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ATUL LIMITED EXPANSION IN EXISTING PRODUCTION CAPACITY AND

ADDITION OF NEW PRODUCTS

PAGE 275

CHAPTER – 6 ADDITIONAL STUDIES

6.1 GENERAL

An additional study including Risk Assessment (RA), Disaster Management Plan and Occupational,

Health & Safety Management System has been carried out for the proposed expansion project to identify

main hazards, to review the effectiveness of selected safety measures and to expand the safety measures

in order to achieve a zero risk culture at the company. The study has been incorporated in the

Environmental Impact Assessment (EIA) report to support the Environmental Management Plan. The

study for the project has been further divided into the following sections:

Risk assessment (Part - 01)

Disaster Management Plan (Part - 02)

Occupational Health and Safety Management System (Part - 03)

6.2 SCOPE OF THIS STUDY

The Qualitative Risk Assessment (QRA) study for proposed expansion has specifically been conducted

considering the Terms of References (TORs) given by the State Expert Appraisal Committee for

Environmental Clearance (EC).

The study has been carried out with a view to comply the following TORs:

TOR No. 41: Disaster Preparedness and Emergency Management Plan including Risk Assessment

and damage control needs to be addressed and included

TOR No. 42: Details of occupational health programme.

Additional TOR for Synthetic Organic Chemical Industry


TOR No. 11: A toxic management plan shall be prepared.

TOR No. 13: What are onsite and offsite emergency plan during chemical disaster.



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PART 01 – RISK ASSESSMENT

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6.3 GENERAL

Atul Ltd. is an agrochemical, Pharma intermediates, dyes & dyes intermediates, polymers, resins and

specialty chemicals unit located at Atul, Di. Valsad, Gujarat. Hence, it deals with various chemicals,

some of which are hazardous in nature by virtue of their intrinsic chemical properties or their operating

temperatures or pressures or a combination of them. Fire, explosion, toxic release or combinations of

them are the hazards associated with industrial plants using hazardous chemicals. Comprehensive,

systematic and sophisticated methods of Safety Engineering, such as, Hazard Analysis and Quantitative

Risk Assessment have been developed to improve upon the integrity, reliability and safety of the

industrial plant.

6.4 OBJECTIVES OF RISK ASSESSMENT

Risk analysis involves an extensive hazard analysis. It involves the identification and assessment of risks

to which the plant personnel, neighboring populations and the surrounding environment are exposed as a

result of the hazards present. This requires a thorough knowledge of failure probability, credible accident

scenario, vulnerability of population etc. Much of this information is difficult to get or generate.

Consequently, the risk analysis is often confined to maximum credible accident studies. It provides basis

for what should be the type and capacity of its on-site and off-site emergency plan and the types of

safety measures to be required for the same.

Objectives of risk assessment are:

To identify hazard and risks resulting from the hazards

To study and foresee the effects of such risks on the workers, public, property and the environment

To find out necessary control measures to prevent or minimize risk

To comply the legal requirement by various safety and environment laws of the country

To get the necessary information for Emergency planning and evacuation

6.5 SCOPE OF THE STUDY

Atul Ltd. has proposed to enhance the production of Dyes, Chlor alkali products, Agrochemical, Resins

and other chemicals. The process deals with various hazardous chemicals. Hence, a quantitative risk



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assessment (QRA) was undertaken to assess the risk impacts associated with the installation, and to

establish a system for minimizing these risks. The QRA study in this report has specifically been

conducted considering the Terms of References (TORs) given by Expert Appraisal Committee of

MoEF&CC for Environment Clearance (EC) as mentioned below:

TOR No. 41: Disaster Preparedness and Emergency Management Plan including Risk Assessment

and damage control needs to be addressed and included


i. Details of existing Occupational & Safety Hazards. What are the exposure levels of above

mentioned hazards and whether they are within Permissible Exposure Level (PEL). If these are not

within PEL, what measures the company has adopted to keep them within PEL so that health of

the workers can be preserved.

ii. Details of exposure specific health status evaluation of worker. If the workers‟ health is being

evaluated by pre designed format, chest x rays, Audiometry, Spirometry, vision testing (Far &

Near vision, colour vision and any other ocular defect) ECG, during pre placement and periodical

examinations give the details of the same. Details regarding last month analyzed data of above

mentioned parameters as per age, sex, duration of exposure and department wise.

iii. Annual report of health status of workers with special reference to Occupational Health and Safety.

iv. Action plan for the implementation of OHS standards as per OSHAS/USEPA.

v. Plan and fund allocation to ensure the occupational health & safety of all contract and casual

workers.

Additional TOR for Synthetic Organic Chemical Industry


i. To which chemicals, workers are exposed directly or indirectly.

ii. Whether these chemicals are within Threshold Limit Values (TLV)/ Permissible Exposure Levels

as per ACGIH recommendation.

iii. What measures company has taken to keep these chemicals within PEL/TLV.

iv. How the workers are evaluated concerning their exposure to chemicals during pre-placement and

periodical medical monitoring.



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v. Liver function tests (LFT) during pre-placement and periodical examination.

TOR No. 11: A toxic management plan shall be prepared.

TOR No. 13: What are onsite and offsite emergency plan during chemical disaster.

6.6 METHODOLOGY ADOPTED

Consequences of loss of containment can lead to hazardous situation in any industry handling potentially

hazardous materials. Following factors govern the severity of consequence of the loss of containment:

Intrinsic properties; flammability, instability and toxicity.

Dispersive energy; pressure, temperature and state of matter.

Quantity present

Environmental factors; topography and weather.

Consequence analysis and calculations are effectively performed by computer software using models

validated over a number of applications. Consequence modelling is carried out by PHAST of DNV

Software.

PHAST contains data for a large number of chemicals and allows definition of mixtures of any of these

chemicals in the required proportion. The calculations by PHAST involves following steps for each

modelled failure case:

- Run discharge calculations based on physical conditions and leak size

- Model first stage of release (for each weather category)

- Dispersion modeling taking into account weather conditions

- In case of flammable gas release, calculate size of effect zone for fire and explosion

6.7 CONSEQUENCE ASSESSMENT

For each defined failure case for the Chemical Storage Facility, the consequence modelling is carried out

to determine the potential effects of releases, the results of which are discussed in terms of hazard

distances.



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The corresponding consequences in terms of flammable and explosive effects are modelled and analysed

by using PHAST software version 6.7. The flammable consequences that may potentially arise from

failure of a storage vessel are:

Jet fires;

Flash fires;

Toxic consequence;

Fireball; and/or

Explosions.

The hazard distances for each event depend on the leak size, operating conditions, weather conditions,

the release location, the release conditions and the dispersion characteristics as calculated by the PHAST

software. Each failure case is entered into PHAST software, where the corresponding consequences are

calculated, based on built-in programmable event trees.

The dispersion of gas releases from different hole sizes are modelled using state-of-art methods. For

flammable, toxic and explosive consequence, the effect zones for the various possible outcomes of such

a release are determined for both early and delayed ignition presents the consequence hazard distances

for the various tank failure case scenarios.

Consequence distances for the following weather conditions have been evaluated in the tables below,

D11: D stability (neutral) and 11 m/s wind speed.

B2: B stability (neutral) and 2 m/s wind speed.

F2: F stability (very stable) and 2 m/s wind speed.

The following descriptions are based on the different hazard types modelled, which are jet fires, flash

fires, toxic consequence, vapor cloud explosions, pool fires.

6.7.1 Jet Fire

A jet fire may result from ignition of a high-pressure leakage of gas from process plants or storage tanks.

Jet fires are characterized by a high momentum jet flame that is highly turbulent. The flame is lifted

above the exit opening from which the gas is discharged generally at high pressure. This distance



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appears because the combustion process can only take place when the flow velocity is reduced

sufficiently to allow stable combustion. Another feature of such fires is the high entrainment of air into

the flame plume due to the highly turbulent flame.

The extent of the consequence of a Jet fire is represented by the thermal radiation envelope. Three levels

of radiation are presented in this report, i.e.:

4 kW/m2; this level is sufficient to cause personnel if unable to reach cover within 20 s; however

blistering of the skin (second degree burn) is likely; 0: lethality,

12.5 kW/m2; this level will cause extreme pain within 20 seconds and movement to a safer place is

instinctive. This level indicates around 6% fatality for 20 seconds exposure.

37.5 kW/m2; this level of radiation is assumed to give 100% fatality.

Jet fires are a direct hazard to people and structures caught within the flame envelope or exposed to high

thermal radiation levels. This scenario is considered for the whole storage facility in which material is

handled at the significant pressures.

6.7.2 Flash Fire

A flash fire is the non-explosive combustion of a flammable vapour cloud resulting from a release of

volatile material into the open air, which, after mixing with air, ignites. The flame initially propagates

slowly, often 10 m/s or less, and in the Shell Maplin Sands experiments often was unable to overcome

the wind speed to flash back to the source. However, where congestion or confinement exist, flame

speeds can accelerate to hundreds of m/s and overpressure effects will result.

The cloud burns as a flash fire and the major hazard to people and to equipment (especially control

cabling) is for those within the burning envelope (including those who might be above on elevated

structures). Flame duration and intensity for most flammable clouds are insufficient to cause a

significant thermal radiation hazard outside the flame envelope. The literature provides little information

on the effects of thermal radiation from flash fires, probably because thermal radiation hazards from

burning vapour clouds are considered less significant than possible blast effects. Furthermore, flash

combustion of a vapour cloud normally lasts no more than a few tens of seconds. Propane experiments

(Maplin) gave average flame speeds of up to about 12 m/s. higher transient flame speeds, up to 28 m/s

were observed in one instance. Pool Fire Formation of pools is also likely, particularly for materials that



PAGE 282

have high boiling points. Flash calculations were conducted to consider the vaporization of light

components in the streams, especially for high pressure or high temperature process conditions. Flashed

vapor and light component releases will behave as jets, with jet fire and vapor cloud impacts modelled in

the same way as for gas releases, as set out in the previous sections.

The extent of the consequence of a flash fire is represented by the flash fire envelope. i.e. the maximum

dispersion distance of the flammable cloud at LFL concentration.

6.7.3 Vapor Cloud Explosion (VCE)

Due to the large volume of flammable materials and highly flammable material with higher proportion

of the more volatile components, there is significant potential for Vapour Cloud Explosion Events

(VCE) in case any ignition source is not available immediately.

Maximum flammable fuel volume for prediction of explosion overpressure effects estimated to be

considerable based on inventory, isolation time, time for vaporization and probability of VCE scenario.

6.7.4 Toxic Consequences

In the event of a release of toxic material not being ignited, the concentration of material in the cloud is

progressively reduced by dilution with air until the concentration is well below any toxic effects. Such

releases do not directly affect the plant, but cloud affect people enveloped by the cloud. Distances to 3%

fatality level, or the IDLH concentration and the exposure limit have been calculated using the

dispersion models. Table No. 6.1 below summarises the toxic consequence results.

Consequence results tables below summarises representative failure cases together with their various

consequence results.

Table No. 6.1 – Consequence Results at Atul

Sr.

No. Node Description

Accident

Scenario

Release

Rate &

Duration

Event Impact

criteria

Consequence Distance(m)

D 11m/s B 2m/s F 2m/s

1.

Caustic

Chlorine

Plant

Caustic

Chlorine Plant

(ST3 & ST5)

Small 0.314 kg/s

& 300 s Toxicity IDLH (10 ppm) 196.53 204.71 1345.30

Medium 7.858 kg/s


Large 125.7 kg/s

& 238.6 s Toxicity IDLH (10 ppm) 2654.64 2252.39 18207.50

Rupture 282.9 kg/s




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Sr.


Accident

Scenario

Release

Rate &

Duration

Event Impact

criteria



Chlorine

Tonner

Small 0.056 kg/s


Medium 1.41 kg/s &

300 s Toxicity IDLH (10 ppm) 498.85 491.54 3168.01

Rupture 5.82 kg/s &

154.7 s Toxicity IDLH (10 ppm) 905.44 864.48 5547.69

2. Sulphuric

Acid Plant

CSA ST6/7/10

Small 0.235 kg/s


Medium 5.88 kg/s &


Large 94.22 kg/s


Rupture 212 kg/s &

259.4 s Toxicity IDLH (50 ppm) 119.61 94.18 403.98

CSA ST-102

Small 0.218 kg/s


Medium 5.45 kg/s &


Large 87.23 kg/s


Rupture 196.3 kg/s


Liq. SO3(ST-

12/106)

Small 0.211 kg/s

& 300 s Toxicity

IDLH (100

ppm) 37.35 32.68 116.58

Medium 5.274 kg/s

& 300 s Toxicity

IDLH (100

ppm) 65.71 102.78 445.71

Large 84.39 kg/s

& 189.6 s Toxicity

IDLH (100

ppm) 287.21 295.55 1117.14

Rupture 189.9 kg/s

& 84.27 s Toxicity

IDLH (100

ppm) 349.54 343.59 1124.13

25% Oleum

ST1

Small 0.42 kg/s &

300 s Toxicity

IDLH (100

ppm) 20.19 25.31 91.75

Medium 10.56 kg/s

& 300 s Toxicity

IDLH (100

ppm) 89.94 80.51 290.29

Large 169 kg/s &

300 s Toxicity

IDLH (100

ppm) 231.26 236.03 811.92

Rupture 280.2 kg/s

& 210.4 s Toxicity

IDLH (100

ppm) 300.72 300.98 1080.80

25% Oleum

ST2

Small 0.446 kg/s

& 300 s Toxicity

IDLH (100

ppm) 21.18 26.47 95.58

Medium 11.16 kg/s

& 300 s Toxicity

IDLH (100

ppm) 91.87 83.31 300.58

Large 178.5 kg/s

& 300 s Toxicity

IDLH (10

0ppm) 234.79 241.94 835.40

Rupture 401.6 kg/s

& 300 s Toxicity

IDLH (100

ppm) 320.39 341.35 1252.56

25% Oleum

ST9

Small 0.42 kg/s &

300 s Toxicity

IDLH (100

ppm) 15.54 30.92 99.03

Medium 10.56 kg/s

& 300 s Toxicity

IDLH (100

ppm) 100.98 97.28 339.88

Large 169 kg/s &

163.2 s Toxicity

IDLH (100

ppm) 303.93 210.74 681.43

Rupture 380.2 kg/s Toxicity IDLH (100 338.59 206.43 646.86



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Sr.


