pre -feasibility report for laying of atf pipeline...

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Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd. PREFEASIBILITYREPORT 1 Pre-Feasibility Report For Laying of ATF Pipeline between Lucknow Marketing Terminal and Aviation Fuel Station AFS at Lucknow Airport By M/s Indian Oil Corporation Ltd. ENVIRONMENT CONSULTANT VARDAN ENVIRONET (QCI/NABET ACCREDITED NO. NABET/EIA/1619/RA0037) D-142, SEC. 57, SUSHANT LOK 3, GURGAON (HARYANA) E-MAIL: [email protected] CONTACT: 0124-4291036, 09899651342

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Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

PREFEASIBILITYREPORT

1

Pre-Feasibility Report

For

Laying of ATF Pipeline between Lucknow

Marketing Terminal and Aviation Fuel Station

AFS at Lucknow Airport

By

M/s Indian Oil Corporation Ltd.

ENVIRONMENT CONSULTANT VARDAN ENVIRONET

(QCI/NABET ACCREDITED NO. NABET/EIA/1619/RA0037)

D-142, SEC. 57, SUSHANT LOK 3, GURGAON (HARYANA)

E-MAIL: [email protected] CONTACT: 0124-4291036, 09899651342

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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1. EXECUTIVE SUMMARY

PREFACE

Marketing Terminal at Amausi, Lucknow (UP) (the Terminal) was commissioned in 2002,

which is about 6.6 km from Aviation Fuel Station at Chaudhary Charan Singh International

Airport, Lucknow (the AFS).

Currently ATF input to the Terminal is through Rail from various refineries and ATF supply to

the AFS is being done through Tank Trucks (TT) from the Terminal. About 15 TTs/ day of ATF

are presently being loaded from the Terminal.

2. IDENTIFICATION OF PROJECT AND PROJECT PROPONENT

(i) PROJECT PROPOSAL

M/sIndian Oil Corporation Ltd. is proposing to Laying of dedicated ATF Pipeline between

Lucknow Marketing Terminal and Aviation Fuel Station AFS at Lucknow Airport.

PROJECT PROPONENT

Name - Mr. Vivek Manjeet

Designation: - Assistant Manager (PJ)

Registered Address: -

Marketing Depot, Baitalpur,Gorakhpur-Deoria

Ph. 9601566433

E-mail – [email protected]

ii. NATURE OF THE PROJECT

The project is for Laying of dedicated ATF Pipeline between Lucknow Marketing Terminal and

Aviation Fuel Station AFS at Lucknow Airport.

The project falls under 6(a) Oil & gas transportation pipe line (crude and refinery/

petrochemical as per the EIA Notification, 2006

iii. NEED FOR THE PROJECT AND JUSTIFICATION

Due to increasing demand of ATF at the AFS, a need was felt for having a pipeline between

the Terminal and the AFS.

Laying dedicated ATF pipeline between the Terminal and the AFS with following

justification:

a) Lucknow Airport being a major international Airport in U.P, it is expected that its ATF

requirement would increase substantially.

b) It is understood that Airport Authority of India (AAI) is proposing to develop/ revamp

the facilities at Lucknow Airport to meet increasing aircraft movements. It has also

been advised that AAI may develop fuel tank farm at Lucknow on open access basis. Hence

having pipeline connectivity would provide a strategic edge to IOC in positioning of ATF at

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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Lucknow Airport in long term and would also help IOC garner increased ATF volumes.

The proposed pipeline would be designed such that it would be feasible to provide

connectivity to future tank farm.

c) Pipeline transport is a much safer operation compared to road transportation./ The

manpower presently engaged for TT loading and unloading could be re-deployed for

other works, thereby resulting in further savings. This would help in achieving improvement

in operations.

iv. DEMAND SUPPLY GAP

On query by PAG, Division has confirmed IOC's estimated future requirement of ATF for the

AFS based on Marketing HO(AVN) as under:

Year TKUyr TKUmonth Yearwise volumegrowth(%)

2016-17(Actual) 78.9 6.6 11.5

2017-18(Actual) 88.0 7.3 10.0

2018-19(Estimated) 96.8 8.1 10.0

2019-20(Estimated) 106.5 8.9 10.0

2025-26(Estimated) 188.6 15.7 10.0

2030-31(Estimated) 303.8 25.3 10.0

2035-36(Estimated) 489.3 40.8 10.0

v. EMPLOYMENT GENERATION (DIRECT AND INDIRECT) DUE TO THE PROJECT

The proposed project will generate direct employment at local level due to laying of ATF

Pipeline. The downtown activity of maintenance of uninterrupted ATF Supply will generate

continues employment.

