1.

0 PREAMBLE

Environmental Auditing in an industrial establishment is an important instrument to

ascertain and prevent overuse of resources, which subsequently cause damage
and degradation of natural environment. Each type of industry has separate distinct
characteristics and identity based on the raw material consumed, process adopted
for manufacture and the finished end product. These aspects, necessitate different
methodology for environmental auditing in different type of industries. In the above
context, it is felt that there is no specific standard system and procedure to carry out
environmental auditing in Fertilizer industry. Considering this need, the Central
Pollution Control Board (CPCB) has undertaken a project to prepare a document on
"STANDARD METHODOLOGY FOR ENVIRONMENTAL AUDITING IN FERTILIZER INDUSTRY”.

The scope of work for the project includes the following activities:

Preparation of questionnaire/format for eliciting information/data from Fertilizer

industries.
Planning for visit and study in a few selected industries having different processes,
feedstock and products.
Visit and field study in a few selected industries having different feedstock,
processes and final products.
Evolving the standard methodology for conducting environmental audit
followed by preparation of draft/final report.

2.0 ENVIRONMENTAL AUDITING

2.1 Definition

Environmental auditing is an important management tool comprising a systematic,

documented, periodic and objective evaluation/assessment of how well the
management systems are performing with the aim of:

Prevention of over uses of resources and reduction in generation of wastes;

Assessment of compliance of regulatory requirements;
Revealing the areas of deviation from management’s environment policy; and
Identification of areas where improvement is required

2.2 Objective

End-to-end environmental survey to observe the performance of the following

facilities:

Storage of feedstock/raw material and chemicals used in the process of

manufacture
Supply, storage, treatment and consumption of water by the industry
Mass balance of water and wastewater
Process of manufacture
Specific consumption of raw material/chemical
In-plant built-in system for control of pollution
Identification of waste generation sources
 Noise environment
Solid waste sources
Segregation of the wastewater for mutual treatment and end-of-pipe treatment
in ETP
Disposal practice of treated wastewater
Treated wastewater reuse, recycle and byproduct production
Monitoring practice
Storm water drainage system
Organizational set-up for management of environmental issues
Compliance of statutory regulations
Environmental policy of the management for safeguard of environment

2.3 Benefits

The main benefits of environmental auditing may be summarized as under:

Environmental auditing helps the management to clearly understand the status

of the industry specifically in the environmental front by an independent source
Auditing identifies the areas where wastage of resources occurring vis-à-vis
financial loss taking place
Adoption of waste recovery and reuse facilities which increases turn-over
Environmental auditing helps in strengthening environmental safeguards for
prevention of accidents
Dependable database is generated for process modification and in preparation
of disaster management plan (DMP)
Environmental auditing clearly exposes the overall performance of industry which
otherwise difficult to evaluate/identify
The human resources engaged in industry always remain alert, well informed and
carry out their responsibilities to preserve the environment for their own benefit
and also for future generation too
Environmental auditing provides useful information and database for statutory
requirements e.g. water cess assessment, environmental statement etc.

2.4 Support of Management

The management of industry should realize the objective and benefits of

environmental auditing and encourage environmental auditing activities. The
industry should extend full cooperation and permit access to the records and other
relevant information. In absence of unconditional sincere support of the
management of the industry, environmental auditing cannot be a success. The
management should interact with the audit team as necessary and adopt
appropriate actions for implementation of the recommendations made in
environmental auditing report. In case the management of the industry is indifferent
and non-responsive towards environmental auditing, then exposition of the benefits
of environmental auditing should be made to the corporate management of the
industry and whatever guidance is required, should be made available from the
corporate management of the industry.

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2.5 Environmental statement

The Ministry of Environment & Forests, Govt. of India issued a notification on

“Environmental Audit Report” on April 28, 1992, which was further amended on April
28, 1993 (Annexure I) and audit report was substituted by ‘Statement’. As per the
notification, every person carrying on an industry, operation or process requiring
consent under Section 25 of Water (Prevention & Control of pollution) Act, 1974, (6 of
1974) or under Section 21 of the Air (Prevention & Control of Pollution) Act, 1981 (14
of 1981) or both, authorization under the Hazardous Waste (Management &
Handling) Rules, 1989 issued under the Environment (Protection) Act, 1986 (29 of
1986) shall submit an Environmental Statement for the financial year ending 31st
March in the Form V to the concerned State Pollution Control Boards on or before
September 30, every year. Thus, the submission of Environment Statement every
year by September 30 is a pre-requisite for industries to obtain consent under Water
& Air Acts. Further, reliable information/data presentation in Environment Statement
needs conducting Environmental Audit. In other words, besides self-assessment,
environmental audit has statutory implication also. Therefore, conducting of
environmental auditing is a regular annual exercise year after year and cannot be
avoided particularly for Fertilizer industries.

2.6 Water Cess

According to the Water (Prevention and Control of Pollution) Cess Rules, 1978, all
industries are to submit the statement on consumption of water for different
purposes in Form No. I (Annexure II) by the 5th of every month for the period of
previous month. Environmental auditing facilities in obtaining the required data for
providing in Form No. I as indicated above.

3.0 FERTILIZER INDUSTRY SCENARIO

3.1 History

Large scale Fertilizer production commenced in India in the year 1951 with the
ammonium sulphate production capacity of 1000 MT per day at Sindri (Bihar). Since
then in last five decades, substantial growth of the industry had taken place and the
same trend is continued. The growth of industry is mainly to meet the domestic
requirement of fertilizer for production of food grain. In the financial year 1999-2000
nitrogenous Fertilizer (N) production was 10.88 million MT and phosphatic Fertilizer
(P2O5) production was 3.41 million MT. It is unfortunate that of late, the Sindri Fertilizer
plant has stopped production and completely retired from Fertilizer production
scenario.

3.2 Types of Fertilizers

The industries generally produce Fertilizers having two primary nutrients:

Nitrogenous Fertilizer

Phosphatic Fertilizer

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The other primary nutrient - Potassium is imported as muriate (Potassium Chloride)
and Sulphate of potash. In addition to the domestic production of Fertilizer,
significant quantities of various types of Fertilizers are imported to meet the demand
and production gap.

3.3 Fertilizer industry category

The Fertilizer industries are categorised based on the type of nutrients, present in
Fertilizers. When only one primary nutrient is present, it is termed as straight Fertilizer
whereas when more than one nutrients are present, the Fertilizer is designated as
complex or mixed Fertilizer. The Fertilizers generally prouced in India are as stated
below:

Straight Nitrogenous Fertilizer

o Urea
o Ammonium sulphate
o Calcium ammonium nitrate (CAN)

Straight Phosphatic Fertilizer

o Single Super Phosphate (SSP)

Complex or Mixed Fertilizer

o Diammonium phosphate (DAP)
o Ammonium nitro phosphate (NP)
o Different blends of NPK Fertilizers

3.4 Captive Plants

In addition to feedstock and raw materials required for Fertilizer production, process
water, power and certain chemicals are also needed and usually produced in
captive plants located in the same premises of the Fertilizer plants:

Water demineralization plant (DM plant)

Sulphuric acid plant (H2SO4 plant)
Phosphoric acid plant(H3PO4)
Nitric acid plant (HNO3 plant)
Captive power plant (CPP)
Steam generation plant (SGP)

The captive plants are integral parts of the main production unit based on the type
of the Fertilizer produced. It is evident that a Fertilizer production plant is generally a
complex of many facilities/features based on the type and ccapaity of main
production plant. The facilities and features generally present in a large production
unit is shown in Figure 1.

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4.0 MANUFACTURING PROCESS OF VARIOUS TYPES OF FERTILIZERS

4.1 Straight nitrogenous Fertilizer

The straight nitrogenous Fertilizers are - Urea, Calcium Ammonium Nitrate (CAN) and
Ammonium Sulphate. Of the above Fertilizers, urea is the most popular fertilizer used
by the farmers and therefore urea is produced many Fertilizer plants in the country.
The first step in the straight nitrogenous Fertilizer production is the production of
ammonia, which supplies the nitrogen component of nitrogenous Fertilizer.

