PREFEASIBILITY REPORT

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1 M/S INDIAN OIL CORPORATION LIMITED PREFEASIBILITY REPORT FOR THE PROPOSED CAPACITY EXPANSION OF MADURAI TERMINAL AT SURVEY NOS. 159 & 160, SIDCO INDUSTRIAL ESTATE, KAPPALUR VILLAGE, TIRUMANGALAM TALUK MADURAI SCHEDULE 6(b) CATEGORY B PREPARED BY

2 A. INTRODUCTION a. BRIEF DESCRIPTION OF PROJECT M/s IndianOil Corporation Limited has Madurai Terminal at Survey Nos. 159 & 160, SIDCO Industrial Estate, Kappalur, Madurai, Tamilnadu The Terminal receives bulk MS, HSD & SKO through CTMPL pipelines from CPCL refinery at Manali. It also receives Ethanol from different suppliers in Tamil Nadu. The products are stored in their respective storage tanks. The stored petroleum products are filled into road tankers in the filling shed where there are 23 TLF bays in 4 sets. Total existing capacity of the Terminal is KL. Proposed project envisages an expansion of storage capacity by the installation of three aboveground storage tanks (2 X 2000 KL) for Ethanol in the Marketing Terminal, (1 X 320 KL) transmix tank and (1x 20 KL) underground Surge Tank in pipeline station (CTMPL). After expansion, the storage capacity will increase to KL. The current proposal has been submitted to SEIAA, TN for the issuance of Environmental Clearance for the expansion of storage capacity (84280 KL) through the addition of three aboveground storage tanks and one underground Surge Tank. b. NATURE OF PROJECT The proposed project is an expansion project for increasing the storage capacity of the existing Terminal by 4340 KL. After implementation of the project, capacity of the Terminal will increase to KL from the present capacity of KL. Hence, the present proposal is classified under Schedule 6(b) & Category B as per EIA Notification c. PROFILE OF PROJECT PROPONENT Indian Oil Corporation Limited is an Indian state-owned oil and gas corporation with its headquarters in New Delhi, India. It is the world's 161 st largest corporation, according to the Fortune Global 500 list, and the largest public corporation in India when ranked by revenue. IndianOil is the highest ranked Indian company in the latest Fortune Global 500 listings. 1

3 The company is mainly controlled by Government of India which owns approximately 79% shares in the company. It is one of the seven Maharatna status companies of India, apart from Coal India Limited, NTPC Limited, Oil and Natural Gas Corporation, Steel Authority of India Limited, Bharat Heavy Electricals Limited and Gas Authority of India Limited. d. NEED FOR THE PROJECT & ITS IMPORTANCE Petroleum Industry plays a crucial role in meeting the daily needs of the common man but also contributes significantly towards Industrial and Economic Growth of the Nation. The demand for petroleum products has increased with the urbanization of the places in Tamil Nadu. In order to meet the demand and to meet ministry guideline in 10% ethanol doping criteria, IOCL proposes to increase the storage capacity of their existing Madurai terminal. The proposed project is meant for improving supply position of POL products in the villages and small towns around Madurai. e. DESCRIPTION OF CURRENT PROPOSAL The current proposal has been submitted to SEIAA, TN for the issuance of Environmental Clearance for the expansion of storage capacity from KL to KL through the construction of three aboveground and one Underground storage tanks. B. SITE ANALYSIS M/s. Indian Oil Corporation Ltd has set up the Terminal at Survey Nos. 159 & 160, SIDCO Industrial Estate, Kappalur, Madurai, Tamilnadu The Google map showing the project site is given in Figure 1. The general location of the project area is shown in Figure 2. 2

4 FIGURE 1 - GOOGLE IMAGE OF PROJECT SITE 3

5 FIGURE 2 - LOCATION MAP OF PROJECT SITE 4

6 a. CONNECTIVITY The project site is well connected by road network. The IOCL Madurai terminal is well connected to NH7. This unit is located in the Eastern direction of this road. The raw material is conveniently transported by this road. Map showing the road network around the site is given in Figure 3. FIGURE 3 - CONNECTIVITY MAP b. SITE CHARACTERISTICS Table 1 - Environmental Settings of the Project Site S. No. Particulars Details 1 Latitude 9 51'3.87"N 2 Longitude 78 1'47.34"E 3 Site Elevation above MSL 134 m 4 Topography Plain 5 Present land use at the site Industrial 6 Nearest highway National Highway-7 (Varanasi-Kanyakumari) 7 Nearest railway station Tiruparankundram Railway Station 4.94 km (NE) 8 Nearest airport Madurai International Airport 6.64 km (ESE) 5

