Trans Indian Inst Met
https://doi.org/10.1007/s12666-020-02158-6
REVIEW
Plant Layout Development for Integrated Steel Plant for Capacity
Expansion: Design Approach
Manik Kumar Ghosh1
Received: 17 November 2020 / Accepted: 11 December 2020
 The Indian Institute of Metals - IIM 2021
Abstract After finalization of process flow for the capacity
expansion of an Integrated Steel Plant, considering the
overall design requirements and inter-relationship amongst
new and existing facilities, overall layout is developed on
available space. Optimization of layout is proposed con-
sidering sizes, locational relationship of new units with
existing operating units, required limiting conditions,
transportation logistics and other auxiliary facilities. Prime
objective of layout optimization should be proper utiliza-
tion of available space which has been identified for
expansion. Optimized layout can be developed through 3D
integrated approach, which considers a common digital
model of the entire plant. It can be achieved by merging the
engineering output from various vendors, merging the
model of existing plants obtained from works, surveys, and
vendors so as to create a seamless layout. The final layout
shall be best possible and can be executed in time bound
manner.
Keywords ISP
Capacity expansion
Brown field

Design approach
1 Introduction
Presently, steel industries are facing growing challenges
due to immense competition, volatile markets and growing
environmental concerns. Optimization of plant layout and
logistics are among the few key factors for the successful
& Manik Kumar Ghosh
manikg@tce.co.in
1
Tata Consulting Engineers Limited, JC 30/A Sector – III,
Saltlake, Kolkata, West Bengal 700106, India
business. Also, layout is important with respect to opera-
tional ease which may otherwise have an impact on cost
and quality. To sustain in this very competitive market,
steel company must increase the efficiency in all existing
production units as well as due care to be taken while
finalizing the proposed expansion scheme by adopting best
available technologies (BAT) with optimum land utiliza-
tion. Due to reduction in product life cycles and fast change
of global steel demands, production and plant planning
cycles have become shorter straining the CAPEX. Engi-
neering considerations for plant layout, in general, at dif-
ferent stages of implementation of a project are shown in
Table 1.
The concept of layout to be adopted would be largely
governed by the technological processes selected for the
expansion. It also depends on the future potential capacity
visualized/based on market study for the steel plants. This
in turn depends on the economic growth that is planned for
the country itself and exposure/desire to expand in inter-
national market, and the significance the planners attach to
the role of steel for accelerating growth in economy. Pre-
sently due to surge in steel demand, developing countries
are installing new steel capacity as well expanding its
existing plant capacity. Development of layout for an
expansion project needs a systematic engineering approach
to effectively utilize land, infrastructure, utilities and mis-
cellaneous existing facilities without interrupting the
existing plant operation and maintenance services to the
best extent possible. The major advantages and challenges
for capacity expansion of existing Integrated Steel Plant
(ISP) are depicted as below:
Advantages
• Minimum procurement of land
• Availability of rail and road connectivity
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Table 1 Engineering considerations for plant layout

Engineering considerations for plant layout
Conceptual stage Engineering stage Implementation stage
Checking System design, plant sizing and layout development Plant sizing and layout finalization

Project location and ecological sensitivity Rail, Road, Power and Water corridor finalization Individual plant general arrangement
of the area finalization based on selected
vendors’ inputs
Land, Water, Power, Transport Individual plant, in-plant water reservoir and waste disposal Finalize plant locations to ensure high
Infrastructure availability pond sizing constructability and ease of O&M
Feasibility of the project covering source, Existing in-plant water reservoir and waste disposal pond Construction road/drain planning
reliability and cost of raw materials adequacy review considering expansion considering construction process
and crane operation
Pre-project activities Plant material handling-storage and unloading rail yard Finalizing pipe/cable/utility routes
layout preparation and provisions for interconnection
in future
Plant layout development with rail [1]–road Interact with TPs and OEMs, review process plant general Construction labour colony location
[2] connectivity arrangement to ensure convenient loading/unloading of finalization
equipment and O&M
Land requirement estimation and initiating Finalize sizes and locations of ancillary and auxiliary Optimum inter-plant material
the process of acquisition facilities including EV Charging, Smart Gate etc. movement
Water drawl permission, environmental [3] Finalize hot metal track layout for ultimate plant capacity Future plant upgradability/
and other clearances and locate process plants depending on their functional augmentation possibilities
dependence
Power purchase agreement and planning Plant road and drain layout preparation showing green belt,
for renewable energy generation landscaping, solar panel/solar tree locations.
