Analysis of the Rapid EIA report prepared for JSW ENERGY LTD’S (JSWEL) 2x660 MW coal based thermal power plant at Kukurda, Nawapara, Dumarpalli, Chhuhipali and Salhona villages of Raigarh Tehsil, Raigarh District, Chhattisgarh | Centre for Science and Environment

Analysis of the Rapid EIA report prepared for JSW ENERGY LTD’S (JSWEL) 2x660 MW coal based thermal power plant at Kukurda, Nawapara, Dumarpalli, Chhuhipali and Salhona villages of Raigarh Tehsil, Raigarh District, Chhattisgarh

Background of the report
JSW Energy Limited (JSWEL) is planning to set up a thermal power plant at Kukurda, Nawapara, Dumarpalli, Chhuhipali and Salheona villages of Raigarh Tehsil, Raigarh District Chhattisgarh state.
This report is a technical evaluation of the Environment Impact Assessment (EIA) document submitted by JSWEL as part of the clearance process for a 2 x 660 MW coal based thermal power plant in villages of Raigarh Tehsil, Raigarh District.The EIA has been conducted by the Hyderabad based VIMTA labs limited.The study area for the EIA includes a core zone (area to be occupied by the project) and a buffer zone (area within a 10-km radius of the project site). 
About CSE
Centre for Science and Environment (CSE) is an independent, public interest research and advocacy organisation, which aims to increase public awareness on science, technology, environment and development. The Centre was started in 1980.
For more than two decades, CSE has been creating awareness about the environmental challenges facing our nation. It has been:
• Searching for solutions that people and communities can implement themselves, 
• Challenging the country to confront its problems, 
• Inspiring it to take action and, 
• Pushing the government to create frameworks for people and communities to act on their own.
About the project
This project is in line with the central government’s massive power capacity addition plan in the XIIth Plan. JSWEL would assist in meeting the increased demand of power in neighboring states and in this connection has entered into a Memorandum of Understanding (MOU) with Government of Chhattisgarh. 
Domestic coal will be considered as main fuel for the project. In the proposed power plant, two Pulverized coal fired super critical boilers will be installed which will be fired on coal sourced from areas located at a distance of 60kms from the site. 
A Railway siding / MGR system of 5 km approx will be drawn from Jamgaon railway station to the project site to transport the coal from the mine.
The technology used is that of Steam Generator units and the Steam parameters considered are in accordance with super-critical technology.
Salient features of the project
Location: JSWEL wants to set up the thermal power plant in at Kukurda, Nawapara, Dumarpalli, Chhuhipali and Salheona villages of Raigarh Tehsil, Raigarh District.
The site is approximately 14.2 kms away from Raigarh and 5.6 kms off the National Highway (NH 200).
The Chote Kelo Nadi flows at a distance of around 2.5 km and Kelo Nadi at a distance of 6.9 kms from the proposed site.Back waters of Hirakud reservoir also forms one of the nearest water bodies. There are no streams or nallas in the project site.
Raigarh district is an emerging hub for the sponge iron industry with industries such as MSP sponge iron plant, Jamgaon, Ind Synergy sponge iron plant, Mahapalli, Shiva Shakthi sponge Iron Industries, Shalkambari Industries, Mamangala Industries  within a  distance of 10 km from the plant site.
Seismically, the site falls under Seismic Zone-III.
Fuel: The plant will source its fuel requirement from SECL / MCL mine nearby; part of the coal may be sourced from JSW share of coal from Utkal, Orissa. 
The coal grade from the prospective mines is expected to be of grade F or G with an ‘as received’ calorific value of approximately 3500 Kcal / Kg. The project requires 6.94 million tonnes of coal per annum.
The project will also require some Heavy Fuel Oil (HFO) and Light Diesel Oil (LDO) as secondary fuel. According to the EIA report, in the proposed power plant, the required HFO/LDO will be 9828 Kilolitres per annum.
Water requirement: The project will require 35 million cubic meters of water (MCM) per year (or 2403 m3/hr) which will be sourced from Mahanadi River located at a distance of 48 kms from the project site. 
