Atul LTD Risk Assessment

ATUL LIMITED
EXPANSION IN EXISTING PRODUCTION CAPACITY AND

ADDITION OF NEW PRODUCTS
CHAPTER – 6 ADDITIONAL STUDIES

6.1 GENERAL
An additional study including Risk Assessment (RA), Disaster Management Plan and Occupational,
Health & Safety Management System has been carried out for the proposed expansion project to identify
main hazards, to review the effectiveness of selected safety measures and to expand the safety measures
in order to achieve a zero risk culture at the company. The study has been incorporated in the
Environmental Impact Assessment (EIA) report to support the Environmental Management Plan. The
study for the project has been further divided into the following sections:
 Risk assessment (Part - 01)

 Disaster Management Plan (Part - 02)
 Occupational Health and Safety Management System (Part - 03)
6.2 SCOPE OF THIS STUDY

The Qualitative Risk Assessment (QRA) study for proposed expansion has specifically been conducted
considering the Terms of References (TORs) given by the State Expert Appraisal Committee for
Environmental Clearance (EC).
The study has been carried out with a view to comply the following TORs:
 TOR No. 41: Disaster Preparedness and Emergency Management Plan including Risk Assessment
and damage control needs to be addressed and included
 TOR No. 42: Details of occupational health programme.
Additional TOR for Synthetic Organic Chemical Industry
 TOR No. 11: A toxic management plan shall be prepared.
 TOR No. 13: What are onsite and offsite emergency plan during chemical disaster.
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PART 01 – RISK ASSESSMENT
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6.3 GENERAL
Atul Ltd. is an agrochemical, Pharma intermediates, dyes & dyes intermediates, polymers, resins and
specialty chemicals unit located at Atul, Di. Valsad, Gujarat. Hence, it deals with various chemicals,
some of which are hazardous in nature by virtue of their intrinsic chemical properties or their operating
temperatures or pressures or a combination of them. Fire, explosion, toxic release or combinations of
them are the hazards associated with industrial plants using hazardous chemicals. Comprehensive,
systematic and sophisticated methods of Safety Engineering, such as, Hazard Analysis and Quantitative
Risk Assessment have been developed to improve upon the integrity, reliability and safety of the
industrial plant.
6.4 OBJECTIVES OF RISK ASSESSMENT

Risk analysis involves an extensive hazard analysis. It involves the identification and assessment of risks
to which the plant personnel, neighboring populations and the surrounding environment are exposed as a
result of the hazards present. This requires a thorough knowledge of failure probability, credible accident
scenario, vulnerability of population etc. Much of this information is difficult to get or generate.
Consequently, the risk analysis is often confined to maximum credible accident studies. It provides basis
for what should be the type and capacity of its on-site and off-site emergency plan and the types of
safety measures to be required for the same.
Objectives of risk assessment are:
 To identify hazard and risks resulting from the hazards
 To study and foresee the effects of such risks on the workers, public, property and the environment
 To find out necessary control measures to prevent or minimize risk
 To comply the legal requirement by various safety and environment laws of the country
 To get the necessary information for Emergency planning and evacuation
6.5 SCOPE OF THE STUDY
Atul Ltd. has proposed to enhance the production of Dyes, Chlor alkali products, Agrochemical, Resins
and other chemicals. The process deals with various hazardous chemicals. Hence, a quantitative risk
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assessment (QRA) was undertaken to assess the risk impacts associated with the installation, and to
establish a system for minimizing these risks. The QRA study in this report has specifically been
conducted considering the Terms of References (TORs) given by Expert Appraisal Committee of
MoEF&CC for Environment Clearance (EC) as mentioned below:
 TOR No. 41: Disaster Preparedness and Emergency Management Plan including Risk Assessment
and damage control needs to be addressed and included
i. Details of existing Occupational & Safety Hazards. What are the exposure levels of above
mentioned hazards and whether they are within Permissible Exposure Level (PEL). If these are not
within PEL, what measures the company has adopted to keep them within PEL so that health of
the workers can be preserved.
ii. Details of exposure specific health status evaluation of worker. If the workers‟ health is being
evaluated by pre designed format, chest x rays, Audiometry, Spirometry, vision testing (Far &
Near vision, colour vision and any other ocular defect) ECG, during pre placement and periodical
examinations give the details of the same. Details regarding last month analyzed data of above
mentioned parameters as per age, sex, duration of exposure and department wise.
iii. Annual report of health status of workers with special reference to Occupational Health and Safety.
iv. Action plan for the implementation of OHS standards as per OSHAS/USEPA.
v. Plan and fund allocation to ensure the occupational health & safety of all contract and casual
workers.
Additional TOR for Synthetic Organic Chemical Industry
i. To which chemicals, workers are exposed directly or indirectly.
ii. Whether these chemicals are within Threshold Limit Values (TLV)/ Permissible Exposure Levels
as per ACGIH recommendation.
iii. What measures company has taken to keep these chemicals within PEL/TLV.
iv. How the workers are evaluated concerning their exposure to chemicals during pre-placement and
periodical medical monitoring.
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v. Liver function tests (LFT) during pre-placement and periodical examination.
 TOR No. 11: A toxic management plan shall be prepared.
 TOR No. 13: What are onsite and offsite emergency plan during chemical disaster.
6.6 METHODOLOGY ADOPTED
Consequences of loss of containment can lead to hazardous situation in any industry handling potentially
hazardous materials. Following factors govern the severity of consequence of the loss of containment:
 Intrinsic properties; flammability, instability and toxicity.
 Dispersive energy; pressure, temperature and state of matter.
 Quantity present
 Environmental factors; topography and weather.
Consequence analysis and calculations are effectively performed by computer software using models
validated over a number of applications. Consequence modelling is carried out by PHAST of DNV
Software.
PHAST contains data for a large number of chemicals and allows definition of mixtures of any of these
chemicals in the required proportion. The calculations by PHAST involves following steps for each
modelled failure case:
- Run discharge calculations based on physical conditions and leak size
- Model first stage of release (for each weather category)
- Dispersion modeling taking into account weather conditions
- In case of flammable gas release, calculate size of effect zone for fire and explosion
6.7 CONSEQUENCE ASSESSMENT
For each defined failure case for the Chemical Storage Facility, the consequence modelling is carried out
to determine the potential effects of releases, the results of which are discussed in terms of hazard
distances.
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The corresponding consequences in terms of flammable and explosive effects are modelled and analysed
by using PHAST software version 6.7. The flammable consequences that may potentially arise from
failure of a storage vessel are:
 Jet fires;
 Flash fires;
 Toxic consequence;
 Fireball; and/or
 Explosions.
The hazard distances for each event depend on the leak size, operating conditions, weather conditions,
the release location, the release conditions and the dispersion characteristics as calculated by the PHAST
software. Each failure case is entered into PHAST software, where the corresponding consequences are
calculated, based on built-in programmable event trees.
The dispersion of gas releases from different hole sizes are modelled using state-of-art methods. For
flammable, toxic and explosive consequence, the effect zones for the various possible outcomes of such
a release are determined for both early and delayed ignition presents the consequence hazard distances
for the various tank failure case scenarios.
Consequence distances for the following weather conditions have been evaluated in the tables below,
D11: D stability (neutral) and 11 m/s wind speed.
B2: B stability (neutral) and 2 m/s wind speed.
F2: F stability (very stable) and 2 m/s wind speed.
The following descriptions are based on the different hazard types modelled, which are jet fires, flash
fires, toxic consequence, vapor cloud explosions, pool fires.
6.7.1 Jet Fire
A jet fire may result from ignition of a high-pressure leakage of gas from process plants or storage tanks.
Jet fires are characterized by a high momentum jet flame that is highly turbulent. The flame is lifted
above the exit opening from which the gas is discharged generally at high pressure. This distance
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appears because the combustion process can only take place when the flow velocity is reduced
sufficiently to allow stable combustion. Another feature of such fires is the high entrainment of air into
the flame plume due to the highly turbulent flame.
The extent of the consequence of a Jet fire is represented by the thermal radiation envelope. Three levels
of radiation are presented in this report, i.e.:
 4 kW/m2; this level is sufficient to cause personnel if unable to reach cover within 20 s; however
blistering of the skin (second degree burn) is likely; 0: lethality,
 12.5 kW/m2; this level will cause extreme pain within 20 seconds and movement to a safer place is
instinctive. This level indicates around 6% fatality for 20 seconds exposure.
 37.5 kW/m2; this level of radiation is assumed to give 100% fatality.
Jet fires are a direct hazard to people and structures caught within the flame envelope or exposed to high
thermal radiation levels. This scenario is considered for the whole storage facility in which material is
handled at the significant pressures.
6.7.2 Flash Fire
A flash fire is the non-explosive combustion of a flammable vapour cloud resulting from a release of
volatile material into the open air, which, after mixing with air, ignites. The flame initially propagates
slowly, often 10 m/s or less, and in the Shell Maplin Sands experiments often was unable to overcome
the wind speed to flash back to the source. However, where congestion or confinement exist, flame
speeds can accelerate to hundreds of m/s and overpressure effects will result.
The cloud burns as a flash fire and the major hazard to people and to equipment (especially control
cabling) is for those within the burning envelope (including those who might be above on elevated
structures). Flame duration and intensity for most flammable clouds are insufficient to cause a
significant thermal radiation hazard outside the flame envelope. The literature provides little information
on the effects of thermal radiation from flash fires, probably because thermal radiation hazards from
burning vapour clouds are considered less significant than possible blast effects. Furthermore, flash
combustion of a vapour cloud normally lasts no more than a few tens of seconds. Propane experiments
(Maplin) gave average flame speeds of up to about 12 m/s. higher transient flame speeds, up to 28 m/s
were observed in one instance. Pool Fire Formation of pools is also likely, particularly for materials that
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have high boiling points. Flash calculations were conducted to consider the vaporization of light
components in the streams, especially for high pressure or high temperature process conditions. Flashed
vapor and light component releases will behave as jets, with jet fire and vapor cloud impacts modelled in
the same way as for gas releases, as set out in the previous sections.
The extent of the consequence of a flash fire is represented by the flash fire envelope. i.e. the maximum
dispersion distance of the flammable cloud at LFL concentration.
6.7.3 Vapor Cloud Explosion (VCE)
Due to the large volume of flammable materials and highly flammable material with higher proportion
of the more volatile components, there is significant potential for Vapour Cloud Explosion Events
(VCE) in case any ignition source is not available immediately.
Maximum flammable fuel volume for prediction of explosion overpressure effects estimated to be
considerable based on inventory, isolation time, time for vaporization and probability of VCE scenario.
6.7.4 Toxic Consequences
In the event of a release of toxic material not being ignited, the concentration of material in the cloud is
progressively reduced by dilution with air until the concentration is well below any toxic effects. Such
releases do not directly affect the plant, but cloud affect people enveloped by the cloud. Distances to 3%
fatality level, or the IDLH concentration and the exposure limit have been calculated using the
dispersion models. Table No. 6.1 below summarises the toxic consequence results.
Consequence results tables below summarises representative failure cases together with their various
consequence results.
Table No. 6.1 – Consequence Results at Atul
Release Consequence Distance(m)

Sr. Accident Impact
Node Description Rate & Event
No. Scenario criteria D 11m/s B 2m/s F 2m/s
Duration
0.314 kg/s
Small Toxicity IDLH (10 ppm) 196.53 204.71 1345.30
& 300 s
7.858 kg/s
Caustic Caustic Medium Toxicity IDLH (10 ppm) 792.68 720.40 4996.31
& 300 s
1. Chlorine Chlorine Plant
Plant (ST3 & ST5) 125.7 kg/s
Large Toxicity IDLH (10 ppm) 2654.64 2252.39 18207.50
& 238.6 s
282.9 kg/s
Rupture Toxicity IDLH (10 ppm) 2816.40 2382.01 18556.80
& 106 s
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Sr. Accident Impact
Duration
0.056 kg/s
& 300 s
Chlorine 1.41 kg/s &
Medium Toxicity IDLH (10 ppm) 498.85 491.54 3168.01
Tonner 300 s
5.82 kg/s &
154.7 s
0.235 kg/s
& 300 s
5.88 kg/s &
300 s
CSA ST6/7/10
94.22 kg/s
& 300 s
212 kg/s &
259.4 s
0.218 kg/s
& 300 s
5.45 kg/s &
300 s
CSA ST-102
87.23 kg/s
& 300 s
196.3 kg/s
& 300 s
0.211 kg/s IDLH (100
Small Toxicity 37.35 32.68 116.58
& 300 s ppm)
5.274 kg/s IDLH (100
Medium Toxicity 65.71 102.78 445.71
Liq. SO3(ST- & 300 s ppm)
12/106) 84.39 kg/s IDLH (100
Large Toxicity 287.21 295.55 1117.14
& 189.6 s ppm)
189.9 kg/s IDLH (100
Sulphuric Rupture Toxicity 349.54 343.59 1124.13
2. & 84.27 s ppm)
Acid Plant
0.42 kg/s & IDLH (100
Small Toxicity 20.19 25.31 91.75
300 s ppm)
10.56 kg/s IDLH (100
25% Oleum & 300 s ppm)
ST1 169 kg/s & IDLH (100
Large Toxicity 231.26 236.03 811.92
300 s ppm)
280.2 kg/s IDLH (100
Rupture Toxicity 300.72 300.98 1080.80
& 210.4 s ppm)
0.446 kg/s IDLH (100
& 300 s ppm)
11.16 kg/s IDLH (100
ST2 178.5 kg/s IDLH (10
Large Toxicity 234.79 241.94 835.40
& 300 s 0ppm)
401.6 kg/s IDLH (100
& 300 s ppm)
0.42 kg/s & IDLH (100
300 s ppm)
10.56 kg/s IDLH (100
25% Oleum Medium Toxicity 100.98 97.28 339.88
& 300 s ppm)
ST9
169 kg/s & IDLH (100
Large Toxicity 303.93 210.74 681.43
163.2 s ppm)
Rupture 380.2 kg/s Toxicity IDLH (100 338.59 206.43 646.86
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Sr. Accident Impact
Duration
& 72.52 s ppm)
0.502 kg/s IDLH (100
Small Toxicity 30.18 43.49 174.48
& 300 s ppm)
12.57 kg/s IDLH (100
Medium Toxicity 165.20 147.05 559.12
ST101& 103 201.2 kg/s IDLH (100
Large Toxicity 519.81 420.68 1523.10
& 300 s ppm)
452.6 kg/s IDLH (100
& 169.8 s ppm)
0.056 kg/s
& 120 s
Chlorine 1.41 kg/s &
Tonner 120 s
5.82 kg/s &
120 s
0.1539 kg/s
& 1800 s
3.849 kg/s
Phosgene Medium Toxicity IDLH (2 ppm) 641.89 601.48 5485.70
& 264 s
Storage tank-
18-1/18-2 61.58 kg/s
& 16.5 s
138.6 kg/s
& 7.33 s
0.141 kg/s
& 1800 s
Phosgene 3.526 kg/s

