Expansion of Ammonia (2200 MTPD) and Urea (3860 MTPD )Nagarjuna Fertilizers and Chemicals Ltd.

MINUTES FOR 32^ndEXPERT APPRAISAL COMMITTEE (INDUSTRY-2) HELD DURING16^th?17^thFebruary, 2012

VENUE: Scope Complex, Core 6, 5^th Floor, IOCL Conference Room, Ministry of Petroleum and Natural Gas, Lodhi Road, New Delhi 110 003.

TIME      10.00 A.M.

32.0        Opening Remarks of the Chairman

32.1    Confirmation of the Minutes of the 31^stMeeting of the Expert Appraisal Committee (Industry-2) held during 12^th?13^thJanuary, 2012.

32.3       Reconsideration:

32.3.1.      Expansion of Ammonia (2200 MTPD) and Urea (3860 MTPD) by installing Urea Plant (1.27 MTPY Phase-III) based on Natural Gas at Kakinada, District East Godavari, Andhra Pradesh by M/s Nagarjuna Fertilizers and Chemicals Ltd. (EC)

                        The project proposal was considered in the 29^th EAC meeting held during 17^th -18^th November, 2011 wherein the committee desired following additional information and matter was deferred till the desired information is submitted:

Value of CO and HC should be re-checked. Stack emission of NOx may be given in mg/Nm³ instead of emission rate.

Rechecking of distance of ground level concentration for SO₂ and NO_x, which is mentioned as 14.1 km in the EIA report. Action plan for water conservation to reduce water consumption. Water consumption should match the existing plant and should not exceed the existing requirement for production of fertilizer/MT. Wastewater generation should also be reduced accordingly.

Effluent characteristics are given only for 4-5 parameters. Other parameters as per CPCB guidelines should also be monitored and submitted.

Table 3.4 should be rechecked where raw water inlet and effluent outlet is mentioned.

Action plan for solid and hazardous waste management and disposal should be given.

Justification for additional NH₃ storage facilities.  

Hazardous waste disposal scheme for all the hazardous wastes to be disposed off should be submitted.

Keeping in view of Tsunami, Risk assessment should also include action plan. All coastal area facilities have to be included in action plan.

Revised Quantitative Risk Assessment considering worst case Scenario determining frequency of occurrence of Scenarios and consequence thereof.

Provide the Fertilizer Complex`s "List of Near Misses" for last two Calendar years.

In Public Hearing Report, it is mentioned that there is no storage of NH₃ but, in actual, there is storage of NH₃. Clarification may be submitted.

TOR letter and its compliance, Public Hearing and point-wise clarification alongwith commitments made with public should be included in the EIA/EMP report.

           

Project proponent vide letter dated 27^th December, 2011 submitted the following information:

1.    Project proponent has informed that figures uder the columns of CH₄ and N-CH₄ had got inadvertently reversed in the original environmental impact assessment report. The NOx values have been given in mg/NM³ as advised.

2.    The ground level concentrations for SO₂ and NO_x have been re-checked and found to be correct. It may kindly be noted that under stable and low wind conditions from the stacks with small heights, there is possibility of reaching these pollutants up to 14.1 Km distance. The data is based on actual measurements.

3.    Total water requirement will be increased from 3953 m³/day to 6653 m³/day after expansion. Industrial Wastewater generation will be increased from 2973 m³/day to 5593 m³/day after expansion.

The treated effluent water characteristics prevailing in NFCL is submitted and found that all parameters are well within the specified limits.

The data for Raw Water Inlet and Effluent outlet ha been rechecked and the Heavy Metals results have been corrected in Raw Water analysis. Also, the additional parameters of TKN, Cyanide, Ar and V have been incorporated in the Table 3.4.11 which are as per the CPCB guidelines for Fertilizer Industry.

Spent catalyst will be sent to the authorized recycler/reprocessor. Waste oil will be used for lubrication process. Spent activated carbon generated from the process plants will be disposed to vendors authorized by APPCB.

The design philosophy followed for Ammonia/Urea Fertilizer complex is to have ammonia storage tank for safely consideration in order to take care of plant interruptions of urea plant and to sustain the continued operation of the ammonia plant. Normally the ammonia plants are designed with matching capacity of urea plants.

As mentioned at S.N. 6.

in assessing the Tsunami hazard along each section of coastline, four probability ranges were developed based on the range of return periods of tsunamis of around 5 m (16 ft) elevation. The assessed hazard is the general elevation along that coastline and does not account for localized variation sin tsunami heights caused by seafloor topography or coastline shape. The four probability ranges have been demonstrated.

Revised QRA Study was conducted considering the possible worst case scenario which is catastrophic rupture of Refrigerated Atmospheric Ammonia Storage Tank leading to Toxic released scenario of Ammonia into the atmosphere. The study has been done with respect to new tank of 10000 MT capacity which will be storing a maximum Quantity of 5000 MT of liquid ammonia at any time as per the operating Philosophy of NFCL. The quantitative risk assessment (QRA) of the ammonia storage facility at NFCL Kakinada has indicated that the individual risk and societal risk parameters are in acceptable region. 

