EXECUTIVE SUMMARY OF RAPID ENVIRONMENTAL IMPACT ASSESSMENTAND ENVIRONMENTAL MANAGEMENT PLAN FOR PROPOSED EXPANSION OF TRICHLORO ETHYLENE, POLY

VINYL CHLORIDE, COGEN POWER GENERATION AND A NEW PRODUCT OF CHLORINATED POLY VINYL CHLORIDE FOR

DCW LTD., SAHUPURAM,

THOOTHUKUDI DISTRICT.

BY PURE ENVIRO ENGINEERING PVT LTD CHENNAI AUGUST 2011

CONTENTS
CHAPTER NO 1 2 Introduction Project Details 2.1 Location 2.1.1 Environmental Settings 2.2 Proposed Production Capacity 2.3 Raw Material Requirement 2.4 Water Requirement 2.5 Land Requirement 2.6 Process Description 2.6.1 Trichloroethylene 2.6.2 Poly Vinyl Chloride 2.6.3 Chlorinated Poly Vinyl Chloride 2.6.4 Cogen Power Plant: 2.7 Manpower Requirement 2.8 Power Requirement 3 4 5 Baseline Environmental Status Prediction of Impacts Environmental Management Plan 5.1 Construction Phase 5.2 Functional Phase 5.2.1 Air Emission & Control Measures 5.2.1.1 TCE Plant 5.2.1.2 PVC Plant 5.2.1.3 CPVC Plant DESCRIPTION PAGE NO 1 2 2 2 3 3 3 4 5 5 5 5 6 6 6 7 9 10 10 10 10 10 11 11

5.2.1.4 Cogen Power Plant 5.2.2 Waste Water Generation, Treatment & Disposal 6 7 8 9 Solid Waste Generation & Disposal Noise Environment Socio Economic Consideration Conclusion

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1. INTRODUCTION

M/s. DCW Limited herein called as DCW operates a Chemical Complex at Sahupuram, Thiruchendur Taluk, Thoothukudi District with multi - locational and multi - product facilities. The products from this complex range from Industrial Grade Salt, Caustic Soda, Liquid Chlorine, Hydrochloric Acid, Trichloro Ethylene, Synthetic Rutile (Beneficiated Ilmenite), Ferric Chloride, Yellow Iron Oxide, PVC Resin. As this is a process plant, it has both power and steam requirements and this is met through Coal based Cogen Power Plant & Oil based Captive Power Plant.

DCW established their Caustic Soda Plant in the year 1958 and the present capacity of Caustic Soda is 1,00,000 TPA using Membrane Cell Process. DCW also established plants for the production of Liquid Chlorine, Trichloro Ethylene, Hydrochloric Acid, Beneficiated Ilmenite, PVC Resin, Captive Power Plant, Ferric Chloride Plant and Pilot Plant for the production of Synthetic grade Iron Oxide at Sahupuram. DCW is strategically located in an industrially backward area with a vision to make use of the available resources (like sea water) for the production of Chlorine and its further effective utilization.

The proposed expansion is by enhancing the production capacity of Trichloroethylene from the existing level of 7200 TPA to 15,480 TPA, Poly Vinyl Chloride from the existing level of 90,000 TPA to 150,000 TPA, a new product of Chlorinated Poly Vinyl Chloride with 14,400 TPA production capacity and Cogen power plant from 58.27 MW to 108.27 MW (by adding 2 x 25 MW) in the existing Industrial Complex at DCW Limited, Sahupuram, Tiruchendur Taluk, Thoothukudi District, Tamil Nadu.

The project planned with an environmentally friendly pollution abatement systems that certainly prove way for sustainable improvements to the original status of the environmental components pertaining to Air, Water, Soil, Noise, Socio-economic factors, Flora & Fauna, etc.

In order to assess the environmental quality of the core and buffer zones, field data are collected and described with impact and mitigative measures adopted. Management plan has been presented in the report for the approval of the statutory authority.

