SAFETY AUDIT REPORT THE ANDHRA SUGARS LIMITED ...

SAFETY AUDIT REPORT

THE ANDHRA SUGARS LIMITED

SAGGONDA

REPORT NO: RPT/793/ANDHRA SUGARS SAGGONDA/APRMS/2019-20/RO

Prepared by

Asia Pacific Risk Management Services Pvt. Ltd

6th Floor, Mookambika Complex

No.4, Lady Desika Road

Mylapore, Chennai – 600004,

Tamil Nadu, India

Email: [email protected]

Web: www.aprms.com

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CONTENTS

Sl.

No

DESCRIPTION PAGE NO.

1. Introduction 4

2. Executive summary 9

3. Review of previous audit records 11

4. Brief details of the plant 11

5. Brief details of the process 15

6. Safety Policy 27

7. Safety Organization 27

8. Safety Communication, Motivation and training 28

9. Safety budget 29

10. Safety committee 29

11. Occupational health center and first aid facilities 29

12. Safety Manuals and rules 31

13. Compliance with statutory regulations 31

14. New equipment review 34

15. Accident reporting, analysis and investigation 35

16. Plant safety inspection 35

17. Personnel Protective Equipments 35

18. House keeping 36


19. Machine guarding and general area guarding 37

20. Material handling equipment 37

21. Electrical and personnel safe guarding 38

22. Hydrogen filling and Liquid Hydrogen area 41

23. Work environment monitoring 41

24. Prevention of occupational diseases 41

25. Work permit 41

26. Firefighting system and fire prevention observations 42

27. Safe Operating Procedures 48

28. Emergency preparedness Plan 48

29. Process safety 52

30. Civil 53

31. Effluent treatment and waste disposal 53

32. Others 54

33 PAC manufacturing 58

34 Chlorine Accidents –Accidents happened else where 59


1. Introduction

The Andhra Sugars Limited, Chemicals and Fertilizers Division is located at Saggonda,

30 Kms from Kovvur in West Godavari District in the state of Andhra Pradesh. Products

manufactured in the plant are Chlorine gas, Liquid Chlorine, Caustic Soda Lye,

Caustic Soda Flakes, Hydro Chloric Acid, Sodium Hypo Chlorite, Hydrogen Gas, Liquid

Hydrogen, Sulphuric Acid and Poly Aluminum Chloride.

The safety audit was conducted on 11th to 12th September 2019 by the following

team:

1 Mr.H.Ramakrishnan

2.Mr A.Lakshman

Due considerations were given for the existing safe guards in the plant.

The consultants wish to place on record their sincere thanks to the management and

staff of The Andhra Sugars Ltd., for their excellent cooperation and participation in

the study.

Date:17.10.2019

In order to comply with the provisions of manufacture, storage and import

ofhazardous chemical rules, 1989 and also to enhance its safety standards, the

organization engaged the services of M/ s Asia Pacific Risk Management Services

Private Limited, Chennai to conduct a comprehensive Occupational Health and

Safety Audit as per IS 14489:1998.

https://www.google.co.in/url?sa=t&rct=j&q&esrc=s&source=web&cd=3&cad=rja&uact=8&ved=0ahUKEwjG37ucysDNAhUFNJQKHU6TD0gQFggkMAI&url=http%3A%2F%2Fcpcb.nic.in%2Fupload%2FPublications%2F(28)HAZARDOUS%2520CHEMICALS%2520RULES.doc&usg=AFQjCNFV84jJX4h7Sg8cLHFc9uEJeH431g&sig2=PPDqUsMPqwohfEwxdKP7uQ&bvm=bv.125596728%2Cd.dGo




Safety Audit Goals

Audits are normally designed to achieve one or more of the following goals

To provide the auditee with an opportunity to assess its own OS & H system

against standards and identify areas for improvement.

To determine the conformity of the implemented OS & H systems with specified

requirements and identify areas for improvement.

To meet regulatory requirements.

Audit Objectives

Occupational Safety and Health (OS & H) audits are conducted

To carry out a systematic critical appraisal of all potential hazards involving

personnel, plant, services and operational methods.

To ensure that OS & H system fully satisfy the legal requirements and those of

company’s written safety policies, objectives and progress.

Audit Methodology

Appraisal of Audit procedures to the concerned executives.

Familiarization visit to various sections of the unit.

Visit to various sections for in- depth study of hazard potential.

Study of the maintenance system of process vessels, machines, pipes,

equipments, buildings etc.,

Interaction with various levels of employees.

Perusal of documents relating to OS &H.

Appraisal of major observations to the functional heads who are decision

makers to improve SHE system.

Documents Perused

The following records are pursued during the audit.

1. OS & H policy

2. Safety Department’s organization chart


3. Safety Budget

4. Safety promotional & motivational measures

5. Training records on safety, fire and first-aid

6. Record of plant safety inspections

7. Accident investigation reports

8. Accidents and dangerous occurrences – statistics and analysis.

9. Record of tests and examinations of equipment and structures as perstatutes

10. Safe operating procedures for various operations

11. Record of work permits

12. Record of monitoring of toxic and flammable and other substances at work

place

13. Maintenance and testing records of the detection and fire fighting equipment

14. Occupational Health Centre/First Aid Details

15. Medical records of employees

16. Records of industrial hygiene surveys (noise, ventilation and illumination levels,

airborne substances and explosive gases)

17. Material safety datasheets

18. On-site emergency plan and record of Mock Drills

19. Communication Systems adopted in the unit

20. Records of waste disposal

21. Housekeeping inspection records

22. Minutes of safety committee meetings

23. Approval of layouts; and other approval from statutory authorities

24. Records of any modifications carried out in plant or process

25. Maintenance procedure records

26. Calibration and testing records

27. Shut down and maintenance procedures

28. In service inspection manuals

29. Records including that of material handling

30. Inspection books and other statutory records

31. Records of previous audits

32. HAZOP Study Reports


33. Safety in transportation of hazardous substances

34. Personal Protective Equipment

35. Pressure Vessels, Pipes and Fittings

36. Lifting Machines and Tackles

37. Mobile Equipment and Vehicular Traffic

38. Tank Storage Area Vessel-Details

39. Onsite Gas Cylinder Storage Area-Details


Areas covered under audit

1. Safety policy

2. Organization Setup

3. Safety Education and Training

4. Employees participation in OS &H

5. Safety Manual &Rules

6. Compliance with Statutory Requirements

7. New equipment review /inspection

8. Accidents reporting, investigation and analysis

9. Risk assessment including hazard identification

10. Plant safety inspections

11. Health and safety improvements plans /targets

12. First aid facilities – Occupational Health Centre

13. Personal protective equipment

14. Housekeeping

15. Machine and general area guarding

16. Material handling equipment

17. Electrical and personal safeguarding

18. Ventilation, illumination and noise

19. Work environment monitoring system

20. Occupational Health

21. Safe operating procedures

22. Work permit system

23. Fire prevention, protection and fighting system

24. Emergency preparedness plan

25. Process / plant modification procedures

26. Transportation

27. Hazardous waste storage and disposal

28. Safety in storage and warehousing

29. Contractor safety system

30. Boilers, Pressure Vessels and Utilities


2. 0 Executive Summary

Presently plant do not have separate safety department. Suggested to have a

separate safety department to oversee the safety activities. This will help in

focusing the safety related activities in monitoring and implementing the

safety improvement plans including the Power plant.

Road Tankers are parked outside the caustic plant near to PAC plant. Several

accidents are reported recently in road tanker parking area in other plants.

Control has to be exercised for road tanker in –out timings, No cooking in the

parking area, Road tanker personnel’s stay in the parking /waiting area are to

be considered.

Transformer 1 and Transformer 2 each 10/16 MVA are aged more than 30 years.

Furfural test is being carried out regularly to monitor the insulation. Life

assessment study to be carried out and the replacement plan to be taken up

by the Andhra Sugars to prevent power failures /accidents.

NIFS Nitrogen injection system fire protection is provided for the 70 KA rectifier

panel.

Plant requires electrical lock out system for safe working in electrical

equipments. Only TAG OUT system is followed in the plant. LOTO system to

cover all dangerous machinery and energy sources are properly shut off and

are not started up unexpectedly while maintenance or service work is being

completed. Suggested for a survey of LOTO implementation equipments like

padlocks, valve lock outs and others for effective implementation.

Anti-toe away system has to be considered for Hydrogen and chlorine filling

vehicles for safety

FRP tanks for HCl acid storage are newly installed.


Vanadium pentoxide toxic chemical is stored along with electrical spares in

H2SO4 plant Substation. This should be stored separately to avoid exposure to

dusts. As per officials a separate storage room is being constructed and the

same needs to be expedited.

PAC Powder area: Power cable passes from ground floor to the elevated

floors. This poses fire spread through cable tray. Fire retardant paint coating to

be provided to prevent fire spread.

Road tanker loading area: This area requires safety platform with safety belt

hooking arrangements to prevent accidents –fall from height. Accidents have

happened in Oil tanker filling stations in Petroleum deports due to non-

availability of safe working arrangements.

Thermography of critical electrical installations is required to assess the system

healthy condition.

Lightning arrester study recommendations are to be implemented.


Empty land

No occupation –Low hazard

Company owned land

No occupation –Low hazard

Gopavaram Village

Low hazard

Company land, Drain Low hazard

3. 0 Review of previous audit recommendations

Previous safety audit was conducted in the year 2018 and all the observations are

completed and some of them are under review.

4. Brief Details of the plant

4.2 Public utilities:

4.2.1 Fire services –Kovvur 30 Kms from the plant

4.2.2 Police Station: Gopalapuram 22 Kms from

plant

4.2.3 Railway station: Kovvur 30 Kms from plant

4.2.4 Nearest hospitals are

1. P.H.C – HUKKUMPETA 08811 – 253511

4.1 Location and surrounding properties


2. Community Health Centre – GOPALAPURAM 9652636709

3. PRASANNA NURSING HOME, PRAKKILANKA 08813 – 282254

4. KOTNIS HOSPITAL, PRAKKILANKA 08813 – 282523

5. GOVT HOSPITAL, KOVVUR 08813 – 231450

6. APEX HOSPITAL, RAJAHMUNDRY 0883 – 2439191

7. SANJANA ORTHOPEDIC, RAJAHMUNDRY 0883 – 2431455

8. S.M.R.M.V. HOSPITAL, TANUKU 08819 – 224905

4.3.0 Total plant area is 320 Acres

4.4 Products manufactured with capacity:

4.5 Key raw materials their sources and inventory

S.NO LIST OF RAW

MATERIALS SOURCE

CAPACITY OF

THE YARD

STOCK

AVAILABILITY

S.NO MANUFACTURING PRODUCTS INSTALLED

CAPACITY

PERMITTED

CAPACITY

1 Caustic Soda 500 TPD 500 TPD

2 Liquid Chlorine 240 TPD 240 TPD

3 Hydrochloric Acid (33%) 1000 TPD 1000 TPD

4 Sulphuric Acid 300 TPD 300 TPD

5 Hydrogen (Bottling) 2.4 TPD 2.83 TPD

6 Caustic soda Flakes 140 TPD 140 TPD

7 Liquid Hydrogen 1 TPD 1 TPD

8 Sodium Hypo Chlorite (100%) 40 TPD 40 TPD

9 Poly Aluminum Chloride 90 TPD (18%) 90 TPD (18%)


1 SALT Andhra Pradesh/

Gujarat 15,000 MT 25 DAYS

2 SULPHUR Import from middle

east 15,000 MT 2 MONTHS

3 HYDRATED

ALUMINA Hindalco / NALCO 5,000 MT 5 MONTHS

4.6 Storage Tank farm details

Sl Tank no Material

stored

Type

oftan

k

Storage

temp.