Service tank- & 288.2 s
19-1/19-2/ 19- 56.41 kg/s
3 Large Toxicity IDLH (2 ppm) 741.54 656.32 5830.80
& 18.01 s
126.9 kg/s
Rupture Toxicity IDLH(2ppm) 742.67 679.61 6191.72
& 8s
3. Phosgene
0.001261
Small Toxicity IDLH (2 ppm) NH NH 22.98
kg/s & 60 s
Phosgene 0.03152
Medium Toxicity IDLH (2 ppm) NH 16.99 103.25
reactor kg/s & 60 s
0.292 kg/s
Rupture Toxicity IDLH (2 ppm) NH 22.81 162.45
& 6.83 s
0.00814
kg/s & 120 s
0.2036 kg/s
& 120 s
1.892 kg/s
& 16.92 s
Flash Fire 125000 ppm 0.30 0.29 0.30
Phosgene 0.0006816
Small IDLH (1200
cylinder kg/s & 180s Toxicity NH NH NH
ppm)
Flash Fire 125000 ppm 1.03 1.18 1.26
0.01704
Medium IDLH (1200
kg/s & 180 s Toxicity NH NH NH
ppm)
Flash Fire 125000 ppm 3.17 3.84 4.28
0.2726 kg/s
Large IDLH (1200
& 164.9 s Toxicity NH NH NH
ppm)
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Sr. Accident Impact
Duration
Flash Fire 125000 ppm 4.37 5.38 6.05
0.6135 kg/s
Rupture IDLH (1200
& 73.29 s Toxicity NH NH NH
ppm)
0.007104
Small Toxicity IDLH (2 ppm) NH NH 102.88
kg/s & 300 s
0.1776 kg/s
Phosgene line Medium Toxicity IDLH (2 ppm) NH 34.59 136.32
& 28.15 s
transfer to
PHIN/NBD 2.841 kg/s
Large Toxicity IDLH (2 ppm) NH 86.83 154.55
& 1.76 s
6.393 kg/s
Rupture Toxicity IDLH (2 ppm) NH 92.02 162.50
& 0.7821 s
Flash Fire 160000 ppm 2.08 1.70 2.51
37.5 kW/m2 NR NR NR
0.03349 Jet Fire
Small 4 kW/m 2
2.40 3.03 3.03
kg/s & 120 s
IDLH (300
Toxicity 21.79 32.16 95.16
ppm)
Flash Fire 160000 ppm 9.92 7.93 10.24
2
37.5 kW/m NR NR NR
0.8373 kg/s Jet Fire
Medium 4 kW/m2 8.65 11.02 11.01
& 47.77 s
IDLH (300
Toxicity 84.11 126.11 298.03
Ammonia ppm)
Cylinder Flash Fire 160000 ppm 36.46 31.55 26.82
37.5 kW/m2 NR NR NR
13.4 kg/s & Jet Fire
Large 4 kW/m 2
29.24 37.29 37.28
2.99 s
IDLH (300
Toxicity 179.53 286.25 44.27
ppm)
Flash Fire 160000 ppm 53.52 39.24 37.18
37.5 kW/m2 NR NR NR
30.14 kg/s Jet Fire
Rupture 4 kW/m 2
42.00 53.38 53.37
& 1.33 s
IDLH (300
Toxicity 235.49 96.96 51.24
ppm)
Flash Fire 160000 ppm 3.44 4.89 5.24
2
37.5 kW/m NR NR NR
0.5448 kg/s Jet Fire
Small 4 kW/m2 7.76 9.66 9.66
& 300 s
IDLH (300
Toxicity 113.67 115.09 283.81
ppm)
Flash Fire 160000 ppm 33.87 28.14 28.07
2
37.5 kW/m NR NR NR
Jet Fire
4 kW/m2 32.74 41.41 41.39
Ammonia 13.62 kg/s
Medium 37.5 kW/m2 NR NR NR
Chilling tank & 14.68 s
Pool Fire 2
4 kW/m 30.05 24.62 22.03
IDLH (300
Toxicity 238.89 272.82 405.14
ppm)
Flash Fire 160000 ppm 95.29 75.74 80.08
37.5 kW/m2 75.79 NR NR
217.9 kg/s Jet Fire 2
Large 4 kW/m 113.24 140.18 140.12
& 0.92 s
37.5 kW/m2 NR NR NR
Pool Fire 2
4 kW/m 42.90 38.30 33.72
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Sr. Accident Impact
Duration
IDLH (300
Toxicity 345.59 592.07 741.72
ppm)
Flash Fire 160000 ppm 133.99 104.39 109.76
2
37.5 kW/m 109.41 NR NR
Jet Fire
4 kW/m2 162.37 200.12 200.02
490.4kg/s &
Rupture 37.5 kW/m2 NR NR NR
0.41s
Pool Fire
4 kW/m2 45.95 41.67 37.21
IDLH (300
Toxicity 458.57 762.19 968.11
ppm)
Flash Fire 159000 ppm 0.88 1.47 1.66
0.264 kg/s
Small 37.5 kW/m2 NR NR NR
& 1800 s Pool Fire 2
4 kW/m 4.75 4.13 4.24
Flash Fire 159000 ppm 2.13 1.92 2.01
2
37.5 kW/m NR NR NR
Medium 4 kW/m2 5.87 5.52 4.89
151.2 s
37.5 kW/m2 NR NR NR
Pool Fire
4 kW/m2 13.20 9.54 9.56
MDC Chilling Flash Fire 159000 ppm 2.35 2.00 2.44

Tank 37.5 kW/m2 10.28 NR NR
105.6 kg/s Jet Fire 2
Large 4 kW/m 17.65 10.71 8.37
& 9.47 s
37.5 kW/m2 NR NR NR
Pool Fire 2
4 kW/m 13.09 9.73 9.74
Flash Fire 159000 ppm 2.35 2.10 2.44
2
37.5 kW/m 12.60 NR NR
237.6 kg/s Jet Fire
Rupture 4 kW/m2 20.87 11.75 9.47
& 4.21 s
37.5 kW/m2 NR NR NR
Pool Fire
4 kW/m2 13.12 9.77 9.80
Flash Fire 160000 ppm 9.18 9.86 7.03
37.5 kW/m2 NR NR NR
Jet Fire 2
4 kW/m 6.63 8.39 8.39
0.5492 kg/s
Small 37.5 kW/m2 NR NR NR
& 600 s
Pool Fire 2
4 kW/m 5.59 5.29 5.34
IDLH (300
Toxicity 98.09 102.01 442.98
ppm)
Flash Fire 160000 ppm 28.43 26.61 15.19
Anhydrous
Ammonia 37.5 kW/m2 NR NR NR
4. SHED C Jet Fire
Storage (C- 4 kW/m 2
26.73 33.92 33.91
03/03/30) 13.73 kg/s
Medium 37.5 kW/m2 NR NR NR
& 600 s
Pool Fire 2
4 kW/m 20.30 19.38 19.36
IDLH (300
Toxicity 352.57 263.83 1182.21
ppm)
Flash Fire 160000 ppm 79.76 46.48 43.22
2
219.7 kg/s 37.5 kW/m NR NR NR
Large Jet Fire
& 45.52 s 4 kW/m2 92.47 114.74 114.70
Pool Fire 37.5 kW/m2 NR NR NR
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Sr. Accident Impact
Duration
4 kW/m2 33.44 32.39 32.44
IDLH (300
Toxicity 687.32 278.32 1879.53
ppm)
Flash Fire 160000 ppm 105.99 61.38 59.27
37.5 kW/m2 NR NR NR
Jet Fire 2
4 kW/m 132.67 163.91 163.84
494.3 kg/s
Rupture 37.5 kW/m2 NR NR NR
& 20.23 s
Pool Fire 2
4 kW/m 33.74 32.64 32.67
IDLH (300
Toxicity 804.30 372.24 1956.15
ppm)
Flash Fire 38000 ppm 0.93 1.08 1.21
2
37.5 kW/m NR NR NR
Jet Fire
0.14 kg/s & 4 kW/m2 0.51 1.14 1.14
Small
1200 s 37.5 kW/m2 NR NR NR
Pool Fire
4 kW/m2 10.39 8.84 8.86
Toxicity IDLH (7ppm) 69.23 66.31 462.61
Flash Fire 38000 ppm 1.51 2.22 2.59
2
37.5 kW/m NR NR NR
Jet Fire
3.56 kg/s & 4 kW/m2 2.65 2.93 2.46
Medium
1200 s 37.5 kW/m2 9.06 9.08 9.10
Pool Fire
4 kW/m2 38.52 35.89 35.98
Toxicity IDLH (7 ppm) 314.55 296.78 2135.92
T-601
Flash Fire 38000 ppm 1.74 2.75 3.90
2
37.5 kW/m NR NR NR
Jet Fire
56.96 kg/s 4 kW/m2 7.08 4.32 3.69
Large
& 1200 s 37.5 kW/m2 12.14 11.70 11.70
Pool Fire
4 kW/m2 52.29 48.84 48.79
5. Epoxy Toxicity IDLH (7 ppm) 483.14 491.45 3395.35
Flash Fire 38000 ppm 1.94 3.02 4.37
2
37.5 kW/m NR NR NR
Jet Fire
128.2 kg/s 4 kW/m2 7.63 4.91 4.31
Rupture
& 829.8 s 37.5 kW/m2 12.14 11.70 11.70
Pool Fire
4 kW/m2 52.29 48.84 48.79
Flash Fire 38000 ppm 1.00 1.17 1.22
2
37.5 kW/m NR NR NR
Jet Fire
0.14 kg/s & 4 kW/m2 0.59 1.19 1.19
Small
1200 s 37.5 kW/m2 NR NR NR
Pool Fire
4 kW/m2 10.87 9.32 9.34
T-601-A Toxicity IDLH (7 ppm) 72.97 69.81 486.05
Flash Fire 38000 ppm 1.59 2.34 2.80
2
37.5 kW/m NR NR NR
Medium 4 kW/m2 2.95 3.05 2.59
1200 s
37.5 kW/m2 9.53 9.56 9.59
Pool Fire
4 kW/m2 40.44 37.75 37.84
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Sr. Accident Impact
Duration
Flash Fire 38000 ppm 1.79 2.85 4.04
37.5 kW/m2 NR NR NR
Jet Fire 2
56.96 kg/s 4 kW/m 7.07 4.47 3.92
Large
& 1200 s 37.5 kW/m2 12.14 11.70 11.70
Pool Fire
4 kW/m2 52.29 48.84 48.79
Flash Fire 38000 ppm 2.06 3.17 4.57
37.5 kW/m2 NR NR NR
Jet Fire 2
128.2 kg/s 4 kW/m 7.64 5.11 4.58
Rupture
& 825.5 s 37.5 kW/m2 12.14 11.70 11.70
Pool Fire
4 kW/m2 52.29 48.84 48.79
Flash Fire 38000 ppm 0.92 0.79 1.23
2
37.5 kW/m NR NR NR
Jet Fire
0.14 kg/s & 4 kW/m2 0.23 0.19 0.18
Small
1200 s 37.5 kW/m2 NR NR NR
Pool Fire 2
4 kW/m 9.89 8.34 8.35
Flash Fire 38000 ppm 1.38 1.99 2.21
37.5 kW/m2 NR NR NR
Jet Fire 2
3.56kg/s & 4 kW/m 1.58 1.98 1.73
Medium
1200s 37.5 kW/m2 8.57 8.57 8.59
Pool Fire 2
4 kW/m 36.54 33.94 34.01
T-608
Flash Fire 38000 ppm 1.50 2.12 2.66
37.5 kW/m2 NR NR NR
Jet Fire 2
56.96 kg/s 4 kW/m 4.76 2.82 2.36
Large
& 596.9 s 37.5 kW/m2 12.14 11.70 11.70
Pool Fire
4 kW/m2 52.29 48.84 48.79
Flash Fire 38000 ppm 1.49 2.18 2.67
37.5 kW/m2 NR NR NR
Jet Fire 2
128.2 kg/s 4 kW/m 5.07 3.19 2.72
Rupture
& 265.3 s 37.5 kW/m2 12.14 11.70 11.70
Pool Fire
4 kW/m2 52.29 48.84 48.79
Flash Fire 38000 ppm 0.93 1.07 1.22
37.5 kW/m2 NR NR NR
Jet Fire 2
0.14 kg/s & 4 kW/m 7.80 6.42 6.41
Small
T-609 1200 s 37.5 kW/m 2
NR NR NR
Pool Fire
4 kW/m2 10.48 8.92 8.94
Medium 3.56 kg/s & Flash Fire 38000 ppm 1.51 1.99 2.39
PAGE 288
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Sr. Accident Impact
Duration
1200 s 37.5 kW/m2 NR NR NR
Jet Fire 2
4 kW/m 1.81 2.05 1.79
37.5 kW/m2 9.15 9.16 9.18
Pool Fire 2
4 kW/m 38.90 36.23 36.29
Flash Fire 38000 ppm 1.57 2.21 2.69
37.5 kW/m2 NR NR NR
Jet Fire 2
56.96 kg/s 4 kW/m 4.73 2.92 2.49
Large
& 1036 s 37.5 kW/m2 12.14 11.70 11.70
Pool Fire
4 kW/m2 52.29 48.84 48.79
Flash Fire 38000 ppm 1.57 2.27 2.96
37.5 kW/m2 NR NR NR
Jet Fire 2
128.2 kg/s 4 kW/m 5.06 3.32 2.91
Rupture
& 460.3 s 37.5 kW/m 2
12.14 11.70 11.70
Pool Fire
4 kW/m2 52.29 48.84 48.79
Toxicity IDLH(7ppm) 384.04 363.58 2572.62
Flash Fire 73000 ppm 1.11 2.41 3.15
37.5 kW/m2 NR NR NR
0.124 kg/s Pool Fire
Small 4 kW/m 2
5.66 4.88 4.90
& 600 s
IDLH (6000
Methanol Toxicity 1.35 5.04 16.93
ppm)
Tank (380
KL) Flash Fire 73000 ppm 2.58 5.08 5.27
2
37.5 kW/m NR NR NR
3.09 kg/s & Pool Fire
Medium 4 kW/m2 19.69 18.97 19.08
600 s
IDLH (6000
Toxicity 4.89 7.77 20.21
ppm)
6. FDH Flash Fire 73000 ppm 1.21 2.41 3.15
37.5 kW/m2 NR NR NR
0.124 kg/s Pool Fire
Small 4 kW/m 2
5.66 4.88 4.90
& 600 s
IDLH (6000
Toxicity 0.14 1.18 16.17
ppm)
Methanol
Flash Fire 73000 ppm 2.58 5.08 5.27
Tank (90 KL)
37.5 kW/m2 NR NR NR
3.09 kg/s & Pool Fire
Medium 4 kW/m 2
19.69 18.97 19.08
600 s
IDLH (6000
Toxicity 0.14 1.92 19.08
ppm)
2
Tank On Fire Pool Fire 37.5 kW/m 31.91 35.23 178.59
The figures below represent the consequence distance due to toxic release. Due to practical difficulties
in order to capture the distances, the consequence distances between 200 m and 2000 m are only
represented. The consequence contours are shown in the best possible manner for easy reference and
understanding.
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Figure No. 6.1 – Small leak of 25% oleum from the 25% oleum ST1
Figure No. 6.2 – Medium leak of 25% oleum from the 25% oleum ST1
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Figure No. 6.3 – Large leak of 25% oleum from the 25% oleum ST1
Figure No. 6.4 – Rupture of 25% oleum from the 25% oleum ST1
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Figure No. 6.5 – Small leak 25% oleum from the 25% oleum ST9
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Figure No. 6.7 – Large leak of 25% oleum from the 25% oleum ST9
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Figure No. 6.9 – Small leak 25% oleum from the 25% oleum ST2
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Figure No. 6.11 – Large leak 25% oleum from the 25% oleum ST2
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Figure No. 6.13 – Small leak of 65% oleum from the 65% oleum
Figure No. 6.14 – Medium leak of 65% oleum from the 65% oleum
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Figure No. 6.15 – Large leak 65% oleum from the 65% oleum
Figure No. 6.16 – Rupture of 65% oleum from the 65% oleum
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Figure No. 6.17 – Small leak of ammonia from the Shed C
Figure No. 6.18 – Medium leak of ammonia from the Shed C
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Figure No. 6.19 – Large leak of ammonia from the Shed C
Figure No. 6.20 – Rupture of ammonia from the Shed C
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Figure No. 6.21 – Medium leak of Ammonia from the Ammonia cylinder
Figure No. 6.22 – Medium leak of Phosgene from the Phosgene cylinder
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Figure No. 6.23 – Large leak of Phosgene from the Phosgene cylinder
Figure No. 6.24 – Small leak of Ammonia from the Ammonia chilling tank
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Figure No. 6.25 – Medium leak of Ammonia from the Ammonia chilling tank
Figure No. 6.26 – Large leak of Ammonia from the Ammonia chilling tank
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Figure No. 6.27 – Rupture of Ammonia from the Ammonia chilling tank
Figure No. 6.28 – Small leak of Chlorine from the Chlorine Toner
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Figure No. 6.29 – Medium leak of Chlorine from the Chlorine Toner
Figure No. 6.30 – Rupture of Chlorine from the Chlorine Toner
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Figure No. 6.31 – Medium leak of CSA from the CSA ST-102
Figure No. 6.32 – Large leak of CSA from the CSA ST-102
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Figure No. 6.33 – Rupture of CSA from the CSA ST-102
Figure No. 6.34 – Medium leak of CSA from the CSA 6710
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Figure No. 6.35 – Large leak of CSA from the CSA 6710
Figure No. 6.36 – Rupture of CSA from the CSA 6710
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Figure No. 6.37 – Small leak Epichlohydrine from the Epoxy 601
Figure No. 6.38 – Medium leak of Epichlorohydrine from the Epoxy 601
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Figure No. 6.39 – Large leak of Epichlorohydrine from the Epoxy 601
Figure No. 6.40 – Rupture of Epichlorohydrine from the Epoxy 601
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Figure No. 6.41 – Small leak of Phosgene from the Phosgene tank 18 1&2
Figure No. 6.42 – Medium leak of Phosgene from the Phosgene tank 18 1&2
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Figure No. 6.43 – Large leak of Phosgene from the Phosgene tank 18 1&2
Figure No. 6.44 – Rupture of Phosgene from the Phosgene tank 18 1&2
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Figure No. 6.45 – Small Leak of SO3 from the SO3 ST12-106
Figure No. 6.46 – Medium Leak of SO3 from the SO3 ST12-106
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Figure No. 6.47 – Large Leak of SO3 from the SO3 ST12-106
Figure No. 6.48 – Rupture of SO3 from the SO3 ST12-106
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6.8 CONCLUSIONS AND RECOMMENDATIONS
The consequence distances were calculated, and have been summarized in this report. The tabulated
distances give a fair idea of the impact that would be caused by the identified scenario.
The following are recommended based on the assumptions, main findings and conclusion drawn from
this consequence study. The following best practices to be followed to demonstrate the ALARP (As
Low as Reasonably Practicable) performance:
 The existing safety measures are maintained at their expected level of performance or better to
ensure all these safety measures are in a good condition. Hence, the same shall be continued even
after the proposed expansion.
 In this facility, particularly the detection, isolation, spill containment, and ventilation etc., are to be
maintained at their expected level of performance or better. A regular inspection should be
performed to ensure all these safety measures are in a good condition throughout the facility
lifecycle.
 Regular maintenance and inspection should be performed for all critical equipment, having higher
consequence damage distance. This is to minimize potential failure due to material degradation or
fatigue.
 Ensure availability and effectiveness of Fire & Gas system and the emergency alarm system and
means of communication, which would enable early warning to all personnel in the event of
accidental release and subsequently enable all personnel to take appropriate action.
 Review arrangements focusing on worst case scenarios, offsite and onsite.
6.9 DETAILS OF STORAGE FACILITIES
Table No. 6.2 – Tank details at Atul
Operation Tank volume