Accident

Scenario

Release

Rate &

Duration

Event Impact

criteria



& 72.52 s ppm)

65% Oleum

ST101& 103

Small 0.502 kg/s

& 300 s Toxicity

IDLH (100

ppm) 30.18 43.49 174.48

Medium 12.57 kg/s

& 300 s Toxicity

IDLH (100

ppm) 165.20 147.05 559.12

Large 201.2 kg/s

& 300 s Toxicity

IDLH (100

ppm) 519.81 420.68 1523.10

Rupture 452.6 kg/s

& 169.8 s Toxicity

IDLH (100

ppm) 641.60 506.35 1795.05

3. Phosgene

Chlorine

Tonner

Small 0.056 kg/s


Medium 1.41 kg/s &


Rupture 5.82 kg/s &


Phosgene

Storage tank-

18-1/18-2

Small 0.1539 kg/s


Medium 3.849 kg/s


Large 61.58 kg/s


Rupture 138.6 kg/s


Phosgene

Service tank-

19-1/19-2/ 19-

3

Small 0.141 kg/s


Medium 3.526 kg/s


Large 56.41 kg/s


Rupture 126.9 kg/s

& 8s Toxicity IDLH(2ppm) 742.67 679.61 6191.72

Phosgene

reactor

Small 0.001261

kg/s & 60 s Toxicity IDLH (2 ppm) NH NH 22.98

Medium 0.03152

kg/s & 60 s Toxicity IDLH (2 ppm) NH 16.99 103.25

Rupture 0.292 kg/s

& 6.83 s Toxicity IDLH (2 ppm) NH 22.81 162.45

Phosgene

cylinder

Small 0.00814

kg/s & 120 s Toxicity IDLH (2 ppm) 28.21 29.03 147.29

Medium 0.2036 kg/s


Rupture 1.892 kg/s


Small 0.0006816

kg/s & 180s

Flash Fire 125000 ppm 0.30 0.29 0.30

Toxicity IDLH (1200

ppm) NH NH NH

Medium 0.01704

kg/s & 180 s

Flash Fire 125000 ppm 1.03 1.18 1.26

Toxicity IDLH (1200

ppm) NH NH NH

Large 0.2726 kg/s

& 164.9 s

Flash Fire 125000 ppm 3.17 3.84 4.28

Toxicity IDLH (1200

ppm) NH NH NH



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Sr.


Accident

Scenario

Release

Rate &

Duration

Event Impact

criteria



Rupture 0.6135 kg/s

& 73.29 s

Flash Fire 125000 ppm 4.37 5.38 6.05

Toxicity IDLH (1200

ppm) NH NH NH

Phosgene line

transfer to

PHIN/NBD

Small 0.007104

kg/s & 300 s Toxicity IDLH (2 ppm) NH NH 102.88

Medium 0.1776 kg/s


Large 2.841 kg/s


Rupture 6.393 kg/s


Ammonia

Cylinder

Small 0.03349

kg/s & 120 s

Flash Fire 160000 ppm 2.08 1.70 2.51

Jet Fire 37.5 kW/m2 NR NR NR

4 kW/m2 2.40 3.03 3.03

Toxicity IDLH (300

ppm) 21.79 32.16 95.16

Medium 0.8373 kg/s

& 47.77 s

Flash Fire 160000 ppm 9.92 7.93 10.24


4 kW/m2 8.65 11.02 11.01

Toxicity IDLH (300

ppm) 84.11 126.11 298.03

Large 13.4 kg/s &

2.99 s

Flash Fire 160000 ppm 36.46 31.55 26.82


4 kW/m2 29.24 37.29 37.28

Toxicity IDLH (300

ppm) 179.53 286.25 44.27

Rupture 30.14 kg/s

& 1.33 s

Flash Fire 160000 ppm 53.52 39.24 37.18


4 kW/m2 42.00 53.38 53.37

Toxicity IDLH (300

ppm) 235.49 96.96 51.24

Ammonia

Chilling tank

Small 0.5448 kg/s

& 300 s

Flash Fire 160000 ppm 3.44 4.89 5.24


4 kW/m2 7.76 9.66 9.66

Toxicity IDLH (300

ppm) 113.67 115.09 283.81

Medium 13.62 kg/s

& 14.68 s

Flash Fire 160000 ppm 33.87 28.14 28.07


4 kW/m2 32.74 41.41 41.39

Pool Fire 37.5 kW/m2 NR NR NR

4 kW/m2 30.05 24.62 22.03

Toxicity IDLH (300

ppm) 238.89 272.82 405.14

Large 217.9 kg/s

& 0.92 s

Flash Fire 160000 ppm 95.29 75.74 80.08

Jet Fire 37.5 kW/m2 75.79 NR NR

4 kW/m2 113.24 140.18 140.12


4 kW/m2 42.90 38.30 33.72



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Sr.


Accident

Scenario

Release

Rate &

Duration

Event Impact

criteria



Toxicity IDLH (300

ppm) 345.59 592.07 741.72

Rupture 490.4kg/s &

0.41s

Flash Fire 160000 ppm 133.99 104.39 109.76


4 kW/m2 162.37 200.12 200.02


4 kW/m2 45.95 41.67 37.21

Toxicity IDLH (300

ppm) 458.57 762.19 968.11

MDC Chilling

Tank

Small 0.264 kg/s

& 1800 s

Flash Fire 159000 ppm 0.88 1.47 1.66


4 kW/m2 4.75 4.13 4.24

Medium 6.59 kg/s &

151.2 s

Flash Fire 159000 ppm 2.13 1.92 2.01


4 kW/m2 5.87 5.52 4.89


4 kW/m2 13.20 9.54 9.56

Large 105.6 kg/s

& 9.47 s

Flash Fire 159000 ppm 2.35 2.00 2.44


4 kW/m2 17.65 10.71 8.37


4 kW/m2 13.09 9.73 9.74

Rupture 237.6 kg/s

& 4.21 s

Flash Fire 159000 ppm 2.35 2.10 2.44


4 kW/m2 20.87 11.75 9.47


4 kW/m2 13.12 9.77 9.80

4. SHED C

Anhydrous

Ammonia

Storage (C-

03/03/30)

Small 0.5492 kg/s

& 600 s

Flash Fire 160000 ppm 9.18 9.86 7.03


4 kW/m2 6.63 8.39 8.39


4 kW/m2 5.59 5.29 5.34

Toxicity IDLH (300

ppm) 98.09 102.01 442.98

Medium 13.73 kg/s

& 600 s

Flash Fire 160000 ppm 28.43 26.61 15.19


4 kW/m2 26.73 33.92 33.91


4 kW/m2 20.30 19.38 19.36

Toxicity IDLH (300

ppm) 352.57 263.83 1182.21

Large 219.7 kg/s

& 45.52 s

Flash Fire 160000 ppm 79.76 46.48 43.22


4 kW/m2 92.47 114.74 114.70




PAGE 287

Sr.


Accident

Scenario

Release

Rate &

Duration

Event Impact

criteria



4 kW/m2 33.44 32.39 32.44

Toxicity IDLH (300

ppm) 687.32 278.32 1879.53

Rupture 494.3 kg/s

& 20.23 s

Flash Fire 160000 ppm 105.99 61.38 59.27


4 kW/m2 132.67 163.91 163.84


4 kW/m2 33.74 32.64 32.67

Toxicity IDLH (300

ppm) 804.30 372.24 1956.15

5. Epoxy

T-601

Small 0.14 kg/s &

1200 s

Flash Fire 38000 ppm 0.93 1.08 1.21


4 kW/m2 0.51 1.14 1.14


4 kW/m2 10.39 8.84 8.86

Toxicity IDLH (7ppm) 69.23 66.31 462.61

Medium 3.56 kg/s &

1200 s

Flash Fire 38000 ppm 1.51 2.22 2.59


4 kW/m2 2.65 2.93 2.46

Pool Fire 37.5 kW/m2 9.06 9.08 9.10

4 kW/m2 38.52 35.89 35.98

Toxicity IDLH (7 ppm) 314.55 296.78 2135.92

Large 56.96 kg/s

& 1200 s

Flash Fire 38000 ppm 1.74 2.75 3.90


4 kW/m2 7.08 4.32 3.69

Pool Fire 37.5 kW/m2 12.14 11.70 11.70

4 kW/m2 52.29 48.84 48.79


Rupture 128.2 kg/s

& 829.8 s

Flash Fire 38000 ppm 1.94 3.02 4.37


4 kW/m2 7.63 4.91 4.31

Pool Fire 37.5 kW/m2 12.14 11.70 11.70

4 kW/m2 52.29 48.84 48.79


T-601-A

Small 0.14 kg/s &

1200 s

Flash Fire 38000 ppm 1.00 1.17 1.22


4 kW/m2 0.59 1.19 1.19


4 kW/m2 10.87 9.32 9.34


Medium 3.56 kg/s &

1200 s

Flash Fire 38000 ppm 1.59 2.34 2.80


4 kW/m2 2.95 3.05 2.59

Pool Fire 37.5 kW/m2 9.53 9.56 9.59

4 kW/m2 40.44 37.75 37.84



PAGE 288

Sr.


Accident

Scenario

Release

Rate &

Duration

Event Impact

criteria




Large 56.96 kg/s

& 1200 s

Flash Fire 38000 ppm 1.79 2.85 4.04


4 kW/m2 7.07 4.47 3.92

Pool Fire 37.5 kW/m2 12.14 11.70 11.70

4 kW/m2 52.29 48.84 48.79


Rupture 128.2 kg/s

& 825.5 s

Flash Fire 38000 ppm 2.06 3.17 4.57


4 kW/m2 7.64 5.11 4.58

Pool Fire 37.5 kW/m2 12.14 11.70 11.70

4 kW/m2 52.29 48.84 48.79


T-608

Small 0.14 kg/s &

1200 s

Flash Fire 38000 ppm 0.92 0.79 1.23


4 kW/m2 0.23 0.19 0.18


4 kW/m2 9.89 8.34 8.35


Medium 3.56kg/s &

1200s

Flash Fire 38000 ppm 1.38 1.99 2.21


4 kW/m2 1.58 1.98 1.73

Pool Fire 37.5 kW/m2 8.57 8.57 8.59

4 kW/m2 36.54 33.94 34.01


Large 56.96 kg/s

& 596.9 s

Flash Fire 38000 ppm 1.50 2.12 2.66


4 kW/m2 4.76 2.82 2.36

Pool Fire 37.5 kW/m2 12.14 11.70 11.70

4 kW/m2 52.29 48.84 48.79


Rupture 128.2 kg/s

& 265.3 s

Flash Fire 38000 ppm 1.49 2.18 2.67


4 kW/m2 5.07 3.19 2.72

Pool Fire 37.5 kW/m2 12.14 11.70 11.70

4 kW/m2 52.29 48.84 48.79


T-609 Small

0.14 kg/s &

1200 s

Flash Fire 38000 ppm 0.93 1.07 1.22


4 kW/m2 7.80 6.42 6.41


4 kW/m2 10.48 8.92 8.94


Medium 3.56 kg/s & Flash Fire 38000 ppm 1.51 1.99 2.39



PAGE 289

Sr.


Accident

Scenario

Release

Rate &

Duration

Event Impact

criteria



1200 s Jet Fire

37.5 kW/m2 NR NR NR

4 kW/m2 1.81 2.05 1.79

Pool Fire 37.5 kW/m2 9.15 9.16 9.18

4 kW/m2 38.90 36.23 36.29


Large 56.96 kg/s

& 1036 s

Flash Fire 38000 ppm 1.57 2.21 2.69


4 kW/m2 4.73 2.92 2.49

Pool Fire 37.5 kW/m2 12.14 11.70 11.70

4 kW/m2 52.29 48.84 48.79


Rupture 128.2 kg/s

& 460.3 s

Flash Fire 38000 ppm 1.57 2.27 2.96


4 kW/m2 5.06 3.32 2.91

Pool Fire 37.5 kW/m2 12.14 11.70 11.70

4 kW/m2 52.29 48.84 48.79

Toxicity IDLH(7ppm) 384.04 363.58 2572.62

6. FDH

Methanol

Tank (380

KL)

Small 0.124 kg/s

& 600 s

Flash Fire 73000 ppm 1.11 2.41 3.15


4 kW/m2 5.66 4.88 4.90

Toxicity IDLH (6000

ppm) 1.35 5.04 16.93

Medium 3.09 kg/s &

600 s

Flash Fire 73000 ppm 2.58 5.08 5.27


4 kW/m2 19.69 18.97 19.08

Toxicity IDLH (6000

ppm) 4.89 7.77 20.21

Methanol

Tank (90 KL)

Small 0.124 kg/s

& 600 s

Flash Fire 73000 ppm 1.21 2.41 3.15


4 kW/m2 5.66 4.88 4.90

Toxicity IDLH (6000

ppm) 0.14 1.18 16.17

Medium 3.09 kg/s &

600 s

Flash Fire 73000 ppm 2.58 5.08 5.27


4 kW/m2 19.69 18.97 19.08

Toxicity IDLH (6000

ppm) 0.14 1.92 19.08

Tank On Fire Pool Fire 37.5 kW/m2 31.91 35.23 178.59

The figures below represent the consequence distance due to toxic release. Due to practical difficulties

in order to capture the distances, the consequence distances between 200 m and 2000 m are only

represented. The consequence contours are shown in the best possible manner for easy reference and

understanding.



