project sector - synthetic organic chemicals industry –...

Project Sector - Synthetic Organic Chemicals Industry – Sr. No. 5(f) of Schedule of EIA Notification, 2006

Environmental Impact Assessment (EIA) – EMP with Risk Assessment & DMP ReportFor Proposed EXPANSION IN EXISTING UNIT of M/s. Sanghvi Organics Pvt. Ltd.

for Manufacturing of Synthetic Organic ChemicalsAt Plot No. 3513 to 3516, Notified GIDC Industrial Estate, Panoli – 394 116, Dist. Bharuch, State - Gujarat, India

Chapter 6. Environment Monitoring Program

Siddhi Green Excellence Pvt. Ltd., Ankleshwar Page 208 of 265

Measurement and quantificationAny of the following types of monitoring methods shall be employed for detection of leaks: (i) Instrumental method ofmeasurement of leaks; (ii) Audio, visual and olfactory (AVO) leak detection; and (iii) Soap bubble method.After the instrumental measurement of leaks, emission from the components will be calculated using stratified emissionfactors (USEPA) or any other superior factors. The total fugitive emission will be established.

Records to be maintainedData on time of measurement & concentration value for leak detection; time of repair of leak; and time of measurement& concentration value after repair of leak shall be documented for all the components.




Chapter 7. Risk Assessment and Disaster Management Plan

Siddhi Green Excellence Pvt. Ltd., Ankleshwar 09 of 265

7 RISK ASSESSMENT & DISASTER MANAGEMENT PLAN

7.1 BACKGROUNDRisk Assessment is a management tool for determining the hazards and risk associated with the various activities of aproject and compute the damage potential of these hazards to life and property. Risk Assessment provides basis fordetermining the safety measures required to eliminate, minimize and control the risks as detailed in DisasterManagement Plan (DMP) to handle onsite and offsite emergencies.In Chemical Industry, Risk Assessment is carried out for the various hazards involved in storage and handling ofhazardous raw materials, intermediates and finished products as well as for the manufacturing processes used by theunit.

7.2 OBJECTIVESThe given study was focused to fulfill the following objectives:- Identification of safety areas- Identification of process and storage hazards- Visualization of maximum credible accident (MCA) scenarios- Consequence analysis of scenarios- Determination of quantities released, impact zones- Estimation of damage distances for the accidental release scenarios with recourse to Maximum Credible

Accident (MCA) analysis- Preventive and control measures required for reducing the risk factors- Delineation of Disaster Management Plan

7.3 SCOPE OF WORKBased on the objectives as defined above, the scope of work for the given study has been framed as under:

Hazard Identification General description of project Study of manufacturing activities Study of plant facilities and layout Hazardous inventory Associated process and storage hazards Safety measures as proposed by the proponent

Hazard Assessment Identification of MCA and worst case scenarios using standard techniques Consequence analysis of selected scenarios using EFFECT model on ALOHA software Determination of risk reduction measures Preparation of DMP Recommendations

7.4 METHODOLOGYFollowing methodology has been followed for given Risk Assessment Study as described in “Guidelines for ChemicalProcess Quantitative Risk Assessment” by CCPS with the help of frequency data from “Purple Book” , 2008.

The guidelines given by SEAC as well as Technical Guidance Manual of MoEF&CC have also been followed. Collecting Input data about Process,Inventories and Site conditions Hazard Identification Defining the Potential Accident Scenarios Evaluation of Consequences and Estimation of Accident Frequencies Estimate the Impacts Estimate the Risk Identify and Prioritize the Risk Reduction measures.






7.5 HAZARD IDENTIFICATIONThis is important and critical step in risk assessment. It is critical because Hazard omitted is hazard not analyzed. Thetools used for identification are experience, detailed process knowledge, engineering codes, checklist, HAZOPs etc.The unit shall handle hazardous materials and shall have a defined and organized hazard control and prevention systemin place. The following statutory compliances shall be applicable to the unit:

1. Manufacture, Storage and Import of Hazardous Chemicals (Amended) Rules, 2000

The hazards of the materials are identified from the MSDS. The major hazards are toxic, fire and explosion. Flammablematerial will form pool on leakage and this pool can sustain a pool fire. In case of toxic material the vapors evaporatedfrom pool disperse in downstream direction and may cause problem for people in process units / buildings

The inventory of hazardous material in the storage area is significantly larger than the inventory involved in the process,hence the scenarios selected for the consequences calculations are from storage vessels. These vessels are locatednear the respective plants only.

7.6 STORAGE HAZARDS AND CONTROL MEASURESThe materials involved are of toxic and flammable nature. The major hazardous materials, their inventories and theirhazardous properties are tabulated in Annexure-26.

The unit is an MAH installation in accordance with the MSIHC rules, 2000 for chlorine tonner storage. No additionalchlorine storage shall be required for the expansion.SOPL has license from CCOE (PESO) for chlorine storage and inventory that come under the purview of Petroleum Act1934 and rules therein. Copies of licenses are annexed as Annexure – 22.

All chemicals are stored and handled in accordance with Material Safety Datasheet. MSDS of few chemicals areannexed as Annexure - 41.

Table 7-1 List of Hazardous chemicals to be handled after expansionLiquid Storages (drums, carboys)Sr. No. Hazardous

Chemical nameState Equipment

ConsideredSize of

container (kg)Max. No. Ofcontainers

Max. storagequantity (MT)

1 Benzoyl chloride Liquid Drum 250 20 52 Acetyl chloride Liquid Drum 200 25 53 Benzyl acetate Liquid Drum 200 50 104 Benzo trichloride Liquid Drum 250 40 105 Acetaldehyde Liquid Drum 200 25 56 Acetic anhydride Liquid Carboys 50 100 5

Bags Storage (Solids)Sr.No.

HazardousChemical name

State Size of container No. Of containers Total storage quantitykg Nos. MT

1 Sodium acetate Solid 25 400 10

Liquid Storage (Above ground Vertical fixed roof Storage Tanks)

Sr.No.

Hazardous Chemicalname

State i.e,solid /Liquid /Gas

Existing No. oftanks & Size atsite, KL

Additional No.of tanks & Sizein KL

Totalstoragecapacityin KL

Storage ParametersPress.kg/cm2 Temp °C

1 Benzal chloride Liquid 2 x 20 = 40 -- 40 Atm. Amb.2 Benzyl chloride Liquid 5 x 20= 100 2 x 20=40 140 Atm. Amb.3 Benzaldehyde Liquid 2 x 35 = 70 -- 70 Atm. Amb.

4 Acetaldehyde(30% solution) Liquid -- 1 x 10 = 10 10 Atm. Amb.






Sr.No.







5 Benzyl alchohol Liquid 2 x 30 = 602 x 35 = 70 -- 130 Atm. Amb.

Liquid Storage (Under ground Horizontal fixed roof Storage Tank)

Sr.No.