Sl. No During Construction Phase During Operation

1. Direct-40 Indirect-0

Direct-10 Indirect-10

Total 40 20

3. PROJECT DESCRIPTION

i. TYPE OF THE PROJECT INCLUDING INTERLINKED AND INTERDEPENDENT PROJECTS, IF

ANY

The Project involves Laying of dedicated ATF Pipeline between Lucknow marketing Terminal

and Aviation Fuel Station (AFS) at Lucknow Airport. There is no interlinked project or

interdependent project.

ii. LOCATION - PIPELINE ROUTE

The Pipeline would originate from the terminal and after traversing a length of 0.6 km, the

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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pipeline route would take eastern direction and would follow an independent route

through cultivated lands for about 1.7 km till Canal with adjoining road (Canal road).

Beyond Canal road, the route would traverse for about 1.3 km mainly through Government

lands and enters the Airport boundary after crossing the Lucknow-Kanpur NH-25 road.

Upon reaching the AFS boundary wall (inside the Airport), the pipeline would traverse along

the Airport boundary wall for about 2.5 km to reach the delivery point.

The terrain is predominantly flat and there are no major undulations in the proposed

route. The pipeline traverses mostly through agricultural land, Government land, National

Highway Authority of India (NHAI) corridor and AAI corridor. There is no reserve forest or

social forestry along the route. The entire pipeline route falls in Lucknow District(Starting at

village-Amausi and end in village-Chilawan. Route map and key plan of 10 km study area of

the proposed pipeline is given in Figure 1 and 2.

Sr. No.

Description Chainage (m) Length

(m) From To

1 WITHIN PREMISES OF IOCL AMOUSI DEPOT 0.00 103.44 103.44

2 WITHIN PREMISES OF IOCL BOTTLING PLANT & ALONG PAVER BLOCK ROAD

103.44 570.34 466.90

3 ACROSS ASPHALT ROAD (BEHTWA - HINDU KHERA) 570.34 586.88 16.54

4 CROSS COUNTRY 586.88 2603.75 2016.87

5 ACROSS ASPHALT ROAD (TO MAHANAGAR PALIKA NIGAM) 2603.75 2611.73 7.98

6 ALONG WBM ROAD (TO NH-25) 2611.73 3582.08 970.35

7 ACROSS NH-25 (KANPUR-LUCKCOW) 3582.08 3621.08 39.00

8 WITHIN PREMISES OF AFS LUCKNOW AIRPORT 3621.08 5987.87 2366.79

Total Length(m) 5987.87

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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Figure 1: Route Map

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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iii. Details of alternative site considered and the basis of selecting the proposed site,

particularly the environmental consideration gone into should be highlighted

Alternate routes are examined and finalized the present route based on least disturbance to

the environment, human habitations, forest, and aquatic body and avoid sanctuary,

archeological monuments and other sensitive locations. The route is optimized and finalized

considering the above factors and connectivity between supply and demand point.

iv. SIZE OR MAGNITUDE OF OPERATION

Laying of 8.625" OD x 0.25" WT, API 5L- X 46 grade pipeline for about 6.6 km from Lucknow

marketing Terminal to the Aviation Fuel Station (AFS) at Lucknow Airport

v. PROJECT DESCRIPTION WITH PROCESS DETAILS

Project Description

The laying of the proposed pipeline system would broadly involve following activities:

a) Installation of 2 (1 running + 1 standby) motor driven Mainline Pumping Units (MLPUs) at

the Terminal.

b) Laying of 8.625" OD x 0.25" WT, API 5L- X 46 grade pipeline for about 6.6 km from the

Terminal to the AFS.

c) Installation of delivery facilities at the AFS.

d) OFC based network which would enable pipeline SCADA to be connected to both ends i.e.

the Terminal and the AFS.

e) Cathodic protection system.

f) Modifications would be carried out at both pumping and delivery ends in the existing

facilities for Control Room, Motor Control Centre (MCC), etc.

g) No new tank has been envisaged at IOC Amausi Terminal and AFS at Lucknow Airport.

The present ATF tankages at the Terminal are 2 x 3600 KL. Further to meet the increasing

requirements of ATF, 1 x 1800 KL SKO tank (out of 3 x 1800 KL SKO tanks) is being reallocated

for ATF service. Another 1 x 1800 KL SKO tank would also be converted to ATF service in

future, if required.

IOC has 4 x 200 KL ATF tanks in the AFS. Space is not available at the / existing location for

development of additional tankages; hence the pipeline has been designed to operate at a

flow rate of 70 KL/hr.