PAGE 290

Figure No. 6.1 – Small leak of 25% oleum from the 25% oleum ST1

Figure No. 6.2 – Medium leak of 25% oleum from the 25% oleum ST1



PAGE 291

Figure No. 6.3 – Large leak of 25% oleum from the 25% oleum ST1

Figure No. 6.4 – Rupture of 25% oleum from the 25% oleum ST1



PAGE 292

Figure No. 6.5 – Small leak 25% oleum from the 25% oleum ST9




PAGE 293

Figure No. 6.7 – Large leak of 25% oleum from the 25% oleum ST9




PAGE 294

Figure No. 6.9 – Small leak 25% oleum from the 25% oleum ST2




PAGE 295

Figure No. 6.11 – Large leak 25% oleum from the 25% oleum ST2




PAGE 296

Figure No. 6.13 – Small leak of 65% oleum from the 65% oleum

Figure No. 6.14 – Medium leak of 65% oleum from the 65% oleum



PAGE 297

Figure No. 6.15 – Large leak 65% oleum from the 65% oleum

Figure No. 6.16 – Rupture of 65% oleum from the 65% oleum



PAGE 298

Figure No. 6.17 – Small leak of ammonia from the Shed C

Figure No. 6.18 – Medium leak of ammonia from the Shed C



PAGE 299

Figure No. 6.19 – Large leak of ammonia from the Shed C

Figure No. 6.20 – Rupture of ammonia from the Shed C



PAGE 300

Figure No. 6.21 – Medium leak of Ammonia from the Ammonia cylinder

Figure No. 6.22 – Medium leak of Phosgene from the Phosgene cylinder



PAGE 301

Figure No. 6.23 – Large leak of Phosgene from the Phosgene cylinder

Figure No. 6.24 – Small leak of Ammonia from the Ammonia chilling tank



PAGE 302

Figure No. 6.25 – Medium leak of Ammonia from the Ammonia chilling tank

Figure No. 6.26 – Large leak of Ammonia from the Ammonia chilling tank



PAGE 303

Figure No. 6.27 – Rupture of Ammonia from the Ammonia chilling tank

Figure No. 6.28 – Small leak of Chlorine from the Chlorine Toner



PAGE 304

Figure No. 6.29 – Medium leak of Chlorine from the Chlorine Toner

Figure No. 6.30 – Rupture of Chlorine from the Chlorine Toner



PAGE 305

Figure No. 6.31 – Medium leak of CSA from the CSA ST-102

Figure No. 6.32 – Large leak of CSA from the CSA ST-102



PAGE 306

Figure No. 6.33 – Rupture of CSA from the CSA ST-102

Figure No. 6.34 – Medium leak of CSA from the CSA 6710



PAGE 307

Figure No. 6.35 – Large leak of CSA from the CSA 6710

Figure No. 6.36 – Rupture of CSA from the CSA 6710



PAGE 308

Figure No. 6.37 – Small leak Epichlohydrine from the Epoxy 601

Figure No. 6.38 – Medium leak of Epichlorohydrine from the Epoxy 601



PAGE 309

Figure No. 6.39 – Large leak of Epichlorohydrine from the Epoxy 601

Figure No. 6.40 – Rupture of Epichlorohydrine from the Epoxy 601



PAGE 310

Figure No. 6.41 – Small leak of Phosgene from the Phosgene tank 18 1&2

Figure No. 6.42 – Medium leak of Phosgene from the Phosgene tank 18 1&2



PAGE 311

Figure No. 6.43 – Large leak of Phosgene from the Phosgene tank 18 1&2

Figure No. 6.44 – Rupture of Phosgene from the Phosgene tank 18 1&2



PAGE 312

Figure No. 6.45 – Small Leak of SO3 from the SO3 ST12-106

Figure No. 6.46 – Medium Leak of SO3 from the SO3 ST12-106



PAGE 313

Figure No. 6.47 – Large Leak of SO3 from the SO3 ST12-106

Figure No. 6.48 – Rupture of SO3 from the SO3 ST12-106



PAGE 314

6.8 CONCLUSIONS AND RECOMMENDATIONS

The consequence distances were calculated, and have been summarized in this report. The tabulated

distances give a fair idea of the impact that would be caused by the identified scenario.

The following are recommended based on the assumptions, main findings and conclusion drawn from

this consequence study. The following best practices to be followed to demonstrate the ALARP (As

Low as Reasonably Practicable) performance:

The existing safety measures are maintained at their expected level of performance or better to

ensure all these safety measures are in a good condition. Hence, the same shall be continued even

after the proposed expansion.

In this facility, particularly the detection, isolation, spill containment, and ventilation etc., are to be

maintained at their expected level of performance or better. A regular inspection should be

performed to ensure all these safety measures are in a good condition throughout the facility

lifecycle.

Regular maintenance and inspection should be performed for all critical equipment, having higher

consequence damage distance. This is to minimize potential failure due to material degradation or

fatigue.

Ensure availability and effectiveness of Fire & Gas system and the emergency alarm system and

means of communication, which would enable early warning to all personnel in the event of

accidental release and subsequently enable all personnel to take appropriate action.

Review arrangements focusing on worst case scenarios, offsite and onsite.

6.9 DETAILS OF STORAGE FACILITIES

Table No. 6.2 – Tank details at Atul

Plant Chemical

Operation Inventory

(MT)

Temp.

(OC)

Pressure

(kg/cm2)

Elevation

(mm) Phase

Tank volume

or Full

Volume (m3) Storage Tank

No.

Caustic-

Chlorine

plant

Chlorine Storage ST 3 30 -18 1 to 1.5 (-775) Liquid 55

Chlorine Storage ST 5 30 -18 1 to 1.5 (-750) Liquid 69

Chlorine Tonner

storage

0.90mt *

200 nos

cylinder

180 32 to

35 8 0 Liquid 1.02



PAGE 315

Plant Chemical

Operation Inventory

(MT)

Temp.

(OC)

Pressure

(kg/cm2)

Elevation

(mm) Phase

Tank volume

or Full


No.

Sulphuric

acid plant

CSA

liquid SO3

Storage

ST 6 55

40 to

42

Atmosphe

ric

900 Liquid 41

ST 7 55 900 Liquid 41

ST 10 55 900 Liquid 41

ST 102 200 0 Liquid 445

Storage

ST 12 16

38 to

40

Atmosphe

ric

7000 Liquid 11

ST 106 16 7000 Liquid 11

ST 11 0 4100

25 % Oleum Storage

ST 1 80

45 to

48

Atmosphe

ric

0 Liquid 54

ST 2 150 0 Liquid 85

ST 9 17 750 Liquid 11

65 % Oleum Storage ST 101 65 45 to

48

Atmosphe

ric

600 Liquid 41

ST 103 65 600 Liquid 41

Phosgene

Chlorine

Feeding

to

reactor

through

Chlorine

tonner

Tonner 900 kg* 5

tonner

Ambie

nt

5-8

kg/cm2

On the

ground

Liquid

& gas 1.02

Phosgene

Storage

in Tank

18-1 /

18-2 ( 2

identical

tank)

18-1 /

18-2 (

Two

identical

tank)

Maximum

1 T in each. - 16' C

Atmosphe

ric 1 meter liquid 7

Phosgene

Service

tank (3

identical

tank)

19-1 /

19-2/

19-3

(three

identical

tank)

Maximum

1 T in each. -10 ' C

1.2

kg/cm2 1 meter liquid 2

Phosgene Reactor

R-1 / R-

2 ( two

identical

reactor

in

series)

2 kg 50 ' C 0.015

kg/cm2 3 metre gas 0

Phosgene Cylinder

storage cylinder

32 kg * 20

cylinder

Ambie

nt

1.5

kg/cm2

On the

ground

Liquid

& gas

CO CO

holder Holder 40 m3

Ambie

nt

0.015

kg/cm2

2 meter

dome ht. (

holder

height is 6

meters)

gas 33

Phosgene

Line

transfer

to PHIN

/NBD

Line to

NBD

plant

5 kg 40' C 0.4

kg/cm2 5 meter gas 0

Ammonia

Feeding

to

chilling

system

Cylinder 40 kg x 5

cyls.

Ambie

nt

10

kg/cm2

On the

ground Liquid

Ammonia Chilling

system

Chilling

tank 200 KG

Ambie

nt

15

kg/cm2

On the

ground

Liquid

& gas

MDC chilling Chilling

tank 1000 kg -17' C 2 kg/cm2 1 meter Liquid 3



PAGE 316

Plant Chemical

Operation Inventory

(MT)

Temp.

(OC)

Pressure

(kg/cm2)

Elevation

(mm) Phase

Tank volume

or Full


No.

SHED C Anhydrous

ammonia Storage

C03/03/

30 10 MT

Ambie

nt

10.5

kg/cm2

In a sump 1

meter

below

ground

level

liquid 22

Epoxy Epichlorohydri

ne Storage

T-601 90 KL Ambie

nt

50 mm of

H2O with

N2

Above

ground liquid 126

T-601-A 100 KL Ambie

nt

50 mm of

H2O with

N2

Above

ground liquid 123

T-608 25 KL Below

25 ˚C.

50 mm of

H2O with

N2

Above

ground liquid 28

T-609 50 KL Below

25 ˚C.

50 mm of

H2O with

N2

Above

ground liquid 50

FDH Methanol Storage

380 KL Ambie

nt

Atmosphe

ric

Above

ground liquid 387

90 KL Ambie

nt

Atmosphe

ric

Undergrou

nd liquid

90 KL Ambie

nt

Atmosphe

ric

Undergrou

nd liquid

Table No. 6.3 – Raw Materials Consumption details

Sr.

No. Product

Quantity

Raw Material

Quantity

Existing Total after

expansion Existing

Total after

expansion

TPM TPM

DYES

1. Sulfur Black 250 833.33

2,4-DNCB 132.26 440.85

Caustic Soda lye 32% 539.94 1799.80

Sulphur 159.09 530.30

Sodium Chloride 46.82 156.08

Sodium Sulphide 30.12 100.40

Soda Ash 8.21 27.38

CHLORO – ALKALI INDUSTRY

1.

Caustic soda /

Potash & Sodium

Sulfide 3400 7500

NaCl (100%) 2592.50 5718.75

2.

Liquid Chlorine /

HCl

Barium carbonate

(100%) 26.69 58.88

Sodium Carbonate 9.86 21.75



PAGE 317

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

(100%)

HCl (100%) 30.60 67.50

NaOH(100%) 25.50 56.25

NaHSO3 (100%) 0.68 1.50

Flocculating agent 0.07 0.15

Precoat alfa cellulose 0.60 1.31

Water 6409.00 14137.50

Sulfuric acid (100%) 25.50 56.25

PESTICIDE TECHNICAL

1.

Carbamate group

of

Agrochemicals

33.3 43.3

Toluene 13.77 17.91

Sodium methoxide 0.89 1.15

Dimethyl carbonate 2.87 3.73

Indanone 1.78 2.32

HCl 1.70 2.21

NaHCO3 soln. 1.59 2.07

Cinconine 0.32 0.42

TBHP 1.23 1.60

Toluene 0.37 0.48

HCl 9.25 12.03

NaOH 1.33 1.72

Ethylene Dichloride 9.34 12.14

BCZ 0.62 0.80

PTSA 0.04 0.06

HyFlow 1.18 1.54

P2O5 1.18 1.54

Methylal 1.52 1.98

IPA 2.66 3.46

ZnBr2 0.06 0.08

Pd/C 0.04 0.06

MA 20.06 26.08

Citric acid 1.91 2.48

Caustic flakes 0.36 0.47



PAGE 318

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

H2 0.06 0.08

N2 0.03 0.04

NaHCO3 0.36 0.47

Silica 0.56 0.73

Hexane 16.71 21.73

2. Diuron 20 220

MCB 111.24 1223.60

Dichloro aniline 13.76 151.40

Phosgene 12.08 132.87

Charcoal 0.28 3.09

DMA 4.07 44.80

3.

Pyridine based

insecticides &

Herbicides

chemical

Imidacloprid

25 29.16

Sulphuric acid 12.50 14.58

Guanidine Nitrate 16.25 18.95

Nitro guanidine 45.00 52.49

EDA 32.85 38.32

HCl 200.00 233.28

KOH 125.00 145.80

2-[Nitroimino]

imidazolidine 12.71 14.82

2-chloro-5-

methylchloro-pyridine 18.65 21.75

Sodium Methoxide 10.00 11.66

DMF 28.13 32.81

4. Sulphonyl Urea 25 35.25

PCF 10.88 15.35

2-Amino-4,6

dimethoxy pyridine 10.60 14.95

Dioxane 36.09 50.89

NN Dimethyl Aniline 12.46 17.57

IPA 56.39 79.51

SNA 15.66 22.09

Acetonitrile 71.43 100.71

DBU 10.10 14.24

HCl Solution (30%) 25.06 35.34

5. Glyphosate 50 65 PMIDA 69.06 89.78



PAGE 319

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

Sodium tung state 0.21 0.27

50% H2O2 24.17 31.42

10% FeSO4 10.36 13.47

6. Isoprothiolane 8.3 18.3

Di Isopropyl Malonate 7.58 16.72

CS2 3.67 8.09

Acetone 22.35 49.27

NaOH 7.98 17.60

TBAB 0.04 0.09

Ethylene Dibromide 7.02 15.48

n-Hexane 16.84 37.13

7. Pyrazosulfurone 0 0.5

Acetonitrile 0.00 1.47

Pyrimidine carbamate 0.00 0.35

1-methyl-4-

ethoxycarbonyl

pyrazole -5-

sulfonamide

0.00 0.29

TEA 0.00 0.19

Methanol 0.00 0.59

8. Bis Pyribac

Sodium 0 0.83

THF 0.00 1.74

2,6-DHBA 0.00 0.40

4,6-DMMSP 0.00 0.81

Sodium hydride 0.00 0.34

9. Azoxystrobin 0 2.08

Toluene 0.00 6.74

DMF 0.00 0.58

CPOPMA 0.00 1.87

2-Cyanophenol 0.00 0.85

K2CO3 0.00 1.21

DABCO 0.00 0.01

Methanol 0.00 3.17

10. Quizalofop 0 1.25

Ethyl-2-(4-hydroxy

phenoxy) -propionate 0.00 0.75

2,6-dichloro

quinoxaline 0.00 0.83



PAGE 320

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

Potassium carbonate 0.00 0.56

DMF 0.00 0.76

Ethanol 0.00 0.63

11. Thiamethoxam 0 10

2-chloro-5-chloro

methyl thiazole 0.00 7.80

3-methyl-4-nitroimino

perhydro-1,3,5-

oxadiazine

0.00 7.60

Potassium hydroxide 0.00 2.00

Dimethyl carbonate 0.00 2.00

Ethanol 0.00 3.40

12. Metribuzine 0 10

4-amino-6-tertiary-

butyl-3-mercapto-

1,2,4-triazinone

0.00 10.10

98% Sulfuric acid 0.00 16.15

Methanol 0.00 2.02

48% Caustic lye 0.00 28.37

13. Diafenthiurone 0 4.17

4-phenoxy-2, 6-

diisopropyl phenyl

isothiocyanate

0.00 3.80

Tertiary butyl amine 0.00 0.89

Toluene 0.00 3.00

Hexane 0.00 7.59

RESIN

1. Epoxy Resin 2500 2600

BPA ( Solid ) 1746.76 1816.63

ECH /recovered ECH 5325.49 5538.51

CSL (48%w/w) 1250.00 1300.00

IPA 25.56 26.58

2. Polygrip rubber

based 0 300

Solvents 0.00 240.00

Chlroprine rubber 0.00 45.00

PTBP Resin 0.00 12.00

Rosin modified resin 0.00 3.00

3. Polygrip TPU

based 0 41.67

Solvents 0.00 35.42

TPU 0.00 6.25



PAGE 321

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

OTHER CHEMICALS

1. Anisole 0 166

Phenol 0.00 150.56

Di-methyl Sulfate 0.00 138.44

CS Lye (48%) 0.00 162.51

2.

