Jindal Steel and Power Ltd. (JSPL) is planning to set up a thermal power plant in village Dongamahua, located in Raigarh district of Chattisgarh. On behalf of the local community there, two activists (from Ekta Parishad and Jan Chetna) requested the Centre for Science and Environment, New Delhi, to technically evaluate the Rapid Environment Impact Assessment done for the project.
The EIA has been conducted by the New Delhi-based Min Mec Consultancy Pvt Ltd. 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 the project
JSPL is operating the Gare IV/1 open cast coal mine, along with a crushing, screening, and washing plant, in Raigarh. This mine and washery is located in Nagarmuda, Janjgir, Tapranga, Dongamahua and Dhaurabhata villages. JSPL is now proposing to set up a 2x150 MW thermal power plant in Dongamahua, which will use the middling and coal fines generated during coal washing at Gare IV/1 as raw material. The company runs a steel plant in Raigarh, and proposes to transmit the power generated by this thermal power plant to its steel plant through its own dedicated transmission network.
Salient features of the project
Location: JSPL wants to set up the thermal power plant in village Dongamahua, Gharghoda Tehsil, of Raigarh district. The site is approximately 50 kms away from Raigarh, and 30 kms off the Raigarh-Ambikapur state highway.
The Kelo Nadi flows at a distance of around 3.5 km from the proposed site. There are many seasonal nullahs, and tributaries of the Kelo, which ultimately merge into the Kelo river.
The area surrounding the project site is rich in coal, and therefore many coalmines are either operating, or are proposed. Also, industries based on coal have also come up. The 4x250 MW OP Jindal Super Thermal Power Plant is under construction 7 km away from the project site. Within a 0-7 km radius of the project site, apart from the Gare IV/1 open cast coal mine, one underground coalmine is operational 3 km away from the proposed site, and another five coalmines are proposed. Raigarh district is also an emerging hub for the sponge iron industry in Chhattisgarh, with many plants already operational and many more in the pipeline.
Fuel: The plant will source its fuel requirement from the Gare IV/1 mine located close to the project site. The project requires 2.47million tonnes of coal per annum (at the rate of 312 tonnes/hour for 330 days). Middling and coal fines will be transported to the plant site via road, or conveyor belts. The project will also require some light diesel oil (LDO).
Water requirement: The project will require 7.46 million cubic meters of water (MCM), which will be sourced from groundwater collected in the mine sump, and from borewells. The entire water requirement will therefore be met from groundwater. According to the EIA report, the water requirement will be reduced from 7.46 MCM to 6.84 MCM through recirculation and reuse of water (page 2-7).
Land use pattern: The project requires 56 acres of land (approximately 22.7 hectares). The area has a flat topography. According to the EIA report, the land acquired for the project is either agricultural or wasteland (page 2-1). No diversion of forestland has been mentioned. However, according to the same report, 25 per cent of the area (83 hectares out of a total of 325 hectares) in Dongamahua village is forested (Annexure-XI).
Also, the EIA report mentions that 26.5 per cent of the area within the EIA’s study area is forestland (Annexure-XI). 77 per cent of the forest land in the study area is under reserve or protected forests. The Tolge, Silot, Burapahar, Jamkhani and Barkachar reserve forests and the Gare and Devgaon protected forests are located within a 10-km radius of the project site.
Figures in the EIA report indicate that agriculture is a main occupation in the buffer zone. 57 per cent of the area is agricultural land, either irrigated or rainfed. Wheat, paddy, millet and maize are the main crops grown.
Human habitation: According to the EIA report, there are 94 inhabited revenue villages within a 10-km radius (page 3-31), some in Sundergarh district of Orissa, and others in Gharghoda Tehsil of Raigarh district in Chhattisgarh. Around 85,000 people reside in a 10-km radius (page 3-31). Some of the villages close to the proposed site are Libra (2 km away), Janjgir (3 km), Amgaon (3.4 km), Baljor (2 km), Dhaurabhata (2.4 km), Jharna (2.6 km), Tapranga, Jhinkabahal, Dangamouha and Sarsmal Kasampali. The mine’s colony is the nearest human habitation, located 1 km away.
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 that should be studied in good detail. According to the EIA report, the proposed project will consume 7.46 MCM of water, which will reduce to 6.84 MCM through recirculation and reuse. All of this will be groundwater – either seepage of groundwater in the existing mine sump, or water from borewells. The EIA report states that the excess water available in the mine sump is 4.39 MCM (page 4-6) and therefore the additional 2.45 MCM will have to be met from borewells.