The pipeline would be operating at 70 KL hr for 8 hours/ day (single shift) in Phase-1, i.e., till a

volume requirement of 0.15 MMTPA is achieved. Beyond that, it would operate at 100 KL

hour for 8 hours/ day (single shift) in Phase-2 till a volume requirement of 0.21 MMTPA is

achieved (by 2030-31). It would be feasible to receive product in the ATF tanks of the AFS at

100 KL/hr. To achieve volume beyond 0.21 MMTPA in subsequent years, the Pipeline would

be operated beyond single shift. No additional CAPEX would be required for achieving the

increase capacity.

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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Project Plan

To accommodate proposed pipeline pumping facilities, available plot measuring

80 m x 80 m has been identified inside the Terminal.

For housing pipeline receipt facilities, a stretch of 45 m x 14 m inside existing IOC's facilities at

the AFS has been identified. After taking in to account of inter­ distance requirement as per

OISD 141 of 16m from boundary wall, the available space for housing pipeline facilities would

be only 13 m x 14 m. In order to use the available space effectively and accommodate all the

station piping facilities, certain modification such as deepening of fire water pond etc, needs

to be done. Further for housing electrical and T&l equipments, it is proposed to either

construct a new building in place of existing record room and parking shed or utilizing existing

office building for housing the equipments and building a new administration building in place

of record room and parking shed. This would be decided suitably during the execution.

vi. RAW MATERIAL REQUIREMENT

ATF Supply To The Terminal Through Pipeline

The Terminal is connected to Gawaria-Lucknow branch pipeline of Barauni-Kanpur

Pipeline (BKPL). However currently only MS, SKO and HSD is delivered to the Terminal through

BKPL.

Investment proposal for extension of Mathura - Tundla Pipeline (MTPL) to Gawaria T-

point has been already approved by the Board in Mar'2018 which envisages re-alignment of

product sourcing of Kanpur & Lucknow with Mathura Refinery (MR) in place of current supply

ex Barauni Refinery (BR) with future connectivity as indicated below.

Upon commissioning of the MTPL extension pipeline (expected project completion by

Sep'2021), MR products including ATF would be pumped to the Terminal.

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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vii. RESOURCE OPTIMIZATION/RECYCLING AND REUSE OF PROJECT

Not applicable

viii. Availability of water, Energy/Power Requirement and its sources

Availability of water- Temporary water requirement will only be during construction phase

water will be taken through Tankers

Energy/Power- source of power required for running Pumps, SCADA and Cathodic Protection

will be from State Electricity Board(In normal times) and in house Diesel Generator(during

Emergency situation).

ix. Quantity of wastes to be generated (liquid and solid) and scheme for their

management/disposal

During construction phase vary marginal quantity of Solid waste from Temporary Camp site

and commercial waste during cutting and electrofusion, welding of pipeline will be generated

which will be disposed of as per standard available practice and guideline. Soil Restoration

(Top soil) will be stored separately and managed.

During Operation sludge waste generated during pigging will be given to SPCB Approved

Vendors

Domestic Effluent generated during construction phase will be managed through mobile

toilets. No waste water will be generated from the proposed Laying of Pipeline as it is only

concerned with Transportation.

x. Schematic Representation of the feasibility drawing which give information of EIA

Purpose

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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4. SITE ANALYSIS

i. CONNECTIVITY

The Terminal is connected to Gawaria-Lucknow branch pipeline of Barauni-Kanpur

Pipeline (BKPL). However currently only MS, SKO and HSD is delivered to the Terminal through

BKPL. The proposed pipeline is about 6.6 km from Lucknow marketing Terminal to the

Aviation Fuel Station (AFS) at Lucknow Airport.

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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ii. LAND FORM, LAND USE AND LAND OWNERSHIP

(A) Total Length (Km.)

State wise Length (Km.)

(a) Uttar Pradesh 05+987.87

#Revenue Details for the section

(a) State 1

(b) District 1

(c) Vikas Khand 1

(d) Village 6

(B) Terrain (km.)

(a) Plain 05+987.87

(b) Slightly Undulating -

(c) Hilly -

(C) Soil Encountered (km.)

(a) Clayey silt 05+987.87

(D) Surface Features (kms.)

(a) Within Premises of IOCL Amousi Depot 00+103.44

(b) Within Premises of IOCL Bottling Plant 00+466.90

(c) Within Premises of AFS Lucknow Airport 02+366.79

(d) Within RoW of Other Raods 00+970.35

(e) Across Various Crossings 00+063.52

(f) Cross Country 02+016.87

(E) Road Crossing (Nos.)

(a) National Highway 1

(b) Other Roads 17

(c) Cart Track 1

(d) Footpath 2

(F) Water Bodies (Nos.)