• According to the website of Ministry of Environment and Forest, from 2005 to 2009, the minstry has been given clearance to 30,580 MW power plant which have proposed to draw water from the Mahanadi. According to the estimation made by us, all these power plant will draw 2787044 m3 of water per day (assuming load factor 80% and specific water requirement 5 lit/unit), this is signifigant quantity and cummulative impact on water availability would be very high if all the plant starts its power generation. 
• Addition of one more thermal power plant of 1320 MW would create additional pressure of water per day on the Mahanadi. Hence it is a big question mark, whether river Mahanadi has suffieciet flow or water to support the power plant in Raigarh. 
• And second important question is the cummulative impact on lean flow ie. during summer.The river flow data, particularly the lean period flow (i.e. in summer) is cricial because River Mahanadi is being heavy exploited by the industries in the Chattisgarh.
• Every industries in Chattisgarh claimed that they would draw water from Mahanadi but failed to provide whether river has suffiecient water to hold industries or not. 
• Meanwhile, River Mahanadi also supplies water to number of cities and iriigation canal for agriculture for example  cuttack city draw 11000 m3/day of water and Bhuneshwar 43000 m3/day for city supply. This clearly shows that Mahanadi is  extensively used not by chattisgarh but also Orissa is also heavy dependent on the Mahanadi.
Land use pattern: The land identified for the proposed project is about 321 ha or (792) acres comprising of 5.2% Government land and 94.8% private land.
About 92% is agricultural land (single crop land) and 8% is barren land. 
The plant site topography is mostly plain with a general elevation of about 208-m above MSL. 
Figures in the EIA report (chap 4) states that the agricultural area in the proposed plant site does not have any irrigation system and is only rain-dependent
The Boiradadar, Jharadipa, Kukurda, Chitkikharu, Gajmar, Dhanbush. Garjanpahar, Natkidungri, Sukhadihi, Jargan, Patrapali and Barkhachar reserve forests are located within 15 km radius.
13.11 per cent of the area (3323.64 hectares out of a total of 25352 hectares) is forested (Annexure-vii).
4.83 per cent of the area (1223.45 hectares out of a total of 25352 hectares) is irrigated (Annexure-vii).
51.79 per cent of the area (13128.86 hectares out of a total of 25352 hectares) is not irrigated (Annexure-vii).
The EIA  report shows the following discrepancies- 
• According to the EIA report the land identified for the proposed power plant project is mostly un-irrigated single crop agricultural land and barren uncultivable waste land but the same EIA report also mentions in chap 2 that 92% of the land is agricultural (single crop) land and only 8% of the land is Barren land.Also the 8% land is forest land and not exactly barren land. This shows that the EIA has stated  different pieces of information in two different chapters.
• Secondly, the diversion of such a huge patch of productive land would have significant negative impact .However, the EIA remains silent on this and contradictly states that no major loss of agricultural productivity is expected
• No elaborate details of the compensation to be provided  such as the type of compensation ,arrangements made, steps taken for private owners losing their lands have been explained.
• EIA has failed to address the impact on the top soil. If we see in term of land requirement, the project will acquire 321 ha of land for the project. The plant will clear 256 ha of land for the different activities, it means expect 65 ha of land for the greenbelt, rest will be use for the plant development. According to CSE estimation, quantity of top soil to be generated as result of land clearing would be approx 12 lakh m3 (Assuming 0.5 m is the thickness of topsoil and 256 ha of land to be cleared). It is a big question mark, how a power plant will use such huge quantity of top soil and where they will use this top soil.
Human Habitation According to the EIA report there are sparsely distributed villages in the buffer zone (chapter 4). However
• There are 69 inhabited villages in about 10 kms dist from the project site.
• Around 51,235 people reside within 10 km radius
• Also 6076 people reside within 3kms itself.
• Some of the nearby villages likely to be effected are Dumarpalli, Salheona, Kukurda, Keshala, Mauhapali, Kari Chhapar and Chhuhipali all lying within 3 kms.
This is an example of false and misleading information given by the EIA report as the area within a 3-km radius itself is densely populated as per the figures above, also taken from the EIA report.
Environmental impact of the project and the analysis of the EIA report
1. Impact of water consumption by the project
Thermal power projects are normally water intensive, and the impact on local water resources is one of the major impact areas.