and

pressure

Type of fire

protection inerting, fixed

Water spray, foam, dyke

1 D203 A,B,C,D,E Caustic

Soda 32%

MSRL 50*C Atm

80*C

Dyke wall

2 D204,A,B,C Caustic

Soda 48%

MS 50*C Atm Dyke wall

3 D710,A,B,C,D,F Liq Chlorine M.S -2to-10*C

2.0 to 10

Kg/Cm2

Dyke wall and

neutralizing system

4 D901 E,F,G,H

D 911

A,B,C,D,E,F,G,H

Hydrochloric

Acid

MSRL 50*C Atm Dyke wall

D902

A,B,C,D,E,F, G,

H

Hydrochloric

Acid

FRP 50*C Atm Dyke wall


Sl Tank no Material

stored

Type

oftank

Storage

temp.

and

pressure

Type of fire

protection inerting, fixed

Water spray, foam, dyke

5 Storage

Tank

1,2,3,4,5,

Sulphuric

acid

M.S 50*C Atm Dyke wall

6 D 801A,B,C,

D

Sodium

Hypochlorite

HDPE 12-15*C Dyke wall

7 Day tank

1

1 and 2

Sodium

Hypochlorite

MSRL 12-15*C Dyke wall

8 V 105

A,B,C,D,E,F,

G,H

Poly

Aluminum

Chloride

FRP Atm

Pressure

and

Dyke wall

9 V101 (at

PAC

unit)

Crude

PAC

FRP 60*C

Atm

Dyke wall

4.7 Boilers

Sl

n

o

Boiler

registry

numbe

r

Boiler

capacit

y

Type

of

boile

r

Boiler

ratin

g

M2

Year of

Manufactur

e

Max.

Working

Pressure

Kg/CM

2

Make

1 AP 2648 10 TPH Wate

r tube 427 1985 14.7

Cethar

Vessels P Ltd

2 AP 3816 15 TPH

Wate

r

Tube

592 2003 17.25 Cetharvessel

s P Ltd

3 AP 3989 15.43 TPH WHB 2091 2005 48.4

Thermal

systems (P)

Ltd

4 AP 939 6 TPH HMT 177 1978 13.3 NESTLER Ltd

4.8 Thermic fluid boilers

1. Thermic fluid heater for heating of heat transfer salt in Bertram’s flaking plant


(70TPD)-Fuel H2 & HFO (Heavy fuel oil)

2. Thermic fluid heater for heating of heat transfer salt in Blow Knox flaking plant

(60TPD)-Fuel H2 & HFO (Heavy fuel oil)

5.0 Brief details of the process.

Caustic Soda Lye and Flakes Plant

Caustic soda (32%) is manufactured by electrolysis of brine solution.

NaCl+H2O -------- NaOH +1/2 Cl2 +1/2H2

Main raw materials are NaCl and Power and the process is described follows:

Raw salt is dissolved in the Saturator, and the saturated brine of about 320 gpl

concentration is prepared. The impurities such as, Calcium, Magnesium, Sulphates

etc. are removed from the Saturated Brine by the addition of Barium Carbonate and

Sodium Hydroxide respectively.

The treated Brine passes through Clarifier. The precipitated impurities, along with

insoluble’s like, sand and clay are settled in clarifier. The overflow from clarifier is sent

through the series of filters (anthracite filter, Dr. M .filter). Organic matters and fine

impurities are filtered in these filters. From Dr. M. Filter purified brine is sent to ion

exchange units for further purification. The polished brine gets heated up in chlorine

recuperator before admitting to the Ion exchange units.

This purified brine enters the Electrolysers. The electrolyser element assembly consists

of anode (titanium) and cathode (nickel) and cation exchange semi permeable

membrane, the membrane is placed between anode and cathode. On giving DC

current the brine solution undergoes electrolysis and forms NaOH and hydrogen on

the cathode side and chlorine on the anode side. The weak brine of about 240 gpl


concentration is returned to the brine plant for re-saturation and purification. Caustic

soda of around 32% concentration, Hydrogen and chlorine gas are produced.

32% caustic soda from electrolyser is further concentrated into 48% in triple effect

evaporation plant by using steam as heating medium.

Caustic Soda Flakes Manufacturing:

Caustic soda flakes manufactured by concentrating caustic soda from 32% /48 % to

99% by multiple effect evaporation with the use of falling film technology in two steps.

First step is concentration of caustic soda rising up from 32% to 48% in the first stage

of the triple effect evaporator and the second step is rising the concentration from

48% to 62 %/73 % by using steam and in the third step to 99 % from 62%/73% with the

use of heat transfer salt in long tube concentrator (evaporator).

The 50% caustic lye will be pumped to the single effect evaporator through a pre

heater. An additive solution prepared by dissolving sugar in caustic lye will be dosed

into feed caustic lye in order to destroy oxidizing agents like chlorates and any

dissolved air in the feed lye so that the corrosion attack of the evaporator equipment

will be minimized.

The evaporation will be under vacuum. The water vapors will be condensed by

means of water to the barometric condenser. The steam ejector or vacuum pump

provides the vacuum to the system.

The 62% caustic liquor from 62% caustic separator bottom will be pumped to the

anhydrous caustic concentrators system, operating 4 Nos in parallel.

The 62% caustic in anhydrous caustic evaporators is heated counter currently with

inorganic molten salt which in turn will be heated in vertical furnace where fuel oil or

hydrogen is used as fuel.


The molten caustic and super-heated vapours will be separated in a separator. The

water vapours will be cooled and condensed in a Surface condenser operating the

system under vacuum. The molten caustic (99%) from the separator is collected into

anhydrous caustic storage tank and overflows into flaker pan where it is converted

into flakes by cooling the anhydrous caustic soda by circulating cooling water in the

flaker to its fusion point, the flakes will be directly filled in HDPE bags with alkathene

liners inside and weighed.

Chlorine Cooling, Drying, Compression, Liquefaction, Storage and Filling

The Chlorine gas is cooled, by exchanging heat with polished brine, then cooled by

cooling water and finally by chilled water to 18*C and then passes through mist filter

to remove NaCl mist.

Moist chlorine is passed through Drying Tower, where concentrated Sulphuric Acid is

circulated and moisture content in chlorine is reduced to below10ppm.

The dry chlorine gas is compressed to a pressure of 2.5 to 3.0 Kg/Cm2 by liquid ring

centrifugal compressors and sent to the Liquefaction Plant through dry chlorine mist

filters.

The compressed gas is condensed by Freon refrigeration system.

Liquid Chlorine flows by gravity to liquid chlorine storage tanks. Uncondensed gas

(sniff gas) is delivered to the HCl Unit.

From the storage tanks chlorine sent to filling by padding with dry compressed air of

about 11 kg/Cm2 pressure.

Hydrogen Bottling Process Description

The hydrogen gas coming out from the cell house at 80o C is cooled to 40oC in Hydrogen

cooler and passed through mist filter to remove NaOH mist and then scrubbed with cold


soft water in a packed column to free the gas from alkali carryover if any. The column is

provided with sloping bottom and proper sealed type draining arrangement for removal

of any accumulated oil and carbon deposit without risking of air ingress into the system.

The scrubbed gas is led .through a safety seal to a wet type gas holder of 50 m3capacity.

A safety seal is interposed between scrubber and gas holder to prevent any over

pressurization of the system. The safety seal will release the gas through vent pipe if

the pressure rises above 110-120 mm WC. The vented gas will be let off to atmosphere

at about 2 m above the highest level in the area through a flash back arrestor. The

safety seal is provided with water supply and a sealed type overflow system.

The scrubbed gas is led to the gas holder through a moisture trap cum flash arrestor.

The trap has been provided with soft water connection and sealed type overflow.

Similar trap is provided at gas holder outlet also.

Knock out drums are provided between hydrogen gas compressors suction header

and compressors suction lines. In this knock out drum moisture in H2 gas gets

separated and drained once in 8 hrs. The collected water is drained through safety

seal pots. H2 enters the compressor through suction strainer and compressed to the

desired bottling pressure of 150 bars. The compressor is of 5 stage “SULZER “make air

cooled type. The compressor is provided with pressurized/ purge type control panel.


A Pressure Maintenance Valve is fitted at outlet of compressor to maintain gas

pressure at the outlet of compressor within narrow limits during cylinder filling

operations.

A high pressure purge bottle is provided in the HP gas system to facilitate removal of

carried over moisture and oil in the gas stream. A drain valve provided is operated

every hour.

The gas from the purge bottle passes through a fine filtration equipments, pre filter,

micro filter and activated carbon filter. Each filter is provided with separate drain

valve to free the gas from oil mist and water vapour.

High pressure hydrogen gas after getting cooled by chilled water is fed high pressure

hydrogen filling manifold through a header fitted with isolation valves for supplying

and cutting off gas to individual manifold for filling cylinders both loose and trailer

mounted.

Flash back arrestors with integral non- return valve are provided at top end of all

hydrogen vent line to facilitate safe venting of hydrogen. All vent line outlets are

taken up to a height about 2 m above highest working level in the surrounding area.

Hydrogen leak detectors are provided in the plant at 5 strategic locations.

Hydrochloric Acid Manufacturing

The Hydrogen gas from electrolysis after cooling is partly used in the production of

Hydrochloric Acid, by reacting Chlorine in a furnace to form Hydrogen Chloride in

the form of gas, which is absorbed in water to form Hydrochloric Acid of 33%

strength.


The HCl synthesis unit consists of three principal parts.viz. The burner, the synthesis

chamber- heat exchanger assembly, receptor and tail gas tower.

The HCl gas after absorption in Cooler –Absorber and tail gas towers will be diverted

to waste HCl scrubber in order to scrub with DM water. The resultant very dilute HCl

acid will be utilized in HCl production by mixing with feed water. The HCl

concentration in the scrubber exit gas will be maximum 10mg/NM3. Thus the

unabsorbed HCl emission from HCl Plant is effectively removed by treating with water

in scrubbers. The scrubbing is counter current and the scrubber uses one inch PVC

rings as media.

Sodium Hypochlorite

As a pollution abatement measure and to recover the waste chlorine as much as

possible, the vent chlorine from various sources is absorbed in 18% caustic to produce

sodium hypo chlorite, which is sold.

The absorption system consists of three absorbers. Each absorber is packed with

randomly distributed packing.

Reaction: Cl2+ 2NaOH ---NaOCl +NaCl+H2O

The reaction is highly exothermic and heat of reaction is removed by circulation of

scrubbing liquid through coolers.

The first and second stage absorbers are mounted on sumps. The Cl2 gas enters the

first stage absorber from bottom and then enters the second stage absorber.

