prefeasibilityreport for environmental clearanceproposed...

Prefeasibility Report M/s ETERNIS Fine Chemicals Limited, MIDC Kurkumbh, Daund, Pune, MS1

PREFEASIBILITYREPORT FOR

ENVIRONMENTAL CLEARANCEPROPOSED

• Capacity Expansion of Existing Products & By-products.

• Addition of Similar Products & By-products.

• Introduction of New Eco-friendly Boiler. • Addition of MIDC Plot. • Change in Name

AT

Eternis Fine Chemicals Limited Plot D- 9/1, D- 9/2, D- 9/3 &D- 15 MIDC Kurkumbh,Tal-Daund, Dist-Pune, Maharashtra 413802


INDEX

# CONTENTS PAGENO.

1 Introduction 2

2 Justification 7

3 Location 8

4 Resources 9

5 Process 14

6 PollutionControl 20

7 BackgroundStudy 26

8 Safety 28

9 Benefits 29

10 EIAStructure 31

11 Conclusion 32


1. INTRODUCTION

Eternis Fine Chemicals Limited, (here-in-after referred to as “EFCIL”) was erstwhile known as Hindustan Polyamides &Fibres Ltd. The change of name is desired for homogenization of business expansion around the globe. This change is duly informed to various Authorities like: (1) Secretiate of Companies. (2) District Authorities. (3) Maharashtra Industrial Development Corporation (MIDC). (4) Maharashtra Pollution Control Board (MPCB) (5) Directorate of Industrial Safety & Health (DIHS) EFCIL,is a Manufacturer-Exporter of fragrance ingredients. We are catering mainly to international customers spread over 20 countries globally. 80-85% of the company’s turnover comes from exports. Our export performance and foreign exchange earnings have been recognized by Government of India, by awarding us the status of “Three Star Export House”. We enjoy the reputation of preferred supplier with most of the top fragrance companies in the world. The present manufacturing activity at this site of 15 products and 8 by-products is with due consent from MPCB, which has been renewed from time to time: and SEIAA’s prior Environmental Clearance, (EC) for manufacturing fragrance ingredients upto to 42,200 TPA and by-products 11,400 TPA. This is valid upto 02 September 2017. Further EFCIL plans to expand its product portfolio and also increase its global market share in the existing products significantly. This will increase the production capacity upto 60,000 TPA (about 42 %) and by-products up to 20,000 TPA. As part of the sustainability initiatives, EFCIL has planned to replace fossil fuels like Furnace Oil with environmentally friendly bio-mass based fuels for its steam requirements by commissioning a bio-mass boiler in the unit for its additional requirement of steam. TheNotificationno.S.O.3067(E)as

amendedon1stDecember2009hascoveredthistypeofindustriesunderitsentry shown as 5(f) Synthetic Organic Chemicals with Category (B). WithScreeningitisnecessaryforus toapproachSEIAA, Maharashtra who are authorized by MinistryofEnvironmentandForests(MoEF),NewDelhiforEnvironmentalClearanceforth i s unit.ThisPre-feasibilityReportispreparedforformingaframeworkfor EIAstudy,ScopingandfinalizingtheTermsofReference. FormI,asisprescribedbythesaidNotificationisdulyfilledupandsubmitted.ThisPre-feasibilityReportisanaccompanimenttothesame.TheFormIcontainsdetailsregardingJustificationoftheproject,NearbyLandUse,Resources,Process,PollutionControl,Aesthetics,RiskInvolved,ConsequentDevelopmentsandEnvironmentalSensitiveIssues.


Need of the project:

This is a specialty chemical used as fragrance in cosmetics. Some of the products were prepared in India for 1st time and as an export substitute also. EFCIL has its own product R&D facility enabling it to search for product range and it’s launching in global market. These products are essentialcomponents in soap,detergent,cosmetics, shampoos,skincare, fragrance, flavor,food;beverage formulations. With completion of the project EFCIL shall achieve a very strong base in global market in turn to get precious foreignexchange for our country and it will enhance India’s position of foreignexchange reserves. Project involves manufacturing of fragrance from organic raw materials by chemical process like Hydrogenation, Esterification, Diels-Alder reaction, Cyclisation, Dehydrogenation, Aldol condensation etc. following by distillation to match precise quality standards. The FINISHED PRODUCTS will be:

a) 15 Existing and b) 26 Proposed in the same family

# Name of Product # Name of Product

1

Para /Ortho Tertiary Butyl Cyclohexanol , Para /Ortho Tertiary Butyl Cyclohexyl Acetate & Para /Ortho Tertiary Butyl Cyclohexyl Acetate Super ( PTBCHA/OTBCHA)

22 Gamma Methyl Ionone/ Methyl Ionone Alpha Iso

2 Styrallyl Acetate 23

Gamma Lactones ( Undeca, Deca, Nona)

3 3,3,5 TrimethylCyclohexyl Salicylate or Homosalate USP

24 1-oxacyclohexadec-12-en-2-one

4

Methyl-3-oxo-2-pentyl-1-cyclopentane acetate / Methyl DihydroJasmonate/ Methyl DihydroJasmonate – High Cis

25 Hydrogen

5

Phenyl Ethyl Alcohol or Beta Phenyl Ethyl Alcohol/ Methoxy Ethyl Phenol/ Phenyl Ethyl Acetate / Phenyl Ethyl Methyl Ether

26 2-(2-methylbutan-2-yl)cyclohexyl) acetate

6 Linayl Acetate 27 Benzyl Salicylate 7 Phenyl Hexanol 28 Hexyl Salicylate 8 3,3,5 TrimethylCyclohexanol 29 Benzyl Acetate

9 Dihydromyrcenol 30 2-(1-(3,3-dimethylcyclohexyl)ethoxy)-2-methylpropyl propionate

10 4-Isopropyl Cyclohexyl Methanol 31

Amyl Salicylate

11 L Menthol/5-methyl-2-propan-2-ylcyclohexan-1-ol

32 Hexyl Acetate

12 1-Methyl-2-(1,2,2-trimethyl[3.1.0]hex-3-ylmethyl)cyclopropyl]methanol

33 Cyclopentadecanolide


13 Linalool/Tetrahydra Linalool 34 Alpha Hexyl Cinnamaldehdyeand OR Hexyl Cinnamic Aldehyde (HCA)

14

Hamber OR (7-acetyl-1,2,3,4,5,6,7,8- Octahydro 1,1,6,7 – Tetramethyl Naphthalene) OR Hamber Premium

