PRE-FEASIBILITY REPORT

Transcription

1 PRE-FEASIBILITY REPORT CAPACITY ENHANCEMENT OF COAL WASHERY FROM 0.96 MTPA TO 5.0 MTPA AT CHHOTTE-DHOUMARPALLI VILLAGE, KARSIA TEHSIL, RAIGARH DISTRICT, CHHATTISGARH Submitted to: Ministry of Environment, Forest and Climate Change New Delhi Submitted by: RAJAN COAL WASHERY LIMITED A unit of Bhatiya Energy Minerals Private Limited Raigarh, Chhattisgarh December, 2017 Page 1 of 18

2 1. EXECUTIVE SUMMARY Sr. No. Description Details 1. Name of the Project Capacity enhancement of coal washery capacity from 0.96 MTPA to 5.0 MTPA 2. Location Chhote Dhoumarpalli village, Kharsia tehsil, Raigarh district, Chattisgarh state Geographical Co-ordinates: Latitude: N Longitude: E 3. Coal Washery Capacity (raw coal) Existing Capacity: 0.96 MTPA Additional Capacity: 4.04 MTPA After Expansion Capacity: 5.0 MTPA 4. Project area 8.1 ha (20 acres) 5. Process Technology Heavy Media Cyclone, Spirals 6. Water requirement & Source The water requirement of 2480 KLD for proposed expansion and existing capacity will be met from the Mand river (2.3 km, E). 7. Power requirement & Source The existing contract demand is 750 KVA supplied by CSEB. Action has already been initiated for obtaining approval from concerned authorities for enhancing the contract demand up to 6000 kva. The enhanced contract demand will also meet requirement of the proposed expansion. In case of power failure the existing 3 nos kva DG sets can meet the requirements of important loads 8. Working hours The plant will operate in three shifts each of 8 hours for 330 days in a year 9. Rehabilitation and Resettlement No R & R issue involved 10. Manpower (for the expansion) Construction Operation 11. Estimated Cost of the Project (expansion) Existing:110 persons Proposed: 400 persons Approximately 40 persons during construction period and 360 persons during operation. Rs. 70 Crores Page 2 of 18

3 2.0 INTRODUCTION OF THE PROJECT/ BACKGROUND INFORMATION 2.1 Identification of project and project proponent Coal is the most abundant fossil fuel. India is blessed with huge coal reserves. 85% of these reserves are non-coking coal, which caters to the need of power, cement and sponge iron plants. However, most of these reserves are of very low grade coal. The reserves of good quality coal are fast depleting and on the other hand, the demand for coal is increasing due to higher demand from steel, power and cement sectors. M/s. Bhatia Energy & Minerals Pvt Ltd is a well-established name in coal handling, transportation, and solar power. Now, they have formed a new company as Bhatia Energy & Minerals Pvt. Ltd. promoted Rajan Coal Washery project with a capacity of 0.96 MTPA at Karsiya (Robertson Railway station) of Raigarh district, Chhattisgarh state. Environmental Clearance issued by State Level Environmental Impact Assessment Authority, Raipur, Chhattisagarh vide letter no: 140/SEIAA-CG/EC/Coal Wash/RGH/225/10 Raipur, dated: 28/08/2012. Consent to establish issued by Chhattisgarh Environment Conservation Board, Raipur vide letter no: 4253/TS/CECB/2014 Raipur, dated: 20/10/2014. BRIEF DESCRIPTION OF NATURE OF THE PROJECT 3.1 Need for the expansion In view of upcoming mines in the area which will add up to CIL production drastically. New customers being added to our company. The proposed expansion coal washery will have the following parameters: Existing capacity : 0.96 MTPA Additional capacity : 4.04 MTPA Total Capacity (after expansion) : 5.0 MTPA No. of operating days in a year : 330 days Plant utilization : 100% The project will have the following outputs: Raw Coal (Equilibrated) Ash %, Moisture - 9%, GCV Kcal/kg Washed Coal (Equilibrated) Ash %, Moist 10 %, GCV Kcal / Kg., Yield of 70-80% Rejects (Equilibrated) Ash %, Yield % All the yield figures indicated are tentative and are meant for estimation purposes only. 3.0 Demand-Supply Gap The demand for non-coking washed coal has significantly increased in view of the Ministry of Environment and Forests Notification on use of coal with ash content not more than 34% in power plants located beyond 1000 km from the pithead Page 3 of 18