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4.1.1 Ammonia

Ammonia an intermediate chemical for manufacture of nitrogenous fertilizer and is

produced by the reaction between hydrogen and nitrogen:

3H2 + N2 = 2 NH3

Nitrogen is obtained from air. Hydrogen, on the other hand, is obtained from
feedstock, e.g. natural gas, naphtha, fuel oil etc. The production of ammonia follows
the following steps:

a) Gasification
b) Shift conversion
c) Carbon dioxide recovery
d) Gas purification
e) Ammonia synthesis
f) Storage of ammonia

a) Gasification

Two main routes are adopted for gasification:

Steam reformation
Partial oxidation

Steam reformation: The industries which use natural gas or naphtha as feedstock
follow steam reformation route. In steam reformation, sulphur, is removed from
feedstock, natural gas or vaporised naphtha. The desulphurised feed is mixed with
steam and led to the Primary Reformer fitted with nickel catalyst. The reaction being
endothermic, external heating of the reformer is required. The partially reformed gas
from primary reformer flows to the secondary reformer where preheated air is mixed
to gas to obtain nitrogen gas in the gas mixture. In this reaction, heat is generated
and recovered as high pressure steam in waste heat boilers. The exit gas after
cooling in the heat exchangers is sent to the shift conversion units.

Partial Oxidation: The feedstock fuel oil essentially follows the partial oxidation route.
Naphtha and coke oven gas may either adopt partial oxidation or steam
reformation for gasification process. In partial oxidation process, oxygen and steam
are pre-heated separately and injected into a refractory lined chamber with
feedstock. Here the hydrocarbons are not completely oxidized. Some quantity of
uncombusted carbon remains in the gas mixture. The gas is freed from carbon by
water wash. The gas is desulphurised and sent to the shift conversion unit. Only a
few units presently follow partial oxidation process e.g. GNFC-Bharuch, NFL-Bathinda
and Panipat etc. Air separation unit is an integral part of the partial oxidation
process for supply of oxygen and nitrogen.

b) Shift conversion

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In the shift conversion process, carbon monoxide (CO) content of gas mixture is
converted into carbon dioxide (CO2) and hydrogen (H2) by passing over activated
iron oxide catalyst in presence of steam.
CO + H2O → CO2 + H2

The shift reaction is carried out in two stages at high and low temperature called HT
and LT shift reaction respectively. The constituents of the mixture of gas after shift
reaction are mainly CO2, H2 and N2.

c) Carbon dioxide (CO2) recovery

Carbon dioxide (CO2) thus obtained is in the mixed stage in a gas mixture. Carbon
dioxide is separated from the gas mixture by absorption process. Typical absorption
solutions presently used are indicated in Table 1. Carbon dioxide is later desorbed
from the absorbent solution and used in the urea manufacturing process or in the
preparation of ammonia carbonate solution needed for the manufacture of
ammonium sulphate by Merseberg process.

Table 1: Carbon Dioxide Absorpti on Processes and Typical Abs orbent

Solution

Process Constituents of abs orbent s olution

Vet rocoke Potassiu m Carbonate (20 per cent) and arsenic
t rioxide (15 per cent) *
Benfield Potassiu m Carbonate (30 per cent)
Diethanolamine (3 per cent) and arsenic
t rioxide (0.3 to 0.9 per cent ) *
Monoethanolamine MEA (15-20 per cent)
(MEA)
Rect isol Met hanol
Catacarb Potassiu m carbonat e, Diethanolamine and
Vanadium Pentoxide
Glycine Potassiu m carbonat e and glycine

* In the modern absorpt ion solutions arsenic component of Vet rocoke

and Benfield processes is withdrawn.

d) Gas purification

Small amount of CO and CO2 remaining in the gas as impurity is removed by

methanation by passing through hot gas over nickel based catalyst to convert CO
and CO2 into methane (CH4) and water. In the steam reformation process
methanation is practiced.

In the plants where partial oxidation process is followed, liquid nitrogen is available
from the air separation unit. In these plants the impurities CO and CO2, methane,
argon etc. are removed by liquid nitrogen wash instead of methanation.

e) Ammonia Synthesis

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Ammonia synthesis is carried out at elevated temperature and pressure of the order
350oC and 270 to 300 atmosphere respectively by passing hydrogen and nitrogen
mixture (1:3 volume ratio) over an activated iron oxide catalyst in converters. Since
at the operating conditions the conversion of hydrogen and nitrogen into ammonia
is of the order 10-20 percent, the reaction gas needs to be cooled to condense and
separate ammonia. The residual gas is recompressed and mixed with fresh make-up
gas and recycled to ammonia converter. Ammonia manufacturing process by
steam reformation and partial oxidation processes are presented in Figures 2 and 3
respectively. The various catalysts used in the production of ammonia with their
composition are presented in Table 2.

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Table 2: Catalysts in use in Ammonia Plants

S. No. Service Catalytic System

1. Hydrodesulphurization CoO-MoO-Al 2 O 3
2. Desulphurization ZnO
3. Pre-reforming NiO-Al 2 O 3
4. (a) Primary gas reforming NiO-Al 2 O 3
(b) Primary naphtha reforming NiO-Su pport
5. Secondary reforming NiO-Al 2 O 3
6. High temperature shift Fe 2 O 3 -Cr 2 O 3
Fe 2 O 3 -Cr 2 O 3 -Cu O
7. Medium temperature shift CuO-ZnO-Cr 2 O 3
8. Low temperatu re shift CuO-ZnO-Al 2 O 3
9. Methanat ion NiO-Al 2 O 3
10. Ammonia synthesis Fe 3 O 4 K 2 O-Al 2 O 3 -CaO

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f) Storage of Ammonia

The product ammonia is stored either in large spheres called HORTON SPHERES at a
pressure 20 atmosphere under ambient temperature or in large atmospheric tanks at
a temperature (-) 33oC.

4.1.2 Urea

Urea is manufactured by reaction of ammonia and carbon dioxide to form

ammonium carbamate first. Ammonium carbamate is then dehydrated to form
urea:

2 NH3 + CO2 ---------------→ NH4 COO NH2

Ammonium Carbamate

NH4COO NH2 ---------------→ NH2 CO NH2 + H2O

Urea

The carbon dioxide-ammonia reaction to form urea, ammonium carbamate and

water takes place in a reaction vessel at a pressure 160-200 atmosphere and
temperature 170-190oC. Unreacted ammonia and carbon dioxide are also present
along with ammonium carbamate and urea in the reactor exit stream. The pressure
of the exit stream is let down in stages in decomposers. The urea formed remains in
the solution while the ammonia and carbon dioxide evolved, are recovered from
the decomposers and recycled in the reaction vessel. The urea solution thus
obtained is concentrated to 99.8% in vacuum evaporators and finally prilled in
Prilling Tower. There are two types of Prilling Tower. In the modern plants natural
draft Prilling Towers are installed which cause comparatively less urea dust emission
from Prilling Tower. Schematic flow diagram for urea production process is provided
in Figure 4. The final product urea is stored in Silo or conveyed to the Bagging Plant
for transportation.

4.1.3 Ammonium Sulphate

There are three processes for manufacture of ammonium sulphate based on the use
of raw material:

a) Direct neutralization process

Ammonia is directly neutralized with sulphuric acid to produce ammonium sulphate.

2NH3 + H2SO4 (NH4)2SO4

(Ammonium Sulphate)

The neutralizer, evaporator and the crystallizer are so interconnected that the heat
released during neutralization is utilized to evaporate water in the ammonium
sulphate slurry. The units operate under partial vacuum. The crystals are separated
by centrifugation and the mother liquor is recycled. The wet salt passes through
rotary drier and cooler to obtain the product ammonium sulphate. The flow

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diagram for production of ammonium sulphate by direct neutralization process is
given in Figure 5.

