Analysis of environmental impact on oil & gas company


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Analysis of environmental impact on oil & gas company

  1. 1. Oil and Gas majors School of Petroleum Management,Analysis of impact of climate change on 2011 Pandit Deendayal Petroleum University, Gandhinagar The Oil & Gas Sector has a variety of impacts on the environment. These impacts depends upon the stage of the process, the size and complexity of the project, the nature and sensitivity of the surrounding environment and the effectiveness of planning, pollution prevention, mitigation and control techniques. This paper consists of macro-Analysis of Impact as well as potential risk faced by Oil & Gas Majors because of Climate Change. 15 Month Executive MBA Programme Anil Kumar Sahu (20104004) Sandeep Prasad (20104005) Sarjeevan Sainbhi (20104006)
  3. 3. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 LIST OF ABBREVIATION CO2 Carbon Dioxide CPCB Central Pollution Control Board E&P Exploration & Production EPA Environmental Protection Act (India) GHG Greenhouse Gas IPCC Intergovernmental Panel on Climate Change MoEF Ministry of Environment and Forests of India SPCB State Pollution Control BoardAnil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006)
  4. 4. Analysis of impact of climate change on Oil and Gas majors Exe-MBA101.0 INTRODUCTION The oil and gas industry is truly global, with operations conducted in every corner of the globe, from Alaska to Australia, from Peru to China, and in every habitat from Arctic to desert, from tropical rainforest to temperate woodland, from mangrove to offshore. The global community will rely heavily on oil and gas supplies for the foreseeable future. World primary energy consumption in 2010 stood at nearly 12002 million tonnes of oil equivalents (BP Statistical Review of World Energy, June 2011); oil and gas represented 57 per cent of world energy supply, with coal providing 29 per cent, nuclear energy 5 per cent and hydro- electric 7 per cent. The challenge is to meet world energy demands, whilst minimizing adverse impact on the environment by conforming to current good practice.2.0 WORLD OIL & GAS MAJORS Below Figures details Oil & Gas producing Nations in the world? Oil Producing Nations Source:,+Oil+%26+Gas Natural Gas Producing Nations Source: Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 4 of 21
  5. 5. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 Source: 1. Ranked in order of 2007 worldwide oil equivalent reserves as reported in "OGJ 200/100", Oil & Gas Journal, September 15, 2008.3.0 WORLD ENERGY BASKET & RELATED FACTS Renewable Energy Energy hydro 2% Nuclear 7% 5% Oil and Gas Coal Nuclear Coal Oil and Gas hydro 29% 57% Renewable Energy Source: BP Statistical Review of World Energy June 2011Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 5 of 21
  6. 6. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 World CO2 emission by sector and fuel Energy supply sector is contributing most to the world CO 2 emission compare to other sector in 2004, followed by industry with 21% Waste and wastewater GHG emissions by sector 3% Waste and wastewater Forestry Energy Supply 19% Transport Energy Supply Agriculture 28% 14% Residential and commercial Building Transport Industry 14% Residential Industry and 21% commercial Agriculture Building 1% Source: IPCC GHG emissions by sector in 2004 In 2009, nearly 57% of CO2 emissions from fuel combustion were produced from oil and gas (oil 37% and 20% Gas). Coal contributed 37%. GHG emission by Fuel Others 0.4% Oil Coal Oil 36.7% 43.0% Natural Gas Coal Others Natural Gas 19.9% Source: IEAAnil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 6 of 21
  7. 7. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 The exploitation of oil and gas reserves has not always been without some ecological side effects. Oil spills, damaged land, accidents and fires, and incidents of air and water pollution have all been recorded at various times and places.4.0 INDIA’S NATIONAL ACTION PLAN FOR CLIMATE CHANGE The Action Plan is based upon seven guiding principles, presented below, that will form the basis for a sustainable development path that also advances economic and environmental objectives. The Plan emphasizes the overriding priority of maintaining high economic growth rates to raise living standards in the country and identifies “measures that promote our development objectives while also yielding co- benefits for addressing climate change effectively.” The Plan also pledges that India’s per capita GHG emissions “will at no point exceed that of developed countries even as we pursue our development objectives.”Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 7 of 21
  8. 8. Analysis of impact of climate change on Oil and Gas majors Exe-MBA105.0 LEGAL AND REGULATORY FRAMEWORK IN INDIA There is no specific legislation at present dealing exclusively with regulations of sources of GHG emissions in India, but several environmental regulations have climate co-benefits. In the recent initiatives for mitigating GHG emissions, the sectoral approach is being considered an important tool to combat climate change by regulating emissions at the sources in various sectors of the economy. India has taken important policy measures at the sectoral level with regard to GHG emissions (see below table).5.1 Gaps for Regulatory Framework for GHG Emissions in IndiaAnil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 8 of 21