4 and in urban area or sensitive area or critically polluted area. The demand for use of washed coal for power generation would further increase as the distance threshold limit has been reduced to 500 km. The Government has also laid thrust on adoption of Clean Coal Technologies (CCTs) to mitigate adverse impact of coal usage on the environment. 4.0 Imports vs Indigenous production Raw coal will be sourced from Chhal mine/ Baroud mine of SECL, Raigarh area. Cost-wise indigenous production is much cheaper than the imported equivalent quality coal. 5.0 Export Possibility No coal will be exported. 6.0 Domestic / export Markets Presently, Coal Washeries established in India are not able to meet the beneficiated coal requirement. 7.0 PROJECT DESCRIPTION 7.1 Type of project The project is a coal washery and was established for beneficiating the raw coal to reduce ash content in the finished product. Raw coal will be sourced from Chhal mine/baroud mine of SECL, Raigarh area. 7.2 Location Nearest town Kharsia is about 6 km, in south-west direction. Nearest railway station Robertson is about 2.0 km in south east direction. General slope of the site is towards south-east and the average contour elevation near to the site is 240 m MSL. The project site is flat terrain with undulation. No forest land involved within the project site and land is already in industrial use. Mand river is about 2.3 km, east. There is no national park, wildlife sanctuary, eco-sensitive zones, elephant/tiger reserve and migratory routes within 10 km of the project site. Rabo RF (NE, 4.5 km), Bargarh RF (NW, 4.5 km), Basnajhar RF (SW, 5.0 km), Endu RF (NNW, 7.8 km), Burhapahar PF(2.4 km, SW), and Lotan RF (9.8 km, NNE) are within 10 km radius of project site. The index map of the project site is shown in Figure-I and a map showing area 10 km around the project site is shown in Figure-II. Page 4 of 18

5 FIGURE-I INDEX MAP SHOWING THE PROJECT SITE Page 5 of 18

6 Proposed Site Coordinates Sr.No. A B Latitude N E Longitude N E FIGURE-II MAP OF THE AREA 10 KM AROUND THE PROJECT SITE Page 6 of 18

7 7.3 Size or magnitude of operation The existing plant was constructed to wash about 0.96 MTPA. Environmental Clearance issued by State Level Environmental Impact Assessment Authority, Raipur, Chhattisagarh vide letter no: 140/SEIAA-CG/EC/Coal Wash/RGH/225/10 Raipur, dated: 28/08/2012. Consent to establish issued by Chhattisgarh Environment Conservation Board, Raipur vide letter no: 4253/TS/CECB/2014 Raipur, dated: 20/10/2014. Now, the present proposal is to enhance the production capacity of coal washery from 0.96 MTPA to 5.0 MTPA. 7.4 Project description with process details Existing: The operating coal washery was built in an area of 8.1 ha. Size of the project is 160x330x18 which implies the plant will operated for 330 days, 18 hours per day at 160 tonnes per hour throughput (TPH). The coal washery s source of raw material (coal) met from Chhal mines (at a distance of 24 km) or the Baround mines (50 km) of SECL in Raigarh. Proposed: Enhancement of coal washery capacity from 0.96 MTPA to 5.0 MTPA at Chhote Dhoumarpalli village, Kharsia tehsil, Raigarh district, Chhattisgarh state. 7.5 Technology and Process Description Salient features of the project are given in Table-. Sr.No Features Existing Proposed enhancement Total 1 Capacity 0.96 MTPA 4.04 MTPA 5.0 MTPA 2 Type of Wet process- Heavy media cyclone technology process 3 Land for 8.10 acres 8.10 acres washery 4 Pollution control Water sprinklers, Bag filters 5 Source of Mines of Raigarh area (Chhal mine/ Baroud mine of Raw coal SECL) a Quantity 0.96 MTPA 4.04 MTPA 5.0 MTPA B Status of XXX XXX XXX coal linkage 6 Water 480 KLD consumption/ requirement Source Mand river 7 Manpower Page 7 of 18