Grading plan based on area drainage/ Space provisions for future plants and construction material
tsunami study and Contour Survey/Geo- storage
tech investigation etc.
Listing non-functional plant/facilities (For Constructability and plant safety aspects review
brownfield expansion projects)
Detailed project report preparation Review provisions for uninterrupted O&M of the existing
plant during other construction activities
Enabling activity considerations for plant layout development
Conceptual stage Engineering stage Implementation stage

Land demarcation, survey Boundary wall, temporary road/drain construction. Construction water, power, yard lighting,
pillar construction Fencing around running plants and dismantling dust suppression, construction office,
of plants not in use to accommodate new units canteen, toilet, stores, material entry gate etc.

• Availability of water supply facilities from perennial 2 Evolution of Layout

sources
Challenges
• Capacity expansion with economy of scale with less
operating units. More CAPEX and market penetration/
share
• Upgradation of existing infrastructure.
• Creation of space within available land
• Provide utility and services facilities within plant
boundary for smooth connectivity between units for
construction and maintenance
This paper deals with the engineering and consideration
for layout development for brownfield capacity expansion.
The layout inevitably undergoes a several numbers of
revisions from the time it is a gleam in the designer’s eye
until the last foundations have been constructed. Even so,
this ‘final layout’ is necessarily a compromise between the
desire to fulfil the criteria outlined in the finalized process
flow sheet and the limitations imposed by the available site,
available finance, construction schedules, preferences of
the client, and a host of other factors. It is also certain that
the plant owner and the designer himself will soon consider
this layout somewhat obsolete. But, where the designer has
had the conceptual vision to look beyond the present needs
and immediate risks and challenges of client, the resultant
layout is likely to maintain its logic and flexibility. In

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retrospect, the plea that ‘conditions have changed’ is sel- • Layout should incorporate built in safety and comfort
dom remembered; the success or failure of a brown field for entire plant life cycle with ease in maintenance/
steel plant layout is its capability to operate continuously at approach.
low cost in spite of changing conditions.
Planning the brown field expansion layout needs to be
Layout is a long-term commitment, and an improper
done, such that it must facilitate faster construction and
planning can create problem in process flow, safety, pro-
commissioning of units without violating any standard
duction, cost, etc. Planning the general layout of a brown
practices. It is vital that the massive capital invested in a
field expansion of integrated steelworks is in line with
steel plant is to put the work in shortest possible time, to
basically an exercise in making a rational arrangement of
which adherence to the construction schedule must be
the main production units with logical disposition of sim-
directed.
ilar facilities in a most economical way to achieve desired
While planning the brown field expansion, adoption of a
output at lowest cost with uninterrupted present operation,
high degree of standardization in layout, building and
the energy networks and the auxiliary shops, within the
equipment/process unit is needed. Expansion layout must
limitations of the existing site maintaining overall safety.
be in 3D platform to facilitate efficient planning and
Optimization of brown field layout of steel works must
designing. Optimized layout is to be developed through 3D
fulfil at least few major criteria
integrated approach with a common digital model of the
• It must ensure uninterrupted receipt and storing of entire plant by
major raw materials with latest operation practices and
• Merging the engineering output from various vendors
to overcome bottlenecks in the existing system, logical
including OEMs
faster movement of intermediate process materials and
• Model of existing plant from client, through surveys/
smooth disposal of finished products, by-products and
scanning of existing facilities including underground
disposal/recycling of plant generated waste.
scanning as required
• Production facilities along with its associated auxiliary
• Vendors to create a seamless layout for safe and time
units together with the system for utilities must be so
bound execution within the battery limit
located to assist in achieving minimum capital and
operating expenditure. This is not only for present A master layout needs to be created showing present
expansion but also for subsequent phase of plant facilities, facilities under current expansion and future
expansion. Sometimes, it often occurs that existing expansion as layout is a long-term or lifetime commitment.
plant has been designed stringently to cut cost and in
long run become more expensive than one which
incurred slightly extra costs for investment on 3 Layout Patterns
flexibility.
