Precipitated Silica (PS) & Nano-PCC Circular Biorefinery · Sangareddy, Telangana · CIN: U35106TS2026PTC210706 · DPIIT: 246192
What Fluxara does, why it works, and the key numbers a banker or investor needs to know.
Rice mills produce two waste streams: rice husk (the outer shell, ~20% of paddy weight) and the ash left after burning it (RHA — Rice Husk Ash). Both are abundant, cheap, and usually discarded. Fluxara converts them into two high-value industrial chemicals.
Precipitated Silica (PS) is the same white powder used in high-performance green tyres, toothpaste, food anti-caking, and industrial rubber. Global price: ₹26–95/kg depending on grade. It is made from the silicon dioxide (SiO₂) locked inside RHA — up to 92% of the ash is amorphous silica.
Nano-PCC (Precipitated Calcium Carbonate) is an obligatory co-product of the NaOH recovery step. When NaOH is recycled after silica extraction, it reacts with lime (CaO) and produces ultra-fine calcium carbonate — the same filler used in paints, plastics, silicone sealants, and paper. Price: ₹8–42/kg by grade.
The plant is thermally self-sufficient: rice husk is burned on-site to generate 199 GJ/day of heat. After running all processes (with MVR heat recovery), 83 GJ/day surplus remains — enough to power a Phase 1B expansion and a future Phase 2 line without buying any fuel.
Fluxara Advanced Renewables & Applications Pvt Ltd
CIN: U35106TS2026PTC210706 · DPIIT: 246192
Promoted by M/S Surya Industries
Site: 3 acres TSIIC Sangareddy, Telangana (₹1 Cr/acre)
Operating: 330 days/yr · 3 × 8-hr shifts/day
Phase 1A — Bank-funded, Day 1 of commissioning
20 MT/day rice husk + 11.432 MT/day purchased RHA
Phase 1B — Self-funded from Y1 accruals (Month 18)
₹1.50 Cr equipment adds 4.568 MT/day RHA capacity
Payback: <2 months
Phase 2 — Self-funded from Y2+ accruals
Full second line on 74 GJ/day thermal surplus
Four reactions drive the entire plant. Understanding these is the key to understanding every cost, yield, and design decision.
Figure 1 — Simplified process flow diagram showing 4 core reactions and product streams
Below 700°C, the silica in rice husk remains in an amorphous (non-crystalline) state — structurally disordered at the atomic level. This is essential: amorphous SiO₂ dissolves readily in NaOH, giving 88% extraction efficiency.
Above 700°C, silica undergoes crystallisation into cristobalite — a highly ordered crystal lattice. Cristobalite does NOT dissolve in NaOH at any practical concentration or temperature. The RHA becomes chemically inert and the entire batch is wasted. This is why a CEMS (Continuous Emissions Monitoring System) is wired to an auto-shutoff at 720°C — a 20°C safety buffer.
Na₂SiO₃ is a clear, viscous liquid used industrially in adhesives, cements, and detergents. At Fluxara it is an intermediate — it is never sold. Instead it is fed directly into Reaction 2 to precipitate silica. The "water glass" is essentially a dissolved form of silica with sodium attached — Reaction 2 removes the sodium by replacing it with CO₂.
The pH at which CO₂ is added controls when silica nucleates vs. grows. At higher pH (8–9), fewer nucleation sites form → larger particles → Standard grade (D50 ~20 µm). At lower pH (5.5–7), rapid nucleation creates many small particles → HDS grade (CTAB ≥175 mg/g, CIPD ≥80%). Dental grade requires additional washing to reduce lead below 1 ppm (Pb ≤1 ppm per FSSAI E551).