Inventory Temp. Pressure Elevation
Plant Chemical Tank Phase or Full
Storage (MT) (OC) (kg/cm2) (mm)
No. Volume (m3)
Chlorine Storage ST 3 30 -18 1 to 1.5 (-775) Liquid 55

Caustic- Chlorine Storage ST 5 30 -18 1 to 1.5 (-750) Liquid 69
Chlorine
0.90mt *
plant Tonner 32 to
Chlorine 200 nos 180 8 0 Liquid 1.02
storage 35
cylinder
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No. Volume (m3)
ST 6 55 900 Liquid 41
ST 7 55 40 to Atmosphe 900 Liquid 41
Storage
ST 10 55 42 ric 900 Liquid 41
CSA
ST 102 200 0 Liquid 445
liquid SO3
ST 12 16 7000 Liquid 11
38 to Atmosphe
Sulphuric Storage ST 106 16 7000 Liquid 11
40 ric
acid plant ST 11 0 4100
ST 1 80 0 Liquid 54
45 to Atmosphe
25 % Oleum Storage ST 2 150 0 Liquid 85
48 ric
ST 9 17 750 Liquid 11
ST 101 65 45 to Atmosphe 600 Liquid 41
65 % Oleum Storage
ST 103 65 48 ric 600 Liquid 41
Feeding
to
reactor 900 kg* 5 Ambie 5-8 On the Liquid
Chlorine Tonner 1.02
through tonner nt kg/cm2 ground & gas
Chlorine
tonner
Storage
18-1 /
in Tank
18-2 (
18-1 / Maximum Atmosphe
Phosgene Two - 16' C 1 meter liquid 7
18-2 ( 2 1 T in each. ric
identical
identical
tank)
tank)
19-1 /
Service 19-2/
tank (3 19-3 Maximum 1.2
Phosgene -10 ' C 1 meter liquid 2
identical (three 1 T in each. kg/cm2
tank) identical
tank)
R-1 / R-
2 ( two
identical 0.015
Phosgene Reactor 2 kg 50 ' C 3 metre gas 0
reactor kg/cm2
Phosgene in
series)
Cylinder 32 kg * 20 Ambie 1.5 On the Liquid
Phosgene cylinder
storage cylinder nt kg/cm2 ground & gas
2 meter
dome ht. (
CO Ambie 0.015
CO Holder 40 m3 holder gas 33
holder nt kg/cm2
height is 6
meters)
Line
Line to
transfer 0.4
Phosgene NBD 5 kg 40' C 5 meter gas 0
to PHIN kg/cm2
plant
/NBD
Feeding
to 40 kg x 5 Ambie 10 On the
Ammonia Cylinder Liquid
chilling cyls. nt kg/cm2 ground
system
Chilling Chilling Ambie 15 On the Liquid
Ammonia 200 KG
system tank nt kg/cm2 ground & gas
Chilling
MDC chilling 1000 kg -17' C 2 kg/cm2 1 meter Liquid 3
tank
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No. Volume (m3)
In a sump 1
meter
Anhydrous C03/03/ Ambie 10.5
SHED C Storage 10 MT below liquid 22
ammonia 30 nt kg/cm2
ground
level
50 mm of
Ambie Above
T-601 90 KL H2O with liquid 126
nt ground
N2
50 mm of
Ambie Above
T-601-A 100 KL H2O with liquid 123
nt ground
Epichlorohydri N2
Epoxy Storage
ne 50 mm of
Below Above
25 ˚C. ground
N2
50 mm of
Below Above
25 ˚C. ground
N2
Ambie Atmosphe Above
380 KL liquid 387
nt ric ground
Ambie Atmosphe Undergrou
FDH Methanol Storage 90 KL liquid
nt ric nd
Ambie Atmosphe Undergrou
90 KL liquid
nt ric nd
Table No. 6.3 – Raw Materials Consumption details
Quantity Quantity
Sr. Total after Total after
Product Existing Raw Material Existing
No. expansion expansion
TPM TPM
DYES
2,4-DNCB 132.26 440.85
Caustic Soda lye 32% 539.94 1799.80
Sulphur 159.09 530.30
1. Sulfur Black 250 833.33
Sodium Chloride 46.82 156.08
Sodium Sulphide 30.12 100.40
Soda Ash 8.21 27.38
CHLORO – ALKALI INDUSTRY
Caustic soda /
1. Potash & Sodium NaCl (100%) 2592.50 5718.75
Sulfide
3400 7500
Liquid Chlorine / Barium carbonate
26.69 58.88
2. HCl (100%)
Sodium Carbonate 9.86 21.75
PAGE 316
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Quantity Quantity
TPM TPM
(100%)
HCl (100%) 30.60 67.50
NaOH(100%) 25.50 56.25
NaHSO3 (100%) 0.68 1.50
Flocculating agent 0.07 0.15
Precoat alfa cellulose 0.60 1.31
Water 6409.00 14137.50
Sulfuric acid (100%) 25.50 56.25
PESTICIDE TECHNICAL
Toluene 13.77 17.91
Sodium methoxide 0.89 1.15
Dimethyl carbonate 2.87 3.73
Indanone 1.78 2.32
HCl 1.70 2.21
NaHCO3 soln. 1.59 2.07
Cinconine 0.32 0.42
TBHP 1.23 1.60
Toluene 0.37 0.48
HCl 9.25 12.03
Carbamate group NaOH 1.33 1.72
1. of 33.3 43.3 Ethylene Dichloride 9.34 12.14
Agrochemicals BCZ 0.62 0.80
PTSA 0.04 0.06
HyFlow 1.18 1.54
P2O5 1.18 1.54
Methylal 1.52 1.98
IPA 2.66 3.46
ZnBr2 0.06 0.08
Pd/C 0.04 0.06
MA 20.06 26.08
Citric acid 1.91 2.48
Caustic flakes 0.36 0.47
PAGE 317
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Quantity Quantity
TPM TPM
H2 0.06 0.08
N2 0.03 0.04
NaHCO3 0.36 0.47
Silica 0.56 0.73
Hexane 16.71 21.73
MCB 111.24 1223.60
Dichloro aniline 13.76 151.40
2. Diuron 20 220 Phosgene 12.08 132.87
Charcoal 0.28 3.09
DMA 4.07 44.80
Sulphuric acid 12.50 14.58
Guanidine Nitrate 16.25 18.95
Nitro guanidine 45.00 52.49
EDA 32.85 38.32
Pyridine based HCl 200.00 233.28
insecticides &
3. Herbicides 25 29.16 KOH 125.00 145.80
chemical 2-[Nitroimino]
12.71 14.82
Imidacloprid imidazolidine
2-chloro-5-
18.65 21.75
methylchloro-pyridine
Sodium Methoxide 10.00 11.66
DMF 28.13 32.81
PCF 10.88 15.35
2-Amino-4,6
10.60 14.95
dimethoxy pyridine
Dioxane 36.09 50.89
NN Dimethyl Aniline 12.46 17.57
4. Sulphonyl Urea 25 35.25
IPA 56.39 79.51
SNA 15.66 22.09
Acetonitrile 71.43 100.71
DBU 10.10 14.24
HCl Solution (30%) 25.06 35.34
5. Glyphosate 50 65 PMIDA 69.06 89.78
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Quantity Quantity
TPM TPM
Sodium tung state 0.21 0.27
50% H2O2 24.17 31.42
10% FeSO4 10.36 13.47
Di Isopropyl Malonate 7.58 16.72
CS2 3.67 8.09
Acetone 22.35 49.27
6. Isoprothiolane 8.3 18.3 NaOH 7.98 17.60
TBAB 0.04 0.09
Ethylene Dibromide 7.02 15.48
n-Hexane 16.84 37.13
Acetonitrile 0.00 1.47
Pyrimidine carbamate 0.00 0.35
1-methyl-4-
ethoxycarbonyl
7. Pyrazosulfurone 0 0.5 0.00 0.29
pyrazole -5-
sulfonamide
TEA 0.00 0.19
Methanol 0.00 0.59
THF 0.00 1.74
Bis Pyribac 2,6-DHBA 0.00 0.40
8. 0 0.83
Sodium 4,6-DMMSP 0.00 0.81
Sodium hydride 0.00 0.34
Toluene 0.00 6.74
DMF 0.00 0.58
CPOPMA 0.00 1.87
9. Azoxystrobin 0 2.08 2-Cyanophenol 0.00 0.85
K2CO3 0.00 1.21
DABCO 0.00 0.01
Methanol 0.00 3.17
Ethyl-2-(4-hydroxy
0.00 0.75
phenoxy) -propionate
10. Quizalofop 0 1.25
2,6-dichloro
0.00 0.83
quinoxaline
PAGE 319
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Quantity Quantity
TPM TPM
Potassium carbonate 0.00 0.56
DMF 0.00 0.76
Ethanol 0.00 0.63
2-chloro-5-chloro
0.00 7.80
methyl thiazole
3-methyl-4-nitroimino
perhydro-1,3,5- 0.00 7.60
11. Thiamethoxam 0 10 oxadiazine
Potassium hydroxide 0.00 2.00
Dimethyl carbonate 0.00 2.00
Ethanol 0.00 3.40
4-amino-6-tertiary-
butyl-3-mercapto- 0.00 10.10
1,2,4-triazinone
12. Metribuzine 0 10 98% Sulfuric acid 0.00 16.15
Methanol 0.00 2.02
48% Caustic lye 0.00 28.37
4-phenoxy-2, 6-
diisopropyl phenyl 0.00 3.80
isothiocyanate
13. Diafenthiurone 0 4.17 Tertiary butyl amine 0.00 0.89
Toluene 0.00 3.00
Hexane 0.00 7.59
RESIN
BPA ( Solid ) 1746.76 1816.63
ECH /recovered ECH 5325.49 5538.51
1. Epoxy Resin 2500 2600
CSL (48%w/w) 1250.00 1300.00
IPA 25.56 26.58
Solvents 0.00 240.00
Polygrip rubber Chlroprine rubber 0.00 45.00
2. 0 300
based PTBP Resin 0.00 12.00
Rosin modified resin 0.00 3.00
Polygrip TPU Solvents 0.00 35.42
3. 0 41.67
based TPU 0.00 6.25
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Quantity Quantity
TPM TPM
OTHER CHEMICALS
Phenol 0.00 150.56
1. Anisole 0 166 Di-methyl Sulfate 0.00 138.44
CS Lye (48%) 0.00 162.51
Resorcinol 0.00 84.48
1,3 Caustic soda flakes 0.00 30.72
2. Cyclohexanedion 0 80 Hydrogen 0.00 1.68
e Catalyst 0.00 0.74
HCl (36%) 0.00 84.48
Acetone 0.00 37.57
Reso - Tar 0.00 15.05
Hyflo 0.00 0.68
3. Resoform P-18
Formaldehyde 0.00 30.26
Powerflex Oil 0.00 0.85
Acetone 0.00 74.29
Reso - Tar 0.00 30.35
Hyflo 0.00 0.68
4. Resoform P-19
37% Formaldehyde 0.00 24.82
0 85 Powerflex Oil 0.00 0.85
Acetone 0.00 11.39
Reso - Tar 0.00 3.83
Hyflo 0.00 0.68
Formaldehyde 0.00 20.49
5. Resoform P-20 Powerflex Oil 0.00 0.85
Para toluene sulfonic
0.00 0.17
acid
Styrene 0.00 29.92
Ethanol 0.00 1.28
CS Lye 0.00 0.09
PAGE 321
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Quantity Quantity
TPM TPM
P-cresol 0.00 731.69
Ra-Ni catalyst 0.00 43.90
Hydrogen 0.00 35.26
Glacial acetic acid 0.00 543.03
Sodium hypochlorite
0.00 3622.31
14.3w/w solution
Sodium bisulphate 5%
0.00 541.75
solution
Caustic lye 48%w/w 0.00 487.01
6. Trans-4-MCHI 10% Brine solution 0.00 676.72
Sodium hydroxide 0.00 485.33
Hydroxyl amine.HCl 0.00 475.03
Sodium metal 0.00 659.85
n- Butanol 0.00 9877.00
H2 (g) 0.00 6.38
30 % HCl 0.00 510.45
0 415 Acetone 0.00 5104.50
Phosgene 0.00 723.76
Toluene 0.00 1785.33
4-Methoxybenzyl
0.00 376.41
p-Anisyl alcohol
7.
chloroformate Phosgene 0.00 346.11
MDC 0.00 406.29
Sodium-t-butoxide 0.00 755.30
DI-TERT- Carbon dioxide gas 0.00 346.53
BUTYL Phosgene 0.00 369.35
8. DICARBONAT
E (Boc. Ethyl acetate 0.00 4096.05
anhydride) Triethyl amine 0.00 136.95
Hyflo 0.00 107.07
N- Hydroxy
N, N- 0.00 419.15
Succinimide
9. Disuccinimidyl
Tribtyl Amine 0.00 778.13
Carbonate
Phosgene 0.00 228.25
PAGE 322
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Quantity Quantity
TPM TPM
THF 0.00 4150.00
2-4 Di chloro Aniline 0.00 5.50
NaNO2 0.00 2.50
toluene 0.00 2.50
HCL 0.00 10.00
Na2SO3 0.00 10.50
H2SO4 0.00 0.50
HCl soln. 0.00 34.00
NaOH soln. 0.00 33.00
t-Butyl alcohol 0.00 29.00
HCHO 0.00 2.50
Sodium Cynate 0.00 3.50
Acetic Acid 0.00 3.00
13% Hypochlorite
0.00 17.00
Solution
NaOH flakes 0.00 2.50
10. HX-13059 0 5 HCl 0.00 13.00
Pure 4-Methyl
0.00 8.15
cyclohexyanol
Glacial acetic acid 0.00 6.54
Sodium hypochlorite
0.00 43.64
14.3 w/w solution
Sodium bisulphate 5%
0.00 6.53
solution
Caustic lye 48% w/w 0.00 5.87
10% Brine solution 0.00 8.15
Hydroxyl amine.HCl 0.00 5.72
Sodium metal 0.00 7.95
n- Butanol 0.00 119.00
H2 (g) 0.00 0.08
30 % HCl 0.00 6.15
Acetone 0.00 61.50
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Quantity Quantity
TPM TPM
Phosgene 0.00 8.72
Toluene 0.00 21.51
FLAVORS & FRAGRANCES
Anisole 0.00 173.33
Propionyl chloride 0.00 167.16
AlCl3 0.00 223.32
EDC 0.00 331.99
13% NaCl 0.00 277.82
10% NaHCO3 0.00 127.33
1. Anethole 0 166.66
Rainey Ni 0.00 5.15
TEA 0.00 0.51
Methanol 0.00 208.33
H2 (g) 0.00 2.86
KHSO4 0.00 2.08
Paraffin oil 0.00 9.13
4-t-butylbenzoicacid 0.00 82.81
Methanol 0.00 74.63
98% H2SO4 0.00 10.14
5% Na2CO3 0.00 33.12
4-
2. Avobenzone 0 83.33 0.00 60.88
methoxyacetophenone
Sodium methoxide 0.00 26.84
Toluene 0.00 460.09
10% H2SO4 0.00 272.71
p-cresol 0.00 129.22
NaOH (flaks) 0.00 167.00
Raspberry
3. 0 100 Cobalt acetate 0.00 1.99
Ketone
Copper oxide 0.00 0.48
Oxygen 0.00 49.70
Acetone 0.00 119.28
PAGE 324
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Quantity Quantity
TPM TPM
30% HCl 0.00 273.36
Ra-Ni (1961) 0.00 1.29
Hydrogen 0.00 2.98
Triethyl amine 0.00 1.57
Divyol oil 0.00 4.97
p-Anisic aldehyde 0.00 179.00
Propanaldehyde 0.00 51.00
Sulfuric acid 0.00 1.32
P-Anisyl sodium bicarbonate 0.00 2.20
4. 0 100
Propanal Sodium carbonate 0.00 2.22
Toluene 0.00 150.00
5% Palladium Carbon 0.00 1.43
Divyol Oil 0.00 2.20
BHT 0.00 0.35
H2 (g) 0.00 1.11
Cyanoacetic acid 0.00 32.92
2 - Ethyl hexanol 0.00 56.50
p - Toluenesulfonic
0.00 1.08
acid
Benzophenone 0.00 101.50
Acetic acid 0.00 71.08
5. Octacrylene 0 83.33 Ammonium acetate 0.00 20.58
Cyclohexane 0.00 57.08
NaCl 0.00 7.08
Darco 0.00 7.17
Hyflowsupper cell 0.00 1.92
Anhyd. Na2SO4 0.00 1.92
Octyl Methoxy p-Anisaldehyde 0.00 118.60
6. 0 200
Cinnamate Ethyl acetate 0.00 436.00
PAGE 325
ATUL LIMITED
Quantity Quantity
TPM TPM
Ethyl hexanol 0.00 135.00
Sodium methoxide
0.00 60.40
powder
Sodium methoxide
0.00 22.80
solution
Phosphoric acid 0.00 4.50
Formic acid 0.00 1.30
Divyol 460 0.00 21.60
Darco 0.00 2.60
Hyflo supercell 0.00 1.10
Table No. 6.4 – Products details
Sr. Capacity (TPM)