  9. 9. Analysis of impact of climate change on Oil and Gas majors Exe-MBA106.0 ENVIRONMENTAL ISSUES FOR THE INDIAN OIL & GAS SECTOR6.1 Human, socio-economic and cultural impacts Source: between-denial-and-alarm-lies-reality/ Exploration and production operations are likely to induce economic, social and cultural changes. The extent of these changes is especially important to local groups, particularly indigenous people who may have their traditional lifestyle affected. The key impacts may include changes in:  land-use patterns, such as agriculture, fishing, logging, hunting, as a direct consequence or as a secondary consequence by providing new access routes, leading to unplanned settlement and exploitation of natural resources;  local population levels, as a result of immigration and in-migration of a remote population due to increased access and opportunities;  socio-economic systems due to new employment opportunities, income differentials, inflation, differences in per capita income, when different members of local groups benefit unevenly from induced changes;  socio-cultural systems such as social structure, organization and cultural heritage, practices and beliefs, and secondary impacts such as effects on natural resources, rights of access, and change in value systems influenced by foreignersAnil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 9 of 21
  10. 10. Analysis of impact of climate change on Oil and Gas majors Exe-MBA106.2 Atmospheric impacts Source: © Atmospheric issues are attracting increasing interest from both industry and government authorities worldwide. This has prompted the oil and gas exploration and production industry to focus on procedures and technologies to minimize emissions. In order to examine the potential impacts arising from exploration and production operations it is important to understand the sources and nature of the emissions and their relative contribution to atmospheric impacts, both local and those related to global issues such as stratospheric ozone depletion and climate change. The primary sources of atmospheric emissions from oil and gas operations arise from:  flaring, venting and purging gases;  combustion processes such as diesel engines and gas turbines;  fugitive gases from loading operations and tankage and losses from process equipment;  airborne particulates from soil disturbance during construction and from vehicle traffic; and  Particulates from other burning sources, such as well testing. The principal emission gases include carbon dioxide, carbon monoxide, methane, volatile organic carbons and nitrogen oxides. Emissions of sulphur dioxides and hydrogen sulphide can occur and depend upon the sulphur content of the hydrocarbon and diesel fuel, particularly when used as a power source. In some cases sulphur content can lead to odour near the facility. Flaring of produced gas is the most significant source of air emissions, particularly where there is no infrastructure or market available for the gas. However, where viable, gas is processed and distributed as an important commodity. Thus, through integrated development and providing markets for all products, the need for flaring will be greatly reduced. Flaring may also occur on occasions as a safety measure, during start- up, maintenance or upset in the normal processing operation.Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 10 of 21
  11. 11. Analysis of impact of climate change on Oil and Gas majors Exe-MBA106.3 Aquatic impacts Source: The principal aqueous waste streams resulting from exploration and production operations are:  produced water;  drilling fluids, cuttings and well treatment chemicals;  process, wash and drainage water;  sewerage, sanitary and domestic wastes;  spills and leakage; and  Cooling water. The volumes of waste produced depend on the stage of the exploration and production process. During seismic operations, waste volumes are minimal and relate mainly to camp or vessel activities. In exploratory drilling the main aqueous effluents are drilling fluids and cuttings, whilst in production operations—after the development wells are completed—the primary effluent is produced water.6.4 Terrestrial impacts Source: Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 11 of 21
  12. 12. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 Potential impacts to soil arise from three basic sources:  physical disturbance as a result of construction;  contamination resulting from spillage and leakage or solid waste disposal; and  Indirect impact arising from opening access and social change. Potential impacts that may result from poor design and construction include soil erosion due to soil structure, slope or rainfall. Left undisturbed and vegetated, soils will maintain their integrity, but, once vegetation is removed and soil is exposed, soil erosion may result. Alterations to soil conditions may result in widespread secondary impacts such as changes in surface hydrology and drainage patterns, increased siltation and habitat damage, reducing the capacity of the environment to support vegetation and wildlife.6.5 Ecosystem Impact Source: Plant and animal communities may be directly affected by changes in their environment through variations in water, air and soil quality and through disturbance by noise. Such changes may directly affect the ecology: for example, habitat, food and nutrient supplies, breeding areas, migration routes etc. The effect is upsetting of the nutrient balances and microbial activity of the soil.6.6 Potential emergencies Plans for all seismic, drilling and production operations should incorporate measures to deal with potential emergencies that threaten people, the environment or property. However, even with proper planning, design and the implementation of correct procedures and personnel training, incidents can occur such as:  spillage of fuel, oil, gas, chemicals and hazardous materials;  oil or gas well blowout;  explosions;  fires (facility and surrounds);  unplanned plant upset and shutdown events;  natural disasters and their implications on operations, for example flood, earthquake, lightning; and  War and sabotage.Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 12 of 21
