmental management a part of overall Environment, Health
and Safety (EHS) Management system. This model EHS system
suggests and addresses EMS issues such as:
• Management system expectation
• Management leadership, responsibilities and accountability
• Risk assessment and management
• Compliance and other requirements
• Personnel, training and contractor services
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-3
• Documentation and communications
• Facilities design and construction
• Operation, maintenance and management
• Community awareness and emergency response
• EHS performance monitoring and measurement
• Incident investigation reporting and analysis
• EHS management system audit
• Management review and audit
With this type of EHS management approach, proposed project
would be able to integrate the requirements of ISO-14001 into the
overall management system.
5.4 ENVIRONMENTAL MANAGEMENT DURING CONSTRUCTION
PHASE
Since the proposed expansion project of M/s. Paragon Organics for
the manufacturing of bulk drugs will be carried in the existing
premises, less construction activities will be required for the
installation of new plant and machineries. Hence, there will be some
adverse impacts on the quality of air and water but, this will not
cause adverse effects on the surrounding atmosphere. No disposal of
construction waste outside the plant and no leaching are anticipated.
The impact will be temporary and negligible. The construction
activities for installation work shall generate noise and dust within
working areas. Therefore, measures will be taken to protect workers.
In order to mitigate the adverse environment impacts during the
construction phase, regular sprinkling of the water will be done.
5.5 ENVIRONMENTAL MANAGEMENT DURING OPERATIONAL
PHASE
5.5.1 AIR ENVIRONMENT
The main point sources will be flue gas emission from the stack
attached commonly to boiler and Thermic fluid heater due to
combustion of bio fuel and process gas emissions from the reactor
vessels containing HCl pollutant. The major air pollutants identified
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-4
from this industry will be; SPM, SO2 and NOx due to flue gas
emission and HCl from process vent.
However, in order to achieve the reduction, it is suggested that
during operational phase regular maintenance and periodic tuning of
the burner system should be done to ensure proper atomization and
subsequent minimization of any unburned combustibles. It reduces
particulate emissions. For this, combustion process may be further
improved by adopting following measures.
• Optimization of combustion aerodynamics should be done
using a flame retention device.
• Re-circulation of flue gas may be considered to achieve the
triple goals of low PM emissions, low NOX emissions and
high thermal efficiency.
• Primary flame zone O2 level should be decreased by
decreasing overall O2 level, controlling (delaying) mixing of
fuel and air, and use of fuel-rich primary flame zone.
Flue gas volume should be checked for amount of air needed for
the complete combustion of the fuel.
During operation phase, the unit may also implement energy
conservation measures through installation of heat recovery
systems. This would reduce the fuel consumption and in turn the
emissions.
Since bio fuel will be used as fuel the flue gas emission will be well
within stipulated norms and there will not be any need of APC
measures. However, the unit also proposes to provide two stage
water scrubber followed by alkali scrubber which will be adequate
to scrub the HCl gas from the process vent and to meet the
stipulated gaseous emission norms.
The unit will also provide adequate stack monitoring facilities for
the periodic monitoring of the stack to verify the compliance of
the stipulated norms.
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-5
Green Belt
In order to minimize the air pollution, the unit proposes to create
the green belt area considering the following guidelines:
• Green cover should be created at all the available open
spaces.
• To make green belt dense more trees are to be planted at
all patches where plantations already exists.
• Strict surveillance will be made to increase the survival rate
of the trees.
• Plants with higher height, medium and low height should be
planted to ensure thick belt for attenuation of fugitive
emission. This activity demands expert advice and guidance.
5.5.2 Measures for fugitive emissions
The fugitive emissions of may be from leakage through valves,
fittings, pumps, etc. Excess use of solvent may also results in the
fugitive emission from the process vessels.
Good house-keeping, proper maintenance and continuous
observation will prevent the chances of any fugitive emission from
the process plant how ever; the unit will adopt adequate measures
for the minimization/prevention of the fugitive emission. The unit
proposes to adopt following measures, which will be continued after
the production starts.
• Regular maintenance of valves, pumps and other
equipments to prevent leakage and thus minimize the
fugitive emissions of VOCs.
• Used brine chillier for recovery of Solvent.
• Entire process will be carried out in the closed reactors with
proper maintenance of pressure and temperature.
• Regular periodic monitoring of work area to check the
fugitive emission.
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-6
In case modernisation is undertaken by M/s. Paragon Organics,
design features as suggested in Table 5.1 for new equipment
may be considered.
5.5.3 Water Environment
The fresh water requirement of M/s. Paragon Organics will be
53.6 m3/day which will be satisfied through its own bore well. The
unit proposes to practice of maintaining the records for the total
water withdrawal from various resources and consumption at
various levels in the plant.
Industrial effluent generation will be around 20.8 m3/day during
the operational phase and whereas domestic effluent of @ 5.3
m3/day will be disposed off to soak pit through septic tank.
To treat the industrial effluent generated from the proposed
expansion project, the unit proposes its own Effluent Treatment
Plant consisting of primary and tertiary treatment facilities, which
will be adequate to achieve GPCB norms. The ETP is designed with
capacity of 25 KLD of effluent which will also hydraulically
adequate.
After confirming stipulated norms entire quantity of treated
effluent will be sent to CETP operated by M/s. EICL for further
treatment and final disposal into deep sea.
Cleaner production technologies will also be adopted to reduce the
quantity of fresh water requirement and industrial wastewater
generation.
The mitigation measures for minimizing the impacts on water
environment in general includes following:
• Minimization of water use
• Segregation and collection philosophy for effluent to
minimize waste generation and facilitate treatment as well
as recycle.
• Treatment philosophy to achieve mandated standards.
• Reuse/recycle and disposal
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-7
Some of the measures, which are to be implemented, include:
• Use of high-pressure hoses for cleaning the floor to reduce
the amount of wastewater generated.
• Reducing the actual process water consumption by way of
improvement in operation of processing units.
• Ensuring proper operation and maintenance schedule for the
ETP.
• Reuse ejector water from vacuum ejectors.
5.5.4 Hazardous/Solid Waste Management
Hazardous/Solid Waste management includes following:
• Measures to minimize waste generation.
• Operation of waste handling, treatment and disposal
facilities.
The Waste Management plan includes:
• Waste Inventory
• Classification of waste
• Packaging, Storing and Transporting Wastes to Disposal site
• Data Management and Reporting
• Personnel Training
• Waste Minimization
The unit has also proposed adequate hazardous waste management
system. The ETP sludge will be sent to TSDF site approved by
GPCB/MoEF. Whereas, discarded bags/liners/drums/barrels will be
decontaminated and reused within the plant premises or sold to
authorized end users and spent/waste oil will be reused as
lubricant/sold to MoEF approved recyclers. The unit has also
provided isolated area for the storage of hazardous waste having
impervious floor, leachate collection system and roof cover. The unit
will also maintain the records for the hazardous waste storage and
disposal. Entire quantity of hazardous waste will be handled as per
Hazardous Waste (Management, Handling and Tran boundary)
Rules’2008.