Product
No. Existing Proposed Total
A. DYES
1. Azo dyes 550.00 0.00 550.00
2. Sulfur Black 250.00 583.33 833.33
3. Sulfur Dyes Range 25.00 0.00 25.00
4. Napthol Range 75.00 0.00 75.00
5. Fast Color Bases 40.00 0.00 40.00
6. Disperse Dyes (Atul-East) + Disperse Dyes (Atul-West) 118.50 0.00 118.50
7. Optical Brighteners 10.00 0.00 10.00
8. Reactive Dyes 127.30 0.00 127.30
9. Vat dyes 105.00 --- 105.00
Total Production Capacity of Dyes 1,300.80 583.33 1,884.13
B. CHLORO – ALKALI INDUSTRY
10. Caustic soda / Potash & Sodium Sulfide 1,800.00 2,200.00 4,000.00
11. Liquid Chlorine / HCl 1,600.00 1,900.00 3,500.00
Total Production Capacity of Chloro – Alkali Industry 3,400.00 4,100.00 7,500.00
C. PESTICIDE TECHNICAL
12. Carbamate group of Agrochemicals 33.3 10 43.3
13. Diuron 20 200 220
PAGE 326
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Sr. Capacity (TPM)

Product
14. Isoproturon 8.30 -8.30 0.00
15. Metoxuron 8.30 -8.30 0.00
16. Trichlo Carbon 8.30 0.00 8.30
17. Cartap. HCl 50.00 0.00 50.00
18. Carbendazim 20.90 0.00 20.90
Herbicides
19. 1,670.00 0.00 1,670.00
(2,4 – D & related products)
Pyridine based insecticides & Herbicides chemical
20. 25.00 4.16 29.16
Imidacloprid
21. Triazole based Fungiside 1.67 0.00 1.67
22. Pyrethroides 10.00 0.00 10.00
23. Sulphonyl Urea 25.00 10.25 35.25
24. MCPA 500.00 0.00 500.00
25. Glyphosate 50.00 15.00 65.00
26. Isoprothiolane 8.30 10.00 18.30
27. Fipronil 5.00 0.00 5.00
28. Formulation 200.00 0.00 200.00
29. Pyrazosulfurone 0.00 0.50 0.50
30. BisPyribac Sodium 0.00 0.83 0.83
31. Azoxystrobin 0.00 2.08 2.08
32. Quizalofop 0.00 1.25 1.25
33. Thiamethoxam 0.00 10.00 10.00
34. Metribuzine 0.00 10.00 10.00
35. Diafenthiurone 0.00 4.17 4.17
Total Production Capacity of Pesticide Technical 2,644.07 261.64 2,905.71
D. BULK DRUGS & PHARMACEUTICALS
36. Mabendazole 2.00 0.00 2.00
37. Tolbutamide 2.50 0.00 2.50
38. Quiniodochlor 15.00 0.00 15.00
39. Bulk drugs & intermediates 9.60 0.00 9.60
40. Diclofenac Sodium / Potassium 2.50 0.00 2.50
41. Atenolol 1.70 0.00 1.70
42. Fresamide 1.30 0.00 1.30
43. Trimethoprim 0.90 0.00 0.90
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ATUL LIMITED
Sr. Capacity (TPM)

Product
44. Para Hydroxyacetophenone 1.70 0.00 1.70
45. Para Hydroxy Phenyl acetamide 3.00 0.00 3.00
46. Acyclovir 5.20 0.00 5.20
47. Bathenechol 5.20 0.00 5.20
48. Pharma Intermediates and chemicals 300.00 0.00 300.00
Total Production Capacity of Bulk Drugs &
350.60 0.00 350.60
Pharmaceuticals
E. RESIN
49. Epoxy Resin 2,500.00 100.00 2,600.00
50. Vinyl Ester Resins 37.50 0.00 37.50
Ketone Formaldehyde Resins &Sulphonamide,
51. 20.80 0.00 20.80
Formaldehyde Resins
52. UF/MF/PF/ Di Cyanadiamide Resins 270.90 0.00 270.90
53. Polyamide Resins 161.70 0.00 161.70
54. Polygrip rubber based 0.00 300.00 300.00
55. Polygrip TPU based 0.00 41.67 41.67
Total Production Capacity of Resin 2,990.90 441.67 3,432.57
F. OTHER CHEMICALS
Anthraquinone, Naphthalene, Benzene Intermediates.
56. 740.00 0.00 740.00
(including Beta – Napthol& BON Acid
57. M Hydroxy Phenol 460.00 0.00 460.00
58. Anisole 0.00 166.00 166.00
59. 1,3 Cyclohexanedione 0.00 80.00 80.00
60. Resoform P-18
61. Resoform P-19 0.00 85.00 85.00
62. Resoform P-20
63. Carbamite 30.00 0.00 30.00
64. Chlorzoxazone& other related products 5.00 0.00 5.00
Agro, Pharma intermediates, Isocyanats& Carbonate
100.00
esters, chloroformats etc.
Trans-4-MCHI
65. 315.00 415.00
p-Anisylchloroformate
----
DI-TERT-BUTYL DICARBONATE (Boc. anhydride)
N, N- Disuccinimidyl Carbonate
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ATUL LIMITED
Sr. Capacity (TPM)

