PRE FEASIBILITY REPORT

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1 2016 Expansion of POL Terminal In Magalia, Indore, Madhya Pradesh PRE FEASIBILITY REPORT 1 P a g e

2 Prefeasibility Report 1 EXECUTIVE SUMMARY INDUSTRIAL AREA (PROCESSING AREA) RESIDENTIAL AREA (NON-PROCESSING AREA) GREEN BELT DRINKING WATER MANAGEMENT (SOURCE & SUPPLY OF WATER) SEWAGE SYSTEM INDUSTRIAL WASTE MANAGEMENT POWER REQUIREMENT & SUPPLY/ SOURCE INTRODUCTION BRIEF DESCRIPTION OF THE PROJECT NEED FOR THE PROJECT AND ITS IMPORTANCE TO REGION EMPLOYMENT GENERATION (DIRECT AND INDIRECT) DUE TO THE PROJECT PROJECT DESCRIPTION TYPE OF PROJECT INCLUDING INTERLINKED AND INTERDEPENDENT PROJECTS, IF ANY LOCATION (SPECIFIC LOCATION AND PROJECT BOUNDARY & PROJECT LAY OUT) WITH COORDINATES DETAILS OF ALTERNATE SITES CONSIDERED AND THE BASIS OF SELECTING THE PROPOSED SITE, PARTICULARLY THE ENVIRONMENTAL CONSIDERATIONS GONE INTO SHOULD BE HIGHLIGHTED SIZE OR MAGNITUDE OF OPERATION TECHNOLOGY AND PROCESS DESCRIPTION RAW MATERIAL REQUIRED ALONG WITH ESTIMATED QUANTITY, LIKELY SOURCE, MARKETING AREA OF FINAL PRODUCTS, MODE OF TRANSPORT OF RAW MATERIAL AND FINISHED PRODUCT RESOURCE OPTIMIZATION/RECYCLING AND REUSE ENVISAGED IN THE PROJECT, IF ANY, SHOULD BE BRIEFLY OUTLINED TRANSPORTATION DETAILS OF RAW MATERIALS AVAILABILITY OF WATER ITS SOURCE, ENERGY/POWER REQUIREMENT AND SOURCE SHOULD BE GIVEN Water Source Electricity & Fuel Requirements QUANTITY OF WASTE TO BE GENERATED (LIQUID AND SOLID) AND SCHEME FOR THEIR MANAGEMENT /DISPOSAL Waste Water generation & Management plan Solid & Hazardous waste generation & Management plan SITE ANALYSIS CONNECTIVITY LAND FORM, LAND USE AND LAND OWNERSHIP TOPOGRAPHY (ALONG WITH MAP) EXISTING LAND USE PATTERN EXISTING INFRASTRUCTURE SOIL CLASSIFICATION SOIL INVESTIGATION WILL BE DONE DURING CONSTRUCTION OF POL STORAGE TERMINAL CLIMATIC DATA FROM SECONDARY SOURCES PLANNING BRIEF P a g e

3 5.1 PLANNING CONCEPT (TYPE OF INDUSTRIES, FACILITIES, TRANSPORTATION ETC) TOWN AND COUNTRY PLANNING/DEVELOPMENT AUTHORITY CLASSIFICATION POPULATION PROJECTION ASSESSMENT OF INFRASTRUCTURE DEMAND (PHYSICAL & SOCIAL) AMENITIES/FACILITIES PROPOSED INFRASTRUCTURE INDUSTRIAL AREA (PROCESSING AREA) RESIDENTIAL AREA (NON-PROCESSING AREA) GREEN BELT DRINKING WATER MANAGEMENT (SOURCE & SUPPLY OF WATER) SEWAGE SYSTEM INDUSTRIAL WASTE MANAGEMENT POWER REQUIREMENT & SUPPLY/ SOURCE REHABILITATION AND RESETTLEMENTS (R& R) PLAN POLICY TO BE ADOPTED (CENTRAL/STATE) IN RESPECT OF THE PROJECT AFFECTED PERSONS INCLUDING HOME OUSTEES, LAND OUSTEES AND LANDLESS LABOURERS (A BRIEF OUTLINE TO BE GIVEN) PROJECT SCHEDULE AND COST ESTIMATE LIKELY DATE OF START OF CONSTRUCTION AND LIKELY DATA OF COMPLETION (TIME SCHEDULE FOR THE PROJECT TO BE GIVEN) ESTIMATED PROJECT COST ALONG WITH ANALYSIS IN TERMS OF ECONOMIC VIABILITY OF THE PROJECT ANALYSIS OF PROPOSAL (FINAL RECOMMENDATIONS) FINANCIAL AND SOCIAL BENEFITS WITH SPECIAL EMPHASIS ON THE BENEFIT TO BE LOCAL PEOPLE INCLUDING TRIBAL POPULATION, IF ANY, IN THE AREA List of Annexure ANNEXURE- I- LETTER AND MOM OF MINISTER OF STATE (IC) P&NG ANNEXURE-II- LAND ALLOTMENT LETTER WITH NOTIFICATION ANNEXURE-III- AUTHORIZATION LETTER FOR HAZARDOUS WASTE ANNEXURE-IV- COPY OF CONSENT LETTER ANNEXURE V: TOPOMAP OF PROJECT SITE ANNEXURE VI- P&ID 3 P a g e