35 Salicylaldehyde or 2-Hydroxy Benzaldehdye or Ortho hydroxyl benzaldehyde

15 3-ethoxy-1,1,5-trimethylcyclohexane

36 Vanillin / Ethyl Vanillin

16 2-cyclohexylidene-2-phenylacetonitrile

37 2-methyl Undecanal/Aldehyde C12 MNA

17 3a,6,6,9a-Tetramethyldodecahydronaphtho[2,1-b]furan

38 2,6,6-trimethylcyclohexa-1,3-diene-1-carbaldehyde

18 Isobutyl Hydroxy – 4 Methyl TetrahydroPyran

39 Cyclamen Aldehyde- Pure

19 6-Tertiary Butyl -2- Methyl Phenol 40 Lilial or Para Tertiary Butyl Alpha Methyl DihyroCinamaldehdye

20

Galaxolide or 1,3,4,6,7,8 – Hyxahydro – 4,6,6,7,8,8 – Hexa Methyl Cyclopenta- Gamma-2-Benzo Pyran/HHCB

41 Other Similar Ingredients

21 Coumarin or 1.2 Benzopyrone Summary:

# Family Existing Existing with Modification

New Total

1 Acetate 4 0 0 4 2 Alcohol 3 0 3 6

3 Ketone 1 0 4 5

4 Ester 1 2 5 8

5 Aldehyde 1 1 5 7 6 Others 1 1 8 10

7 Hydrogen 1 0 0 1

total 12 4 25 41

BY – PRODUCTS will be :Dilute Acids,Low Purity Distilled Products,Technical

Grade of respective products, Recovered Solvents, Recovered PE-PCP Mixture,

andRecovered Salt. Some of these by products will be used internally while some

have market outside.

Being focused on sustainability, EFCIL desire to take following steps –

(1) Implementation of GREEN fuel technology in which biomass brequites will

be used to produce the steam required for the process. This is to reduce the

consumption of fossil fuel producing GHG.

(2) Attending the conditions laid in EC and Consents with special efforts for:

# Condition Regarding


1 3 (iv) Use sprinkling

2 (vii) Proper housekeeping

3 (xv) Green belt 4 5 (xviii) Protect fire

5 (xxi) Mock drill

6 (xxiii) Care of ash 7 17 Avoid Nuisance in surrounding

8 19 Good housekeeping

9 20 Green belt 33% 10 23 Around factory –clean. Fugitive.


2. JUSTIFICATION& NEED EFCIL has established strong relationship with all the main F & F global player –

with some of them for more than 20 years & in some products enjoy 60-100%

share. EFCIL has established its creditability with custom thro’-

(1) Specialization in chemistry particularly hydrogenation (in which the group is a

pioneer in India) & esterification.

(2) Specialization in meeting verifying olfactory needs of the customer-a very key

parameter unique to this industry.

(3) Ability to expand capacities rapidly through speedy execution of projects &

international standard equipment design capability-capacity increased from

around 42,200 TPA in the year 2012.

(4) Ability to offer product ranges at competitive prices due to lower cost base &

high manpower productivity.Ability to offer customized solution based in

customer needs.

(5) Strong R & D skills with state of art modern facility which enables

development of all processes in- house ahead of competition (so far almost

all our product are based on processes developed in house-‘Government

recognized in- house R&D).

(6) Strong Supply chain including 100%captive hydrogen generation plant and

tie-ups with international suppliers.

(7) Strong focus on Environment, Health & Safety (EHS) to meet international

customer requirements/Social accountability (SA 8000) Audit and C-TPAT

compliance.


3. LOCATION EFCIL has a full fledge manufacturing activity established at a D-9/1, D-9/2 & D-

15,M.I.D.C. area, Kurkumbh Tal. Daund, Dist. Pune. Present vacant plot has

sufficient place to expansion of the plant. The land requirement for proposed

industry unit is already in possession and is not Prime Agricultural Land. This is

flat Land whereby Cutting-filling will be balanced and there will be No/Low

Borrowing from Nature. This land is shown on Topo sheet no. 47/J11 and bears

Latitude 180 23 ’ 54.7 ”N , Longitude 740 31 ‘ 27.04 “ E

M.I.D.C. area, Kurkumbh, Tal:.Daund,Dist. Pune is located on national high-way

NH-9 from Pune to Solapur around,75 KM away from Pune city.

Within 10 km Influence Zone, there is no Tropical Forest, BiosphereReserve,

National Park, Wild Life sanctuary and Coral Formation Reserve. The irrigation

Dam, City Pune, Daund, Railway line, and National Highway have good

connectivity. The Clearance is obtained from MIDC.

Kurkumbh M.I.D.C. is at the extreme east side of Pune District. By and large the

area is plain with nature slope towards south east.


4. RESOURCES

Raw materials. In all 103 raw materials are used, 48 for the present products and the remaining

for the proposed products that are to be introduced for the first time, now. The

distribution is –

Physical State of Raw Materials:

# State Present products New products Total

1 Powder 2 -- 2 2 Solid 9 14 23 3 Liquid 37 41 78 4 Gas -- -- 0 Total 48 55 103

As powdery form is very limited, fugitive emission is not a problem. As no gasis used as raw material, handling is easier and emission control equipments are required only for the gases produced during the processing. Chemical State of Raw Materials:


1 Organic 25 33 58 2 Inorganic 23 22 45

Total 48 55 103

The liquids are in majority organic in nature and suitable for bio-oxidation

treatment. The ETP is designed to take this. The liquid do not involve any heavy

metals or inorganics or Cyanide CN. The toxicity is examined from all available

MSDS. We find –

Specified Toxicity of Raw Materials: # State LD50 Present

products New products Total

1 Extremely toxic <5 0 0 0

2 Highly toxic 5-50 0 0 0 3 Toxic 50-200 1 5 6 (*) 4 Non-toxic >200 32 38 70 Total 33 33 76

(*) These are Benzyl Chloride, Lithium Aluminium Hydride Or Borane, Ethyl Chloroacetate, Diethyl Sulphate, Allyl Alcohol, and Ortho Cresol. The total volume of these six chemicals is 1.5 % only of the total raw material consumption.