1,3

Cyclohexanedion

e

0 80

Resorcinol 0.00 84.48

Caustic soda flakes 0.00 30.72

Hydrogen 0.00 1.68

Catalyst 0.00 0.74

HCl (36%) 0.00 84.48

3. Resoform P-18

0 85

Acetone 0.00 37.57

Reso - Tar 0.00 15.05

Hyflo 0.00 0.68


Formaldehyde 0.00 30.26

Powerflex Oil 0.00 0.85

4. Resoform P-19

Acetone 0.00 74.29

Reso - Tar 0.00 30.35

Hyflo 0.00 0.68


37% Formaldehyde 0.00 24.82


5. Resoform P-20

Acetone 0.00 11.39

Reso - Tar 0.00 3.83

Hyflo 0.00 0.68


Formaldehyde 0.00 20.49


Para toluene sulfonic

acid 0.00 0.17

Styrene 0.00 29.92

Ethanol 0.00 1.28

CS Lye 0.00 0.09



PAGE 322

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

6. Trans-4-MCHI

0 415

P-cresol 0.00 731.69

Ra-Ni catalyst 0.00 43.90

Hydrogen 0.00 35.26

Glacial acetic acid 0.00 543.03

Sodium hypochlorite

14.3w/w solution 0.00 3622.31

Sodium bisulphate 5%

solution 0.00 541.75

Caustic lye 48%w/w 0.00 487.01

10% Brine solution 0.00 676.72

Sodium hydroxide 0.00 485.33

Hydroxyl amine.HCl 0.00 475.03

Sodium metal 0.00 659.85

n- Butanol 0.00 9877.00

H2 (g) 0.00 6.38

30 % HCl 0.00 510.45

Acetone 0.00 5104.50

Phosgene 0.00 723.76

Toluene 0.00 1785.33

7. p-Anisyl

chloroformate

4-Methoxybenzyl

alcohol 0.00 376.41


MDC 0.00 406.29

8.

DI-TERT-

BUTYL

DICARBONAT

E (Boc.

anhydride)

Sodium-t-butoxide 0.00 755.30

Carbon dioxide gas 0.00 346.53


Ethyl acetate 0.00 4096.05

Triethyl amine 0.00 136.95

Hyflo 0.00 107.07

9.

N, N-

Disuccinimidyl

Carbonate

N- Hydroxy

Succinimide 0.00 419.15

Tribtyl Amine 0.00 778.13




PAGE 323

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

THF 0.00 4150.00

10. HX-13059 0 5

2-4 Di chloro Aniline 0.00 5.50

NaNO2 0.00 2.50

toluene 0.00 2.50

HCL 0.00 10.00

Na2SO3 0.00 10.50

H2SO4 0.00 0.50

HCl soln. 0.00 34.00

NaOH soln. 0.00 33.00

t-Butyl alcohol 0.00 29.00

HCHO 0.00 2.50

Sodium Cynate 0.00 3.50

Acetic Acid 0.00 3.00

13% Hypochlorite

Solution 0.00 17.00

NaOH flakes 0.00 2.50

HCl 0.00 13.00

Pure 4-Methyl

cyclohexyanol 0.00 8.15

Glacial acetic acid 0.00 6.54

Sodium hypochlorite

14.3 w/w solution 0.00 43.64

Sodium bisulphate 5%

solution 0.00 6.53

Caustic lye 48% w/w 0.00 5.87

10% Brine solution 0.00 8.15


Hydroxyl amine.HCl 0.00 5.72

Sodium metal 0.00 7.95

n- Butanol 0.00 119.00

H2 (g) 0.00 0.08

30 % HCl 0.00 6.15

Acetone 0.00 61.50



PAGE 324

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

Phosgene 0.00 8.72

Toluene 0.00 21.51

FLAVORS & FRAGRANCES

1. Anethole 0 166.66

Anisole 0.00 173.33

Propionyl chloride 0.00 167.16

AlCl3 0.00 223.32

EDC 0.00 331.99

13% NaCl 0.00 277.82

10% NaHCO3 0.00 127.33

Rainey Ni 0.00 5.15

TEA 0.00 0.51

Methanol 0.00 208.33

H2 (g) 0.00 2.86

KHSO4 0.00 2.08

Paraffin oil 0.00 9.13

2. Avobenzone 0 83.33

4-t-butylbenzoicacid 0.00 82.81

Methanol 0.00 74.63

98% H2SO4 0.00 10.14

5% Na2CO3 0.00 33.12

4-

methoxyacetophenone 0.00 60.88

Sodium methoxide 0.00 26.84

Toluene 0.00 460.09


10% H2SO4 0.00 272.71

3. Raspberry

Ketone 0 100

p-cresol 0.00 129.22

NaOH (flaks) 0.00 167.00


Cobalt acetate 0.00 1.99

Copper oxide 0.00 0.48

Oxygen 0.00 49.70

Acetone 0.00 119.28



PAGE 325

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

30% HCl 0.00 273.36

Ra-Ni (1961) 0.00 1.29

Hydrogen 0.00 2.98

Triethyl amine 0.00 1.57

Divyol oil 0.00 4.97

4. P-Anisyl

Propanal 0 100

p-Anisic aldehyde 0.00 179.00

Propanaldehyde 0.00 51.00



Sulfuric acid 0.00 1.32

sodium bicarbonate 0.00 2.20

Sodium carbonate 0.00 2.22

Toluene 0.00 150.00

5% Palladium Carbon 0.00 1.43

Divyol Oil 0.00 2.20

BHT 0.00 0.35

H2 (g) 0.00 1.11

5. Octacrylene 0 83.33

Cyanoacetic acid 0.00 32.92

2 - Ethyl hexanol 0.00 56.50

p - Toluenesulfonic

acid 0.00 1.08

Benzophenone 0.00 101.50

Acetic acid 0.00 71.08

Ammonium acetate 0.00 20.58

Cyclohexane 0.00 57.08


NaCl 0.00 7.08

Darco 0.00 7.17

Hyflowsupper cell 0.00 1.92

Anhyd. Na2SO4 0.00 1.92

6. Octyl Methoxy

Cinnamate 0 200

p-Anisaldehyde 0.00 118.60

Ethyl acetate 0.00 436.00



PAGE 326

Sr.

No. Product

Quantity

Raw Material

Quantity


expansion Existing

Total after

expansion

TPM TPM

Ethyl hexanol 0.00 135.00

Sodium methoxide

powder 0.00 60.40

Sodium methoxide

solution 0.00 22.80

Phosphoric acid 0.00 4.50

Formic acid 0.00 1.30

Divyol 460 0.00 21.60

Darco 0.00 2.60

Hyflo supercell 0.00 1.10

Table No. 6.4 – Products details

Sr.

No. Product

Capacity (TPM)

Existing Proposed Total

A. DYES

1. Azo dyes 550.00 0.00 550.00

2. Sulfur Black 250.00 583.33 833.33

3. Sulfur Dyes Range 25.00 0.00 25.00

4. Napthol Range 75.00 0.00 75.00

5. Fast Color Bases 40.00 0.00 40.00

6. Disperse Dyes (Atul-East) + Disperse Dyes (Atul-West) 118.50 0.00 118.50

7. Optical Brighteners 10.00 0.00 10.00

8. Reactive Dyes 127.30 0.00 127.30

9. Vat dyes 105.00 --- 105.00

Total Production Capacity of Dyes 1,300.80 583.33 1,884.13

B. CHLORO – ALKALI INDUSTRY

10. Caustic soda / Potash & Sodium Sulfide 1,800.00 2,200.00 4,000.00

11. Liquid Chlorine / HCl 1,600.00 1,900.00 3,500.00

Total Production Capacity of Chloro – Alkali Industry 3,400.00 4,100.00 7,500.00

C. PESTICIDE TECHNICAL

12. Carbamate group of Agrochemicals 33.3 10 43.3

13. Diuron 20 200 220



PAGE 327

Sr.

No. Product

Capacity (TPM)


14. Isoproturon 8.30 -8.30 0.00

15. Metoxuron 8.30 -8.30 0.00

16. Trichlo Carbon 8.30 0.00 8.30

17. Cartap. HCl 50.00 0.00 50.00

18. Carbendazim 20.90 0.00 20.90

19. Herbicides

1,670.00 0.00 1,670.00 (2,4 – D & related products)

20. Pyridine based insecticides & Herbicides chemical

Imidacloprid 25.00 4.16 29.16

21. Triazole based Fungiside 1.67 0.00 1.67

22. Pyrethroides 10.00 0.00 10.00

23. Sulphonyl Urea 25.00 10.25 35.25

24. MCPA 500.00 0.00 500.00

25. Glyphosate 50.00 15.00 65.00

26. Isoprothiolane 8.30 10.00 18.30

27. Fipronil 5.00 0.00 5.00

28. Formulation 200.00 0.00 200.00

29. Pyrazosulfurone 0.00 0.50 0.50

30. BisPyribac Sodium 0.00 0.83 0.83

31. Azoxystrobin 0.00 2.08 2.08

32. Quizalofop 0.00 1.25 1.25

33. Thiamethoxam 0.00 10.00 10.00

34. Metribuzine 0.00 10.00 10.00

35. Diafenthiurone 0.00 4.17 4.17

Total Production Capacity of Pesticide Technical 2,644.07 261.64 2,905.71

D. BULK DRUGS & PHARMACEUTICALS

36. Mabendazole 2.00 0.00 2.00

37. Tolbutamide 2.50 0.00 2.50

38. Quiniodochlor 15.00 0.00 15.00

39. Bulk drugs & intermediates 9.60 0.00 9.60

40. Diclofenac Sodium / Potassium 2.50 0.00 2.50

41. Atenolol 1.70 0.00 1.70

42. Fresamide 1.30 0.00 1.30

43. Trimethoprim 0.90 0.00 0.90



PAGE 328

Sr.

No. Product

Capacity (TPM)


44. Para Hydroxyacetophenone 1.70 0.00 1.70

45. Para Hydroxy Phenyl acetamide 3.00 0.00 3.00

46. Acyclovir 5.20 0.00 5.20

47. Bathenechol 5.20 0.00 5.20

48. Pharma Intermediates and chemicals 300.00 0.00 300.00

Total Production Capacity of Bulk Drugs &

Pharmaceuticals 350.60 0.00 350.60

E. RESIN

49. Epoxy Resin 2,500.00 100.00 2,600.00

50. Vinyl Ester Resins 37.50 0.00 37.50

51. Ketone Formaldehyde Resins &Sulphonamide,

Formaldehyde Resins 20.80 0.00 20.80

52. UF/MF/PF/ Di Cyanadiamide Resins 270.90 0.00 270.90

53. Polyamide Resins 161.70 0.00 161.70

54. Polygrip rubber based 0.00 300.00 300.00

55. Polygrip TPU based 0.00 41.67 41.67

Total Production Capacity of Resin 2,990.90 441.67 3,432.57

F. OTHER CHEMICALS

56. Anthraquinone, Naphthalene, Benzene Intermediates.

(including Beta – Napthol& BON Acid 740.00 0.00 740.00

57. M Hydroxy Phenol 460.00 0.00 460.00

58. Anisole 0.00 166.00 166.00

59. 1,3 Cyclohexanedione 0.00 80.00 80.00

60. Resoform P-18

0.00 85.00 85.00 61. Resoform P-19

62. Resoform P-20

63. Carbamite 30.00 0.00 30.00

64. Chlorzoxazone& other related products 5.00 0.00 5.00

65.

Agro, Pharma intermediates, Isocyanats& Carbonate

esters, chloroformats etc. 100.00

315.00 415.00 Trans-4-MCHI

---- p-Anisylchloroformate

DI-TERT-BUTYL DICARBONATE (Boc. anhydride)

N, N- Disuccinimidyl Carbonate



PAGE 329

Sr.

No. Product

Capacity (TPM)


66. HX-13059 0.00 5.00 5.00

67. 4 Ethyl 2,3 – Diocopiperazino carbonyl chloride 3.30 0.00 3.30

68. IminoDibenzyl 5 Carbonyl Chloride 0.80 0.00 0.80

69. Other chemicals (DCP, MCA, MEA, DEA, PCl3, PAA,

MAP etc.) 425.00 0.00 425.00

70. Formaldehyde and base products 3200.00 0.00 3200.00

71. Sulfuric acid / Oleum / Chlorosulphonic acid & salts 11,550.00 0.00 11,550.00

72. Sulpha drug intermediates 193.80 0.00 193.80

73. Acetyl Sulphanilyl Chloride & its derivatives 1,500.00 0.00 1,500.00

74. Acetanilide 500.00 0.00 500.00

75. Sulpha Methyl Phenazole Sodium 1.10 0.00 1.10

76. Pyrazole Base 10.50 0.00 10.50

77. Sulphanilic acid 25.00 0.00 25.00

78. Bis Phenol A 416.70 0.00 416.70

79. Hexamine 150.00 0.00 150.00

80. Epoxy Intermediates 23.80 0.00 23.80

81. Hardener & Auxiliaries 500.00 0.00 500.00

82. Hardener & Intermediates 700.00 0.00 700.00

83. Bisphenol S & Intermediate Chemicals 16.60 0.00 16.60

Total Production Capacity of Other Chemicals 20,551.60 651.00 21,202.60

G. FLAVORS & FRAGRANCES

84. Anethole 0.00 166.66 166.66

85. Avobenzone 0.00 83.33 83.33

86. Raspberry Ketone 0.00 100.00 100.00

87. P-AnisylPropanal 0.00 100.00 100.00

88. Octacrylene 0.00 83.33 83.33

89. OctylMethoxyCinnamate 0.00 200.00 200.00

Total Production Capacity of Flavors & Fragrances 0.00 733.32 733.32

Grand Total 31,237.96 6,770.95 38,008.91



PAGE 330

6.10 SAFETY MEASURES

It is practically impossible to reduce the risk to zero. However, effective measures can certainly reduce

the risk considerably. The safety measures intends to reduce the risk related to various hazards present at

the work place.