4 1 EXECUTIVE SUMMARY Oil marketing companies have projected an increase in demand of POL product in future due to increase in its domestic, Transportation and industrial use. The demand is likely to increase substantially over the years to come. Oil PSUs have planned enrollment of new customers to saturate the demand potential as per directive of the Ministry of Petroleum and Natural Gas, Government of India. In this regard, the meeting held on 6 th October 2016 with Hon ble Minister of state (IC) (P&NG) and PSUs (IOCL/HPCL/BPCL). The minutes of Meeting vid letter No-P20019/41/2014-LPG issued on 24 th December Now HPCL is planning to increase the plant capacity, by reducing the no of tanks (the existing plant was commissioned before 1994, all the design as per last standard. Now as per PESO/OISD standard the inter tanager distance is reduced. So, by increasing the ground covering, the size and storage quantity of all tankages will be revised) at existing plant at Manglia, Indore, and Madhya Pradesh. The existing capacity of the plant is 20,450 KL (18,450 KL Product & 2,000 KL Water) with 23 Tanks, which will be dismantle and proposing 51,600 KL (43600 KL Product & 8000 Water) with the 19 No of tanks. The project is targeted to be mechanically completed within 30 months from the date of handing over the land or statutory MOEF approval. The surmised point of this project mention below. Existing Facilities at Indore IRD Installation: Existing Capacity of Plant-18,450 KL Product & 2,000 KL Water 12 Nos of above ground Storage Tanks 8 Nos U/G Tanks for MS, HSD, SKO, ATF & ethanol, 2 Nos A/G Horizontal tanks 1x8 Bays + 1x2 bays T/T Gantry Pump Houses, Admin building and other allied facilities. Proposed Facilities: Proposed Capacity KL Product & 8000 Water. Dismantling of all tanks, Gantry, Pipeline, Pump house. New facilities proposed:. Tanks-19of varying capacity ( refer Table 1), TT Gantry (two rows of 8 bay ), pump house, and Fire fighting lines/facilities other support facilities and infrastructure facilities like approach roads, Pump Houses, Admin building, and vehicles parking areas. ( details given in the following section) 4 P a g e

5 Table 1: Existing Tanks with Quantity Sl.No Class Material No of Tank Quantity (KL) 1 C FO/LDO A Hexane/MS ULP 8 4, B HSD/SKO/ATF 8 13, TOTAL 21 18, NA Water (Fire Fighting) 2 2, ToTal 23 20,450 Table 2: Proposed Tanks with Quantity Sl.No Class Material No of Tank Quantity (KL) 1 C Bio Diesel 2 3, A Hexane/MS Ethanol 7 11, B HSD/SKO/ATF BIO Diesel 7 28, TOTAL 16 43, NA Water (Fire Fighting) 3 8, ToTal 19 51, Industrial Area (processing area) The proposed project falls under the industrial area and there is no processing involve in this project. The transportation of material for storage purpose thru railway siding and also depend on existing pipeline form BPCL terminal. Mangliya industrial area is situated beside A.B. Road near mangliya village 13 km away from Indore. In this area mainly medium major scale industries are established like dairy plant, solvent extraction, vegetable oil refinery, vanaspati plant and Storage of petroleum product. Total No. of industries registered in the board are 13 out of which red category units are 11 and green are Residential Area (non-processing area) No residential area proposed in upcoming project. 1.3 Green belt 6.5 Acres Green belt is already in existing plant. 1.4 Drinking water management (source & supply of water) No additional manpower will be added in proposed project. Existing drinking water management system is sufficient for proposed project. 5 P a g e