Practically chlorine is absorbed in first stage absorber itself; only a very small quantity

of chlorine enters the second stage from where effluent gas is practically free of

chlorine. The third stage absorber is provided for safety.


Finally the residual waste gases after absorption are let out to the atmosphere

through a chimney of 60 M height. Cl2 detector is provided in the stack line.

The sodium hypo tower pumps and waste chlorine blowers are connected to the

emergency supply and UPS in order to operate them continuously without

interruption during power failure time also.

Sulphuric Acid Manufacturing

Sulphuric acid is manufactured by Double Contact Double Absorption to achieve

higher yield of product.

Sulphur is melted in melting pits fitted with steam coils. Molten Sulphur is fired in

Sulphur furnace with pre dried process air. Sulphur is converted to Sulphur- -di-oxide.

S+O2 ------ SO2 +Heat

The heat liberated is utilized to produce steam in waste heat boiler (WHB). The outlet

gas from WHB enters into five pass converter having V2O5 catalyst where SO2 is

converted to SO3. This is also an exothermic process.

2SO2+O2 ------- SO3 +Heat

The outlet gases are absorbed in Inter Pass Absorption tower (IPAT) where 98.4% acid

is in circulation. The IPAT outlet acid concentration is adjusted to 98.4% by addition

of DM water.

Since SO3 absorption and water dilution to acid are exothermic processes, the

process acid is continuously cooled in acid coolers.

SO3 + H2O -H2SO4 +Heat

The V pass outlet gases are cooled and absorbed in Final Absorption Tower (FAT),

function of which is similar to IPAT. The conversion efficiency of SO2 to SO3 is 99.7%


compared to 97-98% in single contact single absorption process. Hence in DCDA

process emission from plant stack is reduced.

The outlet gases from IPAT and FAT are passed through demisters/ mist eliminators to

prevent carryover of acid mist along with residual gases.

The vent gases from FAT are let out through the stack after passing through an alkali

scrubber, where dilute caustic soda solution is in continuous circulation for

neutralization of SO2 and SO3 gases escaping through the stack. This alkali scrubbing

system is also meant to take care of any excessive emissions during start up periods

and intermediate stoppages for long time. The alkali scrubbing system comprises of

a dilute caustic solution tank, a packed scrubbing tower and circulation pump.

The alkali scrubber liquor, sodium sulphite is effectively used for dechlorination of

return brine in the membrane cell caustic soda plant.

Poly Aluminum Chloride (PAC) Manufacturing

The production of liquid Aluminium chloride consists of etching of alumina with an

aqueous solution of hydrochloric acid.

The reaction takes place in a glass lined reactor equipped with three blade

agitator and a heating jacket.

The reactor is installed on a weighing scale.

At first HCl coming from storage tank is loaded by a centrifugal pump. When loading

of HCl is completed, agitator is started for better mixing of HCl and Aluminium, which

is being added gradually.


The alumina is fed to the reactor by an extendable plastic pipe that is disconnected

from feeding nozzle after alumina feeding is completed.

After loading the temperature is increased up to 70oC by feeding low pressure steam

in the jacket.

At the beginning aluminum chloride reaction occurs between 35-50oC depending

on the concentration of raw materials. This reaction is exothermic. When the

temperature of 70oC is reached steam with medium pressure (8-9 Kg/Cm2) is fed

through jacket.

As the difference between internal and external surface (jacket) cannot exceed

110oC to avoid damage to the glass lining, it is necessary to use steam at two different

thermal levels (3 bar and 8 bar pressure).

At first step the reaction is exothermic and temperature increases to 105oC and then

the temperature increases to 160oC in order to complete PAC formation reaction

(reaction time is about 165minutes).

Once the reaction time is completed, in order to avoid thermal shocks to the liner

inside the reactor, the cooling procedure must be very smooth. Starting with warm

water is composed by a water collecting tank, recirculation pump and a thermo

stated water heat exchanger. When the internal temperature has reached to 90oC,

the product is diluted with water (predetermined quantity) in order to reach the

concentration of PAC solution. The reaction mass is discharged by compressed air.

The total batch time is eight hours. By adding sodium aluminate solution high basicity

PAC can be obtained in a separate preparation Tank.

A safety filter is installed on the discharge line in order to check if any problem on

reactor glass lining has occurred.


The discharged product is further cooled to 60oC in a graphite cooler and then

discharged in the crude PAC tank.

As alumina is fed to the reaction unit in slight excess quantity and some insoluble

material is present in the raw materials, crude PAC has to be filtered. The filtration

system is composed of a filter press and a diaphragm pump. The solids removed

during filtration are discharged through a screw conveyor in a small sludge cart and

disposed as landfill in low lying areas.

After filtration PAC solution is fed to the storage.

All vents of the tanks and reactors are connected to a scrubber that washes the gas

with water before letting to atmosphere. The overflow from the scrubber is collected

in a storage tank.

The overflow of the scrubber is slightly acidic and can be used in various operations

of PAC dilution in the plant without having any impact in the product quality.

In case of opening of safety valve in the reactor, the HCl vapours are released in to

a safety tank that is full of water, which can absorb HCl.

5 Block wise process details are as below

S.No. Production

Block

Products made Type of raw

material

used

In plant

quantity of key

raw materials

Type of reactions

in the block

1. Cell Hall Caustic Soda,

Chlorine,

Hydrogen

(Unprocessed)

Salt (NaCl) 1.60 MT/ Ton of

Caustic Soda

Electrolysis

2. Evaporatio

n Plant

Caustic Soda Lye Caustic Soda

Lye

1.0 MT / Ton Evaporation and

Separation


3. Flaking

Plant

Caustic Soda

Flakes

Caustic Soda

Lye

1.0 MT / Ton Evaporation and

Separation

4. Chlorine

Plant

Liquid Chlorine Chlorine Gas

& Sulphuric

Acid

1.05 MT of

Chlorine gas &

50 Kgs of

Sulphuric acid/

MT of Liq.Cl2

Drying,

Compression &

Condensation

5. Hydro

Chloric

Acid

HCL (33%) Chlorine &

Hydrogen

0.32 Mt of

Chlorine & 0.01

MT of

Hydrogen per

ton of HCL

Burning, Cooling

& Absorption

6. Sodium

Hypo

Chlorite

Sodium Hypo

Chlorite

Caustic Soda

& Chlorine

0.180 MT of

Caustic Soda &

0.107 MT of

Chlorine/ M.T

of Sodium

hypo

Absorption &

Chilling

7. Hydrogen

Bottling

Hydrogen Gas

Filling

Hydrogen

Gas

1.0 NM3 per 1.0

NM3

Compression &

Filling

8. Sulphuric

Acid Plant

Sulphuric Acid Sulphur 0.33 MT per MT

of H2SO4

Melting, Burning,

Catalytic

Conversion &

Absorption

9. PAC Plant Poly Aluminium

Chloride

Alumina

Hydrate,

Sodium

Aluminate &

HCL

0.3 MT Alumina,

0.7 MT HCL, 0.1

MT of Sodium

Aluminate per

MT of PAC

Reaction at

elevated

temperature &

Pressure in GL

reactors

10. Liquid

Hydrogen

Liquid Hydrogen Hydrogen

Gas, Helium

Gas, Liquid

Nitrogen

1.1 MT of H2

gas per MT.

15.0 MT of LN2

per MT

Compression,

Purification,

Chilling


6.0 Safety Policy

Plant has an integrated management system policy covering quality,

environment, health and safety and signed by CMD

IMS policy is signed by CMD and adopted from1.7.2011 Annexure 1

It fulfills the requirements of AP Factory Rules

All employees are made aware of policy statement during induction training.

1.0 More display of safety policy is various department and locations will create more

awareness

7.0 Safety Organization

Safety department is headed by the Mechanical Department head and assisted by

Technical assistants. Fire department responsibilities are also managed by

Mechanical department head.

SAFETY ORGANISATION

7.1 Suggested to have a separate safety department exclusively. This will help in

Executive Director

Safety In-charge

Chairman & Managing

Director

Junior Engineer


focusing the safety related activities in monitoring and implementing the safety

improvement plans.

8. 0 Safety training Communication and motivation

Plant has a plan of 6 hours per person per year for imparting training.

Plant has developed 33 Training programs scheduled and conducted in the

year 2019. Refer Annexure 2

Work permit system

Working at height

Personal Protective Equipment

First Aid

Fire prevention System

Chlorine Cylinders filling and handling

Electrical safety

Confined space entry

Material handling

Maintenance of Transformers

Contract Workmen safety

Training programme for truck drivers on defensive driving

Personal Protective equipment Electrical

Scaffoldings Arrangement for maintenance works

Static Electricity Hazards Preventive measures

Use of fire Extinguishers

Fire prevention system

Operating personal regarding Personal Protection &

Emergency action etc.

Safety contests are organized as a part of Safety Day celebrations during the

month of February.


9. 0 Safety Budget

There is no constraint for purchase of safety and fire equipments. This shows

the management’s commitment on safety.

Safety budget is utilized for the following:

Procurement of Personal Protective equipments and consumables

Fire protection equipments spares

Statutory inspection and certification like pressure vessel testing

National Safety day celebrations and

Fire hydrant system maintenance

10. 0 Safety Committee

Safety Committee is formed as per Factories Act and AP Factories Rules,

1950.

Safety Committee consists of 15 members from various functional

departments of the unit.

Safety committee meetings are held quarterly and minutes are verified.

11. Occupational Health center and First aid facilities

OHC is available in the plant

The medical officer is available in general shift. OHS is staffed with Para

medical staff covering Round the clock.

Exclusive driver for the Ambulance is available in all the shifts.

Twelve first aid boxes with medicines are kept at following locations and

periodically checked

1. Hydrochloric Acid Plant & Hypo Plant

2. Hydrogen Plant


3. Chlorine Filling Section

4. Work Shop

5. Cell House & D.C.S

6. Chlorine Compressor

7. Evaporation Plant/ Bertrams Plant

8. Laboratory/ Brine Plant

9. Power House

10. HTLT 1 & 2

11. R.O Plant

12. PAC Plant

Thirty trained first aiders are in the plant covering all the shifts.

GENERAL SHIFT “ A ” - SHIFT

1. G.U. Bhaskara Rao, Elect. Engineer 1. S.N. Venkata Ratnam, Chemist

2. R.V.V.S.N. Murthy, Elect. Engineer 2. B.V.K. Prasad, Chemist

3. M.V. Satyanarayana Murthy, A. E (Mech) 3. N.V.V. Prasad, Asst. Chemist

4. M. Srirama Krishna, Sr. Chemist 4. U. Narendra Babu, Asst. Chemist

5. N.V.V. Srinivasa Rao, Head Time Keeper 5. B.N.V. Gopala Krishna, Asst. Chemist

6. L. Vasudeva Rao, Asst. Fitter 6. D. Suresh Babu, Fitter Gr-III

7. Desireddy Rama Krishna, Asst. Fitter 7. U. Sreehari Prasad, J.E (Mech)

8. K. Balaji, Inst. Mech-Gr-III 8. Y. Raja Rao, Supervisor (Inst)

9. V.K. Satish Kumar, Electrician Gr-II 9. U. Posi Babu, Security H/G

“ B ” – SHIFT “ C ” - SHIFT

1. D.V.V.S.S. Prasad, Chemist 1. N. Ashok Chowdary, Chemist

2. K. Yesu Babu, Welder Gr. III 2. K. Pream Sagar, Wireman Gr-III

3. P.V. Rama Sastry, Fitter Gr-III 3. CH.S.R.K. Murthy, Helper

4. K. Murali Mohan, Asst. Electrician 4. R.B.V.N.S. Prasad, Chemist

5. M.V.V. Satish Kumar, Supervisor (Mech) 5. M. Phanindra Babu, Supervisor

(Mech)


Medical examinations: Statutory Medical examination is conducted as per AP

Factory Rules and the records available in the plant.