It was informed that there has been no major occurrence of near misses in the Complex in the last two to three years. Further, there have been absolutely no near misses in the area of Ammonia Storage facility. However, details of near misses in the Complex in the last two to three years period is submitted.

Ammonia produced in directly consumed to manufacture urea. As such, during normal and steady state plant operations when Ammonia and Urea Plant loads are matched, then no ammonia is sent to ammonia storage tank. But during interruptions of urea plant or lower load of Urea Plant with respect to ammonia load, liquid ammonia is stored in the storage tank which is consumed back on restoring normalcy in Urea Plant.

            After detailed deliberations, the Committee noted that risk assessment carried out by the Unit was found to be satisfactory and suggested to stipulate following specific conditions alongwith other environmental conditions while considering for accord of environmental clearance:

           

i)          All the conditions stipulated in environmental clearance J-11011/31/90-IA (II) dated 14^th October, 1991, J-11011/8/92-IA (II) dated 22^nd  October, 1992, J-11011/65/96-IA (II) dated 15^th January, 1997 and J-11011/862/2008-IA (II) dated 10^th June, 2009 accorded for the existing projects should be satisfactorily implemented.

ii)         The gaseous emissions (SO₂, NOx, NH₃, HC and Urea dust) and particulate matter from various process units shall conform to the norms prescribed by the CPCB/SPCB from time to time. At no time, the emission levels shall go beyond the prescribed standards. In the event of failure of any pollution control system adopted by the unit, the respective unit shall not be restarted until the control measures are rectified to achieve the desired efficiency. Stack emissions shall be monitored regularly. 

iii)        Adequate stack height shall be provided to Ammonia plant reformer, Heat recovery steam generator (HRSG), NG/ RLNG fired gas turbine and Prilling Tower. Low NOx burners shall be provided to control NOx emissions.

iv)       In Urea Plant, particulate emissions shall not exceed 50 mg/Nm³. Monitoring of Prilling Tower shall be carried out as per CPCB guidelines.

v)        Ambient air quality data shall be collected as per NAAQES standards notified by the Ministry vide G.S.R. No. 826(E) dated 16^th September, 2009. The levels of PM₁₀ (Urea dust), SO₂, NOx, Ammonia, Ozone and HC shall be monitored in the ambient air and displayed at a convenient location near the main gate of the company and at important public places. The company shall upload the results of monitored data on its website and shall update the same periodically. It shall simultaneously be sent to the Regional office of MOEF, the respective Zonal office of CPCB and the A.P. Pollution Control Board (MPCB).

vi)       In plant control measures for checking fugitive emissions from all the vulnerable sources shall be provided. Fugitive emissions shall be controlled by providing closed storage, closed handling &conveyance of chemicals/materials, multi cyclone separator and water sprinkling system. Fugitive emissions in the work zone environment, product, raw materials storage area etc. shall be regularly monitored. The emissions should conform to the limits stipulated by the APPCB.

vii)      Additional water requirement from Godavari River for the expansion plant should not exceed 21170 m³/day and prior permission shall be obtained from concerned Authority and a copy submitted to the Ministry?s Regional Office at Bangalore.

viii)     As proposed industrial effluent should not exceed 2620 m³/day and treated in the ETP. As proposed, Urea plant process condensate shall be treated in a deep hydrolyser followed by stripping. Ammonia plant process condensate (APC) shall be stripped with steam followed by activated carbon and demineralization. Treated condensate shall be recycled/reused in the process. Utilities wastewater shall be treated in the ETP and treated effluent shall be recycled/ reused. Treated effluent shall also be monitored for the parameters namely ammonical nitrogen, Nitrate, Fluoride, pH etc. The treated effluent which can not be reutilized should be disposed off through marine outfall (MOF) system. Sewage shall be treated in STP and treated water shall be recycled/reused within factory premises to achieve zero discharge except rainy season.    

ix)       All the effluents after treatment shall be routed to a properly lined guard pond for equalization and final control. In the guard pond, automatic monitoring system for flow, and relevant pollutants (i.e. pH, ammonical nitrogen, nitrate nitrogen etc) shall be provided with high level alarm system.

x)        The company shall obtain Authorization for collection, storage and disposal of hazardous waste under the Hazardous Waste (Management, Handling and Trans-Boundary Movement) Rules, 2008 and amended as on date for management of Hazardous wastes. Measures shall be taken for fire fighting facilities in case of emergency.

xi)       Spent catalysts and used oil shall be sold to authorized recyclers/re-processors only.

xii)      The company shall strictly follow all the recommendations mentioned in the Charter on Corporate Responsibility for Environmental Protection (CREP).

xiii)     The unit shall make the arrangement for protection of possible fire hazards during manufacturing process in material handling. Fire fighting system shall be as per the OISD 117 norms.

xiv)    Occupational health surveillance of the workers should be done on a regular basis and records maintained as per the Factories Act.

xv)     Green belt shall be developed in 33 % of the plant area. Selection of plant species shall be as per the CPCB guidelines.

xvi)    Remote operated valve placed on NH₃ line to avoid leakage/equipment check should be performed to ensure that remote operated valve (ROV) is all time is functional.