Product
66. HX-13059 0.00 5.00 5.00
67. 4 Ethyl 2,3 – Diocopiperazino carbonyl chloride 3.30 0.00 3.30
68. IminoDibenzyl 5 Carbonyl Chloride 0.80 0.00 0.80
Other chemicals (DCP, MCA, MEA, DEA, PCl3, PAA,
69. 425.00 0.00 425.00
MAP etc.)
70. Formaldehyde and base products 3200.00 0.00 3200.00
71. Sulfuric acid / Oleum / Chlorosulphonic acid & salts 11,550.00 0.00 11,550.00
72. Sulpha drug intermediates 193.80 0.00 193.80
73. Acetyl Sulphanilyl Chloride & its derivatives 1,500.00 0.00 1,500.00
74. Acetanilide 500.00 0.00 500.00
75. Sulpha Methyl Phenazole Sodium 1.10 0.00 1.10
76. Pyrazole Base 10.50 0.00 10.50
77. Sulphanilic acid 25.00 0.00 25.00
78. Bis Phenol A 416.70 0.00 416.70
79. Hexamine 150.00 0.00 150.00
80. Epoxy Intermediates 23.80 0.00 23.80
81. Hardener & Auxiliaries 500.00 0.00 500.00
82. Hardener & Intermediates 700.00 0.00 700.00
83. Bisphenol S & Intermediate Chemicals 16.60 0.00 16.60
Total Production Capacity of Other Chemicals 20,551.60 651.00 21,202.60
G. FLAVORS & FRAGRANCES
84. Anethole 0.00 166.66 166.66
85. Avobenzone 0.00 83.33 83.33
86. Raspberry Ketone 0.00 100.00 100.00
87. P-AnisylPropanal 0.00 100.00 100.00
88. Octacrylene 0.00 83.33 83.33
89. OctylMethoxyCinnamate 0.00 200.00 200.00
Total Production Capacity of Flavors & Fragrances 0.00 733.32 733.32
Grand Total 31,237.96 6,770.95 38,008.91
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ATUL LIMITED
6.10 SAFETY MEASURES
It is practically impossible to reduce the risk to zero. However, effective measures can certainly reduce
the risk considerably. The safety measures intends to reduce the risk related to various hazards present at
the work place.
The details of various safety measures to be considered by Atul Ltd. at various stages of project are as
detailed below:
6.10.1 Process safety measures
The following Safety measures have been adopted from the design stage itself.
 Provision of Safety Valve and pressure gauge on reactor and its jacket.
 Availability of utilities like Chilling water, chilled Brine, Nitrogen, cooling water, vacuum lines,
steam supply and its alternatives to control reaction parameters and avoid undesired reactions,
are/shall be made available.
 Provision of Static earthing at design stage to all solvent handling equipment, reactors, vessels &
powder handling equipment.
 Appropriate Earthing to all the vessels and equipment and protection against Static Electricity.
Also provision of proper earthing facilities for draining in drums.
 Easy access to all emergency valves and switches and emergency handling facilities.
 No free fall of any flammable material in the vessel.
 Safe distance between all solvents and flammable material storage tanks and the process plant.
 Provision of PPEs to all the employees to protect against any adverse health effect during
operations, leakage, spillages or splash.
 Provision of PPE like Helmets, Safety Shoes, Safety Glasses, Acid-Alkali Proof Gloves etc. to the
employees.
 Availability of Material Safety Data Sheets of Raw Materials & Products on the shop floor.
 Provision of Flame arrestor for solvent wherever required for solvent storage and handling.
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ATUL LIMITED
6.10.2 Safety measures to be considered during transportation of raw materials
 Transportation of raw materials in drums on pallets (through trucks) for liquid raw materials and
solvents.
 Provision of static earthing for tanker unloading.
 Use of only earthed flexible steel hose for solvent unloading from the road tanker.
 Provision of fixed pipelines with pumps for solvent transfer up to day tanks/reactors.
 Installation of Double mechanical seal type pumps.
 Provision of NRV on all pump discharge line.
Control Measures for Sulfuric Acid (H2SO4)
Sr. Hazard
Process/ Activity Risk Control Measures
No. involved
Exposure to
sulfuric
The Sulfuric acid to be transported in
vapors and
the special containers with a
Transportation of Road Accident harm to
competent driver.
1. Sulfuric acid in and leakage of human
The transport route to be preplanned
the road tanker sulfuric acid beings,
to avoid accidents and transported in
general public
the less populated areas.
and animals
Air pollution
Exposure to The unloading is to be done under
Leakages of
sulfuric acid nitrogen pressure with a suitable
sulfuric acid
Unloading of vapors and high pressure hose.
during
2. Sulfuric acid from harm to The unloading crew has to be
Transfer –
road taker workers/ competent and with proper training.
unloading
employees USE of required PPE to be done
using hose
Air pollution while unloading.
Exposure to The concentration of the acid to be
Risk due to
sulfuric acid marinated above 90 % all the time as
Storage of leakage and
vapors and the dilute is corrosive to the ordinary
Sulfuric acid in over
3. harm to Mild steel tank
the designated pressurization,
workers/ Corrosion monitoring of the tank
area Safety valve
employees (Thickness testing) to be done
gets operated
Air pollution periodically.
Rupture of Heavy leakage Injury and Maintain acid concentration above
4.
Sulfuric acid line of sulfuric acid Health effect 90% all the time.
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ATUL LIMITED
Sr. Hazard
Process/ Activity Risk Control Measures
No. involved
on the The acid lines to inspect regularly.
employees/wo Corrosion proof MOC should be
rkers and selected e.g. HDPE pipe line instead
nearby of MS line.
surroundings
Reactive with Can result in Operational control to be exercised
oxidizing agents, fire, Injury to to avoid mixing of acid with other
reducing agents, Unwanted employees agents like wood, paper cloth to be
5.
combustible reactions and avoided.
materials, organic surrounding Training of the operating staff to be
materials, people given
Safety Measures for Hydrogen
Brief description of the safety measures taken for Hydrogen storage
 Preventive inspection and maintenance
 Flame proof electrical appliances, tools.
 Earthing strip to be provided at entry to discharge electrostatic charge.
 Earthing have to be provided form both sides of the trucks during filling & being followed.
 Hydrogen sensors with alarm for immediate detection provided on all hydrogen compressor.
 Jumpers provided on all the flange joints.
 Storage system - approved by CCE.
Brief description of the safety measures taken for Hydrogen gas pipe line
 Use of schedule 40, CS seamless pipeline;
 Pipeline is to be laid above ground on firm & fixed supports, except at road crossing.
 Pipeline is to be protected against overpressure by two stage Pressure Reducing Valves and
Pressure Control Valve.
 Control valve is to be connected with the most advanced Distributed Control System, which can
stop hydrogen supply immediately from control room.
 Pipe-line is to be duly hydro-tested at 1.5 times the operating pressure.
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ATUL LIMITED
 Fixed schedule for the regular inspection and maintenance of this piping.
6.10.3 Systems for Fire Fighting
The risk to people after a fire has started largely depends on the adequacy and maintenance of means to
escape, the alarm system, training of the workforce in fire routine and evacuation procedures. At Atul
Ltd., the company has proposed to employ well-resourced and adequate fire fighting network.
Details regarding the fire fighting capacity of the unit are given below:
Table No. 6.5 – Fire Fighting Details
Fire
Number of Fire Details Foam type
Type of Fire water Hydrant Other relevant
Fire pump Deluge valve and
Extinguishers Reservoir Pressure details
extinguishers capacity arrangements quantity
Capacity
Fire hydrant
1) CO2 Mechanical system covering
2) ABC 275 Foam Raw material
145 45000 m3 7Kg/m2 04
3) Foam m3/hr Concentrate storage, fuel &
4) Water CO2 200 lit finish good
storage area
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ATUL LIMITED
Figure No. 6.49 – Fire Hydrant Layout
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ATUL LIMITED
Figure No. 6.50 – Photographs of Onsite Mock Drill & Fire Fighting Training
Fire Tender Onsite Mock Drill
Fire Fighting Training
6.10.4 Additional firefighting measures for proposed expansion
 Safety Sirens with Alarm System in case of emergency shall be provided.
 Emergency Control Room shall be established.
 Assembly points shall be identified.
 First Aid Facility and training shall be provided for the proposed project.
 Personal protective gears and equipment shall be provided for the proposed project.
 Health checkups shall be organized at regular intervals.
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ATUL LIMITED
 Safety Training shall be provided to the employees.
 Sprinkler Systems shall be provided as and when needed.
 Mock drills shall be periodically conducted and factors like response time shall be evaluated.
 Fire squad team shall be formed for handling any emergency situation.
 Fire Hydrant System shall be installed which shall be used for the proposed project.
 Fire Extinguishers shall be provided.
6.10.5 Other safety measures to be employed during the Proposed Project
To maintain high standards in Health, Safety and Environment, various activities shall be undertaken at
the site.
The following key safety measures shall be a part of the proposed project to be implemented by the
proponent:
A. Personnel Safety Measures
 Safety Training shall be regularly provided to the employees.
 Safety Sirens with Alarm System in case of emergency shall be provided.
 Emergency Control Room shall be established.
 Assembly point shall be predetermined and provided as per the requirement.
 Sprinkler Systems shall be provided as per the need.
 Fire Hydrant System shall be installed.
 Fire Extinguishers are also proposed to be provided.
 Mock drills shall be periodically conducted and factors like response time to be evaluated.
 Fire squad team shall be formed for handling any emergency situation.
 First Aid Facility and training shall be regularly provided.
 Personal protective gears and equipments shall be provided to the employees.
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ATUL LIMITED
 Health checkups shall be organized at regular intervals.
 Safety / Health records and MSDS shall be maintained.
B. Noise Environment
 Use of PPE like ear plugs and ear muffs shall be made compulsory near the high noise generating
machines.
 Moreover, the personnel shall be provided breaks in their working hours with the continuous
exposure not increasing more than three (3) hours.
 The plant and equipments are designed with a view to minimize noise pollution.
 To reduce noise, pipe lines shall be liberally sized for low velocities.
 Safety blow off valves, discharge pipes, relief valves, etc. shall be equipped with silencers.
Hearing Conservation program shall be imparted where noise level exceeds 90 dB (A).
PAGE 337
ATUL LIMITED
PART 02 – DISASTER MANAGEMENT PLAN
PAGE 338
ATUL LIMITED
6.11 ON SITE EMERGENCY PLAN
PAGE 339
YEAR – 2015
(Revised on 31/012/2015)
ATUL LIMITED
P.O. ATUL - 396 020
GUJARAT
INDIA.
Safety Health & Environment Dept. Page 25

ATUL LIMITED P.O.
ATUL – 396 020
ON SITE EMERGENCY PLAN
I N DEX
Section I: PROCEDURES
SUBJECT
Sr. No. Particulars
1 Purpose
2 Types of Emergency
3 Control Room
4 Risk and Environmental Impact Assessment
5 Organization for tackling emergency
6 Emergency Alarm System
7 Telephone communication guideline
8 Safe shut down procedure
9 Emergency Alarm system
10 Declaration of major emergency
11 Communication in case of major emergency
12 Mutual aid
13 General
14 Accident investigation & reporting
15 Public relations
16 Plant relations
17 Personnel Protective Equipment / Emergency equipment
18 Safety devices
19 Revision & up dating
20 Mock drills & training – Enclosures

1. PURPOSE:
This plan is prepared to cope up with any emergency, which could occur during
operation. The purpose of this plan is to protect the employees, people residing
in the neighboring areas, the company’s properties and environment to the
maximum possible extent in the event of fire, explosion, toxic spillage’s / releases
due to our own operations, or operations of neighboring companies or natural
calamities like flood, cyclone earthquake etc.
2. TYPES OF EMERGENCIES:
FIRE:
In ATUL– East Site flammable solvents, gases and substances are stored used in
various operations. These substances can catch fire by source of ignitions like
sparks, static electricity, welding and cutting operations, chemical reactions,
electrical short circuits, smoking in non smoking area etc. if air / oxygen /oxidizing
agents also available.
EXPLOSION:
Explosion can result from uncontrolled rate of chemical reaction. overheating or due
to mixture of air with solvent vapors, flammable gases. or flammable dust.
TOXIC SPILLS / RELEASE
Bursting of drums, damage to storage vessels / measuring vessels over

pressurization leading to failure of rupture disc or opening of safety valves or wrong
operation or malfunctioning of valves etc. may result into a toxic spill or release of
toxic gas.
INJURY TO PERSONNEL :
Hazards of unsafe actions or condition caused by poor housekeeping may result into
minor major physical injury. The splashes of chemicals, release of gases may also
cause injury to personnel working in the nearby.

System Elements or Events
Types of Safety Relevant
that can lead to major Hazards
Accident Components
Accidents
System
Events
Elements
Fire 1. Electrical 1. Damage 1. Use of flameproof
Solvents Short Circuit to Property fittings, frequent
checking of earthing
and wiring etc.
Flammable 2. Lighting 2. Human 2. Regular
Injury Maintenance
Schedule
3. Lighting arrestors
with
proper earthing
Fuel & Lub. 3. Hot Work 4. Work Permit
Oil System
Light Waste 4. Smoking 5. No Smoking area is
defined.
1. Damage 1. Stringent
Explosion
2. 2. Pressure
system on
3. 3. Provision
of
and
4. Hydrant
Fog nozzles,
curtains
5.
1. Unsafe 1. 1. Good
2. Violation 2. Training
Human
2.
Injury
Working of Procedure or 3. Provision of PPEs as
height temporary required.
disablement
3. Control Room
SHE Office phone 5265 / 5246 shall be converted into a Control Room for any
emergency and the Site Main Controller according to situation shall operate from this
place. If situation demands then Occupier / Directors office phone 5800 shall be
converted in to a Control Room.

4. Risk Environmental Impact Assessment
Risk in Atul can broadly be divided in two categories
Risk of leakage – spillage of toxic Chemical
Risk of Fire
Toxic Chemical Risk
PODUCT LOCATION AVERAGE STORAGE

TONS
Ammonia NI FCB Tank form (East) Shed H, 20 (1 Storage tanks)
Near RM stores (West)
Aquious Ammonia Near Pharma Plant (PP) Sulphuric 40 (1 Storage tanks)
Sol. Acid Tank Farm (East) Shed D 400 (1 Storage tanks)
Chlorosulphonic acid (West)
Sulphuric acid 98% Sulphuric Acid Tank Farm (East) 2000 (24 Storage tanks)
Shed A, B, C, H, J, K, N (West)
Pharma Tank Farm (PP)
65% Oleum Sulphuric Acid Tank Farm (East) 110 (8 Storage tanks)
Shed C, H, J, N (West)
25% Oleum Sulphuric Acid Tank Farm (East) 220 (3 Storage tanks)
Shed A, B, C, H, J, K (West)
Sulfur Trioxide Sulphuric Acid Tank Farm (East) 10 (2-Storage tanks)
Phenol 98% PH1, PH II (East) Shed N (West) 170 (7 Storage tanks)

Bisphenol Plant (PP)
Chlorine Caustic soda plant (East) 40 (3 Storage tanks) &
Shed G (West) tonners
Phosgene, Phosgene plant (East), Near 1(2 Storage tanks)
Dimethyl Sulphate Pharma Plant (PP), Shed-N ( Drum
West), Pharma tank farm
(PP)
Fire Risk
PODUCT LOCATION AVERAGE STORAGE

TONS
Benzene Polyester Plant (East) Shed F 30 (5 Storage tanks)
(West)
FCB & Polyester Plant (East) Shed 350 (13 Storage tanks)
Methanol A, N (West) Pharma plant (PP)
Toluene FCB Plant (East) Shed F (West) 50 ( 3 Storage tanks)
pharma & PHIN plant (PP)
Ethanol Polyester Plant (East) Shed B 40 (3 Storage tanks)
(West)

Haxane Epi Pharma & PHIN plant (PP) 75 (4 Storage tanks)
Chlorohydrine Xylene Epoxy tank farm (PP) 7 (2 Storage tanks)
Pharma tank farm (PP) 55 (3 Storage tanks)
50 (3 Storage tanks)
20 (1 Storage tanks)
N.B. : The fire extinguishing facilities are installed and provided as per tariff advisory
committee and people are trained these facilities.
Environment Impact Assessment is given in Annexure 12
5. ORGANISATION FOR TACKLING EMERGENCY :

During normal working hours and except on holidays, the Site Main Controllers,
Incident Controllers, Deputy Incident Controllers, key personnel, essential workers,
Security Officer, Fire officer and Safety Officer are available at factory premises. On
hearing the emergency siren they will start emergency procedure as laid down in the
following part. After normal working hours and on holidays Security Officer, Fire
Officer, Safety Officer, Incident Controllers/Deputy incident Controllers (See
annexure 14,15,33) site main controllers (see Annexure 18) will be called to
attend emergency by shift chemist with the help of Security personnel. Duty schedule
of incident controllers for any day is available at Security office / Control Room.
Organogram for Plant Emergency Response
Site Incident Controller / Shift

In - Charge
Safety Officer Fire & Security

Shift Chemist /
(On Call) Services (On Call)
Engineer
Assembly Point First-aid Medical

In-Charge Centre (On Call)
Duties of persons responsible for combating Emergency
4.1 Site Incident Controller / Shift In-Charge : (See annexure 16 & 33)

1. Raise the emergency alarm, if it is not already sounding.
2. Arrange to secure all ignition sources.
3. Assign specific duties to the staff / workmen n to bring the critical of the
emergency.
4. Assess the severity of the incident and the likely extent of the emergency.
5. Determine actions necessary to overcome the course of the incident and linit
the extent of its effects.
6. Advise plant personnel on how to combat the emergency with due care for
personal safety.
7. Provide guidance to fire fighting personnel on –
• Type of fire extinguishers, and
• Type of personal protective to be used
8. Ask for evacuation of the plant, if necessary.
9. Nominate someone to act as Assembly Point In-Charge and to obtain head
count.
10. Provide information to and seek guidance from the safety Officer and
Departmental Heads on their arrival.
11. Along with Plant In-Charge, Safety Officer and Manufacturing Head decide
whether nearby Plants are likely to be affected and whether on-site
emergency should be declared or not.
Once the emergency is attended to and the incident is under control, arrange to
give all clear siren.
4.2 Safety Officer.
1. On hearing Siren, reach the incident site immediately.