8 Heavy Media Technology: The proposed washery shall incorporate the latest designs and the latest equipment s and shall be a heavy media cyclone based coal processing unit. ROM shall be delivered to the truck dump station via tippers and the capacity of the truck dump hopper shall be 25tons. The truck dump shall be an elevated bunker with access for trucks to unload the ROM into the hopper. ROM shall be carried to the crushing and screening tower using a 1200 mm belt conveyor BC1. The ROM will be discharged over a single deck scalping screen having a heavy duty rod deck for screening the (-) 50mm coal. The undersize from the screen will report to the belt conveyor BC2 which carries coal to its storage stockpile. The oversize from the screen will be discharged to a double roll crusher with toothed rolls where the 50mm-250mm coal will be crushed to a consistent (-)50 mm size. The crusher product will also report to the same conveyor BC2 for stockpiling. A concrete stacking tube is proposed for stocking the raw crushed coal. The stacking tube shall have a capacity to store 12000MT of coal. There shall be 2 reclaim hoppers with vibrating feeders at their discharge which will feed the plant feed conveyor BC3 with coal. The capacity of the vibrating feeders can be changed by a simple mechanism. The uses of dozers are proposed to push the raw crushed coal into the reclaim hopper. The coal being carried on BC3 shall be discharged on a raw coal sizing & desliming screen where (-) 10/13mm coal will be removed on the first section of the screen and this coal having a relatively lower ash will report to the Fines carrying conveyor FC1. The Oversize will proceed to the second section of the screen where coal will be subjected to jets of water by which the slime on the coal body is washed off. The effluent from the desliming screen will be taken to the effluent treatment plant. The coal slurry consisting of coal water & magnetite is pumped using a special heavy media pump to the heavy media cyclone. The heavy media Bath is the main coal washing device in the coal preparation plant. The deep flow bath already carries media (Water and Magnetite powder) and the deslimed coal is received by the bath. In the bath the lighter (clean) is separated through the overflow and the heavier (rejects) is gathered and conveyed through the reject outlet of the bath to the reject screen. Thus the clean and reject is separated. Both the cleans and the rejects report to a Draining and rinsing screen with specially designed underpans to collect the drain water and the rinse water. In the first section of the screen (drain section) the water and magnetite slurry is drained partially. This drained water flows back to the heavy media sump. In the second section of the screen (rinse section) water jets are used to wash the coal of magnetite sticking to it body. The rinse water being of a lower specific gravity than the slurry in the sump has to be subjected to a wet drum magnetic separator where magnetite from the rinse water is concentrated and sent back Page 8 of 18

9 to the heavy media sump for recirculation. The effluents from the magnetic separator reports to the effluent treatment plant. The reject coal from the reject D&R screen is discharged over the reject coal belt BC5 for suitable stockpiling. The clean coal is discharged over the clean coal conveyor BC4 where the clean coal is blended with the raw bypass coal in the ratio to give final ash content as required by the end user. The product on BC4 is carried to a clean coal loadout bin which has Clamshell gate at the discharge for loading coal onto trucks. The effluent treatment plant consists of one Hi-rate thickener and its associated flocculent dosing system, underflow sludge carrying pump and a multiroll belt press. The effluent from the plant which reports to the hi-rate thickener is collected in the thickener tank. This tank is dosed with suitable amounts of flocculent which aids settlement of suspended solids and helps to give a clearer overflow. The settled solids are collected at the bottom cone of the thickener tank by rotating rake arms the height of which can be adjusted if the amount of solids in the effluents increases. The solids which are collected in the bottom of the thickener is pumped using a special centrifugal pump to the multiroll belt press for reclamation of water. The dried cakes are blended with the rejects. The overflow of the thickener which is clear water is pumped back to the preparation plant for recirculation Auxiliary Services Auxiliary services such as fresh water supply, compressed air, dust extraction, dust suppression, firefighting arrangements were also provided. Dust Control Arrangements Water spraying arrangement with the help of nozzles was provided near the truck receiving arrangement, near stack tube for raw coal and discharge pulley of washery feeding conveyor to suppress the dust. Dust extraction system consisting of hoods, ducting, centrifugal fan, cyclones, screw conveyors, stack have been provided near the screening and crushing house for control of dust generated at this place. The details of the equipment in the existing coal washery are as given below: Sr.No Particulars A Raw coal Section 1 Truck Receiving hopper 2 Vibratory feeders 3 Belt conveyor 4 Suspended type Electromagnetic separator 5 Primary screen 6 Double roll crusher 7 Secondary screen Page 9 of 18

