Analysis of the EIA Report Prepared for VISA Power Limited 2x600 MW Coal Based Thermal Power Project at Raigarh, Chhattisgarh

August 31, 2010

Background of the report

VISA Power Limited is planning to set up a thermal power project in Dumarpalli and Deveri village of Raigarh district, Chhattisgarh.This report is a technical evaluation of the Environment Impact Assessment (EIA) document submitted by VISA Power Limited as part of the clearance process for a 2 x 600 MW coal fired thermal power plant .The EIA has been conducted by GIS Enabled Environment & Neo-graphic Centre (GreenC).

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

Raigarh Thermal Power Project 2x600 MW shall be a pulverised coal fired thermal power project based on Sub-critical boiler parameters. However there are better technologies that are available in the field of Thermal Power Projects such as super-critical technology and CFBC.

The proposal involves construction and operation of two units of 600 MW.The first unit of 600MW is expected to be completed within the period of 36 months from the date of Financial Closure, while the complete plant shall be under commercial operation within 42 months.

In the proposed power plant, Pulverized coal fired sub critical boiler will be installed which will be fired on coal sourced from coal blocks in Fatepur. Merry-go- round (MGR) system is suitable as the captive coal mine is only 65km away from the project site

The technology used is that of Steam Generator units and the Steam parameters considered are in accordance with Sub-critical technology.

Coal will be transported from the mines by rail as well as road.

Salient features of the project

Location:

The proposed site is located in Dumarpalli and Deveri village in Raigarh Tehsil, District

Raigarh, Chhattisgarh. Land around 780 acres has been identified Dumarpalli and Deveri village. The altitude of the region is between 220-240 m above Mean Sea Level (MSL)

The site is approximately 20 kms away from Raigarh. The nearest railway station is at Bhupdeopur. The proposed site is located 5 km away from the National Highway 200. The nearest airport is Raipur (250 km away).

The River Mahanadi flows at a distance of about 30km from the proposed plant location.

The River Mand is at a distance of approx 2 – 2.5 km from the site

The plant area lies in catchment of two natural drains;

i) Paraspali nala

ii) Charbhatha nala.

These drains flow in north to south direction and join the Mand River in downstream of southern boundary of the plant area. Storm runoff in plant area (2.676 sq km) is carried by these two drains.

The area falls under Seismic Zone-III

The EIA report does not acknowledge the presence of other major industries in its study period such as a thermal power plant (Jindal), Cement Plant (Jindal), Sponge Iron Plant (Jindal) and Monnet Ispat (multi purpose) which is a wrong practice.

Fuel:

During initial period of plant operation, the entire coal will be sourced from SECL/CIL coalfields for which application is already been filed by Visa Power. After that the coal for the plant will be received from Fatepur east coal block

The coal grade from the prospective sites is expected to be of grade E or F with a calorific value of approximately 3500 Kcal / Kg. The project requires 7.06 million tonnes of coal per annum at 100% PLF.

The project will also require some Light Diesel Oil (LDO) as secondary fuel. According to the EIA report, in the proposed power plant, the required LDO will be 14500 Kilolitres per annum (for 2 units).

Coal Transportation and handling:

Coal will be transported by road as well as the Railway system. Merry-go- round (MGR) system is suitable as the captive coal mine is only 65km away from the project site The nearest Bhupdeopur railway station will be utilized for this purpose.

The following discrepancies have been noted in the EIA report-

• In the entire report there is no mention of the percentage of coal that would be transported by rail and the percentage that would be transported by road.

• Initially the report suggests that both rail and road network would be used (page1). Then the EIA mentions rail network for transfer of coal(page 1).Later the EIA mentions that coal from the coal block will be transported initially through road till the proposed railway network becomes operational.( page 75)

Hence the EIA report therefore gives out misleading information in the above case.

• Also the EIA fails to mention the details of the railway network that it proposes to set up or the date by which it shall be operational.

• The EIA does not talk of any mitigation measures, during transport of coal, especially in case of its transport by road which is very important as it has a significant impact.

Also the EIA states that it will construct an approach road, but does not give any specification such as dimension of the road, its budget allocation, timeline, etc.

In the report (page 83) it is also stated “Where sections of existing roads are used for transport of construction materials and machinery, subsidiary roads shall be constructed as appropriate, so that the existing roads are not significantly congested. Existing roads will also be strengthened, if required, for transportation of material, goods etc.”

However, the report remains silent on the number of subsidiary roads that will be constructed or which road would be strengthened, the number of roads that would be strengthened, the budget allocation for the same.

EIA report mentions “Suitable planning for traffic movement as per time schedule during planning stage and Practice caution in use of vehicles to avoid disturbance of regular local traffic during construction stage”. However in the entire report there is no explanation provided for “suitable planning” or in what way caution will be exercised.

Water requirement:

The project will require approx 36 million cubic meters of water (MCM) per year (or 4600 m3/hr) which will be sourced from Mahanadi River located at a distance of 30 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 1200 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 industry in Chattisgarh claims that they would draw water from Mahanadi but fails to provide whether the 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.