2.0 PROJECT DETAILS 2.1. LOCATION The proposed expansion by means of enhancement in production of TCE, Cogen Power Plant, PVC and CPVC will be within DCWs own land premises of Sahupuram, Trichendur Taluk, Thoothukudi District in their existing complex. The plant is located at a distance of about 5 kms from the Bay of Bengal and about 14 Kms from the town of Tiruchendur in the South-eastern direction. The nearest railway station is Arumuganeri and is situated about 1.5 kms in the south western direction. The nearest Harbor and Airport are at Thoothukudi at about 30 kms away from the project site. 2.1.1 ENVIRONMENTAL SETTINGS Latitude Longitude Topography Above mean Sea level in m Climate Temperature Relative Humidity Rainfall Topography & Drainage Major Soil characteristics Major Land use Major Crops National Park Archaeological Monuments Industry Nearest Town & Railway Station Nearest Highway Nearest Airport Nearest Hill Ranges Ecological sensitive areas (Wild life Sanctuaries) Nearest Water Course Nearest Sea 8 35 N 78 6 E Flat Terrain 2 to 2.5 m Semi-Arid 37C Max, 23 C Min, 30C Mean 75 % Maximum & 40 % minimum 450 to 750 mm (Mean Annual rainfall, IMD) Located in a flat terrain Sandy and clayey Industrial Paddy, Bajra, etc. No National Park within 10 Km radius No Archeological Monuments Nil Town: Arumuganeri 3 Km Railway Station: Arumuganeri 1.5 Km State Highway 1 Km Tuticorin 30 Km Nil No ecologically sensitive areas within 5 Km radius of the core zone Thamirabarani River 5.2 Km Bay of Bengal 5 Km 2

2.2 PROPOSED PRODUCTION CAPACITY S.No Product / Division Quantity (Tonnes / Annum) Existing 1. 2. 3. 4. Trichloroethylene (includes perchloroethylene) Poly Vinyl Chloride Chlorinated Poly Vinyl Chloride Cogen Power Plant 7200* 90,000 NIL 58.27 MW {(2x25 MW) + (8.27 MW)} (* only Trichloroethylene and ** New Product) 2.3 RAW MATERIAL REQUIREMENT Quantity Required (Tonnes / Day) S.No 1. 2. 3 Division Trichloroethylene (TCE) PVC CPVC Raw Material Calcium Carbide Vinyl chloride monomer PVC Resin Chlorine 4 Cogen Power Plant Coal Existing 16 260 NIL NIL 754 Proposed 16.5 174 24 23 1000 Total 32.5 434 24 23 1754 Proposed 8280 60,000 14,400** 2 x 25 MW Total 15480 150,000 14,400 108.27 MW

The safe handling of hazardous chemicals will be followed as per the MSIHC Rules, 1989 as amended in 2000.

2.4 WATER REQUIREMENT The details of water consumption for the existing and proposed plants are shown below. The additional fresh water required for the proposed expansion activity for both process and domestic purpose will be met from River Thamirabarani and TWAD Board.

S.No

Division Existing Fresh Water Recycled Water

Water Consumption (KLD) Proposed Total Fresh Water Recycled Water 250 240 240 Total

Trichloro Ethylene

250

2 3. 4.

PVC CPVC Cogen Power Plant

970 5624

110 980

1080 6604

650 120 3864

75 800

725 120 4664

5.

Domestic

100

100

Total

6944

1090

8034

4878

875

5753

2.5 LAND REQUIREMENT

Area in Sq.m S.NO 1. 2. 3. Land Use Total Plot Area Total Plinth area Roads, Parking Area & Others 4. 5. Green belt Area Vacant area 34000 132553 2000 40800 36000 Existing 265803 17880 2570 Proposed

2.6 PROCESS DESCRIPTION 2.6.1 TRICHLOROETHYLENE Trichloroethylene is prepared by chlorination of acetylene to form tetrachloroethane and subsequent dehydrochlorination to form trichloroethylene. Acetylene produced by reacting calcium carbide with water is treated to remove impurities like moisture, hydrogen sulphide, etc., and then directly chlorinated using ferric chloride as the catalyst in the TETRA synthesis towers to produce tetrachloroethane. This is further dehydrochlorinated with lime slurry and crude trichloroethylene is formed. This is distilled and purified and stabilized before filling in drums.