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-8
5.5.5 Noise Control Technique
The main sources of noise within the plant are: boiler,
manufacturing activities, transferring pumps and material
handling systems. Additional noise will be generated due to
installation of new machineries and equipments however, these
impacts will be very minor and temporary in nature. The impact
on the environment during the operational phase will be long term
but, of insignificant quantity.
To minimize the noise pollution, the unit proposes the following
noise control measures:
• Noise suppression measures such as enclosures, buffers
and/or protective measures should be provided wherever
noise level is more than 90 dB (A).
• Employees should be provided with ear protection measures
like earplugs or earmuffs. Earplug should be provided to all
workers where exposure is 85 dB(A) or more.
• The transportation contractor shall be informed to avoid
unnecessary speeding of the vehicles inside the premises.
• Extensive oiling, lubrication and preventive maintenance will
be carried out for the machineries and equipments to reduce
noise generation.
• The selection of any new plant equipment will be made with
specification of low noise levels.
• Areas with high noise levels will be identified and segregated
where possible and will include prominently displayed
caution boards.
• The green belt area will be developed within plant premises
and around the periphery to prevent the noise pollution in
surrounding area.
Monitoring of noise levels is essential to assess the efficacy of
maintenance schedules undertaken to reduce noise levels and
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-9
noise protection measures. A good quality digital sound pressure
level meter is essential for this purpose.
5.5.6 Green Belt Development
Tree plantation is one of the effective remedial measures to
control the air pollution and noise pollution. It also causes
aesthetics improvement of the area as well as sustains and
supports the biosphere.
Plantation around the pollution sources will control the air
pollution by filtering the air particulate and interacting with
gaseous pollutant before it reaches the ground.
Each plant shows different air pollution tolerance level depending
upon number of factors. In green belt area about 1000 trees per
acre of land as prescribed by Gujarat Pollution Control Board shall
be planted. The selection of tree species suitable for plantation at
the industry shall be governed by following factors,
• The trees should be tolerant to air pollutants present in the
area
• The trees should be able to grow and thrive on soil of the
area, be evergreen, inhabitant and having minimum of leaf
fall.
• The trees should be tall in peripheral curtain plantation and
with large and spreading canopy in primary and secondary
attenuation zone
• It is also recommended to plant few trees, which are
sensitive to air pollution as air pollution indicator.
The unit proposes to develop the green belt on 2,400 sqm area
about 33 % of total plot area.
5.6 RESOURCE CONSERVATION / WASTE MINIMIZATION
The units shall also implement the concept of waste minimization
circle including recovery and use of by-products. Good Housekeeping
or proper housekeeping practice makes the system easier and less
costly. Some of these are as follows:
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-10
• Solid wastes e.g. powders, spills, etc. in process, and
packaging are to be separately collected and disposed off
instead of allowing these to effluent streams. This will
reduce load and increase the efficiency of treatment system.
• Liquid wastes from various sections should be collected and
treat with effluents.
• Rain water harvesting system shall be adopted to reduce the
fresh water requirement.
• Cleaner production technology shall be adopted for the
resource conservation and pollution control.
5.7 HEALTH & SAFETY
M/s. Paragon Organics will follow occupational health program right
from the start of production. Health hazards associated with
occupation are called occupational hazards. The following check-ups
shall be carried out regularly to avoid occupational hazards:
• Pre-employment medical check-up at the time of
employment.
• Provision of periodic medical check up for all the employees
• To provide necessary first aid facilities, the first aid training
shall also be given to the employees.
• Monitoring of occupational hazards like noise, ventilation,
chemical exposure shall be carried out at frequent intervals.
• The unit will appoint the medical officer for the regular
medical examination and treatment of the employee.
• Our unit is an active member of Industries Association,
where the state of art facilities for training for Occupational
risk and safety are provided to the members of the unit. It
has also provided health care centre with required
infrastructures.
The following precautions shall be taken to avoid foreseeable accident
like spillage, fire and explosion hazards and to minimize the effect of
San Envirotech Pvt. Ltd, Ahmedabad
REIA of Paragon Organics 5-11
any such accident and to combat the emergency at site level in case
of emergency.
• Various emergency spots in plant area will be identified and
kept in sharp and alert watch.
• Use of protective equipments will be regularly checked and
will be kept easily accessible and easily workable during
emergency.
• Safety installations like available quantity of running water
will be regularly watched.
• Fire bucket and hose reels will be provided to withstand the
fire or explosion conditions.
• Various types of fire extinguishers such as (Foam type,
water type, CO2 type) will provide inside the factory
premises.
• Every pressure vessel will be provided with minimum one or
more pressure relief devices. The design of the valve is
made in such a way that the breakage of any part will not
obstruct force discharge of the liquid under pressure.
Moreover, relief valves are tested and a periodic schedule
for their testing shall be maintained. The defective valves
will be removed if found unsafe for the operation.
5.7.1 Possibility of occupational health hazard & its control
An occupational hazard is a thing or situation with the potential to
harm a worker. Occupational hazards can be divided into two
categories: safety hazards that cause accidents that physically
injure workers, and health hazards which result in the
development of disease. Hazards can be rated according to the
severity of the harm they cause - a significant hazard being one
with the potential to cause a critical injury or death.
In case of M/s. Paragon Organics, different types of solvents will
be used which can enter in the human body by the way of
inhalation of vapour or spray and skin absorption, these are the
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REIA of Paragon Organics 5-12
commonest method of entry. Skin absorption usually arises from
direct contact of the liquid solvent with the hands and arms of
workers who are cleaning objects manually or handling objects
recently dipped in or coated with solvents.
5.7.2 Preventive Measures
The methods of protecting the work force from exposure to toxic
agents in the workplace apply to the use of solvents:—
• Segregation of processes using solvents;
• Enclosures or special ventilator control of processes;
• Good general ventilation — particularly important if the
solvent is used in a confined space;
• Personal protection — Protective clothing should be worn,
including gloves, where there is a possibility of absorption
through the skin. Suitable respiratory protection is
necessary like Panorama gas mask with cartridge suitable
for the chemicals we will be handling, Breathing Air
Apparatus and Air hood with instrument air connection.
• Gas detector with emergency alarm systems in confined
area.
• Emergency preparedness plan.
5.8 OCCUPATIONAL HEALTH PROGRAMME
Some of the philosophies underlining the occupational health
programme are discussed below.