2. Find out about the type emergency, whether it is due to toxic gas leak, fire or
explosion.
3. Provide advice on use of appropriate personal protective equipment by personnel
assigned to tackle the emergency.
4. Check wind direction and inform the nearby Plants.
5. Guide the Security staff for cordoning off affected area, if such isolation is required
. Send persons for medical treatment, if required.
6. Depending on the severity, take joint decision with the Site Indent Controller
whether senior management should be alerted and whether Main Centre Controller
should be called.

4.3 Shift Chemical / Engineer.
1. On hearing siren receiving message on telephone proceed th the incident site

immediately.
2. Assist the Site Incident Controller.
3. Make arrangement to obtain help and resources (men, materials and machinery)
from other Plants, if necessary
4. If plant evacuation is necessary then after shutting sown plant to safe condition,
ask he plant personnel t o proceed to assembly point. Nominate s o m e o n e a s
assembly point In charge to take attendance and receive further instructions.
4.4 Fire & Security Personnel:
1. On hearing siren reach the incident site immediately.

2. Seek information from Shift Chemist / Safety Officer about the nature of the
emergency and precaution to be taken in tacking the emergency.
3. Ensure use of proper personal protective equipment while operating in dangerous
area or zone.
4. Limit use of fire hydrant to permissible areas only.
5. Help to cordon the are of incident and do not allow any unauthorised persons to
go near the affected area.
6. If required carry our search an rescue operation the control of Fire Officer / Shift
Chemist.
4.5 Trained / Experiences worker :
He will start combating emergency and call for help if emergency is in area.
Otherwise he shall give charge of his work to the supervisor and go to the site of
emergency and help in combating emergency. Each plant will nominate at least one
such worker per shift.
4.6 Assembly – point In-charge :
1. As soon as the siren is heard, take charge of the assembly point nearest to the
plant giving due consideration to the wind direction and severity of fumes or fire
in the plant (as seen from outside)
2. Take head count in case shed evacuation is ordered. Record the names and
identity of persons reaching the assembly point.
3. Communicate the data to the Site Incident Controller and Safety Officer
(highlight the names of persons who may be missing).
4. Check and record if any one is injured or affected by chemicals.
5. Send affected persons to the First-aid Centre or Atul Medical Centre, as required.
6. Inform the Medical Centre the name of chemical causing the emergency.

4.7 First-aid Centre :
1. The male nurse provide first-aid treatment to any casualties sent from the plant.
2. The male nurse or Ambulance attendant will liaise with Transport Section for
transporting the victims from the incident site to Atul Medical Centre.
4.8 Atul Medical Centre :
1. On hearing the siren for on-site emergency, the Doctor on duty should come to
the Atul Medical Centre immediately to treatment casualties, if any.
If any required, the Doctor must inform the Civil Hospital, Valsad or other hospital
in Valsad. asking for readiness to handle casualties, giving information on nature of
injuries, chemicals involved and number of affected persons who may be referred.
4.9 Duties & Responsibilities : (Annexure 14 to 18)

The person is assigned with the duties under this plant. Any person failing to perform
his duties shall be properly dealt with.
4.10 Emergency Alarm System

Though out factory area of Atul Limited switches are installed and housed in a small
box with glass cover / push buttons. (See annexure 26.)
In case fire / accident / emergency the glass of housing should be broken with
hammer provided or by passing electric push button switches. The fire siren will be
actuated automatically. There will be audio visual indication of location at
respective fire stations of Atul.

5. Telephone Communication Guide Line
KEY PERSONNEL OF THE ORGANIZATION WHO WILL ASSUME RESPONSIBILITIES IN CASE OF AN EMERGENCY:
INCIDENT CONTROLLERS
Concern divisional GM (Mfg) will act as Incident Controller. He will be responsible for physically tackling the emergency at site. He will judge
the situation and brief SMC (Site Main Controller) to take decision for on-site emergency. Division wise list of Incident Controller and their
alternatives are as under
In absence of incident controller alternative incident controller will take charge of incident controller. In normal case, second incident
controller (Runner) will remain available for helping incident controller to control the emergency.
If both the persons i.e. incident controller and alternative (Deputy) incident controller are not available in campus, they have to ensure that
second incident controller is available in campus / colony area on call, to act as incident controller.
Sr. Incident controller's Runners

No. Name in Designation Division Place of availability Phone No. Name & Place of Phone No.
priority In the Residence In the Residence Designation availability
order factory address factory
1 2 3 4 5 6 7 8 9 10 11
1 Mr. Parag Shah GM-Mfg BI East Site/BI Down 5645 Dr. D. V. Doshi Old Reso 5119
Office Colony Plant Office 233170(P&T)
2 Mr. R. K. Arora GM-Mfg Color West Site Down 4215 234310 Mr. H. S. Maint. Office 4255/6484
Colony Prajapati West Site 233228(P&T)
3 Mr. GM-Mfg PI North Site Wyeth 3446 230194 Dr. H. A. Naik North Site 3502/6212
Ravishankar Colony Admin Bldg 233816(P&T)
Sharma
4 Mr. N. S. Daga GM-Mfg PO North Site O type 3880 7485/2334 Mr. H. R. Patel Office of 3454/6221
colony 48 Epoxy Plant 233087
5 Mr. Sujoy M GM-Mfg CP Production Down 5572/ 7055 Mr. Nilesh Engineering 5283/7425
Office/East Colony 2265 Doshi Office-CP 234267
6 Mr. S. J. G.M. Infra Production Down 5334 7031/ Mr. Dipak C. Power Plant 5317/
Hansoti Office/East Colony 233389 Patel Office – East 230388
P&T

DEPUTY INCIDENT CONTROLLERS
Sr. Division Name & Designation Place of availability Contact No.

No.
1. BI Mr. Ashish Gandhi TE Office 9824106258
2. COLOR Mr. Vrajesh Parikh TE Office 4245/9824136657
3. PI Mr. H R Patel TE Office 4278
9925149538
4. PO Mr. M. R. Simpi TE Office 4471/9723551353
5. CP Mr. Prashant Sonawane TE Office
6. IN Dr. D. V. Doshi TE Office 9924143624

6. Safe shut down procedure : (In Process Plants)
When it becomes necessary to evacuate the plant due to emergency arising out of
fire, explosion or toxic leakage the following procedure should be adopted in normal
cases. The instruction from site main controller / incident shall be final.
i Stop addition / charging of any material to reaction vessel.
ii Start cooling if heating process is going on.
iii Stop stirrer if setting of reaction mass is not likely to jam agitator.
iv Stop all the processes e.g. filtration, centrifuging, drying, grinding, packing etc.
v Services required for scrubbing system should not be stopped.
7. Fire :
a) The person noticing the emergency should the alarm from the nearest fire alarm
switch. He shouts for help calling ‘Fire-Fire’ and workmen working in the affected
area who are trained in fire fighting immediately start combating the fire, with fire
extinguishers.
b) Shift chemist should rush to the site and take charge emergency operation and
should arrange to inform Fire/ Security and he should instruct workmen for shut
down procedure in the nearby area.
c) Other workmen of the section also the persons who are combating emergency by
bringing firef ighting equipment, removing flammable combustible material from
nearby area clearing the passage for firef ighting personnel, under instructions of
shift chemist.
d) Fire / Security Officer & Fireman :
They rush to the emergency with fire tender and help combating fire.
e) One of the Firemen immediately rushes to the fire pump room and starts the fire
pump and wait there for further instruction.
f) Security Officer/main gate Watchman informs Safety Officer Incident Controllers
and site Main Controller according to duty / Schedule given, regarding emergency.
g) The watchman at the main gate shall direct any outs ide person e.g. members of
mutual aid team, representative of govt. From d i s t r i c t a u t h o r i t i e s o r a
press representative, to the SHE office.
7.2 Toxic spill or leakage of Gas / Hazardous material
a) Workmen in the area will take actions for containing and stopping the spill, by
wearing required PPE’s.
b) The shift chemist will rush to the spot taking precautions and arrange for doing
the following as per need:

c) In case of exposure to gas move the victim to fresh air and provide artificial
respiration or in case of burns due to hazardous material give immediate water
shower to affected person and send them for medical treatment ambulance.
Note: In case shift chemist find spill is major (that cannot be managed by the
Department alone) he should sound the fire alarm to seek the help from Fire /
Security and other services as Per procedure No. 8.1
7.3 Injury:
a) Workman at the site help the injured person to go into open area and take him
to the Ambulance Room for first aid, by Ambulance.
b) Male nurse at ambulance room arranges to send the injures person to Atul
Medical centre or company’s Doctor.
c) As advised by doctor, the injured person is taken to Valsad or Pardi Hospital.
d) Responsible man is deputed by Plant Manager or Factory Manager to accompany
the injured person along with company’s Medical Officer’s report when sending to
Valsad or Pardi Hospital.
8. Declaration of Major Emergency (see Annexure 29)
The persons on emergency duty along with concerned G. M. Mfg. / Plant Incharge in
consultation with Safety Manager decide about the gravity of the situation and inform
the
control room to declare on site emergency. In this case continuous is sounded for 4
minutes.
8.1 Declaration of off site Emergency:

If nearby colonies / villages required then off site emergency is declared by sounding
10 minutes continuous siren of all 3 companies. In case of off site emergency
separate procedure ACDCP (Atul Complex Disaster Control Plan) is when and that
document must be used.
8.2 Giving all clear signal :

After the Emergency is brought under control G.M. MFG. / Occupier / Factory
Manager will decided and give instructions for all clear siren (i.e. One minute
continuous siren0

9. Communication in case of major Emergency
On declaration of major emergency, the Atul complex Disaster Control Plant becomes
operative. The GM Corporate-SHE/Factory Manager who are members of the Main
Control sub Committee of ACDCP will inform the following persons about the disaster
and ask for help to combat the situation. They remain in touch with Director /
Occupier for guidance if needed.
Name Designation Telephone No. Represent

District Collector, Valsad Chairman D.C.C. of O-0263-253613, Government
ACDCP
Occupier / Director, Atul Vice Chairman DCC of O-233261,R- Atul Ltd.
Ltd. ACDCP 233241
Dy. Director ISH Valsad Secretary DCC of O-253612, Government
ACDCP, Valsad
District Supdt. of Police, Chairman P&G Sub O-254222, Government
Valsad Committee of ACDCP
Atul Police Station, Atul 233515 Government
Atul Gram Panchayat, Atul O-234562 Government
G.P.C.B. Vapi Regional Office O-0260-2432089 Government
D.C.C. = Disaster Control Committee, P & G :

The District Collector Valsad shall arrange help from Valsad Municipality, Zilla
Panchayat, and other Government and non-Government Organizations. The District
authorities shall inform nearby villages for evacuation and / or other measures in case
of emergency arose.
10. Mutual Aid
We have arrangements with the neighboring sites situated in the campus namely Atul
– (East, PP Site & West Site), to help each other in case of any emergency. The
transport facilities, fire fighting facilities/ equipment, personal protective equipment
and other emergency equipment is available for mutual aid. (See annexure 21, 23 &
25)
11. General
11.1 Shift Chemist Control the people of their section ensure that people who are trained
in the fire fighting and first aid are relieved to go to the spot of emergency.
11.2 Incident controller, safety Officer and Fire / Security Officer shall check the spot
after fire is extinguished (or emergency is over) and declare the area safe for

cleaning or putting back to operation and blow siren for all clear. This all clear
SIGNAL is continuous siren for 1 minute.
12. Accident investigation and Reporting*

Every accident that has resulted in personal injury, likely danger to human life or
property damage shall b investigated thoroughly departmentally.
Departmental head may take help of safety Department and / or other experts from
outside for the investigation. A report shall be mode indicating the root cause of the
incident and proposed remedial measures.
12.1Preliminary written report from Department Manager is sent to safety, Health and
Environment Department, Director, Vice President and GM mfg. within 24 hours (even
if oral information is given) after the incident. This is being discussed in safety
committee meeting.
12.2 Factory manger will inform the Factory inspector and / or other Government
authorities as required.
13. Public Relation

The occurrence of a serious disaster in only factory would be a matter of public
interest. Misunderstanding of Reporters has some times led to distorted and
exaggerated stories, which reflect unfavorably upon the company. Speed and
frankness in supplying accurate of the company.
factory Manager or in his absence person appointed by Director will provide the facts
and accurate picture of the situation to the following :
He will inform :
1. Personnel Managers Factory Mangers of teh neighboring compines.
2. Sarpanches of villages likely to be affected by the emergency.
3. Dy. Director ISH
4. Collector at Valsad
5. M.L.A’s at Valsad and Pardi and M.P. Valsad only if the accident leads to off site
emergency
6. News correspondents at Valsad
Person responsible for giving Information ensure the following:

1. Do not try to hide the facts. They will come out later any way.
2. Do not release estimates of damage without consulting occupier.
3. Do not speculate, stick to the facts.
4. Do not attempt to blame anybody.