6 1.5 Sewage system Existing Sewage system is sufficient for proposed project. No additional facility will be required. 1.6 Industrial waste management There is no industrial waste will be generated by this project. Pleasantly 10 KL oil sludge is generated in once in 5 year from existing facility and it will be increase by 15 KL. The agreement is already signed with approved vender for dispose/recycle the waste. 1.7 Power requirement & supply/ source 400 kv electricity supplied by local electricity board and this is also sufficient for proposed project. No additional facility will be required. For the power backup 100 and 200 KW already existing in plant and it will be sufficient. 6 P a g e

7 2 INTRODUCTION Hindustan Petroleum Corporation Ltd is a Government of India Enterprise with a Navratna Status, and a Forbes 2000 and Global Fortune 500 company, is a leading public sector undertaking (PSU) engaged in refining, transportation and marketing of petroleum products across the country. HPCL has the second largest share of product pipelines in India with a pipeline network of more than 2,500 kms for transportation of petroleum products and a vast marketing network consisting of 13 Zonal offices in major cities and 101 Regional Offices facilitated by a Supply & Distribution infrastructure comprising Terminals, Pipeline networks, Aviation Service Stations, LPG Bottling Plants, Inland Relay Depots & Retail Outlets, Lube and LPG Distributorships. As an integrated oil company with refineries, marketing terminals/depots and retail outlets, HPCL is playing a significant role in the nation s economic development and growth. The proposed terminal is to cater the demand of POL products in western India from Manglia terminal. 2.1 Brief Description of the Project Oil marketing companies have projected an increase in demand of POL product in future due to increase in its domestic, Transportation and industrial use. The demand is likely to increase substantially over the years to come. Oil PSUs have planned enrollment of new customers to saturate the demand potential as per directive of the Ministry of Petroleum and Natural Gas, Government of India. In this regard, the meeting held on 6 th October 2016 with Hon ble Minister of state (IC) (P&NG) and PSUs (IOCL/HPCL/BPCL). The minutes of Meeting vid letter No-P20019/41/2014-LPG issued on 24 th December The MoM letter enclosed as an Annexure-I. Now HPCL is planning to increase the plant capacity, by reducing the no of tanks (the existing plant was commissioned before 1994, all the design as per last standard. Now as per PESO/OISD standard the inter tanager distance is reduced. So, by increasing the ground covering, the size and storage quantity of all tankages will be revised) at existing plant at Manglia, Indore, and Madhya Pradesh. The existing capacity of the plant is 20,450 KL (18,450 KL Product & 2,000 KL Water) with 23 Tanks, which will be dismantle and proposing 51,600 KL (43600 KL Product & 8000 Water) with the 19 No of tanks. 2.2 Employment Generation (Direct and Indirect) due to the project Currently 30 employee on HPCL pay roll, 25 No security staff and 14 contractor. For proposed project approx 95 people (Employee/security/Contractor) will work. 7 P a g e