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b) Merseberg process

First ammonium carbonate solution is prepared by absorbing carbon dioxide in

ammonia solution. Ammonium carbonate solution is then reacted with gypsum
(CaSO4, 2H2O) to produce ammonium sulphate and calcium carbonate.

2NH4OH + CO2 (NH4)2 CO3 + H2O

CaSO4, 2H2O + (NH4)2 CO3 (NH4)2 SO4 + CaCO3 + 2H2O

Calcium carbonate (chalk) is removed by filtration. Ammonium sulphate solution is

evaporated under vacuum, crystallized, centrifuged and dried. Natural gypsum or
byproduct gypsum of phosphoric acid plant may be used as raw material for
production of ammonium sulphate by the above process. The production process is
shown in Figure 6.

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c) Ammonium sulphate from coke oven byproduct ammonia

Coke oven gas contains about one per cent ammonia by volume. This gas is cooled
and passed into saturators containing weak sulphuric acid. Ammonium sulphate
crystals formed in the saturator are recovered, centrifuged, washed and dried to
obtain ammonium sulphate salt.

4.1.4 Calcium Ammonium Nitrate (CAN)

First, ammonium nitrate solution is prepared by reacting preheated ammonia with

nitric acid in a neutralizer. The heat of reaction is utilized for evaporation and 80-83
per cent ammonium nitrate solution is obtained. This concentrated solution is further
concentrated to obtain 92-94 per cent solution in vacuum concentrator.
Concentrated ammonium nitrate solution is then sprayed into the granulator along
with regulated quantity of limestone powder and the recycle fines from the screens.
The hot granules are dried in rotary drier by hot air, screened and cooled in
coolers to obtain the product CAN. The process of manufacture is provided in
Figure 7.

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4.2 Straight Phosphatic Fertilizer

4.2.1 Single super phosphate (SSP)

Ground rock phosphate (90 per cent passing through 100 mesh seive) is mixed with
sulphuric acid (55 to 75 percent) in a special designed mixer, which discharges the
product to a wide belt conveyor. The reaction is completed in the belt conveyor:

Ca10(PO4)6 F2 + 7 H2SO4 3 Ca(H2PO4)2 + 7 CaSO4 + 2 HF

The reacted mass is then sent to a curing shed where the product is stored for 3 to 4
weeks for curing and drying. The cured product is milled and screened to obtain
the product SSP. Where granulation is practiced, the cured SSP is granulated in
presence of steam. The manufacturing process is given in Figure 8.

4.3 Complex & mixed Fertilizer

4.3.1 Diammonium phosphate (DAP)

DAP is manufactured by reacting ammonia with phosphoric acid:

2 NH3 + H3PO4 (NH4)2 HPO4

Diammonium phosphate

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Ammonia, either gaseous or liquid and phosphoric acid of 40-54 per cent P2O5 are
used for the reaction. The preliminary neutralization is carried out in a preneutraliser
and then the slurry containing DAP and MAP (mono-ammonium phosphate) is sent
to the granulator where it is further ammoniated to get the desired mole ratio of
ammonia/phosphoric acid. Any unreacted ammonia gas is then scrubbed with
weak phosphoric acid and returned to the preneutraliser. The granulator discharge
is then dried and screened. Dried undersize granules are separated and recycled in
the process. The production process for DAP is shown in Figure 9.

4.3.2 Nitrophosphate

The term nitrophosphate covers the range of Fertilizers containing nutrients nitrogen
and phosphorous (sometimes along with potassium) obtained from nitric acid
acidulation of rock phosphate. The main raw materials required for the production
of nitrophosphates are nitric acid, rock phosphate and ammonia. A few processes
are available for the production of nitrophosphates. However, the process generally
adopted involves the following steps:

Digestion
crystallization of calcium nitrate
calcium nitrate separation
neutralization of mother liquor

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 calcium nitrate conversion and recycle
evaporation
prilling

Digestion: Ground rock phosphate is digested with 54% HNO3 in reactors, where the
following reaction takes place:

Ca10 (PO4) 6 F2 + 2OHNO3 6H3PO4+10Ca (NO3) 2 + 2HF

Crystallisation: The undesirable calcium nitrate is removed as calcium nitrate

tetrahydrate by cooling the acidulated mass.

Calcium nitrate separation: Calcium nitrate tetrahydrate crystals are separated by

filtration or centrifugation.

Neutralization of mother liquor: The mother liquor is neutralized with ammonia in the
neutralizer. Due to heat of reaction, considerable quantity of water is vaporized
during neutralization.

Calcium nitrate conversion: The separated calcium nitrate crystals are taken to the
reactor and reacted with ammonia and carbon dioxide to form ammonium nitrate
and calcium carbonate (chalk). Chalk is separated by filtration and the mother
liquor after concentration is taken to the neutralizer.

Evaporation: The neutralized mother liquor augmented with ammonium nitrate is

evaporated where the moisture content is reduced to around 0.5 per cent.

Prilling: The nitrophosphate melt from the evaporator is finally prilled in prilling tower.

The production process of nitrophosphate is given in Figure 10.

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4.3.3 NPK Complex Fertilizer

Various grades of NPK complex or mixed Fertilizers may be produced adopting the
similar process route. The common process involves metering of ammonia and
phosphoric acid in required proportions to the pre-neutralizer and transferring the
resulting slurry to the granulator. During granulating nitrogen content of the product
is increased as per the requirement by addition of ammonia and urea as necessary.
Potash and suitable filler are also added to obtain correct product formulation. The
granulator discharge is then dried, screened, cooled and coated with coating
agent to improve the storage properties. The manufacturing process is shown in
Figure 11.

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4.4 Manufacturing process of captive plants

4.4.1 Sulphuric Acid

Sulphuric acid is produced from sulphur. First sulphur dioxide is obtained by burning
of the molten sulphur in presence of air. Sulphur dioxide is then converted to sulphur
trioxide in presence of vanadium pentoxide catalyst. Sulphur trioxide thus obtained
is absorbed in recycling concentrated sulphuric acid in absorption tower. The plants
installed earlier and the smaller units of sulphuric acid plants use single absorption
process, which have conversion efficiency of 96-98 per cent. New sulphuric acid
plant now-a-days utilize double conversion double absorption (DCDA) process.
DCDA process can realize above 99 per cent conversion efficiency. The production
of sulphuric by DCDA process is shown in Figure 12.

4.4.2 Nitric Acid

Nitric acid is produced by oxidation of ammonia. The liquid ammonia is

evaporated, superheated and sent with compressed air to a converter, containing
platinum and rhodium catalyst. In the converter, ammonia is converted into nitric
oxide, which is then converted into nitrogen dioxide in the oxidation vessel with the
help of secondary air. Nitrogen dioxide is absorbed in water to form nitric acid in the
absorption column.

4NH3 + 7O2 4 NO2 + 6 H2O

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4 NO2 + 2H2O + O2 4 HNO3

In the Fertilizer industry normally 53-55 per cent nitric acid is produced. The flow
diagram for nitric acid production is given in Figure 13.

4.4.3 Phosphoric acid

Phosphoric acid is manufactured using rock phosphate. The following steps are
adopted in production of phosphoric acid:

a) Rock phosphate grinding

In the grinding mill the rock phosphate is ground to a level of fine powder.

b) Acidulation

Finely ground rock phosphate and sulphuric acid are mixed in a digester at a
temperature around 70 to 80oC to form phosphoric acid and gypsum.

Ca10 (PO4)6F2 + 10 H2SO4 + 2O H2O 10 CaSO4 2H2O + 6H3PO4 +2HF

c) Separation of gypsum

Gypsum is separated from phosphoric acid by filtration in pan filters.