1 Toluene Liquid 5 x 50 = 250 2 x 80 = 160 410 Atm. Amb.

Gas Storage Cylinders:Sr.No

HazardousChemical name

State i.e Liquid/solid/gas

qty. in onecontainer

No. ofcontainers

Total quantityMT

1 Chlorine Liquified gas under pr. 900 kg tonners 70 63

Preventive Measures provided Majority Production processes to be observed and controlled incorporating adequate instrumentation through temp.

and pressure indicators, controllers and recorders. DCS automation shall be adopted for proposed expansion. Welded pipes to be used wherever feasible Suitable gasket material to be used Suitable gland packing to be used in valves Regular inspection and Preventive maintenance to be carried out with reference to plant operations like pumps,

valves, pipes etc as per maintenance program. Flammable Storage Tanks : - Tanks are properly Earthed. Earthing and Bonding provided to Unloading pump and

Tankers. Tank vent equipped with Breather valve and Flame arrester. Tanks shall be provided with Level indicatorwith high level alarm and level overfill switch. SOP is in place for Tanker unloading, All electrical and instrumentationfixtures are Flame proof

Lightning arresters are provided as per requirement. Majority Production processes to be observed and controlled by DCS system incorporating adequate instrumentation

through temp. and pressure indicators, controllers and recorders. All pressure vessels are equipped with PSVs. Do’s and don’ts for maintenance of critical equipment and machinery prepared and instructed to operators Work Permit system implemented for hot work in Plant / Storage area, Vessel Entry Permit, Working at Height,

Opening of the Process lines.

Control Measures to be provided :- Fire hydrant system shall be in place. Portable Fire Extinguishers are installed asper requirement. Foam and Water Monitor installed around Tank farm storing flammable materials. Safety shower andeye wash installed at critical locations. Storage tanks storing hazardous chemicals provided with dyke for containment.ECC equipped with Self Contained Breathing Apparatus, PPE’s. Onsite Emergency plan is in place. Site has adedicated and trained Fire fighting team and First Aider team, emergency aid from DPMC and Panoli Fire station.

7.7 PROCESS HAZARDS AND THEIR CONTROL MEASURESTable 7-2 Process Hazards and their Control MeasuresSr.No. Cause Reason

Type ofHazardspossible

Probability/ Severity

Preventive Measuresprovided

ControlMeasuresprovided

1. Leakagefrom line /valve

Failure of valveor joints

ChemicalSpill,Toxic

Low/Medium

• All lines / valvesperiodically checked,

Fire Extinguisher,fire water network,Sand buckets,






2. Failure ofpart ofvessel orjacket

Overpressureand failure ofsafety device

Release,Fire

• preventivemaintenance of allsafety devices

• Operators trained forthe process and SOPs

• PPE provided toworkers

• Spill kits• Flameproof fittings are

provided.

First-aid andMedical facilities,(Company ismember ofDPMC-Ankleshwar)

3. Spillagefrom drums/ bags

Manual error,rupture

7.8 OTHER HAZARDS & CONTROL

Sr.No

Name ofpossibleHazards

/emergencyIts sources & reasons

Its effects onpersons,

property andenvironment

Place ofEffect Control measures provided

1 MechanicalHazards

Rotating Equipments viz.Agitator drives, pumps –accidental entanglement ofclothes or body touch,electrical shockHand Tools and portablepower tools – hit or fall onbody part due to mis-operationor sudden startup or manualerror, electrical shock

Damage toperson

Productionarea,warehouse,utility

Guards are provided on all rotatingequipment.The hand tools shall be kept atspecified location so that they areeasily available when required.Proper earthing is provided to allelectrical equipment and checkedregularly. Operators are skilled andexperienced.

2 Steam &Electricity

Sparks, Electrical shocks Damage toproperty andperson

Productionarea as wellas MCCRoom

Flameproof fittings, proper earthing,covered cable trays, lighteningarrestor provided, PPE utilized whileworking.

3 Road /TransportationHazard

Hit of the vehicle or trolley Loss ofproperty andperson

Adjacentroads andadjacentareas

Restricted vehicular movement,Operator training on safetransportation Material transporterare educated for materials to betransported.

4 LighteningHazard

Natural Loss ofproperty andperson

Wholefactory

Lightening Arrestor installed

5 Cyclone, Flood,Earthquake

Natural Loss ofproperty andperson

Wholefactory

Disaster ManagementPanoli GIDC estate falls in theSeismic Zone III. Since the estateis located at sufficient height fromsea, there are no instances ofTsunami in the recorded past.The project area is sufficiently awayfrom major river - Narmada river,since the site is at an elevation of ~20 m from the MSL. Storm waterdrainage network is inplace andalso the floods or abnormally highprecipation may obstruct block theinternal roads and NH-8 only for ashort period owing to the gooddrainage.

6 Spillage Pipe leakage, Flange jointleakage

Loss ofproperty andperson

Place ofspill

Adequate PPEs for handling , spillkits






7.8.1 Sensitive locations around the projectTable 7-3 Sensitivelocations around the projectSr.No.

Name of thevillage

Approx. aerialdist. From the

stack, kmDirection

w.r.t stack Type of AreaUpwind or downwind

w.r.t predominant winddirection (SW-NE)

1. Panoli 1.77 224.11° Residential-Industrial Upwind2. Sanjali (CT) 1.19 33.57° Residential-Industrial Downwind3. NH-8 2.04 88.56° National Highway Downwind4. Nana Borsara 2.44 175.14° Residential Crosswind

Study Area Map (Area within 10 km radius from centre of project site)

Co-ordinates of Centre of Project Site: Latitude: 21°32'46.32"N, Longitude: 72°59'13.45"EThe study area comprises of:-

Panoli industrial estate – marked with red boundary Part of Ankleshwar Industrial estate – marked with green boundary 41 nos. of areas having residential and agricultural land uses Reservoirs, Ponds and lakes Kondh ki khadi & Amla Khadi Tapi canal Part of NH 8, SH 166, SH 6, SH 13, SH 76 & SH 64 Western railway (Main line) - Mumbai - Ahmedabad railway line Western railway - Ankleshwar-Rajpipla section

Ref: Census 2011 & Toposheet (Toposheet is attached as Annexure- 17)







Name of thevillage


stack, kmDirection














Name of thevillage


stack, kmDirection













7.9 PROPOSED RISK REDUCTION MEASURES FOR THE PROJECTSince the plant is handling flammable chemicals as well as carries out chemical reactions, the proponent has committedto provide suitable safety measures with modern & adequate facilities for accident prevention and hazard control.

Defined Standard Operating Procedures for Maintenance systemsDefined maintenance procedures are followed for maintenance of lines or equipments handling hazardous materials.Standard Operating procedures are prepared for all critical activities like hazardous chemical tanker unloading.

Area Segregation: - Production plant shall be segregated Flame proof and Non Flame proof area. Flame prooffittings/Equipments will be provided in flame proof area.

DCS Control System and Emergency Shutdown SystemDCS automation shall be adopted for proposed expansion. All unit processes and unit operations shall be carried outunder stringent controls and monitoring systems and instrumentation.

Common features of Storage Tanks- Located in a designated area within Concrete Dyke wall.- Level indicators with high / low alarms in tanks are provided. Interlocks are provided to stop pump, close

ON/OFF valves to avoid overfilling.- Breathing valve and Flame arrestors provided on Storage tank storing Flammable chemicals. ,- Fire water ring with hydrant post is available in storage area.

Fire Fighting Arrangements :(Source : Onsite plan of Sanghvi Organic Pvt. Ltd. – SOPL-OSEP-2016)

The proponent is member of Disaster Prevention & Management Centre, Ankleshwar which is fully equippedfor handling of industrial emergencies & disasters such as fire & rescue, chemical spills, toxic release / gasleaks, road & rail accidents, natural calamities like flood, cyclone , earthquake etc., rural fires, etc.