2.6.2 POLY VINYL CHLORIDE: The production of Poly Vinyl Chloride is carried out by the method of suspension polymerization technology. The PVC slurry coming out of the reactor is sent to blow down kettle, where the surplus VCM is stripped off the slurry and the slurry free of VCM is sent for drying, while the VCM gas is so recovered is sent to Gas holder for liquefaction and recycle. The wet cake is dried in dryers, bagged and sent to godown. Vinyl Chloride Monomer, buffer, suspending agent and de-foaming agent are admitted in a reactor and allowed to react in a controlled condition.

2.6.3 CHLORINATED POLY VINYL CHLORIDE: The Suspension PVC Resin powder is stored in a silo. Nitrogen flushing followed by degassing under vacuum is carried out for the removal of Oxygen and moisture content in S-PVC resin. SPVC is taken to the reactor, where Chlorine is admitted progressively and the reaction is initiated by UV irradiation. The pressure is set at 1 bar and temperature at 600C. The reaction temperature increases from 600C to 72.50C. Closed loop cooling water is admitted to remove the heat of reaction. The reaction gases leaving the reactor is passed through cyclones, filtered and split into two streams. The main one is recycled and the other one is sent to HCl unit followed by Hypo unit for the recovery of HCl acid and Sodium Hypo chlorite respectively. The recycled reaction gases are enriched with pure gaseous Chlorine before being dried by means of Sulphuric acid and then recycled back to the reactor after cooling.

The CPVC resin is then transferred to the degassing vessel where, the adsorbed Cl2 and HCl are removed by flushing the CPVC powder with dried and hot air. The exhaust mixer of air is sent to HCl unit and then to the Hypochlorite unit. Then CPVC passes through a screen and is sent to the C-PVC daily storage and packed.

2.6.4 COGEN POWER PLANT: We have proposed to generate additional electricity of 2 x 25 MW using Coal. For this, Atmospheric Fluidized Bed Combustion (AFBC) Boiler of 125 x 2 MT/hr and steam Turbine generator (with speed more than 5500rpm) are proposed to be used. The entire quantity of power (2 x 25 MW) generated will be used for the expansion projects. The Boiler used is 125 x 2 MT/hr capacity and after generating electricity (2 x 25MW). The steam required will be used in the process. The AFBC boiler has the flexibility to intake 100% coal. The raw materials Viz., coal is transported from Thoothukudi port by road and then stored in raw materials storage yard. Then the raw materials are taken to fuel preparation area / sizing area where the raw materials are crushed using crushers and sieved in vibrating screens to obtain required sizes and then stored in silos / bunkers. Coal is then injected and fired into the boiler to generate steam. The steam generated will then be taken to the Steam Turbine Generator and electricity (2 x 25 MW) will be produced. The steam required for process will be extracted from the turbine.

2.7 MANPOWER REQUIREMENT The manpower required for the proposed expansion projects are about 90 persons and at present there are 1000 persons working in the existing plant.

2.8 POWER REQUIREMENT The power requirement for the proposed various units are as follows. Division S.No 1 2 TCE PVC Existing 05 MW 2.63 MW 6 Power Requirement Proposed 0.5 MW 1.76 MW Source Cogen Power Plant. Cogen Power Plant.

3 4

CPVC Cogen

4 MW

1.2 MW 4 MW

Cogen Power Plant. Cogen Power Plant.

3.0 BASELINE ENVIRONMENTAL STATUS The baseline environmental status was assessed to predict the existing environmental condition of the study area covering 10 km radial distance around the proposed Expansion activity site of DCW Ltd. Baseline information for Air, Water, Noise, Flora & Fauna and Socio Economic environments are taken into consideration to assess the existing scenario. Attributes Meteorology Baseline Status The minimum temperature recorded was 19oC and maximum temperature was found to be 37oC during the study period (April to June). Annual rainfall ranges from 450 mm to 750 mm. Ambient Air Quality Ambient Air Quality was monitored at 12 locations within a 10 km radius of the project site. The observed 98th percentile PM10 levels were in range of 33.86 g/Nm3 to 55.64 g/Nm3 , The 98th percentile PM2.5 values range between 10.86 g/Nm3 to 21.82 g/Nm3. The 98th percentile Sox values range g/Nm3 to 20.9 g/Nm3. between 6.96 g/Nm3 to 17.94 g/Nm3. The 98th percentile Nox values range between 7.96