Specified Odor status of Raw Materials:


1 Odorless 5 10 15 2 Sweet 20 30 50 3 Pungent, strong 9 11 20 (*) 4 Characteristic 5 8 13 Total 39 59 98

MSDS also gives details on odour, where relevant. The product is used as fragrance. The total volume of these 20 (*) chemicals is 0.5 % of the total raw material consumption. However overall this is an aromatic specialty chemicals and foul-odor is not a problem faced. All 41 products are sweet in odor. Water Solubility status of Raw Materials is such that the soluble component is more, the non-soluble part creates problem of solid waste and fugitiveswhich is lesser here. Use of Raw Materials:

# Use Present products New products Total

1 Reactants 30 43 73 2 Solvents 3 5 8

3 Catalysts 2 4 6

4 Work-up chemicals 7 9 16

Total 42 61 103

Only one of the raw materials is in the names of hazardous chemicals havingthreshold limit needing accident emergency preparedness (Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 as amended). This is Hydrogen which is used as a helping chemical for hydrogenation. This is manufactured inside the campus and therefore the inventory is very small and much less then as specified in the rules. If there are trials of new molecules, then watch may be kept on such development right from R & D laboratory experiments itself.

Utilities: In addition to the raw material, utilities are also required. These are additionally: (1) Power: Need 12000KVA available through Govt. Electricity Board. (2) Man Power: Staff, Skilled and Unskilled totally 220 persons already available.

Additional manpower required is 160 numbers. (3) Water Need is about 1152cum/d and shall be met fromMIDC supply. (4) Steam requirement 25TPH for total expansion of unit can be met from green

fuel boilers of 12.5 TPH each (two numbers) as proposed.

A) Fuel:

# Type Tonnes Per Annum (TPA)


1 Biomass Briquettes 26,280

2 HSD (High Speed Diesel) 600 only for stand-by DG Sets. 3 FO (Furnace Oil) 4380 4 LDO (Light Diesel Oil) 150

B) Stacks:

#

Type

TPH

Stack

1 Biomass Briquette Boiler

10.5 1 of 30 meters after bag filter.

2 Furnace Oil Boiler

1 x 2.5 1 x 2.8 1 x 4.5 2 x 4.5

1 of 30 meters (only for standby) 1 of 30 meters 1 of 30 meters (only for standby) 2 of 30 meters each

3 Thermic Fluid Heater

1 x 3 lac Kcal/hr. 3 x 6 lac Kcal/hr.

3 of 30 meters 1 of 30 meters

In addition Process Vents are provided (15 numbers) to control fugitives

emissions. Thermic Fluid heaters are non IBR gadgets.

C) DG Sets:

#

Capacity

Numbers

1 100 KVA 1

2 160 KVA 1

3 250 KVA 2

4 500 KVA 10 (6 existing &4 proposed)

D) Storage Tanks are existing. These will be optimized and added as necessary, and care is taken regarding storage of raw materials, solvent, fuels as enough space between tanks in tank farmProper illumination on street and in plant. Response care is taken as follows: i. Proper colour code to tanks and pipe lines, gas lines. ii. Proper bonding and earthing to all metal flange joints of tanks to

conduct and remove all static charges. iii. Fixation of rigid and permanent lightening conductors to tanks. iv. Fixation of flame arresters to needed vessels. v. Fixation of visible gauges to bulk storage vessels. vi. Proper quality of gaskets and their fastening at right place. vii. Calibration of all tanks and their display. viii. Proper and timely labeling of all material during process and handling. ix. Proper loading and unloading system to solvents, fuels. x. Proper rigid shade for gas cylinders to avoid direct sun light, storm, rain etc. xi. Strict follow up for Gas Cylinder Rules.


xii. No fuel / liquid / solvents transfer, loading / unloading during 18.00 to 06.00 hours from bulk store and tank farm area to process area, without Work Permit.

E )Building materials: This is not a heavy construction, and majority is in fabrication from Mild steel structural. The orientation is so kept as to balance nearly the cutting and filling. The small requirement is available systematically. The construction -erection time willbe small and will be done in daytime. Labor camp is not necessary. # Particulars Existing Addition Total

1 Plot Area (SQM) 75800 24600 100400 2 Total Built Up Area (SQM) 29900 12810 42710 F )Plant and equipments are also needed as:

# Equipment

1 Gas-inducing Hydrogenators, 500 psig

2 High pressure Hydrogenator, 1000 psig

3 SS316 Reaction Vessels of different capacities

4 Storage tanks of different capacities

5 High Vacuum Batch Distillations

6 Sulzerpackings, 500 mm - 2 m dia.

7 Continuous Distillation column — Sulzer, 900 mm dia.

8 Wipe film Evaporators

9 Falling film Evaporators

10 Vacuum Pumps — Busch & Beach-Russ

11 Reactive distillation systems

12 Glass Lined Reactors — 2 m 3 -8 m 3

13 Helical Ribbon Reactor — 8 m 3

14 Continuous Hydrogen generation plant from Mahler

15 Automation control systems

16 Calendrias

17 Vapor separator

18 Pumps

19 Preheaters

20 Condensers

21 Salt settlers

22 Centrifuge


G )Total Cost for proposed project will be Rs. 105.00 Crores. Out of this for environment protection Rs. 15 crores will be spent as capital expenditure and Rs. 5Crores/ annum is earmarked for Operation & Maintenance.

Thus all the resources are available and will be used economically and judiciously.


5. PROCESS

Products:

Here the unit produces in all fourteen routine products (with one supporting product which is locally required for hydrogenation) and in similar families twenty six more new molecules are introduced in the same line of chemicals. Seven by-products are presently identified which otherwise would have gone as a waste and creating a waste burden. With additional products also these by-products will continue. However, now two of them are to be entered into the regime of Hazardous Waste as per new policy of MPCB. We note that the product is such as does not have any seasonal preferences. The three shifts are equally engaged in production. As such the situation is favorable since the effluent load on ETP (as also on emission control equipments and Hazardous waste handling) is generally uniform and no shocks on microbial culture presently (at least post-equalization). If in future, there is some change in this product mix, watch will be kept on such development right from R & D trials. The present all products are carbohydrates of simpler type with only C, H and O atoms. The proposed 26 also are in the same family and are also simple carbohydrates thus –