Emergency electric siren is installed at security room Wind direction indicators are provided at Alcohol plant top and Multi effect Evaporator plant Lightning arrestor is provided to all stacks Relevant sections of the factory shall be covered with fire hydrant system. Fire extinguishers are provided at

all necessary locations and of suitable type and capacity. Flammable areas are classified as per applicablerules and protected by spark avoidance and flameproof electric fittings. Details can be referred at chapter 7.

The organization has developed an on-site emergency plan to handle emergencies. The details about DMP &On-site Emergency plan are mentioned in chapter 7.

The proponent is member of Disaster Prevention & Management Centre, Ankleshwar

Fire Extinguishers:Sr. No. Type of Fire extinguisher Capacity Quantity Installed1 ABC Type (DCP) 10 kg 432 CO2 4.5 kg 13 CO2 9 kg 14 Mechanical Foam 50 Litre 25 Sand Buckets 5 Ltr 4

Emergency Equipment (as per latest onsite plan)Personal Protective EquipmentRespiratory Non-respiratorySCBA (30 minutes) Nos. 04 TypeDust Masks, Organic vapor masks Goggles, Hand gloves – PVC, Rubber, Elec.

shockproof, Safety shoes, nose masks,Helmets, Safety shower with eyewash fountain






Chlorine kit YES – 01 No.FRP hood YES – 01 No.Electric siren with 0.5 km range YES – 01 no.

Fire-fighting teamAll personnel receive training on first aid and fire. Refresher training is a continuous process.Trained firefighters : available in all shifts + general shiftTrained for :- Fire Fighting / Rescue / SCBA/ First Aid/ Toxic spill control – external as well as internalAdequate fire fighting personnel shall be made available at new plant sections also.With context to operational safety, SOPL has taken suitable safety measures with modern & adequate facilities foraccident prevention and hazard control. Relevant sections of the factory shall be covered with fire hydrant system. Fire extinguishers are provided at all

necessary locations and of suitable type and capacity. Flammable areas are classified as per applicable rules andprotected by spark avoidance and flameproof electric fittings. Details can be referred at chapter 7.

The organization has developed an on-site emergency plan to handle emergencies. The details about DMP & On-site Emergency plan are mentioned in chapter 7.

The proponent is member of Disaster Prevention & Management Centre, Ankleshwar Mutual aid agreement with neighbouring industry - M/s. PI industries is also made, copy annexed as Annexure-35

Further suggestions from EIA consultant Emergency power for all critical drives / instruments Intelligent / Fuse less MCC for entire site Civil foundations and structural work shall take into account protective measures for earthquakes, cyclones,

landslides, flooding etc. Seamless pipelines to be used wherever necessary. Flange guards to prevent splashing incase of gasket failure. Scheduled testing and maintenance of earthing pits by certified agency Training programme shall be conducted regularly to all employees on chemical safety and process safety.

Inbuilt Safety at design, construction & commissioning stages Fail safe instrumentation and control systems for DCS, including indicators, high and low alarms, NRVs,

controllers. PSVs and TSVs on reactors, detectors at required locations Civil foundations and structural work shall take into account protective measures for earthquakes, cyclones,

landslides, flooding etc. Jumpers provided on flanges to prevent static charge. Lightning arrester to be installed at all critical locations A well-planned and well-maintained electrical grounding system with sufficient earthing pits provided covering

all areas handling flammable chemicals including storages, production areas, loading, unloading areas,warehouses etc.

Flame arrestors, breather valves provided to Storage tanks as per requirement and applicable rules. The bulk chemicals storage area kept away from the main production areas.

For emergency management: (to be augmented for new plant section) - Fire hydrant system covering the entire plant to be provided. Fire hydrant system shall be augmented to

cover new plant section. Suitable type and no. of Fire Extinguishers shall be provided at new plant sections Emergency power for all critical drives / instruments Additional procurement of Self Contained Breathing apparatus (SCBA), LEL detectors and oxygen

detectors for emergency handling. Drains covering the plant to contain contaminated water during fire emergency






Eye washers / showers to be provided at all required locations Well equipped First-aid centre already available Amendment to Onsite emergency plan and emergency management

The proponent has consented to implement the above to the best possible extent.

7.9.1 Safety During operational phase Safe operating procedures are developed for handling of hazardous chemicals and for critical process

operations such as loading and unloading tankers, drum charging, drum movement, vessel opening or drumopening, work permit systems. Safety measures to be taken by Transport agency including Emergency actionand TREM card are also developed in site plan, abstract annexed as Annexure – 8.

Safety Measures in StorageChlorine Storage Area:

Chlorine tonners are stored separately and isolated area. Chlorine kit, FRP hood, SBA set, etc. provided Each tonner is examined, while receiving. Provision of ammonia torch. Personnel Protective Equipment are issued to workers & operatives. Displayment of notice for filled and empty Tonners. Water shower with eye-washer provided. Chlorine is supplied through header and connector.

Tank Area All the tanks of liquid chemicals like HCl is marked with label, capacity, propoer material of construction, level

indicator, dyke wall with acid proof brick lining, etc. The statutory notice for acid & alkali danger is displayed in storage area. The safety showers – Eye washers provided. Transfer of Acetic chloride, Benzyl Chloride, Benzoyl chloride etc liquid chemicals are transferred through

closed circuit only by pump, with wearing necessary personal protective equipment. The vessels, Barrels, Pipeline are properly earthed and continuity test of such earth wire is done regularly. DCP, CO2 type of fire fighting equipment are available. Overhead and underground water tank for emergency purpose. Lightening arrestor is provided.

Storage Area Raw materials are stored separately as per their characteristics Storage area is declared as non-smoking zone. Level indicator is provided on tank. Water shower provided. Fire fighting equipments are provided. Provision of Personal Protective Equipment shall be used while enter in the area.

Process area Flameproof Electrical Motor/ Switches/ Fitting etc. are provided. Pressure guage, Temperature indicator, Non-return valve, etc, instruments are provided. Condensers, Scrubbers, pump sets; stack etc. equipments are provided. Safety valves are provided on all reactors and jackets. Earthing provided to all reactors and vessels. Water shower with Eye washers provided. Personal Protective Equipment given. Qualified & Experienced person. All the revolving & moving exposed parts of machineries guarded. The complete plant is declared no smoking zone.






No welding cutting operation will be carried out without proper care. The scrubber and effluent treatment plant are in operation continuously. First aid box is provided. Fire extinguishers are installed at different locations.

Other Safety related measures : Appropriate PPE provided to workers w.r.t type of operation and material handled. Preventive maintenance schedule for all critical equipment and vessels planned and followed. Do’s and don’ts

for maintenance of critical equipment and machinery prepared and instructed to operators (Copy annexed asAnnexure 18)

Work Permit system to be implemented for hot work in Plant / Storage area, Vessel Entry Permit, Working atHeight, Opening of the Process lines.