Medical emergency practice:

After receipt of the communication from the time office about the incident, we will rush

to the incident area by ambulance. After thorough examination of the Patient, if it is major

injury, he will be sent to Dispensary by ambulance. In the dispensary, he will be given First

Aid and taken to the ESI Hospital or other necessary hospital for further treatment purpose.

If the patient is in normal condition with minor injury, then the patient will be given

treatment in our dispensary. After found normal he will be send back to work.

12. 0 Safety Manual and Rules

Safety manual

Plant is certified for EMS and OSHAS system. Department manuals are available

with Standard Operating Procedures.

13. 0 Compliance with statutory requirements

Following are the important Acts and Rules applicable to this unit.

1. Factories Act &Rules

2. Indian Electricity Act &Rules

3. Pollution Control Act &Rules

4. Gas cylinder rules

5. Contract Labor Act &Rules

6. Weights and Measures Act &Rules

7. Petroleum Act

8. Indian Boilers Act

Detailed legal register is available and is updated periodically. Details are as below:


Sl. No Subject Form in which

Application to

be made

Present

status,

Renewal up

to

1. Water (P&C of pollution) Act, 1974 and

rules, 1981

APPCB/VSP/RJY449/CFO/HO/2019 Dt:16-

10-19

Form- D 31-08-2024

2. Air (P&C of pollution) Act, 1981 and rules,

1982/83


10-19

Form- I 31-08-2024

3. Hazardous waste (M&H) rules, 2016


10-19

Form- I 31-08-2024

4. Hazardous wastes (Management,

Handling and Trans boundary movement)

Rules,2016

Form- 4 Every June

5. Environment Protection Act, 1986 Form- V Every

September

6. Public Liability Insurance Act, 1991 Document 31st March

2020

7. Environmental Protection Rules – Env.

Clearance

EIA & CFE Once get

valid 7 years

8. The Factories Act, 1948/1987 Form no- 4 Every year

9. The Indian Electricity Rules Act, 2003 H.T agreement

/

Appendix VIII

--------

10. Arms Act, 1959 and Arms Rules, 1962 Form- II 31-03-2020

11. The Explosive Act, 1884 The Explosive rules

1983 Petroleum Act, 1934

Form IX & XV 31-12-2024


12. Gas Cylinder Rules 2004 Hydrogen Gas

Cylinders Storage

Form- F 30-09-2023

13. Gas Cylinder Rules 2004 Hydrogen Gas

Cylinders Filling

Form- E 30-09-2023

14. Gas Cylinder Rules 2004 Chlorine Cylinders

Storage

Form- F 30-09-2023

15. Gas Cylinder Rules 2004 Chlorine Cylinders

Filling

Form- E 30-09-2023

16. Gas Cylinder Rules 2004 Testing and

Examination of Hydrogen Cylinders

- 30-09-2026

17. Gas Cylinder Rules 2004 Testing and

Examination of Chlorine Cylinders

- 30-09-2026

18. Under Explosive Act see rules act 1884 sec

49&50 Licenses to store chlorine

Form- III 31-03-2019**

19. Under Explosive Act see rules act 1884 sec

49&50 Licenses to store Liquid Nitrogen

Form- III 30-09-2024

20. Licensed to Transport Compressed Gas in

a Pressure Vessels Vehicle noAP-37-Y-2392

Form- IV 30-03-2021

21. Indian Boilers Act Regulations 389 Boiler

AP-3989

Form- VI 01-02-2020


AP-3816

Form- VI 01-01-2020


AP-939

Form- VI 01-02-2020


AP-2648

Form- VI 01-08-2020

25. Contract Labour (Regulation & Abolition)

Act, 1970

Form No- 2 Continued

26. Employees Provident Fund Act, 1952 Form 5 A Continued

27. Employees Family Pension Scheme, 1971 Form 5 A Continued

28. Employees Deposit Linked Insurance

Scheme,1976

Form 5 A Continued


29. Employees Group Saving Linked Insurance Policy Continued

30. Individual Happy Family Floater Policy Application 30-09-2020

31. Manufacturer/ packer of pre packed

commodities, under rule 27 of the Legal

Metrology Packaged Commodities Ruled,

2011

Certificate Continued

32. Bureau of Indian Standards certification

marks license:

PAC- Caustic Soda – Lye and Solid (Flakes)

CM/L- 4581066

CM/L-

6600042110

31-03-2020

20-06-2020

33. E- Waste Rules- 2016 -- Continued

34. Employees Compensation Act, 1923 -- Continued

35. Employee State Insurance Act, 1948 Form- 01 Continued

36. Food Safety Standards Act, 2006 Form- A 14-04-2022

Note: Sl. No. 18, we have applied for the renewal of Chlorine storage license well within the time.

we are awaiting for the license renewal from the PESO.

14. 0 New Equipment review/Inspection

Plant design consultants are M/s Thyssen Krupp Industrial solutions India. Lamella clarifier

system is developed by the plant and successfully established in brine plant.

Plant to consider evolving a check list for management of change

The checklist is to include the following:

1. Any process change should be wetted by engineering packages.

2. Engineering data sheet entry to be made for any specification change

3. Insurance related aspects need to be covered –introducing the changes to be

incorporated in the policy for additional assets involved.

4. Any change in on site emergency plan subsequent to change

5. Design code compatibility on the equipments on which modification

6. Statutory compliance or reporting of the modification.


A model of the points to be considered is annexed to this report. Annexure

15. 0 Accident investigation and near miss reporting

No reportable accidents happened in the plant

Near miss incident investigations: Near miss accidents are investigated and

corrective actions are taken.

It is suggested to have preventive actions (similar locations) to be included in the

investigation report.

16. 0 Plant safety inspection

16.1 In the plant safety inspection and audit are carried out systematically and

documented. Standard operating procedures are available and followed.

16. 2 The status of the objectives and targets shall be reviewed periodically and

recorded.

17. 0 Personal Protective Equipment

17. 1 Plant is certified for EMS. Hazard Identification and Risk assessment register is

available. PPE s identified for the operations and procured.

17. 2 Safety Officer reviews and ensures the special PPE s is available for use.

17.3 Critical PPEs available in the plant are

Sl PPE description Quantity

1 Eye wash cum shower combination units 29

2 SCBA 27


3 Breathing air cylinders 43

4 Emergency life breathing apparatus 04

5 Emergency escape breathing

Apparatus

15

6 Ear muff 40

7 Cryogenic suit 02 at LH2 plant

8 Heat resistant suits 02 at LH2 plant

9 Heat resistant blanket 1000mmx6000 mm 02 at Acid plant

10 Cryogenic hand gloves 02 pairs atLH2

plant

11 Wind sacks 07

12 Canister gas mask 41

13 Spare canisters 13

14 Full face masks 06

15 Hose connected type face masks 05

16 Particulate filters 104

17 Air blower with intended hose mask 1

Escape breathing Apparatus are checked monthly and the check sheet being

followed is attached in Annexure 3

SCBA PM Check list is attached in Annexure 4


17. 0 Housekeeping

Housekeeping is an essential part of Occupational Safety and Health program.

Housekeeping can prevent 50 % of accidents and near misses.

18. 1 Spill kits are to be made available for the storages and labs

19. 0 Machine guarding and Safety reliefs

Any machine part, function, or process which may cause injury must be safeguarded.

Where the operation of a machine or accidental contact with it can injure the

operator or others in the vicinity, the hazards must be either controlled or eliminated.

Section 21 of factories Act 1948 and various sections of AP Factories Rules require

safety guarding of machines and processes against injury and ill health of personnel.

19.1 Chlorine filling area: Safety latch for crane hook and spreader beam hook is

required.

19.2 Spreader beams are locally made. Testing by competent person is required.

Suggested to verify the standard spreader beam capacity.

19.3 Tonners are lifted with lifting hooks clamped on the rips. There is possibility of

throat opening in the hooks due to repeated use. Throat opening to be checked in

periodical maintenance.

20.0 Material handling equipments & Road safety

20.1 Material handling equipments are tested as per AP Factories Rules and

certificates are available.

20.2 Lot of dust is generated by vehicle movement in the plant roads and

water spray is carried out in the plant. Effectiveness to be monitored and the

water sprinkling frequency has to be increased.


20.3 Fire tender is parked inside the Chlorine bullet area. This needs to be

parked in safe area away from the bullet storage for easy operation.

20.4 Inside the fenced area of Chlorine bullets several trucks and transport

vehicles are parked. This needs to be avoided.

21. 0 Electrical and Personnel Safe Guarding

21.1 In the substation UPS room used batteries are kept. They are potential fire

hazard. They should be removed from the battery room once they are found

defective or life is expired.

21.2 In the substation UPS room Normal plug point is available. Flame proof

plug point and flame proof tools are to be used inside the battery room.

21.3 Battery terminals need cap to prevent shorting while tightening the

terminals during inspection.

21.4 Substation battery room exhaust is not run continuously. Continuous

running is required to avoid any accumulation of Hydrogen generated during

charging and discharging cycles.

21.5 Transformer 1 and Transformer 2 each 10/16MVA are aged more than 30

years. Furfuraltestis being carried out regularly to monitor the insulation. Life

assessment.

Study to be carried out and the replacement plan to be taken up by the Andhra

Sugars to prevent power failures / accidents.

(ix) he shall ensure that the transformers of 10 MVA and above


rating or in case of oil filled transformers with oil capacity more

than 2000 Liters are provided with fire fighting system as per IS -

3034:1993 or with Nitrogen Injection Fire protection system:

21.6 In10/16MVAtransformer No1 Oil leakage from the top flanges are observed.

Suggested to check the oil level in conservator and maintain it for the loss and

correct the same at the earliest.

21.7 All transformers neutral conductor to be provided with HV insulation to

prevent contact with the neutral bar under short circuit conditions.

21.8 Buchholz relay is tested during the annual maintenance from the control

panel for functioning but mechanical check for the contacts to close by Nitrogen

passing to be checked to ensure the mechanical contacts are closing for tripping.

21.9 Transformer 4 and 5 each 10/16MVA are newly installed. The soak pit is

made by tank form buried below the ground. The man whole portion of the tank

form need to raise above ground to check and remove any water accumulation

inside. Also provide a vent pipe with inverted U shape to release the gas generated

during draining the transformer oil under fire condition and to avoid rain water entry

during rains.

21.10 70 KA rectifier transformer DM water level is in closed loop. Low level alarm

in the tank needs to be verified and provided if not available. DM water level

monitoring may be carried out.