M/s. Paragon Organics will employ well qualified and experienced
safety Manager and make arrangement for part time doctor for
regular checking of health of the employees. Also, plans to become
member of any local hospital for emergency need. Annual health
check for employees will be carried out and record will be
maintained. Regular training to plant personnel in safety fire fighting
and first aid will be provided.
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Unit will maintain a healthy work environment. This will be
accomplished through the identification, evaluation and control of
workplace environmental factors which may cause sickness, impaired
health or significant discomfort and inefficiency among workers.
Environmental factors such as noise, physical hazards toxicity/
chemical hazard and ergonomic hazards will be monitored on a
periodic basis to assist in maintaining a healthy work environment.
Workers exposed to noise and toxic materials will be evaluated
against applicable recognised exposure levels in the Factories Act.
Hearing protection aid will be provided to workers who work in the
high noise areas, during construction of the proposed facilities and
also to those who will continue through the life of the facility.
5.8.1 Hazard Communication and Chemical Safety
The information on the hazards of the materials to be used will be
provided to the workers for the proposed project of M/s. Paragon
Organics. A hazardous chemical directory is being developed to
maintain information on the hazards associated with each chemical
used. Copies of Material Safety Data Sheets for all hazardous
materials at the proposed facility will be kept at the unit and will be
available for employee review. Specific programs and procedures for
the control of health hazards associated with potentially harmful
materials such as Acids, Alkali and volatile chemicals etc. will follow
the guiding principles established for Occupational Health. The
hazard communication program will serve as the basis for selection
of personal protective equipment such as gloves, goggles, face
shields, etc. A selected group of employees at the proposed facility
will receive first aid training to provide an immediate response and
medical care for injuries.
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5.9 POST-PROJECT ENVIRONMENTAL MONITORING
The post – project environmental monitoring suggested herewith
should be as per the following guideline. The highlights of the
integrated environmental monitoring plan are:
• The stack monitoring facilities like ladder, platform and port
– hole of all the stacks maintained in good condition.
• Regular monitoring of all gaseous emissions from stacks /
vents and all fugitive emissions in the process areas.
• The performance of air pollution control equipment
evaluated based on these monitoring results.
• Water consumption in the complex recorded daily.
• Analysis of untreated and treated effluent, before discharge
into the final disposal pipeline carried out regularly.
• Performance of effluent treatment plant units evaluated
based on these analysis results.
• As far as possible, noise curbed at its source, with the help
of acoustic hood and other such noise reducing equipments.
• Regular noise level monitoring to be carried out.
• Green belt properly maintained and new plantation
programmes undertaken frequently.
• Continued environmental awareness programmes carried
out within the employees and also in the surrounding
villages.
• Rain water harvesting ponds will be developed within the
industrial premises and encouraged in the surrounding
villages too. All possible back–up and support provided to
them.
Ambient Air Quality monitoring
Schemes for monitoring ambient air quality stack emissions and
fugitive emissions are proposed. The ambient air quality
monitoring systems are recommended for monitoring the ground
level concentrations and fugitive emissions around the plant. M/s.
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Paragon Organics should install three monitoring stations around
its battery limit (at 1200 as per guideline) for monitoring SPM, SO2
and NOX. The combined data will provide overall characteristic and
emission from the industry. For this, the following equipment is
recommended to be procured or can higher the services from
Environmental consultant by the project proponent for
implementing the above mentioned monitoring schemes:
Respirable dust sampler
Blower -1.0-1.5 m3/min capacity with adapter for uniform suction
through filter and a properly calibrated manometer assembly for
the determination of flow rate through filter paper.
Rota meter- For gaseous sampling, calibrated Rota meter (0-5
LPM) for maintaining flow rate should be provided
Main housing-The main housing should be rectangular with a
stand of about 1.25 m height.
Besides this, stack emissions monitoring as per GPCB guidelines
shall be carried out.
Noise Environment
Monitoring of noise levels is essential to assess the efficacy of
maintenance schedules undertaken to reduce noise levels and
noise protection measures. A good quality digital sound pressure
level meter is essential for this purpose.
Water Environment
Wastewater should be analyzed at the ETP discharge regularly.
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Table – 5.1:- Design features for minimization of fugitive emissions
Sr
No Equipment Design Features
Control Efficiency
%
Seal less design 100 1 Pumps
Dual Mechanical Seal 100
2 Valves Seal less Design 100
3 Compressor Dual Mechanical Seal 100
4 Connectors Weld together 100
5 Pressure Relief
Devices Rupture Disc 100
6 Sampling
Connection Closed loop sampling 100
Table – 5.2:- Environment Monitoring
Nature of Analysis Frequency of Analysis
Number of Sample
Stack Monitoring of each stack (Flue gas & Process stack)
Monthly At all stack
Work Place monitoring
including Hydrocarbon
Monthly 3 Locations
Ambient Air Quality
Monitoring
Monthly for 24 hours or as per the
statutory conditions
3 Location
Industrial Effluent for applicable parameters as per the Consents Conditions
Ones in a Month One Sample
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Figure – 5.1: EHS Management
Technical Director
Partner
Environment Management
Cell
Officer -
Environment/Safety
ETP Operator
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REIA of Paragon Organics 6-1
Chapter - 6 QUANTITATIVE RISK ASSESSMENT
6.1 INTRODUCTION
M/s. Paragon Organics has been one of the bulk drugs manufacturing
unit since 2004 located at plot no. 582, ECP road, Village: Luna,
Taluka: Padra, Dist.: Vadodara. Now, the unit proposes to enhance
its production capacity with introduction of some new bulk drugs.
The risk assessment studies have been conducted for identification of
hazards, to calculate damage distances and to spell out risk
mitigation measures.
6.1.1 Scope of Study
The scope of work is to carry out risk analysis for the proposed
project of the production facility covering all the hazardous chemicals
to be handled and stored at the plant.
6.1.2 Study Objective
The objective of the risk analysis includes the following:
• Identification of hazards
• Selection of credible scenarios
• Consequences Analysis of selected accidents scenarios
• Risk Mitigation Measures
6.1.3 The Study Approach
The risk assessment study broadly comprises the following steps:
• System Description
• Identification of Hazards
• Selection of Credible Accident Scenarios
• Consequence Analysis
• Risk Mitigation Measures
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6.1.4 System Description
This step comprises the compilation of the location, design and
operational information needed for the risk analysis.
6.1.5 Identification of Hazards
Hazards associated with the plant are identified and summary of
relevant accident cases are reviewed.
6.1.6 Selection of Accident Scenarios
The release sources and potential accidents scenarios in the plant are
listed. For each selected release source several scenarios are
developed depending upon the failure mode causing loss of
containment.
6.1.7 Effects & Consequence Estimation
Effects & consequence estimation are done to determine the potential
for damage or injury from the selected scenarios. The incident
outcomes are analyzed using release rate, dispersion, combustion,
and heat radiation and explosion models from fires.