All employees covered under Group Insurance Policy along with personal accident cover Accident records maintained and top management at headquarters appraised Periodical medical checkup of employees done & health records kept All the equipment and pipelines marked for identification All the safety devices and instruments like safety valves, tested, inspected and recalibrated as per safety

norms. Fire hydrant system, Fire extinguishers, fire alarms, detectors to be examined periodically and preventive

maintenance to be undertaken. Hydraulic testing of pressure vessels and tanks done through Government approved Competent Person. (As

per rule). Match boxes, Cigarettes, Mobile, any petroleum product prohibited. Visitors required depositing such items at

security gate. To check preparedness of workers for emergency control, mock drills on regular basis and disaster drills as per

factory inspectorate guidelines to be conducted. Fire fighting team with adequate firefighters in each team and having proper training Trained first aid team Head count of all employees inside the Plant premises maintained by the Duty Security Head in a register on

the Gate. Similarly, head count of all contract workers maintained.

Detectors & alarmsPresently chlorine sensors are installed at – chlorine storage area

For the proposed expansion, suitable audio alarms with trip system shall be programmed in the DCS system for alertingthe plant personnel in case of any leakage. Suitable manual call points for fire alarm system shall also be installed.A public address system controlled from DCS room shall also be provided to warn of abnormal situations throughout theplant for taking quick and corrective action.

The operators and supervisor are continuously taking rounds of the plant and monitoring the process parametersthrough local monitoring instruments provided in the field.

Plant security personnel are present on all gates of premises and strategic location for the security of the plant. Anyperson or employee or contractor personnel are not allowed without proper purpose / gate pass.CCTV cameras shall be installed in future for monitoring the site 24x7.

Inhouse medical facility

First Aid BoxesFirst aid boxes is provided in First aid centre and all the necessary items are maintained by First aid centre incharge.They are inspected on regular basis. Selected employees from each department are trained for first-aid course to beavailable in all shifts and additional employees of new plant sections shall also be given training. All firstaiders are givenrefresher training once in a year.List of trained first aiders is kept in ECC and onsite emergency plan.






First-aid centreFirst Aid Centre is provided near security cabin having First–Aid box and arrangements for first-aid treatments. It shallbe augmented to have one bed, observation cum treatment table, medicine Cupboard with antidotes, dressing &dispensing arrangment, toilet, bathroom with shower, washbasin, air conditioner, computer – printer, ophthalmic charts,eye washer, Stethoscope, Thermometer, Weight Machine.Antidotes for major chemicals handled by the unit are identified and list is attached as Annexure-21.These shall be made available at firstaid centre.

Center shall be connected with intercom facility or mobile phone at all times. The contact number of all nearby hospitalsand medical facilities shall be kept and put up on a board in the First Aid Center.

External aid for treatmentWelcare Hospital, Kharod and Smt. Jayaben Modi Hospital, GIDC Ankleshwar are contacted for medical treatment.Unit has own transport vehicle for emergency transport. Ambulance facilities are available from 108 and WelcareHospital, Kharod as well as from nearby LSI units.

Assembly pointsIdentification

Sr. No. Location of the Assembly Point Accommodation Capacity1 Behind Admin Building 252 Nr. Vehicle Parking Area 25

7.10 VISUALIZATION OF ACCIDENT SCENARIOSBased on the inventory, physical and chemical properties as well as the activities associated with storage and handlingof hazardous chemicals, the largest potential hazard inventories are considered. Different release scenarios arevisualized for these inventories and short-listed for carrying out the consequence analysis.One scenario considered for all is ‘Catastrophic Failure’, which is the worst case (WC) and frequency of which is veryrare in the lifetime of the plant. Hence most credible accident scenarios (MCA) are also considered primarily leaks fromtanks, vessels or pipelines, drum damage in drum storage area.

MCA (Maximum Credible Accident) analysis is considered the most appropriate consequence analysis method for riskassessment since it does not involve quantification of the probability of occurrence of an accident and estimates theconsequent effects of an accident scenario in terms of damage distances of heat radiation, toxic releases, vapor cloudexplosion, pool fire etc. Major hazards posed by hazardous chemical storages can be assessed using MCA analysis.Hence most credible accident scenarios (MCA) are also considered primarily leaks from tanks, vessels or pipelines.Leak in the vessel or leak from the flange joints of these connections is possible. The leak through flange failure isconsidered from 50% of flange perimeter and accordingly equivalent area is calculated. This area is approximated tohole of 10mm or 10% of pipe diameter. The small bore pipes less than 2” is considered full bore leak.

For our analysis we consider leak from pipeline which are at pump discharge, hence it shall be pressurized and feedingto reactor or storage.






7.10.1 Selection of Initiating Events and ScenariosFollowing event tree is followed for deciding toxic and/or flammable effects:

Based on the inventory of hazardous chemicals and their hazardous properties, following accident scenarios have beenvisualized for the given project.






Table 7-4 Worst Case (WCS) and Most Credible Accident (MCS) Scenarios selected for the study

Sr. No. Hazardous Chemical Name Storage Parameters Equipment Considered Scenario Selected Type OfScenario Flammable/ ToxicTemp (°C) Pressure (kg/cm2)

1 Toluene Amb Atm. Underground Horizontal Fixedroof storage tank

Leak through 10mm hole MCS Flammable

2 Chlorine 45 12 Tonner Tonner Damage MCS Toxic

3 Benzal chloride Amb Atm. Vertical Fixed roof storagetank

CatastrophicFailure WCS Toxic

4 Benzyl chloride Amb Atm. Vertical Fixed roof storagetank

CatastrophicFailure WCS Toxic

5 Benzaldehyde Amb Atm. Vertical Fixed roof storagetank

CatastrophicFailure WCS Flammable

6 Benzo trichloride Amb Atm. 250 kg HDPE drum Drum Damage MCS Toxic

7 Acetaldehyde Amb Atm. Vertical Fixed roof storagetank

CatastrophicFailure WCS Flammable

8 Acetyl chloride Amb Atm. 200 kg HDPE drums Drum Damage MCS Flammable

WCS : Worst Case Scenario MCS : Most Credible Scenario






7.11 CONSEQUENCE ANALYSISHazardous substance on release can cause damage on a large scale in the environment. The extent of damage isdependent upon the nature of the release and the physical state of the material. It is necessary to visualize theconsequences and the damages caused by such releases. The quantification of the damage can be done by means ofvarious models, which can further be related in terms of injuries and damage to exposed population and buildings.

Software used for consequence analysis for proposed expansion project: ALOHA (AREAL LOCATIONS OFHAZARDOUS ATMOSPHERES)

Is part of the CAMEO suite developed by US Environmental Protection Agency (EPA), ALOHA® is an atmosphericdispersion model used for evaluating releases of hazardous chemical vapors, including toxic gas clouds, fires, andexplosions. Using input about the release ALOHA generates a threat zone estimate. A threat zone is the area where ahazard (such as toxicity, flammability, thermal radiation, or damaging overpressure) is predicted to exceed a user-specified level of concern. Threat zones can also be plotted on maps with MARPLOT to display the location of facilitiesstoring hazardous materials and vulnerable locations (such as hospitals and schools). Specific information about theselocations can be extracted from CAMEO information modules to help make decisions about the degree of hazard posed.

In order to assess the damage, the damage criteria have to be first defined.There are three principle types of exposures to hazardous effects

Heat radiation from a jet, pool fire, a flash fire or a BLEVEExplosion,Toxic effects, from toxic materials or toxic combustion products

A basis for the weather conditions (Temperature, wind speed etc.) is chosen for input in these models.