# Common name Formula Odor Application

1 Benzyl salicylate

C14 H12 O3 Sweet, floral For fruity, floral fragrance

2 Hamber C16 H26 O Woody, floral Fascination 3 OTBCHA C12 H22 O2 Fruity citrus Toilet soaps 4 OTBCH C10 H20 O Pine-like, minty Perfumery 5 PTBCHA C12 H22 O2 Sweet, creamy Low cost blender 6 PTBCH C10 H20 O Pine-like,

balsamic intermediate

7 PTBCHA Super C12 H22 O2 Sweet, creamy Blender to countless. 8 Styrallyl acetate C10 H12 O2 Green, musty Base of perfumery

Summary of production can be stated as – # Name MTY MTY

1 Present 15 products at present level 42200 2 Present 15 products at increased level with

Proposed 26 products at introduced level 60000

3 Present by- products at present level 11400 4 Present by-products at increased level with

Proposed by-products at introduced level 20000

Total 53600 80000

The summary can be given in another form as – # Family Existing Existing with

Modification New Total

1 Acetate 4 0 0 4 2 Alcohol 3 0 3 6

3 Ketone 1 0 4 5

4 Ester 1 2 5 8


5 Aldehyde 1 1 5 7 6 Others 1 1 8 10

7 Hydrogen 1 0 0 1

total 12 4 25 41

The summary can be given in yet another form as –

# Predominant process Existing New Total

1 Hydrogenation 2 2 4

2 Esterification 2 4 6 3 Hydrogenation + Esterification 3 3 6

4 Condensation 2 3 5

5 Oxidation 0 3 3

6 Cyclization 1 8 9 7 Other 2 6 8

Total 12 29 41

Our present working is being repeated in majority of the proposed products as well. Our workers therefore have experience in dealing with it with ease. In the past, the industry has not taken any liberty of overstepping the consented production limits. We will continue the same discipline.

Synopsis of manufacturing Process:

# Product Steps to get final product

1 3,3,5 TrimethylCyclohexanol

Isophorone is hydrogenated

2 Homosalate USP OR 3,3,5 TrimethylCyclohexyl Salicylate

3,3,5-trimethyl cyclohexanol reacted with Methyl salicylate.

3 Coumarin or 1.2 Benzopyrone

Salicylaldehyde and acetic anhydride are reacted.

4 Hexyl Salicylate 1-hexanol and methyl salicylate are reated.

5 Phenyl Ethyl Acetate / Phenyl Ethyl Methyl Ether / Methoxy Ethyl Phenol

Phenylethylalchol and acetic acid reacted in presence of a acidic catalyst

6 Vanillin / Ethyl Vanillin

1) Cataecholconveretd in to guiacol by reacting with dimethyl sulphate or dimethyl carbonate,

2) Guaiacol is then reacted with glyoxylic acid and 3) then oxidized


7

Methyl-3-oxo-2-pentyl-1-cyclopentane acetate / Methyl DihydroJasmonate/ Methyl DihydroJasmonate – High Cis

(1) Methyl dihydrojasmonate is brominated and debrominated

(2) selective hydrogenation

8 Phenyl Hexanol (1) Reacting benzaldehyde and isoprenol (2) Hydrogenation.

9 3a,6,6,9a-Tetramethyldodecahydronaphtho[2,1-b]furan

(1) Oxidative degradation of Sclareol to a lactone (2) Hydrogenation and dehydrogenation .

10 2-(2-methylbutan-2-yl)cyclohexyl) acetate

(1) 2-tertiary butyl phenol is hydrogenated (2) Esterified with acetic anhydride

11

Salicylaldehyde or 2-Hydroxy Benzaldehdye or Ortho hydroxyl benzaldehyde

Phenol and formaldehyde are reacted in presence of a catalyst

12 Dihydromyrcenol Dihydromyrcene is reatced with acid

13 Benzyl Acetate Benzyl chloride and sodium acetate are reacted

14 Gamma Methyl Ionone/ Methyl Ionone Alpha Iso

(1) Citral and methyl ehtyl ketone are reacted (2) Then cyclized

15 Gamma Lactones ( Undeca, Deca, Nona)

Reacting corresponding alcohol (1-Octanol, heptanol and hexanol) with acrylic acid or methyl acrylate

16 1-oxacyclohexadec-12-en-2-one

(1) Cyclododecanone is reacted with allyl alcohol in a radical reaction

(2) Dehydrated using a acid catalyst (3) Then treated with proxide and cleaved with acid

17 Amyl Salicylate Amyl alcohol and methyl salicylate are reacted to

18 Hexyl Acetate Hexanol and acetic acid or acetic anhydride are reacted

19 Pentadecanolide

(1) Cyclododecanone is reacted with allyl alcohol in a radical reaction.

(2) Dehydrated using a acid catalyst. (3) Then treated with proxide and cleaved with acid


20 Cyclamen Aldehyde- Pure (1) Cumal and propionaldehyde (2) Hydrogenaion

21

2-(1-(3,3-dimethylcyclohexyl)ethoxy)-2-methylpropyl propionate

(1) Dihydromyrcene is reacted with formic acid (2) Then reatced with propionic anhydride .

22 MENTHANOL (4-Isopropyl Cyclohexyl Methanol)

Cumal is hydrogenated

23 Isobutyl Hydroxy – 4 Methyl TetrahydroPyran

Isoprenol and isovaleraldehyde are reacted

24 LILIAL or Para Tertiary Butyl Alpha Methyl DihyroCinamaldehdye

(1) Benzaldehyde is reacted with propionaldehyde Rreaction with isoutylene

(2) Hydrogenation and dehydrogenation

25 6-Tertiary Butyl -2- Methyl Phenol

o-cresol is reacted with isobutylene

26

Galaxolide or 1,3,4,6,7,8 – Hyxahydro – 4,6,6,7,8,8 – Hexa Methyl Cyclopenta- Gamma-2-Benzo Pyran/HHCB

(1) Alpha methyl styrene is reacted with isoamylene to give intermediate pentamethylindane

(2) Then reacted with propylene oxide followed by formaldehyde

27 3-ethoxy-1,1,5-trimethylcyclohexane

(1) Isophorone is hydrogenated to 3,3,5-trimethyl cyclohexanol

(2) Then reacted with diethylsulphate using a base catalyst

28 L Menthol/5-methyl-2-propan-2-ylcyclohexan-1-ol

(1) m-cresol is rected with propylene to give thymol (2) Thymolis hydrogenated to give menthol

29

1-Methyl-2-(1,2,2-trimethyl[3.1.0]hex-3-ylmethyl)cyclopropyl]methanol

(1) Alpha pinene is epoxidized (2) Then isomerized to campholenic aldehyde (3) Then reacted with di-iodomethane

30 2-cyclohexylidene-2-phenylacetonitrile

Benzonitrilenadcyclohexanone reacted in presence of a catalyst

31 2-methyl Undecanal/Aldehyde C12 MNA

1-Decene is reacted with carbon monoxide and hydrogen gas mixture in presence of a special catalyst


32 2,6,6-trimethylcyclohexa-1,3-diene-1-carbaldehyde

(1) Citral is converted into cyclocitral using aniline and other materials.