10 Sr.No Particulars 8 Vibratory feeders B Washing Section B.1 Main unit (coarse coal section) 1 Raw Coal / By pass screen 2 De-Sliming Screen 3 Heavy Media Cyclone sump 4 Heavy Media cyclone pump 5 Heavy Media Cyclone, 1000mm dia. 6 D&R screen for Clean coal 7 Basket type Centrifuge for clean coal 8 Sieve Bend before D&R screen for rejects 9 D&R Screen for rejects 10 Wet drum Magnetic Separator for clean coal 11 Wet drum Magnetic Separator for rejects 12 Density Gauge and transmitting unit 13 Level transmitting unit 14 Pressure gauge and pressure transmitting unit 15 Magnetite charging pump 16 By pass conveyor B.2 Add-on circuit (coarse coal section) 1 De-Sliming Screen 2 Heavy Media Cyclone sump 3 Heavy Media cyclone pump 4 Heavy Media Cyclone, 800mm dia. 5 Sieve Bend before clean coal D&R screen 6 D&R screen for Clean coal 7 Basket type Centrifuge for clean coal 8 Sieve Bend before D&R screen for rejects 9 D&R Screen for rejects 10 Wet drum Magnetic Separator 11 Density Gauge and transmitting unit 12 Level transmitting unit 13 Pressure gauge and pressure transmitting unit 14 Magnetite charging pump 15 Clean coal conveyor 16 Refuse conveyor C Fine coal circuit (common for main and add on circuits) 1 Raw coal Classifying cyclone sump 2 Raw coal Classifying cyclone sump pump 3 Set of classifying cyclones 4 Spirals 5 Sieve bend before screen bowl centrifuge 6 Screen bowl centrifuge 7 Sieve bend before high frequency screen 8 High frequency screen 9 High rate thickener, 25 m dia. 10 Thickener under flow pump 11 Thickener over flow/ Clarified water pump 12 Belt press 13 Belt wash pump/ spray pump 14 Flocculent dosing system for thickener and belt press. 15 Clean up pump D Clean coal circuit Page 10 of 18

11 Sr.No Particulars 1 Belt conveyor 2 On line ash monitor 3 Belt Weighing machine E Rejects circuit 2 Belt conveyor 3 Sector gate below truck loading hopper- Common for all units Facilities/ Auxiliary services: The following are already in operation in the plant: i. Dust suppression system with spray nozzles etc. at truck receiving station, Discharge pulley conveyor. ii. Dust extraction system at primary screen, double roll crusher and secondary screen in screening and crusher house. The system is consisting of hoods, ducts, blower, cyclone, air lock valves, screw conveyor, stack etc. iii. Compressed air system iv. Firefighting system consisting of fire hydrants, Fire extinguishers, fire pumps, water tank, Fire alarm system etc. v. One number of stack tube for stacking raw coal in each module/ unit vi. One number of stack tube for stacking clean coal in each module/ unit vii. One number of exhaust fan and sump pump under each stack tube. viii. Slime pond equipped with over flow pump ix. Road weigh bridges along with control room. x. Rail weigh bridge Utilities: i. Administrative building with First aid center ii. Coal testing Laboratory iii. Work shop iv. Stores v. Canteen vi. Rest shelter vii. Car and cycle shed viii. 33Kv/ 433V Substation outdoor yard ix. MCC cum control room for washery Page 11 of 18

12 x. MCC and control room for clean coal loading section. xi. MCC and control room for silo and rapid loading arrangement. xii. Generator rooms xiii. Fresh water reservoir with pumps xiv. Reservoir for firefighting along with pump house. xv. Shed for Flocculent dosing system xvi. Road weigh bridges along with control room. xvii. Rail weigh bridge along with control room xviii. Security and time office xix. Junior guest house 8.0 Raw material required along with estimated quantity, likely source, marketing area of final products, mode of transport of raw material and finished product The existing requirement is about 0.96 MTPA raw coal and the requirement after expansion will be 4.04 MTPA raw coal. The sources or raw coal will be from basket of mines of MCL. Selection of process is based on the study of the available washability test results of coal from SECL mines in the region. Raw coal will be sourced from (Chhal mine/baroud mine of SECL, Raigarh area). Transportation of raw coal from mines to washery site will be by tipping trucks (Chhal 12 km, Baroud mine 45 km) via existing SECL coal transportation road. Washed coal will be transported through railway siding at about 0.70 km from site near Robertson station Resource optimization / recycling and reuse envisaged in the project, if any, should be given The washery was designed on zero discharge basis so the water required will met from the recycled water and small quantities of water is required for topping, dust suppression and industrial use Employment Generation (Direct &Indirect) due to the Project During construction period, the requirement of man power will be about 250. In the operation phase, 270 persons will get direct employment in various services. The maintenance of the proposed plant will be looked after by the existing manpower. The plant management will be responsible for overall performance of the unit. The management will be supported by a team of highly skilled persons having varied expertise and experience, which will function individually as well as collectively for overall performance of the plant Availability of water its source, Energy /power requirement and source should be given Page 12 of 18