7.11.1 Frequencies Estimation:The risk is computed as product of consequence of event and frequency of occurring of the event.As part riskassessment frequency estimation is one of the activity. In literature and published guidelines the frequencies ofcatastrophic failure of various equipments are published. Also for credible scenarios the frequencies for leaks fromequipments or pipelines are available in the same source as above. For credible scenario the frequency of leak event iscalculated as summation of frequencies of each element in the considered vessel.

No Item Mode Of Failure Failure Frequency1 Atmospheric Storage Tanks Catastrophic Failure 10E-9 /yr

Significant Leak 10E-5 /yr2 Process Pipelines

<=50mm Dia Full Bore rupture 8.8 x 10E-7 /yrSignificant Leak 8.8 x 10E-6 /yr

>50mm<=150mm Dia Full Bore rupture 2.6 x 10E-7 /yrSignificant Leak 5.3 x 10E-6 /yr

<150mm Dia Full Bore rupture 8.8 x 10E-7 /yrSignificant Leak 2.6 x 10E-6 /yr

3 Hoses Rupture 3.5 x 10E-2 /yr4 Pressure Vessel Catastrophic Failure 3 x 10E-6 /yr

Significant Leak(6" nozzle) 7 x 10E-6 /yr5 Liquid Line Pipeline Leak 3 x 10E-7 /yr

Fittings Leak 5 x 10E-6 /yr6 vapor line Leak 3 x 10E-6 /yr7 6" Pipe Leak (1 kg/s) 6x 10E-6 /yr8 3" Pipe Leak (1 kg/s) 6 x 10E-5 /yr9 Flange Leak (1 kg/s) 3 x 10E-4 /yr10 Pump Seal Leak (1 kg/s) 5 x 10E-3 /yr






For warehouse where the drums of chemicals are stored and handled the frequencies are as follows,No Item Mode Of Failure Failure Frequency

1storage of substances inwarehouseswith protection levels 1 and 2

Liquid Spill 1 x 10E-5 Per handling

Fire 8.8 x 10E-4 / yr

2storage of substances inwarehouseswith protection level 3

Liquid Spill 1 x 10E-5 Per handling

Fire 1.8 x 10E-4 / yr

Table 7-5 Failure History dataSN Item International Data Indian Data

1 Process Controller 2.4 x 10-5 hr-1 3.0 x 10-5 hr-12 Process Controller Valve 2 x 10-6 hr-1 2.4 x 10-5 hr-13 Alarm 2.3 x 10-5 hr-1 4.6 x 10-5 hr-14 Leakage at biggest storage tank 5 x 10-5 yr-1 3.0 x 10-5 yr-15 Leakage pipe line 1 x 10-7 m-1yr-1 3.0 x 10-8 m-1yr-16 Human failure 1 x 10-4 (demand)-1 1.8 x 10-3 (demand)-1

Table 7-6 Assumed failure rate for the studySN Item Rupture (yr-1) Leakage (yr-1)

1 Pipe lines<3”3”-15”>15

10-610-7--

10-510-610-8

2 Vessel- pressurized- Atmospheric

5 x 10-61 x 10-5

5 x 10-51 x 10-4

Table 7-7 Damage Due To Incident Radiation IntensityIncident Radiation Intensity (kJ/m²s) Type of Damage62.0 Spontaneous ignition of wood37.5 Sufficient to cause damage to process equipment25 Minimum energy required for ignite wood at infinitely long exposure (non piloted)12.5 Minimum energy required of piloted ignition of wood, melting plastic tubing etc.

4.5 Sufficient to cause pain to personnel is unable to reach cover within 20 sec.;however blistering of skin (1st degree burns) is likely

1.6 Will cause no discomfort on long exposure

Table 7-8 Physiological Effects Of Threshold Thermal DosesDose Threshold (kJ/m²) Physiological Effect37525012565

Third Degree BurnsSecond Degree BurnsFirst Degree BurnsThreshold of pain, no reddening or blistering of skin caused

1st Degree Burns Involve only epidermis, blister may occur2nd Degree Burns Involve whole of the epidermis over the area of burns plus some portion of dermis3rd Degree Burns Involve whole of epidermis and dermis. Subcutaneous tissues may also be damaged

Table 7-9 Heat Radiation & Escape TimeRadiation Intensity BTU/hr/ft² Time to Pain Threshold (Seconds)440 (1.39 kW/m²) 60550 (1.6 kW/m²) 40740 (2.33 kW/m²) 30920 (2.9 kW/m²) 161500 (4.7 kW/m²) 92200 (6.93 kW/m²) 63000 (9.5 kW/m²) 5






3700 (11.66 kW/m²) 46300 (19.9 kW/m²) 2

Table 7-10 Tolerable Over Pressure Limits For Various ObjectsIncident OverPressure (Bar)

Incident OverPressure (psi) Object

0.02 0.29 Schools0.04 0.59 Domestic Housing0.05 0.74 Public Roads0.07 1.03 Ordinary Plant Buildings0.10 1.47 Buildings with shatter-resistant windows fixed roof tanks containing highly flammable or toxic

materials0.20 2.94 Floating roof tanks, other fixed roof tanks, cooling towers, utility areas site roads0.40 5.88 Other hazardous plants0.70 10.29 Non-hazardous (if occupied) plants. Control room designed for blast resistance.

7.11.2 Assumptions Common for all ScenariosMaximum Minimum

Temperature Deg.C 45 11Wind speed m/s 5.55 1Average Wind speed m/s 2-5Wind Direction From South WestHumidity % 70Ground Roughness Urban or ForestCloud Cover % 50

Atmospheric stability class D and F are considered for analysis. The stability classes are selected based on thetemperature & wind velocity. The software prompts most suitable stability class based on temperature & windvelocity. For project atmospheric temperature & wind velocities the software prompted stability classes D & Fare selected for analysis.

Stability class D & wind velocity 5.55 m/s represents most turbulent atmosphere at site which is ideal toanalyse effects within or nearby plant area. Stability class F and wind velocity 1 m/s represents most stableatmosphere at the site which is ideal to analyse effects at far distances.

For any particular case if other stability class is chosen, it is included in its detail analysis. At respective class atmospheric temperatures, if flash point is higher and chemical may not ignite. But to

assess the radiation effect at such situations, the radiation effect is calculated assuming burning is started dueto other ignition source.

For chemicals having flash point more than 45 degC, the effect is analsyed only for class D. For all toxic material release LC50 are taken as the toxic end points. If LC50 is not available then LD50 values

are considered For thermal radiation the distances for radiation level 37.5 kw/m2, 4kw/m2 and 1.6kw/m2 are calculated. For vapor cloud explosion the distance for overpressure of 0.5 psi is calculated. For credible flammable scenario, the scenario selected for drum damage which is having lowest flash point is

Acetyl chloride (5 deg C) for flammable material. For credible toxic scenario, the scenario selected for drum damage which is having lowest LC50 value is Benzo

Trichloride (19ppm/2hrs.) for toxic material. For gas services the flow through leak is calculated in ALOHA by modelling leak through pipe with closed off

(i.e. isolated portion). But this will give the rate which will be present only after isolation. The decreasingpressure inside pipe will affect the discharge rate. The rate of discharge before isolation will be at constantpressure and hence will be more than the rate calculated by ALOHA.