(2) The cyclocitral is then rominated using N-Bromosuccinimide

(3) Dehydrobromination .

33 Linalool/Tetrahydra Linalool/Linayl Acetate

(1) Alpha pinene is converted into cispinane (2) Then oxidized to pinanehydroperoxide to

cispinanol. (3) Then reduced to give linalool. (4) Linaool is then hydrogenated. (5) On esterification with acetic anhydride gives.

34

Otrtho Tertiary Butyl Cyclohexanol/ Acetate

(1) Hydrogenation of OTBP and (2) Further acetylation of PTBCH

35 Para Tertiary Butyl Cyclohexanol / Acetate

(1) hydrogenation of PTBP (2) further acetylation of PTBCH .

36 Staryl Acetate Acetylation of Acetophenone

37 HexaCinnamicAldehdye Reaction of Octanol&Benzaldehdye

38 Benzyl Salicylate Mixing of benzyl chloride with salicylic acid

39

HAMBER or (7-acetyl-1,2,3,4,5,6,7,8- Octahydro 1,1,6,7 – Tetramethyl Naphthalene) or Hamber Premium

Mixing of myrcene and MPO in the presence of catalyst BF3/ Phosphoric Acid

40 MPO Mixing of MEK with Acetaldehyde with 98 % sulphuric acid as catalyst

41 Cyclamen (1) Condensation of cuminic aldehyde and

propionaldehyde (2) Hydrogenation in the presence of a catalyst.

Thus: (1) 21products achieved in one single step. (2) 13 products achieved in two steps. (3) 06 products achieved in three steps. (4) 01 products achieved in more than three steps.

Out of the 41 products two are selected as representative and its chemistry,


mass balance, process steps and resultant product, by-product and waste-products with environmental significance are described. Similar for remaining 39 also will follow.

PROCESS FLOW DETAILS OF MANUFACTURING OF BENZYL SALISYLATE

PROCESS FLOW DETAILS OF MANUFACTURING OF CUMARINE


Process Steps It is necessary to consider as a first step, the preventive measures related to chemical industry. These are as – (1) Air Pollution:

i. To curtail the rise in levels of SPM SOx,NOx in the ambient air and to avoid exposure to fine solid particles following methods can be helpful.As far as possible closed condition process.

ii. Proper isolation of the unit operation with walls, partitions etc. iii. Provision of nature and forced air circulation as per need. iv. Provision of cyclone collector, bag filters, blowers to collect fine solids v. Use of sulphur free fuel i.e the Biomass Briquettes. vi. Use of face shield, breathing apparatus, nose masks, air muffs etc.

To staff (2) Noise :

i. Proper isolation of noise creating equipment with wall/rigid partition. ii. Use of rigid support, shock absorbing wooden blocks/rubber pads,

dampeners, plastic foams to all noise marking machines.


iii. Preventive, periodic servicing and timely, proper lubrication to equipment.

(3) Water : i. Most of reaction, purification, distillation need heating/cooling by water

medium. They do not take part in reaction, thus do not create effluent water.

ii. Some reactions involve washing of intermediate product and water layer separation.

iii. Due arrangement has been made to collect such water quantity and treat in ETP.

(4) Operation: To avoid discards and run-away reactions care is taken for testing and certification of equipment and checkup as follows –

i. Proper testing and certification of all equipment s per DISH norms. ii. Periodic checking of meger value of the earthing and its record. iii. Periodic testing of gases and solvent storage vessels as per Chief

Controller of Explosives, Nagpur after each 5 years. iv. Availability of the record of the same to concerned authorities. v. After completion of 5 years for the structures, testing and stability

certification from structural engineer for all structures

6. POLLUTIONCONTROL

Preventive:

Preventive measures are considered first on various operations in theprocesses

so that resultant pollution and wastage should be limited. They are:

A During concept, design and policy stage:

(1) Precise selection of the process, raw materials. (2) Use of best equipment. (3) Optimum lay out of vessels, tanks, pumps. (4) Correct location of ladders, platforms, pipe support and fittings. (5) Proper design of equipment to avoid any sort of solids to escape in air

during operations. (6) Proper design of equipment to avoid any contact of chemicals to working

staff during operations.

B During erection and full commissioning stage:

(1) Precise selection of persons in operation (trained or skilled ). (2) Pre employment and periodic medical check up of all staff of factory.


(3) Availability of the same record to each person concerned to understand his status.

(4) Thorough training of the operations, handling, dangers, hazards, remedied forvarious chemicals involved.

(5) Use of wooden support, rubbers sheets, foams, shock absorbing materials,dampners to vibrating and noise making machines

(7) Proper guarding and painting to guard to all moving parts of all equipment (8) Proper bonding and earthing of machines, equipment. (9) Automation and proper instrument appliances. (10) Prevention of all types of direct and indirect exposure of chemicals to

staff.

Performance checking of all equipment before full commissioning

(1) Precise use of instruments in process. (2) Fixation of limit switches, isolators for equipment. (3) Proper selection of power supply cables and their effective insulation. (4) As per needs enough natural and forced draft air supply at work place. (5) Proper testing, X ray diffraction study etc. for tanks, vessels and availability

of record of the same for reference (6) Proper selection of tanks, vessels, pumps and their material of construction.

C. During operational phase:

(1) As far as possible closed condition processes (2) A properly laid down standard operation procedure for all operation in plant (3) Strict vigilance in process operation and control (4) Proper rigid support to stand and operation for all valves on lines (5) Provision of return lines for solvents from plant to avoid spillage and solvent

loss (6) Proper, exact and timely use of personal protective equipment like gloves,

goggles, masks, breathing apparatus, aprons, shoes, helmets, raincoat, eye washers, body showers, body lotions, etc.