The project will require 35 million cubic meters of water (MCM) per year (2403 m3/hr), which will be sourced from Mahanadi River located at a distance of 48 kms from the project site. Irrigation department of Chhattisgarh govt has indicated the availability of sufficient water in the river. As the required water is available even during lean season and as no groundwater source is proposed to be tapped for meeting the water requirements during operation of the power plant, no impacts on groundwater resources is envisaged.
Some of the discrepancies noticed in the report are as follows-
• The EIA simply states repeatedly that the Chhattisgarh govt has already allotted the desired quantity of water and has confirmed its availability in river Mahanadi. However, the EIA remains silent about the capacity of the river, the stress likely to be caused on the river, impact of this water demand on the surrounding human habitation and other such essential details. 
• EIA has proposed to take 2403 m3 of water per day from the Mahanadi river but failed to provide technical information of the river flow information and water availability in Mahanadi to support this plant in especialy in the lean period. EIA also failed in providing the other competative users and other industrial plants downstream who are also dependent on Mahanadi.
• Also on calculating the average consumption of the coal based power plant using 85% plant load factor and 4.5 to 5 per unit, the water requirement of the plant comes upto more than 5000 m3/hr. However the EIA reports only need for 2403 m3/hr, which is very less compared to our calculated figure.
• Moreover the EIA report fails in providing technical justification for achievement of the plant’s low water requirement figure.
• According to the report about 60-m3/hr of wastewater will be used for ash handling system, 30 m3/hr used for green belt and 2 -m3/hr is in the form of sludge. 
However according to the above information it would mean that 720 m3 per day would be used for the green belt which occupies only 160 acres i.e. around 4.5 m3 per acre per day. This is a huge amount of water for a small patch of land.
This only seems impossible, as it would lead to flooding of the area.
• Plus no information is provided about the rainy season when there will be no need to water the green belt and the usage of this water during the same.
• Remaining 533-m3/hr of wastewater will be collected in Effluent Collection and Equalization Tank (ECET), treated in Reverse Osmosis plant and re-used for cooling tower make-up. Here again no information about the Reverse Osmosis, its cost and its capacity is given.
• The EIA states that the storm water in the project area will be collected through storm water drains and collected in the storm water tank, which is lined to prevent any contamination of ground water, which will be utilized in the plant operation resulting in conservation of fresh water. Here the material used as the lining material has not been mentioned.
• As per the report EIA claimed that suitable rain harvesting pits will be provided along the storm water drain to recharge the ground water table. For rain water harvesting, EIA has provided a very superfical information. EIA failed to provide techanical details on rainwater harvesting structure, budget allocated, time schedule of the same.
• According to the EIA, sanitary effluent will be treated in sewage treatment plant. However the dimensions, capacity or cost of the sewage plant have not been mentioned.
• The EIA mentions a raw water storage provision in the plant site, but fails to mention the details such as cost, capacity or dimensions.
It also states that the reservoir will be lined, but does not again as above, mention the material used for lining.
• Similarly no elaborate information has been provided about the water treatment plant again such as cost, capacity or dimensions.
• The ash pond is located in the east direction according to a map in chapter 2, the river Mahanadi also flows in the same direction. This has not been mentioned in the report at all. Neither have mitigation measures been mentioned for the problems likely to result because of this. 
• The report mentions that the plant will follow the Zero discharge rules, but fails to explain how.
On the whole the EIA presents the reader with misleading and incomplete    information in this section.
2. Impact of the project on local air quality
The coal based thermal power plant is hugely air polluting. Assessment of the impact of air pollutants on the surrounding environment is therefore very important in the EIA. Suspended particulates, sulphur dioxide (SO2), oxides of nitrogen (NOx), carbon dioxide (CO2) and emissions of mercury have to be estimated, and their impact assessed.
Particulate emissions
According to the EIA report,( chap 4 ) the concentration of outlet gases will be at each of the two flues at most 50 mg/Nm3. 
So, the SPM emission rate will be 1979 tonnes/ annum.
 High efficiency (>99.9%) electrostatic precipitators are proposed to be installed to limit the particulate matter emissions to below 50 mg/Nm3.
• EIA states that ESP will be installed with the stack as a pollution control equipment and claims that the emissions from stack will be less than 50 mg/Nm3. However EIA report fails to provide any techanical specifiaction of the ESP such as the number of fields and area of collecting electrodes etc. 