6.1.8 Risk Reduction Measures
Based on hazard identification and consequence analysis, risk
reduction measures are suggested to reduce risk and enhance safety
at the plant.
6.2 HAZARDOUS IDENTIFICATION
Hazard is defined as those chemical or physical conditions that have
the potential for causing damage to people, property or the
environment. This chapter describes hazards associated with the
plant due to handling and storage of hazardous chemicals. Maximum
credible accidents scenarios involved in release of hazardous
materials are selected and vulnerable zones are computed.
Hazard identification is the first step in the risk analysis and entails
the process of collecting information on the types and quantities of
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hazardous substances stored and handled, the location of storage
tanks & other facilities, potential hazards associated with the spillage
and release of hazardous chemicals.
The assessment of vulnerable zones resulting from an accidental
release of hazardous substance into the environment is one of the
key elements of risk analysis. Quantification of the effects of such
releases requires, data of the chemicals stored or handled in the
area, quantities stored, operating parameters, quantity that would be
released in case of an accident, meteorological conditions and
physical attributes of the area.
The starting point of risk analysis study is the identification of
hazards and selection of scenarios that are then addressed for further
consequence analysis.
The proposed plant will be engaged in handling and storage of
various flammable and toxic hazardous materials. Important
characteristic of these hazardous materials are described in details.
6.2.1 Hazardous Substances to be handled at Paragon Organics
M/s. Paragon Organics will be engaged in handling and storage of
various flammable and toxic hazardous materials. Important
characteristic of these hazardous materials are described in details.
6.2.2 Hydrochloric Acid (26 – 28 %)
Hydrochloric acid is of slightly yellow Colour with a pungent, irritating
odor and identified as a corrosive hazard of Class 8. When spilled on
the ground, it evaporates and some toxic vapor may be formed but
acid vapor cloud will be vary small and of no consequence is
anticipated.
6.2.3 Toluene
Toluene is a clear and colourless liquid with a sweet, pungent,
benzene-like odour. It is chemically stable and will not polymerize.
However, it is reactive with strong oxidizing agents, concentrated
H2SO4 and HNO3, N2O4, AgClO4, BrF3, HF6, halogens and molten
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Sulphur. On combustion, it releases carbon monoxide, nitrogen
oxides, smoke and part of oxidized hydrocarbon fragments.
It is sensitive to static discharge and will accumulate a static charge
on agitation or while decanting but it is not sensitive to mechanical
impacts.
Physical and chemical properties of Toluene are as given below:
Odour Threshold range 0.2 – 37 ppm
Vapour Pressure 22 mmHg / 7.1kPa (20oC)
Vapour Density 3.1 (air = 1)
Boiling Point 110.6oC
Freezing Point -95oC
Specific Gravity 0.868
Water Solubility 0.6 gm/l (200C)
Flash Point 4.4oC - 6oC
Auto ignition Temperature 4800C – 550oC
Flammable Limits 1.2 % - 7.1%
Toluene should be stores and handled in a cool dry environment,
away from sources of ignition, heat and oxidizing agents and
adequate ventilation should be provided. Toluene accumulates a
static charge during transfer from one container to another. When
transferring the quantity over 5 litres, prior grounding should be
done to containers to prevent static discharge. Cutting, drilling,
welding or grinding should be avoided on or near toluene containers.
Foam, dry chemical, water fog should be used as fire fighting media.
Water spray can be used only to cool the containers. Water jet
should not be used for extinguishing as toluene floats on water and
will not cool below flash point.
6.2.4 Sodium Hydroxide (NaOH)
Sodium hydroxide is white flaked and odourless. It is identified as a
corrosive hazard of ‘Class 8’. On spillage on the ground, it
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evaporates and some toxic vapour may be formed but this alkali
vapour cloud is generally vary small and of no consequence.
It is harmful if swallowed or inhaled and causes burns to any area of
contact. It is not considered to be fire hazard. Do not handle without
PPEs. Use safety goggles, Gumboots, PVC hand gloves and rubber
apron if required.
Main Physical properties are as follows:
Molecular formula NaOH
Appearance Clear Soapy Liquid or white
flakes
Odour Odourless
Boiling point 1480C
Vapour pressure at 400C 3.6 mm Hg
Bulk density 1.5 g/ml
pH Highly alkaline
Specific gravity 2.12
6.2.5 Acetone
Acetone is a colorless liquid having fruity odour and pungent in
taste. It is identified as a hazardous in case of skin contact (irritant),
of eye contact (irritant), of ingestion, of inhalation, slightly
hazardous in case of skin contact (permeator). The substance is
toxic to central nervous system (CNS), it may be toxic to kidneys,
reproductive system, liver & skin. Repeated or prolonged exposure
to the substance can produce target organs damage. Do not handle
without PPEs. Use safety goggles, Lab coat, Vapour respirator, be
sure to use approved gloves.
Main Physical properties are as follows:
Molecular formula C3H6O
Appearance Clear Liquid
Odour Fruity
Boiling point 56.20C
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Vapour pressure at 200C 24 kPa
Vapour density 2 (Air=1)
pH Not applicable
Specific gravity 0.79
Odour Threshold limit 62 ppm
6.2.6 Chloroform
Chloroform is a clear colorless liquid having pleasant, sweetish odour
with burning, sweet taste. It is identified as a hazardous in case of
skin contact (irritant), of eye contact (irritant), of ingestion, of
inhalation, slightly hazardous in case of skin contact (permeator).
The substance is a toxic in nature. Do not ingest, do not breathe
gas/fumes/vapour/spray. Wear suitable protective clothing. In case
of insufficient ventilation, wear suitable respiratory equipment. If
ingested, seek medical advice immediately and show the container
or the label. Avoid contact with skin and eyes. Keep away from
Incompatibility such as metals & Alkalis. Do not handle without PPEs.
Use safety goggles, Lab coat, Vapour respirator.
Main Physical properties are as follows:
Molecular formula CHCl3
Appearance Clear Liquid
Odour Pleasant, Sweetish
Boiling point 61.00C
Vapour pressure at 200C 21.1 kPa
Vapour density 4.36 (Air=1)
Specific gravity 1.484
Odour Threshold limit 85 ppm
6.2.7 Xylene
Xylene is a colorless liquid with aromatic hydrocarbon odour. It is
identified as a harmful by inhalation and in contact with skin. Vapour
may cause drowsiness and dizziness. Slightly irritating to respiratory
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system. Irritating to skin. Moderately irritating to eyes, may cause
lung damage if swallowed. Possibility of organ or organ system
damage from prolonged exposure. Highly flammable in use, may
form flammable/explosive vapour-air mixture. Electrostatic charges
may generated during pumping,. Electrostatic discharge may cause
fire. It is a toxic to aquatic organism. Do not handle without PPEs.
