B. GENERAL CONDITIONS

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1 Reason of Request Nandan Steels and Power Ltd Query of State Pollution Control Board officers due to following descriptions of EC which reads as below: 3. Steel Billets/Ingots will be produced through induction furnace route using Sponge Iron and Metal scrap from SMS, Ferro Alloys, Steel Ingots/Billets for Rolling Mill as the raw materials. These Billets/Ingots will be fed to a Rolling Mill to produce structural steels. 5. The Ministry of Environment and Forest hereby accords environmental clearance to the above project under the provisions of EIA Notification dated 14 th September 2016 subject to strict compliance of the following specific and general conditions In addition in General Condition B (ii) it is stated that: B. GENERAL CONDITIONS ii. No further expansion or modification in the plant should be carried out without prior approval of the Ministry of Environment and Forest In light of the above, the CECB officials want us to submit the clarification from MOEFCC towards these conditions, to grant the Consent for proposed modernization. They say that no such conditions are given in EC granted to other similar units.

2 Nandan Steels and Power Ltd Facts of the Proposal A] Independent Billet Reheating Based Steel Rerolling Mill (Structural Steel) TPA capacity was setup with Consent dated 08/07/2004 from CECB 2. Consent Capacity was amended from TPA to TPA on dated 04/11/2004 B] Expansion of Existing Rolling Mill and Installation of a New MS Ingot/Billet production facility through Induction Furnace Route 3. On dated 07/04/2007 the capacity in consent was expanded to TPA for Rolling Mill and TPA M.S. Ingot/Billet production through Induction Furnace. 4. The Company obtained EC vide F J-11011/328/2007-IA II(I) Dated 31/10/2007 for production of MS Ingot/Billet and TPA Structural Steel.

3 Present Scenario Nandan Steels and Power Ltd At present Company has following production facilities in operation: Independent Billet Reheating Furnace based Steel Rolling Mill to produce TPA Structure Rerolled steel. Independent Induction Furnaces to produce MS Ingot/Billet = TPA Both these types of furnaces are categorized as Secondary Metallurgy as per EC granted under Category 3(a)

4 Pictorial Diagram of Independent Facilities Separately Implemented Induction Furnace Division Billet Reheating based Rerolling Mill Tested Billet from Market Flue Gas Pig Iron, Sponge Iron, Scrap Flux, Ferro Alloys, De-oxidizers Coal Furnace Oil Producer Gas Plant BILLET REHEATING FURANCE INDUCTION FURANCE CRUCIBLE Coal Ash Reheating for Hot Billet Melting in Crucible Hot Metal at C filling in Ladle Slag Removal Mill Scale Rolling Mill Driven by Electrical Motors Casting of Billet in Concast Rerolled Steel Hot Steel Billet/Ingot TPA Miss Rolls End Cutting Cooling Finished Product TPA Structural Steel send to Market Reroll able cold billet

5 Field Photographs showing implemented Process at Induction Furnace Division Raw Material handling Melting of Raw Material Processing Billet Making Sizing, Cutting, Cooling Finished Product Cold MS Ingot/Billet

6 Field Photographs showing implemented Process at Billet Reheating Furnace based Rolling Mill Billet Re-heating Furnace Re-rolling Re-rolling Re-rolled Products

7 Nandan Steels and Power Ltd TECHNOLOGICAL AND PROCES ASPECTS OF THE PROPOSED PROCESS INTEGRATION

8 Nandan Steels and Power Ltd Due to introduction of Clean and Green Technology known as Direct Hot Charging Rolling Facility in 2013 by Indus Smelters Limited in India. (which was awarded by Ministry of Steel, and United Nations Development Program ), it has become possible to convert the Hot billets produced by Induction Furnaces directly to Wire Rods by setting up a Rolling Mill. Therefore company proposed to implement this hot Charging rolling facility with existing Induction Furnaces and to convert hot billets directly in shape of wire rod.

9 Pictorial Diagram of Independent Facilities Separately Implemented Induction Furnace Division Billet Reheating based Rerolling Mill Tested Billet from Market Flue Gas Pig Iron, Sponge Iron, Scrap Flux, Ferro Alloys, De-oxidizers Coal Furnace Oil Producer Gas Plant BILLET REHEATING FURANCE INDUCTION FURANCE CRUCIBLE Coal Ash Reheating for Hot Billet Melting in Crucible Hot Metal at C filling in Ladle Slag Removal Mill Scale Rolling Mill Driven by Electrical Motors Casting of Billet in Concast Rerolled Steel Hot Steel Billet/Ingot TPA Miss Rolls End Cutting X Cooling Electrical Driven t Hot Charging Rerolling Mill Finished Steel TPA Structural Steel Reroll able cold Billet TPA Wire Rod No change in Production capacity No change

10 Proposed downstream integration portion to be added Hot Billets conveyor from Existing Facility Electrical Driven t Hot Charging Rerolling Mill TPA Wire Rod

11 Brief chart of existing products for Which EC is granted and the proposed products Nandan Steels and Power Ltd S.NO. and Items Existing Proposed Final Remarks expansion Induction Furnaces TPA nil (70000 TPA) This will be shifted in to produce Hot condition to Wire Billets/Ingot Rod Mill Billet Reheating TPA nil TPA No change based structure rerolling mill Wire Rod Mill nil TPA TPA Hot Billets from Induction Furance will be brought to convert into Wire Rod Final capacity TPA In case wire rod is not Wire Rod in demand then the & TPA Billets will be sold as structural business as usual steel after cooling it. Note: there will be no change in production capacity.