• Moreover, EIA also state that they will use coal having ash content in range of 40 to 45%. In such high ash containig coal and lack of techanical specification on ESP, it is doubtful that ESP will achieve the standard of  less than 50 mg/Nm3
• Also since the area has many coal based iron plants within 10 kms , when the particulate  emissions from all the plants will be added the figures will be significantly high and will cause severe damage to the environment. 
SO2 and NOx emissions
Sulphur dioxide (SO2) emission rate (Based on 0.5 of Sulphur) in each flue is 1291.38 g/s/flue, its value on an annual basis would be approx 73,640 tonnes/annum. 
• The EIA report has not paid attention to the control of SO2 emissions – not sufficient mitigation measures have been suggested. SO2 emissions even at low concentrations can be detrimental to some kinds of plants. They can cause decreased yields, chlorophyll loss and greater leaf fall. The impact of SO2 emissions is even higher under humid and high wind conditions. 
• Also since the area has many coal based iron plants within 10 kms , when the SO2 emissions from all the plants will be added the figures will be significantly high and will cause severe damage to the environment. 
Oxides of Nitrogen (NOx) based on 9 kg of NOx/ ton of coal burnt is 1,162.24 g/s/flue which amount to approx 66,276 tonnes/annum.
• The report has not suggested many mitigative measures 
• The EIA report states that “To reduce the NOx emissions from the steam generator, all provisions in the steam generator design and fuel firing system will be made”. But the report fails to explain the provisions.
Mercury emissions:
Mercury as Hg emission according to EIA is 0.051g/s/flue. Which is approx 2.908 tonnes/annum. 
• There is not much mention of impact analysis, mitigation for mercury emissions. This should not be ignored, as thermal power plants account for 70 per cent of the country’s mercury emissions. 
• Raigarh in future would be worst affected by mercury contamination, according to Ministry of Environment & Forest website, in Raigarh alone ministry has given clearance to 21,205 MW in between 2005 to April 2009, this figure is excluding of power plant prior to 2005.
• A single proposed plant of 2x660 MW has potential to emit 2908.224 kg of mercury every year; one can imagine the quantity of mercury to be emitted from 21,205 MW. This is a significant issue for the Raigarh district.
Carbon dioxide emissions: 
• The EIA has also completely ignored CO2 emissions from the proposed plant. 
• Neither has the EIA given detailed information about the emissions nor has it mentioned its impacts.
 This is not acceptable, as the thermal power sector contributes 11 per cent of total CO2 emissions, 65 per cent of the industrial greenhouse gas emissions. On calculating the carbon dioxide emission using the formula 997gms/unit(according to CPCB guidelines) , the proposed plant will release approx 8.8 million tonnes of carbon dioxide per year.
Fugitive emissions
Regulations governing air pollution concentrate on point source emissions – however, emissions from non-point sources, i.e. emissions during raw material storage, transportation and handling are equally important to monitor and control. In fact, often, fugitive emissions are more harmful than particulate emissions. 
The fugitive dust emissions expected are from coal storage yards, coal conveyor belt area, ash dumping areas, transportation of fuel and solid waste. 
If 0.4kg/h/hr of fugitive emission is obtained,this will mean approximately 1013.76 tonnes of dust per annum.
The following discrepancies have been observed- 
• The EIA report for the proposed project has not made any estimation of fugitive emissions.   
• According to the EIA report, the fuel will be received through rail line and the solid waste will be sent to dyke areas through pipeline. Hence, no dust emissions from transportation are envisaged. But in chapter 2, it is said that transportation of construction material may even take place by road and hence, potential of fugitive dust will be the greatest threat.
• Also the EIA has mentioned superficial mitigation plans such as ‘water spraying’ as a means of controlling emissions. Whereas the only way of controlling fugitive emissions is through proper infrastructure and proper management
Best practices in the reduction of fugitive emissions would be closed storage areas, mechanical material handling systems, and wherever possible. The EIA report has not elaborated on many of these points.
• There has been no effort to convert nonpoint sources to point sources through creation of vacuum or suction which is one of the main steps to control fugitive emissions.
The fugitive dust emissions are to be controlled by installation of closed conveyor system along with suitable dust suppression measures. 
Measures have also been adopted to control hydrocarbon emissions according to the EIA.
Fly ash 
Apart from coal, fly ash is also a source of fugitive emissions. 