Pollutants such as CO, Cl2 & VOCs were found to be below the detection levels and hence there is no adverse impact on the air environment. From the above, it can be observed that all the parameters are within the NAAQ standards for all the locations within 10 km radius of the project site. Ambient Noise Level Noise Monitoring was carried out at 12 locations. The results of the monitoring program indicated that both the daytime and night time Noise levels were found to be within the prescribed limits for all the locations.

Water Environment

The project is located in an area where the perennial river Tambiraparani terminates about 7 KM away from Bay of Bengal.There are not much ground water dependent users. Tamil Nadu Water Supply and Sewerage Board (TWAD Board) meets water requirements for populate and the industry in the region. Agriculture depends mostly on surface water sources. Some of the populate also have their own ground water extractions systems. The groundwater levels are at a depth ranging from 2 m to 4 m below ground level in the study area, within the peripheral area of the proposed plant and in the adjoining villages.

Water Quality

10 groundwater samples and 2 surface water samples were analyzed. In general the ground water quality of the study area is good and most of the parameters are within the permissible limits ISO 10050 requirements in the study area. The minimum and maximum TDS concentration in the study area during the study periods are 1200 and 4200 mg/L respectively. The ground water quality during the rainy season may be good in the slightly higher TDS concentration areas due to natural recharge of the aquifers. The rapid assessment of ground water quality of the project area indicates that this area is free from ground water quality threat.

Soil Quality

The pH values of the samples analysed range from 6.5 to 8.5 indicating moderately alkaline nature of the soil. Electrical conductivity in the study area ranges from 0.3 to 0.6 micromhos/cm.

Organic carbon in the samples analysed range from 0.2 to 0.4 % w/w indicating deficiency in organic carbon. The nutrients like Nitrogen, Phosphorus and Potassium are on the average level and need to be supplemented for soil fertility. Biological Environment The ecological scenario in and around the site is indicative of dry to semi dry ecological conditions. There are no endangered, threatened or rare plant species at the plant species at the plant site or within 10 km radius of the plant that need to be conserved. Socio-Economic Environment There will be no issues related to land acquisition, resettlement and rehabilitation as the landfalls within DCW premises. It is also predicted that due to the expansion activities, transportation facilities, electricity, educational facilities etc will be further improved, which would lead to improve the quality of the life of the local population. This would give major economic boost in the area.

4.0 PREDICTION OF IMPACTS The potential impacts on the environment from the existing and proposed plant are identified based on the nature and extent of the various activities associated with project construction and operation. Pollution potential of the existing and proposed plant on the surrounding environment is also discussed. The existing and proposed unit will have impacts of different magnitude on varied environmental components. The sources of air pollution, water pollution and solid waste generation for the existing and proposed expansion activities are identified and the impacts due to the above are superimposed on the existing baseline environment.

5.0 ENVIRONMENTAL MANAGEMENT PLAN (EMP) Environmental Management Plan includes the protection, mitigation and enhancement measures to be implemented to reduce the adverse impact on the environment and thereby meet the stipulated norms specified by the Pollution Control Boards. The adverse environmental impacts during the functional phase of the existing and proposed expansion of TCE, PVC, CPVC and Cogen Power Plant under normal operating conditions are from air emissions, wastewater generation and solid waste generation. The abatement measures for the above are considered as per Pollution Control Boards guidelines.

5.1 CONSTRUCTION PHASE Construction time will be reduced as far as possible to minimise the adverse impacts due to construction activities. Mitigate measures practised during construction phase to minimise adverse impacts are (a) construction workers in the building construction areas will be given masks to protect them from dust, (b) workers operating noisy equipment will be provided with earmuffs/ear plugs, (c) low cost sanitation facilities will be provided for construction workers.