8 Figure 1: Plant Lay Out 8 P a g e

9 3 PROJECT DESCRIPTION In proposed project, there is no process involved, only the storage of finished product (MS, HSD, SKO, ATF, HEXANE, FO & LDO) at terminal. All these materials will receive by existing pipeline and through rail wagons. The products are pumped through dedicated pipelines laid from POL siding to the respective product tanks. The terminal is provided with a total proposed storage capacity of 51, 600 KL of Tankage (MS, Ethanol, HSD, SKO, ATF, LDO & FO and water) and allied facilities. Details of storage tanks are provided in Table. All tanks are enclosed in dyke wall, capable of enclosing the volume of largest tank among others within the dyke in case of failure. New hydrant system and foam pourers will be provided to meet the Oil Industry and Safety Directorate (OISD) std Distribution/Dispatched of POL Product POL Products are dispatched through road tanks through closed dealer network system. Two number of TT gantry with 8 bay will be construct and addition space for 8 bay gantry will be leave free for future expansion. In addition to all Ethanol blending and additives blue dye dosing facility will be provided. Existing Facilities at Indore IRD Installation: Existing Capacity of Plant-18,450 KL Product & 2,000 KL Water 12 Nos of above ground Storage Tanks 8 Nos U/G Tanks for MS, HSD, SKO, ATF & ethanol, 2 Nos A/G Horizontal tanks 1x8 Bays + 1x2 bays T/T Gantry Pump Houses, Admin building and other allied facilities. Proposed Facilities: Proposed Capacity KL Product & 8000 Water. Dismantling of all tanks, Gantry, Pipeline, Pump house. New facilities proposed:. Tanks-19of varying capacity, TT Gantry (two rows of 8 bay ), pump house, and Fire fighting lines/facilities other support facilities and infrastructure facilities like approach roads, Pump Houses, Admin building, and vehicles parking areas. Detailed Process flow is given in Annexure VI. Table 3: Existing Tanks with Quantity Sl.No Class Material No of Tank Quantity (KL) 1 C FO/LDO A Hexane/MS ULP 8 4, B HSD/SKO/ATF 8 13, TOTAL 21 18, NA Water (Fire Fighting) 2 2, G.TOTAL 23 20,450 Table 2: Proposed Tanks with Quantity Sl.No Class Material No of Tank Quantity (KL) 9 P a g e

10 1 C Bio Diesel 2 3, A Hexane/MS Ethanol 7 11, B HSD/SKO/ATF BIO Diesel 7 28, TOTAL 16 43, NA Water (Fire Fighting) 3 8, G.TOTAL 19 51, Table 5: Existing Facility/Structure S. No. Structures AREA (SQ.M) 1 SECURITY CABIN 12 2 CHECKING PLATFORM CAR / CYCLE PARKING OFFICE BUILDING WORKER'S REST ROOM 48 6 DG / CONTROL ROOM-I BAY T/T GANTRY CALIBRATION SHED 64 9 LUBE DRUM YARD FIRE PUMP HOUSE AND EXTENSION TLF PUMP HOUSE TWD PUMP HOUSE TRANSFORMER YARD PLANT TOILET FLOOD LIGHT TOWER BLACK OIL GANTRY PLATFORM SEALING PLATFORM (PROPOSED) (RESIZE) OIL WATER SEPARATOR 9 20 TT LOCKING SHED LUBE WARE HOUSE NEW CONTROL ROOM LABORATARY LAB BUILDING CONTROL ROOM AUTOMATION BLUE DYE SHED (RESITEMENT) LAB BUILDING EXTENSION SECURITY CABIN(EXTENSION) POLE TYPE HIGH MAST WEIGH BRIDGE ADDITIVE SHED AIR COMPRESSOR SHED PLANING AND LOCKING ROOM ATF PUMP HOUSE 10 P a g e

11 35 ATF LOADING/ UNLOADING POINT Total 3860 Table 6: Proposed Facility/Structure SL.NO STRUCTURE AREA (SQ.M) 1 PLANNING ROOM 50 2 SECURITY CABIN/TT CHECKING 85 2A SEALING PLATFORM 50 3 SECURITY CABIN/TT CHECKING 28 4 OFFICE BUILDING CONTROL ROOM 300 5A LAB BUILDING T.T. PARKING AREA A 8X2 NO BAYS TT GANTRY 7 TLF PRODUCT PUMP HOUSE FIRE WATER PUMP HOUSE FIRE WATER PUMP HOUSE 10 CALIBRATION FACLILITY ENGG WARE HOUSE DU WARE HOUSE A DU SHED ETP TWO PUMP HOUSE IBACKS ROOM TRANSFORMER SUB SATTAION/MCC/DG ROOM VAPOUR REC SCRAP YARD SAMPLE ROOM DRIVER REST ROOM WATCH TOWER 23 DOSING SHADE (3 NO.) 12 TOTAL Type of Project including interlinked and interdependent projects, if any This is isolated storage project, as per EIA notification, project comes under the 6 B category. There is no interlined with this project. 3.2 Location (specific location and project boundary & project lay out) with coordinates The latitude and longitude of proposed site is N and E. 11 P a g e