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d) Washing of gypsum

Gypsum is washed to make it free from phosphoric acid and is disposed as gypsum
slurry into gypsum pond.

e) Concentration of phosphoric acid

Dilute phosphoric acid is recycled to the digester. The concentrated portion of acid
is further concentrated by direct heating using steam in vacuum evaporator. The
concentrated acid thus obtained is of 52-54 per cent P2O5. Figure 14 shows the
manufacturing process of phosphoric acid.

4.5 Utilities & offsite facilities

4.5.1 Raw water

The Fertilizer industry consumes considerable quantity of water in production of

Fertilizers. The main requirements are for:

cooling tower make up

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 feed to the demineralization plant
process and service needs
fire service
sanitary and potable water supply

One of the main factors in selection of site for the Fertilizer factory is the adequate
availability of required quantity of water. Generally raw water is drawn from rivers,
streams, canals, lakes, reservoirs etc. Ground water is also used by many industries.
In some cases, municipalities supply clarified water. So, in most cases sufficient
storage facility in reservoir is provided inside the factory area or adjacent to the
factory to cope with the unexpected shortfall of water due to any reason
whatsoever. The technique of reverse osmosis is adopted in a few industries for
conversion sewage effluent into reasonably good water for use by the industry.

4.5.2 Raw water treatment plant

Raw water treatment plant is installed mainly for clarification of water. In some
cases, partial softening is also carried out in the raw water treatment plant. The
treatment chemicals are usually alum - lime. Some industries also use polyelectrolyte
for clarification purpose. Clarified water is filtered in rapid sand filters before use as
process water. Filtered water is disinfected by chlorination before supply as
sanitary/potable water.

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4.5.3 Demineralization

Dematerialized (DM) water is required particularly for boiler feed purposes. Small
quantity is also required for process.

DM plant consists of cation and anion units followed by mixed bed unit for further
purity. Usually, cation units are regenerated by sulphuric acid. A few industries use
hydrochloric acid also for cation regeneration. The anion exchange units are
regenerated by sodium hydroxide. In some plants, where weak base anion
exchange is also installed, the regeneration is carried out by ammonium hydroxide.
Mixed bed units are generally regenerated by use of sulphuric acid and sodium
hydroxide. In some industries condensate polishing units are provided for removal of
residual impurities and heavy metals present in the condensates.

4.5.4 Steam and power generation

Fertilizer industry consumes considerable quantity of steam for various purposes. To

cater the need of steam, steam generation plants are installed. In general, in the
older industries/small production units, power is made available from the State
Electricity Boards (SEBs). But due to inadequate and irregular power supply from
SEBs, industries now prefer to install power plants as captive power source. These
captive power plants are integral parts of the industries and located in the same
premises

4.5.5 Raw material

Feedstock natural gas is supplied by Gas Authority of India (GAIL) by pipeline at the
factory premises terminal. Feedstock naphtha, fuel oil and other chemicals are
stored in the factory to facilitate regular supply. Coal storage is made for captive
power plants operated using coal. Sulphuric acid plant requires sulphur storage
facility. Phosphoric acid manufacturing units need rock phosphate storage facility.
Sulphur, rock phosphate and potash requirements are generally imported. Some of
the industries use imported ammonia and phosphoric acid for production of
Fertilizers. The commonly used chemicals are chlorine, sulphuric acid, sodium
hydroxide, cooling water conditioning chemicals, boiler water conditioning
chemicals etc.

4.5.6 Storage of the products and bagging facilities

Fertilizers like urea, ammonium sulphate etc. are stored in Silos. Bagging of the
products are carried out in bagging plants. Fertilizer products may directly
transported by conveyor belts to bagging plants or stored in Silos.

4.5.7 Fire Fighting and Safety Measures

All Fertilizer industries provide appropriate fire fighting facilities and carry out mock
drills at regular intervals. Safety department looks after safety aspects during
operation and maintenance of plants.

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4.5.8 Pollution control facilities

Pollution control facilities include pollution control systems incorporated in the main
production plants. Emission control measures for stacks and fugitive emission control
devices are also provided for reduction of air pollution. Further, end of the pipe
wastewater treatment system is provided in effluent treatment plants (ETPs). Most of
the industries, specially the large industries, provide good laboratory and monitoring
facilities, for ascertaining pollution aspects of the environment in and around the
factory.

4.5.9 Disposal of the treated wastewater

Treated wastewater is generally used in the demonstration farm, development of

greenery and green belt around the factory. The excess treated wastewater is
disposed of into adjacent nallas, rivers, sea etc.

5.0 POLLUTION ABATEMENT

5.1 Earlier Scenario

At the earlier stages of Fertilizer production in the country, serious attention was not
given regarding environmental pollution and conservation of resources. General
understanding and consciousness regarding environmental aspects were lacking. In
absence of regulations/guidelines and laws, it was not possible to pressurize the
industries to contain pollution. The designers of Fertilizer plants did not provide
appropriate and adequate pollution control devices and resource consumption
minimizing techniques in the design blue prints, as regulations/laws were absent in
the country. In addition, lack of appropriate technology for incorporation of
minimizing pollution was not within the reach of the designers. Further, requirement
of adequate finance for adoption of modern technology was another bottleneck.
With the backdrop of above scenario, pollution arising from Fertilizer industries
remained unattended and unchecked.

5.2 Availability of modern and advanced technology

As the time past, the situation gradually changed. Environmental pollution/

degradation became a global issue. Public health hazard due to unabated
pollution, made people more and more conscious about preservation of
environment. Consequently, search for minimizing pollution from industry became a
global challenge. In the recent years, considerable advancement took place
towards conservation of resources and reducing pollution emanating from industries
with the implementation of modern developed technologies. Clean technologies
are now available with the designers of plants and may be adopted by the
industries to conserve resources and minimizing pollution of the environment. A few
examples of modern clean technology as available for adoption and incorporation
by the Fertilizer industry are stated below:

Use of arsenic in absorbent solution of carbon dioxide recovery process was

eliminated in most of the ammonia producing Fertilizer plants.

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 Process condensate of ammonia producing plant is used as boiler feed water
after stripping of ammonia present in the condensate and processing in the
polishing unit of DM plant.
Cooling water-conditioning inhibitor based on chromate was replaced by non-
chromate chemicals for conditioning of recirculating cooling water system.
In the urea plant, built-in system - thermal hydrolyser stripper is available for
recovery and reuse of ammonia and urea from process condensate. The
stripper bottom water finds use as boiler feed water after treating in DM plant
Polishing unit.
The modern urea prilling tower use natural draft system which results in significant
reduction in urea dust loss due to emission.
Purge Gas Recovery Unit (PGPU) is also available for reducing ammonia emission
and consequently consumption of feed-stock.
Urea dust scrubbing system in bagging plant reduces urea dust in working area
and scrubber blow down is used in the production process.
The hydrofluoro silicic acid discharged from phosphoric acid plant can be
converted into by-product fluoride compound e.g. Aluminium Fluoride.
Sulphur as by-product is recovered from fuel oil based feedstock for ammonia
production.
Incorporation of DCDA system in sulphuric acid plant increases product sulphuric
acid and reduces oxides of sulphur emission. Now-a-days alkaline scrubbers are
also used for reduction of oxides of sulphur emission during start-up and shut-
down of sulphuric acid plants.
The Pollution Control Boards motivate the industries to adopt the available
modern technologies for reduction of pollution.

5.3 Effluent Treatment Plant (ETP)

Inspite of all efforts with the various types/systems of control of pollution, some
quantity of wastewater is released from plants. In addition, unforeseen wastewaters
are generated during malfunctioning of process plants. All these wastewaters are
treated at the Effluent Treatment Plants (ETPs). Wastewater are segregated based
on characteristics and treated in separate units. ETPs are installed to comply with
regulatory standards. Standards for different category of Fertilizers as specified by
the Gazette Notification of Government of India are given in Annexure IV.
5.4.1 Conservation of water and generation wastewater

The maximum limit of consumption of water and generation wastewater are also
prescribed by Gazette Notification by Government of India (Annexure V).