The details of various safety measures to be considered by Atul Ltd. at various stages of project are as

detailed below:

6.10.1 Process safety measures

The following Safety measures have been adopted from the design stage itself.

Provision of Safety Valve and pressure gauge on reactor and its jacket.

Availability of utilities like Chilling water, chilled Brine, Nitrogen, cooling water, vacuum lines,

steam supply and its alternatives to control reaction parameters and avoid undesired reactions,

are/shall be made available.

Provision of Static earthing at design stage to all solvent handling equipment, reactors, vessels &

powder handling equipment.

Appropriate Earthing to all the vessels and equipment and protection against Static Electricity.

Also provision of proper earthing facilities for draining in drums.

Easy access to all emergency valves and switches and emergency handling facilities.

No free fall of any flammable material in the vessel.

Safe distance between all solvents and flammable material storage tanks and the process plant.

Provision of PPEs to all the employees to protect against any adverse health effect during

operations, leakage, spillages or splash.

Provision of PPE like Helmets, Safety Shoes, Safety Glasses, Acid-Alkali Proof Gloves etc. to the

employees.

Availability of Material Safety Data Sheets of Raw Materials & Products on the shop floor.

Provision of Flame arrestor for solvent wherever required for solvent storage and handling.



PAGE 331

6.10.2 Safety measures to be considered during transportation of raw materials

Transportation of raw materials in drums on pallets (through trucks) for liquid raw materials and

solvents.

Provision of static earthing for tanker unloading.

Use of only earthed flexible steel hose for solvent unloading from the road tanker.

Provision of fixed pipelines with pumps for solvent transfer up to day tanks/reactors.

Installation of Double mechanical seal type pumps.

Provision of NRV on all pump discharge line.

Control Measures for Sulfuric Acid (H2SO4)

Sr.

No. Process/ Activity

Hazard

involved Risk Control Measures

1.

Transportation of

Sulfuric acid in

the road tanker

Road Accident

and leakage of

sulfuric acid

Exposure to

sulfuric

vapors and

harm to

human

beings,

general public

and animals

Air pollution

The Sulfuric acid to be transported in

the special containers with a

competent driver.

The transport route to be preplanned

to avoid accidents and transported in

the less populated areas.

2.

Unloading of

Sulfuric acid from

road taker

Leakages of

sulfuric acid

during

Transfer –

unloading

using hose

Exposure to

sulfuric acid

vapors and

harm to

workers/

employees

Air pollution

The unloading is to be done under

nitrogen pressure with a suitable

high pressure hose.

The unloading crew has to be

competent and with proper training.

USE of required PPE to be done

while unloading.

3.

Storage of

Sulfuric acid in

the designated

area

Risk due to

leakage and

over

pressurization,

Safety valve

gets operated

Exposure to

sulfuric acid

vapors and

harm to

workers/

employees

Air pollution

The concentration of the acid to be

marinated above 90 % all the time as

the dilute is corrosive to the ordinary

Mild steel tank

Corrosion monitoring of the tank

(Thickness testing) to be done

periodically.

4. Rupture of

Sulfuric acid line

Heavy leakage

of sulfuric acid

Injury and

Health effect

Maintain acid concentration above

90% all the time.



PAGE 332

Sr.

No. Process/ Activity

Hazard

involved Risk Control Measures

on the

employees/wo

rkers and

nearby

surroundings

The acid lines to inspect regularly.

Corrosion proof MOC should be

selected e.g. HDPE pipe line instead

of MS line.

5.

Reactive with

oxidizing agents,

reducing agents,

combustible

materials, organic

materials,

Unwanted

reactions

Can result in

fire, Injury to

employees

and

surrounding

people

Operational control to be exercised

to avoid mixing of acid with other

agents like wood, paper cloth to be

avoided.

Training of the operating staff to be

given

Safety Measures for Hydrogen

Brief description of the safety measures taken for Hydrogen storage

Preventive inspection and maintenance

Flame proof electrical appliances, tools.

Earthing strip to be provided at entry to discharge electrostatic charge.

Earthing have to be provided form both sides of the trucks during filling & being followed.

Hydrogen sensors with alarm for immediate detection provided on all hydrogen compressor.

Jumpers provided on all the flange joints.

Storage system - approved by CCE.

Brief description of the safety measures taken for Hydrogen gas pipe line

Use of schedule 40, CS seamless pipeline;

Pipeline is to be laid above ground on firm & fixed supports, except at road crossing.

Pipeline is to be protected against overpressure by two stage Pressure Reducing Valves and

Pressure Control Valve.

Control valve is to be connected with the most advanced Distributed Control System, which can

stop hydrogen supply immediately from control room.

Pipe-line is to be duly hydro-tested at 1.5 times the operating pressure.



PAGE 333

Fixed schedule for the regular inspection and maintenance of this piping.

6.10.3 Systems for Fire Fighting

The risk to people after a fire has started largely depends on the adequacy and maintenance of means to

escape, the alarm system, training of the workforce in fire routine and evacuation procedures. At Atul

Ltd., the company has proposed to employ well-resourced and adequate fire fighting network.

Details regarding the fire fighting capacity of the unit are given below:

Table No. 6.5 – Fire Fighting Details

Type of Fire

Extinguishers

Number of

Fire

extinguishers

Fire

water

Reservoir

Capacity

Fire

pump

capacity

Hydrant

Pressure

Details

Deluge valve

arrangements

Foam type

and

quantity

Other relevant

details

1) CO2

2) ABC

3) Foam

4) Water CO2

145 45000 m3

275

m3/hr

7Kg/m2 04

Mechanical

Foam

Concentrate

200 lit

Fire hydrant

system covering

Raw material

storage, fuel &

finish good

storage area



PAGE 334

Figure No. 6.49 – Fire Hydrant Layout



PAGE 335

Figure No. 6.50 – Photographs of Onsite Mock Drill & Fire Fighting Training

Fire Tender Onsite Mock Drill

Fire Fighting Training

6.10.4 Additional firefighting measures for proposed expansion

Safety Sirens with Alarm System in case of emergency shall be provided.

Emergency Control Room shall be established.

Assembly points shall be identified.

First Aid Facility and training shall be provided for the proposed project.

Personal protective gears and equipment shall be provided for the proposed project.

Health checkups shall be organized at regular intervals.



PAGE 336

Safety Training shall be provided to the employees.

Sprinkler Systems shall be provided as and when needed.

Mock drills shall be periodically conducted and factors like response time shall be evaluated.

Fire squad team shall be formed for handling any emergency situation.

Fire Hydrant System shall be installed which shall be used for the proposed project.

Fire Extinguishers shall be provided.

6.10.5 Other safety measures to be employed during the Proposed Project

To maintain high standards in Health, Safety and Environment, various activities shall be undertaken at

the site.

The following key safety measures shall be a part of the proposed project to be implemented by the

proponent:

A. Personnel Safety Measures

Safety Training shall be regularly provided to the employees.

Safety Sirens with Alarm System in case of emergency shall be provided.

Emergency Control Room shall be established.

Assembly point shall be predetermined and provided as per the requirement.

Sprinkler Systems shall be provided as per the need.

Fire Hydrant System shall be installed.

Fire Extinguishers are also proposed to be provided.

Mock drills shall be periodically conducted and factors like response time to be evaluated.

Fire squad team shall be formed for handling any emergency situation.

First Aid Facility and training shall be regularly provided.

Personal protective gears and equipments shall be provided to the employees.



PAGE 337

Health checkups shall be organized at regular intervals.

Safety / Health records and MSDS shall be maintained.

B. Noise Environment

Use of PPE like ear plugs and ear muffs shall be made compulsory near the high noise generating

machines.

Moreover, the personnel shall be provided breaks in their working hours with the continuous

exposure not increasing more than three (3) hours.

The plant and equipments are designed with a view to minimize noise pollution.

To reduce noise, pipe lines shall be liberally sized for low velocities.

Safety blow off valves, discharge pipes, relief valves, etc. shall be equipped with silencers.

Hearing Conservation program shall be imparted where noise level exceeds 90 dB (A).



PAGE 338

PART 02 – DISASTER MANAGEMENT PLAN



PAGE 339

6.11 ON SITE EMERGENCY PLAN

Safety Health & Environment Dept. Page 25

YEAR – 2015

(Revised on 31/012/2015)

ATUL LIMITED

P.O. ATUL - 396 020

GUJARAT

INDIA.


ATUL LIMITED P.O.

ATUL – 396 020

ON SITE EMERGENCY PLAN

I N D E X

Section I: PROCEDURES

SUBJECT

Sr. No. Particulars

1 Purpose

2 Types of Emergency

3 Control Room

4 Risk and Environmental Impact Assessment

5 Organization for tackling emergency

6 Emergency Alarm System

7 Telephone communication guideline

8 Safe shut down procedure

9 Emergency Alarm system

10 Declaration of major emergency

11 Communication in case of major emergency

12 Mutual aid

13 General

14 Accident investigation & reporting

15 Public relations

16 Plant relations

17 Personnel Protective Equipment / Emergency equipment

18 Safety devices

19 Revision & up dating

20 Mock drills & training – Enclosures


1. PURPOSE:

This plan is prepared to cope up with any emergency, which could occur during

operation. The purpose of this plan is to protect the employees, people residing

in the neighboring areas, the company’s properties and environment to the

maximum possible extent in the event of fire, explosion, toxic spillage’s / releases

due to our own operations, or operations of neighboring companies or natural

calamities like flood, cyclone earthquake etc.

2. TYPES OF EMERGENCIES:

FIRE:

In ATUL– East Site flammable solvents, gases and substances are stored used in

various operations. These substances can catch fire by source of ignitions like

sparks, static electricity, welding and cutting operations, chemical reactions,

electrical short circuits, smoking in non smoking area etc. if air / oxygen /oxidizing

agents also available.

EXPLOSION:

Explosion can result from uncontrolled rate of chemical reaction. overheating or due

to mixture of air with solvent vapors, flammable gases. or flammable dust.

TOXIC SPILLS / RELEASE

Bursting of drums, damage to storage vessels / measuring vessels over

pressurization leading to failure of rupture disc or opening of safety valves or wrong

operation or malfunctioning of valves etc. may result into a toxic spill or release of

toxic gas.

INJURY TO PERSONNEL :

Hazards of unsafe actions or condition caused by poor housekeeping may result into

minor major physical injury. The splashes of chemicals, release of gases may also

cause injury to personnel working in the nearby.


1. Damage 1. Stringent

2. 2. Pressure

system on

of

3.

3. Provision

and

4. Hydrant

Fog nozzles,

curtains

5.

1. Unsafe

2. Violation

1.

2.

1. Good

2. Training

Types of

Accident

System Elements or Events

that can lead to major

Accidents

Hazards

Safety Relevant

Components

System

Elements Events

Fire Solvents

1. Electrical

Short Circuit

1. Damage

to Property

1. Use of flameproof

fittings, frequent

checking of earthing

and wiring etc.

Flammable 2. Lighting 2. Human

Injury

2. Regular

Maintenance

Schedule

3. Lighting arrestors

with

proper earthing

Fuel & Lub.

Oil

3. Hot Work 4. Work Permit System

Explosion

Light Waste 4. Smoking 5. No Smoking area is

defined.

Human

Injury

Working of

height

Procedure

or

temporary disablement

3. Provision of PPEs as

required.

3. Control Room

SHE Office phone 5265 / 5246 shall be converted into a Control Room for any

emergency and the Site Main Controller according to situation shall operate from this

place. If situation demands then Occupier / Directors office phone 5800 shall be

converted in to a Control Room.


4. Risk Environmental Impact Assessment

Risk in Atul can broadly be divided in two categories

Risk of leakage – spillage of toxic Chemical

Risk of Fire Toxic Chemical Risk

PODUCT LOCATION AVERAGE STORAGE

TONS

Ammonia NI FCB Tank form (East) Shed H,

Near RM stores (West)

20 (1 Storage tanks)

Aquious Ammonia

Sol.

Chlorosulphonic acid

Near Pharma Plant (PP) Sulphuric

Acid Tank Farm (East) Shed D

(West)



Sulphuric acid 98% Sulphuric Acid Tank Farm (East)

Shed A, B, C, H, J, K, N (West)

Pharma Tank Farm (PP)


65% Oleum Sulphuric Acid Tank Farm (East)

Shed C, H, J, N (West)


25% Oleum Sulphuric Acid Tank Farm (East)

Shed A, B, C, H, J, K (West)


Sulfur Trioxide Sulphuric Acid Tank Farm (East) 10 (2-Storage tanks)

Phenol 98% PH1, PH II (East) Shed N (West)

Bisphenol Plant (PP)


Chlorine Caustic soda plant (East)

Shed G (West)

40 (3 Storage tanks) &

tonners

Phosgene,

Dimethyl Sulphate

Phosgene plant (East), Near

Pharma Plant (PP), Shed-N (

West), Pharma tank farm

(PP)

1(2 Storage tanks)

Drum

Fire Risk

PODUCT LOCATION AVERAGE STORAGE

TONS

Benzene Polyester Plant (East) Shed F

(West)


Methanol

FCB & Polyester Plant (East) Shed

A, N (West) Pharma plant (PP)


Toluene FCB Plant (East) Shed F (West)

pharma & PHIN plant (PP)

50 ( 3 Storage tanks)

Ethanol Polyester Plant (East) Shed B

(West)



Haxane Epi

Chlorohydrine Xylene

Pharma & PHIN plant (PP)

Epoxy tank farm (PP)

Pharma tank farm (PP)


7 (2 Storage tanks)




N.B. : The fire extinguishing facilities are installed and provided as per tariff advisory

committee and people are trained these facilities.