  13. 13. Analysis of impact of climate change on Oil and Gas majors Exe-MBA107.0 A NEW RISK LANDSCAPE CREATED BY INEVITABLE CLIMATE CHANGE Brand value Climate Change Physical risk Risk on Oil and Business risk Gas Competiveness risk Sector Regulatory risk Finance Threat from renewable7.1 Brand Value: Managing carbon emissions can enhance brand value; recent marketing studies from UK show that 67% of consumers more inclined to buy a product with a low carbon footprint; 49% more likely to buy if carbon footprint details are on packaging of products. COMPANIES that manage their carbon emissions responsibly can significantly enhance their brand value and make themselves and their products more attractive to potential customers as well as investors. Carbon foot-printing is a hugely valuable tool for understanding the impact a business has on climate change and how to use that footprint as part of a long-term plan to reduce carbon emissions. Foot- printing can also help businesses to improve processes, cut costs and meet reporting requirements for environmental legislation. There are two types of carbon footprint that need to be addressed. An organizational carbon footprint can measure the direct greenhouse gas emissions from all activities across the organization, including energy used in buildings, industrial processes and company vehicles, as well as indirect emissions such as business travel. A product carbon footprint measures greenhouse gas emissions over the whole life of a product, goods or service, from the extraction of raw materials and manufacturing right through to its use, recycling and disposal.Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 13 of 21
  14. 14. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 Quantifying greenhouse gas emissions through a carbon foot-printing exercise will help organizations to identify the opportunities for carbon emission reduction. The next step is to develop a carbon reduction plan, action it, and measure and monitor ongoing progress. Once an organizational carbon footprint has been calculated, it can be published and independently certified. Communicating this footprint to employees will help engage them in the carbon reduction and energy management process and independent certification gives employees something to aim for as an eco-aware workforce. Communicating an organizational footprint outside the company – for example as part of a corporate social responsibility report – will demonstrate to customers and stakeholders that the business takes tackling climate change seriously. A product carbon footprint also considers greenhouse gas emissions of an organization’s suppliers, customers and distributors related to a product’s manufacture and use. It also covers emissions created by disposing of any waste and the impact of recycling. A product carbon footprint can help to differentiate a product or service and enhance brand image as well as providing a better management of an organization’s supply chains. Once calculated, a product carbon footprint can be communicated in a number of ways including on product labeling.7.2 Physical Risks Global warming poses threat of sea level rise, hurricanes/ other natural calamities for especially those situated in the coastal regions. Coastal E&P facilities, Refineries can face huge damage due to cyclones and hurricanes. Rising sea levels pose threats of high tides and low tides and flooding of coastal refineries which depend on shipping. Water shortages due to depletion of snow or glacier fed rivers changing course or getting dried out. Extreme temperatures may bring in inefficiency in refining. The following are among the possible physical effects that could result from climate change:  Sea level rise: Melting of the polar icecaps and a resulting rise in the sea level could be one of the most serious consequences of climate change. The potential for damage is enormous, especially as coastal areas become more developed. Companies could be affected not only through direct loss of facilities and real estate, but also through potential impacts on their workers, many of whom could be forced to move if seawaters rise significantly. Not only might some areas be submerged, but areas not previously at risk to storm surge could become so.  Hurricanes, typhoons and cyclones: Hurricane Katrina focused world attention on the damage a massive hurricane causes when it strikes a populated area. As with a rising sea level, coastal areasAnil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 14 of 21
  15. 15. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 could expect to bear the brunt of the damage from increased storm activity; although tropical- storm damage from floods and wind can extend hundreds of miles inland. Asian countries dependent on monsoon season could be damaged by any change in the timing and intensity of storms.  Drought: Some areas of the world may become more prone to drought; already-dry areas may find the delicate balance they now live under tilted to one of desertification. Among the potential losses are destroyed crops, loss or reduction of water resources, damage to ecosystems, and forced migration of people.  Wildfires: Along with increased drought conditions comes the possibility of an increase in wildfires, both in forests and grasslands. Wildfires tourism centers; timber, grazing, and agricultural land; wildlife habitat; private homes; and more.  