• The report states that the plant area lies in catchment of two natural drains but fails to provide any information such as its length, location or mitigation measures adopted by the plant for the same.

Land use pattern

The land identified for the proposed project is approx 325 ha or (780) acres.The plant site topography is mostly plain with a general elevation of about 220-240 m above MSL

Land Requirement

• Main plant facilities-180 acres

• Coal storage-35 acres

• Raw Water Reservoir - 50 acres.

• Ash Pond Area - 250 acres of land.

• Green belt -210 acres (30%)

Land Use (study area)

• The major share of the land is agricultural consisting about 299.45 sq.km (80.71%)

• Forest land comprises of 47.45 sq.km. (12.78%)

• Barren land in the area consists of 10.97sq.km (2.95%)

Land Use (project area)

• Single crop-26%

• Barren land – 21%

• Culturable waste- 3%

• Rocky outcrop- 50%

The EIA report shows the following discrepancies-

1. From the above figures it can be clearly seen that majority of the land both under the study area and project area is agricultural land which will be converted to industrial land.

The diversion of such a huge patch of productive agricultural land would have significant negative impact .However; the EIA remains silent on this.

2. The EIA report states that a separate R&R study in detail will be conducted by project proponent to assess the socioeconomic conditions of the Project Affected Household.

However, 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 anywhere in the report.

3. According to the EIA report there are no ecologically sensitive receptors within the study area in page 3.

However, the same EIA report states (page 3) that the study area is home to endangered species. No information about the respective endangered species has been provided in the report and the effect of the upcoming plant on its survival has not been mentioned either

4. The EIA report states initially that the reserve forests are beyond the study area and lie within 10-15 km of the project site. Later the report states that the two reserve forests-Urdana and Rabo are located within the study area.

In reality both the reserve forests are within 5km, with Rabo being at a distance of 3-4 kms from the site.

The EIA report, thus, provides false and misleading information.

5. EIA has failed to address the impact on the top soil clearly. If we see in terms of land requirement, the project will acquire 325 ha of land for the project. The plant will clear 238 ha of land approx for the different activities, it means expect 88 ha of land approx for the greenbelt, rest will be used for the plant development.

According to CSE estimation, quantity of top soil to be generated as result of land clearing would be approx 11 lakh m3 (Assuming 0.5 m is the thickness of topsoil and 238 ha of land to be cleared).

No precise information on how the power plant will use such huge quantity of top soil and where exactly it will use this top soil.

6. The EIA report states that it shall consider strategies to avoid soil quality degradation; however it fails to explain any such strategies in the entire length of the report.

Human Habitation

The proposed project site only includes the land of Dumarpalli and Deveri village.

According to the EIA report except for some scattered small villages habitation, No major settlement / town has been located within the study area. However

• There are 96 villages within the 10 km radius study area.

• The total population of project affected villages Dumarpalli and Deveri is 2363.

• Deveri and Dumarpalli have 284 of Scheduled Caste and 355 of Scheduled Tribe population.

This is an example of false and misleading information given by the EIA report as the area within the project affected site itself is densely populated as per the figures above, also taken from the EIA report.

Also the report does not provide the exact demographic status. It fails to provide information on the number of people likely to be displaced by this project.

Moreover the data collected in this matter is of secondary nature. Plus it is based on 2001 population census which is nearly 9 years old.

The EIA report states that a separate R&R study in detail will be conducted by project proponent to assess the socioeconomic conditions of the Project Affected Household.

There is no mention of special provisions for the members of Scheduled Caste and Scheduled Tribe which form a huge part of this population anywhere in the 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 approx 36 million cubic meters of water (MCM) per year (4600 m3/hr), which will be sourced from Mahanadi River located at a distance of 30 kms from the project site.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

• 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 4600 m3 of water per hour 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.

• According to the EIA, sanitary effluent from the plant and the township will be treated in sewage treatment plant. However the dimensions or capacity 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, mention the material used for lining.

• The EIA report states that the water system of the proposed project has been developed with maximum recycle and reuse of water, so as to minimize the water requirement for the project.

However, in the entire EIA report, it is not mentioned that there will be a subsequent reduction in water demand from 4600m3/hr to a lesser figure due to the “maximum recycle and reuse of water”.

• Also on calculating the average consumption of the coal based power plant using 100% plant load factor and 5 litres per unit, the water requirement of the plant comes up to more than 6000 m3/hr. However the EIA report shows a need for 4600 m3/hr of water, 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 EIA report Rainwater Harvesting will be implemented at proposed plant to conserve storm water. 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.

• Considering the huge quantity of DM plant(30m3/day), the EIA fails to provide further information on the same.

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, the concentration of outlet gases will be at most 50 mg/Nm3.

Per flue.So, the SPM emission rate will be 23760 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 Electrostatic Precipitators will be installed as a pollution control equipment to limit the particulate (SPM) emission below statutory limit ( 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%. 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 a coal based sponge iron plant, thermal power plant and cement plant nearby, 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 1230.95 g/s/flue, its value on an annual basis would be approx 70193.6928 Tonnes/annum.