21.11 NIFS Nitrogen injection system fire protection is provided for the 70 KA

rectifier panel.


21.12 Provide Guard for the HV DC bus bars in rectifier transformer area. This job

is being carried out.

21.13 Provide warning Signs “DANGER, HIGH VOLTAGE DC, ENTRY ONLY FOR

AUTHOURISED PERSONNEL” in HV DC bus bar area.

21.14 HT/LT SS1 Emergency generator diesel day tanks needs earthing to

prevent static charge accumulation.

21.15 In HT LT SS1 an Auto transformer is available for motor checking. The

transformer Cable cellar below HT LTSS1: Lot of unwanted materials are stored in

the cable cellar. Also contractors are entering the cable cellar to keep their things.

Any fire / handling things can damage the cables and will result in disruption. Cable

cellar should be cleared of storage of materials and entry should be for authorized

personnel only.

21.16 H2SO4Plant33/0.433KVSS:Transformerisindoortypewith3sidesclosed.

Ventilation is adequate as per plant officials. This needs to be verified for summer

times.

21.17 Auxiliary Supply panel with lead acid batteries for Transformer control

panels is 132 KV substations. The room with lead acid batteries rack requires flame

proof equipments like FLP switches, FLP exhaust. This room also requires H2 Detector.

22. 0 Hydrogen filling and Liquid Hydrogen area

22. 1 In hydrogen purity analyzer room lights and switches are non-flame proof one.

Requires flame proof fittings.

23. 0 Work environment monitoring


23. 1 Periodical internal air quality monitoring is required as chlorine, HCl, H2SO4 are

manufactured, stored and transported in the plant.

24. 0 Prevention of occupational diseases

Occupational Health is the promotion and maintenance of the highest degree of

physical, mental and social well-being of workers in all occupations by preventing

departures from health, controlling risks and the adaptation of work to people, and

people to their jobs. (ILO / WHO 1950).

Several measures adopted in the organization in prevention of occupational

hazards:

Pre-employment medical examination of all new employees are carried out

and the records are available

Medical examination for the hazardous operations is identified and the medical

examinations are conducted.

25. Work permit

Work permit system procedure is available in plant. There are several permits in the plant

to carry out the work safety. These includes

Gas/Acid Line maintenance work permit

Excavation work permit

Hot work permit

Working at Height Permit

Vessel / Confined space entry work permit

Electrical work permit

General work permit.

.

25. 1 Plant requires electrical lock out system for safe working in electrical

equipments. Only TAG OUT system is followed in the plant. LOTO system to cover all

dangerous machinery and energy sources are properly shut off and are not started


up unexpectedly while maintenance or service work is being completed. Suggested

for a survey of LOTO implementation equipments like padlocks, valve lock outs and

others for effective implementation.

25. 2 During audit In SS HTLT1 electricians are attending panel maintenance. They do

not have electrical work permit / General work permit as required for the work. This

needs to be viewed seriously and permit system needs to be followed for all the

works.

26. 0 Firefighting systems and Fire prevention observations

Plant has Fire fighting crew with 18 Security staff covering all the shifts. Apart

from this plant personnel are also trained in fire fighting periodically.

Plant has emergency crew with members from security, Medical, Chemical,

Civil, Electronics, Electrical, Instrument and Automobile Departments for

meeting any emergency.

Fire hydrant system and Fire extinguishers details

Storage Tanks 2 no’s

Capacity 650m3’each

Pump capacities Motor Driven pump 273 m3 /hr. at 8Kg/cm2 -1 no

Diesel engine driven pump 273 m3 /hr. at 7.0Kg/cm2 -1 no

Jockey pump 10.8 m3 /hr. at 8.0Kg/cm2-1 no

Number of fire hydrant points 60

Number of water monitors 05

Plant has a fire tender to meet any emergency.

Fire Buckets 140 numbers are available in various locations of the plant.

Fire extinguishers details: 278 fire extinguishers of various types are provided in

various locations of the plant.


Medium velocity sprinkler / Deluge system

Sl Location Type Spray

Nozzle

MODE

L

No

of

spray

nozzles

No

of bulbs

Flow

rate

M3/

hr

Bulb

fusion

tempin Deg C

S.NO

I

EQIPMENT DESCRIPTION

FIRE EXTINGUISHERS:

QTY

1 ABM Foam 9lit.cap.(stored pressure type) 14

2 ABM Foam 9lit.cap.(cartridge type) 07

3 ABM Foam 50lit.cap.(cartridge type) 01

4 ABC Clean Agent 4kg cap. 06

5 BC DCP 5 Kg .cap (cartridge type) 34

6 BC DCP 6 Kg.cap (stored pressure type) 4

7 BC DCP 10 Kg.cap.(cartridge type) 14

8 ABC DCP 2 Kg.cap.(stored pressure type) 07





13 BC CO2 2 Kg.cap.(gas type) 05

14 BC CO2 3.2 Kg.cap.(gas type) 06




18 BC CO2 9 Kg.cap.(gas type) 16


20 BC DCP 75 Kg.cap. (cartridge type) 01

21 BC DCP 9 Kg.cap. (cartridge type) 01

Total 278


1 H2 Bottling

plant

No 1

MVWS K-64-120 40 - 181 -

2 H2 Bottling

plant

No 2

Deluge K-42-120 45 45 225 79

3 HT/LT No1

cable

cellar

MVWS K-41-140 64 - 186 -

4 LH2 Plant

Tanker

Filling

Deluge K42-110 78 78 225 79

5 LH2 Plant

Tanker

parking

Deluge K-91-110 36 36 225 79

Fire detection and alarm system


Sl Location Smoke

detect

or

Heat

Dete

ct or

Manu

al call

points

Loop

power

sound

er

Line

fault

isolator

Flame

detecto

rs

1

3.8 MW HFO generator

House control room &

132/33 KV Substation

12 8 1 1 1 --

2 Rectifier room No-3 6 -- 1 1 -- --

3 HT/LT cable gallery

room and DG room 16 8 4 4 -- --

4 HT/LT Room first floor 16 -- 2 2 1 --

5 CSP DCS Control Room 16 -- 2 2 -- --

6 DCS Control Panel

Equipment Room 6 -- 1 -- 1 --

7 Rectifier Control Room 4 -- -- 1 -- --

8 DCS Instrumentation

Panel Room 4 -- -- -- -- --

9 Polarization Rectifier

Control Room 8 -- 1 1 1 --

10 Battery Room -- 4 -- -- -- --

11 HT/LT Switch Gear

Room- 1 & 2 12 -- 1 1 -- --

12 Liquid hydrogen plant -- -- 3 -- -- 4

13 STORES 4 -- -- -- -- --

14

Bertram’s Flaking Plant

DCS Control Panel

Room & Control Room

4 -- -- -- -- --

15 VFD Room at CL2 Plant 2 -- -- -- -- --

16 VFD Room at Brine

plant 2 -- -- -- -- --

Total 112 20 16 13 4 4


26.1 Provide list of areas covered in each zone in the panel for easy identification

when there is an indication.

26.2 Rectifier Transformer area smoke detection system needs to be extended.

26.3 HTLT SS1 cable cellar is at ground level and the panel room is at first floor. In

several places cable entry from the bottom are not covered properly. This will result

infirepropagationfromcellarandviceversa.Suggestedforfirespreadpreventionby

proper sealing or with fire retardant paint coated for 1 meter on both sides. ( N02 DG

AMF panel cable entry there is gap)

26.4 Plant has the following UPS systems. Observations on the inspected UPS

systems are follows. Safety requirements for UPS is attached in Annexure 6

LIST OF UPS SYTEMS AND THEIR LOCATIONS

SL CAPCITY

IN KVA

MAKE LOCATION PURPOSE

1 3 Siemens Control room For No1 Rectifier

2 3 HL -REL Control room For No2 Rectifier

3 2.5 HL-REL Control room For No3 Rectifier

4 300 EMERSON Control room For Polarization

rectifier

5 2*10 Accutech

Infosystems Pvt

Ltd

Control room For No 4 Rectifier

6 160 Synergy HT/LT 2 For Hypo plant

7 300 HL REL HT/LT2 For Hypo plant

8 20 Accutech

Infosystems Pvt

Ltd

LH2 Plant For Laboratory


9 10 -do- MCC3 Room

top floor

For laboratory

26.5 300 KVA + 160 KVA UPS Room: There are 4 numbers of 2T ac units are working

continuously 24x7. Domestic AC units are not rated for continuous operation.

Additional capacity AC units are to be fixed and run cyclically so that no ac unit will

run continuously for more than 8 hours. Accidents have occurred in Pharma units labs

due to continuous working ac units. Similarly Rectifier control room has 24x7 working

ac units.

26.6 300 KVA + 160 KVA UPS Room: In UPS room under false flooring power cables

are laid along with communication cables. So false flooring requires smoke detector.

26.7 300 KVA + 160 KVA UPS Room: It is suggested to provide compartments for

UPS and Battery units separately. The battery rack needs to be maintained at 25*C

and the UPS can work up to 35 Deg C safely. Also exhaust will generate heat from

the UPS unit. Providing separate AC systems / unit will conserve power and also

Separation of battery racks and UPS can be achieved.

26.8 H2SO4 plant: Panel room requires smoke detector provision.

26.9 Anti-toe away system has to be considered for Hydrogen and chlorine filling

vehicles for safety

26.10 For flaking plant furnace, LPG is used as pilot fuel. LPG is drawn from

commercial cylinders through manifold. In the manifold there are five inlet points and

one outlet point. There were only two LPG cylinders kept connected to the manifold.

It was observed that on removal of cylinder the adopter connecting the LPG cylinder

and manifold was left over as such. If the isolation valve provided at the adopter of


the manifold passes, LPG will leak into the surroundings. Hence it is suggested to

keep the adaptor connected to the cylinder even the cylinder is empty till another

cylinder is connected.

26.11 Dual fuel (Hydrogen and fuel oil) are used for flaking plant furnace. It was told

that HAZOP study has been conducted by the plant supplier.

26.12 PMCCN1&N2VFDroom: Cleanagent fire extinguishing modules may be

provided for fire fighting as providing other systems at height will be difficult.

27. Safe Operating procedure

Safe Operating procedures are available in each department considering the safety

in Operations, environmental requirements and Occupational health. SOP s are

prepared as per the EMS.

27.1 Operators may be trained periodically on SOP and whenever the SOP s is

updated

27.2 SOP s updating is to be carried out whenever there is process changes are

taken up.

28. Emergency Preparedness plan

On site Emergency preparedness plan considering possible emergency

scenarios is available and is in accordance with MSIHC Rules.