Use safety goggles, Lab coat and Vapour respirator.
Main Physical properties are as follows:
Molecular formula C6H4(CH3)2
Appearance Colorless liquid
Odour Aromatic hydrocarbon
Boiling point 135-1550C
Vapour pressure at 200C 0.8-1.2 kPa (4.5kPa@500C)
Vapour density 3.7 (Air=1)
Specific gravity 0.87
Flash Point 21-27 0C
Explosive Limits (In Air) 1-7.1 %
6.3 QUANTITIES OF HAZARDOUS MATERIALS
Many chemicals will be stored at the plant in small to large
quantities as per requirement. Majority of chemicals are stored in
small quantities. As per Manufacture, storage and Import of
Hazardous Chemicals rules 1989 and amendment subsequently,
there will be only few hazardous chemicals, which have potential for
creating risk to life and property in an unlikely event of leakage or
spillage followed by fire.
The bulk quantities of hazardous chemicals are stored at the plant in
tank farm area with adequate dyke. Other chemicals will be stored in
cylindrical tanks, barrels and carboys. Details of storage of
hazardous materials are given in Table 6.1.
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Table 6.1: Facilities for Storage of Chemicals
Sr. No.
Name of Chemicals Storage Capacity, MT
MOC
1 NaOH 15.0 MSRL
2 Methanol 5.0 MS Drum
3 Acetone 2.0 MS Drum
4 Toluene 2.5 MS Drum
5 HCl 1.0 Carboys
6.4 HAZARDS DUE TO LEAKAGE OR CONTAINMENT
Hazardous chemicals to be handled and stored at the plant are in
mostly liquids form. In the event of leakage or accidental release of
these chemicals, it will create only localized effects within the short
distances from fixed or spread pool in case of fire. There is
possibility that release of some hazardous chemicals may form
vapour cloud which can move towards wind direction and may
explode in the event of fire if mass and concentration of air and
vapour mixture is within the LEL and UEL limits. However, mass of
vapour and air mixture may not be adequate to generate explosive
mass.
Storage and handling of hazardous chemicals will not pose any
hazardous situation if these are handled or stored correctly with
adequate safety provisions and fire fighting facilities. Therefore,
suitable safety measures including fire fighting facilities will be
provided at the plant to attend any emergency due to accidental
release of these hazardous chemicals.
Among the hazardous inventories, there are few potential toxic
materials that can form toxic vapour cloud in unlikely event of
release.
6.5 MAXIMUM CREDIBLE ACCIDENT SCENARIOS
The plant will be dealing with many hazardous substances described
in details. Most of hazardous chemicals are in the form of liquid and
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considered as flammable and provided with dyke for loss of
containment. Subsequently, their consequence due to thermal
radiation will be confined within short distances. If released
quantities are not ignited, therefore, vapour formation can result in
vapour and air mixture and may generate explosive mass which can
explode if it gets the source of ignition. Toxic cloud of hazardous
chemicals may also be formed and moved towards wind direction.
6.5.1 Methodology for Selection of Accident Scenarios
In this study, following steps are followed for scenario selection for
risk analysis study:
• The hazardous materials to be handled at the plant and the
associated hazards have been identified and assessed.
• Operating and storage conditions of handling and storage of
hazardous materials are studied.
• An assessment is made of what inventories can get released
accidentally.
• Release rates are calculated considering deferent cases. For
further analysis of selected release sources, representative
failure modes and failure sizes are identified.
6.5.2 Maximum Credible Accident Scenarios
Following maximum credible scenarios have been selected for
consequence analysis as a result of accidental releases:
Table No. 6.2- Maximum Credible Accident Scenarios
Sr. No.
Type of Release Outcome Cases Considered
Formation of pool and thermal radiation due to fire Vapour cloud explosion 1.
Release of Toluene from Drums
Dispersion of toxic cloud of vapours Formation of pool and thermal radiation due to fire Vapour cloud explosion 2. Release of Chloroform Dispersion of toxic cloud of vapours
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Sr. No.
Type of Release Outcome Cases Considered
Formation of pool and thermal radiation due to fire Vapour cloud explosion 3. Release of Acetone Dispersion of toxic cloud of vapours
6.5.3 CONSEQUENCE ANALYSIS
Consequence analysis for the selected accident scenarios has been
carried to estimate the vulnerable zones. Thermal radiation
distances have been computed based on various heat flux values
vulnerable to men and materials at the plant, while modelling of
dispersion cloud is based on IDLH (Immediately Dangerous for Life
and Health) values. On identification of vulnerable zones for failure
cases, measures can be taken for risk mitigation and to eliminate or
minimize damage to the plant and injury to personal.
6.6 Probable Hazards & Risk
From the preliminary risk assessment study carried out for Paragon
Organics, some of the possible hazards have been identified. The
likely accident scenarios considered are given below:
Table No. 6.3 Probable Hazards & Risk
Sr. No.
Scenario Vulnerability Zone
Remarks
1. Spill of Solvent /Acids/Alkali
Area close to spill area
Isolate the area immediately and ensure no ignition source comes near by. Reclaim the material if possible or cover the spill with sand/mud /foam (to be safely disposed off later)
2. Flammable liquid tank in tank farm on fire
Area adjoining to tank periphery/ other tanks in tank farm
Deluge all adjoining tanks till fire stops and heat is dissipated. Transfer/neutralize the spillage (if any).
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The above-mentioned hazards scenarios can further aggravate into
much more serious incidents if not intercepted in time. The fire in
one tank of tank farm can spread to adjoining tanks and may result
in explosions. The vulnerability zone will be considerably enlarged.
The vapors of toxic fluids/dust if carried away by wind above TLV
concentrations may further enlarge the vulnerability zone. Similarly,
toxic fluid spillage and all wastes leaving the live processing zone if
not decontaminated properly can cause serious health hazard to
plant personnel and persons in nearby area.
6.7 METHODOLOGY, APPROACH AND DAMAGE CRITERIA FOR RISK
ASSESSMENT
Consequence analysis is that part of risk analysis, which considers
individual failure cases and the damage, caused by each failure case.
It is done to predict the outcome of potentially serious hazardous
accidents to man and material in and around the plant boundary
limits. The advantages of carrying out consequence analysis are
given below:
• To improve plant layout (for new projects and for expansion of
existing one)
• To meet statutory requirements
• Protection of public in the nearby areas (no residential/
inhabited near by)
• Disaster management planning
• Training tool
The findings of a consequence analysis provide information about
hazardous effects resulting from an accident scenario. In addition,
Methods for dealing with possible catastrophic events are also
provided.