On calculating, we get approx 70600.4 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 a coal based iron plants, thermal power plant and a cement plant nearby, when the SO2 emissions from all the plants will be added the figures will be significantly high and will cause significant impact to the environment.

Oxides of Nitrogen (NOx) emissions are 750 mg/Nm3 per flue.

When calculated according to 0.47 gm/Kwh it amounts to approx 4466.88 tonnes/annum.

• The report has not suggested many mitigative measures

• The EIA report has not paid attention to the control of NOx emissions – not sufficient mitigation measures have been suggested

According to the report very general measures have been suggested to control emissions.

The EIA report states the provision of 275m stack as a control measure for the gaseous pollutants namely NOX and SO2, which is not sufficient .Apart from that the EIA report does not give any further details of any other control measure.

There are no special measures taken to control or reduce NOX and SO2.

Mercury emissions:

• The EIA has also completely ignored mercury emissions from the proposed plant. The report remains silent on mercuric emissions.

• Neither has the EIA given detailed information about the emissions nor has it mentioned its impact

• 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 2x600 MW has potential to emit approx 1710 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.

On calculating Hg emission, it amounts to approx 1.71 Tonnes/Annum.

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 9.47 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/hc/hr of fugitive emission is obtained, this will mean approximately 44.92 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, for the control of fugitive dust emission within and around the coal handling plant, coal dust extraction and suppression systems would be provided

However the report does not elaborate on the above said, by mentioning the systems or the equipment used and speaks more of water sprinklers for dust suppression instead.

• According to the EIA report, the fuel will be received through rail line and transportation of construction material may even take place by road and hence, potential of fugitive dust will be the greatest threat.

• 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.

• No measures have been adopted to control hydrocarbon emissions.

• 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.

Fugitive emission from coal handling

The company will use 35 ha of land for the coal handling and storage. Further, coal is proposed to be stored in open, which is a bad practice from the environmental perspective. The open coal storage yard has high potential to increase the fugitive dust and also impact surrounding ambient air. Being a significant issue, EIA failed to provide mitigation measures for the same such as closed storage yard.

Fly ash –

Apart from coal, fly ash is also a source of fugitive emissions.

Ash Content in Coal is approx 40%.

An estimated 2.82 MTPA of ash (fly ash (0.56 MTPA) and bottom ash (2.26 MTPA)) will be generated every year, and all of this will be highly susceptible to fugitive emissions.

100 % fly ash utilization has been proposed. Around 250 acres out of 780 acres has been allotted for Ash disposal

• The figure mentioned above is wrong, there is no explanation how 0.56 MTPA of fly ash would be generated.

• EIA fails to provide % of ash handled in dry form and % of ash in slurry form.

• The fly ash disposal is proposed to be lined with clay. However it is not a good practice. It is advisable that the disposal tank should be lined with clay and SDPE ,which is a synthetic liner.

• Also the river Mand is in close proximity(2-2.5 km) to the fly ash Disposal site, and since it is proposed that the disposal site would be lined with clay alone, there is a major risk of contamination of the river, let alone soil and groundwater.

Monitoring impact of air pollution

The monitoring has been conducted during the winter seasons for the period from December 2009 to February 2010.

• Therefore, given the nature of the project site, and the location of other polluting industries in the vicinity, 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.

• Being a very high impact project of capacity, it should generate site specific data such as mixing height, inversion condition.

However the report fails to generate primary data, and they rely on secondary data

• According to the EIA report, the predominant wind direction was found to be north-east during all the seasons except for monsoon, where the predominant wind direction is south west. The second predominant was south west and north west.

Therefore more monitoring sections should be present in the above mentioned direction but it is not so. In fact the monitoring stations are majorly present in the opposite direction

• 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.

However, there is no mention of mitigation measures for the above said.

3. Local biodiversity

Biodiversity has been poorly portrayed by the report. The region surrounding the proposed site is rich in biodiversity.

According to the EIA report there are no ecologically sensitive receptors within the study area in page 3

The EIA report states initially that the reserve forests are beyond the study area and lie within 10-15 km of the project site. Later the report states that the two reserve forests-Urdana and Rabo are located within the study area.

In reality both the reserve forests are within 5km, with Rabo being at a distance of 3-4 kms from the site.

The EIA report, thus, provides false and misleading information.No information about the respective endangered species has been provided in the report and the effect of the upcoming plant on its survival has not been mentioned either.

The report fails to provide schedule wise information of the species present in the study area.

According to data acquired from Raigarh Forest Division there are many species of animals such as Barking deer ,Indian rattle ,Spotted deer, Bison, Wild dog, Blue bull, Indian wild boar, Hyena, Jackal etc.

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.

The fly ash disposal is proposed to be lined with clay. However it is not a good practice. It is advisable that the disposal tank should be lined with clay and SDPE, which is a synthetic liner.

According to the EIA report, Ash pond will be provided with clay liner to prevent leaching of contaminants to groundwater however even though the report mentions clay liner, no details about the budget allocation, dimensions, etc are given.

CONCLUSION

VISA Power Limited proposed thermal power plant is not a small-scale project. Main impact areas of the project – would be its impact on 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.