Mock drill report : refer annexure 5

Key personnel for managing On Site emergency plan are

OFFICE RES

EXECUTIVE DIRECTOR 4360


FACTORY MANAGER 4366 4391

PERSONNEL MANAGER 4327 4390

ADVISER (MECHANICAL) 4326 4388

DY. CHIEF ELE. ENGINEER 4313 4383

INSTRUMENT ENGINEER 4325 4378

ASSISTANT ENGINEER CIVIL 4309

MEDICAL OFFICER 4337

SAFETY INCHARGE 4339 4389

Plant has Fire fighting crew with 18 members covering all the shifts. Apart from

this plant personnel are also trained in fire fighting periodically

GENERAL SHIFT “A” - SHIFT

1. U. Adinarayana Murthy, Asst. Security Officer 1. V. Rama Krishna, Security Head Guard

2. B. Murali Mohan, Security Head Guard 2. D. Raja Babu, Security Guard

3. D.V. Rama Krishna, Security Guard 3. CH. Mutyala Rao, Security Guard

4. P. Vijaya Kumar, Security Guard

5. K. Chitti Moshai, Security Guard

“B” – SHIFT “C” - SHIFT

1. MD. Mahaboob Alam, Security Head Guard 1. U. Posi Babu, Security Head Guard

2. B. Nageswara Rao, Security Guard 2. N. Veera Krishna, Security Guard

3. P. Posa Rao, Security Guard 3. A. Chamcha Rao, Security Guard

4. K. Sesha Rao, Security Guard 4. D. Venkata Krishna, Security Guard

5. K. Srinivas, Security Guard 5. CH. Israil, Security Guard


Emergency grew with specific areas are identified and employees responsible for the

same is as follows:

EMERGENCY CREW

U. ADINARAYANA MURTHY SECURITY

MD. ALAM SECURITY

V. RAMA KRISHNA SECURITY

U. POSIBABU SECURITY

Y. MOHAN KUMAR MEDICAL

N.V.V. SRINIVASA RAO MEDICAL

K. YESU BABU CHEMICAL

GARAPATI VENKATESWARA RAO CHEMICAL

N. SANYASI RAO MECHANICAL

ALLU SRINIVASA RAO MECHANICAL

A. SATYANARAYANA CIVIL

P. RAMA KRISHNA ELECTRONICS

B.G. KONDALA RAO ELECTRICAL

V.K. SATISH KUMAR ELECTRICAL

P. SASI BUSHAN KUMAR INSTRUMENT

Y. KASI INSTRUMENT

M. RAJESH AUTO MOBILE

Plant has emergency crew with members from security, Medical, Chemical,

Civil, Electronics, Electrical, Instrument and Automobile Departments for meeting any

emergency.

District authorities and their contact details are

DISTRICT AUTHORITIES & EMERGENCY TELEPHONE NO’S


DISTRICT COLLECTOR ELURU 08812 230050

REVENUE DIVISIONAL OFFICER KOVVUR 08813 231488

MANDAL REVENUE OFFICER GPR 08813 274451

DISTRICT MEDICAL OFFICER ELURU 08812 230278

DY. SUPERINTENDENT OF POLICE JRG 08821 225503

INSPECTOR OF FACTORIES ELURU 08812 231190

POLLUTION CONTROL BOARD ELURU 08812 249668

POLICE STATION GPR 08813 252433

FIRE STATION KOVVUR 08813 231101

MUTUAL AID

[A] JOMC - JEGURUPADU 0883 2453179

[B] GTPS - VIJJESWARAM 08813 285408

11 chlorine and Hydrogen leak detectors are available in the plant

Emergency mock drills are conducted during general shift hours. During general

shift hours senior managers and officials will be present and weakness in the system

will not get exposed. It is advised to conduct emergency mock drills during odd hours,

rainy days and holidays.

29.0 Process Safety

29.1 Working persons in the hydrogen compression and bottling area are provided

with Electrostatic dissipative shoes. Periodically integrity of these shoes shall be

ensured.


29.2 Lye storage and loading area should be lined with alkali resistant tiles.

29.3 As per IS 4262 if a common bund wall is made for more than one tanks, then

capacity of the bund should be enough to hold the content of the largest tank (after

deducting the space occupied by the other tanks). The bund wall and the floor of the

bunded area should be made of acid resistant material. The slope of the floor should

end up in a sump having drain pipe with valve approachable from outside. The drain

should discharge into an acid resistant neutralization sump of adequate size. The

height of the bund wall and its distance from the tank periphery should be so adjusted

that the jet of acid released from any part of the body of the tank may not fall outside

the brim of the bund wall.

29.4 All storage tanks do not have hazard indication. All storage tanks shall be marked

with hazard indication label as per NFPA

29.5 FRP tanks for HCl acid storage are newly installed. Less than 2 years old. FRP tank

test procedure guidelines developed with the following standards

ASTM E 1067-07 Standard Practice for AE Examination of Fiberglass Reinforced

Plastic Resin (FRP)Tanks;

ASME, Boiler and Pressure Vessel Code; and

RTP-1, Reinforced Thermoset Plastic Corrosion-Resistant Equipment

30.0 Civil

30.1 4x10/16 MVA transformers have a soak pit located outside the yard. It does not

have any vent. Vent is required as the transformer oil drained during emergency will be

hot and will generate fumes. To avoid over pressurization of choke pit vent is required.

Provide vent of goose neck type to avoid rain water ingression.

30.2 Similarly the choke pit has to be checked periodically for free from moisture /

water as hot oil during draining in emergency will create steam and will cause steam


explosion.

30.3 PMCC N1&N2 panel room there is only one entrance is available. Escape route

is required.

31.0 Effluent treatment and waste disposal

ASL has implemented various recycling systems of waste water streams and the generated

effluents from the 500 TPD Caustic Soda Plant, 300 TPD Sulphuric Acid Plant & 90 TPD PAC

plant operations will be treated in existing ETP followed by R.O. After neutralization,

clarification, disinfection and filtration the water is going to R.O. Plant as feed water. The

R.O. permeate is being utilised for cooling water makeup and reject is being utilised in

brine saturator.

About 766 KLD of effluents will be generated from the Chemicals & Fertilisers division of

Saggonda unit. The existing ETP is designed to treat about 1200 KLD or a maximum hourly

flow of 35 KL. This means that the present ETP capacity will suffice, quantity – wise to meet

the hydraulic effluent load generated from the 500 TPD Caustic Soda Plant operations as

well as from the Sulphuric Acid plant & PAC plant operations.

The various categories of effluent streams from different sections of the Caustic Soda plant

namely Cell House, Chlorine liquefaction, DM Water plant, Secondary brine purification,

HCl plant and Hypo plants are collected through an exclusive epoxy lined drain system

into the equalisation tank.

The effluents from caustic soda plant have wide variations in their PH values and therefore

the first step in the ETP is the PH correction. ETP consists of an equalisation tank where

different effluents streams join and get mixed and this is followed by a neutralization tank

where PH is brought to 7.5 to 8.0 by the addition of Caustic Soda Lye or Hydrochloric Acid.

The effluents from the equalization tank are pumped into the clarifier, where suspended

solids in the effluent are settled. The clarifier is circular is shape with a conical bottom and

a slow speed rake mechanism drags the suspended solids to the centre of the conical

bottom. The sludge settled is drawn to the sludge drying beds for drying. The clear and

treated effluent is obtained from the clarifier overflow collected into receiving tank and

pumped to R.O. Plant.

EQUIPMENT DETAILS OF EFFLUENT TREATMENT PLANT

1) Equalisation cum Neutralisation Tanks

Size : 6.0 X 6.0 X 2.25 m SWD

Volume : 81.0 M3 Each

M.O.C. : RCC / EPOXY

No. of Units : 2

Hydraulic Retention Time : 2 Hours.

Mixing : Agitation with Mechanical Agitators- 2 Nos

Drive for Agitation : 5.0 HP / 60 RPM

2) Chemical Dosing Tanks


Size : 1.5 m X 2.0 m SWD

Volume : 3.5 M3 each

M.O.C : HDPE

No. of Units : 2 (one for NaOH and another for HCl)

3) Pumps for feed to Clarifier

Capacity : 60 M3 / Hr. each

Head : 15 m

Motor : 12.5 HP / 1440 RPM

No. of Units : 2

4) Over flow weir box

Size : 2.9 X 2.9 X 0.5 m SWD

Volume : 4.2 M3

M.O.C : MS / EPOXY

No. of Units : 1

5) Clarifier


Volume : 125 M3

M.O.C : MS / EPOXY

HRT : 9.5 hours

Sludge hoper Slope : 1 in 12

Sludge removal : Scrapper Mechanism

Drive for Scrapper : 1.0 HP

No. of Units : 1

6) Treated Effluent Holding Tank


Volume : 57 M3

M.O.C : MS / FRP

No. of Units : 1

7) Pump for Treated Effluent to R.O. Plant

Capacity : 60 M3 / Hr.

Head : 30 m

Motor : 15 HP / 1440 RPM

No. of Units : 2

8) Sludge Drying Beds

Size : 4.0 X 3.0 X 0.25 m

Volume : 3.0 M3 each

M.O.C : RCC

No. of Units : 2

9) On-Line pH analysers


Effluent inlet to ETP : 1 no.

Effluent outlet from ETP : 1 no.

II. R.O. Plant Process Description:

We have installed Reverse Osmosis(R.O.) plant of capacity 40 m3/hr for the treatment and

reuse of the effluents generated from the process operations of our Saggonda unit. Main

operations of R.O. plant are as follows:-

a) Chemical Treatment

b) Clarification

c) Primary Filtration

d) Ultra Filtration and

e) R.O. Filtration

Reverse Osmosis is a membrane process in which synthetic semi permeable membranes

are used to remove dissolved impurities from water.

a) Clarification system:

The clarifier serves the purpose of reducing suspended solids, colloidal silica & removal

of heavy metals from effluent water.

High Rated Solid Contact Clarifier (HRSCC):

It works mainly on two basic principles namely coagulation/flocculation and Hydraulic

separation. Coagulation & Flocculation occurs in the flocculation zone when the feed

stream comes in intimate contact with chemical mixtures and the suspended sludge

particles from previously treated water. This contact also promotes flocs growth as

smaller particles agglomerate into larger heavier particles.

The hydraulic separation principle uses an up flow design to move water into the settling

zone for clarification.

The HRSCC provides three zones for better clarification.

i) Rapid mix zone:- Where raw water re-circulated precipitates and fresh reagents

are rapidly mixed together.

ii) Slow miz zone:- Where gentle mixing permits floc formation and brings the floc

into intimate contact with the suspended particles.

iii) Clarification or settling zone:- Where the up ward flow (rise rate) is reduced to a

low value to permit the precipitation to settle out.

Settled sludge is moved continuously along the floor towards centre of unit by means

of a slowly rotating scrapper which covers the entire floor area.

The sludge from the HRSCC will be led into the sludge drying bed.

The clarifier effluent is collected in the clarified water tank and further it is pumped to

the Multigrade filter.

b) Multigrade Filter System:-

The clarified water is passed through a Multigrade filter to reduce the suspended solids


present in the water. This filter is provided to keep a check on the suspended solids.

The suspended particles in the feed water get entrapped in the filter media. Pebbles

of two different sizes and sand used as filter media. The filter will have to be

backwashed with effluent water for 10 to 150min. daily. The filtered water is then passed

through the Ultra filtration unit.

c) Ultra filtration system:-

Ultra filtration is a low pressure membrane process for the removal of colloidal silica,

colloidal particles, all particulate matter, suspended solids and bacteria.

The feed effluent flows from the inside of the fibres, permeates through the membrane

and is removed as the product from the shell side.