14. Plant Evacuation Procedure :
It may be necessary to evacuate the building and / or surrounding buildings where
emergency has occurred. The evacuation instructions are given by Site Main
Controller after assessing the situation in emergency. (See annexure 19)
15 Personal Protective / Emergency Equipments

(See annexure 21 column No. 13,22 & 24)
Personal protective equipments / Emergency equipments are to be used according to
the nature of emergency such as fire, toxic spill gas leakage etc. List of personal
protective equipment / Emergency equipment with its location is circulated
separately to all departments. (See annexure 20). The responsibility for maintenance
of such equipment is as under :
1. Fire Fighting Equipment : Security & Fire Department

2. Personal protective equipments. : Plant Incharge / concerned department
3. Communication & Other instrumental : Electrical & Instruments Dept.
equipment
16. Safety Devices *(See annexure 4 column No.8)

The safety devices provided to safe guard against hazard are maintained in upto date
working condition and tested for their performance from time as per the preventive
maintenance schedule prepared i advance.
17. Revision & Updating :
The plan is subject to revision due to the following reasons.
1. To fulfill new statutory requirements if any.
2. To incorporate additional Hazards and risk identified on the basis of risk analysis.
3. Organizational changes, in the company if any.
4. Introduction of new / additional facilities in the form of equipment, mutual aid etc
to combat emergencies of fire, toxic release / spill or physical injury.
18. Mock Drills & Training.

The success of this plan will depend upon th education of all concerned and practice
of the same at regular intervals. The periodic drill is carried out to check performance
of the men and equipments. regular training Programs or fire fighting, use of gas
masks and first aid are conducted. This training also include tabletop and functional
drill of the plan. The full-scale drill is carried out in presence of statutory authorities,
press, and police for handling situation effectively.

ENCLOSURE – 1
A FORM TO RECORD EMERGENCY INFORMATION
Details of call as reported :
Caller’s Name & designation Date Time
Phone No.
Purpose of Call as reported:
Is any particular advice required immediately?
Name of Chemicals, To be spelt out clearly :
Brief description of incident
Fire / Explosion / Liquid Spill / Gas release
Quantity involved
Packaging / storing / handling / using details
Location of incident
Cause, if know, in brief
Has anyone been injured Yes/No if Yes, how many?
Affected by chemicals Yes/No if Yes, how many?
What first aid has been given? Yes/No
Has any one been taken to Yes/No
dispensary / hospital?
If Yes address of the hospital
If caused by vehicle,
Who owns the chemicals?
Vehicle Number and Name & Address of the owner
To whom was the load consigned?

ENCLOSURE – 2
ACTION PLAN IN THE EVENT OF MAJOR CHLOROSULPHONIC ACID LEAKAGE
1. Evacuate and cordon off the area.

2. Approach the area of leakage from windward side.
3. Stop leak if, possible.
Only trained persons equipped with personal protective clothing and suitable
respiratory protection from amongst the following should attempt to stop the
leak.
1. Positive pressure fresh air mask (Randle mask)
2. Self contained breathing apparatus.
4. If the leakage is observed from the storage tank body start transferring of
material in the spare tank immediately.
5. Do not allow acid to go in the drain. Plug the drain line.

6. Arrange for during sand over the spilled acid.
7. Keep organic material out of contact with acid spill.
8. If possible, arrange a vigorous spray of water from the actual are of spill (on
windward side) provided the spill is minor i.e. 50-100 litters.
9. To minimize the effect of Hydrochloric acid fumes coming from chlorosulphonic

acid to the following
a) Hold a wet cloth or handkerchief over the mouth and nose
b) Breathe as little as possible
c) Try to be at as high level as possible. Hydrochloric acid is heavier than air
and settles down.
d) Escape away from the site of accident in direction perpendicular to the wind.

ENCLOSURE – 3
ACTIONPLAN IN THE EVENT OF MAJOR CHLORINE GAS LEAKAGE
1. Evacuate and cordon off the affected area.
2. Approach the area of leakage from windward side.
3. Stop the leak if, possible. Only trained persons equipped with personal protective
clothing and suitable respiratory protection from amongst the following should
attempt to stop the leak.
1) Positive fresh air mask (Randle mask)
2) Self contained breathing apparatus.
4. If tonner / cylinder is found to be leaking even after closing the valve, remove it if
possible to an isolated open place and roll to such a position that the leaking
point is an top.
5. Spillage should be contained for neutralization with lime / caustic.
6. In case of fire, water however be used on other tonners / cylinders lying in the
vicinity.
7. Operate Portable hood system for absorption of leaking chlorine.
8. To minimize the effect of chlorine, do the following.

a) Hold a wet cloth or handkerchief over the mouth or nose.
c) Remain at as high level as possible because chlorine is heavier than air settles
down.
d) Escape away from the site of accident in a direction perpendicular to the wind.

Sheet No. 1
1. Instantaneous release of 900 kgs. Chlorine
C = Concentration
Concentration (C) at any x for a given wind speed will be function of Time. The
values below refer to maximum concentration.
C Max mg/ PPM
m3
100 M 102047 15142
200 M 15065 5188
300 M 4920 1694
400 M 2224 766
500 M 1201 414
600 M 726 250
800 M 328 113
900 M 237 82
1000 M 177 61
1250 M 96 33
1500 M 58 20
1750 M 38 13
2000 M 26 9
2500 M 14 5
3000 M 8.5 3
IDLH for Chlorine = 75 mg/m3 = 26 PPM Immediate Danger to life & health
STEL for Chlorine = 9 mg/m3 = 3 PPM Short Term Exposure Limit.
TLV for Chlorine = 3 mg/ m3 = 1 PPM Threshold Limit Valve.

ENCLOSURE – 4
ACTION PLAN IN THE EVENT OF MAJOR AMMONIA GAS LEAKAGE
1. Evacuation and cordon off the area.

2. Approach the area of a leakage from windward side.
leak.
a. Positive fresh air mask (Randle mask)
b. Self contained breathing apparatus
4. In confined area spray, plenty of cold water reduces concentration of ammonia in air.
5. In open area see wind direction and create a water fog (using fog nozzles) downward
from a convenient distance so that the released ammonia vapours can be effectively
absorbed.
6. Flush away spillage preferably by water
7. To minimize that effect of ammonia, do the following.
a) Keep that effect closed and open them only for a brief period as required.
b) Hold a wet cloth or handkerchief over the nose and mouth
c) Breathe as little as possible

Sheet No. 2
2. Instantaneous release of 15 ton Ammonia
Concentration (C) at any x for a given wind speed will be function of Time. The
values below refer to maximum concentration.
C Max mg/ PPM
m3
100 M 1700781 2446123
500 M 20021 28795
1000 M 2956 4251
1500 M 965 1388
2000 M 436 627
2500 M 236 339
3000 M 143 206
3500 M 93 134
4000 M 64 92
4500 M 47 68
5000 M 35 50
IDLH for Ammonia = 500 ppm

STEL for Ammonia = 27 mg/m3 = 35
TLV for Ammonia = 18 mg/ m3 = 25 PPM

ENCLOSURE – 5
ACTION PLAN IN THE EVENT OF MAJOR OLEUM LEAKAGE
1. Evacuation and cordon off the area.

2. Approach the area of a leakage from windward side.
leak.
a. Positive fresh air mask (Randle mask)
b. Self contained breathing apparatus
4. Do not allow Chemical to go in the drain. Plug the drain line.
5. Arrange for dumping sand / lime over the spilled Chemical, wearing full PPE.
6. To minimize that effect of Oleum, do the following.
a) Hold a wet cloth or handkerchief over the mouth and nose
c) Try to be at as high level as possible, Oleum is heavier than air and settles
down.

ATUL LIMITED
DMP for Hydrogen
 On -line monitoring of Hydrogen in Chlorine
 Flame arrester on Hydrogen gas line
 In Hydrogen compressors area all electrical appliances should be flameproof. Electrical motor
should be with Earthing at both side.
 Hydrogen gas detectors should be installed at Hydrogen compressor and activates alarm in case
of Hydrogen leakage
 TAC approved Fire hydrant system throughout the plant.
 Water Sprinkler should be provided around transformers
 Round the clock availability of full size own Fire Tender
 Mutual aid schemes with the adjoining industries
 Product storage tanks should be provided with dyke wall
 Four levels of communication (Telephone, P A system, Walkie talkie, Siren system)
 Incident investigation and corrective system including near-miss cases
Handling and Storage of Hydrogen
 Use adequate ventilation.
 Separate Hydrogen cylinders from oxygen, chlorine, and other oxidizers by at least 20 feet (6.1
meters) or use an approved gas cabinet.
 Store only where temperatures will not exceed 125° F (52° C).
 The must be no sources of ignition in areas where Hydrogen is being stored
 Segregate empty cylinders from full cylinders.
 When a cylinder is not in use, screw the valve protection cap firmly in place.
 Secure cylinders upright at the top and bottom. Adjust the cylinder racks so that cylinders are
tightly secured.
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Safe handling of hydrogen cylinders
The following should also be noted when handling hydrogen cylinders and bundles:
 Cylinder and bundle valves are only to be opened when the pressure reducer with undamaged
sealings has been carefully connected. The points of connection should be checked to ensure
they don„t leak.
 Cylinder and bundle valves are to be closed when not in use in order to prevent gas leakage from
leaking connections.
 If a cylinder or bundle valve is leaking or when hydrogen escape cannot be stopped by closing
the valve, the hydrogen container has to be transported outside where it is to be emptied. Repairs
on hydrogen cylinders or bundles, including the valves, are only to be carried through by the gas
supplier.
6.12 OFF SITE EMERGENCY
6.12.1 Communication in case of Major Emergency
On declaration of major emergency, the Atul complex Disaster Control Plan becomes operative.
The GM Corporate-SHE/Factory Manager who are members of the Main Control sub Committee
of Atul Complex Disaster Control plan (ACDCP) will inform the following persons about the
disaster and ask for help to combat the situation. They will remain in touch with Director
/Occupier for guidance if needed.
Name Designation Telephone No. Represent

Chairman D.C.C. of
District Collector,Valsad O-0262-253613, Government
ACDCP
Occupier / Director, Atul, Vice Chairman DCC of O-233261
Atul Ltd.
Ltd. ACDCP 233241
Secretary DCC of
Dy. DISH Valsad O-253612, Government
ACDCP,Valsad
District Supdt. of Police, Chairman P&G Sub O-254222, Government
Valsad Committee of ACDCP
Atul Police Station, Atul 233515 Government
Atul Gram Panchayat, Atul O-234562 Government
GPCB Vapi Regional Office O-0260-2432089 Government
D.C.C. = Disaster Control Committee, P & G:
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ATUL LIMITED
The District Collector Valsad shall arrange help from Valsad Municipality, Zilla Panchayat,
and other Government/Non-Government Organizations. The District authorities shall inform nearby
villages for evacuation and / or other measures in case of emergency arose.
6.12.2 Mutual Aid
We have arrangements with the neighboring sites situated in the campus namely Atul – (East, PP
Site & West Site), to help each other in case of any emergency. The transport facilities, firefighting
facilities/ equipment, personal protective equipment and other emergency equipment shall be
available for mutual aid.
6.12.3 Mock Drills & Training
The success of this plan will depend upon the education of all concerned and practice of the same at
regular intervals. Periodic drill is carried out to check performance of the manpower and equipments.
Regular training programs on firefighting, Use of gas masks and first aid are conducted. This training
also include tabletop and functional drill of the plan. The full-scale drill is carried out in presence of
statutory authorities, press, and police for handling situation effectively.
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ATUL LIMITED
PART 03 – OCCUPATIONAL HEALTH AND SAFETY
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ATUL LIMITED
6.13 GENERAL
For large industries, where various activities are involved during construction, erection, testing,
commissioning, operation and maintenance; the men, materials and machines are the basic inputs.
Industrialization generally brings problems of occupational health and safety.
The proponent therefore has properly planned and taken steps to minimize the impacts of
industrialization and to ensure appropriate occupational health and safety including fire plans.
The key safety measures mentioned under shall be a part of proposed expansion project.
6.14 OCCUPATIONAL HEALTH
Occupational health needs attention both during construction/erection and operation/maintenance

phases. However, the problem varies both in magnitude and variety in the above phases.
6.14.1 Construction and Erection
The occupational health problems envisaged at this stage can mainly be due to constructional accidents
and noise generation. To overcome these hazards, in addition to arrangements to reduce it within the
Threshold Limit Values (TLVs), necessary protective equipment shall be supplied to the workers.
6.14.2 Operation and Maintenance
The problem of occupational health in the operation and maintenance phase is primarily due to noise
which could affect consultation. The necessary personal protective equipment shall be given to all the
workers exposed to high noise. The working personnel shall be given the following appropriate
personnel protective equipment.
 Industrial Safety Helmet;
 Welders equipment for eye and face protection;
 Cylindrical type earplug;
 Ear muffs;
 Safety belt/line man's safety belt;
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 Leather hand gloves;
 Asbestos hand gloves;
 Electrically tested electrical resistance hand gloves; and
 Industrial safety shoes with steel toe.
Atul also has a Department of Health (DoH) for regularly checking health of the employeesand
providing medical aid in case of injury to the personnel. The DoH is responsible for taking care of the
Occupational Health & Safety of the employees at Atul Ltd.
A) DEPARTMENT OF HEALTH (DOH) at ATUL LTD
1. Medical Centres
 DoH Main (Department of Health) within Atul complex
 OHC (Occupational Health Centre, 24x7) within Factory premises.
2. Scope of Services
 Primary healthcare for employees & family
 Occupational healthcare
 Health monitoring
 Employee health check-ups
 EMS (Emergency) 24x7
 AOD (Accident on duty) management 24x7
 OHC services 24x7
 Medical Laboratory
 Referrals
3. Systems & facilities available
 HMIS (Hospital management & information systems)
 Office automation
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ATUL LIMITED
 ECG machine (two)
 Multipara Monitor with O2 Saturation (one)
 Finger pulse oximeter (one)
 Glucometer (two)
 Otoscope cum Ophthalmoscope (one)
 AED (automated external defibrillator) (one)
 Suction machine (two)
 Fully automated biochemistry analyzer (one)
 Fully automated hematology analyzer (5-part) (one)
 Automated Centrifuge (two)
 Microscopes (two)
 Blood Roller Mixers (two), Pipettes & Other Lab accessories
 Needle cutters (three)
 Oxygen cylinders (ten)
 Ambulance van with stretcher (two)
 Emergency observation beds (five)
 Medical assistance/aid visit bag (two)
 Dr Consultation equipment
 Antidotes as applicable
 First aid boxes as required
4. Manpower
 Full-time Doctors – Three (residing in campus)
 Contract Doctor – One (Medical Advisor) (residing at Valsad)
 Lab Technician – One
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ATUL LIMITED
 Nurse – One (Male)
 Medical Assistants – Five (Male)
5. Software Use
 Online software for health monitoring and medical history for all employees
EMP for the Occupational Safety & Health hazards so that such exposure can be kept within
Permissible Exposure Level (PEL)/Threshold Level Value (TLV) so as to protect health of
workers.
1. An EMP for Occupational Safety and Health shall be proposed to implement with the following
objectives:
 To keep air-borne concentration of toxic and hazardous chemicals below PEL and TLV
 Protect general health of the workers likely to be exposed to such chemicals.
 Providing training, guidelines, resources and facilities to the concerned department for
occupational health hazards
 Permanent changes to workplace procedures or work location to be done, if it is found necessary