5.4.2 Charter on Corporate Responsibility for Environmental Protection in Fertilizer

Industry (CREP)

The guidelines incorporated in CREP (Annexure VIII) are also desired to be complied
with by all Fertilizer industries.

5.5 Disposal/reuse of treated wastewater and dispersion of emission

The treated wastewater is stored in holding ponds before disposal or reuse.

Maximum reuse is generally practiced in development of greenery and greenbelt.

24
Some industries use this water as fire service water and washings. After utilizing the
treated wastewater, the balance wastewater, if any, is disposed into the nearby
drain or the adjacent river preferably with a pipeline having diffuser at the terminal
end submerged into water. However, generally location of industries dictates the
method of disposal and also the sink of disposal.

Similarly stack heights are set as stipulated in the standards and heights of prilling
towers are fixed by the designers of plants for dispersion in the air environment.

5.6 Monitoring

The effectiveness and performance of pollution control measures are watched by

monitoring facilities at regular intervals or continuously as required by regulatory
authorities or performance checking by the officials of the industry.

6.0 STEPS IN ENVIRONMENTAL AUDITING

6.1 The activities in environmental auditing are conducted in three main steps:

pre-audit activities (home work)

work at industry site (industry visit)
post audit activities (work at site & home)

6.2 Pre-audit activities

The following functions are carried out in pre-audit activities:

6.2.1 Formation of audit team

The audit team is selected from officials of an organization who have fair knowledge
of Fertilizer industry. The team leader is desired to have adequate expertise in
Fertilizer industry. Knowledgeable industry officials preferably be inducted in the
team.

6.2.2 Preparation of Questionnaire

Format for resume for eliciting information/data from industry are to be developed
for collection of detail information of the industry particularly directed towards
environmental auditing. The response of the industry on the questionnaire is very
useful for environmental auditing.

6.2.3 Visit to the industry

A preliminary visit by one member of the team is helpful to be familiar with the
industry and planning for the audit visit by the full team members.

6.3 Work of Industry Site

6.3.1 The main functions at site are as follows:

25
 discussion with the technical officials
Review of reports, drawings, maps etc.
preparation of check list
end to end survey and auditing
discussion with the officials of the industry based on the observations made
during auditing
Preliminary draft report preparation

6.4 Post-audit activities

6.4.1 The post audit activities comprise of the following functions:

Evaluation & consolidation of data information collected and observed in actual

visit
Identification of short-comings
Finalization of Auditing Report
Presentation of the report submitted to the engaging authorities

7.0 VISIT TO FERTILIZER INDUSTRIES

7.1 Visits undertaken

Studies were carried out by visiting a few representative Fertilizer industries. Selection
of industries were made based on the following aspects:

Products manufactured
Raw material, feedstock, intermediate chemical used for manufacture
Process adopted for manufacture
Use of toxic chemicals like arsenic, chromium which can be totally eliminated
Age of the plant
Water supply source and consumption pattern
Management of wastewater control, treatment, recycle, use and disposal
Modern methods adopted for control and reduction of emission
Problems of plants for complying with the standards - particularly constraints of
small manufacturing units

During visit to the industries, the officials of the industries were associated. The
information and data collected from the industries were very helpful during the visit.
The Fertilizer Association of India (FAI) was also associated during the visit. In few
industries, monitoring of wastewater/emission were conducted by the team
members and assisted by the officials of the industries.

7.2 Findings of the field studies

7.2.1 The observations gathered during the study trips are summarized below and
utilized for the development of Standard Methodology for Environmental
Auditing in Fertilizer Industry:

(i) The preliminary discussion with FAI and the authorities/management of

industries revealed that most of the industries are aware of environmental audit

26
 practices. The management of industries has clear opinion that environmental
auditing provides wide range of information, which are not available to the
management through the routine information as supplied by the Technical
Services Section. But due to various reasons e.g. Non-availability of separate
technical officials who can carry out independently environmental auditing,
financial constraints for appointing outside experts for this purpose, lack of
uniform documented procedure for environment auditing, absence of
statutory provisions etc. do not encourage the management to implement
environmental auditing system on regular basis. In this context, the endeavour
made by CPCB for preparation of standard methodology for environmental
auditing is appreciated by the industries.

(ii) The control of usage of raw materials, chemicals, water etc. are most important
aspects of environmental auditing. This aspect does not find proper
place/understanding in some of the industries. The industries are more
concerned about the compliance of statutory standards as given in the
consent letters. The standards of wastewaters and stack emissions are generally
given in terms of concentration. The environmental auditing quantifies the loss
through pollutants generated and points out conservation aspects.

(iii) Appropriate monitoring facilities are absent in some of the industries. The
fluctuating characteristics both flow and nature of wastes are not revealed due
to absence of frequent monitoring. Laboratory facilities are not adequate to
tackle/assessment of wastes. Shortage of sampling and laboratory staff cause
difficulties.

(iv) The segregation of wastewaters based on characteristics is not practiced in

most of the industries. This helps in easy recovery, reuse by mutual treatment
and treatment of wastewaters.

(v) It is noted that the terms recycle, reuse, zero discharge etc. are often
misinterpreted. The term recycle is repeated use of the same water in the
process e.g. recirculating cooling water system. Similarly the term reuse means
the wastewater is used in some other purpose in some other process facilities
e.g. Condensate are used as boiler feed water, treated wastewaters are used
for chemical solution preparation, scrubbing etc. The treated wastewater used
for irrigation may be defined as water application on soil for agricultural
purpose. The concept of zero discharge may be addressed in-depth. In regard
to soil application, the quantity of treated wastewater must be ascertained
which can be loaded continuously based on the characteristics of soil without
damaging the quality of soil and polluting ground water. Further, during rainy
season the water requirement for irrigation depend upon rainfall. Thus it may
be concluded that nitrogenous Fertilizer production factories cannot have zero
discharge throughout the year until sufficient storage is provided. However,
phosphoric Fertilizer industries may maintain zero discharge with sustained
production, because wastewaters generated may be reused in the process. It
is ascertained that straight nitrogenous Fertilizer production units may require
discharge of excess quantity of treated wastewater to the adjacent water
disposal sink.

27
(vi) It was observed that treated wastewater disposal is not taken seriously by most
of the industries. Treated wastewater disposal is an important function of the
industry. Therefore, organized facility is desired to be provided by the industry
including measurement of flow and also proper sampling facilities. In few
industries more than one outlet is provided for disposal of treated wastewater.

(vii) Another neglected area observed was - the management of storm water
drains. Many industries discharge wastewaters into the storm water drains. This
practice cannot account the wastewaters and thus by-passed out of the
factory in uncontrolled manner.

(viii) Excess raw material or chemicals are also used by many industries. This causes
unnecessary wastage of resources. Excess use of water, is always seen in all
industries.

(ix) It was noted/observed that proper instrument for measurement of flow of

water/wastewater was not installed by the industries. Sample drainage points
are hazardous in many cases. Stacks are also not provided with proper sample
points and facilities for approaching the sampling point for collection of
samples.

(x) Many industries do not have independent cell/department for management of

environmental aspects/ issues. These industries do not have updated
standards/norms/ guidelines as notified by the regulatory authorities.

(xi) Most of the industries are not serious about House Keeping. Some industries do
not have organized greenery and greenbelt development practice.

8.0 CONCLUSION

A short resume and scenario of Fertilizer industry status in the country is exposed in
PART I of this document. This is expected to help the Environmental Audit team in
conducting their assignment. In the light of above information of PART I, the
Standard Methodology for Environmental Auditing in Fertilizer Industry is evolved and
presented in the PART II of this document.

The existing standards in force as specified in Annexure IV and V of this document

are presently under review by CPCB and will be notified after finalisation.

28
PART-II

Environmental Auditing
in Fertilizer Industry –
Standard Methodology
9.0 INTRODUCTION

9.1 Fertilizer Industry

Fertilizer industry is one of the major industries in the country. The industry is uniformly
scattered throughout the country and is very friendly to the nation as it is related to
the enhanced food production needed for the growing population.