(a) Major Canal/Channels 2

(b) Rivers -

(c) Major Drain/Nala/Creek -

iii. TOPOGRAPHY (MAP)

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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iv. EXISTING LAND USE PATTERN

Not Applicable as the proposed project is for new pipeline

v. EXISTING INFRASTRUCTURE

Not Applicable as the proposed project is for new pipeline

vi. SOIL CLASSIFICATION

Sl. No.

State Chainage(km) Total Length

(km) Description

From To

1 Uttar Pradesh 00+00.00 10+541.40 10+541.40 Clayey silt

TOTAL LENGTH(km) 10+541.40

vii. CLIMATIC DATA

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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The climate here is mild, and generally warm and temperate. In winter, there is much less rainfall than in summer. The average annual temperature in Lucknow is 25.7 °C. Precipitation here averages 1001 mm. Precipitation is the lowest in November, with an average of 2 mm. Most precipitation falls in August, with an average of 305 mm. At an average temperature of 33.8 °C, May is the hottest month of the year. In January, the average temperature is 16.0 °C. It is the lowest average temperature of the whole year. Between the driest and wettest months, the difference in precipitation is 303 mm. The average temperatures vary during the year by 17.8 °C.

viii. SOCIAL INFRASTRUCTURE AVAILABLE

Sl. No.

Chainage (m)

Distance of Dwellings from Centre line of Pipeline in (m)

No. of Dwellings

Total No. of

dwelling units

in 1600 mtr

Class Remarks

Distance Left

Distance Right

1 0 0.00 1 39 III IOCL AMOUSI DEPOT

2 564 21.94 1 IOCL LPG Bottling Plant

3 720 53.62 1 HOUSE

4 723 75.58 1 HOUSE

5 742 65.98 1 HOUSE

6 1011 17.82 6 HOUSES

7 1032 47.33 1 HOUSE

8 1049 13.70 1 Grave

9 1055 89.62 1 The Akshaya Patra Foundation Lucknow

10 1075 60.71 1 HOUSE

11 1090 89.63 1 HOUSE

12 1135 61.38 1 HOUSE

13 1156 114.36 1 HOUSE

14 1297 182.71 1 HOUSE

15 1347 149.5 1 HOUSE

16 1377 128.49 15 VILLAGE SITE WARI KALA

17 1401 54.79 1 HOUSE

18 1412 82.45 1 HOUSE

19 1505 26.95 1 HOUSE

20 1578 88.95 1 HOUSE

21 1843 95.62 4 177 III HOUSES

22 1845 14.48 1 HOUSE

23 1859 89.04 1 HOUSE

24 1888 59.84 5 HOUSES

25 1917 65.34 1 HOUSE

26 1923 77.75 1 HOUSE

27 1926 181.72 1 HOUSE

28 1937 118.74 1 HOUSE

29 2005 185.18 1 HOUSE

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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Sl. No.

Chainage (m)

Distance of Dwellings from Centre line of Pipeline in (m)

No. of Dwellings

Total No. of

dwelling units

in 1600 mtr

Class Remarks

30 2397 124.42 1 HOUSE

31 2405 84.38 1 HOUSE

32 2406 66.78 1 HOUSE

33 2490 66.42 5 HOUSES

34 2506 143.92 1 HOUSE

35 2622 17.17 1 Primary School

36 2716 20.02 1 Temple

37 2726 171.19 150 VILLAGE SITE NADARGANJ

38 3563 43.94 1 674 IV HARMAN PUNJABI DHABA

39 3652 33.56 1 JUNAID'S COMMUNICATION

5. PLANNING BRIEF

i. Planning Concepts

The Pipeline would originate from the terminal and after traversing length of 0.6km, the pipeline route

would take eastern direction and would follow an independent route through cultivated lands for

about 1.7 km till Canal with adjoining road(Canal road).Beyond Canal road, the route would traverse

for about 1.3 km mainly through Government lands and enters the Airport boundary

after crossing the Lucknow-Kanpur NH-25 road. Upon reaching the AFS boundary wall (insidethe

Airport), the pipeline would traverse along the Airport boundary wall for about 2.5 km to reach the

delivery point. The terrain is predominantly flat and there are no major undulations in the proposed

route. The pipeline traverses mostly through agricultural land, Government land, National Highway

Authority of India (NHAI) corridor and AAI corridor. There is no reserve forest or social forestry along

the route. The entire pipeline route falls in Amousi village of Lucknow District.

ii. Population Projection

Refer as Item No. 4 viii

iii. Land use Planning (breakup along with green belt area etc.)