Ash Content in Coal is approx 41%.
An estimated 3.123 million tonnes of ash (fly ash (2.498 MTPA) and bottom ash (0.625 MTPA)) will be generated every year, and all of this will be highly susceptible to fugitive emissions. 
These issues are particularly important with respect to the storage and handling of fly ash. If ash is stored in the open, or handled manually, the potential of fugitive emissions is very high given the extremely fine nature of ash particles.
Around 112 acres out of 792 acres has been allotted for Ash disposal.
Some of the discrepancies in the EIA report are as follows-
• Dimensions and details of storage of fly ash/ bottom ash have not been mentioned.
• The report states that “100% ash water recovery system would be provided to recover and reuse the ash pond water” but how 100% ash water will be recovered has not been mentioned.
• EIA fails to provide % of ash handled in dry form and % of ash in slurry form.
• There is some discrepancy in the report as it states at one place,100% ash will be disposed off in slurry form where as elsewhere the same report mentions that ash will be disposed in dry form.
Monitoring impact of air pollution
The monitoring has been conducted during post monsoon and part of the winter season (1 Oct to 31st Dec 2009). 
• Therefore, given the nature of the project site, and the location of other polluting industries in the vicinity (sponge iron plants), Emission values have been calculated i.e modelling has been done taking only the emission of the particular plant in consideration and not keeping in mind emission from all the industries surrounding it.
• According to the EIA report, most prevalent wind directions are northeast and southeast post monsoon, Northeast and northwest during winter.  The most prevalent wind directions near the project site annually are NE and SE. Therefore more monitoring sections should be present in the above mentioned direction but it is not so.
• Also the most probable wind direction is towards the existing forested area. Deposition of fly ash in the forests as it tends to get arrested in the forested area leads to a huge negative impact.
3. Local biodiversity
The region surrounding the proposed site is rich in biodiversity. 
There are around 8 Reserved Forest blocks in 10-km radius from project. The forest blocks consist mostly of Salai, Tendu, Mahua, Saja, Char Ganja, Dhauwra, Harra and Dhobin.
As per the EIA report a maximum 288 number of plant species were recorded from the study area.
According to the EIA report, 82 animal species were recorded/reported from study area during study period, out of which 1 species belongs to Sch-I, 8 species belong to Sch-II, 4 species belong to Sch-III and rest of the species belong to Sch-IV and Sch-V as per Wildlife Protection Act, 1972.
However the ecologically-rich study area is now facing the brunt of this proposed project. 
4. Solid waste management
Ash is the main solid waste generated in the coal based thermal power plant.
Major portion of the ash will be utilized by supplying to potential users. Efforts will be made to utilize 100% fly ash as per the Fly Ash Notification, 1999 and its subsequent amendments.
• However, the project has not incorporated reuse of fly ash as part of its operations – i.e. there is no mention of whether a brick making facility will be set up, or whether users of fly ash (like cement manufacturers etc.) have been identified and long-term contracts signed to ensure use of the fly ash generated. 
• Experience shows that unless proper mechanisms are set in place, fly ash will not be used even if it can be used. Therefore, just implying that fly ash may be used does not mean that it will actually be used.
• No data on the expected for reuse of fly ash or how 100% reuse is expected is mentioned.
• According to the EIA report, Ash pond will be provided with HDPE liner to prevent leaching of contaminants to groundwater however even though the report mentions HDPE liner, no details about the budget allocation, dimensions, etc are given.
JSWEL’s proposed thermal power plant is not a small-scale project. Main impact areas of the project – would be its impact on local biodiversity and agricultural productivity.
A major setback of this EIA report is its lack of clarity and sound information in many cases like that on the stress likely to be caused by this project on the river.
 It is the site of the project that will play the largest role in deciding its overall environmental impact. The region is eco-sensitive for many reasons, the forests are home to many species and moreover forests play an extremely important role in groundwater recharging. 
The ecology in the area is already facing the impacts of many industrial projects- many coal mines, and many sponge iron plants. The impact on the local ecology will be cumulative. 
Also the area is a productive agricultural area which would result in significant   negative impact.
The biggest weakness of the EIA report is that it has not been able to capture the overall, cumulative impact of the project and it remains silent on many issues providing no useful information at many places.

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