13 12.1 Water Supply & Sewerage Water consumption of operating 0.96 MTPA is about 480 KLD- process 364 KLD, domestic-60 KLD, dust suppression and green belt development is about 110 KLD. The water requirement of 2480 KLD for proposed expansion and existing capacity will be met from the Mand river (2.3 km, E). Status of water allocation from Ground water department. Wastewater generated will be treated from and will be 100% recycled back to the process in a closed circuit module. Domestic sewage will be treated in septic tank and soak pit. Therefore no effluent will be discharged outside of the premises Power Power requirement for the existing plant met from Chhattisgarh State Power Distribution Company Limited (CSPDCL) 150 KVA DG set for standby power supply installed. The existing contract demand is 750 KVA supplied by CSEB. Action has already been initiated for obtaining approval from concerned authorities for enhancing the contract demand up to 6000 kva. The enhanced contract demand will also meet requirement of the proposed expansion. In case of power failure the existing 3 nos kva DG sets can meet the requirements of important loads Quantity of wastes to be generated and scheme for their Management/disposal The plant was constructed based on Zero effluent discharge basis. The rejects generated will be gainfully utilized by the prospective customers. Fines recovered from the slurry will be disposed off along with the rejects. The liquid waste generated will be treated in the plant for which equipment have been provided and the same was described in the fine coal circuit. There will not be any liquid discharge from the plant PROPOSED INFRASTRUCTURE 14.1 Industrial area (processing area) The Land use breakup of existing 8.10 acres of project land is as given below: S. No. Description Area in acres 1 Land for washery Land for reject disposal area Land for greenbelt development Land for coal storage yard and truck tripling 1.10 system yard 5 Land for raw water reservoir Land for fabrication / construction yard etc Others 0.38 Total 8.10 Source: Rajan Coal Washery Limited 14.2 Social infrastructure The existing canteen, rest shelter/room, recreation room will be shared and meet the requirement of expansion. Page 13 of 18

14 14.3 Connectivity Nearest railway station is Robertson RS (2.0 km, SE) and Kharsia station is at about 6.0 km, S from the project boundary. NH-200 is about 26 km, SE ad Raipur is the nearest airport at about 300 km Drinking Water Management (Source & Supply of water) The water requirement of 2480 KLD for proposed expansion and existing capacity will be met from the Mand river (2.3 km, E). Status of water allocation from Ground water department. The Rain water collected in the rain water harvesting pond is being treated to remove iron content and then is being treated in RO plants to make the water suitable for drinking Sewerage System Soak pits have been provided near the administrative building and other buildings for handling sewerage generated. The leakages in the plant are guided to slime pond where the coal fines will be settled and clean water will be recycled for use in the washery. No separate sewerage plant has been provided as the generation of sewerage is very negligible and can be handled by soak pits Wastewater/Effluents Management Washery effluent The effluent generated during washing are treated with the help of high rate thickened, belt press and slime ponds so that zero discharge can be achieved. There will not be any solid wastes Domestic effluent Soak pits have been provided near the administrative building and other buildings for handling sewerage generated. The leakages in the plant are guided to slime pond where the coal fines will be settled and clean water will be recycled for use in the washery. No separate sewerage plant has been provided as the generation of sewerage is very negligible and can be handled by soak pits Solid and liquid waste Management Coal rejects (0.32 MTPA) will be lifted by the parties who shall get their coal washed. Coal fines will be removed in the form of belt press cake. The oil and grease collected from oil water separator will be sold to authorized recyclers. About 300 to 400 lit of used engine will be available in a year. The used engine oil will be stored in the barrels and sold to the authorised recyclers in the market. Rain water harvesting will be carried out for roof top water administrative building. Coal stock yard (raw coal, washed coal, coal rejects and coal fines) will be housed in closed sheds in pucca platform above ground level provided with wind shields/ wind breaking walls. Page 14 of 18