Fertilizers are chemical compounds containing concentrated form of major plant

nutrients e.g. Nitrogen, phosphorous and potassium. Fertilizers are generally applied
into soil to enrich soil suitable for agricultural activities. Thus Fertilizers enhance rapid
and uniform growth of agricultural products. It is apparent that controlled
application of chemical Fertilizers in soil play a vital role in achieving sufficient
production of food grains as required in the country. In order to augment Fertilizer
production capacity to match the growing demand of Fertilizers, new Fertilizer plants
are being installed and old plants subjected to expansion and revamp. Inspite of all
these efforts, there still remains a sizable consumption and production gap. This gap
is filled by the imports of Fertilizers. Thus increase in Fertilizer production capacity will
be continued in future also.

9.2 Production of Fertilizer and pollution

The process of production of different types of Fertilizers is described in Section 4.0

(PART I). Fertilizer production is associated with depletion of natural resources
followed by generation of pollutants/wastes and its release to the adjacent
environment of the industry. Increased Fertilizer production means increased
depletion of natural resources and generation of pollutants/wastes, which may
cause degradation of natural environment. Some of the pollutants are hazardous
and toxic in nature. The Central Pollution Control Board (CPCB) has classified
Fertilizer-manufacturing industry as one of the major polluting industry. While
conducting Environmental Auditing, the pollutants can be identified and the actions
ascertainedn to neutralize the adverse effects wastes.

9.3 Pollution abatement

The modern and advanced clean technology for production of Fertilizers conserve
resource and minimize generation of pollutants/wastes. Presently state-of-art clean
production technology is directed towards preventing over-use of raw
materials/feedstock/chemicals and also water/energy. All these features are
suitable for incorporation in coming up new Fertilizer plants. For aged and old plants,
production technology upgradation is essential requirement. The management of
industries is seriously concerned due to possibility of increased cost of production on
updating the technology of production by incorporation of modern technology. On
the other hand, in case production technology is not modernized, it may become
difficult to comply with the standards as specified by the regulatory authorities. To
deal with such a complex situation, it is extremely necessary to carry out a
comprehensive study to recommend to the management the proposed action
plan. In this approach, the end-to-end survey report of Environmental Auditing
Team is very useful component. The feasibility report thus prepared may expose the

29
possibility of pay back on implementation of proposal of modernization of the
manufacturing process.

9.4 Professional Environmental Auditing

Environmental Auditing is a specialized job. It needs sufficient knowledge backed

by wide experience. Professional Environmental Auditing Team carries out the
entrusted assignment easily and firmly identifies the praiseworthy works and
shortcomings or drawbacks in functioning of the industry. In many cases,
performance of pollution control equipment and effluent treatment plant (ETP) are
neglected as these facilities are considered secondary functions in relation to
process plant machineries. In some other cases, equipments meant for specific
pollution control purpose remains idle and ultimately become scrap material. The
grey areas of the industry are magnified before the management of the industries
by independent work of the environmental audit team. Therefore, Environmental
Auditing by professional team is a dependable instrument of management for
protection and improving the quality of environment, which in turn point out the
bright image of the industry. The technical officials of the management of the
industry may also conduct Environmental Auditing provided they get full
cooperation and access to necessary areas and get an independent status for
directly reporting to Head of the Management. Whoever is assigned to the work of
Environmental Auditing, it should be done at regular interval preferably at least once
in a year.

10.0 STANDARD METHODOLOGY

10.1 Evolving standard methodology

In evolving the standard methodology for conducting Environmental Auditing in

Fertilizer Industry, the following activities were carried out:

For understanding the industry, discussions with the officials of Fertilizer Association
of India (FAI) were made.
Literature survey on Environmental Auditing was done.
In-depth study of a few representative Fertilizer industries were conducted out by
visited to gain practical experience.
Finally, wide and long experiences were utilized in evolving and preparation of
this document.

10.2 Pathway of Environmental Auditing

Three major steps are followed in Environmental Auditing

Pre-audit home activities

Activity at industry site
Post-audit home activities

The above activities are detailed out for easy understanding in Figure 15.

30
10.2.1 Pre-audit home activities

The main purpose of pre-audit activities is to be familiar with the industry where
Environmental Auditing is proposed to be carried out. In this short period, it is desired
to collect as many information as possible on the industry. In other words,
mobilization for ensuing activities on Environmental Auditing must be made. The
work may be summarized as under:

31
(1) Selection of Team Leader

The team leader should be dynamic person having wide knowledge and
experience on the Fertilizer industry. The main duty of the team leader is to pilot the
team, coordinate with the officials of industry and encourage the team to work
systematically.

(2) Collection of basic information

Industries are generally member of Fertilizer Association of India (FAI). FAI is the
storehouse of various information on Fertilizer industry. The team leader should
interact with the officials of FAI and collect the basic information necessary for
conducting Environmental Auditing and record the information for future use. FAI
has a good library which may be utilized by the team leader and the officials of the
team.

(3) Selection of Auditing Team

It is desired to have only three to four devoted, energetic technical professionals for
auditing in the industry. One or two knowledgeable officials from the industry may
be co-opted in the team for easy collection of information from different
sections/departments of the industry. Secretarial assistance also required in team for
maintaining records and typing etc. The requirements of Environmental Audit team
are summarized below:

The team members should have sufficient knowledge and experience on

Environmental Auditing
Exposure to Fertilizer industry, manufacturing process of Fertilizers, pollution
abatement systems etc. are of advantage for the team members. In this
connection, books published by FAI are very useful e.g.

o Fertilizer Production Technology

o Fertilizer statistics

The team should be familiar with the guidelines, regulatory measures, standards
of wastes/noise/ambient air as published by CPCB, MoEF, State Pollution Control
Board etc. In addition, for the specific industry proposed to be audited, the
team should collect the following information:

o Stipulations made during clearing the project (industry)

o Consent conditions on wastewater, stack emissions
o ambient air, noise, hazardous wastes etc.
o Status of compliance of the stipulations/standards
o Local problems, if any.

(4) Questionnaire preparation

To get elicit information from the industry where Environmental Auditing is proposed,
a detailed questionnaire is to be prepared and sent. The questionnaire should
contain all aspects related to process and environment. The industry may be

32
requested to provide additional information beyond the questionnaire in case such
information is concerned to environment/control of pollution/resource conservation
etc. The models of format for Resume/Questionnaire prepared for nitrogenous &
complex Fertilizer and SSP plants are given in Annexure VII & VIII respectively. The
Format for Resume may be changed or modified based on the local status of the
industry.

(5) Dialog with Industry

It is necessary to have initial discussion with the industry. This may be done by
preliminary visit to the industry or by use of electronic media. This will result in good
understanding between the two parties - industry officials and the environmental
auditing team officials. The joint efforts with mutual understanding, the entrusted
work can be carried out with full cooperation and completed with satisfaction of
both parties.

(6) Mobilization

The Environmental Auditing Team should be equipped with all requirements. Many
industries are having modern laboratory and facilities for monitoring of water, air,
solid wastes and noise. The industries, which do not have such facilities, the Audit
Team may have to carry such equipment, which are necessary. The requirement
may be listed after initial discussion with the industry. Apart from technical
requirement, financial needs may be assessed and made available to the Auditing
Team.

(7) Plan for visit

Itinerary for the visit to the industry may be made after discussion with the industry
officials. It is important that the plants under the industry should be normally
operating at full capacity and the concerned officials of the industry connected
with Environmental Auditing are available for assisting Audit Team. Appropriate
lodging & food arrangements and transport facilities as required for the Audit Team
should be made available for smooth working.

(8) Literature Survey

The literature survey on Fertilizer industry is expected to start from the very beginning,
soon after the work has been undertaken. Further, study should be intensified based
on specific industry to be audited. The filled in Format for Resume is expected to be
available by this time. The information provided in filled in Format for Resume, should
be examined/studied in depth with reference to the available literature. Any
additional information necessary should be listed and intimated to the industry for
mailing to the Audit Team.