6.7.1 Hazards Evaluation: Exposure to Toxic Dusts / Vapors
Leakage in process plant from failure of nozzles, joints (flange joint),
welding failures or dripping from non-holding valves/glands or dusts
generation during charging of solids at times goes unnoticed. If the
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leaky dust or fluids being toxic and odorless it is a potential source
of risk, which may cause fatal/serious hazards.
Liquids with high saturation vapor pressures evaporate faster
because the evaporation rate (mass/time) is essentially proportional
to the saturation vapor pressure. In the case of vaporization into
stagnant air, the vaporization rate is proportional to the difference
between the saturation vapor pressure and the partial pressure in
the stagnant air.
6.7.2 Liquid Pool Evaporation or Boiling
The pool boiling cases may be encountered during heavy leakage in
enclosed area (dyke wall of tanks) and with heat source nearby
(ambient or fire) the vapor can explode or catch fire (in case the
material is flammable and sparks/flame contact is made).
6.7.3 Plant Leakage in Confined Space
A chemical fluid spill is a common type of process incident and can
lead to potentially serious accident. If the spilled material gives rise
to hazardous vapor or aerosol these may interact with plant
environment resulting in explosion or harm to plant’s personnel/
damage to plant equipment/machinery (if vapors are toxic/
corrosive/inflammable). Most chemical spills do not have such
dramatic sequences but they must all be handled carefully and
correctly. Plant of Paragon Organics will open with natural
ventilation.
6.7.4 Damage Criteria
In order to appreciate the extent of damage produced by various
accident scenarios, it is appropriate to discuss the physiological/
physical effects of toxic fluid exposure/thermal radiation intensities
due to spillage causing subsequent fire. The thermal radiation
usually results in burn on the human body and damage to
plantation. Furthermore, inanimate objects like equipment, piping,
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cables, etc. may be affected and may aggravate the situation
further.
Consequence analysis has been carried out for selected failure cases.
Consequence analysis quantifies vulnerable zones for a likely
incident and once the vulnerable zone is identified for an incident,
measures are proposed to eliminate damage to plant and potential
injury to personnel.
6.8 RISK MITIGATION MEASURES
For risk mitigation / reduction, attempts should be made either to
reduce inventories that could get released in the event of loss of
containment or failure likelihoods or both as feasible. Risk analysis
identifies the major risk contributors, which enables prioritization of
the plant that deserve special attention in terms of inspection and
maintenance in particular and over all safety management as a
whole.
For the risk reduction at the plant, the following salient suggestions
and recommendations are made:
• On site and off site emergency response plan should be
prepared and circulated to concern persons.
• Personnel at the proposed plant and public in surrounding
area should be made aware about the hazardous substance
stored at the plant and risk associated with them.
• A written process safety information document should be
compiled for general use.
• The document compilation should include an assessment of
the hazards presented including (i) toxicity information (ii)
permissible exposure limits. (iii) Physical data (iv) thermal
and chemical stability data (v) reactivity data (vi)
corrosivity data (vii) information on process and mechanical
design.
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• The process design information in the process safety
information compilation must include P & IDs/PFDs; process
chemistry; maximum intended inventory; acceptable upper
and lower limits, pressures, flows and compositions and
process design and energy balances.
• The adequate numbers of heat and smoke detectors should
be provided at strategic locations in the plant and indication
of detectors/sensors should be provided in main control
room.
• Predictive and preventive maintenance schedule should be
prepared for equipment, piping, etc. and thickness survey
should be done periodically as per standard practices.
• A written procedure (Management of Change) must be
developed to manage changes to process chemicals,
technology, equipment and procedures that affect a
covered process.
• Safe work practices should be developed to provide for the
control of hazards during operation and maintenance such
as: (i) lockout/tag out (ii) Confined space entry (iii)
Opening process equipment or piping (iv) Control over
entrance into a facility by maintenance, contractor,
laboratory, or other support personnel.
• Personnel engaged in handling of hazardous chemicals
should be trained to respond in an unlikely event of
emergencies.
• The plant should check and ensure that all instruments
provided in the plant are in good condition and
documented.
• Safety measures in the form of “DO” and “Don’t do” should
be displayed at strategic locations especially in local
language and English.
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• Regular mock drills should be carried out once in every 3
months and shortcomings should be recorded and rectified.
Records should be maintained for the response of Mock
Drills and corrective actions should listed and taken
accordingly.
6.8.1 Personal Protective Equipment
Personal protective equipments are devices that are fitted and issued
to each worker personally for his or her exclusive use. They are
intended for temporary use and emergency response action only. If
a worker has to enter in a contaminated area, he must wear
adequate protective equipment. Employees should be taught when
and how to use respiratory apparatus provided, and how to
recognize defects in the equipment. Full dress escape drills should be
conducted at least once a year. If such safety equipment is not
available, entry into the contaminated area should not be attempted.
• Personal protective equipment should be easily accessible
outside the hazardous material storage area and away from
areas of likely contamination.
• Employees who work near RM storage Tank must be issued
a properly fitting cartridge type or canister type escape
respirator.
• Facial hair should not be permitted for those who are issued
escape-type or self-contained respirators because it
prevents a proper seal.
• Each employee should maintain his/her personal protective
equipment clean and in working condition at all times.
• All equipments should be used and maintained in accordance
with the manufacturer’s instructions.
6.8.2 Handling of Hazards
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• Personal protective equipment used by the person during
handling of hazardous chemicals, should be replaced after
certain time.
• Any spillage of hazardous chemicals should be cleaned and
disposed off as per standard practice.
• Empty drums of hazardous chemicals should be neutralized
immediately.
• Personnel engaged in handling of hazardous chemicals
should be made aware of properties of hazardous chemicals.
6.8.3 General Working Conditions
(a) House Keeping
• All the passages, floors and stairways should be maintained
in good condition. The system should be available to deal
with any spillage of dry or liquid chemical at the plant.
• Sufficient disposable bins should be clearly marked and
these should be suitably located in the plant.
• Walkways should be clearly marked and free from
obstructions.
• In the plant, precaution and instructions should be displayed
at strategic locations.
• All pits, sumps should be properly covered or securely
fenced.
• Roads/walkway within the plant should be maintained neat
and clean.
(b) Ventilation
• Adequate ventilation should be provided in the work floor
environment.
• The work environment should be assessed and monitored
regularly.
• Local ventilation is most effective method for controlling
dust and gaseous emissions at work floor.
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6.8.4 Safe Operating Procedures
• Safe operating procedures should be available for almost all
operations and equipments.
• Workers should be informed of the consequences of failure
to observe the safe operating procedures.
6.8.5 Work Permit System
Work permit system should be followed at the plant. Hazardous work
permit should be used for hot work, electrical works, etc.
6.8.6 Fire Protection
• Adequate fire fighting facilities should be available at the
plant, including, dry chemical powder type, water CO2 type,
mechanical foam type, CO2 type and sand buckets.
