EIA analysis of coal washery at Raigarh

August 31, 2010

A coal washery Plant is being proposed by M/s Sarda Energy & Minerals Limited., (SEML). Ekta Parishad, on behalf of the local communities of Raigarh district of Chattisgarh, has requested us to technically evaluate the Environmental Impact Assessment (EIA) document of Coal Washery Plant of 400 tonnes per hour throughput capacity at Village Bajarmura – Dholnara in Tehsil; Gharghora (now Tamnar, District Raigarh of Chattisgarh.

M/s Sarda Energy & Minerals Limited., (SEML) formerly known as Raipur Alloys & Steel Ltd is in a process of state of the art coal beneficiation facilities to meet the demand of washed coal for captive Sponge Iron Plant at Siltara, Raipur (CG). M/s. SEML has been allotted a captive coal block Gare Palma IV/7 at Karwahi, Tehsil Tamnar, District Raigarh, which is about 200 KM from their Steel Plant at Raipur. It is proposed to install a Coal Washery Plant of 400 tonnes per hour throughput capacity.

About the project

M/s Sarda Energy & Minerals Limited., (SEML) formerly known as Raipur Alloys & Steel Ltd is in a process of state of the art coal beneficiation facilities to meet the demand of washed coal for captive Sponge Iron Plant at Siltara, Raipur (CG). M/s. SEML has been allotted a captive coal block Gare Palma IV/7 at Karwahi, Tehsil Tamnar, District Raigarh, which is about 200 KM from their Steel Plant at Raipur. It is proposed to install a Coal Washery Plant of 400 tonnes per hour throughput capacity.

M/s Sarda Energy & Minerals Limited., (SEML) requested State Level Expert Appraisal Committee for miner change in location of proposed coal washery due to shortage of area for O.B. dump for which it got permission.

The change in location is given as below:

Old Location                                                   New Location

Village: Karwahi  & Khamria                           Village – Bajarmura - Dholnara

Tahsil –Gharghora (now Tamnar)                   Tahsil – Gharghora (now Tamnar)

District – Raigarh C.G.                                    District – Raigarh C.G.

Project location: The coal Washery plant of 400 tonnes per hour throughput capacity is proposed at village Bajarmura – Cholnara, Tehsil Gharghora (now Tamnar), District Raigarh. Total proposed area is of 10.12 Ha (pit head coal washery adjacent to captive coal mine at Karwahi). Size of the project is 400 X 300 X 8, 0.96 Million TPA coal washery.  The plant would be operating for 300 day, 8 hours per day. Source of coal is captive coal mine at Karwahi (Gare Palma Block IV/7)

The basic objective of the project is to:

• To provide with washed coal for the proposed coal beneficiation plant which in turn is being proposed to meet the demand of washed coal for captive Sponge Iron Plant at Siltara, Raipur.

Technical Report

There are several drawbacks in the quality of the EIA report. The report is poor in terms of assessing the impacts of the project on the environment. Some of these drawbacks/lapses are presented below:

1. Water balance given in the report states that source of water would be mine seepage. However details regarding how much mine seepage is produced in the mine, how it is stored and how it will be reused is absent in the report. The use of mine seep in coal washery is thus subjective in nature and cannot be cleared.

   The water balance in the report does not clearly specify the discharge of wastewater or zero discharge plans that it claims, it’s not clear as of how would the process water of 364 m³/day will be reused and discharged. Evaporation loss could not be accounted for such huge amount of water to be evaporated and not getting discharged at all. Overall the balance in water balance is not clear. Accounting of water and makeup water is not clear in the water balance of the project.

   The mine seep water that the project claims to use is ultimately the ground water; hence the project would directly or indirectly impact the ground water regime of the area. This ground water would already be affected due to the mining which would increase due to the coal washery. Also the distance between the mine and coal washery is not specified, transport of this mine water for the coal washery is not specified, Hence data regarding water balance is inadequate to predict  the impact on water regime.

   Coal yard drainage will be stored in a separate sump (page no. 4.8). However what will be done of this coal yard drainage after storage is not specified in the report. Method of disposal or its impact on the nearby areas has not been justified in the report.

2. Cumulative impact of the project:Already a coal mine exists in close vicinity. This would have severe impact on the surrounding environment and the social setup of the area. The coal washery would only increase the impact on these. The report fails to provide the cumulative impact of the mining activity and the coal washery on the nearby areas. It has claimed its impact based on individual activity. The report also fails to specify location of other industries in the nearby areas and cumulative impact of these industries.

In land use of the study area, the report does talk about a power plant in the 10 Km radius of the project. However it does not discuss the impact of all the industrial activities on the nearby areas and people residing in them. The distance of different industries in the nearby area is also an important factor in determining the cumulative impact which has been left out in the report.

3. Land use: Land that would be acquired for the coal washery comprises of 28.26% of forest land.  Impact of this forest land is not discussed in the report. The report fails to asses the impact of such huge forest land that would be destroyed for the coal washery. Nor does it talk about the flora fauna that depends on the forest and livelihood of the tribal who strive on this forest.

Agriculture land in the study area comprises of 57%. The yield of this agriculture land is claimed to be reducing. This can be attributed to the industrialization or the mining in the nearby area. This project would aggravate this loss of agriculture. Thus the impact prediction on agriculture land due to the project is being underestimated in the report. People depending on these agriculture lands would be affected largely due to the upcoming project which cannot be avoided. Mitigation plan does not talk about improving the livelihood conditions or the agriculture yield of the fields in the study area.