Environment Impact Assessment is given in Annexure 12

5. ORGANISATION FOR TACKLING EMERGENCY :

During normal working hours and except on holidays, the Site Main Controllers,

Incident Controllers, Deputy Incident Controllers, key personnel, essential workers,

Security Officer, Fire officer and Safety Officer are available at factory premises. On

hearing the emergency siren they will start emergency procedure as laid down in the

following part. After normal working hours and on holidays Security Officer, Fire

Officer, Safety Officer, Incident Controllers/Deputy incident Controllers (See

annexure 14,15,33) site main controllers (see Annexure 18) will be called to

attend emergency by shift chemist with the help of Security personnel. Duty schedule

of incident controllers for any day is available at Security office / Control Room.

Organogram for Plant Emergency Response

Site Incident Controller / Shift

In - Charge

Safety Officer

(On Call) Shift Chemist /

Engineer

Fire & Security

Services (On Call)

Assembly Point

In-Charge

First-aid Medical

Centre (On Call)

Duties of persons responsible for combating Emergency

4.1 Site Incident Controller / Shift In-Charge : (See annexure 16 & 33)


1. Raise the emergency alarm, if it is not already sounding.

2. Arrange to secure all ignition sources.

3. Assign specific duties to the staff / workmen n to bring the critical of the

emergency.

4. Assess the severity of the incident and the likely extent of the emergency.

5. Determine actions necessary to overcome the course of the incident and linit

the extent of its effects.

6. Advise plant personnel on how to combat the emergency with due care for

personal safety.

7. Provide guidance to fire fighting personnel on –

• Type of fire extinguishers, and

• Type of personal protective to be used

8. Ask for evacuation of the plant, if necessary.

9. Nominate someone to act as Assembly Point In-Charge and to obtain head

count.

10. Provide information to and seek guidance from the safety Officer and

Departmental Heads on their arrival.

11. Along with Plant In-Charge, Safety Officer and Manufacturing Head decide

whether nearby Plants are likely to be affected and whether on-site

emergency should be declared or not.

Once the emergency is attended to and the incident is under control, arrange to

give all clear siren.

4.2 Safety Officer.

1. On hearing Siren, reach the incident site immediately.

2. Find out about the type emergency, whether it is due to toxic gas leak, fire or

explosion.

3. Provide advice on use of appropriate personal protective equipment by personnel

assigned to tackle the emergency.

4. Check wind direction and inform the nearby Plants.

5. Guide the Security staff for cordoning off affected area, if such isolation is required

. Send persons for medical treatment, if required.

6. Depending on the severity, take joint decision with the Site Indent Controller

whether senior management should be alerted and whether Main Centre Controller

should be called.


4.3 Shift Chemical / Engineer.

1. On hearing siren receiving message on telephone proceed th the incident site

immediately.

2. Assist the Site Incident Controller.

3. Make arrangement to obtain help and resources (men, materials and machinery)

from other Plants, if necessary

4. If plant evacuation is necessary then after shutting sown plant to safe condition,

ask he plant personnel to proceed to assembly point. Nominate someone as

assembly point In charge to take attendance and receive further instructions.

4.4 Fire & Security Personnel:

1. On hearing siren reach the incident site immediately.

2. Seek information from Shift Chemist / Safety Officer about the nature of the

emergency and precaution to be taken in tacking the emergency.

3. Ensure use of proper personal protective equipment while operating in dangerous

area or zone.

4. Limit use of fire hydrant to permissible areas only.

5. Help to cordon the are of incident and do not allow any unauthorised persons to

go near the affected area.

6. If required carry our search an rescue operation the control of Fire Officer / Shift

Chemist.

4.5 Trained / Experiences worker :

He will start combating emergency and call for help if emergency is in area.

Otherwise he shall give charge of his work to the supervisor and go to the site of

emergency and help in combating emergency. Each plant will nominate at least one

such worker per shift.

4.6 Assembly – point In-charge :

1. As soon as the siren is heard, take charge of the assembly point nearest to the

plant giving due consideration to the wind direction and severity of fumes or fire

in the plant (as seen from outside)

2. Take head count in case shed evacuation is ordered. Record the names and

identity of persons reaching the assembly point.

3. Communicate the data to the Site Incident Controller and Safety Officer

(highlight the names of persons who may be missing).

4. Check and record if any one is injured or affected by chemicals.

5. Send affected persons to the First-aid Centre or Atul Medical Centre, as required.

6. Inform the Medical Centre the name of chemical causing the emergency.


4.7 First-aid Centre :

1. The male nurse provide first-aid treatment to any casualties sent from the plant.

2. The male nurse or Ambulance attendant will liaise with Transport Section for

transporting the victims from the incident site to Atul Medical Centre.

4.8 Atul Medical Centre :

1. On hearing the siren for on-site emergency, the Doctor on duty should come to

the Atul Medical Centre immediately to treatment casualties, if any.

If any required, the Doctor must inform the Civil Hospital, Valsad or other hospital

in Valsad. asking for readiness to handle casualties, giving information on nature of

injuries, chemicals involved and number of affected persons who may be referred.

4.9 Duties & Responsibilities : (Annexure 14 to 18)

The person is assigned with the duties under this plant. Any person failing to perform

his duties shall be properly dealt with.

4.10 Emergency Alarm System

Though out factory area of Atul Limited switches are installed and housed in a small

box with glass cover / push buttons. (See annexure 26.)

In case fire / accident / emergency the glass of housing should be broken with

hammer provided or by passing electric push button switches. The fire siren will be

actuated automatically. There will be audio visual indication of location at

respective fire stations of Atul.


5. Telephone Communication Guide Line

KEY PERSONNEL OF THE ORGANIZATION WHO WILL ASSUME RESPONSIBILITIES IN CASE OF AN EMERGENCY:

INCIDENT CONTROLLERS

Concern divisional GM (Mfg) will act as Incident Controller. He will be responsible for physically tackling the emergency at site. He will judge

the situation and brief SMC (Site Main Controller) to take decision for on-site emergency. Division wise list of Incident Controller and their

alternatives are as under

In absence of incident controller alternative incident controller will take charge of incident controller. In normal case, second incident

controller (Runner) will remain available for helping incident controller to control the emergency.

If both the persons i.e. incident controller and alternative (Deputy) incident controller are not available in campus, they have to ensure that

second incident controller is available in campus / colony area on call, to act as incident controller.

Sr.

No.

Incident controller's Runners

Name in

priority

order

Designation Division Place of availability Phone No. Name &

Designation

Place of

availability

Phone No.

In the

factory

Residence

address

In the

factory

Residence

1 2 3 4 5 6 7 8 9 10 11

1 Mr. Parag Shah

GM-Mfg BI East Site/BI

Office

Down

Colony

5645 Dr. D. V. Doshi Old Reso

Plant Office

5119

233170(P&T)

2 Mr. R. K. Arora GM-Mfg Color West Site Down

Colony

4215 234310 Mr. H. S.

Prajapati

Maint. Office

West Site

4255/6484

233228(P&T)

3 Mr.

Ravishankar

Sharma

GM-Mfg PI North Site Wyeth

Colony

3446 230194 Dr. H. A. Naik North Site

Admin Bldg

3502/6212

233816(P&T)

4 Mr. N. S. Daga GM-Mfg PO North Site O type

colony

3880 7485/2334

48

Mr. H. R. Patel Office of

Epoxy Plant

3454/6221

233087

5 Mr. Sujoy M GM-Mfg CP Production

Office/East

Down

Colony

5572/

2265

7055 Mr. Nilesh

Doshi

Engineering

Office-CP

5283/7425

234267

6 Mr. S. J.

Hansoti

G.M. Infra Production

Office/East

Down

Colony

5334 7031/

233389

P&T

Mr. Dipak C.

Patel

Power Plant

Office – East

5317/

230388


DEPUTY INCIDENT CONTROLLERS

Sr.

No.

Division Name & Designation Place of availability Contact No.

1. BI Mr. Ashish Gandhi TE Office 9824106258

2. COLOR Mr. Vrajesh Parikh TE Office 4245/9824136657

3. PI Mr. H R Patel TE Office 4278

9925149538

4. PO Mr. M. R. Simpi TE Office 4471/9723551353

5. CP Mr. Prashant Sonawane TE Office

6. IN Dr. D. V. Doshi TE Office 9924143624


6. Safe shut down procedure : (In Process Plants)

When it becomes necessary to evacuate the plant due to emergency arising out of

fire, explosion or toxic leakage the following procedure should be adopted in normal

cases. The instruction from site main controller / incident shall be final.

i Stop addition / charging of any material to reaction vessel.

ii Start cooling if heating process is going on.

iii Stop stirrer if setting of reaction mass is not likely to jam agitator.

iv Stop all the processes e.g. filtration, centrifuging, drying, grinding, packing etc.

v Services required for scrubbing system should not be stopped.

7. Fire :

a) The person noticing the emergency should the alarm from the nearest fire alarm

switch. He shouts for help calling ‘Fire-Fire’ and workmen working in the affected

area who are trained in fire fighting immediately start combating the fire, with fire

extinguishers.

b) Shift chemist should rush to the site and take charge emergency operation and

should arrange to inform Fire/ Security and he should instruct workmen for shut

down procedure in the nearby area.

c) Other workmen of the section also the persons who are combating emergency by

bringing firef ighting equipment, removing flammable combustible material from

nearby area clearing the passage for firef ighting personnel, under instructions of

shift chemist.

d) Fire / Security Officer & Fireman :

They rush to the emergency with fire tender and help combating fire.

e) One of the Firemen immediately rushes to the fire pump room and starts the fire

pump and wait there for further instruction.

f) Security Officer/main gate Watchman informs Safety Officer Incident Controllers

and site Main Controller according to duty / Schedule given, regarding emergency.

g) The watchman at the main gate shall direct any outs ide person e.g. members of

mutual aid team, representative of govt. From d i s t r i c t au tho r i t i e s o r a

press representative, to the SHE office.

7.2 Toxic spill or leakage of Gas / Hazardous material

a) Workmen in the area will take actions for containing and stopping the spill, by

wearing required PPE’s.

b) The shift chemist will rush to the spot taking precautions and arrange for doing

the following as per need:


c) In case of exposure to gas move the victim to fresh air and provide artificial

respiration or in case of burns due to hazardous material give immediate water

shower to affected person and send them for medical treatment ambulance.

Note: In case shift chemist find spill is major (that cannot be managed by the

Department alone) he should sound the fire alarm to seek the help from Fire /

Security and other services as Per procedure No. 8.1

7.3 Injury:

a) Workman at the site help the injured person to go into open area and take him

to the Ambulance Room for first aid, by Ambulance.

b) Male nurse at ambulance room arranges to send the injures person to Atul

Medical centre or company’s Doctor.

c) As advised by doctor, the injured person is taken to Valsad or Pardi Hospital.

d) Responsible man is deputed by Plant Manager or Factory Manager to accompany

the injured person along with company’s Medical Officer’s report when sending to

Valsad or Pardi Hospital.

8. Declaration of Major Emergency (see Annexure 29)

The persons on emergency duty along with concerned G. M. Mfg. / Plant Incharge in

consultation with Safety Manager decide about the gravity of the situation and inform

the

control room to declare on site emergency. In this case continuous is sounded for 4

minutes.

8.1 Declaration of off site Emergency:

If nearby colonies / villages required then off site emergency is declared by sounding

10 minutes continuous siren of all 3 companies. In case of off site emergency

separate procedure ACDCP (Atul Complex Disaster Control Plan) is when and that

document must be used.

8.2 Giving all clear signal :

After the Emergency is brought under control G.M. MFG. / Occupier / Factory

Manager will decided and give instructions for all clear siren (i.e. One minute

continuous siren0


9. Communication in case of major Emergency

On declaration of major emergency, the Atul complex Disaster Control Plant becomes

operative. The GM Corporate-SHE/Factory Manager who are members of the Main

Control sub Committee of ACDCP will inform the following persons about the disaster

and ask for help to combat the situation. They remain in touch with Director /

Occupier for guidance if needed.

Name Designation Telephone No. Represent

District Collector, Valsad Chairman D.C.C. of

ACDCP

O-0263-253613, Government

Occupier / Director, Atul

Ltd.

Vice Chairman DCC of

ACDCP

O-233261,R-

233241

Atul Ltd.

Dy. Director ISH Valsad Secretary DCC of

ACDCP, Valsad

O-253612, Government

District Supdt. of Police,

Valsad

Chairman P&G Sub

Committee of ACDCP

O-254222, Government

Atul Police Station, Atul 233515 Government

Atul Gram Panchayat, Atul O-234562 Government

G.P.C.B. Vapi Regional Office O-0260-2432089 Government

D.C.C. = Disaster Control Committee, P & G :

The District Collector Valsad shall arrange help from Valsad Municipality, Zilla

Panchayat, and other Government and non-Government Organizations. The District

authorities shall inform nearby villages for evacuation and / or other measures in case

of emergency arose.

10. Mutual Aid

We have arrangements with the neighboring sites situated in the campus namely Atul

– (East, PP Site & West Site), to help each other in case of any emergency. The

transport facilities, fire fighting facilities/ equipment, personal protective equipment

and other emergency equipment is available for mutual aid. (See annexure 21, 23 &

25)

11. General

11.1 Shift Chemist Control the people of their section ensure that people who are trained

in the fire fighting and first aid are relieved to go to the spot of emergency.

11.2 Incident controller, safety Officer and Fire / Security Officer shall check the spot

after fire is extinguished (or emergency is over) and declare the area safe for


cleaning or putting back to operation and blow siren for all clear. This all clear

SIGNAL is continuous siren for 1 minute.

12. Accident investigation and Reporting*

Every accident that has resulted in personal injury, likely danger to human life or

property damage shall b investigated thoroughly departmentally.