Heat waves: The European heat wave of 2003—widely cited as being related to climate change— caused the deaths of an estimated 22,000 people. Demand for air conditioning during periods of extreme heat could lead to massive power outages.7.3 Business Risks Extreme weather conditions results in increased energy cost & higher contingency requirement results in erosion of profit margins. Business risk due to climate change includes:  Climate Change Policy Risk: With climate change mitigation driven by lawmakers, the risk of politically motivated changes to public policy towards climate change is high. Businesses that are in a carbon-intensive industry or reliant on climate change-motivated subsidies or other favorable regulation are particularly vulnerable. Conversely, most investors avoid projects with high policy risk due to its unpredictability.  Market Risk: Naturally, businesses face the risk of changes in the prices of oil, gas, electricity and, where required, carbon. To mitigate these risks, companies can either reduce their exposure or hedge the risk. At 2009 levels of carbon price, the cost of carbon is almost negligible. However: At $60 per ton carbon price, 10% of total cash flow of listed companies will be transferred from companies with below average carbon efficiency to those with above average efficiency.  Reputational Risk: Since climate change issues are high in the public mind, not to engage in the debate could cause a public backlash.Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 15 of 21
  16. 16. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10  Credit Risk: Due to increased business risk exposure to carbon price, credit rating of such entities may be at risk. For instance, Drax Power, which operates a coal fired power plant in the UK, has been downgraded in 2009 to below investment grade, thus increasing the cost of borrowing and making it unsuitable for institutional funds to invest. Other Classification for Business Risk Include risk related to:  Natural Capital: This risk threatens the natural resources or capital that many businesses rely on for raw materials (forests, fisheries, agriculture) or indirectly (real estate, tourism, retail, restaurant). For example, even if your business does not depend directly on natural capital you still need to ask about your suppliers and customers.  Government Policies: There is a risk that policies will influence the market to favor less greenhouse gas-intensive businesses, products and services.  Customer and Public Pressure: Whether you sell business-to-business or directly to consumers, your customers will increasingly prefer climate-friendly products.7.4 Competitiveness Risk Has Effect on Gross Refining Margin. As energy costs increase, Oil industries using conventional and carbon intensive energy sources will see a reduction in the GRM.7.5 Regulatory risks ‘Carbon ’tax’ implementation on states by Central government can affect profitability of the Oil & Gas sector7.6 Financial risks Just as continuing with business as usual poses financial risks for society, and insurers in particular, so a switch to renewable could result in the loss of value in investments in the fossil fuel economy. This has been used as an argument by the affected lobbies to deter action on limiting emissions. The cost of mitigation depends crucially on the target level of greenhouse gases that is selected as "safe" and the timing of action. For a level of CO2 around of 550 ppmv (parts per million by volume), which is roughly twice the pre-industrial level, the pure economic costs are at a global level are minimal, and are in fact offset by side-benefits e.g. cleaner air quality, provided that an early start is made on addressing the problem to avoid locking-in further investment in "dead-end" technologies.Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 16 of 21
  17. 17. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 This point becomes more acute at the level of industry sector or individual company, since they are vulnerable to substitution by the new technologies. For example " Changing Drivers", a recent study by World Resources Institute & Sustainable Asset Management of the automobile industry, suggested a range of potential impacts, from +10% for Toyota, to -15% of company value for Ford if emission constraints become significant. Perceptive investors have realized this, and are now beginning to challenge company management to address these issues through a number of initiatives - Institutional Investors on Global Climate Change, Investors Network on Climate Risk, and The Carbon Disclosure Project. What is clear is that European companies are already aware of the issue and have started to plan for a carbon-constrained world, but other regions, particularly USA are lagging behind. This is symptomatic of a second key point that the commercial world needs clear.7.7 Threat from Renewable energy Renewable energy facilities generally require less maintenance than traditional generators. Their fuel being derived from natural and available resources reduces the costs of operation. Even more importantly, renewable energy produces little or no waste products such as carbon dioxide or other chemical pollutants, so has minimal impact on the environment. Renewable energy projects can also bring economic benefits to many regional areas, as most projects are located away from large urban centers and suburbs of the capital cities. These economic benefits may be from the increased use of local services as well as tourism.8.0 CHANGE DRIVER FOR OIL AND GAS COMPANY Inevitable climate change will have impacts for all companies, but oil and gas companies can be particularly vulnerable. The key drivers for adaption will be found in regulatory and legal liabilities, changes in cost and revenue profiles, market transformations, stakeholder interest. Some examples of how these drivers are beginning to affect oil and gas companies and how they are anticipated to change over the next few years are outlined below:Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 17 of 21