Details of the land acquisition for the project and impact of this land acquisition on the village is not given in the report. Land acquisition is a crucial stage in any project and this would have huge irreversible impact on the people whose land would be acquired or person whose livelihood is dependent on the land. Number of people dependent on the forest, agriculture land or forest for their livelihood is not specified in the report which makes the report week in terms of assessing the impact of the project on the livelihood of the people residing in the nearby villages.

4. Impact on water bodies:The area is surrounded by number of water bodies. Impact of a coal washery would defiantely be on these water bodies. Such an impact has been neglected by the report. Nor does the report talk about any mitigation measures for the water bodies that would be impacted due to wash water that might get discharged in the river. Two major rivers, River Kelo and River Pajhar are flowing nearby to the site. The coal washery would defiantely have impact on these rivers which is not being predicted by the project proponent,

The contour of the area is towards the water bodies; this would lead to siltation in the river and overflow from the washery to flow into the rivers and other water bodies. Kelo River is used for domestic purpose by many people in the surrounding areas hence the impact on the river cannot be neglected and proper mitigation plan has to be given in order to protect the pristine water bodies of the area. .

5. Impact on reserved forest: The coal washery is located near to Silot reserved forest and other smaller forests. How much ever pollution abatement is followed, this would have impact on the reserved forest. The forest would already been damaged due to the nearby mining activities. This impact has been neglected and biodiversity of the area being sensitive cannot be neglected. Proper conservation plan for the forest area has to be worked out for the nearby forest areas which will be affected. The report fails to notice the crucial impact of air pollution from the coal washery on this reserved forest. Flora and fauna in this reserved forest cannot be neglected and impact on these flora and fauna by the project is claimed to be less which does not get justified in the report.

6. The loading and unloading areas for the coal are open. This would give rise to dust and air pollution. This has to be closed in order to decrease the air pollution in the nearby areas and hazards that it might cause due to the dust. Maximum amount of air pollution is generated in handling of coal. This would create a nuisance for the nearby local people. This impact has to be mitigated suing proper measure like covering the area. Loading and unloading mechanism is not properly disclosed.

7. Employment generation:Employment generation, as stated in the report will be provided to the local people. However this is subjective in nature, since no plan is discussed regarding the same. Number people that will be employed, percentage f locals that would be employment in the washery and other details are not specified. Thus inadequate details makes the employment generation subjective in nature.

8. During construction phase, huge amount of dust will be generated. This would have severe impact on the close by bio diversity, forest areas as well as people residing in the nearby villages. Sprinkling of water is inadequate in terms of mitigation measure that is being proposed by the project proponent. Proper care with respect to air pollution during the construction phase has to be taken which the report fails to address.

During operational phase, coal handled in the washery is around 3200 tones/day. Due to such huge amount of coal handling, the mitigation measures followed for the fugitive dust emission control is inadequate. Sprinkling of water and dust suppression systems would not suffice to curb the impact of air pollution on the nearby areas,

9. Chattisgarh is already a smoke laden district with high air pollution. This is the result of high industrialization in the area and obviously Raigarh, district of Chattisgarh is also not spared from this impact. . Ambient air quality data from the State pollution control board or other secondary source has not been quoted in the report. This makes the air quality impact prediction liable to improper prediction. Use of secondary data along with the primary observation would have made the ambient air quality impact prediction more reliable and justifiable.

10. The solid waste generated would consist of shale sand stone etc. (page number 4.6). However, the quantity of this solid waste is not specified in the report. Nor is the impact being predicted to be non significant justified in the report. Solid waste would defiantely pose a problem when stored in stacked. The report claims to use some amount of waste in low lying areas however it does not give a proper plan for the same. Thus solid waste generated would pose a threat to the nearby people and the environment, Solid waste management plan needs to be given when amount of waste generated forma project is huge.

11. Measures to minimize the socio economic impact are specified in the report (page no. 4.9). However it is subjective in nature. As the report does not specify the budget allocation for the same, time frame in which it would be accomplished nor does it give the responsible person in for these measures to be implement. Hence it is subjective in nature.

Migration of people in the plant would create a stir in the residing people’s culture and way of living. This cannot be avoided. Total employment generation, people migrating from other areas are not specified in the report which makes the report more poor in terms of impact prediction and provision of mitigation measures. Migration is an issue that needs to be addressed.

12. Rain water harvesting has been proposed by the project proponent however it does not specify the location of harvesting pits nor does it talk about number of pits that would be used for rainwater harvesting. Hence rain water harvesting scheme in subjective in nature.

13. There will be significant increase in number of trucks (118 trucks/day as per the report page no 4.4.) due to transportation of raw material and finished goods in the area. However the report does not specify the trips these trucks would cover or the distance covered for the raw material or the finished products to be transported. However the fugitive dust emission due to these trucks would be high. Hence proper mitigation plan for traffic control and dust generation should be worked out. Also such increase in number of trucks would lead to accidents. The current scenario of accidents in the area is not furnished in the report which is an important factor to be considered when a new project with heavy transportation requirement comes up. However the report fails to capture this issue or provide any mitigation of control plan.