Ultra Filtration (UF) is a unit operation often used to remove suspended solids, colloids,

traces of oil and macro molecules from liquid streams. As pre treatment to reverse

osmosis system. UF significantly increases the membrane life for the R.O. membranes

and reduces the cleaning frequencies, thereby reducing operating expense for R.O.

system.

Over view of Ultra filtration (UF):

Ultra filtration (UF) is a pressure driven unit operation in which particulate, colloids,

emulsified oils, and macro molecules are separated from a liquid feed stream upon

passage through a porous semi permeable membrane. On the separation of size

spectrum, UF falls between Nano filtration (Membrane pore sizes below app 0.01 micro

meter) and micro filtration (pore sizes grater than 1.0 micro meter).

UF has greater removal efficiency and gives higher quality product water.

The UF permeate water from the UF module will then flow to RO feed tank from where

it will be pumped to RO system.

d) Reverse Osmosis System:-

Reverse Osmosis process is a membrane process in which synthetic semi permeable

membranes are used to remove dissolved impurities from water. When a semi

permeable membrane separates a dilute and concentrated solution of slats, due to

osmosis, the water from the dilute solution side passes though the membrane to the

concentrated side till osmotic equilibrium is attained. Any process in excess of the

osmotic pressure reverses the direction of flow of water and water from the

concentrated side enters the dilute side. This process is called the reverse osmosis.

It is very essential to ensure that the water fed to reverse osmosis membranes is free

from particulate matter, scale forming salts Ca & Mg and silica to prevent membrane

fouling. Also, the water should be free from organic matter, heavy metals and oxidising

agents like free chlorine. For that dosing S.M.B.S. and Anti scalant chemicals to the

system.

Capacities:

HRSCC Feed flow rate : 1X 49 m3/hr


MGF Flow rate : 1X 40 m3/hr

UF Feed flow rate : 1X 40 m3/hr

RO Feed flow rate : 1X 40 m3/hr

Recovery : 70%

Permeate flow rate : 1X 28 m3/hr

R.O. permeate is being utilised for cooling water makeup/green belt development

and R.O. reject is being utilised for Brine Saturator. Plant wastes generated are disposed as below in compliance with Hazardous waste

disposal authorization

S.NO WASTE DESCRIPTION DISPOSAL METHOD

1 BRINE SLUDGE

Disposed into lined land fill in

our own premises 2 SATURATOR SLUDGE

3 ALUMINA SLUDGE

FROM PAC PLANT

4 SULPHUR SLUDGE Send to Kovvur SSP plant for

utilized as filler material

5 SPENT V2O5 CATALYST Send to TSDF parawada

32.0 Others

32.1 Hydrogen is filled in individual cylinders as well as in road trucks containing

hydrogen cylinder banks. It is advised not to allow filled road truck rest near the plant

and to send out the filled road truck after finishing formalities as quick as possible.

32.2 Wherever sulphuric acid is handled like in chlorine drying area, it is recommended

to display caution like “WEAR GOGGLES” and ensureit.

32.3 Dyke requirement for Tank farm as per OSID is


OISD (Oil industry Safety Directorate) 118

General;

(a) The tank height shall not exceed one and half times the diameter of the tank

or 20 m whichever is less. For the installations covered under Oil Mines Regulation,

the maximum height of the tank, dyke requirements etc. shall be as per Oil Mines

Regulations

(b) Piping from / to any tank located in a dyked enclosure should not pass

through any other dyked enclosure. Piping connected to tanks should run directly

to outside of dyke to the extent possible to minimise piping within the enclosures.

(c) The minimum distance between a tank shell and the inside toe of the dyke

wall shall not be less than half the height of the tank.

(d) There shall be access on all four sides of each dyke area and roads should be

linked to minimize the effect if one road is cut off during the fire.

This needs to be followed to prevent spigot flow outside the tank farm in case of

leak from the tank.

32.4 21m3x4 Hypo storage tanks are not provided with dyke.

33.Poly Aluminum Chloride (PAC) Manufacturing

33.1 Plant DCS room requires smoke detector. False flooring also requires smoke

detector.

33.2 24x7 AC units are in DCS. Additional AC units are to be provided and no ac is

working more than 8 hours continuously has to be ensured to prevent fire hazard.

33.3 Hcl Storage tank farm: The pumps are inside the dyke. Pumps should be

outside the dyke farm for safety.

33.4 HCl Tank farm dyke capacity is less as against the requirement of 550 M3.

(110% capacity of the largest tank)


33.5 PAC flaking area: Power cable passes from ground floor to the elevated floors.

This poses fire spread through cable tray. Fire retardant paint coating to be provided

to prevent fire spread.

33.6 Road tanker loading area: This area requires safety platform with safety belt

hooking arrangements to prevent accidents –fall from height. Accidents have

happened in Oil tanker filling stations in Petroleum depots due to non-availability of

safe working arrangements

34.0 Chlorine Accidents –Accidents happened else where






Annexure 1



Annexure 2 Training plan 2019

THE ANDHRA SUGARS LIMITED [C & F DIVISION]

SAGGONDA

PROPOSED TRAINING PLAN -2019

HR– F 001/ REV: 02/Dt.01-11-2017

SL.

No Name of the Training Programme

Faculty of Dept

Schedule Targeted

Manpower

1. Operating personnel safety regarding personal protection and emergency action

Safety / Chemical January 40

2. Chlorine leaks handling Safety / Chemical January 30

3. Hydrogen gas cylinders safety Safety / Chemical February 40

4. Operation and maintenance of plants in co-

ordination with other plants and departments

Chemical February 35

5. Training programme for truck drivers on

defensive driving

Safety March 50

6. Static Electricity hazards – Preventive measures Electrical / Safety March 40

7. Personal Protective Equipment Safety March 50

8. Chlorine cylinder filling and handling safety Safety / chemical March 40

9. First aid Dr. J. Bhanu

Prasad

March 30

10. Maintenance of Transformers Electrical March 25

11. Lubrication oil & grease to various pumps and

gear boxes

Mechanical March 35

12. Confined space entry Safety / Chemical April 30

13. Material handling Safety / Chemical April 40

14. Personal protective equipment electrical Electrical May 40

15. Effect of Brine Plant disturbances on

Electrolysis

Chemical May 30

16. Personal Protective Equipment Safety June 40

17. Safety during Chlorine cylinder filling Chemical /

Safety

June 40


18. Coupling alignment of pumps Mechanical June 20

19. Fire prevention system Safety July 30

20. Operation of different types of Pumps Mechanical July 30

21. Training programme for truck drivers on safe

transportation of Hazardous chemical

Safety / Admin August 50

22. Chemical process control Chemical/Inst August 40

23. Work permit system Safety September 40

24. Electrical Switch gears Electrical September 35

25. Chlorine leak handling Safety / Chemical October 20

26. Contract work men safety Safety / admin October 60

27. Maintenance of Motors Electrical October 25

28. Use of fire Extinguishers Safety November 50

29. Personal protective equipment Safety November 50

30. Mechanical shaft seals Mechanical November 35

31. Electrical safety Electrical December 30

32. Scaffoldings Arrangement for maintenance

works

Safety /

Mechanical

December 30

33. Variable frequency drive (VFD) Electrical December 40


Annexure 3 Preventive maintenance check list -Escape Breathing Apparatus


C&F DIVISION, SAGGONDA

PREVENTIVE MAINTENANCE CHECK LIST

EMERGENCY LIFE /ESCAPE BREATHING APPARATUS

FORMAT NO: SFTY – F 001

FREQUENCY: MONTHLY DATE:

Ta

g

No

.

LOCATIO

N

Cylinder Condition of Sign of

plant

person

Remark

s

No. H.T

Due

Pres-

sure

Bar

Loc

k

clip

Cylinde

r Valve

Should

er

Strap

Pr.

Gau

ge

Face

mask

Hose

&hose

connectio

n

condition

1 LH2 plant ELBA

2 LH2 plant ELBA

3 LH2 plant EEBA

4 LH2 plant EEBA

3 CL2 filling EEBA

4 CL2 filling EEBA

5 CL2 filling EEBA

6 Cl2

compress

or

EEBA

7 Cl2

compress

or

EEBA

8 Time

office

ELBA

9 Time

office

ELBA

10 Cell

house

EEBA

11 Cell

house

EEBA

12 DCS EEBA

13 DCS EEBA


Annexure 4 SCBA Preventive Maintenance Check list


C&F DIVISION, SAGGONDA PREVENTIVE MAINTENANCE CHECK LIST

SELF CONTAINED BREATHING APPARATUS FORMAT NO:SFTY – F001 FREQUENCY: MONTHLY DATE:

Ta

g

N

o.

LOCATI

ON

Cylinder Condition of Condition of

Face Mask

Rem

arks /

Sign

of

plant

perso

n

N

o

.

H.

T

D

u

e

Pre

s--

sur

e

Ba

ck

Pla

te

De

ma

nd

Valv

e

Cyl

.

Str

ap

Ass

ly.

Wa

ist

Bel

t

Buc

kle

set

Shoul

der

Strap

Shoulde

r

Adjusta

ble

Strap

Pr.

Gau

ge

Wh

is-

tle

Glas

s

Head

Band

1 HCL

plant

2 HCL

plant

3 CL2

filling

4 CL2

filling

5 CL2

filling

6 Cl2

compre

ssor

7 Time

office

8 Time

office

9 Cell

house

10 Cell

house

11 Cell

house

12 DCS

13 Acid

plant

14 Acid

plant

15 LH2

plant


Annexure 5 : Mock drill report


Chemical & Fertilizers Division

SAGGONDA-534 318

REPORT ON THE MOCK DRILL – REHEARSING ON-SITE EMERGENCY PLAN DATED

24th APRIL, 2019

Mock drill of the On-site Emergency plan, on-field exercise was conducted in the Factory

premises on Wednesday, 24th April, 2019, during surprised visit of Dy. Chief Inspector of

factories and Inspector of factories, Eluru and witnessed the mock drill as observers.

PREPARATORY MEASURES

Prior to this mock drill, Oral information by phone from personnel manager to the key

persons on the day on ‘Emergency preparedness and response‘ arranged to line

supervisors for mock drill on chlorine and exact time will be announced later.

ACCIDENT SCENARIO

Liquid Chlorine leak from ‘OUTLET LINE OF D710’B’ STORAGE TANK.’

The following persons has participated in the Mock Drill and following rolls.

Works main controller Mr. G. Ramesh

Manager (Personnel) Mr. M. Srinivas

(Observer accompanying to Dy. chief inspector of factories)

Safety in-charge Mr. T.V. Subba Rao

Works incident controller Mr. K.V. Subba Rao

Emergency communication Mr. M. Prasannakumar

Off site Measures Mr. V.V.S. Kishore kumar

Mr. R.V.V.S.N. Murthy

Chemical Department Mr. B.V.K. Prasad

Mr. B. Malleswararao

Mechanical Department Mr. M. Durga Nagendra

Mr. L. Vasu Deva Rao

Mr. P.V. Manikanta


Electrical Department Mr. G.U. Bhaskararao

Mr. CH.V.B.A. Siva kumar

Mr. T. Rama Mohan

Mr. M. Satish

Civil Department Mr. N. Lokesh

Search& rescue Team Mr. V. Ramakrishna

Mr. G. Elisha

Mr. K. Srinivas

Mr. MD. Alam

Electronics Mr. P. Rama Krishna

Medical Mr. Y. Mohan Kumar

Head Count Mr. N.V.V. Srinivasarao

Observers Mr. R. Prasad Kumar

Mr. B. Suresh

MOCK DRILL:

Initially instrument department people activated the chlorine sensor in chlorine storage

tanks.