(7) Flame proof fittings to all solvent storage area and in plant (8) Proper training to all staff to use the above personal protective equipment (9) Strict use of cotton ware only to all staff in plant area. Strict prohibition of

any naked flame, match box, gas lighter, ignition source, any synthetic cloths in plant area. Display of material safety data sheets for all chemicals handled and present in plant operations. Proper scrubbing arrangement for vent gases. Implementation of green belt or tree plantation near solvent storage area in tank farm to avoid rise in temperature in summer.

B) Thereafter control

Water regime

The factory receives water from MIDC, fully treated in their water works for the purpose. As the sanction is adequate the industry does not need to tap any groundwater or bring water by tankers. For fulfilling the conditions laid by the Environmental Clearance (3 [iv],[vii], [xv], [xviii], [xxi], xxiii]), and Consent to operate (17,19,20,23), as well as for new product mix, water budget is worked out. This will satisfy the compliance schedule. It is, next, necessary to prepare a table of water accounting. This is attempted as:


# Station Input Loss Effluent & Nature Fresh Recycled Feed Low

TDS High TDS

Other

1 Domestic 25 5 20 2 Manufacturing DM

regeneration 10 7 3

Vessel washing

10 2 8

Process 80 20 15 25 60 Product

Purification 105 29 10 66

Scrubber 5 1 4 Floor washing 10 5 5 Sub-total 205 15 20 59 44 137 3 Utilities Pump cooling 100 30 70 Boiler make-up 240 230 10 Cooling make-

up 600 49 599 50

Sub total 840 149 859 120 10 4 Compliance Dust suppress 25 25 Ash quench 25 25 Fire service &

mock drill 15 15

Sub total 15 50 65 5 Greening 67 100 167

Sub-total 67 100 167 Total 1152 314 20 1155 164 147 20

Thus summary: # Station Input Loss Effluent & Nature

Fresh Recycled Feed Low TDS

High TDS

Other

1 Domestic 25 5 20 2 Industrial 1060 214 20 983 164 147 3 Greening 67 100 167 Sub-total 1152 314 20 1155 164 147 20 Total 1486 1155 331 Thus, the industry has three sub-streams of wastewaters, namely: a) Domestic sewage-sullage 20 cum/day. This is subjected to treatment through

septic tank. b) Trade effluent of high TDS from process waste-water side 147 cum/day. This

is subjected to treatment through MEE. MEE works on added steam. It finally results in about 15 TPD as solid waste which goes to CHWTSDF and condensate water of 132 CMD + 33 CMD contributed by condensed steam, which too needs treatment. This becomes a sub-stream [d].

c) Trade effluent of low TDS from process waste-water side 164 cum/day. This is subjected to treatment through ETP. In this ETP we are also admitting the


sub-stream [d]. d) The sub-stream [b] above has given rise to this sub-stream [d]. This is mixed

with sub-stream [c], as 165+164 = 329 CMD and treated in ETP. e) Thus we have two treatment trains, for trade effluent. Train “I” to cater to the

need of wastewater sub-stream of [c] and [d] and Train “II” to cater to the need of wastewater sub-stream of [b]. The pipe-lines are seen so laid dedicatedly.

Train “I” is an ETP consisting of primary, secondary and tertiary with a capacity of 350 cum. This is followed by advanced two- stage Reverse Osmosis with a capacity to take corresponding load coming from 329 cum stream. From this the resultant permeate 307 cum is used as recycle within our premises and the 22 concentrate or reject is dealt along with the high TDS stream B of 147 CMD, thus 147 + 15 = 162 CMD. Train “II” is a plant of MEE two parallel units of capacities 150 and 50 cum (Mazda and Mojj make respectively). This is followed by Agitated Thin Film Dryer (ATFD).The resultant solid waste is transported to CHWTSDF, of which the industry has valid membership. Train “I” gives rise to sludge, and more efficiently we run the ETP train, the sludge load increases. This is required to be dewatered for which three stage efforts are made by filter press, centrifuge and SDB sludge drying beds. The liquor is sent back for treatment at point one equalization tank and the dewatered sludge to CHWTSDF. Treatment Train “I”: The unit operations and unit processes in this configuration are – Oil-grease separator, Equalization tank, Coagulation tank, Clarifier flocculator, Aeration tank-1 (with its secondary clarifier in built), Aeration tank-2 (with its secondary clarifier in built) in series, Chlorination tank, pressure sand filter, activated carbon filter, hybrid Reverse Osmosis, P-Tube Reverse Osmosis, filter press, decanter, sludge drying beds and attendant air-grids, dosing, air-lift pumps, panels, micro-processor. The civil structures of ETP are – # Unit Size m Working

volume m3 HRT Hr.

1 Oil-grease separator 6.5x1.5x1.2 8.8 0.64 2 Equalization tank 8.8 dia x 2.5 120 8.75 3 Coagulation tank 3x 0.75x1 1.5 0.10 4 Clari-floculator 3x3x4 30 2.18 5 Aeration tank-1 (with its

secondary clarifier in built) 7.5 dia x 6 220 16.05

6 Aeration tank-2 (with its secondary clarifier in built) in series

7.5 dia x 6 220 16.05

7 Filter Feed Tank 2x2x2 8 0.58

(1) Further the advance waste water treatment (AWWT) is also given.

(2) This AWWT is by way of Reverse Osmosis, which can offer recyclable quality.

(3) This Reverse Osmosis is also done in two steps, the first being with Hybrid

type followed by P-Tube Reverse Osmosis. This not only gives efficiency but

also offers continuity with lower membrane attendance time-wastage.


(4) Both the Reverse Osmosis steps are individually controlled by micro-

processors, thereby fully safe and unattended operation and semi-automatic.

If the TDS and COD are not attended the unit does not allow the flow to pass

further and in fact gives an alarm to the attendants.

(5) The design is –

# Attribute In Hybrid RO In PT-RO system.

1 Quantity of incoming wastewater cum/d

329 33

2 Incoming TDS mg/lit 1500 14100

3 Incoming COD mg/lit 250 2275 4 Recovery % 90 55

5 Permeate cum/d 296 18 6 Reject cum/d 20 15

7 Permeate TDS mg/lit 100 1000 8 Permeate COD mg/lit 25 250

9 RO reject cum/d 33 15 10 RO reject TDS mg/lit 14100 30200

11 RO reject COD mg/lit 2275 4750

(6) The design thus aims as above and the combined RO Permeate is 314

cum/day. In actual level of present day maximum production, this recyclable

stream will be about 314 cum/d. On similar lines the reject going to MEE will

be 15 cum/d.