• Planning of future expansion must provide opportunity The layout pattern to be adopted for expansion of an
for rational expansion to large future capacity to meet integrated steelworks depends on major factors as follows
growing requirements and also to take advantage of the
• Identification of area available, demolition of existing
economy of scale. This requires not merely space for
facilities which is nonfunctional for creating new
additional and larger production units, but also design
facilities
provision for enlarging utilities such as water, power,
• Shape of the selected area available for the facilities
gas lines and railway tracks with minimum interference
under expansion
with existing operations. Layout should not only
• Contours and soil characteristics in the selected area
incorporate proved technological advances in the
• Alignment of existing incoming raw materials and
design under the present expansion phase, but also
utilities for blast furnace (BF), sinter plant (SP), coke
give thoughts to techniques which shall show provision
ovens (CO), etc.,
for future expansion of the plant. Creation of space for
• Alignment of existing hot metal tracks from existing
new units considering sustainable and captive operation
BF to steel melt shop (SMS)
is most important for plant layout development
• Auxiliaries and utilities supply to the new units
• Ease of operation between existing and proposed
• Alignment with existing intra-/inter-plant rail/road
facilities
network for both incoming and outgoing material.
• Adaption to zonal industrial requirements, local natural
• Disposition of raw materials unloading yard and
requirement, alignment with local urban needs and
finished product storage/sorting yard.
environmental protection including green belt as elab-
• Alignment between existing rolling mill (RM) and new
orated later.
steel melt shop.

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3.1 Creation of Space for New Facilities
Creation of space for new process units and supporting
facilities is one of the most important areas for capacity
expansion. The following may be considered
• Use of area available of existing slag dump, if
available,
• Reclamation of waste storage area, as far as practicable
• Shifting of existing large spare storage/maintenance
shops facilities at individual units mainly created in the
old ISPs into a well-designed central store and central
maintenance work shop.
• Avoiding granulated slag storage and direct transport of
the same to nearby cement plant or storage of the same
in silos outside plant boundary for road transport
• Gradual phasing out of old inefficient units and
utilization of the area for installation of high capacity
units, etc.
Use of existing slag dump for installation of new facil-
ities has already been considered in one of the ISPs in India
with modification of existing infrastructure and logistics
and shutting down of low capacity BFs and old SMS with
twin hearth furnaces.
Old ISPs in Indian facilities were created not only for
critical spares but also for non-critical items in large
quantities as the lead time of delivery was high due to non-
availability of ancillary industry. Presently, spares are
available, and the plants are operating with optimum spares
to reduce cost towards working capital. The space
requirement for local storage thereby has significantly
reduced. Possibility of installation of a state-of-the art
central store at a most convenient place and creation of
space for new facilities for capacity expansion needs to be
considered.
A systematic approach/audit for identifying nonfunc-
tional units like foundry, forge shop, heat treatment units,
machine shop needs to be carried out to create space to be
utilized for new facilities.
Dismantling of lower capacity units which are not effi-
cient in a phased manner and installation of large capacity
unit adopting the principal of economy of scale is desir-
able. Area available for such units for installation of new
units will also help for lower CAPEX. As an example,
phasing out of old low capacity sinter plants, replacement
of smaller BFs/capacity increase of existing BFs using/
strengthening of existing foundation, adoption of simulta-
neous operation of all BOFs, etc., will support more
rational layout development for capacity increase. Such
steps have already been adopted by ISPs worldwide. Some
of the existing steel plants with area utilization per ton of
crude steel production are shown in Table 2
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It may be noted from Table 1 that some of the ISPs in
India have space for significant capacity expansion con-
sidering available land and proper planning of layout
development will ensure sustainability of individual ISP. A
well-planned layout may bring down the land utilization to
about 1 m2/ton of crude steel.
3.2 Raw Materials Unloading Yard and Storage
Majority of the plants unload the materials either by wagon
tipplers or by track hoppers depending upon the availability
of wagons in that circuit. Present unloading rate of single
wagon tippler in our country is about 4–5 rakes a day. This
results in requirement of substantial area for developing the
railway yard. If we adopt tipple house of having unloading
capacity of two wagons (twin tippler) at a time, unloading
rate will be to 7–8 rakes a day, thus leading to reduction in
requirement of area by 30–40% than the existing system.