The CTAB surfactant added post-precipitation coats each silica particle. CTAB consumption — 0.289 MT/day (₹1,80,000/MT, imported) — is the primary driver of HDS premium. This is why CTAB supply chain (4-week buffer mandatory) is the highest supply-risk item in the BOM.
| Compound | Formula | MW (g/mol) | Role in Process |
|---|---|---|---|
| Silicon Dioxide | SiO₂ | 60.08 | Feedstock from RHA |
| Sodium Hydroxide | NaOH | 40.00 | Leaching reagent, recovered |
| Sodium Silicate | Na₂SiO₃ | 122.06 | Intermediate (water glass) |
| Carbon Dioxide | CO₂ | 44.01 | Precipitation reagent (free, from furnace) |
| Sodium Carbonate | Na₂CO₃ | 105.99 | NaOH recovery feedstock |
| Calcium Hydroxide | Ca(OH)₂ | 74.09 | Causticisation reagent (from CaO slaking) |
| Calcium Carbonate | CaCO₃ | 100.09 | Nano-PCC product |
| Calcium Oxide (quicklime) | CaO | 56.08 | Purchased feedstock ₹6,000/MT |
| Water | H₂O | 18.02 | Solvent throughout |
What goes in, what comes out, and how the numbers are derived. All figures for Phase 1A unless noted.
A mass balance is simply a material accounting statement: inputs = outputs + accumulation. For a continuous steady-state plant (no accumulation), every kilogram of raw material must appear somewhere in the outputs — either as product, by-product, waste, or atmospheric emission.
The key chain: RHA → SiO₂ extraction → Na₂SiO₃ → PS precipitation → Na₂CO₃ → NaOH recovery + Nano-PCC. The 12% of SiO₂ that is NOT extracted (100% − 88% = 12%) leaves as desilicated residue sold to brick kilns at ₹900/MT.
| Stream | Phase 1A (MT/day) | Phase 1B (MT/day) | Notes |
|---|---|---|---|
| INPUTS | |||
| Rice husk combusted | 20.000 | 20.000 | Thermal anchor — unchanged in Ph1B |
| Purchased RHA (92% SiO₂) | 11.432 | 16.000 | ₹750/MT contract (min 90% SiO₂ clause) |
| Bonus RHA from combustion | 3.600 | 3.600 | ₹0 cost — from own furnace |
| NaOH fresh makeup (100%) | 4.375 | 5.705 | As 48% lye: 9.114 / 11.882 MT/day |
| CaO quicklime v15 | 13.364 | 17.440 | ≥85% purity · v15 +14.2% from v14 |
| CTAB surfactant | 0.289 | 0.376 | Imported · ₹1,80,000/MT · 4-wk buffer |
| Stearic acid | 0.162 | 0.211 | PCC coating for sealant grade |
| INTERMEDIATE | |||
| Total RHA to leach reactor | 15.032 | 19.600 | Purchased + bonus |
| SiO₂ available (92% of RHA) | 13.829 | 18.032 | |
| SiO₂ extracted (88% eff.) | 12.170 | 15.868 | Goes to precipitation |
| OUTPUTS — PRODUCTS | |||
| Precipitated Silica (PS) | 13.149 | 17.145 | 4,339 / 5,658 MT/yr @ 330 days |
| Nano-PCC | 20.272 | 26.432 | 6,690 / 8,723 MT/yr — obligatory co-product |
| OUTPUTS — BY-PRODUCTS | |||
| Desilicated residue | 2.862 | 3.732 | ₹900/MT to brick kilns — revenue |
| CO₂ generated (combustion) | 25.050 | 25.050 | Unchanged in Ph1B (same husk quantity) |
| CO₂ consumed (precipitation) | 9.360 | 12.204 | Includes 5% excess over stoichiometric |
| CO₂ surplus (BCR upside) | 15.690 | 12.846 | NOT in base revenue — BCR upside only |
| WATER | |||
| Fresh water makeup | 84 KLD | 110 KLD | After 80% ZLD recycle |
Table 1 — Daily mass balance, Phase 1A and Phase 1B comparison
This surprises many people. The answer is stoichiometry: per mole of Na₂CO₃ converted, the CaCO₃ product has MW = 100.09 g/mol, but the NaOH "input equivalent" (2×NaOH = 80 g/mol) is lighter. Furthermore, Ca(OH)₂ (from CaO slaking) adds calcium mass to the product. So the PCC stream carries the weight of both the carbonate anion AND the calcium cation — it is inherently a heavier molecule per mole of sodium processed.