• The fire fighting system and equipment should be tested and
maintained as per relevant standards.
• The fire drills should be conducted once in six months.
6.8.7 Emergency Preparedness
• On-site emergency plan should be prepared and readily
available for an unlikely event of emergency.
• Emergency telephone numbers should be available and
displayed properly at strategic locations.
6.8.8 Static Electricity
• All equipments and storage tanks/containers of flammable
chemicals should be bounded and earthed.
• Electrical resistance for earthing circuits should be
maintained. Periodic inspections should be done for earth pit
and record should be maintained.
6.8.9 Material Handling
• Material handling areas should be clearly defined.
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• The workers should be made aware about the hazards
associated with manual material handling.
6.8.10 Communication System
• Adequate communication facilities should be available at the
plant and supported with uninterrupted power supply.
• Communication facilities should be checked periodically for
its proper functioning.
6.8.11 Accident Reporting, Investigation And Analysis
A system should be initiated for accident reporting, investigation and
analysis. To motivate and to increase awareness among the
personnel at the plant about safety, total accident (lost time injury)
free days can be displayed on the board prominently at strategic
location.
6.8.12 Safety Inspections
The system should be initiated for checklist based routine safety
inspection and internal audit of the plant periodically. Safety
inspection team should be formed from various disciplines and
departments.
6.8.13 Safe Operating Procedures
Safe operating procedures should be formulated and updated,
specific to process & equipment and distributed to concerned plant
personnel.
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Chapter 7 ONSITE DISASTER MANAGEMENT PLAN
7.1 INTRODUCTION
An emergency is said to have arisen when operators in the plant are not
able to cope with a potential hazardous situation i.e. loss of control of
an incident, causes the plant to go beyond its normal operating
conditions, thus creating danger. When such an emergency evolves,
chain of events which affect the normal working within the factory area
and/or which, may cause injuries, loss of life, substantial damage to
property and environment both inside and around the factory take
place, then the DISASTER is said to have occurred.
M/s. Paragon Organics is the existing unit located at plot no. 582, ECP
road, Village: Luna, Ta. Padra, Dist.: Vadodara. At present the unit is
involved in production of only one product and now, proposed to
expand its production capacity with introduction of some new products.
As described in chapter-6, the risk assessment studies have been
conducted for identification of hazards, to calculate damage distances
and to spell out risk mitigation measures.
Despite of our best efforts to manage an emergency situation in the
prevention of any risk hazards from the manufacturing process or
material handling, things can go wrong. Therefore, it is essential to plan
and develop the support system, which will be required in case an
emergency arises.
7.2 PROBABLE HAZARDS AND RISK
From the preliminary risk assessment study presented in Chapter 6 of
this report, some of the possible hazards have been identified.
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7.3 OBJECTIVES OF THE PLAN
Following are the Objectives of the disaster management plan:
• To define and assess emergencies, including risk and
environment impact assessment.
• To reduce possibilities of an accident
• To safeguard employees, visitors and other people in the
vicinity.
• To minimize damage to property and/or the environment.
• To inform employees, general public and the authorities on the
hazards/risk assessed, safeguards provided, residual risks, if
any, and the role to be played by them in the event of an
emergency.
• To be ready for the mutual aid if need rises to help the
neighbouring unit. Normal jurisdiction of an On-site Emergency
Plan is the own premises only, but looking to the time factor in
the arriving the external help of off-site plan agency, the
jurisdiction must be extended outside to the extent possible in
case of an emergency occurring outside.
• To inform authorities and mutual aid centres to come for help.
• To affect rescue and treatment of casualties to count injured.
• To identify and list any dead.
• To inform and help relatives.
• To secure the safe rehabilitation of affected area and to restore
normality.
• To provide authoritative information to the news media.
• To preserve records, equipment, etc., and to organize
investigation into the cause of the emergency and preventive
measures to stop its reoccurrence.
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• To ensure safety of the work force before they re-enter and
resume work.
• To work out a plan with all provisions to handle emergencies
and to provide for emergency preparedness and the periodical
rehearsal of the plan.
The structure of the plan may vary depending on number of employees,
materials and processes, availability of resources, location of site, size
and complexity of work.
The plan should not be complicated. Instructions should not overlap or
create any confusion. Responsibilities should be clearly assigned and
should be workable smoothly. For clear understanding and quick action,
the action (role) by each individual (his emergency duty) should be
prepared in a booklet or card size and given to him.
7.4 IDENTIFICATION OF MAJOR HAZARDS
The major hazardous field where disaster management plan is required
are as under:
• Bursting of high-pressure steam pipe, vessels, etc. due to
abnormal pressure rise
• Fire hazard due to ignition of fuel
• Inhalation of any hazardous chemical
7.5 SCOPE OF THE PLAN
• The plan will set into action immediately after a fire or other
hazard occurs in and/or around the plant
• Fuel storage facility will be situated away from the manufacturing
plant and will follow all rules and regulation
• All the electrical fittings will be of explosion proof fitting
• All necessary fire-fighting arrangements will be provided near the
storage area
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7.6 THE UTILITY, ORGANIZATION AND UTILIZATION OF RESOURCES
AND FACILITIES FOR EMERGENCIES
In order to maintain an emergency response capability, certain facilities
must be kept in a state of readiness and sufficient supplies and
equipment must be available. In some cases, it may be impossible to
maintain all of the equipment necessary for all possible emergencies. In
these cases, agreements have to be made with neighbouring facilities to
provide additional support as and when necessary.
Where the local police or private agencies may be called upon, such as
volunteer fire companies and ambulance associations, agreements have
to be developed ahead of time. Emergency hardware can be classified
according to its use during the response operations. Typical examples
are:
• Emergency operation centres
• Communication equipment
• Alarm system
• Personal protection equipment
• Fire fighting facilities, equipment and supplies
• Spill and vapour release control equipment and supplies
• Medical facilities, equipment and supplies
• Monitoring systems
• A media Centre
• Transportation system
• Security and access control equipment
Some of these resources will also be available in the local
municipalities. It is the responsibility of the plant management to
ensure that the appropriate equipments and materials are available to
respond to their very hazard-specific emergencies at the facilities,
independently from external resources. These resources can be
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extremely valuable, but should be used mainly in support of the main
response actions that the facility personnel will have to implement in
case of a serious emergency.
In any case, the availability of resources within the community must be
determined before hand, so that these resources can be mobilized, if
the time comes to do so.