The equipment for use is proposed to be of following specifications : # Particulars Mazda make Mojj Make

1 Feed rate kg/hr 6000 2500 2 Feed concentration % TS 13 to 25 10 3 Product rate salt kg/hr 1350 263 4 Water evaporation kg/hr 4975 2237 5 Heating steam @ 7 kg/cm2, 1890 kg/hr 7 kg/cm2, 560 kg/hr 6 Cooling water flow cum/hr 60 60

The gadget will have indication panel reading jacket temperature of calendria, vapour separator, 1-2-3-4 cooling water inlet-outlet, forced circulation calendria outlets, vacuum gauge indicating vacuum in condenser, level indication and control loop for regulation of product out from each evaporator so as to maintain constant level. In addition, PLC will be there which incorporates the operation, start-up/ shut down logic. This is controlled though PC. There is SCADA run time software proposed. .

Agitated Thin Film Dryer (ATFD): This is a welcome appendage post-MEE for further dewatering and comfort of handling the waste matter. This Agitated Thin Film Dryer-Evaporator has a capacity of 500 kg/hour water evaporation and is adequate for this present


scenario. This will handle solids of 40%. Attendants are keeping a watch on steam pressure, shell temperature, cooling water temperatures and vacuum temperature. This is serving well as seen during the inspection period and may continue without any change. CHWTSDF: What finally remains is the salt for disposal as hazardous solid waste. This is being sent systematically, with manifest, authorized transporters and documented. This needs to be routinely informed to MPCB on prescribed format and the same is being done. This performance should continue.

MEE Technology:

It has been imperative that the waste volume should be reduced to as small as possible. This is to achieve the critical material balance with the filler material i.e. press mud, which is available seasonally, i.e. for a shorter duration, and therefore in a limited quantity. This purpose is achieved with the help of Multi Effect Evaporator system, which is specially designed for such application and effluent. This achieves a dual purpose of not only volume reduction of the Spent wash, which is further validified to achieve zero discharge, but more important, water recovery, which can be reused in the process.

Solid Waste:

This is not a big problem. The solid in process generate only as yeast spent residue. This is highly biodegradable and can be taken to compost yard without difficulty.

Municipal Solid Waste : # Waste Quantity Treatment Disposal Remark

1 Canteen 100 kg/d Compost Own garden Organic 2 Office 50 kg/d -- Sales Non-Haz.

Non- Hazardous( Commercial/ Industrial)

# Type of Waste Quantity (TPA)*/

(NPA)** Mode of Disposal

1 Empty Paper & PP Bags 900 Recycler

2 Wooden Pallets 60 Recycler

3 Plastic/HDPE Scraps 55 Recycler

4 Biomass Briquette Ash 2400 Recycler

5 Scrap MS / SS 25 Recycler

6 Glass Waste 3 Recycler

7 Ash 3600 Recycler

Hazardous:

# Waste Cat Mty/npy


1 ETP Sludge 34.3 100

2 Chemical Residue 33.1 220

3 RO Reject/ Solids from MEE 34.3 5500

4 Spent Oil 5.1/5.2 200

5 Spent Solvent 20.2 50

6 Spent Ion exchange resins 34.1 0.3

7 Discarded barrels/cans/liner contaminated with hazardous waste or chemicals

33.3 5600 **

8 Process Waste 21.1 45

9 Spent Catalyst 35.2 10

10 Spent Carbon 35.3 25

11 Other like battery waste, e -waste etc

1

12 Oily Sludge 20.3 0

*TPA = Tonnes per Annum, **NPA = Numbers per Annum

7. BACKGROUNDSTUDY:

Thisisimportantpartofstudy. (A) NaturalEnvironment:-

We propose to do the sampling as –

(1) Surface Water: 2 Locations, 11 Parameters. (2) Ground Water: 9 Locations, 9 Parameters. Includes 1 upgradient and 2

downgradient of compost yard source. (3) AAQ Ambient Air Quality stations 2 down wind and 1 up wind location in 1

km area, from Co-gen Stack (4) Noise: 9 Locations. (5) Soil: 9 Locations, 2 locations in Actual Compost yard area proposed.

The stations will be selected in all the eight directions from the factory and in 10 km radius.

(B) ManmadeEnvironment:-

(1) This will include existing land-use, demography, employment, socio-


economic aspects and community development needed and proposed. This will be for entire area both rural and urban in this study zone.

(2) Socio-Economic Status in Influence Zone will include the study of Non- Workers percentage whether high, from the percentage employed population on Agricultural, how far is the scope for other avenues of livelihood like Live Stock, Forestry, Fishing, Hunting, Orchards, Mining, Trade Commerce.

(3) Further Out of Total Land what percentage is already under Cultivation and Out of Total Land what percentage is already under Irrigation.

(4) If the land is not likely to support more people, then whether Industrialization is necessary to improve the situation. All this will be studied as cost benefit ratio.

From the earlier studies we have assembled some information as --

Micro-Meteorology:

Pune District is divided in rain shadow area of Sahyadrirange. Its western region enjoys good rain fall of 900 mm, central part receives about 700 mm and rain shadow area of eastern Talukas of Daund, Baramati, Indapur get hardly 500 mm rainfall. Most of the rainfall happens in months of June to October. Generally the climate is dry. Kurrkumbh is a at extreme right side region of Pune District. Thus rainfall in this area is around 500mm.

Air Environment:

Air in general is dry in Pune District. During rainy season it is humid.

Noise Environment:

Main use of land in Daund, Baramati, IndapurTalukas was farming. Thus by and large noise levels in kurkumbh area below 45dB.Due to rise in vehicular traffic on Pune Solapur national high way no.09 there is some rise in noise levels up to 50 dB.

Land Environment:

The slope of land in Pune District is form and North West to east and south East. Western part of Pune District is part of Pune District is part of western Ghats of Sahyadri range, Bhīma and Nira main revisers of south east.in east sector of IndapurDaund and BaramatiTalukas slopes are less and plain area prevails in west part of Pune District soil has red and black colour.in east sector the red colour diminishes and black soil is observed. The industrial activity was initiated on barren land around 30 years ago.

Water Environment:

Bhima , a main tributary of kishna River flows about 10.5 km away(aerial distance)form this zone.Bhima and its tributary,Nira river form boundaries of Pune District in east and south east direction. All water supply to M.I.D.C. kurkumbh area is from Bhima river.