There are some discrepancies in the EIA while calculating the water consumption. The EIA report has calculated the water consumption in the mines and the washeries using 300 as the number of working days. However, if the number of working days were to taken as 330 (as the same EIA report has subsequently done for calculating the water consumption in the thermal power plant), which is a generally accepted figure for number of working days in any industry, the water consumption would increase (0.235 MCM for the mines, and another 0.165 for the washeries).
However, there is also some discrepancy in the data provided in the EIA report, and data recorded by the company elsewhere. According to the letter dated December 6, 2005 (No.J-11015/204/2005.IA.II (M)), and written by the Ministry of Environment and Forests (MoEF) to Jindal Steel and Power Ltd. (this is the letter where the MoEF grants environmental clearance for the expansion of the capacity of the Gare IV/I mines from 2 million tonnes per day to 6 million tonnes per day), “the total water requirement of the project is 2325.27 m3/day, out of which 244.75 m3/day is drinking water requirement which will be met from ground water and remaining 2080.52 m3/day for other mining operations will be met from mine water (sump).”
Therefore, the actual water consumption by the mines is not 0.214 MCM, but 0.687 MCM.Also, the EIA report claims that the water requirement in the washeries would increase to 1,400 m3/day in the future, from the current 500 m3/day (page 4-6).This means an additional consumption of 900 m3/day. Therefore, the water requirement which will be met from borewells will be 3.23 MCM, and not 2.45 MCM.Even if the water availability and water consumption from the proposed Gare IV/2&3 mines is taken into consideration, the water consumption required would be 1.38 MCM. This is the minimum water requirement of the proposed thermal power plant, which will be met from borewells.
Also, the EIA report has calculated the average seepage of groundwater into the mine sump as 11,200 m3/day (page 4-6). Elsewhere, the report claims that groundwater seepage from Gare IV/2&3 (proposed, and not operational mines) would be 4872 m3/day. However, there is no information on how these figures were calculated. Only a rapid EIA has been done, with data collection for one season.
The EIA has tried to assess the impact of the project’s operations on local water resources by doing a simple water balance. According to the EIA report, the total groundwater recharge is 46 MCM, while the current groundwater utilisation is just 5.1 MCM (pages 3-19, 3-20). However, while assessing the impact on local groundwater resources, the EIA has not taken into account the cumulative impact of water consumption by various industrial and non-industrial sources. Apart from the huge 4x250 MW OP Jindal Super Thermal Power Plant (which is completely dependent on groundwater), the other industrial users in the region have not been accounted for in the EIA.
The EIA report has calculated the annual monsoon recharge by using the water table fluctuation method. However, the EIA has not made any estimation of possible recharge through other sources – for instance recharge through water spread areas, recharge through irrigated areas and recharge through mine discharge.
Similarly, while calculating groundwater utilisation, the EIA report has only taken into consideration domestic water consumption and water consumption for irrigation. However, if an overall groundwater balance has to be done, it is also important to calculate groundwater utilisation by others users – for instance groundwater consumption by cattle, water utilisation in forest areas, groundwater pumped out as mines discharge, and groundwater losses.For example, such a study was done by the Central Mine Planning and Design Institute Ltd. (CMPDI) while conducting the environment impact assessment for the Nataraj Underground Project in the Talcher coalfields, operated by Mahanadi Coalfields Ltd.
Another issue related to groundwater is that breaching of groundwater by mining activity has the potential to substantially alter the local groundwater regime. For instance, in the Gare IV/1 mine, the average seepage of groundwater is 11,200 m3/day (page 4-6). The other mines in the area (either operational or proposed) will also probably similarly alter the local groundwater regime. It is estimated that at Gare IV/2&3, the daily mine water seepage will be 4,872 m3/day. There are many operational and proposed coal mining projects in the area. Breaching of the groundwater table is likely to be the rule rather than the exception, since the groundwater table in the area is quite low – varying between 2-10 m below the ground. The cumulative impact of large-scale and widespread breaching of the groundwater table could have serious adverse impacts on the local water regime, vastly reducing water availability and increasing stress. This has not been given any consideration in the EIA report.
