Paryavaran Mitra finds gaps in draft Environmental Impact Assessment report for Tatas’ ultra mega power plant, writes to GPCB

umppBased on his study of the draft Environmental Impact Assessment (EIA) report of the proposed expansion of the Tatas’ Ultra Mega Power Plant (UMPP), operating under the banner of the Costal Gujarat Power Ltd at village Tunda-Vandh, taluka Mundra, district Kutch, senior environmental expert Mahesh Pandya has argued the IEA report has a large number of gaps, which need to be filled up. Heading Paryavaran Mitra, an environmental NGO, Pandya makes following observations in a letter to Hardik Shah, member-secretary, Gujarat Pollution Control Board, Gandhinagar:

  1. CO2 emissions: Thermal power sector contributes 11 per cent of the total carbon dioxide (CO2) emissions and 65 per cent of industrial greenhouse gas emissions.  Yet, the developers have claimed that “it would be the most energy-efficient plant in India compared to existing assets and therefore has lower Green House Gases (GHG) emissions”. The draft EIA report does not give any detailed information about the CO2 emissions, nor does it mention anything about its impact.
  2.  Impact on air pollution:  The draft EIA report says that “after the proposed expansion project, there will be increase in the level of particulate matter (PM10), sulfur dioxide (SO2), and nitric oxide and nitrogen dioxide (NOx).”  It also admits that “the predicted background concentrations at all the Ambient Air Quality Monitoring Systems (AAQMS) were found exceeding the limit of stipulated standard for PM10”. At the same time, it says, “Since the cumulative incremental value of particulate matter is only 3.9 microgram per m3, therefore, the proposed expansion project is not likely to have significant adverse impact on the ambient air quality of the surrounding area.” However, it ignores the fugitive emissions which will add up to this figure.  So ,it is very important for the developers to apply stringent air pollution reduction measures.
  3. No fly-ash utilization plan: The total fly-ash generation of the industry after expansion will be about 1,608 million tonnes (MT) per day.  The draft EIA report mentions that the Coastal Gujarat Power Ltd (CGPL) “will plan to utilize cent per cent ash in a phased manner in cement, construction industries, back filling, construction of road, agriculture, and brick making.” Yet, the EIA report fails to mention the amount of fly-ash utilized in various uses, and also does not mention any cement industry in the vicinity or elsewhere with whom any agreement or memorandum of understanding (MoU)  is proposed to be signed for buying up fly-ash.
  4. Lack of details of effluent treatment plant (ETP) and sewage treatment plant (STP):  The draft EIA report says that “the effluent from the STP will be reused for dust suppression and green belt development to the extent possible.” It adds, the treated effluent from ETP will be used for “gardening and dust suppression”. However, no information has been provided about the rainy season when there will be no need to water the green belt.  Also, it does not give any details or dimensions of the proposed ETP and STP.
  5. Lack of details of corporation social responsibility (CSR) budget:  The draft EIA report gives a lot of details about CSR plans, which it has been doing for the existing project. But it  does not mention activity-wise break up of financial commitment, nor does it give separate budget year-wise or activity-wise details of the proposed project.
  6. Impact on fisheries:  As per the terms of reference (TOR) for the draft EIA report, the impact on fisheries at various socioeconomic levels should be assessed. However, on one hand, the developers say that they have found fishing activities in the area to be “very minimal”. At the same time, they say that the CGPL is planning to carry out fresh study about the impact on fisheries after the operation of the plant starts, and then go in for mitigation measures of any negative impact arising out of it. So, if the developers do feel the need of a study, why has it not done it at this stage?
  7. Contradictory statements in the EIA report:  On page 69, the draft EIA report says, “In the study area there are three reserved forests i.e. Shiracha reserved forest in the central region dominated by prosopis juliflora, Borana reserved forest in south-east region where there was plantation of eucalyptus and acacia nilotica, and Depa reserved forest in northern region which was also dominated by prosopis juliflora. However, on page 108 it is written that there are “no ecologically sensitive areas like wildlife sanctuary and reserved forest within 10 km radius from the plant.” There is a need for justification on this.
  8. Missing details of water treatment plant:  The sea water, it is pointed out, will be utilized for cooling water make-up, ash handling system and reverse osmosis (RO) plant of the proposed power plant. But the draft EIA report gives no elaborate information about the water treatment plant, including its cost, capacity or dimensions.
  9. Zero discharge unit?:  The draft EIA report mentions that “processed effluent water will be re-circulated within the process where possible.” And if cannot be re-circulated “it will be treated to a suitable level and will be discharged to the sea”. Yet, the draft EIA report claims that it will follow “zero discharge” rules.  So, will it be a zero-discharge unit on as-and-when-required basis?
  10. Power distribution: It is not clear what will be state-wise distribution of power supplies to the five states, namely Gujarat, Rajasthan, Maharashtra, Haryana, and Punjab by the developers.
  11. Environmental clearance: The draft IEA report does not say if the developers have obtained environmental clearance for the existing unit. If this ha been done, a copy should be made public.
  12. Actual power production: The draft IEA report is silent on actual power production, water consumption, waste water generation, and solid waste generation of the existing unit during the last  few years. This should be provided.
  13. Employment opportunities: The draft IEA report is silent on how many local people are employed in the existing unit and how many local people will get employment through this proposed expansion. Details should be provided.
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