12 Figure. Study Area Map 12 P a g e

13 3.3 Details of alternate sites considered and the basis of selecting the proposed site, particularly the environmental considerations gone into should be highlighted Alternative sites have not been considered for proposed project because the proposed project is coming in existing plant area. Major Factor involved in the selection of site are listed below The project site is in industrial area Site is connected with state highway for easy transport of POL product. Site is near to railway station and connected by railway line for import of POL product. Power, water and manpower is available near the project site. There is no forest or eco sensitive area within the 10km of project site 3.4 Size or Magnitude of Operation This is an expansion of existing project to construct POL storage Terminal. Class A, B, and C product will store and dispatched according to demand of market. Total storage capacity of POL storage will 51,600 KL future tanks. All facilities including admin building and other important structure will be constructed in acres of land and 33% (6.5 Acres) of total land will be used for green belt development. 3.5 Technology and Process Description POL products (MS, HSD, SKO, ATF, FO & LDO) will received through existing pipeline and rail wagons and stored in Tanks, further distributed thru tankers. 3.6 Raw material required along with estimated quantity, likely source, marketing area of final products, mode of transport of raw material and finished product. Construction material will be required during construction phase for building and utility quantity will be finalized during construction. POL product will be imported through Tank Wagon and store in respective tank 3.7 Resource optimization/recycling and reuse envisaged in the project, if any, should be briefly outlined. The sources of waste water from the proposed terminal are from canteen facilities and office building. The waste water is treated in sewage treatment plant and is reused for gardening and other activities like toilet flushing and cleaning purposes. Zero discharge is proposed for the terminal project. There is no process effluents generated. Hence impact on water quality from the proposed project is insignificant. 3.8 Transportation details of Raw Materials The raw material will be transported thru Railway Wagon and pipeline of BPCL Magaliya Terminal also. 13 P a g e

14 3.9 Availability of water its source, energy/power requirement and source should be given Water Source No additional water will be required for proposed project. Presently 12 KLD water requirement for Existing project. The source of water for the proposed project is meeting through Bore wells. Sewage will be treated in proposed STP. No trade effluent generates from the operation Electricity & Fuel Requirements For the Existing project, 250KV supply provided by Madhya Pradesh State Electricity Distribution Company Limited but future demand will be increase by 400kvA. Also for Power backup, HSD used as a fuel for D.G sets (100 & 200 kv) and it will be sufficient for proposed project also Quantity of waste to be generated (liquid and solid) and scheme for their management /disposal Waste Water generation & Management plan There is no manufacturing process as it is only storage and filling plant hence there will be no generation of Effluent. Sewage will be treated through septic tanks and soak pits Solid & Hazardous waste generation & Management plan The hazardous wastes generated is petroleum tank bottom sludge, Petroleum tanks are cleaned once in five year, The type and quantities of Hazardous waste generated from various processes are Approx.10 KL and it will be increase by 15 KL. The tank bottom sludge is sold out at third party to authorized vendor. The proponent is having authorization of 3.0 MT (15.0 MT/Year) in waste stream 3.1 for cleaning of petroleum oil storage tank sludge contacting oil and 0.04 MT (Yearly) in waste stream 5.1 used oil. The Authorization Letter enclosed as an Annexure II. The impact of solid waste on the environment will be insignificant. The Management of Hazardous waste will be done as per Hazardous Waste Management Rules P a g e

15 4 SITE ANALYSIS 4.1 Connectivity Mangliya industrial area is a industrial area, situated beside A.B. Road near mangliya village 13 km away from Indore. In this area mainly medium major industries are established like dairy plant, solvent extraction, vegetable oil refinery, vanaspati plant and Storage of petroleum product. Nearest railway station : Mangliya Gaon Railway Station (0.20 KM, NW )Indore Railway station (15 KM, SW) Nearest highway: Agra-Bombay Road,(0.380 km, E), NH-3,(1.59 km, E) Nearest Airport: Devi Ahilyabai Holkar Airport, Indore (25 KM, SW) Figure 2: Connectivity of Proposed plant 4.2 Land Form, Land Use and Land Ownership The existing plant is laying in Mangaliya industrial area, the copy of land allotment letter and copy of notification enclosed as an Annexure III. The existing plant area is about Acres and upcoming proposed facility coming in same premises. There is no additional land is required for POL Terminal. 4.3 Topography (along with map). The topography of the site is plain. Refer Annexure V. 15 P a g e