Combined with CaO purchased at 13.364 MT/day, the product PCC tonnage necessarily exceeds the silica tonnage. This is structural, not an error.
How 20 MT/day of rice husk becomes 199 GJ/day of useful heat, why MVR is mandatory, and where the 83 GJ/day surplus goes.
Net Calorific Value (NCV) is the energy released per kg of fuel burned, accounting for the energy lost evaporating moisture in the fuel. Rice husk has NCV ≈ 12,150 kJ/kg at 10% moisture. At 20 MT/day = 20,000 kg/day: gross thermal = 20,000 × 12,150 = 243,000,000 kJ/day = 243 GJ/day.
A boiler cannot capture 100% — efficiency is typically 80–85%. At 82%: useful heat = 243 × 0.82 = 199.3 GJ/day. This is the energy available for process use.
MVR (Mechanical Vapour Recompression) is a heat pump for evaporators. Instead of using fresh steam to evaporate water from the sodium silicate solution, MVR compresses the vapour produced and reuses it as the heat source. At 65% energy saving on evaporation: MVR saves 0.65 × 167.1 = 108.6 GJ/day. Without this saving, process heat demand (224.9 GJ/day) would exceed supply (199.3 GJ/day) by 25.6 GJ/day — the plant cannot operate at design throughput.
Figure 2 — Energy waterfall: from gross thermal to 83 GJ/day surplus
| Energy Item | GJ/day | Notes |
|---|---|---|
| Rice husk NCV (as-received, 10% moisture) | 12,150 kJ/kg | Per kg husk |
| Gross thermal (20 TPD) | 243.0 | 20,000 kg × 12,150 kJ/kg ÷ 1,000 |
| Boiler efficiency loss (18%) | −43.7 | 1 − 0.82 = 18% loss |
| Useful heat available | 199.3 | 243.0 × 0.82 |
| WITHOUT MVR (shown for reference only — plant CANNOT operate in this mode) | ||
| Evaporation demand (no MVR) | 167.1 | Concentrating Na₂SiO₃ solution |
| Leach reactor heat | 42.7 | Heating to 90°C |
| Spray dryer heat | 15.1 | Drying PS to <6% moisture |
| Total process demand (no MVR) | 224.9 | EXCEEDS supply by 25.6 GJ — DEFICIT |
| WITH MVR (design basis — v15) | ||
| MVR saving (65% of 167.1) | −108.6 | Evaporation reduced to 58.5 GJ/day |
| Evaporation with MVR | 58.5 | |
| Leach reactor | 42.7 | Unchanged |
| Spray dryer | 15.1 | Unchanged |
| Process heat with MVR | 116.3 | v15 corrected figure |
| Thermal surplus (with MVR) v15 | 83.0 | 199.3 − 116.3 GJ/day |
| Phase 1B consumes | ~9.0 | Extra 4.568 MT/day RHA processing |
| Remaining for Phase 2 | ~74.0 | 83 − 9 GJ/day |
Installed: 585 kW
Operating: 454 kW
Solar PV: 250 kWp (315,000 kWh/yr)
Net grid: ~2.13M kWh/yr
Cost: ₹1.49 Cr/yr @₹7/kWh
250 kWp rooftop system
Generation: 315,000 kWh/yr
Saving: ~₹0.22 Cr/yr
Self-consumption priority — no export in base model
ZLD recovery: 80%
Fresh makeup Ph1A: 84 KLD
Fresh makeup Ph1B: 110 KLD
ETP+ZLD: 25 KLD capacity
Capital expenditure breakdown, financing structure, and key equipment rationale.