  18. 18. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 CHANGE DRIVERS StakeHolder s Oil and Regulations Gas Market Company Cost and Revenue8.1 Regulatory and legal drivers: As the impacts of climate change become more direct, we are likely to see governments resort to prescriptive regulation and statutory controls to ensure that oil and gas companies providing essential infrastructure take appropriate action on adaptation. In the United Kingdom the Climate Change Act 2008 gives the government the power to require oil and gas companies to assess and disclose the impacts climate change might have on their business. The wealth of information on the impacts of climate change from the scientific community, academia, research institutions, government, trade associations, and NGOs is so great that it would be difficult for a senior executive or professional advisor to claim ignorance when challenged. As the financial impacts of climate change are further recognized, we are likely to see litigation used to recover costs incurred as a consequence of failures to account for changing climatic conditions. There is increasing pressure for companies to disclose how much the decommissioning of oil and gas infrastructure will cost the company. The UK government recently updated the Petroleum Act, tightening the laws on decommissioning, making it compulsory for companies to take the impacts of climate changeAnil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 18 of 21
  19. 19. Analysis of impact of climate change on Oil and Gas majors Exe-MBA10 into account in their activities. This is bolstered by 70 countries that have mandated the use of the IFRS (International Finance Reporting Standards), which includes obligations on decommissioning. More stringent design standards from regulatory bodies are likely to continue to arise.8.2 Cost/revenue drivers Operational costs at refineries are likely to increase in response to changes in asset efficiency and resilience with higher ambient air temperatures. Disruptions to transport links due to permafrost thaw is already having significant impacts with companies having to hold and maintain larger onsite spare parts and materials stores. Increasing water resource issues has become a major incentive for companies to introduce water management measures. Operational costs could increase in response to changes in design standards for offshore platforms. Hurricanes Ivan, Katrina and Rita all produced conditions that exceeded the offshore platform design wave height requirements. Climate change will put more pressure on insurance for oil and gas companies.8.3 Stakeholder Investors and other stakeholders, including market and financial analysts, governments and regulatory agencies, research institutions, consumers, local communities and NGOs – are already starting to place greater pressure on oil and gas companies to address climate risks and opportunities. Corporate operations are increasingly scrutinized in the context of climate change, for example: • There are signs that there could be increasing numbers of lawsuits filed against oil and gas companies due to their activities • Banks are looking at the lending risks associated with project finance.8.4 Market Drivers Energy underpins our social and economic systems. Access to reliable and increased supplies of low- carbon energy are essential to meet the adaptation needs arising from, for example, increasing urbanisation, agriculture (to improve yields and manage drought), transportation, the built environment (to cool buildings), potable water supplies, drainage and waste water treatment. Peak demands will increase in summer months in response to increasing temperatures and the need for energy for cooling. Changes in energy demands for space heating, transportation and other climate sensitive processes such as pumping water for agricultural irrigation and other industrial and domestic uses are already taking place. Oil and gas consumption has fallen in the USA, Europe and Australia with warmer winters reducing the need for energy for heating.Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 19 of 21
  20. 20. Analysis of impact of climate change on Oil and Gas majors Exe-MBA109.0 SUMMARY: BUSINESS PERSPECTIVE ► Climate change and global warming: major threat to the Oil & Gas industries. ► The Oil & Gas sector will be a significant part of an evolving solution to the CO2 challenge and certainly drive the ushering of a cleaner hydro carbon age in future. ► Companies have already started pursuing strategies to position themselves in the cleaner, more sustainable and low carbon growth trajectory by conscious reorganization of their product portfolio and restructuring of their multi-location operations. ► Big Oil Companies like British Petroleum is planning to invest USD 8 billion in low carbon power and alternative energy business over the next decade and aims at USD 1 billion of operating profit by 2015 from this business only. ► Adoption of the right strategy for mitigating long term climate change risks can provide distinct competitive advantage. ► Companies seeking to develop their strategies should first analyze their ‘value-at-stake’ or ‘value- at-risk’ under a variety of scenarios from current and emerging policies to reduce carbon emissions.Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 20 of 21
  21. 21. Analysis of impact of climate change on Oil and Gas majors Exe-MBA1010.0 REFERENCES 1. 2. 3. Ernest & Young, Climate change issues in Oil & Gas Sector; PPT. 4. Strengthening Legal and Policy Frameworks for Addressing Climate Change in Asia: India. Professor Dr. Bharat H. Desai. Center for International Legal Studies, SIS Jawaharlal Nehru University; New Delhi. --- End ---Anil Kumar Sahu (20104004); Sandeep Prasad (20104005); Sarjeevan Sainbhi (20104006) Page 21 of 21