15 Municipal Waste: Negligible municipal wastes will be generated, which after composing will be used as manure. There will be no domestic wastes as residential buildings are not constructed in the washery premises REHABILITATION AND RESETTLEMENT (R & R) PLAN The proposed expansion project is within existing washery premises and the expansion does not require any additional land so no rehabilitation and resettlement of displaced persons is required PROJECT SCHEDULE & COST ESTIMATES Total project cost has been estimated as Rs.70 Crores ANALYSIS OF PROPOSAL (FINAL RECOMMENDATIONS) 17.1 Pollution Control Design of washing plant will include measures to ensure effective compliance with environmental regulations. The following measures are proposed: Online Continuous Ambient Air Quality Monitoring system (CAAQMS) will be installed in the washery premises for monitoring PM, PM 2.5 & PM 10 for transmitting the real time data to the State Pollution Control Board and the Central Pollution Control Board servers. Dust extraction / dry fog type dust suppression system to control dust from the material transfer points. Regular Water Sprinkling on roads Plant with close circuit water circulation system so that no effluent is discharged in the open outside the plant boundary. All the process effluent will be collected in the thickener. Settled slurry of the thickener will be dewatered in a multi roll belt press. The dewatered filter cake will be mixed with the rejects. The clarified water from thickener overflow will be re-circulated to the plant for use as process water. Only make-up water requirement will be added in the clarified water tank. Since the plant will be designed with close circuit water system, no treatment of the process waste water will be needed. Emergency settling ponds will be constructed to take care of any unforeseen situation like pipe line jamming or break down of thickener. The clarified water from these ponds will be recycled as process water. Separate rain water harvesting is available in the plant, which will eventually reduce ground water abstraction. Equipment like centrifuge, belt press, high frequency screen as well as thickener will be installed to maximize water recovery from the washing circuit. This will ensure water conservation. Plantation in 33% of the project area is envisaged Financial and Social Benefits The project will improve the socio-economic status of the society in the region by generating direct and indirect employment opportunities. The project will contribute additional revenue to the State & Central exchequers in the form of Page 15 of 18

16 taxes, cess, etc. The anticipated impacts of the project are explained below: Human settlement is expected to increase after this project gets operational. In the long term, the project will have impact on the population growth due to migration of people from outside area. Indirect employment opportunities will also add to this. The literacy level of the project area is likely to increase as there will be influx of many educated people taking up jobs in the project, which is likely to result in establishment of better educational facilities. The impact of the project on the civic amenities will be minimal. Various initiatives to be planned in the project area will result in improvement / upgradation of civil amenities. The expenditure on environmental management for the year is about Rs 4.5 lakhs on account of concreting of internal roads, water spraying by tankers. The expenditure does not include expenditure incurred due to dust extraction system, water spraying system in the plant, thickener and belt press operating cost etc. The budget for environmental Management plan for the year will be about Rs 5.0 lakhs on account of concreting of internal roads, construction of two new settling ponds, tree plantation, water spraying by Water tankers. The budget amount is exclusive of expenditure incurred due to dust extraction system, water spraying system in the plant, thickener and belt press operating cost etc. The project related construction activities will benefit the local populace in a number of ways such as supply of construction labourers skilled, semi-skilled and un-skilled, tertiary sector employment and provision of goods and services for daily needs including transport. The proposed project will provide employment to the skilled as well as un-skilled persons. The local population will be given preference depending upon their suitability to the job requirement. Besides direct employment, indirect employment opportunities will also open up. The project will have positive impact in the region. Quality of life of the people will further improve, which in-turn will improve the socio-economic conditions of the area. Page 16 of 18

17 ANNEXURE-I PLANT LAYOUT (EXISTING) ANNEXURE-II PLANT LAYOUT PROPOSED (WITH LEGEND SHOWING ALL THE UNITS) Page 17 of 18

18 ANNEXURE-III PROCESS FLOW SHEET Page 18 of 18