Specific assumptions are mentioned in the detailed description of each scenario in following sections. TheALOHA text summary output and mapping of threat zones superimposed on google earth imagery of the siteplan for each scenario is annexed as Annexure 12.






7.11.3 Summarized Table for effects of Consequences

Table 7-11 Toxic End points of Consequence Analysis

No Hazardous Material EquipmentConsidered Scenario Selected Material

ReleasedEnd

PointEndpoint

ConcentrationStability

ClassMaximumDistance

mMaximum Distance

to IDLH m

1 Chlorine Tonner Leak through 10mm hole 218 / 129 kg LC500.5hrs

500 D 49 413 (10 ppm)500 F 51 611(10 ppm)

2 Benzo Trichloride Drum Drum Damage 250 kgLC50(0.5hr) 19 D <10 67 (PAC3 - 5.3

mg/m3)

19 F <10 45 (PAC3 - 5.3mg/m3)

3 Benzyl Chloride Tank Catastrohic Failure 22000kg(20KL)

LC502hrs

150 D <10 43 (10 ppm)150 F <10 19 (10 ppm)

4 Benzal Chloride Tank Catastrohic Failure 25000kg(20KL)

LC502hrs

400 mg/m3 D <10 38 (PAC3 - 14 mg/m3)400 mg/m3 F <10 15 (PAC3 - 14 mg/m3)

Note : ‘Material Released’ is the total material spilled or released from container. In case of Liquid Pool, from this released material some of the material will be evaporated and dispersed indirection of wind. This evaporated quantity will be less than total quantity depends on the properties of material spilled and atmospheric conditions.Detailed output of aloha is attached as Annexure – 12.






Table 7-12 Flammable End points of Consequence Analysis

No HazardousMaterial

EquipmentConsidered

ScenarioSelected

MaterialReleasedinto env.

StabiltyClass

Flash FireEnvelopeDiameter

LOC (60% ofLEL)

ExplosionOverpressureDistance for

0.5psi(0.05bar)

pool/Jet Fire

BurnDuration

Heat Iradiation Maximum distances,m

kg m m mins 37.5Kw/m2 4Kw/m2 1.6Kw/m2

1 Acetaldehyde Tank CatasthophicFailure 10KL

D 11 <10 - -- - - -

F -- At 11 deg C the vapors releasing from solution are very less. Hence theconsequence is not analysed.

2 Benzaldehyde Tank CatasthophicFailure

38500(35KL)

D <10 - PoolFire >60 <10 21 29

F -- - PoolFire The material is below its flash point(60 degC)

3 Toluene Tank Leak through10mm hole 847 kgs

D <10 - PoolFire 4 11 29 41

F LOC was neverexceeded - Pool

Fire 5 <10 25 40

4 Acetyl chloride Drum Drum damage 200 kgD <10 - Pool

Fire 6 <10 <10 11

F <10 - PoolFire 6 <10 <10 <10

Note : ‘Material Released’ is the total material spilled or released from container. In case of Liquid Pool, from this released material some of the material will be evaporated and dispersed indirection of wind. This evaporated quantity will be less than total quantity depends on the properties of material spilled and atmospheric conditions.Detailed output of aloha is attached as Annexure – 12.






7.11.4 Inference of Consequence analysisFlammable and Toxic Storage Tank (Toluene, Benzaldehyde,Acetaldehyde etc)The major flammable consequence is pool fire. In case of catastrophic failure of tank the released liquid will becontained inside the dyke and pool is formed.The maximum radiation from pool fire is estimated from Toluene fire. The pool fire of Toluene is severe among alltanks.The Flammable storage tank is located separately. All plant areas and other buildings are more than 20m away fromflammable tank area. Hence the risk from maximum radiation which may cause damage to steel structure iseliminated.

Nonflammable and Toxic Storage Tank (Benzal Chloride, Benzyl Chloride etc )The catastrophic failure of atmospheric storage tanks of Benzal Chloride and Benzyl Chloride is analyzed.The frequency of catastrophic failure of atmospheric tanks is 1 x 10E-5.The major flammable consequence is pool fire. In case of catastrophic failure of tank the released liquid will becontained inside the dyke and pool is formed.The severe toxic effect is from failure of Benzal Chloride and Benzyl chloride. The LC50 of Benzal chloride is(400mg/m3, 2hrs) distance is <10m .The PAC3 concentration (14mg/m3) distance is 41m. And The LC50 of Benzylchloride is (150ppm, 2hrs) distance is <10m .The IDLH concentration (10ppm) distance is 43m. It may go beyondplant battery limit.This scenario is to be considered for emergency response and control planning.

Drums and Tonners Storage Area:Most of the raw materials are stored and handled in 200 lit drums. The drum damage during handling is analysed asmost credible scenario.The scenario for Acetyl chloride is analysed for flammable. And Benzo Tri chloride is analysed for toxic material.The 37.5 kw/m2 radiation from Acetyl chloride fire is experienced up to less than 10 m. The 4kw/m2 and 1.6 kw/m2radiations distance is <10m and 11m respectively. But this is very short lived fire. All Acetyl chloride will burnt within6mins.The LC50 concentrations from Benzo Tri chloride is experienced upto <10m. and IDLH concentration is experiencedup to 67m.The toxic effects are from Chlorine scenarios.The severe toxic effect is from Chlorine leak. Chlorine LC50 (500ppm) distance is 51m. The IDLH concentration(10ppm) distance is 611m. It may go beyond plant battery limit.

7.11.5 Risk to Individuals from a Major ReleaseThe risk to health to an individual at a specific point in the direction of the plume or heat radiation is dependent on anumber of factors, the most important being:

the direction of the wind when the release takes place; and mitigating factors, such as whether the individual might be indoors or out of doors.

In the case of the wind direction, the plume width may be represented by the sector of a circle having an includedangle of 15°. In such a case, on the basis that wind direction arise, it is possible to approximate that an individualpresent in a single location for one year may be exposed for only 15/360ths of that year, or 4 x 10-2In reality, it is unlikely that a person would be present at any one location in the open air for 100% of the year.Allowing for periods at work or indoors, a risk reduction factor of 3 is reasonably conservative.(three shift operation isconsidered)Also the fatality % due to radiation is assumed at 50%.This assumption is based on the response time and theduration of fire in our case.The overall consequence of the mitigation due to wind direction and indoor/outdoor location would be the product ofthese three factors, namely 1.33 x 10-2.The overall chance of an individual being affected at a specific location by exposure to the toxic gases would be asindicated in following table. From the table it is clear that for catastrophic failure the distance for 50% fatality is morethan MCS scenarios.