Mock drill was commenced at 3.45 PM.

FIRST RESPONDENTS:

3.45 PM DCS Operating People Informed to Chlorine plant Chemist over Phone,

regarding chlorine sensor alarm sounding at Chlorine Storage Tanks.

3.46 PM DCS in-charge communicated the information to neighboring HCL plant

chemist, H2SO4 Plant chemist and hydrogen bottling people and

Department head (Works main controller), works incident controller and

Manager (Personnel) about the incident.

3.47 PM As per prior instructions of Manager (Personnel), Security staff stopped the

Vehicular traffic in side the Factory premises. Truck operators were sent to

safe area.

3.47 PM Chemist and Fitter wearing SCBA sets rushed to the Chlorine storage tanks area

to investigate location, source and size of leak.


3.47 PM Works incident controller observed wind direction and cautioned the down

stream people.

3.52 PM Chlorine plant chemist informed the preliminary investigation details to Works

incident controller and Works main controller. Chlorine leak observed at

outlet pipe line of D710 ”B” storage tank.

WIND DIRECTION

Prevailing wind direction found towards the North-west side and likely

affected places will be Factory main gate, Time Office, lorry yard and PAC

plant etc.

3.54 PM Works main controller instructed DCS in-charge to make announcement for

all key persons to assemble at Emergency control room.

3.55 PM Announcements are made in PA system thrice stating- “Attention please,

Mock Drill, Chlorine leak at Chlorine Storage Tanks, key persons to assemble

at emergency control room located at the Hcl plant Chemist Room.”

KEY PERSONS RESPONSE

Response timings of Key persons to Emergency control room are noted.

Works Main Controller 4.00 PM A.E (Instrumentation) 3.58 PM

Safety In charge 4.00 PM J. E (Civil) 4.02 PM

A.C.E. Engineer 3.59 PM Electrical Engineer 3.58 PM

Works incident controller 3.59 PM Sr. Supervisor (Electronics) 4.00 PM

DISCUSSIONS IN EMERGENCY CONTROL ROOM:

4.02 PM Works main controller fed accurate information regarding chlorine leak to

the key persons.

4.03 PM Works main controller taken decision to bring ON-SITE EMERGENCY in to

force.

4.03 PM As per the instructions of Works main controller time keeper sounded

emergency siren.

Following decisions were derived after discussion.

Mechanical Department to try to arrest the chlorine leak.

Chemical Department to Stop the plant and arrange content transfer.

Electrical Department to provide facilities as needed by WIC.


Electronics Department to make announcements in P.A. System.

Instrument Department to communicate information to management and

mutual aid industries.

Safety department to arrange necessary PPE’s.

PUBLIC ANNOUNCEMENT CENTRE:

Electronics supervisor started to make announcements continuously at 5 min. time

intervals regarding mock-drill and escape routes until the normalcy restored as

per instructions of works main controller.

SEARCH & RESCUE:

4.03 PM As per instructions of Manager (Personnel), Two Security guards performed

search and rescue operations. They bought one victim from chlorine storage

tanks area; first aid was given in the ambulance van and shifted the victim

to O.H.C.

PERSONNEL EVACUATION:

4.04 PM As per instructions of Manager (Personnel), Security staff started evacuation

with the help of Hand mikes from East side to the Assemble Point No-2&3

located at caustic lye loading and LH2 Plant.

4.22 PM Head counts were taken by the Time keeper 25 persons were evacuated.

Enquiries were made about the persons not found at surrounding areas.

EMERGENCY COMMUNICATION CENTRE:

4.04 PM Instrument department has set up emergency communication centre and

communicated the information to the top executives of the industry, other

units of ASL group, Mutual-aid industries and VRO & President of the neighbor

village.

ON- SITE EMERGENCY ACTIONS:

4.05 PM As per instructions of works main controller, Chlorine plant chemist and Fitter

went to the Chlorine filling points and diverted the liquid chlorine from the

common filling header to DC Header Through five empty Chlorine tonners

at a common header pressure of 9.5 Kg/cm2.

4.04 PM Works incident controller, Safety in-charge and support teams reached the

designated Base camp, East side of Chlorine storage tanks.


4.06 PM Plant chemist and Mechanical supervisor examined the location of leak

spot.

4.07 PM Works incident controller examined the leak spot and leak severity.

4.08 PM As per instructions of works incident controller, Electrical Department

arranged a pedestal fan near the leak spot.

4.09 PM The Header pressure came down to 7.0 Kg/cm2 only, so as per instructions of

Works main controller, diversion points are increased to five numbers.

4.10 PM Then header pressure dropped to 4 Kg/cm2.

4.11 PM Mechanical people went to leak spot and removed the insulation. And

found leak spot is at horizontal pipe.

4.12 PM As per instructions of works incident controller, Mechanical people arranged

clamp to rectify the leak. Leak got controlled.

4.13 PM Works incident controller and chemist went to leak spot and examined and

found no chlorine coming out.

4.14 PM Works incident controller reported to works main controller that leak control

measures are completed.

4.15PM Civil department persons supplied few bags of lime powder for making

containment and neutralization of liquid chlorine spill.

OFF-SITE MEASURES:

4.10 PM Electrical Engineer and A.E Chemical with gas masks, Chlorine gas monitor

and walkie-talkie traveled on vehicle along the wind direction (path) to a

distance about 1.5 kilometers to estimate the off-site effects. They identified

no effect around the factory. They communicated their observations at

different places to the works main controller.

POST EMERGENCY MEASURES:

4.22 PM Works main controller and key persons reached to Chlorine Leakage area

and reviewed the accident scenario and effectiveness of the emergency

actions performed.

4.23 PM Works main controller after conforming that leak was totally controlled,

made declaration on lifting the On-site emergency.

4.27 PM Time keeper sounded ALL CLEAR siren for 30 seconds.

4.28 PM DCS in-charge made announcements twice in the PA system


stating.“Mockdrill is over, On-site emergency is lifted and normalcy was

restored in the Factory.”

4.29 PM Evacuated plant personnel were sent back to the respective work places.

4.30 PM Vehicular movement is allowed inside the Factory.

OBSERVATIONS:

1. Time taken for preliminary investigation 07 Min.

2. Time taken for announcement after preliminary Investigation 03Min.

3. Time taken for key persons to assemble at Emergency control Room

after announcement

Works main controller 05 Min.

Works incident controller 03 Min.

Safety in charge 05 Min.

Add. C. E. E 04 Min.

Electrical Engineer 03 Min.

A.E Instrumentation 03 Min.

J.E (civil) 07 Min.

Sr. Supervisor (Electronics) 05 Min.

Time taken for rescue operation from Announcement 08 Min.

Time taken for evacuation from Announcement 09 Min.

Leak rectification work starting after observation of leak 27 Min.

Total time for all clear 45 Min.

REMARKS:

For mock drill operations 10 numbers SCBA sets were utilized

(Chemical-3 No’s, Mechanical- 3 No’s, Electrical- 2 No’s, Rescue

team- 2 No’s) and total 4 No’s of air cylinders are fully consumed and

6 no’s of air cylinders consumed partially.

10 No’s canister masks are used for this Mock Drill.

SUM-UP MEETING

At 4.50 PM Dy. Chief inspector of Factories and all the key persons and other

participants of the Mock drill were met in the Conference hall. Mock drill

performance event wise reviewed with the participants.


Dy. Chief Inspector of Factories was mentioned that the MOCK DRILL

performance was satisfactory, co-ordination is good and it is to be further

improved to minimize the lapses and time gap.

Deputy Chief Inspector of factories gave following suggestions:

1. Sequence of mock drill to be reviewed.

2. Mock drill should be conducted in realistic way, all departments has to act as per

requirement in consultation with incident controller/main works controller to reduce

the time taken.

3. Following teams separately to be formed for meeting emergencies.

a) Rescue team

b) Fire fighting and First aid teams

d) CL2 and H2 Mitigation teams

4. Monitoring the wind direction shall be continuous and rescue operations to be done

as per it, Announcement to be done to guide people into escape routes as per it.

*********************************

Annexure 6

UPS systems with VRLA batteries require the following for safety and fire prevention.

Several accidents happened in other units resulting in huge loss of property.

-Batteries life has to be monitored and replaced as per manufacturer’s

recommendations. Normally it is of 5 years. Plant maintains separate

register for this.

Room temperature has to be 25*C. Every 5*C rise in temperature will

reduce life of batteries by half.

Regular inspection of batteries for bulging is practiced in the

plant. UPS battery stand has to be earthed.

Flame proof equipments, light, switches are to be used.


Annexure 7 Management of change key points

Plant modification: following table provides the checklist for plant modification may

be used.

S.No Description

1.0 Design

1.1 Standard code for designing

1.2 Adequate anchoring of equipment and

structures

1.3 Process flow and PID made, necessary

changes on the existing PID is suitably

modified after Hazop

1.4 New EMP & OHS and SMP need to be

identified and addressed

1.5 Process adequacy verified

1.6 Responsibility enters for engineering data

sheet identified.

1.7 Mechanical structural design and its

adequacy checked

2.0 Electrical

2.1 Hazard classification for electrical fittings

2.2 Lock out provision

2.3 Clear access for emergency switches

2.4 Provide proper signs for switch

boards/panels

2.5 Proper grounding of the equipment

2.6 All the static electricity earthing provisions

are made

3.0 Safety regulations

3.1 Design of pressure vessel/ piping

3.2 Pressure relief devices to be provided


3.3 Obtain test certificate from manufacturer /

competent authority

3.4 PG’s & TG’s to be fixed in proper place

3.5 Hot surfaces to be insulated

3.6 Safety interlock built in safety system are

study in conjunctions with operating /

existing system and it’s satisfactory.

4.0 Operation procedure

4.1 Explain operational procedure, safety

aspects

4.2 SOP to be prepared

4.3 Present operation manuals to be modified

5.0 Work area

5.1 Access for operation and maintenance

5.2 Free from toxic, dust or fumes

5.3 Proper colour to be done

5.4 Noise control to be ensure

5.5 Eye wash and shower provided

5.6 Adequate lighting provided

5.7 Adequate ventilation provided

5.8 Direction of flow marked

5.9 Fire extinguishers and fire hydrants

5.10 Proper drainage provided

5.11 Hand railings, stairways, wall ways

5.12 Display of proper boards

6.0 Guarding

6.1 Protection of moving parts of machine

6.2 Guards provided for transmission parts

7.0 Any other

7.1 Spare parts needs to be addressed


8.0 Insurance

8.1 Appropriate values are increased in

insurance policy

8.2 Said modification does not result in any

insurance warranty (condition) breach or

increase in premium rates

Date post:	22-Jan-2023
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