| CAPEX Category | ₹ Lakhs | ₹ Cr |
|---|---|---|
| Land — 3 acres TSIIC Sangareddy @₹1 Cr/acre | 300 | 3.00 |
| Civil (sheds, RCC, roads, drains, bunds) | 178 | 1.78 |
| Process equipment subtotal | 1,345 | 13.45 |
| Ancillary — E&I + piping @52% of process equip | 699 | 6.99 |
| Utilities (HT, DG 200 kVA, Solar 250 kWp) | 170 | 1.70 |
| Contingency @8% | 215 | 2.15 |
| Pre-operative + WC + DPIIT grant (−₹35L) | 190 | 1.90 |
| TOTAL PROJECT COST | 3,096 | 30.96 |
| Component | ₹ Cr | % | Terms |
|---|---|---|---|
| Term Loan (Debt) | 20.12 | 65% | 10.5% p.a. · 7yr · 12M moratorium |
| Promoter Equity | 10.84 | 35% | Surya Industries + promoter |
| Annual Debt Service | 4.07 Cr/yr | — | Post-moratorium (Y2+) |
| Equipment | ₹ Lakhs | Notes |
|---|---|---|
| Furnace 20 TPD + IBR boiler | 280 | IBR registration mandatory |
| Leach reactors ×3 (SS/PP-lined, 10KL) | 120 | 90°C NaOH — PP lining critical |
| Filter presses ×2 | 110 | |
| Spray dryers ×2 (500 kg/hr, SS316) | 160 | Food grade requires SS316 |
| Causticisation + CaO slaker | 90 | |
| Triple-effect evaporator (MVR-ready) | 150 | MVR mandatory from Day 1 |
| PCC hydrocyclone classifiers | 80 | Particle size control |
| ETP + ZLD (25 KLD) | 120 | ZLD Day 1 — regulatory |
| QC Lab (BET + PSD + XRF) | 40 | XRF for CaO purity, BET for PS spec |
Operating cost breakdown for Phase 1A. Understanding cost structure is essential for managing DSCR in ramp-up years.
| Item | ₹ Cr/yr | % OPEX |
|---|---|---|
| NaOH 48% lye (9.114 MT/d × ₹18,240 × 330) | 5.49 | 27.7% |
| Rice husk (20 MT/d × ₹5,500 × 330) | 3.63 | 18.3% |
| CaO quicklime v15 (13.364 × ₹6,000 × 330) | 2.65 | 13.4% |
| CTAB surfactant (0.289 × ₹1,80,000 × 330) | 1.72 | 8.7% |
| Stearic acid | 0.64 | 3.2% |
| Purchased RHA | 0.28 | 1.4% |
| Packing + transport | 1.20 | 6.1% |
| Electricity (variable) | 0.49 | 2.5% |
| Variable Subtotal | 16.10 | 81.2% |
| Item | ₹ Cr/yr |
|---|---|
| Electricity (base grid, net solar) | 1.00 |
| Labour (25 staff, avg ₹4.8L CTC) | 1.20 |
| Maintenance (2% of fixed assets) | 0.65 |
| Admin + insurance + other | 0.87 |
| Fixed Subtotal | 3.72 |
| TOTAL OPEX Phase 1A | ₹19.82 Cr/yr |
| Scenario | OPEX Impact |
|---|---|
| NaOH recovery +1% (82%→83%) | −₹0.47 Cr/yr |
| Rice husk price +₹500/MT | +₹0.33 Cr/yr |
| NaOH price +10% | +₹0.55 Cr/yr |
| CaO price +₹500/MT | +₹0.22 Cr/yr |
| CTAB price +10% | +₹0.17 Cr/yr |
Phase 1B total OPEX: ₹22.40 Cr/yr (v15 corrected). Phase 1B OPEX includes the extra 4.568 MT/day RHA and proportional chemical costs.
Year-by-year P&L, debt service coverage, and how the model reaches bankability.