Departmental head may take help of safety Department and / or other experts from

outside for the investigation. A report shall be mode indicating the root cause of the

incident and proposed remedial measures.

12.1Preliminary written report from Department Manager is sent to safety, Health and

Environment Department, Director, Vice President and GM mfg. within 24 hours (even

if oral information is given) after the incident. This is being discussed in safety

committee meeting.

12.2 Factory manger will inform the Factory inspector and / or other Government

authorities as required.

13. Public Relation

The occurrence of a serious disaster in only factory would be a matter of public

interest. Misunderstanding of Reporters has some times led to distorted and

exaggerated stories, which reflect unfavorably upon the company. Speed and

frankness in supplying accurate of the company.

factory Manager or in his absence person appointed by Director will provide the facts

and accurate picture of the situation to the following :

He will inform :

1. Personnel Managers Factory Mangers of teh neighboring compines.

2. Sarpanches of villages likely to be affected by the emergency.

3. Dy. Director ISH

4. Collector at Valsad

5. M.L.A’s at Valsad and Pardi and M.P. Valsad only if the accident leads to off site

emergency

6. News correspondents at Valsad

Person responsible for giving Information ensure the following:

1. Do not try to hide the facts. They will come out later any way.

2. Do not release estimates of damage without consulting occupier.

3. Do not speculate, stick to the facts.

4. Do not attempt to blame anybody.


14. Plant Evacuation Procedure :

It may be necessary to evacuate the building and / or surrounding buildings where

emergency has occurred. The evacuation instructions are given by Site Main

Controller after assessing the situation in emergency. (See annexure 19)

15 Personal Protective / Emergency Equipments

(See annexure 21 column No. 13,22 & 24)

Personal protective equipments / Emergency equipments are to be used according to

the nature of emergency such as fire, toxic spill gas leakage etc. List of personal

protective equipment / Emergency equipment with its location is circulated

separately to all departments. (See annexure 20). The responsibility for maintenance

of such equipment is as under :

1. Fire Fighting Equipment : Security & Fire Department

2. Personal protective equipments. : Plant Incharge / concerned department

3. Communication & Other instrumental : Electrical & Instruments Dept.

equipment

16. Safety Devices *(See annexure 4 column No.8)

The safety devices provided to safe guard against hazard are maintained in upto date

working condition and tested for their performance from time as per the preventive

maintenance schedule prepared i advance.

17. Revision & Updating :

The plan is subject to revision due to the following reasons.

1. To fulfill new statutory requirements if any.

2. To incorporate additional Hazards and risk identified on the basis of risk analysis.

3. Organizational changes, in the company if any.

4. Introduction of new / additional facilities in the form of equipment, mutual aid etc

to combat emergencies of fire, toxic release / spill or physical injury.

18. Mock Drills & Training.

The success of this plan will depend upon th education of all concerned and practice

of the same at regular intervals. The periodic drill is carried out to check performance

of the men and equipments. regular training Programs or fire fighting, use of gas

masks and first aid are conducted. This training also include tabletop and functional

drill of the plan. The full-scale drill is carried out in presence of statutory authorities,

press, and police for handling situation effectively.


ENCLOSURE – 1

A FORM TO RECORD EMERGENCY INFORMATION

Details of call as reported :

Caller’s Name & designation Date

Phone No.

Purpose of Call as reported:

Is any particular advice required immediately?

Name of Chemicals, To be spelt out clearly :

Brief description of incident

Fire / Explosion / Liquid Spill / Gas release

Quantity involved

Packaging / storing / handling / using details

Location of incident

Cause, if know, in brief

Time

Has anyone been injured Yes/No if Yes, how many?

Affected by chemicals Yes/No if Yes, how many?

What first aid has been given? Yes/No

Has any one been taken to Yes/No

dispensary / hospital?

If Yes address of the hospital

If caused by vehicle,

Who owns the chemicals?

Vehicle Number

and Name & Address of the owner

To whom was the load consigned?


ENCLOSURE – 2

ACTION PLAN IN THE EVENT OF MAJOR CHLOROSULPHONIC ACID LEAKAGE

1. Evacuate and cordon off the area.

2. Approach the area of leakage from windward side.

3. Stop leak if, possible.

Only trained persons equipped with personal protective clothing and suitable

respiratory protection from amongst the following should attempt to stop the

leak.

1. Positive pressure fresh air mask (Randle mask)

2. Self contained breathing apparatus.

4. If the leakage is observed from the storage tank body start transferring of

material in the spare tank immediately.

5. Do not allow acid to go in the drain. Plug the drain line.

6. Arrange for during sand over the spilled acid.

7. Keep organic material out of contact with acid spill.

8. If possible, arrange a vigorous spray of water from the actual are of spill (on

windward side) provided the spill is minor i.e. 50-100 litters.

9. To minimize the effect of Hydrochloric acid fumes coming from chlorosulphonic

acid to the following

a) Hold a wet cloth or handkerchief over the mouth and nose

b) Breathe as little as possible

c) Try to be at as high level as possible. Hydrochloric acid is heavier than air

and settles down.

d) Escape away from the site of accident in direction perpendicular to the wind.


ENCLOSURE – 3

ACTIONPLAN IN THE EVENT OF MAJOR CHLORINE GAS LEAKAGE

1. Evacuate and cordon off the affected area.

2. Approach the area of leakage from windward side.

3. Stop the leak if, possible. Only trained persons equipped with personal protective

clothing and suitable respiratory protection from amongst the following should

attempt to stop the leak.

1) Positive fresh air mask (Randle mask)

2) Self contained breathing apparatus.

4. If tonner / cylinder is found to be leaking even after closing the valve, remove it if

possible to an isolated open place and roll to such a position that the leaking

point is an top.

5. Spillage should be contained for neutralization with lime / caustic.

6. In case of fire, water however be used on other tonners / cylinders lying in the

vicinity.

7. Operate Portable hood system for absorption of leaking chlorine.

8. To minimize the effect of chlorine, do the following.

a) Hold a wet cloth or handkerchief over the mouth or nose.


c) Remain at as high level as possible because chlorine is heavier than air settles

down.

d) Escape away from the site of accident in a direction perpendicular to the wind.


Sheet No. 1

1. Instantaneous release of 900 kgs. Chlorine

C = Concentration

Concentration (C) at any x for a given wind speed will be function of Time. The

values below refer to maximum concentration.

C Max mg/

m3

PPM

100 M 102047 15142

200 M 15065 5188

300 M 4920 1694

400 M 2224 766

500 M 1201 414

600 M 726 250

800 M 328 113

900 M 237 82

1000 M 177 61

1250 M 96 33

1500 M 58 20

1750 M 38 13

2000 M 26 9

2500 M 14 5

3000 M 8.5 3

IDLH for Chlorine = 75 mg/m3 = 26 PPM Immediate Danger to life & health

STEL for Chlorine = 9 mg/m3 = 3 PPM Short Term Exposure Limit.

TLV for Chlorine = 3 mg/ m3 = 1 PPM Threshold Limit Valve.


ENCLOSURE – 4

ACTION PLAN IN THE EVENT OF MAJOR AMMONIA GAS LEAKAGE

1. Evacuation and cordon off the area.

2. Approach the area of a leakage from windward side.




leak.

a. Positive fresh air mask (Randle mask)

b. Self contained breathing apparatus

4. In confined area spray, plenty of cold water reduces concentration of ammonia in air.

5. In open area see wind direction and create a water fog (using fog nozzles) downward

from a convenient distance so that the released ammonia vapours can be effectively

absorbed.

6. Flush away spillage preferably by water

7. To minimize that effect of ammonia, do the following.

a) Keep that effect closed and open them only for a brief period as required.

b) Hold a wet cloth or handkerchief over the nose and mouth

c) Breathe as little as possible



Sheet No. 2

2. Instantaneous release of 15 ton Ammonia

Concentration (C) at any x for a given wind speed will be function of Time. The

values below refer to maximum concentration.

C Max mg/

m3

PPM

100 M 1700781 2446123

500 M 20021 28795

1000 M 2956 4251

1500 M 965 1388

2000 M 436 627

2500 M 236 339

3000 M 143 206

3500 M 93 134

4000 M 64 92

4500 M 47 68

5000 M 35 50

IDLH for Ammonia = 500 ppm

STEL for Ammonia = 27 mg/m3 = 35

TLV for Ammonia = 18 mg/ m3 = 25 PPM


ENCLOSURE – 5

ACTION PLAN IN THE EVENT OF MAJOR OLEUM LEAKAGE

1. Evacuation and cordon off the area.

2. Approach the area of a leakage from windward side.




leak.

a. Positive fresh air mask (Randle mask)

b. Self contained breathing apparatus

4. Do not allow Chemical to go in the drain. Plug the drain line.

5. Arrange for dumping sand / lime over the spilled Chemical, wearing full PPE.

6. To minimize that effect of Oleum, do the following.

a) Hold a wet cloth or handkerchief over the mouth and nose


c) Try to be at as high level as possible, Oleum is heavier than air and settles

down.




PAGE 340

DMP for Hydrogen

On -line monitoring of Hydrogen in Chlorine

Flame arrester on Hydrogen gas line

In Hydrogen compressors area all electrical appliances should be flameproof. Electrical motor

should be with Earthing at both side.

Hydrogen gas detectors should be installed at Hydrogen compressor and activates alarm in case

of Hydrogen leakage

TAC approved Fire hydrant system throughout the plant.

Water Sprinkler should be provided around transformers

Round the clock availability of full size own Fire Tender

Mutual aid schemes with the adjoining industries

Product storage tanks should be provided with dyke wall

Four levels of communication (Telephone, P A system, Walkie talkie, Siren system)

Incident investigation and corrective system including near-miss cases

Handling and Storage of Hydrogen

Use adequate ventilation.

Separate Hydrogen cylinders from oxygen, chlorine, and other oxidizers by at least 20 feet (6.1

meters) or use an approved gas cabinet.

Store only where temperatures will not exceed 125° F (52° C).

The must be no sources of ignition in areas where Hydrogen is being stored

Segregate empty cylinders from full cylinders.

When a cylinder is not in use, screw the valve protection cap firmly in place.

Secure cylinders upright at the top and bottom. Adjust the cylinder racks so that cylinders are

tightly secured.



PAGE 341

Safe handling of hydrogen cylinders

The following should also be noted when handling hydrogen cylinders and bundles:

Cylinder and bundle valves are only to be opened when the pressure reducer with undamaged

sealings has been carefully connected. The points of connection should be checked to ensure

they don„t leak.

Cylinder and bundle valves are to be closed when not in use in order to prevent gas leakage from

leaking connections.

If a cylinder or bundle valve is leaking or when hydrogen escape cannot be stopped by closing

the valve, the hydrogen container has to be transported outside where it is to be emptied. Repairs

on hydrogen cylinders or bundles, including the valves, are only to be carried through by the gas

supplier.

6.12 OFF SITE EMERGENCY

6.12.1 Communication in case of Major Emergency

On declaration of major emergency, the Atul complex Disaster Control Plan becomes operative.

The GM Corporate-SHE/Factory Manager who are members of the Main Control sub Committee

of Atul Complex Disaster Control plan (ACDCP) will inform the following persons about the

disaster and ask for help to combat the situation. They will remain in touch with Director

/Occupier for guidance if needed.

Name Designation Telephone No. Represent

District Collector,Valsad Chairman D.C.C. of

ACDCP O-0262-253613, Government

Occupier / Director, Atul,

Ltd.

Vice Chairman DCC of

ACDCP

O-233261

233241 Atul Ltd.

Dy. DISH Valsad Secretary DCC of

ACDCP,Valsad O-253612, Government

District Supdt. of Police,

Valsad

Chairman P&G Sub

Committee of ACDCP

O-254222,

Government

Atul Police Station, Atul 233515 Government

Atul Gram Panchayat, Atul O-234562 Government

GPCB Vapi Regional Office O-0260-2432089 Government

D.C.C. = Disaster Control Committee, P & G:



PAGE 342

The District Collector Valsad shall arrange help from Valsad Municipality, Zilla Panchayat,

and other Government/Non-Government Organizations. The District authorities shall inform nearby

villages for evacuation and / or other measures in case of emergency arose.

6.12.2 Mutual Aid

We have arrangements with the neighboring sites situated in the campus namely Atul – (East, PP

Site & West Site), to help each other in case of any emergency. The transport facilities, firefighting

facilities/ equipment, personal protective equipment and other emergency equipment shall be

available for mutual aid.

6.12.3 Mock Drills & Training

The success of this plan will depend upon the education of all concerned and practice of the same at

regular intervals. Periodic drill is carried out to check performance of the manpower and equipments.

Regular training programs on firefighting, Use of gas masks and first aid are conducted. This training

also include tabletop and functional drill of the plan. The full-scale drill is carried out in presence of

statutory authorities, press, and police for handling situation effectively.



PAGE 343

PART 03 – OCCUPATIONAL HEALTH AND SAFETY



PAGE 344

6.13 GENERAL

For large industries, where various activities are involved during construction, erection, testing,

commissioning, operation and maintenance; the men, materials and machines are the basic inputs.

Industrialization generally brings problems of occupational health and safety.

The proponent therefore has properly planned and taken steps to minimize the impacts of

industrialization and to ensure appropriate occupational health and safety including fire plans.

The key safety measures mentioned under shall be a part of proposed expansion project.

6.14 OCCUPATIONAL HEALTH

Occupational health needs attention both during construction/erection and operation/maintenance

phases. However, the problem varies both in magnitude and variety in the above phases.

6.14.1 Construction and Erection

The occupational health problems envisaged at this stage can mainly be due to constructional accidents

and noise generation. To overcome these hazards, in addition to arrangements to reduce it within the

Threshold Limit Values (TLVs), necessary protective equipment shall be supplied to the workers.

6.14.2 Operation and Maintenance

The problem of occupational health in the operation and maintenance phase is primarily due to noise

which could affect consultation. The necessary personal protective equipment shall be given to all the

workers exposed to high noise. The working personnel shall be given the following appropriate

personnel protective equipment.