Adoption of merry-go-round (MGR) system during
expansion/modernization if space permits will improve the
cycle time of rake handling as well as minimization/avoid-
ance of demurrage pay as per rules/stipulations by Indian
Railways. Inter-connectivity between raw materials
unloading yard (RMUY) and finished product exchange yard
must be ensured to maximize the utilization of empty rake
from the RMUY for loading of products. This will minimize
the operating cost (getting freight benefit from railways) as
the same rake will be utilized loading and unloading. Typical
layout of twin tippler with MGR is shown in Fig. 1.
Review of raw material storage capacity inside plant,
adoption of technology like bedding and blending instead
of source-wise storage through quality analysis for each
rake will optimize space requirement of storage and han-
dling facilities for all incoming materials.
3.3 Iron and Steel Making Area
As discussed earlier under ‘creation of space’, major
challenges in the coke oven, sinter plant, blast furnace area
are development of space not only for new/upgraded
facilities but also space for required power, utility, services
facilities, construction equipment, availability of road for
maintenance, etc.
The degree of difficulty of accommodating expansion
units within an existing plant greatly depends on new
technological requirements and variations from initial stage
assumptions. For example, difficulty in accommodating
coke dry quenching (CDQ) plant with boiler and power
plant in an existing ISP, for reduction of carbon footprint
and statutory requirement, has been faced mainly due to
paucity of space near coke oven battery (COB). This is one
of the areas where layout plays a key role in association
with process to finalize the layout.
Trans Indian Inst Met
Table 2 Utilization of land per ton of crude steel
Sl. no Capacity of plant in MTPA
1 9.7
2 3.3 can be expanded to 8 within same area
3 10 (Proposed)
4 5.0
Fig. 1 Typical example of
incoming bulk material
handling system
3.4 Hot Metal Movement from Blast Furnace (BF)
to Steel Melting Shop (SMS)
Adequate rail infrastructure for evacuation of additional
hot metal to SMS is also of prime importance. Develop-
ment of general layout is more challenging when BFs are in
different areas due to limited space in the existing area and
hot metal to be transported from different BFs to different
steel shops depending on requirement.
Normally, torpedo cars carry hot metal from BF under
pull condition and before entering SMS; it will be push
condition as per standard practices. As hot metal circuit is
the life line of steel plant, proper planning should be done
at the exit of BF cast house and before the entry to SMS.
Optimization of hot circuit with common parking bay of
torpedo cars is essential for better coordination and their
effective utilization of space, i.e. travel distance of torpedo
cars should be minimum from BF to SMS. It has been
observed that travel distance of torpedo cars in majority of
old steel plants is more due to disposition of BF and SMS.
Proper planning should be done to the extent possible to
keep travel distance as minimum as possible with respect to
BF, SMS, Torpedo ladle repair shop and Pig Casting
Machines (PCM)/hot metal pooling pits/iron granulation
units. To avoid man machine interface in the hot metal
circuit and to continue with safe operation practices, road
over bridge is generally proposed for un-interrupted
movement of torpedo cars. A localized simulation study
can be carried out with all parameters like BF, converter
and other units, tapping time/processing times, cranes data,
transfer car data, etc., to check the correctness of the
conceived system with an aim to achieve zero interference
movement to avoid consequential delay and build up.
Land area in acres Area utilization in m2/Ton of crude steel
2205 0.92
2000 1.01
3000 1.21
13,371.345 10.82
Movement of hot metal from existing as well as pro-
posed iron making plants to both existing and proposed
steel making facilities is to be considered while planning
for hot metal track layout. Suitable connection of existing
HM track with the proposed HM track shall be made for
the ease of hot metal movement between existing and
proposed plant. Alternatively, road movement of hot metal
can be considered. However dedicated road for this to be
planned.
3.5 SMS and Rolling Mills
The steel melt shops may be parallel to the BF base line or
at varying angles to it in ‘herring-bone’ pattern. As the
length of a BOF melt-shop is almost half that of an
equivalent ‘open-hearth’ shop, the layout of a plant with
BOF steelmaking is considerably more compact. The
rolling mill complexes may then follow a sequential flow
from the melt-shops or may again be parallel to the base
line. Generally, at plants designed for three or four such
production lines to attain large future capacities, the
arrangement of both melt-shops and primary mills in
sequence, rather than in parallel to the base line, is
preferable.