7 S. No. Particulars Details 9 Nearest town/city Koothiyarkundu 1.92 km (NNE) 10 Water body Thenkarai Pond 6.41 km (NE) Avaniyapuram Lake 8.6 km (ENE) Nallathangal Pond 9.39 km (ENE) 11 Nearest Port Tuticorin Port 122 km (SSE) 12 Hills / valleys Thiruparankundram Hill 5.18 km (NE) Samanar Malai 8.17 km (NNE) Thiruparankundram 5.2 km (NE) 13 Rock Samanar Malai, Keelakuilkudy 6.6 km Archaeologically important (NNE) places Rock cut bas relief and beds and a mutilated Jain stone image, Karadipatti 8.65 km (N) 14 National Parks / Wildlife Sanctuaries/ Eco-sensitive zones as per Wild Life Nil in 10km radius Protection Act, Reserved / Protected Forests Nil in 10km radius 16 Seismicity Seismic Zone-II as per IS1893 (Part 1): Defense Installations Nil in 10 km radius c. CLIMATE Temperature During the summer months i.e., March-May, the mean maximum temperature is found to vary from 35.2 C to 37.3 C and the minimum temperature ranges from 19.9 C to 21.4 C in the winter months (December-February). Relative Humidity Humidity at Madurai is fairly medium throughout the major part of the year and maximum humidity of 84% during the North East Monsoon & Minimum of 63% during the South west monsoon. 6

8 Rainfall The total annual mean rainfall received at Madurai is about mm. Rainfall peaks during the month of October (mean monthly being about mm) followed by November (mean monthly being about mm) with the four monsoon months (June to September) contributing about 36.0% (about mm) of the total annual rainfall. d. SOIL Five major types of soil such as red soil, black soil, Brown soil and alluvial soil are found. The major soil type of Madurai district is Red soil, about 36 percent of the district is covered by red soil. About 20% & 14% of the district is covered by the Black soil & brown soil respectively. Red soil, black soil and brown soil are major soil types available in the district. e. INFRASTRUCTURE Since the proposed Project is an expansion project within the premises of the Madurai terminal, it will use all the infrastructural facilities of the existing Terminal. f. INDUSTRIAL WASTE MANAGEMENT Following waste management measures which are in line with the existing practice is conceived in the design to meet the environmental standards and environmental operating conditions for the project: I. AIR POLLUTION MANAGEMENT The Air Pollution mitigative measures conceived for the project is summarized below: Water spraying is conceived to minimize dust Pollution during excavation and earthwork (during construction phase). Hydrocarbon is stored in Floating Roof (FR) Tanks to minimize vapour loss. The DG sets have stack heights as specified by CPCB. Greenbelt is also developed along plant boundary to restrict air Pollution. 7

9 II. III. IV. WATER POLLUTION MANAGEMENT Wastewater Management philosophy is based on the following: The wastewater management philosophy is based on Zero Discharge concept. All oily effluents are diverted to Oil Water Separator (OWS). The wastewater from OWS after removal of oil & after testing is used for Green Belt development within the terminal. Domestic Sewage generated at the terminal is treated in the septic tank and disposed of via soak pit. The separate storm water drainage system is provided at the facility. The non-contaminated rainwater is discharged directly to rainwater harvesting pit within the facility. However, particularly during the monsoon, any oilcontaminated rainwater is led to the OWS for treatment prior to discharge. NOISE POLLUTION MANAGEMENT The following noise abatement measures are practiced for the Madurai Terminal: The equipment, which is the source of noise, has built-in type noise control abatement technology. Greenbelt is already developed around plant boundary and other strategic locations to reduce noise Pollution. SOLID WASTE MANAGEMENT The following measure is followed for the management of solid waste in Madurai Terminal: All biodegradable wastes (food and kitchen wastes) at the Terminal will be collected and disposed of through local bodies. Tank bottom sludge is generated while cleaning of oil storage tanks. The cleaning of oil storage tanks is done once in five years as per the practice of Oil Industry. Oily sludge generated will be treated through bioremediation technique. Bioremediation is a waste management technique that involves the use of organisms to remove or neutralize pollutants from a contaminated site. In our terminal, we have nine numbers of storage tanks for storing petroleum products. As per statutory requirements once in 5 years, all tanks will be cleaned and 8