Without a comprehensive water balance for the entire area, it will not be possible to predict the impact on local groundwater resources. The Kelo river, which is one of the important sources of water in the region, is already heavily stressed. It has consequently been the focus of many protests against industrialisation in Raigarh. The poor water flow in the river has meant that various users, including industry, are now becoming increasingly dependent on groundwater. Therefore, protecting the groundwater from being excessively exploited is imperative. If industries (dependent on groundwater) come up in the region without a proper assessment of their impact, the water crisis in the area will increase to unmanageable levels. In fact, when Jindal Power Ltd. asked for permission to dig 40 tubewells for its Super Thermal Power Plant, the Groundwater Survey Department recommended against giving this permission – stating the possible adverse impacts on the local groundwater regime (ref: letter dated 15/04/2006). In yet another communication, the Water Resources Department of Raigarh, as well as the Groundwater Survey Department in Bilaspur have calculated the groundwater availability in the area as just 0.9 MCM. If this is the case, the area is completely incapable of handling the water requirement of the proposed plant (the minimum water requirement for the project is 1.38 MCM, and that too after the proposed Gare IV/2&3 mines are opened).
2. Impact of the project on local air quality
Thermal power projects are hugely air polluting. Assessing the impact of air pollutants is therefore very important in the EIA for a thermal power plant. 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: The EIA for the proposed project has estimated the particulate emissions as 64.5 kg/hr, which works out to 511 tonnes of particulate emissions per annum (page 4-3). However, according to the EIA report, this estimation is based on an assumption that the concentration of outlet gases will be at most 50 mg/Nm3(page 4-3). This is theoretically possible, but vast experiences show that even with Electro Static Precipitators (ESPs) attached, particulate emission levels < 50 mg/Nm3 are often not achieved. Therefore, it is quite likely that the particulate emissions will be much higher.
SO2 and NOx emissions: The EIA has estimated the SO2 emissions as approximately 3120 kg/hr. This estimation has been crosschecked and verified by CSE, by using information provided on coal consumption, and sulphur content in coal (between 0.4-0.6%, on an average 0.5% as per page 2-5). However, while the EIA mentions that light diesel oil will be used as a secondary fuel, there is no mention of how much oil would be consumed. Oil has a high sulphur content (1.8%, as per page 2-6), and therefore, data on the quantity of oil consumed would make the estimation of SO2 emissions much more robust. The EIA report has not paid attention to the control of SO2 emissions – no mitigation measures have been suggested. Studies show that SO2 emissions even at low concentrations of 5-20 mg/Nm3 can be detrimental to some kinds of plants – for instance chickoo, litchi, cashew, mangoes etc. 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.
Similarly the EIA report has estimated the NOx emissions as approximately 4,000 tonnes per annum. NOx emissions can be detrimental at low concentrations of 3-20 ppm. The report has not suggested any mitigative measures.
Mercuryemissions: Mercury emissions from the power plant have been completely overlooked by the EIA. There is no mention whatsoever – no estimation, no impact analysis, no mitigation. However, this should not be ignored, as thermal power plants account for 70 per cent of the country’s mercury emissions. Considering average mercury content of 0.25 ppm, mercury emissions from the proposed plant account for 618 kg/annum.
Carbon dioxide emissions: The EIA has also completely ignored CO2 emissions from the proposed plant. 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. The proposed plant will release 9.47 lakh tonnes of carbon dioxide per annum (calculated at the rate of 997 gms of CO2/kWh of power generated).
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.
Increase in traffic load: According to the EIA report, entire transportation of the coal will be done by roads hence, potential of fugitive dust will be the greatest threat. Further, EIA report also states that flyash from the thermal power will be used for filling the dug out area. But EIA is silent on the impact of flyash on environment due to transportation.
The EIA report for the proposed project has not made any estimation of fugitive emissions. According to the EIA report, approximately 2.47 million tonnes of middling and coal fines will be used every year. Assuming that just 0.1 per cent of this raw material escapes in the atmosphere in the form of dust, this will mean approximately 2,500 tonnes of dust per annum. If 0.5 per cent is lost as fugitive dust, this figure jumps to over 12,500 tonnes of dust per annum.
Apart from coal, fly ash is also a source of fugitive emissions. An estimated 1.37 million tonnes of ash (fly ash and bottom ash) will be generated every year (page 4-7), and all of this will be highly susceptible to fugitive emissions.
The EIA report has neither made estimations, nor analysed the impact of fugitive emissions. The only way of controlling these emissions is through proper infrastructure and proper management. The EIA has mentioned ‘water spraying’ as a means of controlling emissions, but in reality, effective control of fugitive emissions requires closed storage areas, closed transportation systems, mechanical material handling systems, andwherever possible conversion of non-point source emissions to point source emissions through creation of vacuum or suction.