To analyse the bottleneck inside a plant, a simulation
software may be used and Gantt chart analysis or har-
monogram and other output will show the bottleneck.
Simulation software with 3D animated view of plant and
equipment can be developed on existing software platform
to suit to one’s requirement, and optimum result can be
obtained by debottlenecking. Simulation also helps final-
izing optimum crane, ladle, tundish, transfer car require-
ments within the plant and justifies the requirement of each
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units to attain the capacity expansion which give direction
on CAPEX and help minimizing OPEX.
3.6 Auxiliaries and Utilities
As important as the main production units, is the placement
of its auxiliaries. The arrangement of mould preparation,
scrap yard and stripper around a steel melt shop is difficult
as it involves the frequent movement of large tonnages
over short distances. The production shops and their
satellites are to be connected to water and energy sources.
The vast inputs of utilities required by modern processes
make it desirable that production units be planned around
as ‘utilities corridor’ which has ample space for distribu-
tion networks, their substations, water cooling and treating
units, and has easy access for maintenance as well as for
further expansion. The location of the power plant again
depends on the load centre and the quantum of power to be
generated.
Many processes at the steel plant, create fumes and
smoke, while others contaminate water supplies. The siting
of production units and their design must therefore pay
attention to the control of air and water pollution. These
problems need to be tackled from the earliest stages in
order that the atmosphere above an industrial community
and the rivers or other water resources remain clean for all
time. Zero discharge of industrial waste water and planning
for such effluent treatment area and giving back to system
should be planned in all new expansions.
It is desirable that at steel plants, particularly those,
where expansion is likely to be a continuing process,
construction yards and facilities are provided in a separate
adjoining area. So-called temporary facilities have a habit
of continuing indefinitely, and it is therefore necessary that
construction yards be well conceived and have access to
expansion sites with minimum interference to plant oper-
ations. In general, site fabrication in large scale is to be
discouraged inside an operating plant and prefabricated
structure may be thought off which is becoming popular
day by day to limit site activity, thus avoiding space
crunch, unwanted man and material movement, etc.
3.7 Central Receipt & Dispatch Yard (CRDY)
and Mills Sorting Yard (MSY)
It has been observed that location of CRDY and MSY in
some of old steel plants is different. To optimize the layout,
possibility is to be explored to eliminate these situations/
scenarios by providing CRDY and MSY adjacent to each
other or in a common yard. Necessary shunting operations
for placement of empty wagons in the mills, withdrawal of
loaded wagons from the mills, and formation of loaded
rakes will be performed in respective rolling mills sorting
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Trans Indian Inst Met
yards. Finished product rakes will be sent to the common
receipt/dispatch yard within the stipulated time given by
railways for onward dispatch to various destination.
3.8 Rail and Road Logistics
It is very important to study the rail and road logistics
within the plant boundary as well as surrounding areas of
existing plant to meet the requirement of the proposed
expansion. With the expansion plan, plant may face the
logistics problem because of difficulties, namely lack of
approach/connectivity required for the expansion, lack of
use of new technologies, parking areas, clear defined path
to follow the route of internal movement and storage space.
To mitigate this, simulation study has to be done for the rail
and road logistics to optimize the layout as well as zero
interface of man and vehicles within the plant.
The road traffic for the operating plant and traffic for
construction of new units for expansion shall be separated.
The proper logistics planning to avoid conflict of operation
traffic with construction traffic shall be done while devel-
oping the layout. It is preferable to have separate entry/exit
gate for construction traffic. If needed, temporary con-
struction roads shall be laid for movement of construction
traffic. Special logistics consideration is to be made for
planning new units inside the operating plant. Safety norms
for movement of construction traffic shall be considered
while planning.
3.9 Power and Water Infrastructure
3.9.1 Power Infrastructure
Allmost all the existing ISPs are connected to the national
grid. It will be necessary to undertake a power simulation
study for each unit planning for capacity increase.
Accordingly, the utilization of existing main distribution
sub-station(s), installation, if necessary, and cable con-
nection route both for high tension (HT) and low tension
(LT) lines are to be finalized. The cable routing for both
HT and LT lines is optimized based on detailed survey
covering both underground and over ground lines and
facilities.
Efforts have been made to consider power generation
from excess heat in the form of gas with good or moderate
calorific value/steam generation from various shops. This
will bring down dependency on grid power requirement,
wastage of sensible heat and add on decreasing carbon foot
print effort.