10 during cleaning the sludge settled in the tank will be taken out and will be disposed of safely through bioremediation. The spent or used oil will be stored at a specific location prior to safe disposal through CPCB/TNPCB approved recycler. Other hazardous wastes if any like spent batteries, waste oil, empty drums of oil/chemicals, fluorescent tubing etc. is disposed of in accordance with approved. C. PROJECT DESCRIPTION M/s. IndianOil Corporation Ltd has set up the Terminal at Survey Nos. 159 & 160, SIDCO Industrial Estate, Kappalur, Madurai. a. LAYOUT OF PROJECT SITE The total land area available in Madurai Terminal is around 65 Acres. The total land is under the possession of IOCL. LAND USE BREAKUP S. No Description Area GREENBELT Development 1. Marketing Terminal 46 acres 10 Acres 2. Pipeline Station 5 acres 1 Acre 3. CFA & Bitumen Depot 3 Acres - 4. Greenbelt Area 11 Acres 11 acres Total Area 65 Acres 22 Acres (34% in 65 Acres) The Terminal layout is represented in Figure 4. 9

11 FIGURE 4 - SITE LAYOUT 10

12 b. DETAILS OF ALTERNATE SITES CONSIDERED Siting of the Project No alternative site is considered, as it is an expansion of an existing terminal in which all infrastructure facilities exist. The site has been selected mainly with the following considerations: Availability of existing infrastructural facilities for proposed expansion project. No additional land acquisition is required for the expansion project. The total land is under the possession of IOCL. Availability of water Technology / Process The project site will only deal with receipt, storage and distribution of petroleum product (viz. MS, HSD, SKO, and Ethanol). Thus from technology/process point of view, there is no scope of consideration for alternatives. c. SIZE & MAGNITUDE OF OPERATION The present storage capacity of Terminal is total KL. After expansion, the storage capacity will increase by 4340 KL Aggregate capacity after expansion will be KL. Table 2 - Tank Details TANK HEIGHT/ PRODUCT TYPE OF TANK DIA NO. LENGTH CAPACITY T101 MS FRVT 28 M 15 M 8600 KL T102 MS FRVT 28 M 15 M 8600 KL T103 MS FRVT 28M 15M 8600 KL T201 SKO CRVT 20 M 13 M 4000 KL T202 SKO CRVT 20 M 13 M 4000 KL T203 SKO CRVT 20 M 13 M 4000 KL T301 HSD CRVT 36 M 14 M KL T302 HSD CRVT 36 M 14 M KL T303 HSD CRVT 36 M 14 M KL T401 ETHANOL UG 3 M 10 M 70 KL 11

13 T402 ETHANOL UG M 10 M 70 KL 1 ETHANOL IFRVT 14 M 15 M 2000 KL 2 ETHANOL IFRVT 14M 15M 2000 KL CTMPL TRANSMIX TANK FRVT 8M 7.5M 320 KL CTMPL SURGE TANK UG 2.1 M 6 M 20 KL - EXISTING TANK DETAILS - PROPOSED TANK DETAILS d. PROCESS DESCRIPTION The Madurai Terminal at Kappalur is operated by IOCL. The terminal functions primarily as Petroleum products storage and distribution facility. The terminal operations are categorized as, 1. The Products are received through CTMPL pipelines from CPCL refinery, Manali (MS, HSD, SKO) and Ethanol through Road Tankers. 2. Unloading of Ethanol from Road Tankers in the designated tanks through Pumps 3. Storage in Aboveground & Underground Tanks 4. Loading in Tank Trucks through Pumps for distribution. 1. Receipt of product Petroleum products will be received through Road Tankers (Ethanol) and CTMPL Pipelines from CPCL Refinery, Manali (MS, HSD, SKO). 2. Unloading and Storage Products will be stored in designated above ground and Underground tanks. 3. Loading & Dispatch Empty Tank Lorries which report to the Terminal are sent to tank lorry filling bays. They are filled through loading arms fitted in the bays. Products come to the loading arm from the products tank through pump provided in the pump house. The 12