Not Applicable as the proposed project is for laying pipeline.

iv. Assessment of Infrastructure demand (Physical & Social)

Social Benefits as Due to increasing demand of ATF at the AFS, a need was felt for having a

pipeline between the Terminal and the AFS.

v. Amenities/facilities

Social Benefits as Due to increasing demand of ATF at the AFS, a need was felt for having a

pipeline between the Terminal and the AFS.

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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6. PROPOSED INFRASTRUCTURE

i. Industrial Area (PROCESSING AREA)

Not Applicable

ii. RESIDENTIAL AREA (NON PROCESSING AREA)

For housing pipeline receipt facilities, a stretch of 13 m x 14 m inside existing IOC's facilities at

the AFS has been identified. Further, for housing electrical and T&l equipments, it is

proposed to either construct a new building in place of existing record room and parking

shed or utilizing existing office building for housing the equipments and building a new

administration building in place of record room and parking shed.

iii. Green belt

Adequate greenbelt is developed at Amausi Marketing Terminal. Not Applicable as the

proposed project is for laying pipeline.

iv. SOCIAL INFRASTRUCTURE

Refer as Item No. 4, viii

v. CONNECTIVITY (TRAFFIC AND TRANSPORTATION ROAD/RAIL/METRO/WATERWAYS ETC

The proposed pipeline is crossing through NH-25, Gahru Minor and Amausi Distibutory.

Nearest Railway station is Amousi Railway station is at distance of ~0.76 km from the pipeline

in the NW direction. The proposed pipeline is connecting Lucknow marketing Terminal and

Aviation Fuel Station (AFS) at Lucknow Airport.

vi. DRINKING WATER MANAGEMENT

Temporary water requirement will be only during construction phase and will be met with by

tanker supply from nearby municipal source.

vii. SEWERAGE SYSTEM

Not Applicable for proposed project.

viii. INDUSTRIAL WASTE MANAGEMENT

Not Applicable for proposed project.

ix. SOLID WASTE MANAGEMENT

Marginal amount of solid wastes will be generated at the camp side along the pipeline route,

and same will be disposed as per SPCB / CPCB Guideline.

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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x. Power Requirement & supply/source

Temporary DG set will be required for electro fusion welding only during construction phase

of laying of pipeline. Source of power required for running Pumps, SCADA and Cathodic

Protection will be from State Electricity Board(In normal times) and in house Diesel

Generator(during Emergency situation).

7. REHIBILITATION AND RESETTLEMENT (R&R) PLAN

Not applicable as there is no displacement involved.

8. PROJECT SCHEDULE & COST ESTIMATE

Completion schedule - 18 months from the date of administrative approval or Environmental

Clearance/ Statutory Clearances.

Cost Estimate -The proposal for laying of IOCL's captive ATF pipeline from Lucknow

Marketing terminal to Lucknow AFS, at an estimated cost of Rs.35.71 crore including CER

Budget.

S.No. Descriptionofltem(s) Cost (Rs.inLakh)

1. Survey&FieldEngineering 41.3

2. Land Acguisition, ROW &Cro.QCom_Qensation

LandCost 0

RoWCompensation 353.5

CropCompensation 2.0

3. MainlinePipes 585.5

4. MainlineMaterials 0

5. MainlineConstruction 642.0

6. Pum.Q Station and Terminal

Civil 149.3

Electrical 228.2

Mechanical 616.5

Instrumentation 142.6

FireAlarm&DetectionSystem 84.2

7. CathodicProtection 87.3

8. Telecommunication &Tele supervisory 212.9

9. Contingencies(5%) 157.3

10. Project Management and Engineering, Insurance (6%) 198.2

11. CorporateEnvironmentalResponsibility@2% 70.0

12. Total Cost in (Lakh) 3570.7

Laying of ATF Pipeline between Lucknow marketing Terminal and Aviation Fuel Station (AFS) at Lucknow Airport by M/s Indian Oil Corporation Ltd.

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9. ANALYSIS OF PROPOSAL (FINAL RECOMMENDATION)

Pipeline transport is a much safer operation compared to road transportation. /The man

power p resent ly engaged for TT loading and unloading could be re-deployed for other

works, there by resulting in further savings. This would help in achieving improvement in

operations. Lucknow Airport being a major international Airport in U.P, it is expected that its

ATF requirement would increase substantially. It is understood that Airport Authority of India

(AAI) is proposing to develop/ revamp the facilities at Lucknow Airport to meet

increasing aircraft movements.

Proposed ATF Pipeline is not passing through passing through national parks

/sanctuaries/coral reefs /ecologically sensitive areas

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