7.7 RESPONSE ORGANISATION STRUCTURE
To set up a response organization structure necessary for chain of
commands during emergency situation, which may arise in the
premises, is one of the most important objectives of emergency plan,
which is briefly described hereunder:
Functions and Responsibilities
The main key person of the emergency plan is Chief Emergency
co-ordinator (Factory Manager / Plant Head). He shall be assisted by,
• Emergency Plant Coordinator, Chief (Production)
• Material Management Coordinator, Chief (Commercial)
• Special Job Coordinator, Chief (Administration Finance)
Chief Emergency Coordinator
He shall be responsible for
• Essential communications
• Public relation
• Transportation
• Investigation and reports
• Alert the hospital authorities
Emergency Plant Coordinator (Chief-Production)
• Rush to the site of emergency on receipt of information.
• Direct plant operation/shut-down operations as needed to
control situation.
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• Guide the Shift Production Officer and members of the
Emergency Squad in fire fighting/rescue operations.
• Arrange for any additional fire fighting/safety equipment,
which may be required at the site.
• Keep in constant touch with the Chief Emergency Coordinator
and pass on all relevant and necessary information to him so
as to enable him keep in touch with concerned authorities.
• Keep in touch with the other coordinators for requirement of
any services like external help, communication, transportation,
etc.
• Arrange for replacement/refilling of used up fire fighting
equipments or gas masks/canisters so as to make these
available at the site at the earliest.
• Carry out investigation of the accident and assist in filling of
statutory reports as required.
• Carry out preliminary investigation into the accident with the
help of concerned personnel.
• Preserve records/evidence that may be required for
investigation.
Material Management Coordinator (Chief-Commercial)
• Rush to the site of emergency.
• Keep the stores open for emergency issue of any items that
may be required for control of emergency.
• In case some material is not available, arrange for its
emergency purchase.
• Keep contact with other coordinators to assess any
requirements in terms of material.
• Arrange for any trucks/trolleys, which may be required for
transportation of materials.
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• Keep in constant touch with the Chief Emergency Coordinator.
• Assess the situation in consultation with the Chief Emergency
Coordinator and other coordinators.
• Arrange to get maintenance mechanics along with their
toolboxes to provide help in any isolation/repair work as may
be required.
• Arrange for requisite number of contractor workmen in case
any additional help is required.
• Arrange for the Shift Electrician and get power supply to the
affected area, if required.
• Make arrangements for temporary lighting/emergency lighting
at the affected area, as required.
• In case of a power failure, ensure the running of the DG sets
and uninterrupted power supply to emergency facilities.
Special Job Coordinator (Chief – Administration/Finance)
• Rush to the site of emergency
• Assess the situation in consultation with Emergency Plant
Coordinator to provide help as may be required.
• Keep in constant touch with the Chief Emergency Coordinator.
• Assess the situation in consultation with Chief Emergency
Coordinator.
• Attend to all emergencies related communications at the
Security Gate.
• Arrange for all Security Guards at their respective post and in
case of the availability of some spare Security Guards, they
may be sent to site of emergency to assist emergency Squad
in fire fighting/rescue operations.
• Closely monitor all movements at the gate, keeping passage
clear for movement of emergency vehicles.
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• No visitors should be allowed to come inside the premises
during the period of emergency.
• Assess the law and order situation inside/outside the premises
and take necessary action accordingly. Proper vigilance to be
maintained to avoid any attempts from inside/outside
saboteurs.
• Arrange to keep the emergency vehicles and ambulance ready
with their drivers for any movement of personnel/material.
• Arrange for canteen services for the personnel on duty and in
the affected area.
• In case of any injuries, provide necessary first aid and arrange
for shifting of the injured personnel to the ESI or other
hospitals as the case may be.
• Attend to any external calls/telephones relating to information
about emergency.
• In case of need from other emergency coordinators at site,
arrange to inform external agencies like Fire Brigade, Police
Station, Ambulance and other Medical Services.
• Arrange for filling of statutory report that may be required.
7.8 EMERGENCY RESPONSE CENTRE
The place identified as Emergency Response Centre will be
considered as the Security Gate Office.
The location of Emergency Response Centre may change in future as
per convenience. The facilities available at the Emergency Response
Centre shall include:
• Internal Telephone
• External Telephone
• Manual Fire/Emergency Siren
• Siren Actuation Switch
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• Important Address and Telephone Numbers
• Emergency Vehicles
• Confined Space Entry Procedure
• List of antidote/actions to be taken in case of exposure to
hazardous Chemicals/materials.
• Material Safety Data Sheets of chemicals
• A copy of On-Site Disaster Management Plan
All communications after General Shift working hours and on
Sundays/Holidays are to be routed through the Security Gate Office.
General Rules
• Follow sense of discipline and do not panic.
• Do not rush and endanger your personal safety.
• Use personnel protective equipment according to the situation.
• Do not block any passages which may hinder the movement of
emergency Vehicles.
• In case you have to shut down your plant operations, do it in
an orderly manner as per standard operating procedures.
• In situation when you have to leave your work and evacuate to
identify places out of operating areas, do it in an orderly
manner.
• Follow instructions of the Emergency Co-ordinators.
• Understand the disaster management plan well and take
interest in practice drills
Emergency Squad
There is a group of personnel (5-10 in number) who will be identified to
handle any emergency situation. These personnel including officers shall
be taken from various operating areas and will be imparted extensive
training in fire fighting, material safety data for hazardous chemicals,
rescue operations, decontamination procedures, confined space entry
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procedures, first aid and other related functions. The members will be
so chosen that at any given time, at least 2–3 members of Emergency
Squad will be available in the premises.
Communication System
Intercom telephone points shall be provided at all critical areas of
operations. An Emergency Telephone shall be available at the
Emergency Response Centre. In addition, telephone connections shall
be provided at the residence of all critical personnel to ensure
immediate contact.
7.9 POST EMERGENCY – RECOVERY
When an emergency is over, it is desirable to carry out a detailed
analysis of the causes of accidents to evaluate the influence of various
factors involved and to propose methods to eliminate or minimize them
in future. Simultaneously, the adequacy of the disaster preparedness
plan will be evaluated and any shortcomings will be rectified.
Accident Investigation
a. After the emergency is over and plant operation has become normal, the investigation shall be carried out as soon as possible to determine the cause of the event.
b. Representatives from various disciplines should take part and report in the investigating team.
c. The area of the event shall be sealed off so that tampering or alteration of the physical evidence will not occur.
d. Key components shall be photographed and logged with time, place, direction, etc.
e. Statements shall be taken from those who were involved with the operation or who witnessed the event.
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Damage Assessment
This phase of recovery establishes the quantum of replacement of
machinery considered necessary for bringing back the plant to normal
operation, property and personnel losses, and culminates in a list of
necessary repair, replacement and reconstruction work.
Insurance companies will be informed of the damage and requested to
pay the compensation as per claim.
Cleanup and Restoration
• This phase will only begin after the investigation is complete.
• Reporting documentation will be prepared and forwarded to