5.2 FUNCTIONAL PHASE 5.2.1 AIR EMISSION & CONTROL MEASURES 5.2.1.1 TCE PLANT There would be negligible air pollution during the operation of expansion activity. The reduction in the air pollution levels will be achieved by incorporating the following air pollution control measures. Acetylene sensor will be installed in the generation area to detect Acetylene leak if any and to trigger an alarm. In the Tetra Synthesis tower, Ferric Chloride will act as a catalyst to initiate the reaction between Chlorine and Acetylene. During this reaction, any increase in Chlorine will be reflected in the TetraChloro Ethane produced and will be absorbed in the Scrubber. For control of fugitive emissions, a periodical leak detection system will be in place. VOCs will be monitored in the work zone environment. Air pollution potential of the proposed expansion is very low, hence it would not have any adverse impact on Air quality.

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5.2.1.2 PVC PLANT There will be unreacted VCM containing vapors during the Polymerization reaction which will be pumped to a recovery system. The VCM containing vapors are compressed, cooled, condensed, and recycled to the process for reuse. Monitoring of VCM levels in the plant, work zone environment and fugitive emissions will be conducted. On-line monitoring of VCM will also be conducted. The major sources of air pollution from the PVC unit and the recommended control measures are as follows: AIR POLLUTION CONTROL MEASURES PVC Stack No Description of Stack Stack Height (m) PVC Plant Existing 01 02 03 04 05 06 07 08 09 Flash dryer 1st Stage Flash dryer 2nd Stage Flash dryer 3rd Stage Fluid Bed Dryer Fluid Bed Dryer Boiler I (9 T/hr) Boiler II (9 T/hr) (standby) DG Set (1450 KVA) DG Set (1500 KVA) (Stand by) 10 Boiler III (16 T/hr) (Stand by) PVC Plant Proposed 11 12 Fluid Bed Dryer DG Set (2000 KVA) 30 30 Cyclone Separator with Stack Stack 51 Low Nox burner with Stack 24.5 24.5 24.5 30 30 15 15 15 15 Cyclone Separator and Stack Cyclone Separator and Stack Cyclone Separator and Stack Cyclone Separator and Stack Cyclone Separator and Stack Stack Stack Stack Stack Control Measures

5.2.1.3 CPVC PLANT During the Chlorination process of SPVC, gases leaving the reactor will be passed through cyclones, filtered and split into two streams. The main one is recycled and the other one is sent to existing HCl unit followed by Hypo unit for the recovery of HCl and Sodium Hypo chlorite. The exhaust mixer of air from degassing vessel will be sent to HCl unit and then to the Hypochlorite unit. 11

5.2.1.4 COGEN POWER PLANT The main sources of air pollution, its control measures and fugitive emissions from the Cogen Power plant are as follows: AIR POLLUTION CONTROL MEASURES COGEN Stack No. Description of Stack Stack Height (m) Cogen Power Plant Existing 01 Boilers I & II 93 Electrostatic Precipitator with Sufficient Stack height Cogen Power Plant Proposed 02 Boilers III & IV 93 Electrostatic Precipitator with Sufficient Stack height Control Measures

The fugitive emission from the bulk material handling and storage yard will be controlled by installing suitable dust suppression system, ash conditioning using effluent.

5.2.2 WASTE WATER GENERATION, TREATMENT & DISPOSAL The Wastewater generation for the existing and proposed expansion projects of TCE, PVC, CPVC and Cogen Power Plant are summarized in below table.

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WASTEWATER GENERATION S.No Source Wastewater Generation (KLD) Existing Trichloroethylene Plant 1. 2. Lime Water from Acetylene generation Cooling Tower Blow Down 70 10 80 40 110 110 0.6 145 405.6 Chlorinated Polyvinyl Chloride 8. Cooling tower blow down Cogen Power Plant 9. 10. Cooling Tower Blow Down Reject from WTP 1172 230 1402 97 932 230 1162 3 2104 460 2564 100 25 25 Polyvinylchloride Plant 3. 4. 5. 6. 7. Softener Regenerate DM Plant reject Cooling Tower Blow Down Boiler blow down UF Reject 26 74 75 0.4 97 272.4 66 184 185 1 242 678* 70 10 80 140 20 160 Proposed Total

Total Wastewater generation from TCE

Total Wastewater generation from PVC

Total Wastewater generation from Cogen 11. Domestic

* 185 KLD of Cooling tower blow down after expansion will be recycled back to the PVC process. Treatment & Disposal of Domestic Sewage The additional sewage quantity of 3 KLD to be generated from the proposed expansion activity will be treated in the existing Sewage Treatment Plant which has been installed to a capacity of 150m3/day and it will be adequate to handle the additional flow of sewage. The treated sewage will be used for green belt development.