16 Figure 2: Plant Boundary of Proposed plant 4.4 Existing land use pattern The project area is laying Industrial area; there is no national park, wild life sanctuary, eco sensitive areas within 10 Km from the proposed project boundary. 4.5 Existing Infrastructure Adjacent BPCL/IOCL POL Terminal and well connected to rail facility. 4.6 Soil Classification Soil investigation will be done during construction of POL Storage Terminal. The district is covered by medium black soils. These soils are 0.46 to 0.9 meters thick and are rich in lime and lime nodules. The sub-soil and the partially disintegrated rock below allow easy drainage and hence these medium black soils can be freely irrigated. 16 P a g e

17 4.7 Climatic data from secondary sources The climate of Indore district is characterized by hot summer and well distributed rainfall during the southwest monsoon season. Monsoon arrives generally in the middle of June and the weather becomes pleasant. January is generally the coolest month. Sometimes in December, the minimum temperature. Normal annual rainfall of the district is mm. The district receives maximum rainfall during the south west monsoon period. Thus about 91.2 % of the total annual rainfall takes place during the south west monsoon period (June to September) alone. The maximum monthly rainfall takes place during the month of July. 17 P a g e

18 5 PLANNING BRIEF 5.1 Planning Concept (type of industries, facilities, transportation etc) Town and Country Planning/Development authority classification. Type of Industry: Construction of POL Storage Terminal 5.2 Population Projection Due to proposed project, there will be no impact on population inside and outside the plant. 5.3 Assessment of Infrastructure Demand (Physical & Social) On the basis of the preliminary site visit, the infrastructure demand in the villages was assessed on the basis of need and priority. Employment would be as per prevailing norms of state government for skilled and unskilled people for the proposed project activity. 5.4 Amenities/Facilities Proper site services such as First Aid, Canteen, Drinking Water, etc. will be provided to the workers. 18 P a g e

19 6 PROPOSED INFRASTRUCTURE 6.1 Industrial Area (processing area) The proposed project fall under the existing premises of HPCL, which is located in Mangliya industrial area. Mangliya industrial area is situated beside A.B. Road near mangliya village 13 km away from Indore. In this area mainly medium major scale industries are established like dairy plant, solvent extraction, vegetable oil refinery, vanaspati plant and Storage of petroleum product. Total No. of industries registered in the board are 13 out of which red category units are 11 and green are Residential Area (non-processing area) No residential area proposed in upcoming project 6.3 Green belt 6.5 Acres Green belt is already in existing plant. No additional green belt will be required. 6.4 Drinking water management (source & supply of water) There is no addition manpower will be added. So, existing drinking water management system is sufficient for proposed project. 6.5 Sewage system ETP facility is proposed for project. There is no addition manpower will be added. So, existing Sewage system is sufficient for proposed project. 6.6 Industrial waste management Approx 10 KL oil sludge is generated in 5 year form existing facility and it will be increase by 15 KL. The agreement is already signed with approved vender for dispose/recycle the waste. 6.7 Power requirement & supply/ source 250 kv electricity supplied by local electricity board and this is also sufficient for proposed project. No additional facility will be required. For the power backup 100 and 200 KW already existing in plant and it will be sufficient. 19 P a g e

20 7 REHABILITATION AND RESETTLEMENTS (R& R) PLAN 7.1 Policy to be adopted (central/state) in respect of the project affected persons including home oustees, land oustees and landless labourers (a brief outline to be given) Not applicable because the proposed project is located in Existing plant of HPCL. 20 P a g e

21 8 PROJECT SCHEDULE AND COST ESTIMATE 8.1 Likely date of start of construction and likely data of completion (time schedule for the project to be given) The time schedule for completion of project is 30 months after getting the all the statuary clearances. 8.2 Estimated project cost along with analysis in terms of economic viability of the project. Total cost for proposed project activity is Rs.150 Cr. 21 P a g e

22 9 ANALYSIS OF PROPOSAL (FINAL RECOMMENDATIONS) 9.1 Financial and social benefits with special emphasis on the benefit to be local people including tribal population, if any, in the area. The project will be beneficial to people as the company progress and expands its activity gradually. Through CSR activity company management will be committed to improve infrastructural facilities for the local people in fields of Environmental, Medical, and Transportation etc. The local people especially tribal population will be benefited by way of indirect employment opportunities which will improve the socioeconomic environment of the area. 22 P a g e

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