The EIA report has not elaborated on many of these points. While dealing with control of fugitive emissions, the emphasis is on water spraying. The report does mention that raw material will be transported from the mines to the plant through roads or covered conveyor belts, and that there will be ‘effective dust suppression/collection systems at the transfer points’, though no details have been provided (page 5-3).
However, there is no mention of other infrastructure/mechanisms that should be installed to reduce fugitive emissions (like covered material storage yards, covered material loading/unloading points with attached suction devices etc.). 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. The EIA report does not adequately address how fly ash will be handled so as to reduce fugitive emissions.
Monitoring impact of air pollution: The EIA has been conducted during the summer season. However, for proper evaluation of air pollution impacts, monitoring and data collection should be done during winter also. Therefore, given the sensitive nature of the project site, and the location of other polluting industries in the vicinity (thermal power plants, mines, sponge iron plants etc.), a rapid EIA with one-season data collection is insufficient.
According to the EIA report, the most prevalent wind directions near the project site are northeast and southwest (page 3-13). Therefore, for proper air pollution impact analysis, monitoring should be done in the downwind direction – i.e monitoring stations should be located southwest and northeast of the proposed site. Therefore, monitoring stations should ideally be located at the mine colony, and at the villages of Libra, Jhinkubahal, Jharna, Tapranga, Bajlor, and Janjgir. The EIA has not done monitoring at all these locations. Overall, the data collected on air quality is not sufficient to adequately analyse the impact of air pollution.
3. Local biodiversity
The region surrounding the proposed site is rich in biodiversity. More than a fourth of the area in the buffer zone is forested. According to the EIA report, even the core zone is home to mammals like foxes and bandars (Bandar is included in Schedule I of the Wildlife Protection Act 1972). The buffer zone consists of many protected species including the spotted deer, the rheasus macaque, the bear, and the leopard.
The region surrounding the proposed plant is also rich in mahua plantations, which is of very high economic value to the local community (page 3-30). There are allegations (recorded in a case submitted to the National Appellate Authority, which is reviewing the environmental clearance given to the 2nd stage of JSPL’s existing steel plant) that emissions from JSPL’s existing steel plant in Raigarh have caused a reduction in the yields of mahua crop in the surrounding areas. It is therefore important to conduct a thorough study of the exact impact of various pollutants on mahua as well as other vegetation in the forests in the region. No such analysis is available in the EIA report.
However, the biggest weakness of the EIA in terms of evaluating the impact of the project on local biodiversity is that no attempt has been made to do a cumulative impact analysis of the various industrial activities. The ecologically-rich study area is now facing the brunt of not just this proposed project, but also of other large projects in the area – including the 4x250 MW Super Thermal Power Plant.
4. Solid waste management
The proposed plant will generate fly ash and bottom ash – a total of 1.37 million tonnes of solid wastes will be generated. The EIA report has not dealt extensively with how fugitive emissions from fly ash storage and handling will be controlled. Regarding waste utilisation, according to the EIA report, ‘in the initial years of operations, efforts will be made to ensure maximum utilisation of fly ash in dry form for commercial use such as brick making, manufacturing of pozzolona cement …Unutilised fly ash shall be converted to high concentration slurry and shall be transported to abandoned portion of coal mines’ (pages 5-8, 5-9). 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 contacts 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 – just 10 per cent of the fly ash generated in the country is reused, even though India has a huge cement manufacturing capacity. Therefore, just implying that fly ash may be used does not mean that it will actually be used.
JSPL’s proposed thermal power plant is not a small-scale project. There are two main impact areas of the project – impact on local groundwater regime, and impact on forests and local biodiversity. The project is coming up in a forested area. 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 form the base of peoples’ livelihood in this predominantly tribal area (mahua in particular is central to the local economy), the forests are also home to many protected species and moreover forests play an extremely important role in groundwater recharging.
The ecology in the area is facing the impacts of many industrial projects – including the 4x250 MW Super Thermal Power Plant, many coal mines, and many sponge iron plants. Therefore, in considering the environmental impact of this proposed project, the larger picture has to be kept in mind. The impact on the local ecology – whether on the forests, or on the local groundwater regime - will be cumulative. The biggest weakness of the EIA report is that it has not been able to capture the overall, cumulative impact of the project.