12 Assessment of Proposed Process Nandan Steels and Power Ltd Scenario Increase/expansion in production capacity Increase in Raw material Increase in Fuel Increase in wastage Increase in Emission Change in category of product Does proposed wire rod mill process falls under purview of EIA Notification 2006 Does the process increase Green House Gas emission. Does this expansion leads to change in existing production technology Result No No No (No fuel required) No (rather decrease) No (rather decrease) No No No (rather decrease) No

13 Merits of the Process Nandan Steels and Power Ltd At present Cold Billets produced from Induction Furnaces is sold to other rolling mills, which is required to be reheated through Billet Reheating Furnace; by firing of Fossil fuel; by adoption of the proposed process the equivalent amount of fossil fuel firing will be avoided, resulting in reduction in Green House Gas emission. The proposed downstream integration process will be driven by the electricity, therefore there will be no requirement of fuel. The latent heat content in billets will be used without being wasted, which will otherwise being wasted in atmosphere. In addition water required for cooling of hot billets, will be saved through this process adoption.

14 Nandan Steels and Power Ltd Copy of the CECB letter for requirement of Amendment in EC due to Point No.3

15 Nandan Steels and Power Ltd Clarification about the applicability of Para 3 and general condition B(ii) of EC granted to us It is not expected in EC that if our re-rolling mill is not operational then we should stop production of Induction Furnace; viz-a-viz also it is not expected that we must stop re-rolling mill, if the Induction Furnaces is not in operation. As both the process and equipment and facilities are independent and these are not integrated process. That any industry which is buying billet/ingot from our Induction Furnace division for their re-rolling mill has to seek EC and Consents for their Units by them selves. That any industry which is selling billet/ingot from their Induction Furnaces or steel plant for our re-rolling mill has to seek EC and Consents for their Units by them selves.

16 Nandan Steels and Power Ltd It is not expected by the granted EC that we can t sell the Billets Ingots produced in our Induction Furnace; nor any restriction is there that we can t buy the MS Ingots/Billets for our Re-rolling mill. We are not required by the EPA Act or EIA notification to seek EC to buy or sell any of the Raw Material or Finished goods. Also there is no condition stipulated in the EC that we have to produce the Billets for our rerolling mill in our unit itself or that we have to use the Billets produced in our Induction Furnaces by ourselves only. The Para 3 at best can be said to be enforcing on our unit that we will produce the Billets or Ingots which are suitable for steel structural rerolling. It may interpreted that due to this condition we are not allowed to produce ingots suitable for casting or forging or SS grade or Aluminum Ingot or SS ingots or Copper Ingots etc.

17 Nandan Steels and Power Ltd Justifications; why we didn t applied to seek fresh EC for the proposed Green Technology based downward process integration since begening Obligation under EIA Notification 2006: certain restrictions and prohibitions on new projects or activities, or on the expansion or modernization of existing projects or activities based on their potential environmental impacts as indicated in the Schedule to the notification. construction of new projects or activities or the expansion or modernization of existing projects or activities listed in the Schedule to this notification entailing capacity addition with change in process and or technology shall be undertaken in any part of India only after the prior environmental clearance from the Central Government or as the case may be, by the State Level Environment Impact Assessment Authority Justification: It is neither a New Project, nor expansion nor the process activity being added is included in schedule

18 Nandan Steels and Power Ltd Requirements of prior Environmental Clearance(EC):- All new projects or activities listed in the Schedule to this notification; Expansion and modernization of existing projects or activities listed in the Schedule to this notification with addition of capacity beyond the limits specified for the concerned sector, that is, projects or activities which cross the threshold limits given in the Schedule, after expansion or modernization; Any change in product - mix in an existing manufacturing unit included in Schedule beyond the specified range. Justification: It is neither a New Project, nor expansion, Neither Modernization of the existing Process. No Increase in Production capacity of the products granted to be produced in the existing EC from the scheduled process. Also the process activity or the Wire rod being added is NOT included in schedule.

19 Nandan Steels and Power Ltd 7(ii). Prior Environmental Clearance (EC) process for Expansion or Modernization or Change of product mix in existing projects: All applications seeking prior environmental clearance for expansion with increase in the production capacity beyond the capacity for which prior environmental clearance has been granted under this notification or with increase in either lease area or production capacity in the case of mining projects or for the modernization of an existing unit with increase in the total production capacity beyond the threshold limit prescribed in the Schedule to this notification through change in process and or technology or involving a change in the product mix shall be made in Form I and they shall be considered by the concerned Expert Appraisal Committee or State Level Expert Appraisal Committee within sixty days, who will decide on the due diligence necessary including preparation of EIA and public consultations and the application shall be appraised accordingly for grant of environmental clearance.

20 List of activities which are included in Schedule: Nandan Steels and Power Ltd (1) (2) (3) (4) (5) 3(a) Metallurgical a)primary industries metallurgical industry Sponge iron General Condition shall (ferrous & non manufacturing apply for Sponge iron ferrous) All projects <200TPD manufacturing b) Sponge iron manufacturing 200TPD c)secondary metallurgical processing industry All toxic and heavy metal producing units 20,000 tonnes /annum Secondary metallurgical processing industry i.)all toxic And heavy metal producing units <20,000 tonnes /annum ii.)all other non toxic Secondary metallurgical processing industries >5000 tonnes/annum In case of secondary. metallurgical processing industrial units, those projects involving operation of furnaces, onlv such as induction and electric arc furnace, submerged arc-furnace, and cupola with capacity more than 30,000 tonnes pa, (TPA) would require environmental clearance -