on the basis of findings from the Workplace Monitoring Plan.
 It is proposed that this EMP be formulated on the guidelines issued by the Bureau of Indian
Standards on OH&S Management Systems: IS 18001:2000 Occupational Health and Safety
Management Systems
 Proposed EMP shall be incorporated in Standard Operating Procedure also.
 The proposed EMP shall also include measures to keep air-borne concentration of toxic and
hazardous chemicals below its PEL and TLV, like…
o Leak Surveys
o Separate storage for toxic chemicals
o Exhaust Ventilation
o Proper illumination
o Close processes to avoid spills and exposures
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o Atomization of process operations to hazards of manual handling of chemicals
o Supply of proper PPEs like Air mask, Berating canisters, SCBA sets, On-line breathing apparatus
at the places where there is possibility of presence of toxic chemicals
o Regular maintenance program for pumps, equipment, instruments handling toxic and corrosive
chemicals
o Display of warning boards
o Training to persons handling toxic and combustible materials/chemicals.
Workplace Monitoring Plan
 It is proposed that a Workplace Monitoring Plan shall be prepared & implemented in consultation
with FMO.
 Each workplace must be evaluated to identify potential hazards from toxic substances or harmful
physical agents. Air-borne concentration of combustible material shall be measured and records
shall be maintained.
Health Evaluation of Workers
 It is proposed that management shall device a plan to check and evaluate the exposure specific
health status evaluation of the workers.
 Workers shall be checked for physical fitness with special reference to the possible health hazards
likely to be present where he/she is being expected to work before being employed for that
purpose. Basic examinations/tests like Liver Function tests, chest x ray, Audiometry, Spirometry,
Vision testing (Far & Near vision, color vision and any other ocular defects) ECG, etc. shall be
carried out. However, the parameters and frequency of such examination shall be decided in
consultation with Factory Medical Officer.
 While in work, all the workers shall be periodically examined for the health with specific reference
to the hazards which they are likely to be exposed to during work. Health evaluation shall be
carried out considering the bodily functions likely to be affected during work. The parameters and
frequency of such examination shall be decided in consultation with Factory Medical Officer and
Industrial Hygienists. Plan of monthly and yearly report of the health status of workers with
special reference to Occupational Health and Safety shall be prepared.
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ATUL LIMITED
6.15 SAFETY PLAN DURING PROJECT EXECUTION STAGE (CONSTRUCTION &

COMMISSIONING)
Safety of both men and materials during construction and operation phases is of concern. Safety plan
shall be prepared and implemented in the proposed project activity. The preparedness of an industry for
the occurrence of possible disasters is known as emergency plan. The disaster in the plant is possible due
to collapse of structures and fire/explosion etc. The proposed project would formulate safety policy
keeping in view the safety requirement during the construction, operation and maintenance phases, with
the following regulations:
 To allocate sufficient resources to maintain safe and healthy conditions of work;
 To take steps to ensure that all known safety factors are taken into account in the design,
construction, operation and maintenance of plants, machinery and equipment;
 To ensure that adequate safety instructions are given to all employees;
 To provide wherever necessary protective equipment, safety appliances and clothing as well as to
ensure their proper use;
 To inform employees about materials, equipment or processes used in their work which are known
to be potentially hazardous to health or safety;
 To keep all operations and methods of work under regular review for making necessary changes
from the point of view of safety in the light of experience and up to date knowledge;
 To provide appropriate facilities for first aid and prompt treatment of injuries and illness at work;
 To provide appropriate instruction, training, retraining and supervision to employees in health and
safety, first aid and to ensure that adequate publicity is given to these matters;
 To ensure proper implementation of fire prevention methods and an appropriate fire-fighting

service together with training facilities for personnel involved in this service;
 To organize collection, analysis and presentation of data on accident, sickness and incident
involving people injury or injury to health with a view to take corrective, remedial and preventive
action;
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ATUL LIMITED
 To promote through the established machinery, joint consultation in health and safety matters to
ensure effective participation by all employees;
 To publish/notify regulations, instructions and notices in the common language of employees;
 To prepare separate safety rules for each type of occupation/processes involved in a plant; and
 To ensure regular safety inspection by a competent person at suitable intervals of all buildings,
equipment, work places and operations.
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PART 04 – PUBLIC HEARING
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6.16 PUBLIC HEARING
The Public Hearing (PH) for proposed project was conducted on 21/06/2016 at 11:00 am at Atul Gram
Panchayat Hall, Vill: Atul, Tal & Dist: Valsad, Gujarat.
Mr. A. G. Patel, Member Secretary of PH and Regional Officer (RO), Gujarat Pollution Control Board
(GPCB), Vapi welcomed the Chairman of PH and Collector & District Magistrate, Valsad District,
officers, elected representatives & public participated in the PH.
Mr. A. G. Patel gave brief about the EIA notification and PH procedure, which was followed by the
presentation for the proposed expansion project by the proponent. The public gathered in the PH have
welcomed the said project and expressed good opinion about the said project.
The summary of query raised/clarification and points discussed during PH is mentioned as under:
Sr.
Suggestion by Suggestion Reply by Project Proponent
No.
Mr. Ashwin Patel  He told that ground water  Company representative informed that
Ex. Sarpanch, level has been decreased due company does not use bore well water.
Dived Village, to around 200-250 bore wells Par River is the source of water for
Valsad District. operated in Atul. existing as well as proposed expansion
 He also appreciates the project. Bore wells are only for checking
projects undertaken by Atul and testing of ground water.
Ltd.
 He asked about situation in  Company representative replied that
case of Phosgene leakage. Phosgene plant is running since 1970,
there is not a single accident of exposure,
and we ensure that there will not be
abnormal incident in future also. We are
1. going to install a state of the art new
Phosgene plant of 5000 TPA capacity
supplied by Chemical Design
Incorporation (CDI), USA with latest
technology and zero storage which will
be safer than the existing plant. There
will be foolproof interlock system
provided for the safety. Apart from this,
Phosgene plant will be kept in complete
enclosure which will be connected to
three stage scrubbing system. Also,
existing plant will be dismantled after
commissioning of new plant.
 He asked that industry will  Company representative informed that
PAGE 352
ATUL LIMITED
Sr.
No.
provide drinking water in case they are already providing drinking
of non-availability of ground water to nearby villages and it will be
water in our village continue in future also.
Mr. Ramesh  He told that due to make of  Company representative informed that
Chandra Vasanaji power plant chimney for noise from steam blow down is normal
Patel control of pollution, noise during commissioning of any boiler but
2. Dived Village, pollution is increasing. the same will be stopped completely
Pardi Group after commissioning is completed.
Gram Panchayat,
Dist: Valsad
Mr. Nanubhai  He told that reddish water  Mr. A. G. Patel, RO, GPCB told that till
Ahir having foul smell found in date we have not received any compliant.
3. Vill: Dungarwadi, nala. Farmers are suffering. We will definitely take appropriate
Tal & Dist: Coconuts and mango‟s size actions on receiving any such complain.
Valsad are reducing.
Mr. Hiren Patel  He told that mango crop is  Company representative informed that
Near Cynamid affected and greenbelt is the award received by the Magod farmer
Bus Stop, At: reduced in nearby villages for producing highest mango production
Atul, Valsad because of company‟s from the Government of Gujarat last
4. pollution. month in Krishi Mahotsav. The Gujarat
Government bestowed the same. It
reveals the truth and correct information.
As per the Government records, crops
are increasing.
Mr. Ashokbhai  He stated that company got  Company representative informed that
Dived Village, closer notice for discharging Atul Company was running its ETP
Valsad untreated effluent. Still they since when there is no such concept in
are not providing treatment the industries. The same was being
and hence fishes are dying. upgraded time to time. Company got
closure notice three years back due to
leakage in old effluent line. Company
had taken adequate actions for the same
and also made operational two more
5. ETPs.
 Company representative informed about
the increase in fish production and
shown Government records for the same.
 He told that Magod village‟s  Company representative informed that
farmers have filed case CPCB team has conducted
against the company for comprehensive 48 hr continuous
damaging environment in monitoring and taken water, air and soil
high court. samples with respect to complaint in
PAGE 353
ATUL LIMITED
Sr.
No.
which no abnormalities was observed.
This report is available on CPCB website
and company is also ready to share the
same.
 Honorable high court had already
disposed off the matter.
 He asked about how many  Total 958 permanent employees are
permanent workers are working in company and out of this, 546
working in company? How villagers of nearby 14 villages and 405
many of them are skilled? of Valsad district. Recent recruitment
How many contract labours was also from the nearby villages. Total
are working in company? 4000 people are working in the
company. Out of which 1000 employee
are in management category and 2000
are contract labours. 99% of local people
had been given employment.
Mr. Hemang  He asked about online  Company representative informed that
Tandel monitoring system and said each stack and treated effluent are online
Valsad that, GPCB & CPCB are the monitored by GPCB and CPCB
only authorities to view the continuously as per Government rules.
data? Can we access the GPCB and/or CPCB are serving notice
same? in case of non-abnormality observed
during online monitoring.
 He asked that up to what  Company representative informed that
time/period data is stored. we are keeping one-year data records
6. and taking back-up every week.
 He asked about facilities  Company representative informed that
available in the company in total 3 fire tenders are available in the
case of fire and details of company. Fire Extinguishers, fire
firefighting system. hydrant and smoke detector sensors are
also provided at prominent locations.
 He asked that what actions  Company representative informed that
company will take in case of we are providing help of fire tender to
fire at Parnera Hill. the nearby community in case of such
incidents.
Mr. Vijay Patel  He told that chemical smell is  Company representative informed that
Chanvai Village, being observed from the there is no such problem and our
7.
Valsad Kalyani school children‟s employee children‟s are also studying in
uniform. this school.
Mr. Harshad  He asked that how much solid  Company representative informed that
8.
Desai waste will be generated after company is having incinerator as per the
PAGE 354
ATUL LIMITED
Sr.
No.
Valsad proposed expansion? How it CPCB guideline for incinerable waste
will be handled? and secured landfill site for inorganic
waste disposal. Company is disposing
waste as per the GPCB/CPCB
guidelines.
 He asked for huge rise in  Company representative informed that as
brine purification sludge per new government rules Brine sludge
quantity. is not a toxic waste. Earlier there was
mercury plant which is already been
stopped and new cleaner membrane cell
technology has to be installed. In the
new membrane technology, brine
standards are very stringent and hence its
purification process will generate more
sludge than the old mercury cell.
Ms. Purvi Rathod  She told that we are receiving
Sarpanch, Hariya potable water two times, two
Village, Valsad hours daily in our village.
 She told that we have formed
a committee and discussing
with company for the
problems. Because of this,
9.
even poorest people have
been benefited with toilet
facilities.
 She told that company has
provided employment to our
villagers and hope that will
continue in future as well.
Mr. Hiteshbhai  He asked that company will  Company representative informed that if
Valsad ready to give compensation crops will be damaged due to company‟s
10.
for the crop damage by them. pollution than company will do the
necessary for the same.
Mr. Nareshbhai  He told that Atul has done
Desai much social work and
Haria Village, constructed Aanganwadi &
11. Valsad building for gram panchayat.
We are getting water every
day. Company has built eighty
toilets in our village.
Mr. Nanubhai  He told that pollution level
12.
Tandel has decreased a lot in recent
PAGE 355
ATUL LIMITED
Sr.
No.
Deputy Sarpanch years. Fisherman are getting
Umarsadi village, more earning by fishing now a
Valsad days. Conditions are better
than previous years.
 He told that company is
providing help since many
years. Computers and sewing
machines are provided in
primary school.
Finally, Chairman informed that we have taken notes of all the oral presentations. We have also taken
notes of all the oral and written reply given by the company. Since there is no further question from
anybody, today‟s proceeding of PH is declared as closed with the permission of chairman of
Environment PH.
6.16.1 Public Hearing Proceedings
PAGE 356

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ATUL LIMITED

EXPANSION IN EXISTING PRODUCTION CAPACITY AND

CHAPTER – 6 ADDITIONAL STUDIES

 Risk assessment (Part - 01)

6.2 SCOPE OF THIS STUDY

 TOR No. 42: Details of occupational health programme.

Additional TOR for Synthetic Organic Chemical Industry

 TOR No. 10: Details of occupational health programme.

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

PART 01 – RISK ASSESSMENT

6.4 OBJECTIVES OF RISK ASSESSMENT

Objectives of risk assessment are:

 To identify hazard and risks resulting from the hazards

 To find out necessary control measures to prevent or minimize risk

 To get the necessary information for Emergency planning and evacuation

6.5 SCOPE OF THE STUDY

 TOR No. 42: Details of occupational health programme.

Additional TOR for Synthetic Organic Chemical Industry

 TOR No. 10: Details of occupational health programme.

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

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

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

6.6 METHODOLOGY ADOPTED

 Intrinsic properties; flammability, instability and toxicity.

 Dispersive energy; pressure, temperature and state of matter.

 Environmental factors; topography and weather.

- Run discharge calculations based on physical conditions and leak size

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

- Dispersion modeling taking into account weather conditions

6.7 CONSEQUENCE ASSESSMENT

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

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

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

6.7.1 Jet Fire

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

6.7.2 Flash Fire

6.7.3 Vapor Cloud Explosion (VCE)

6.7.4 Toxic Consequences

Table No. 6.1 – Consequence Results at Atul

Release Consequence Distance(m)

Release Consequence Distance(m)

Release Consequence Distance(m)

Phosgene 3.526 kg/s

Release Consequence Distance(m)

Release Consequence Distance(m)

MDC Chilling Flash Fire 159000 ppm 2.35 2.00 2.44

Release Consequence Distance(m)

Release Consequence Distance(m)

Release Consequence Distance(m)

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

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

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

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

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

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

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

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