Industrial Safety Helmet;

Welders equipment for eye and face protection;

Cylindrical type earplug;

Ear muffs;

Safety belt/line man's safety belt;



PAGE 345

Leather hand gloves;

Asbestos hand gloves;

Electrically tested electrical resistance hand gloves; and

Industrial safety shoes with steel toe.

Atul also has a Department of Health (DoH) for regularly checking health of the employeesand

providing medical aid in case of injury to the personnel. The DoH is responsible for taking care of the

Occupational Health & Safety of the employees at Atul Ltd.

A) DEPARTMENT OF HEALTH (DOH) at ATUL LTD

1. Medical Centres

DoH Main (Department of Health) within Atul complex

OHC (Occupational Health Centre, 24x7) within Factory premises.

2. Scope of Services

Primary healthcare for employees & family

Occupational healthcare

Health monitoring

Employee health check-ups

EMS (Emergency) 24x7

AOD (Accident on duty) management 24x7

OHC services 24x7

Medical Laboratory

Referrals

3. Systems & facilities available

HMIS (Hospital management & information systems)

Office automation



PAGE 346

ECG machine (two)

Multipara Monitor with O2 Saturation (one)

Finger pulse oximeter (one)

Glucometer (two)

Otoscope cum Ophthalmoscope (one)

AED (automated external defibrillator) (one)

Suction machine (two)

Fully automated biochemistry analyzer (one)

Fully automated hematology analyzer (5-part) (one)

Automated Centrifuge (two)

Microscopes (two)

Blood Roller Mixers (two), Pipettes & Other Lab accessories

Needle cutters (three)

Oxygen cylinders (ten)

Ambulance van with stretcher (two)

Emergency observation beds (five)

Medical assistance/aid visit bag (two)

Dr Consultation equipment

Antidotes as applicable

First aid boxes as required

4. Manpower

Full-time Doctors – Three (residing in campus)

Contract Doctor – One (Medical Advisor) (residing at Valsad)

Lab Technician – One



PAGE 347

Nurse – One (Male)

Medical Assistants – Five (Male)

5. Software Use

Online software for health monitoring and medical history for all employees

EMP for the Occupational Safety & Health hazards so that such exposure can be kept within

Permissible Exposure Level (PEL)/Threshold Level Value (TLV) so as to protect health of

workers.

1. An EMP for Occupational Safety and Health shall be proposed to implement with the following

objectives:

To keep air-borne concentration of toxic and hazardous chemicals below PEL and TLV

Protect general health of the workers likely to be exposed to such chemicals.

Providing training, guidelines, resources and facilities to the concerned department for

occupational health hazards

Permanent changes to workplace procedures or work location to be done, if it is found necessary

on the basis of findings from the Workplace Monitoring Plan.

It is proposed that this EMP be formulated on the guidelines issued by the Bureau of Indian

Standards on OH&S Management Systems: IS 18001:2000 Occupational Health and Safety

Management Systems

Proposed EMP shall be incorporated in Standard Operating Procedure also.

The proposed EMP shall also include measures to keep air-borne concentration of toxic and

hazardous chemicals below its PEL and TLV, like…

o Leak Surveys

o Separate storage for toxic chemicals

o Exhaust Ventilation

o Proper illumination

o Close processes to avoid spills and exposures



PAGE 348

o Atomization of process operations to hazards of manual handling of chemicals

o Supply of proper PPEs like Air mask, Berating canisters, SCBA sets, On-line breathing apparatus

at the places where there is possibility of presence of toxic chemicals

o Regular maintenance program for pumps, equipment, instruments handling toxic and corrosive

chemicals

o Display of warning boards

o Training to persons handling toxic and combustible materials/chemicals.

Workplace Monitoring Plan

It is proposed that a Workplace Monitoring Plan shall be prepared & implemented in consultation

with FMO.

Each workplace must be evaluated to identify potential hazards from toxic substances or harmful

physical agents. Air-borne concentration of combustible material shall be measured and records

shall be maintained.

Health Evaluation of Workers

It is proposed that management shall device a plan to check and evaluate the exposure specific

health status evaluation of the workers.

Workers shall be checked for physical fitness with special reference to the possible health hazards

likely to be present where he/she is being expected to work before being employed for that

purpose. Basic examinations/tests like Liver Function tests, chest x ray, Audiometry, Spirometry,

Vision testing (Far & Near vision, color vision and any other ocular defects) ECG, etc. shall be

carried out. However, the parameters and frequency of such examination shall be decided in

consultation with Factory Medical Officer.

While in work, all the workers shall be periodically examined for the health with specific reference

to the hazards which they are likely to be exposed to during work. Health evaluation shall be

carried out considering the bodily functions likely to be affected during work. The parameters and

frequency of such examination shall be decided in consultation with Factory Medical Officer and

Industrial Hygienists. Plan of monthly and yearly report of the health status of workers with

special reference to Occupational Health and Safety shall be prepared.



PAGE 349

6.15 SAFETY PLAN DURING PROJECT EXECUTION STAGE (CONSTRUCTION &

COMMISSIONING)

Safety of both men and materials during construction and operation phases is of concern. Safety plan

shall be prepared and implemented in the proposed project activity. The preparedness of an industry for

the occurrence of possible disasters is known as emergency plan. The disaster in the plant is possible due

to collapse of structures and fire/explosion etc. The proposed project would formulate safety policy

keeping in view the safety requirement during the construction, operation and maintenance phases, with

the following regulations:

To allocate sufficient resources to maintain safe and healthy conditions of work;

To take steps to ensure that all known safety factors are taken into account in the design,

construction, operation and maintenance of plants, machinery and equipment;

To ensure that adequate safety instructions are given to all employees;

To provide wherever necessary protective equipment, safety appliances and clothing as well as to

ensure their proper use;

To inform employees about materials, equipment or processes used in their work which are known

to be potentially hazardous to health or safety;

To keep all operations and methods of work under regular review for making necessary changes

from the point of view of safety in the light of experience and up to date knowledge;

To provide appropriate facilities for first aid and prompt treatment of injuries and illness at work;

To provide appropriate instruction, training, retraining and supervision to employees in health and

safety, first aid and to ensure that adequate publicity is given to these matters;

To ensure proper implementation of fire prevention methods and an appropriate fire-fighting

service together with training facilities for personnel involved in this service;

To organize collection, analysis and presentation of data on accident, sickness and incident

involving people injury or injury to health with a view to take corrective, remedial and preventive

action;



PAGE 350

To promote through the established machinery, joint consultation in health and safety matters to

ensure effective participation by all employees;

To publish/notify regulations, instructions and notices in the common language of employees;

To prepare separate safety rules for each type of occupation/processes involved in a plant; and

To ensure regular safety inspection by a competent person at suitable intervals of all buildings,

equipment, work places and operations.



PAGE 351

PART 04 – PUBLIC HEARING



PAGE 352

6.16 PUBLIC HEARING

The Public Hearing (PH) for proposed project was conducted on 21/06/2016 at 11:00 am at Atul Gram

Panchayat Hall, Vill: Atul, Tal & Dist: Valsad, Gujarat.

Mr. A. G. Patel, Member Secretary of PH and Regional Officer (RO), Gujarat Pollution Control Board

(GPCB), Vapi welcomed the Chairman of PH and Collector & District Magistrate, Valsad District,

officers, elected representatives & public participated in the PH.

Mr. A. G. Patel gave brief about the EIA notification and PH procedure, which was followed by the

presentation for the proposed expansion project by the proponent. The public gathered in the PH have

welcomed the said project and expressed good opinion about the said project.

The summary of query raised/clarification and points discussed during PH is mentioned as under:

Sr.

No. Suggestion by Suggestion Reply by Project Proponent

1.

Mr. Ashwin Patel

Ex. Sarpanch,

Dived Village,

Valsad District.

He told that ground water

level has been decreased due

to around 200-250 bore wells

operated in Atul.

He also appreciates the

projects undertaken by Atul

Ltd.

Company representative informed that

company does not use bore well water.

Par River is the source of water for

existing as well as proposed expansion

project. Bore wells are only for checking

and testing of ground water.

He asked about situation in

case of Phosgene leakage.

Company representative replied that

Phosgene plant is running since 1970,

there is not a single accident of exposure,

and we ensure that there will not be

abnormal incident in future also. We are

going to install a state of the art new

Phosgene plant of 5000 TPA capacity

supplied by Chemical Design

Incorporation (CDI), USA with latest

technology and zero storage which will

be safer than the existing plant. There

will be foolproof interlock system

provided for the safety. Apart from this,

Phosgene plant will be kept in complete

enclosure which will be connected to

three stage scrubbing system. Also,

existing plant will be dismantled after

commissioning of new plant.

He asked that industry will Company representative informed that



PAGE 353

Sr.


provide drinking water in case

of non-availability of ground

water in our village

they are already providing drinking

water to nearby villages and it will be

continue in future also.

2.

Mr. Ramesh

Chandra Vasanaji

Patel

Dived Village,

Pardi Group

Gram Panchayat,

Dist: Valsad

He told that due to make of

power plant chimney for

control of pollution, noise

pollution is increasing.


noise from steam blow down is normal

during commissioning of any boiler but

the same will be stopped completely

after commissioning is completed.

3.

Mr. Nanubhai

Ahir

Vill: Dungarwadi,

Tal & Dist:

Valsad

He told that reddish water

having foul smell found in

nala. Farmers are suffering.

Coconuts and mango‟s size are reducing.

Mr. A. G. Patel, RO, GPCB told that till

date we have not received any compliant.

We will definitely take appropriate

actions on receiving any such complain.

4.

Mr. Hiren Patel

Near Cynamid

Bus Stop, At:

Atul, Valsad

He told that mango crop is

affected and greenbelt is

reduced in nearby villages

because of company‟s pollution.


the award received by the Magod farmer

for producing highest mango production

from the Government of Gujarat last

month in Krishi Mahotsav. The Gujarat

Government bestowed the same. It

reveals the truth and correct information.

As per the Government records, crops

are increasing.

5.

Mr. Ashokbhai

Dived Village,

Valsad

He stated that company got

closer notice for discharging

untreated effluent. Still they

are not providing treatment

and hence fishes are dying.


Atul Company was running its ETP

since when there is no such concept in

the industries. The same was being

upgraded time to time. Company got

closure notice three years back due to

leakage in old effluent line. Company

had taken adequate actions for the same

and also made operational two more

ETPs.

Company representative informed about

the increase in fish production and

shown Government records for the same.

He told that Magod village‟s farmers have filed case

against the company for

damaging environment in

high court.


CPCB team has conducted

comprehensive 48 hr continuous

monitoring and taken water, air and soil

samples with respect to complaint in



PAGE 354

Sr.


which no abnormalities was observed.

This report is available on CPCB website

and company is also ready to share the

same.

Honorable high court had already

disposed off the matter.

He asked about how many

permanent workers are

working in company? How

many of them are skilled?

How many contract labours

are working in company?

Total 958 permanent employees are

working in company and out of this, 546

villagers of nearby 14 villages and 405

of Valsad district. Recent recruitment

was also from the nearby villages. Total

4000 people are working in the

company. Out of which 1000 employee

are in management category and 2000

are contract labours. 99% of local people

had been given employment.

6.

Mr. Hemang

Tandel

Valsad

He asked about online

monitoring system and said

that, GPCB & CPCB are the

only authorities to view the

data? Can we access the

same?


each stack and treated effluent are online

monitored by GPCB and CPCB

continuously as per Government rules.

GPCB and/or CPCB are serving notice

in case of non-abnormality observed

during online monitoring.

He asked that up to what

time/period data is stored.


we are keeping one-year data records

and taking back-up every week.

He asked about facilities

available in the company in

case of fire and details of

firefighting system.


total 3 fire tenders are available in the

company. Fire Extinguishers, fire

hydrant and smoke detector sensors are

also provided at prominent locations.

He asked that what actions

company will take in case of

fire at Parnera Hill.


we are providing help of fire tender to

the nearby community in case of such

incidents.

7.

Mr. Vijay Patel

Chanvai Village,

Valsad

He told that chemical smell is

being observed from the

Kalyani school children‟s uniform.


there is no such problem and our

employee children‟s are also studying in this school.

8. Mr. Harshad

Desai He asked that how much solid

waste will be generated after


company is having incinerator as per the



PAGE 355

Sr.


Valsad proposed expansion? How it

will be handled?

CPCB guideline for incinerable waste

and secured landfill site for inorganic

waste disposal. Company is disposing

waste as per the GPCB/CPCB

guidelines.

He asked for huge rise in

brine purification sludge

quantity.

Company representative informed that as

per new government rules Brine sludge

is not a toxic waste. Earlier there was

mercury plant which is already been

stopped and new cleaner membrane cell

technology has to be installed. In the

new membrane technology, brine

standards are very stringent and hence its

purification process will generate more

sludge than the old mercury cell.

9.

Ms. Purvi Rathod

Sarpanch, Hariya

Village, Valsad

She told that we are receiving

potable water two times, two

hours daily in our village.

She told that we have formed

a committee and discussing

with company for the

problems. Because of this,

even poorest people have

been benefited with toilet

facilities.

She told that company has

provided employment to our

villagers and hope that will

continue in future as well.

10.

Mr. Hiteshbhai

Valsad He asked that company will

ready to give compensation

for the crop damage by them.

Company representative informed that if

crops will be damaged due to company‟s pollution than company will do the

necessary for the same.

11.

Mr. Nareshbhai

Desai

Haria Village,

Valsad

He told that Atul has done

much social work and

constructed Aanganwadi &

building for gram panchayat.

We are getting water every

day. Company has built eighty

toilets in our village.

12. Mr. Nanubhai

Tandel He told that pollution level

has decreased a lot in recent



PAGE 356

Sr.


Deputy Sarpanch

Umarsadi village,

Valsad

years. Fisherman are getting

more earning by fishing now a

days. Conditions are better

than previous years.

He told that company is

providing help since many

years. Computers and sewing

machines are provided in

primary school.

Finally, Chairman informed that we have taken notes of all the oral presentations. We have also taken

notes of all the oral and written reply given by the company. Since there is no further question from

anybody, today‟s proceeding of PH is declared as closed with the permission of chairman of

Environment PH.

6.16.1 Public Hearing Proceedings

Date post:	08-Jul-2020
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