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Treatment & Disposal of Effluent Generated from TCE Plant The total quantity of effluent generation after expansion will be 160 KLD. Out of which, 140 KLD will be used in the High TDS and Low TDS Effluent Treatment Plant for Lime Preparation. Since the un-reacted lime from the lime boiling reactor generated will be filtered and the wet cake containing Calcium hydroxide will be used in our own integrated Effluent Treatment Plant for the neutralization purpose and 20 KLD of cooling tower blow down will be reused for gardening.

Treatment & Disposal of Effluent Generated from PVC Plant About 295.6 KLD of effluent generated from the existing unit is treated in the ETP and the treated effluent is used for Ilmenite product washing. After expansion the total quantity of effluent 493 KLD will be treated in the existing ETP which will be augmented to accommodate the additional flow of effluent to be generated from the expansion activity. Finally the treated effluent will be used for Ilmenite product washing. The Augmentation of the existing treatment plant involves addition of equipments such as pumps, Clarifier, Side stream Filter, Micron Filter and Ultra Filtration membrane system to handle the additional flow to be generated from the expansion activity.

Treatment & Disposal of Effluent Generated from CPVC Plant The only effluent generation will be of Cooling tower blow down from the proposed CPVC unit which will be reused for gardening.

Treatment & Disposal of Effluent Generated from Cogen Power Plant The total quantity of effluent generation after expansion will be 2564 KLD and this will be treated in the existing Effluent Treatment Plant where the existing RO Plant will be augmented to accommodate the additional flow of effluent to be generated from the expansion activity. One part of the treated effluent will be recycled for cooling tower makeup and the other part will be used for dust suppression and Ilmenite product washing.

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6.0 SOLID WASTE GENERATION & DISPOSAL The source, quantity of solid waste expected to be generated and its mode of disposal is given in below. SOLID WASTE GENERATION AND DISPOSAL S.No Source Quantity Generated (Tonnes/Day) Existing Non- Hazardous Waste 1. Food Wastes 0.04 0.01 0.05 Vermicomposting / Used as Manure 2. 3. Bio Sludge Calcium Hydroxide (TCE Plant) 4. Calcium Chloride (TCE Plant) 5. Fly Ash (Cogen Power Plant) Hazardous Waste 1. Used Oil (Cogen Power Plant) 2. Used Oil (PVC Plant) 0.002 0.003 0.005 0.015 0.015 0.030 Collected in barrels, stored in closed shed for safe custody and Sent to TNPCB authorized recyclers having valid 83 300 383 8.9 8.9 17.8 3.0 8 0.002 8 3.002 16 Manure for Gardening. Used in the Integrated Effluent Treatment Plant. Sent to the Solar Evaporation pit and sold as CaCl2 in solid form. Sold to Cement kilns Proposed Total Mode of Disposal

registration with CPCB.

7.0 NOISE ENVIRONMENT The noise effect on the nearest inhabitants during the construction activities will be negligible. Noise prone areas will be restricted during night times. Vehicular noise will be attenuated by the greenbelt. The noise generated in the areas including DG set, compressor without attenuation is about 90.2 dB. As noise insulation system is incorporated at initial stage for all such likely centres, noise levels are expected to be well within the specified limits.

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8.0 SOCIO ECONOMIC CONSIDERATION The project will not involve any displacement of local people. Employment opportunities will increase due to this proposed expansion projects.

9.0 CONCLUSION During the study period parameters such as ambient air quality, Noise level, Water quality and Soil characteristics were well within the TNPCB permissible limits. By implementing the above Pollution abatement projects with necessary air pollution control measures, water pollution control measures and Solid waste management. The proposed project will not have any adverse impact on the environment and will have only positive impacts.

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