Flammable effect

No HazardousChemical

Incident/DifferentCases

Consequence EffectOverpressure(psig)/

Radiation(kw/m2)

Frequency ofOccurance

per yr

No of Vessels/Reactors(No of Probable

Sources)


per yrConsequence

Mitigation factor


per yr(Representing

Individual Risk)

CummulativeIndividual Risk

(Areawise)

1 Toluene Leak through 10 mmhole

Radiation(Pool Fire) 1.00E-05 5.00 5.00E-05 1.33E-02 6.65E-07 6.65E-07

2 Benzaldehyde Catastrophic Failure oftank


3Acetyl chloride Drum damage


4 Toluene Leak through 10 mmhole


Toxic effect

No HazardousChemical

Incident/DifferentCases


per yr

No ofJoints/Flanges/

Valves(No of Probable leak

locations)


per yrConsequence

Mitigation factor

Frequency ofOccurrence per yr

(RepresentingIndividual Risk)

CummulativeIndividual Risk

(Areawise)

1 Chlorine Pipeline/TubingLeakage 1.00E-05 24.00 2.40E-04 1.33E-02 3.19E-06 3.19E-06

2 Benzal Chloride Catastrophic Failure 1.00E-05 2.00 2.00E-05 1.33E-02 2.66E-07 3.46E-063 Benzyl Chloride Catastrophic Failure 1.00E-05 7.00 7.00E-05 1.33E-02 9.31E-07 4.39E-064 Benzo Trichloride Drum Damage 1.00E-05 40.00 4.00E-04 1.33E-02 5.32E-06 9.71E-06






7.12 RECOMMENDATIONSFlammable Tank Storage Area:

The major fire scenario is pool fire. If pool fire arises due to failure of any of the tank inside common dyke ofFlammable Storage Tank –farm, it is very important to prevent failure of other tanks in the dyke. This can beachieved by keeping the other tanks cool with water spray.

It is recommended to have water spray arrangement near the tanks. The fire fighting distance should be from at distance of minimum 15m from tank dyke with fire resistant clothing. Fire water network providing hydrants and monitors should be around Tank, reactor building/ process area. Also

provision of hydrants on elevated structures and buildings to be ensured. The foam fire extinguishing system should be used for pool fire fighting. Fireproofing requirement of structure and equipment supports needs to be analysed and fireproofing to be

provided accordingly. No pumps to be installed inside the dyke. All transfer pumps should have double mechanical seals. The tanks shall be provided with breather valve with flame arrester and emergency vent. Emergency vehicle shall be able to move around Flammable Tanks.

Non Flammable and Toxic Tank: Fire water network providing hydrants and monitors should be around Tank. No pumps to be installed inside the dyke. Safety shower & eye washer to be placed near Tank. Breather valve and emergency vent shall be provided.

Drums,Tonners and carboys Storage In drum storage area in warehouse, toxic and flammable materials shall be stored separately. The area shall be provided with small bund wall (100mm) to contain any spill. The warehouse shall be well ventilated. Fire water network providing hydrants and monitors should be around warehouse. Safety shower & eye washer to be placed near warehouse. Smoke detector and/or automatic actuated DCP extinguishers should be installed to get early warning and control

of any fire incident

The list of chemicals or names of chemicals and actions in case of spill should be displayed in store area. The requiredneutralizers and spill kit (Soaker- adsorbers/PPEs/disposal bags) should be kept in storage area.


































The fittings in flammable storage area should be classified fittings. Safety shower & eye washer to be placed near warehouse.

Chlorine Tonner Storage Area Chlorine Gas detectors to be maintained and inspected regularly for effectiveness and set alarm level FRP hood, chlorine kit and neutralizing agent should be placed in ready-to-use condition Only trained personnel to attend leaking tonners Regular training for using FRP hood and chlorine kit and emergency action for tonner leak should be conducted

Instrumentation & Control:The reactors should have minimum pressure & temperature indications. The alarm should be provided on eithertemperature or pressure based on the nature of process (exothermic or high pressure reaction)

Applicable Regulation:Chlorine Tonners will require to follow The Gas Cylinder Rules, 2016.Tank and Drum storages shall follow Manufacture Storage and Import of hazardous chemicals Rules, 1989, amended2000

General The plant handles flammable materials like Toluene, Acetaldehyde etc. The handling of these materials

requires control of spark, ignition source, and open flame. This is ensured by selecting equipments as perHazardous area classification analysis. Ensure that all electrical installations and instruments are as perhazardous area classification(ref IS 5571 & 5572)

Spiral wound gaskets are recommended for hydrocarbon lines. Screwed fittings should not be used except forstainless steel instrumentation.

Fireproofing requirement of structure and equipment supports needs to be analysed and fireproofing to beprovided accordingly.

The process area should be classified area for selection of electrical equipments and instruments. The construction and fabrication should be as per standard codes and practices (ASME /ANSI / IS etc) as the

failure frequencies will be valid for such construction. If there is some deviation then the frequencies mayincrease.

Fire fighting team with adequate firefighters in each team and having proper training Trained first aid team (min. 5) Provide training for employees in the procedures established for their operating and maintenance functions.

Also a refresher training program at specific intervals is to be prepared to keep operators updated. The fire fighters crew who is responding to emergency involving such chemicals should be aware of toxic

effects of stored chemicals and should use the advised PPEs for those chemicals.






wind direction pointers shall be well maintained for visibility and operation so that in an emergency the winddirection can be directly seen and downwind population cautioned

Smoking shall be prohibited in designated locations. Match boxes, Cigarettes, Mobile, any petroleum product prohibited. Visitors required to deposit such items at

security gate. Ignition exclusion Zones of the Plant shall be clearly marked with ‘No Sparks Zone’. Use of portable electrical instruments such as transistor radio or cellular phone handsets should not be allowed

to be carried in the Plant premises. Work likely to involve flame or sparks, such as, welding or burning, shall be performed only after the area is

checked for no presence of flammable material and other safety arrangement as required. A proper training shall be given to the staff to handle any emergency situation and use of PPE during the work

and emergency. Personal protective equipments to be provided to all the employees related to the type of work and hazard

associated Mutual aid from neighboring industries to be made available whenever need arises. Proper drains around production and storage areas, connected to ETP to contain contaminated water during

fire emergency Eye washers / showers to be provided at all required locations Personal protective equipments to be provided to all the employees related to the type of work and hazard

associated All the equipment and pipelines shall be marked for identification All the safety devices and instruments like safety valves, shall be tested, inspected and recalibrated as per

safety norms. Fire extinguishers, fire alarms, detectors shall be serviced and examined periodically and preventive

maintenance to be undertaken. Hydraulic testing of pressure vessels, and tanks shall be done through Government approved Competent

Person. (As per rule). Head count of all employees inside the Plant premises will be maintained by the Duty Security Head in a

register on the Gate. Similarly, head count of all contract workers and labourers shall be maintained.

7.13 DISASTER MANAGEMENT PLANThe proponent M/s. Sanghvi Organics Pvt. Ltd. is already carrying out production activities with a good record of safetymanagement. The proposed new plant shall have similar operations as for existing w.r.t production, manufacturingprocesses, utilities, chemical inventory, process control, safety aspects etc. and with better plant technology.

Proponent is committed to employ best available technology for manufacturing of proposed products. Latest design andinstrumentations shall be used in process equipment fabrication. The new plant operations shall be DCS controlled withminimum manual operations. The plant design and layout aspects also comply with the applicable regulations andrequirements of industrial ergonomics. Thus, the risks associated with the project are having low probability andseverity.

SOPL management has prepared and implemented an on-site emergency plan in compliance to the requirements ofSchedule 8A under rule 68J(12)(1) of Gujarat Factories Rule 1963 (2004) and schedule 11 under Rule 13 (1) of TheManufacture Storage and Import of hazardous chemicals Rules, 1989, amended 2000. The DMP includes emergencypreparedness plan, emergency response team, emergency communication, emergency responsibilities, emergencyfacilities, and emergency actions. The content page of onsite plan is annexed as Annexure -13.