14 quantity filled in the tank lorry is measured by flow meters fitted in the bay. After Checking the right quantity the tank lorry is sent to retail outlets. Figure 5 - Process flow chart e. RAW MATERIAL REQUIREMENT & MATERIAL BALANCE The terminal is only for Storage and Distribution of POL and no processing is carried out, hence no Raw material is required. f. POWER REQUIREMENT & SOURCE The total power required during operation phase is about 565 KVA which is being met from TANGEDCO. No additional power requirement envisaged post expansion. In absence of power supply, this will be met from DG sets. D.G sets specifications are detailed in below Table: Table 3 - Details on D.G sets S. No. Capacity Stack height Number Fuel used (KVA) From GL (m) HSD BS III HSD BS III HSD BS III 11 g. MANPOWER REQUIREMENT 13

15 Total Manpower available in present Terminal is 26 Nos. No Additional Manpower is required for Expansion. Manpower Breakup Regular Employees General 6 Shift A 2 Shift B -2 Shift C 2 Security Staff Combined with Mktg. Personnel Trained in First Aid 5 nos. Others (Technicians / Helpers) 4 nos. h. WATER REQUIREMENT, SOURCE & WASTEWATER GENERATION The maximum consumption of water for the terminal is 3 KLD. For drinking purpose, the terminal is purchasing mineral water. For other purposes, water is sourced from bore wells. Sl. No. Particulars Quantity (KLD) 1 Domestic Use (Flushing) Canteen 1.25 Total 3 Canteen water will be reused for Greenbelt Development 1.25 Total water requirement for the Terminal is 3 KLD. Water balance table & diagram for the Terminal are given in below Table and Figure. This includes canteen, flushing, etc., No additional water requirement is envisaged for the proposed expansion. S. No. Domestic water requirement (KLD) Table 4 - Water balance table Canteen water requirement (KLD) Domestic sewage generation (KLD) Total 3 Septic tank Soak Pit * Note Wastewater generated from tank farm if any will be primarily oily water with suspended solids. After flow through OWS, this water will be released to Strom Water Drain. 14

16 Total water requirement (3 KLD) Domestic requirement (1.75 Sewage generated (1.4 KLD) Canteen Water requirement (1.25 KLD) Reuse for Greenbelt (1.25 KLD) Septic Tank/Soak Pit Figure 6 - Water balance chart D. INFRASTRUCTURE REQUIREMENTS The lists of equipments present at the Terminal are Table 5 - List of equipments / facilities & number S. No Equipment Total Number / Capacity Fire FIGHTING APPLIANCES/EQUIPMENTS/CHEMICALS 1 Fire Tenders/Firefighting engines Combined with Mktg. 2 Water Storage capacity 3 Fire Hoses 18 Jet-4 Fog-4 universal-4 curtain 4 Jet/fog/spray Nozzles nozzle-3 5 Foam Branch 2 6 Jumbo Jet Nozzles nil 7 Foam Compound (KL) 22,000 Liters SAFETY EQUIPMENTS 1 PVC Suit 2 2 Compressed air B.A. Set 1 3 Refill Cylinders for B.A. Set 1 4 Cascade B.A Set Nil 5 Fire Proximity Suit 1 15

17 LIST OF MARKETING TERMINAL FACILITIES 1. MS Storage (28m x 15m ht) 3 x 8600 KL 2. SKO Storage (20m x 13m ht) 3 x 4000 KL 3. HSD Storage (36m x 14m ht) 3 x KL 4. Ethanol Storage (3m x 10.50mLG 2 x 70 KL & 14m x 15m ht) 5. Truck Checking Station (11 x 2 bays 5.5m) 6. Drinking water sump 5 x 5m & 1m Deep 7. DG shed 9m x 9m 8. 8 Bay TLF shed Gantry A 9. 4 Bay TLF shed Gantry B Bay TLF shed Gantry C Bay TLF shed Gantry D 12. Foam Storage shed 7m x 8.4m 13. Bio Remediation Pit 12m x 12m 14. Water Tank (16m x 13m) 3 nos. (2x2600KL & 1x5200KL) 15. Fire Fighting pump house 44 x 9m 16. Fire water Sump 6 x 4m & 2m deep 17. Calibration Water sump 6.5m x 3.8m 18. Fire Water Sump 5.9m x 5.2m 19. OWS Sump 5.8 x 5.8m 20. Ethanol pump house 8m x 4m 21. Unloading bay (For Ethanol) 10m x 5.5m GAS DETECTION EQUIPMENT FOR GAS LEAKAGE: Hand held multi gas detectors are provided at the station to check the presence of CO, H2S, LEL and O2 concentration at the area of work. Fixed Gas Detectors and Open Gas Detectors were provided in MS Tank Farm & Pump house. a. AIR POLLUTION CONTROL MEASURES No emissions will be generated during the operations as the entire process will be carried out through close circuit piping from a storage area to TLF gantry. The only point source of emissions is D.G sets. D.G sets have been fitted with stacks of adequate height to disperse the pollutants. 16