DSCR = (EBITDA − Income Tax on PBT) ÷ (Principal Repayment + Interest). It answers: "For every ₹1 of debt service due this year, how many rupees of operating cash does the plant generate?" Banks require DSCR ≥ 1.25× as the loan covenant. A DSCR of 2× means the plant generates twice the cash needed to service debt — very comfortable. A DSCR of 0.27× (Year 1) means the plant cannot service debt from operations — the promoter's bridging WC of ₹1.55 Cr covers the gap. Year 1 is the moratorium period; no principal repayment is due, only interest.
Y1/Y2 DSCR uses EBITDA/DS directly (minimal tax because EBITDA is low or moratorium applies). Y3/Y4+ include 25.17% income tax on PBT after depreciation. The exact tax figure requires the depreciation schedule annexure (pending for v16).
| Year | Utilisation | Revenue | OPEX | EBITDA | EBITDA% | Debt Service | DSCR |
|---|---|---|---|---|---|---|---|
| Y1 Moratorium |
60% | ₹13.94 Cr | ₹13.38 Cr | ₹0.56 Cr | 4.0% | ₹2.11 Cr | 0.27× ⚠ |
| Y2 HDS qualified |
75% | ₹30.81 Cr | ₹16.73 Cr | ₹14.08 Cr | 45.7% | ₹4.07 Cr | 3.46× |
| Y3 FSSAI + Ph1B |
90% | ₹51.12 Cr | ₹20.32 Cr | ₹30.80 Cr | 60.3% | ₹3.73 Cr | 7.57× |
| Y4+ Full premium |
100% | ₹61.75 Cr | ₹22.40 Cr | ₹39.35 Cr | 63.7% | ₹3.38 Cr | 9.64× |
Utilisation at which EBITDA covers fixed OPEX + interest
Based on 10-year DCF on full project cash flows
Leverage amplifies equity returns significantly
Return on equity base of ₹10.84 Cr at Y4+ EBITDA
The jump is not just utilisation (60%→75% adds only ~25% volume). The key driver is product qualification: HDS (High Dispersibility Silica) for green tyres qualifies in Y2. HDS commands ₹45–50/kg domestic vs. ₹26/kg standard — a 73–92% premium. Once the first tyre manufacturer qualifies the batch (typically 3–6 month trial + approval cycle), the entire HDS volume shifts to premium pricing. Revenue per MT effectively doubles for the HDS portion. Similarly, Y3's FSSAI dental certification unlocks ₹90–95/kg pricing (3.5× standard).
Precipitated silica and nano-PCC grade specifications, pricing, and target markets.
| Grade | ₹/kg Domestic | ₹/kg Export FOB | Key Spec | Applications | Timeline |
|---|---|---|---|---|---|
| Standard | ₹26 | ₹42 | BET 140–165 m²/g · D50 ≤20 µm | Rubber, animal feed, carrier | Day 1 |
| HDS | ₹45–50 | ₹72–84 | CTAB ≥175 mg/g · CIPD ≥80% | Green tyres (Michelin, Birla) | Year 2 |
| Dental/Food (FSSAI E551) | ₹90–95 | ₹144–152 | Pb ≤1 ppm · D50 ≤12 µm | Toothpaste, food anti-caking | Year 3+ |
CTAB (cetyltrimethylammonium bromide) surface area is the standard test for measuring the silica surface accessible to polymer chains in a rubber compound. The CTAB surface area (mg/g) directly correlates with how well the silica disperses in the tyre rubber matrix — hence "High Dispersibility Silica."
A CTAB ≥175 mg/g with CIPD (CTAB-based In-rubber Performance Descriptor) ≥80% means the silica is engineered for low rolling resistance (better fuel economy) — the defining performance claim of green tyres. This specification requires precise pH control during precipitation, strict particle size control, and CTAB surface treatment post-filter.