(9) Start for visit

The sincere and hard homework is the basic requirement for conducting
Environmental Auditing. Therefore, pre-audit homework is given importance. After
satisfactory completing pre-audit home activities, the Audit Team may move for

33
visiting the industry. The Team should carry all the necessary implements required for
Environmental Auditing.

10.2.2 Activities at Site

(10) Discussion with industry officials

After settling down at the industry site, first the officials of the industry responsible for
different section/department are introduced to the Audit Team members.
Discussions with the co-opted members from the industry are later made and
explained about the procedure to be adopted for conducting audit.

(11) Exposition by industry

The industry officials organize a meeting to render a presentation on varioua aspects

including process, operation and performance of the industry. During deliberations,
in these technical meeting lots of information/data are revealed which are not
available otherwise. The spirit of discussions should be friendly and should move in
the positive direction to carry out Auditing.

(12) Map, drawing, records etc.

The maps are very useful to ascertain the location of the industry and its adjacent
areas. Lay out drawings provide the internal location of plants, storm water drains,
wastewater transport, treatment, disposal facilities, stacks & ambient air monitoring
stations etc. Typical features in a factory are depicted in Figure 1. Records reveal
the performance of the industry. These are back-up information required for the
audit Team.

(13) Check List

Checklist is a concise of items/facilities to be inspected by the Audit Team. The main

purpose of checklist is to ensure that no aspect particularly related to environment is
missed during conducting environmental auditing. The checklist is prepared with the
technical assistance of the officials of the industry. During study/inspection,
additional items/areas may come out which are not included in the checklist earlier.
The checklist thus prepared may have the following main sections:

Supply and storage of raw materials, feedstock, chemicals etc.

Process plants operation

o Built-in pollution control measures

o Sources of generation of wastewater
o Consumption of water
o Generation stack vents/emissions
o Solid waste generation & management practice
o Consumption pattern of chemicals, raw material/feedstock etc.
o Noise generation & attenuation

Captive Plants

34
 o Similar approach as that of process plants may be adopted

Utilities

o Water supply, treatment, consumption etc.

o Wastewater treatment, storage, recycle, use, disposal etc.
o Storm water drainage, control system etc.
o Finished and intermediate product storage
o Bagging of products and transportation
o Fire, safety and health aspects
o Recovery of by-product

A model check list for straight nitrogenous Fertilizer plant producing urea using
natural gas/naphtha as feedstock and adopting steam reformation process
(ammonia plant) is presented in Annexure VII.

Similar check list may be prepared for the industry where Environmental Auditing is
planned to be conducted. It may be noted that check list is the driving force in
Environmental Auditing and advantage of check list should be taken fully while
Environmental Auditing is done.

(14) Material Balance

Establishment of material balance of substances used in the industry is major work in

Environmental Auditing. The raw material and chemical consumption pattern and
the mass balance of water and wastewater, are very important functions for
ascertaining the performance of the industry.

(a) Raw material/feedstock/intermediate material

Chemicals are used for manufacture of products/intermediate chemicals. In the

manufacturing technology various reactions necessary for industrial production do
not follow the stoichiometric principle. Based on design parameters requirements of
reactant chemicals are generally more than the theoretical values.

The norms of raw material/chemical consumption for manufacture of Fertilizer

intermediate chemical and also by the captive plants located at the same premises
of the industry are given in Table 3. Similarly, norms of chemicals/raw material
consumption for manufacture of different kinds of Fertilizers are presented in Table 4.

Table 3: Norms of raw material/chemical consumption for manufacture

of Fertilizer intermediate chemicals
Intermediate Raw material MT per MT except
Natural gas
Ammonia (NH 3 ) Nat ural Gas 860 Nm 3
Sulphuric Acid (H 2 SO 4 ) Su lphu r 0.34
Phosphoric Acid (H 3 PO 4 ) Rock (33% P 2 O 5 ) 3.3
as P 2 O 5
Nitric Acid (HNO 3 ) NH 3 0.285

35
The above norms as presented in Tables 3 and 4 may be compared with the actual
data found during Environmental Auditing activities at the industry site. The variations
may be recorded and the reasons for such deviations may be discussed with the
concerned officials of the industry. The excess of material use than the norms may
be termed as resource-waste. Methods of prevention of such loss may be tentatively
evolved and recommended after discussion with the technical officials of the
industry. This over-use may be exposed in terms of money-loss.

(b) Mass balance of water and wastewater

The working out and establishing mass balance of water consumption by industry is
very important for environmental auditing and assessment. It is a prime tool to
ascertain whether the industry drawing reasonable quantity of water from the
natural resources for various activities conducted by the industry. When the mass
balance of water is correctly established, it reveals the areas where water is misused
by consuming excess quantity of water. The mass balance of water points out the
facilities where the use of fresh water may be avoided or reduced substantially or
saved by the path of recycle/reuse/recovery. The leakage of water due to storage
in reservoirs and transportation may also be identified and accounted.

To prepare mass balance of water, it is essential to know the water circuit of the
industry. The flow pattern of water and wastewater of the factory is to be drawn on
a sheet of paper. The flow of water in different units/facilities obtained from flow
meters is to be incorporated in the diagram. Therefore, flow meters are essential in
the water circuit. The processing of raw water, its consumption in different facilities
and generation of wastewater are discussed below:

Raw water supply and storage: Raw water drawn from river, lake or ground
water sources is generally stored for a few days in water reservoir inside the
factory premises. Loss of water occurs due to
o leakage in reservoir
o evaporation and
o transportation leakage

Raw water pre-treatment: Raw water is rendered pretreatment for clarification

and sometimes for partial softening. Loss of water takes place due to
o water present in clarifier sludge
o filter back water

Filtered water storage: Filtered water is generally stored in concrete or steel tanks
for a few hours for requirement in the industry. Supply of clarified water from this
tank is made for the following purposes:

o Cooling tower make-up

o Once-through cooling in plants
o Process/service
o DM plant make-up
o Fire services
o Sanitary/drinking

36
Table 4: Norms of Intermediate Chemicals/Raw Material
consumption for production of Fertilizer product (MT per
MT)

S. Fe rti l i ze r NH 3 CO2 Rock H 2 SO 4 H 3 PO 4 HNO 3 KC l Gyps um

N o. P ro d u c t Pho sphate as 60%
P2O5 K2O
1. A m m o nium
Sul p hat e
- From 0.26 - - 0.7 5 - - - -
H 2 SO 4
rout e
- From 0.27 0.3 8 - - - - - 1.80
gy psum
rout e
2. C AN (25 % 0.16 - - - - 0.59 - -
N)
3. Urea 0.57 0.7 4 - - - - - -
4. SSP - 0 .63 0.38 - - - -
33 % P 2 O 5
5. UAP (2 8- 0.36 - - - 0 .29 - - -
2 8- 0)
6. D AP
- from 0.23 - - - 0 .47 - - -
phosphoric
ac id
- from 0.23 - 1.5 1.30 - - -
p h osp h a t e 33 % P 2 O 5
rock
7. N KP (14- 0.18 - - - 0 .38 - 0.25 -
3 5-14)
8. N KP (17- 0.22 - - - 0 .18 - 0.30 -
1 7-17)
9. N KP (19- 0.24 - - - 0 .20 - 0.38 -
1 9-19)
1 0. N KP (12- 0.15 - - - 0 .34 - 0.28 -
3 2-16)
1 1. N it r o 0.10 - - - 0 .16 0.3 1 0.26 -
p h osp h a t e
(15-15-15)

Cooling Tower make-up: Cooling towers consume significant quantity of

water as cooling is affected by evaporative cooling. In cooling towers loss of
water is due to

o Evaporation
o Windage loss
o Blow down (continuous or intermittent)
o Bottom sludge disposal
o Side stream filter back wash

37
Except evaporation and windage losses, all other losses cause generation of
wastewater.

Once- through cooling water : Some industries do not use cooling towers or
by-pass the cooling tower and use water for direct cooling of equipment and
then discharge as wastewater stream. In this system, consumption of water is
very high. This once- through cooling system should be avoided.