18 Table 6 - Details on existing APCs Sources of emission Air Pollution Control measure Material of construction Stack height from GL (m) DG sets 2 x 320 KVA DG set 1 x 150 KVA DG sets 2 x 385 KVA Acoustic Enclosure with Stack MS Pipe 9 Acoustic Enclosure with Stack MS Pipe 9 Acoustic Enclosure with Stack MS Pipe 11 b. WASTEWATER TREATMENT METHOD From the Terminal, 1.4 KLD sewage will be generated, which will be disposed of through septic tanks & soak pits. Washing water generated from tank farm washing will be diverted to oil water separator and clarified wastewater will be reused for gardening etc. c. FIRE FIGHTING & PROTECTION SYSTEM Fire and Gas Detection System The basic philosophy of Fire Protection System design is centered on water as the main fire extinguishing medium. Our system is designed to give the adequate quantity of water at a specified minimum pressure and for an estimated minimum time required for firefighting. Sufficient quantity of water is always available and is pumped at pressure into a fire water piping network throughout the plant. Provision for other fire extinguishing medium such as foam, CO2, Dry Chemical powder etc. have been made at various locations in the pipeline to control/fight the fire at the very initial stage. The Fire station is connected with Fire alarm points located at various places in the pipeline. Siren at different places is also provided to alert the personnel about fire/disaster etc. Various Fire Fighting Facilities provided in the plant are based on the accepted requirements stipulated in OISD-STD-117. Fire Safety Coordinator and Fire Team Responsibilities of the Fire and Safety Coordinator shall include the following: 17

19 (a) to activate emergency sirens as per the practice codes; (b) To take charge of all firefighting and rescue operations and safety matters. (c) To ensure that key personnel is called in and to release the crew of firefighting operations as per emergency procedure. (d) Assess functioning of his team and communicate with the Main Incident Controller and Administrative Controller for any replenishment or, replacement of manpower/firefighting equipment. (e) Direct the Fire Brigade personnel and mutual aid members to their desired roles as also the proper positioning of the manpower and equipment. (f) To decide the requirement of mutual aid and instruct Fire Station, who, in turn, will contact mutual aid members. (g) To coordinate with outside fire brigades for properly coordinated firefighting operation; (h) To ensure that casualties are promptly sent to First Aid Centre / Hospital. (i) To arrange requirement of additional firefighting resources including help from mutual aid partners; (j) Ensure empty and loaded trucks are removed to safer area to the extent possible so as not to affect emergency handling operations (k) Continually lease with the Chief Incident Controller and implement the emergency combat strategies as communicated by him; and (l) Ensure adequate hydrant pressure in the mains and monitor water level in the reservoir. Fire Fighting Facilities Fire Water Tanks with storage capacity KL (For 4 Hour Firefighting) for handling Double Contingency. Fire Engines 6 Nos. each having capacity of 616 m 3 /hour. Fire Hydrant System Hydro Carbon Detection system (HCD) at MS Tank T101, T102, T103 & at product pump house. Sprinkler system Foam Pourer System on all product tanks. 18