CIPD is calculated from dynamic mechanical analysis of the rubber compound — tyre manufacturers run this test in-house as part of supplier qualification. This is why HDS qualification takes 3–6 months and requires supplying samples before any order.
| Grade | ₹/kg | Particle Size | Applications |
|---|---|---|---|
| Coatings / Bulk | ₹8–15 | 2 µm d50 | Paints, coatings, paper |
| Sealant (stearic coated) | ₹26 | 0.7 µm d50 | Silicone sealants (GE, Momentive) |
| Plastics (OCC coated) | ₹42 | 0.5 µm d50 | PP/PE compounding, masterbatch |
Raw (uncoated) CaCO₃ is hydrophilic — it attracts water and clumps in polymer matrices, causing weak spots. Stearic acid coating makes each particle surface hydrophobic (oil-loving), allowing it to disperse uniformly in silicone or polymer matrices without agglomeration. The coating adds minimal cost (₹1,20,000/MT stearic acid at 0.162 MT/day) but commands a 50–100% price premium over uncoated bulk PCC.
Particle size (d50 = median diameter) is controlled via hydrocyclone classifiers. The plastics grade at 0.5 µm requires tighter classification and more passes — hence highest price at ₹42/kg.
Self-funded expansion from Year 1 accruals. Equipment-constrained (not thermally). Payback under 2 months.
Phase 1A leaves 83 GJ/day thermal surplus. Phase 1B only requires ~9 GJ/day to process an additional 4.568 MT/day of purchased RHA. The binding constraint is equipment throughput, not heat. A second filter press, a second spray dryer, an extra leach reactor, plus piping — totalling ₹1.50 Cr — unlocks this capacity.
At ₹9.29 Cr/yr incremental EBITDA from ₹1.50 Cr investment, the payback is under 2 months. This is why Phase 1B is funded from Year 1 accruals, never from bank debt. Installing it at Month 18 (mid-Year 2) allows the first year of cash to accumulate before the investment.
| Phase 1B Equipment | ₹ Lakhs |
|---|---|
| Additional filter press | 30 |
| Second spray dryer | 65 |
| Extra leach reactor | 25 |
| Piping + E&I | 30 |
| Phase 1B TPC | ₹1.50 Cr |
| Metric | Phase 1A | Phase 1B |
|---|---|---|
| Total RHA/day | 15.032 MT | 19.600 MT |
| PS/year | 4,339 MT | 5,658 MT |
| PCC/year | 6,690 MT | 8,723 MT |
| Revenue (Y4+) | — | +₹12.33 Cr/yr |
| EBITDA increment | — | +₹9.29 Cr/yr |
| Payback | — | <2 months |
| Thermal used | — | ~9 GJ/day |
| Thermal remaining | 83 GJ/day | ~74 GJ/day |
Stress tests on the Y4+ base case (₹61.75 Cr revenue, ₹39.35 Cr EBITDA, 9.64× DSCR). All scenarios remain above the 1.25× covenant.
| Scenario | EBITDA Impact | Revised EBITDA | DSCR | Verdict |
|---|---|---|---|---|
| PS price −20% all grades | −₹7.77 Cr | ₹32.02 Cr | 7.87× | Bankable |
| NaOH price +30% | −₹2.75 Cr | ₹37.04 Cr | 9.10× | Bankable |
| NaOH price +50% | −₹4.58 Cr | ₹35.21 Cr | 8.65× | Bankable |
| Rice husk price doubles | −₹3.63 Cr | ₹36.16 Cr | 8.88× | Bankable |
| Utilisation 85% in Y4+ | −₹4.57 Cr | ₹35.22 Cr | 8.65× | Bankable |
| Dental/FSSAI delayed to Y5 | −₹8.90 Cr (Y3) | ₹22.33 Cr (Y3) | 5.49× (Y3) | Bankable |
| Combined: PS−15% + NaOH+30% + 85% util | −₹14.00 Cr | ₹25.79 Cr | 6.34× | Bankable |
| Worst case: PS−25% + NaOH+50% + 75% + no export | −₹26.52 Cr | ₹13.27 Cr | 3.26× | Stressed (>1.25×) |
| Upside: BCR + electricity export | +₹1.27 Cr | ₹41.06 Cr | 10.09× | Upside |
36-month critical path from financial close to FSSAI-certified dental/food grade production.