Socioeconomic:


Due to intimation of the industrial activity in this area many local persons found suitable jobs and thus are prospering. Thus experienced semi-skilled and skilled people are now available to meet the requirement of men power at all levels and in all sectors.

8. SAFETY

Safety and Occupational Health will be dealt carefully. A disciplined approach is natural to this industry. Safety policy will be in place. The unit will be registered under Factory Act and are bound by State Factory Rules. Thus, First aid trained and Fire-fighting trained person will be available in every shift. Safety Officer will be appointed, as also the competent person retained. Where necessary, provisions of other Acts, where required like Petroleum act, Explosive Act, etc. will be obeyed. Fire fighting system is kept as per norms of Insurance Company and CIF.

Maintenance:

(1) Strict permit to work system for maintenance and other operations. (2) Periodic and preventive maintenance of all equipment. (3) Proper and exact lubrication to all machines, pumps, compressors, lifts etc. (4) Proper shut down operation plan. (5) Checking and replacement of worn out and faulty electrical cable in time. (6) Insertion of proper power isolators. circuit brakers, limit switches.

Fire and fire fighting:

(1) Follow up of BIS 2190 and NFPA code for all fires. (2) Proper selection of staff to handle fire extinguishers.


(3) Periodic training to all concerned staff. (4) Proper selection of fire extinguishers. (5) Fixation of fire hydrant system. (6) Daily at least one trial of the fire hydrant system for its performance. (7) Reserved separate water stock for fire fighting and prevention program. (8) Generator back up for fire equipment

Fire hazard due to solvents or chemicals:

EFCIL is a chemical processing unit. It has stock of raw materials including solvents. Toavoid handling and transport of Hydrogen, it has methanol cracking activity to produceHydrogen gas formation and storing the same in bulk quantity. Besides this finishedCMS are also in stock. Some of them can burn if ignition occurs while some arechemical compounds with oxygen as one constituent. In case of any ignition, fire orexplosion they will burn and also assist the fire to continue till the stock is exhaustedcompletely. In such scenario probability of any fire, any ignition source or explosion is very high. Fire is any time a threat to men. material, process. image of the organization in public and environment. If it is initiated, noticed quickly and extinguished in minimum time, than it can save the probable losses. As per UN survey of reasons of any accident to occur and consequent damage to materials, men and ‘property, most of the causes of fire to start are very simple and can be controlled. A statistical table can be consideredas follows to know the cause and their probabilities. DMP (Disaster Management Plan) and off-site emergency plan will be in place. Accordingly, Personal protection equipment will be given and use will be insisted. Consulting Physician is retained to attain the factory.

OCCUPATIONAL HEALTH PLAN:

Since its establishment, EFCIL has a perfectly chalked out plan to monitor the health status of all its employees. Also periodic safety training, first aid training, disaster control rehearsal trials twice in a year are performed. All training programs and the disaster control plan are updated periodically and executed. All employees are aware of the importance of occupational health and respond to the same.


9. BENEFITS

The industry will produce such product which is a vital commodity in the national as well as international market, and which will save foreign exchange. This will not disturb the present land use because our area occupied will be only small % of Influence zone 10 km. Compatible Architecture will be adopted and No Prime Agriculture Land will be put to this industrial use. Trees will be maintained and not razed down. No Rehabilitation is involved. People will get jobs here and some incidental small employment like eatery, canteen, tyre repairs, and garage too will become available to genuine people. This will be beneficial to the society. Due to this project, workforce will get more advantage.

For sustainable benefit of people EFCIL has a correctly chalked out an environment management plan at its Kurkumbh plant. It covers periodicalambient air and stack monitoring, Water and noise sampling and testing.During expansion Phase -Only 30 % area of land will be used for construction. There will be insignificant rise inSPM generation. Due care to check the same has been planned. During operation phase -- A full and fool proof environment management cell will operate to monitor factors of environment as per CPCB norms.

Green Belt Development Plan is undertaken. Around 1/3rd of total land area is


reserved for green belt and will be used for greening drive.

10. EIASTUDYREPORT

This will be finally prepared and submitted as per guidelines given by MoEFas –

Chapters Contents

I Proponents,ToR,Purpose

II Projectexplained.Whythis,Whyneeded,Whyhere,Whatpriorities,Whatoptions

III EnvironmentSetting Natural&Man-made

Material,Method,Approach Delphitechnique

IV HighSignificant Impact LowInsignificant Impact&Shield

ProperSite, Prevention, Abatement, Treatment, Mitigation, Smooth Disposal

V AlternateAnalysis

SelectionofRawMaterials,Site,Process,Machinery-Hardware,Collaborators,Staff&Team

VI Monitoring=Stations,Parameters,Frequency,Statistics,Rectify

VII ExtraInnings Risk=ToEnvironment,ToHealth,ToBankers


PublicConsultationReporting

Community=OusteesRehabilitation. Others-Assistance

VIII Benefits=Physical,Social,Employment,OtherTangible. Sustainableconsiderations

IX Cost-Benefit.IfProjectDone. IfNo-Project

X EMP=Plan,Cell,Schedule,Watch-dog,Monitoring,Documentation,Reporting

XI Summary,Conclusion,Justification,Mitigation.

XII EIATeam=Proponent,Consultant,Associates,Future

Impact during operation Phase:

(1) Air Environment : Due to the use of carbon neutral fuel there will be no increase in SO2, NOx in the atmosphere.

(2) Noise Environment: Due to rise in vehicular transport noise level may rise 50 to 55dB(A) level.

(3) Water environment: No impact on water environment is envisaged. (4) Land environment: Hardly impact on land environment is envisaged. (5) Socioeconomic impact: Creation of M.I.D.C. at kurkumbh has led to

initiated chances for job opportunities to local as well as out side persons at various levels. Due to expansion at EFCIL these chances will enhance their position.

11. CONCLUSION

(1) This project is very necessary in view of producing Synthetic Organic

Chemicals, a useful foreign exchange saver product which the nation requires as a useful resource for development.

(2) The local people have already accepted this industry and further up gradation for their benefit will be welcome in their area.

(3) The candidate site is suitable from general MoEF expectations. (4) Water, power, raw material, utilities and Market is assured and found

available with ease. (5) Full precautions will be taken for Pollution Control, Resource Conservation

and Environmental Protection. (6) This is cost effective and Sustainable Development.

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prefeasibilityreport for environmental clearanceproposed...

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