20 HVLRs 04 nos. Around MS Tank Farm Emergency Shut Down Devices Located at TLF, TLF PH, TWD PH, Control Room, and Security Cabin & Admin Building LIC Cabin. Table 7 - List of Fire Fighting and First Aid Equipments Type of Fire Extinguishers Availability Type of Fire Extinguishers Availability DCP 9 KG &10 KG 78 GREEN FLAG 2 DCP 75 KG 10 SCABA 2 DCP 25 KG 13 PA SYSTEM 1 CO 4.5 KG 25 HOSE BOX 34 CO 2 KG 1 TROLLEY 1 AFFF FOAM KL CO2 CART200G 76 FIRE HOSES IN STORE 13 CO2 CATS2KG 3 FIRE HOSES IN BOX 74 CO2 CART1KG 18 JET NOZZLE IN STORE 2 DCPBAG10KG 650 JET NOZZLE IN BOX 34 DCPBAG75KG 120 SAND DR W/SCOOP 17 DCPBAG25KG 75 SFTY HELMET 60 WCFM IN TT GANTRY 7 STR W/BLANKET 2 WCFM HAZ 27 F AID BOX 3 WCFM NONHAZ 7 R HAND GLOVE 4 DOUBLE HYDRANT POINT HAZ 35 EXPL METR DOUBLE HYDRANT POINT 2 NONHAZ 7 F PROX SUIT 2 I ATCFOAM 1 KL RESUSC 2 FIRE WATER KL ELEC SIREN 1 FIRE WATER PUMPS 6 ELEC SIREN 1 JOCKEY PUMPS 2 HAND SIREN 6 EMERGENCY TOOL KIT 1 WATER JEL BLANKET 1 M.1.MEFG_P 2 RED FLAG 2 M.2.MEFG_F 3 19

21 20 PREFEASIBILITY REPORT

22 Figure 7 - Fire Hydrant Layout 21

23 d. RAINWATER HARVESTING Rainwater harvesting system available with 4 Nos. of pits to collect the rainwater from building roofs and is used to recharge the ground water resource. E. CORPORATE SOCIAL RESPONSIBILITY As a constructive partner in the communities in which it operates, IndianOil has been taking concrete action to realize its social responsibility objectives, thereby building value for its shareholders and customers. The Corporation respects human rights, values its employees, and invests in innovative technologies and solutions for sustainable energy flow and economic growth. In the past five decades, IndianOil has supported innumerable social and community initiatives in India, touching the lives of millions of people positively by supporting environmental and health-care projects and social, cultural and educational programmes. Besides focusing primarily on the welfare of economically and socially deprived sections of society, Indian Oil also aims at developing techno-economically viable and environment-friendly products & services for the benefit of millions of its consumers, while at the same time ensuring the highest standards of safety and environment. Every year, IndianOil sets aside a fixed portion of its profits for spreading smiles in millions of lives across the country through a comprehensive community welfare and development programme. About one-fourth of the community development funds are spent on the welfare of Scheduled Caste and Scheduled Tribe beneficiaries. Indian Oil has a concerted social responsibility programme to partner communities in health, family welfare, education, environment protection, providing potable water, sanitation, and empowerment of women and other marginalized groups. IndianOil has always been in the forefront in times of national emergencies. Indian Oil People have time and again rallied to help victims of natural calamities, maintaining an uninterrupted supply of petroleum products and contributing to relief and rehabilitation measures in cash and kind. Moreover, the unit has planned to carry out various activities for the upliftment of poor people, welfare of women and labors, education of poor students as part of CSR in the 22

24 nearby villages and therefore, during and after proposed project, unit will spend more than that required by statutory norms every year towards CSR activities. Proposed CSR Works Details of Madurai Terminal ( ): 1. RO water plant for Karuvelampatti - Rs.10 lakhs 2. Solar PV Street light post - Rs. 09 Lakhs 3. Community Hall at Karuvelampatti - Rs. 20 Lakhs 4. Community Toilet at Karuvelampatti - Rs. 10 Lakhs 5. Tiles works / Computer Room at Govt. School - Rs. 07 Lakhs Net Total - Rs.56 Lakhs F. PROJECT Cost The total project cost for the proposed expansion is around Rs Crores. G. BUDGET TOWARDS ENVIRONMENTAL MANAGEMENT PLAN AND MONITORING PLAN Table 8 - Budget for Implementation of EMP and Monitoring Plan (Cost in Lakh Rupees) S. No Description Recurring Cost Capital Cost Per Annum 1. Green Belt/Horticulture Rain Water Harvesting 5 - Municipal Waste Management Storage and disposal of oily sludge from tank cleaning 5. Environmental Monitoring Water Management Air Pollution Control Environmental Awareness and Training - 2 Total

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