Key statutory requirements and certifications for operating and selling in target markets.
| Requirement | Details |
|---|---|
| TSPCB Category | Orange (PI 41–59), NIC 2029 "Agro-waste beneficiation" |
| TSPCB Consent (NOC) | 6–9 months processing time — apply at land possession |
| CEMS | Mandatory on chimney before CTO is granted |
| ZLD | Day 1 — zero liquid discharge mandatory |
| PCB NOC | Green category — applies to lab chemicals |
| Standard | Applies To |
|---|---|
| FSSAI E551 | Food-grade precipitated silica (Y3+) |
| IS 6579 | Precipitated silica — general industrial |
| BIS | Toothpaste-grade silica |
| IBR Registration | Boiler — mandatory before steam operations |
All changes from v14 to v15, and the inviolable design decisions that cannot be altered without a full DPR revision.
| Parameter | v14 Value | v15 Value | Change | Reason |
|---|---|---|---|---|
| CaO consumption (Ph1A) | 11.698 MT/day | 13.364 MT/day | +14.2% | Full causticisation stoichiometry — prior figure understated Ca(OH)₂ needed to convert all Na₂CO₃ |
| CaO consumption (Ph1B) | 15.253 MT/day | 17.440 MT/day | +14.3% | Same correction applied to Phase 1B |
| Thermal surplus (with MVR) | 117 GJ/day | 83 GJ/day | −29% | Prior figure was unsupported; Section 6 audit: 199.3 − 116.3 = 83 GJ/day |
| OPEX Phase 1A | ₹19.49 Cr/yr | ₹19.82 Cr/yr | +₹0.33 Cr | CaO cost correction (+₹0.33 Cr/yr at Ph1A) |
| OPEX Phase 1B | ₹21.97 Cr/yr | ₹22.40 Cr/yr | +₹0.43 Cr | CaO cost correction at Ph1B volume |
| Ph1B incr. EBITDA | ₹9.72 Cr/yr | ₹9.29 Cr/yr | −₹0.43 Cr | Higher CaO OPEX reduces EBITDA increment |
| # | Rule | Consequence of Violation |
|---|---|---|
| 1 | Hybrid config (purchased + bonus RHA) is optimal | Fully-purchased RHA eliminates ~₹10 Cr/yr bonus streams |
| 2 | Bonus ash processed into PS/PCC — never sold raw | Destroys economics; raw ash is ₹0–300/MT vs ₹26+/kg product |
| 3 | Phase 1B from Y1 accruals only — never bank debt | Increases leverage and debt service beyond covenant margins |
| 4 | Phase 2 self-funded from Y2+ accruals | Zero bank debt for any Phase 2 expansion |
| 5 | MVR mandatory from Day 1 | Without MVR: 25.6 GJ/day deficit — plant cannot operate |
| 6 | Buy CaO, slake on-site — never pre-slaked Ca(OH)₂ | Higher cost, shorter shelf life, logistics waste |
| 7 | Customer engagement Month 1 | Delays HDS qualification → misses Y2 premium pricing |
| 8 | FSSAI application at Month 10 commissioning | 12–18M cycle delays dental revenue beyond Y3 |
| 9 | PCC is obligatory — causticisation is not optional | Without PCC, NaOH recovery collapses → OPEX doubles |
| 10 | Furnace temp ≤700°C strictly (CEMS auto-shutoff at 720°C) | Above 700°C: cristobalite forms → RHA chemically inert → batch lost |
| 11 | Furnace/boiler building = fire-rated RCC (not PEB) | PEB is not permitted for IBR-registered boiler structures |
| 12 | Land = ₹1 Cr/acre (not ₹17L/acre — old error) | ₹17L/acre was a prior version error — TPC would be understated by ₹2.5 Cr |