Process/Service water: In some operations, water is consumed in the process

and water does not find its way out in the wastewater stream. On the other
hand, service water is used in the process for various purposes which includes:

o Washing
o Cleaning
o Cooling of sample points
o Suppression of dust etc.

The water thus used is discharged as wastewater.

DM Plant make up water: Water demineralization plant or water softening

plant by Ion-exchange processes is an utility requirement specially for boiler
feed water or some chemical processes. Water loss from these facilities is due
to regeneration of ion-exchange material by use of chemicals. The washings
are highly alkaline and highly acidic in nature.

Fire Service water: Fire service water is always required even if no occurrence
of fire in the industry. Consumption of water are for the following reasons:
o Maintenance of fire hydrants to supply water always at a predetermined
pressure

Sanitary/drinking water: Water of potable quality is used in the factory for

drinking and sanitary purposes. The wastewaters discharged are subjected to
treatment in Sewage Treatment Plant (STP).

In cases the industries have residential colony adjacent to the factory, water is
also supplied the colony. Sometimes water is supplied to the adjacent villages as
social responsibility of the industry.

Wastewater Generation: Wastewater generation takes place from the

process plants, captive plants and utilities. Wastewaters are generally
segregated according to their characteristics sometimes built-in wastewater
treatment system, discharges very good quality of water. The water thus
produced is reused in the plants. Sometime, two or three wastewater streams
are mutually treated based on their characteristics. In any case, it is generally
required to treat wastewaters to meet regulatory standards in an Effluent
Treatment Plant (ETP) located at the terminal end of the factory. The treated
wastewaters are generally stored in Holding Ponds of appropriate size. The
treated wastewater from Holding Ponds is reused in the plants if practicable
or utilized as irrigation water for development of greenery and green belt
around the industry or used in the demonstration farms etc.

38
 Disposal of Treated Wastewater: Though industries recycle and reuse treated
wastewater for various purposes, even then generally a surplus quantity of
treated wastewater remains particularly in nitrogenous Fertilizer plants or in
case of rainy days when treated wastewater cannot be utilized for irrigation
purposes. The excess treated wastewater, which cannot find utilization, is
disposed of into adjacent river or nallah/drain or sea.

Conclusion: The quantity of water used for various purposes in the industrial
activities and wastewaters generated should be collected and tabulated for
purpose of development mass balance diagram. In estimating and assessing
the quantity of water and wastewater, provision of suitable measuring
instruments at the appropriate locations are extremely necessary and should
be pointed out in the Environmental Auditing Report. Total quantity of water
used by the industry and total quantity of wastewater generation by industrial
activities are very useful data both for the industry and regulatory authorities.
To prepare reasonably correct water balance, it is also essential to ascertain
water loss due to evoporation and the moisture present in products and
waste products.

The regulatory limits for water usage and wastewater generation by the industry
for production of different types of Fertilizer is presented in Annexure V. A model
diagram of water-wastewater balance is provided in Figure 16 to facilitate easy
understanding of Environmental Auditing Team.

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(15) End- to-end Field Survey

The entire facilities present inside the factory premises are to be divided into
several parts/divisions to facilitate examination of items indicated in the check
list. While visiting the various parts of the industry the team should make keen
observation to cover the additional items, which were not included in the check
list earlier prepared. The data collected and the observations made are to be
recorded at the visiting spot. It may be necessary to discuss with the
participating industry officials for clarification of various issues/aspects arising out
during inspection activity. Special attention should be given towards wastage of
raw material, chemical, water, product etc.

(16) Waste generation point sources

Waste generation sources are generally spread over the factory premises. These
are stack emissions, wastewaters and solid wastes generation points. Some of the
wastes are continuously generated having irregular flow pattern.

The composition of wastes generally vary widely. There are also intermittent
wastes generation sources depending on the operation of plants. Non-point
source generation of wastes has also to be assessed with identification of
parameters. These fugitive sources may cause serious pollution. The wastewaters
are to be segregated based on characteristics and routed separately to
facilitate reuse or specific treatment. The facilities available for measuring the
flow and monitoring the characteristics should be checked.

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Ambient air monitoring facilities at the boundary limit of the industry should also
be examined. All the above information should be recorded on the spot during
survey. It will be wise to prepare proforma/data sheets for filling up data and
information observed/collected.

(17) Performance of Treatment of Wastes

It was experienced that waste treatment systems were installed but the
treatment units are not operated due to various reasons. Further, many treatment
units were not rendering satisfactory service/performance. During environmental
auditing all such situations are to be addressed in the report. If possible some
performance study may be conducted by the industry in presence of the audit
team.

(18) Compliance of Statutory Regulations

The standard of wastes for compliance by the industry, are given in the consent
letter issued by the regulatory authorities. It is necessary to check the status of
compliance of various conditions laid down in the consent letter. The audit team
may carry out monitoring with the help of the industry officials to verify all the
compliance conditions.

(19) Preparation of draft report at site

The preliminary draft report is prepared at site to facilitate

checking/review/validation of the data/information as collected during audit
inspection. This may be done jointly with the concerned officials of the industry.
The missing data/information are collected for including in the draft report and
the misleading data/information are corrected/modified. This preliminary draft
report will be the base material for the final report of auditing.

(20) Preliminary Exposition of Findings

It is desired to render exposition of the findings of the environment auditing to the

senior officials of the industry present at the site for their appraisal and comments.
The observations of the senior officials will be considered with care before
preparing the draft final report.

10.2.3 Post Audit Home Activities

(21) After completing the work at site, the audit team will return and prepare
the final draft report of Environmental Audit. The draft report should be
systematic and write up should have appropriate supporting
data/information.

(22) Identification of short-comings

The draft final report will facilitate to find out the short-comings/drawbacks
regarding the performance of the industry in the environment front. The wastage
of the resources by the industry should be pointed out and if possible financial
loss may be interpreted and focused before the industry officials.

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(23) Evolving the recommendation

To attain the environmentally sound industry, whatever is necessary may form the
recommendation chapter. The recommendations should be based on the
environment auditing carried out by the team. Vague recommendations are to
be avoided. The practical implementation aspect has also to be kept in mind
while evolving the recommendations. While recommendation is made, the pay
back aspect, if any, should be highlighted.

(24) Action plan and time frame for execution

A general idea about the action plan and execution of work may be included in
the report. The industry should prepare feasibility report based on the action plan
and implementation aspect as submitted in the final draft report.

(25) Exposition before corporate officials of management

The final draft report as prepared by the Audit Team should be presented before
the corporate management officials for their appraisal and comments. There
may be full deliberations on various issues arising out of the report.

(26) Managements reactions

The management of the industry put into commission environmental auditing of

the industry. Therefore, the report of the environment audit team need to be
scrutinized and examined in detail by the management for addressing all the
issues reported in the scope of the work. Further, the recommendations made
are to be examined for viability of implementation by the industry. The reaction
of the management on the report is very important and should be considered by
the Audit Team. The final report may be modified in the light of
observations/comments made by the management.

(27) Periodic follow-up based on time frame

It is the responsibility of the management to honour the recommendations of the

Audit Report as the work was done at the instance of the management. It is
desirable that the management should constitute a in-house team to follow up
the implementation programme.

11.0 CONCLUSION

The Standard Methodology for Environmental Auditing in Fertilizer Industry is

elaborated and step-by-step work procedure is provided for easy execution of
audit performance. The checkpoints are vital for working. It is necessary that the
industry should note these points and at regular interval, inspection of these
locations may be made as a routine work. The Environmental Auditing will help
the industry in many ways if the recommendations are implemented with
devotion. It is desired that Environmental Auditing should be conducted every
year for updating the data/information.

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