Trans Indian Inst Met
3.9.2 Water Infrastructure
All the existing ISPs have perennial source of water as
mentioned earlier. However, the raw water requirement
and make up water consumption to upgrade water infras-
tructure require thorough review of the existing facilities.
Old ISPs in India had cooling ponds for water system. With
technological development of closed circuit system, the
makeup water requirement is significantly low with
advanced technologies.
Based on the analysis, the raw water requirement and
keeping in mind the GOI regulation towards zero dis-
charge, the infrastructure development for water has been
properly considered in the layout. It is understood that
some ISPs in India have implemented capacity expansion
without major modification of the existing system.
3.10 3D Engineering and Simulation Studies
for Layout Development
Engineering in 3D platform supported by simulation
studies for layout development mainly for capacity
expansion will help for generating layout which will
address logistic development, internal material handling
and transport, optimum movement of materials, proper
inter-facing, reduced additional work of rerouting of
facilities, operation and maintenance, constructability and
implantation of project within cost and schedule. The fol-
lowing activities may be followed:
• Development of engineered 3D layout based on exist-
ing available drawings, site surveys, scanning of all
over ground and underground facilities including drone
surveys, are necessary.
• Identification of location of new units and optimization
with various options with 3D model review.
• Development of tentative 3D layout of new facilities
with integration of the existing facilities based on
available information.
• Development of engineered 3D general layout and
individual shop layouts during detailed engineering
based on information from vendors, clash checking and
issue of good for construction drawings extracted from
3D model.
• Development of overall project execution plan with
movement of construction equipment like cranes, etc.
• Integration of 3D models with project schedule/Pri-
mavera for 4D execution within schedule and budget.
3.11 Environment and Carbon Foot Print
Reduction
The latest regulations, stipulations of MoEFCC (Ministry
of Environmental, Forest and Climate Change), the
requirements of respective state governments and other
statutory bodies need to be considered while developing
the integrated general layout for the plant including exist-
ing and proposed plant. Statutory requirements for instal-
lation of new facilities like green areas within the plant
boundary, location of new units considering near-by river,
water bodies, forest, highways, tsunami for plants near
coastal areas, etc., are followed.
Global warming and Green House Gas (GHG) emission
are of concern today. Many countries are signatories of
Paris Protocol and ratifies the same for CO2 emission
reduction. As iron and steel making units are one of the
major contributors towards GHG generation in industrial
sector, it is necessary to address the issue during layout
model development. Over and above, installation of facil-
ities for generation of power using green energy sources,
identification of areas where solar power facilities can be
installed needs to be looked into.
The requirement of shifting of technological processes
from carbon-based reduction to H2-based reduction and
electric steel making are considered for minimization of
CO2 emission and sustainability in future. Layout devel-
opment for capacity expansion of ISPs considering the
above needs to be addressed, and provision of facilities is
provided.
4 Conclusion
The optimization of layout of a steelwork has an important
effect on cost and also on its potential to grow.
Capacity expansion of existing ISPs has many advan-
tages, and engineering for development of such layout for
each plant also has serious project-related challenges.
Technology selection, identification of space for new units,
creation of space through shifting of facilities/demolition,
integration of old and new facilitate, etc., as described in
this paper need to be addressed during engineering.
Simulation studies and engineering in 3D platform of
the existing facilities during layout development can opti-
mize cost ensuring flawless movement of materials from
receipt of input materials and dispatch of finished products,
constructability, negating problem related to interreference
of facilities, avoiding modification during erection. Inte-
gration of 3D model with implementation schedule will
help in installation of project with capacity of expansion
within budget and schedule.
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Last and not the least, the environmental issues towards
zero waste discharge, GHG reduction, reduction of carbon
footprint using alternative renewable source of energy and
creation of space for the same are considered.
Acknowledgements The authors are thankful to the Management of
TCE for allowing to publish this paper.
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1. Indian railway schedule of dimensions for broad gauge. www.
iricen.gov.in
2. Indian road congress codes and special publications. www.irc.nic.
in
3. Siting guidelines for industries—MoEFCC http://moef.gov.in/
wpcontent/uploads/2017/06/moef_gov_in_citizen_specinfo_
enguin_html.pdf
Publisher’s Note Springer Nature remains neutral with regard to
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