The plan also includes an OFF site emergency plan for the concerned government authority giving details about steps tobe taken to inform related Government agencies, Medical Centers, Rescue teams and other local agencies, in an eventwhere the emergency poses danger to surrounding area requiring evacuation.EIA Consultant has reviewed the latest plan (SOPL-OSEP-2016) assessing suitability and adequacy w.r.t proposedexpansion. The review points are mentioned herewith.






Objectives of DMPAs per latest plan - Any additions or modifications required for expansion -

To identify the emergency and affecting area. To disclose the type of emergency & to act

accordingly. Initially contain and ultimately bring the incident

under control to minimize damages to property, lifeand environment.

Rescue & treat casualties and safe guard others. Identify the personnel affected/ dead, inform their

relatives and provide for their needs. Ensure the safe rehabilitation and return to normalcy

in the affected areas. Provide authoritative information to the news media

& others. Preserve relevant records & equipments for

subsequent inquiry into the causes andcircumstances which lead to the emergency.

To secure the safe rehabilitation of affected area

and to restore normalcy. To provide authoritative information to the news

media To preserve records, equipment etc., and to

organize investigation into the course of the onsiteemergency and preventive measure to stop itsrecurrence.

To provide resource and methods for effectivecontrol of emergencies arising out of toxic leakageand fire due to hazardous chemicals.

To train the people to act efficiently and withconfidence in an emergency.

To prevent the emergency turning into a disaster To minimize damages to the property, people and

environment.

Components of DMPAs per latest plan - Any additions or modifications required for expansion - Emergency Organization - structure, duties and

responsibilities of authorities response team, theircoordinators

Communication Major accident response procedures Action plan for specific emergency Action plan for road transport emergency Off-site Emergency plan Mock drill / Rehearsal / Exercise Annexures 1 to 33 Related Appendices

Training, Rehearsal & Records Updation in Annexures in prescribed formats

Emergency ResponseAs per latest plan - Any additions or modifications required for expansion - Written procedures for controlling different types of

emergencies Training of workforce for procedures and individual

roles and responsibilities Availability of emergency response equipment with

location and quantity and incharge

Additions for new product manufacturing sections andstorages shall be made in line with the results ofconsequence analysis and other risk assessmentstudies carried out by the management as perrequirement

Following points shall be kept in mind while preparing theprocedures : The exposure of workers to be limited as much as

possible during the operation Contaminated areas should be cleaned and, if

necessary disinfected Limited impact on the environment at the extent

possible.

Levels of EmergencyFour levels of emergency are defined :Level-1 : On-siteLevel-II : Off-site – Mutual Aided / Local crisisLevel – III : Off-site – District CrisisLevel – IV : Off-site – State Crisis / Natonal Crisis

No changes required






The communication system beginning with raising the alarm,declaring the major emergency and procedure to make it known toothers include the following :

No changes required

Declaring the major emergency Emergency Siren Code Information And Warning Safe Assembly Points Declaration Of Emergency

Assembly points :Location AccommodationBehind Admin Building AllNr. Vehicle Parking Area All

Emergency Control Center (ECC) is established at admin officeand store. ECC is equipped with following items :

Emergency telephone nos. with contact persons List of Essential workers and key persons List of trained person in first aid and fire Layout of site plan of the unit Layout on fire-pipeline network and fire protection system Gas pipeline network system Details on storage of hazardous chemicals with stock position Copy of Onsite Emergency plan, etc.

ECC in charge as identified for individual ECC will maintain it.

Updated documents to be placed at ECCs

Emergency Communication (Available system at SOPL)As per latest plan - Any additions or modifications required for expansion -Levels of Emergency and Siren Codes arementioned in the plan.

Addition of alarms, PA system and sirens in new plant section.To add Testing of siren - Plain & wailing for one minute on Every Monday at1100 hrs.

1) Landline telephones2) Emergency mobile phones3) Emergency phone at Emergency Control Room4) Mobile phone with Senior Engineer

Sr. No. Type of siren Location of Siren Operating Range of siren1 Electrical Security Office 0.5 KM

Any additions or modifications required for expansionThere shall be additional manpower employed in the plant during construction phase as well as operational phase of theexpansion including contract labour. This additional manpower, particularly construction labour shall be given propertraining on the levels of emergency and their role during emergency. Regular inspection and examination of theirawareness about possible incidences and their emergency response shall be undertaken by EHS personnel. Mock drillfor construction labour is also suggested.

Emergency Management Team - additional personnel from new plant sections to be addedThe following emergency management executive/personnel are required to play stellar role in combating theemergency. Site Main Controller Incident Controller (Manager (Oprns.) /manager (Maintenance)) Deputy Incident Controllers (Deputy Manager / Asst. Manager) Essential Workers Key Personnel Plant Supervisor/Operator






Communication Controller/Telephone Operator Personnel Officer Security Officer Safety Officer

The plan designates all positions and also defines the roles and responsibilities of Site Controller, Incident Controllerand other key personnel for emergency control. Personnel from new plant sections shall be added in the list of allpositions of emergency management team.

Emergency organogram

The existing DMP includes the following : Onsite action and emergency control procedures based on consequence analysis results Evacuation & Transportation Safe Close-Down Use Of Mutual Aid Use Of External Authorities Medical Treatment Accounting for personnel

Mitigation of Environmental Impact during emergency for - Fire, Explosion Chemical Spillage Mitigation of Environmental Impact during emergency for -Fire, Explosion and Chemical Spillage

Additions required : Access to Records Rehabilitation Consequence analysis shall be included together with their emergency control procedures if different from existing. Specific medical treatment as per MSDS shall be noted by FMO and added in OHC manual and given training to

first-aiders.












first-aiders.












first-aiders.






Changes in Annexures to onsite emergency planAnnexureNo. Annexure Changes or additions

1. Identification of the factory No. of workers working in all shifts and any other changein incharge personnel

2. Site plan (Key plan) No change3. Factory Layout To be revised for new sections4. Storage Hazards & Controls Add for new hazardous chemical storages5. MSDS Add for new hazardous chemicals6. Process & vessel Hazard & Controls No change7. Other Hazards & Controls No change8. Trade waste disposal update9. Record of past incidents update10. Gas dispersion concentration No change11. Evacuation Table No change12. Environment Impact Assessment update13. Meteorological data update14. Incident Controllers update15. Deputy Incident Controllers update16. Site Main Controllers update17. Key Personnel update18. Essential Workers update19. Assembly Points No change20. Emergency Control Centre No change, revised documents to be placed at the centre21. Fire & Toxicity Control Arrangements Update for new fire fighting components22. Medical Arrangements No change23. Transport & Evacuation arrangements No change24. Pollution control arrangement25. Other arrangement26. Alarms and Sirens No change27. Internal Phones update28. External Phones update29. Nominated persons to declare major Emergency No change30. A form to record Emergency Telephone calls No change31. Statutory communication update32. Separation Distances No change33. Emergency instruction booklet update

Offsite Emergency Preparedness – already addressed in existing plan

Abstracts of Latest District Disaster Management Plan (DDMP) downloaded from website of Bharuch Collector’s Officeare presented herewith for information on emergency control facilities available in this region :-

project sector - synthetic organic chemicals industry –...

Documents