To,
The Chairperson and Members,
Expert Appraisal Committee (Industrial Projects 3),
Ministry of Environment, Forests and Climate Change (MoEF&CC),
Indira Paryavaran Bhawan, Jor Bagh Road,
New Delhi – 110003, India
Subject: Urgent Appeal Regarding the Proposed 40 TPD Polytetrafluoroethylene (PTFE) Production Plant by TGV SRAAC Ltd. in Gondiparla, Kurnool District – Scheduled for Appraisal on July 15, 2025
Respected Members,
We, the deeply concerned citizens of Andhra Pradesh and members of the Human Rights Forum (HRF), submit this urgent appeal with profound apprehension regarding the proposed 40 TPD Polytetrafluoroethylene (PTFE, commonly known as Teflon) production plant by TGV SRAAC Ltd. in Gondiparla, Kurnool district. As the appraisal for environmental clearance is critically scheduled for July 15, 2025, we implore your esteemed committee to undertake a rigorous, transparent, and comprehensive review of this project. Our concerns are amplified by the critical dependence of nearly four crore Telugu people across Andhra Pradesh and Telangana on the Krishna River, our vital lifeline, and the alarming global precedents set by the PTFE industry.
- Our Fundamental Concerns as Citizens:
- As the primary stakeholders – farmers, workers, parents, and students – whose lives are inextricably linked to the Krishna River, we voice our fundamental concerns. The river serves as our sole source of drinking water, irrigation for our farms, and a crucial foundation for our livelihoods. The prospect of contamination from PTFE production, which involves persistent and toxic chemicals like PFAS (per- and polyfluoroalkyl substances), fills us with dread. These ‘forever chemicals’ are known to accumulate in the environment and human body, posing severe health risks including cancer and developmental issues. A good number of rivers in the world have been poisoned by PTFE production. We cannot permit our sacred Krishna River to become a repository for such hazardous substances, thereby jeopardizing the well-being of millions.
- Global Precedents and Warnings from the PTFE Industry:
- Our anxieties are compounded by the well-documented global history of environmental degradation and public health crises linked to PTFE and related chemical production. We note with grave concern that the company’s Environmental Impact Assessment (EIA) report fails to disclose the specific surfactant used in polymerization. However, information shared by a company representative with Jana Vignana Vedika, a local organization, indicates the use of HFPO-DA (also known as GenX).
- This is particularly alarming given recent international developments:
- EU Court Ruling (Chemours): The European Union Court recently (2022) rejected an appeal by Chemours, a major chemical producer, to remove HFPO-DA (GenX) from the list of Substances of Very High Concern (SVHC). This decision underscores the recognized toxicity, persistence, and environmental and human health hazards associated with this chemical, which is integral to PTFE manufacturing.
- Italian Court Convictions (Miteni): On June 26, 2025, officials of Miteni, an Italian PFAS producer, were sentenced to lengthy prison terms for severe water pollution and community harm.
- These cases serve as stark warnings, demonstrating the irreversible damage that can result from inadequately regulated PTFE production. We cannot permit Andhra Pradesh, with its critical reliance on the Krishna River, to become another casualty of such industrial negligence.
- Specific Concerns Regarding TGV SRAAC Ltd.’s Proposal:
- Our scrutiny of TGV SRAAC Ltd.’s proposal reveals several critical deficiencies:
- Flawed Environmental Impact Assessment (EIA): The current EIA report appears to contain unsubstantiated data and lacks credible supporting evidence. It critically fails to address:
- The emissions of highly potent greenhouse gases, specifically HFC-23 (R23), which possesses a Global Warming Potential (GWP) 14,800 times greater than CO₂.
- A comprehensive plan for the safe management and disposal of toxic PFAS chemicals, including PFOA or GenX, which are inherently linked to PTFE production and pose a generational threat of polluting our rivers and soil.
- Lack of Proven Technology and Expertise: TGV SRAAC Ltd. reportedly possesses no in-house technology for PTFE production and has not formalized any agreement with a technology licensor. Proceeding without demonstrated expertise or a proven, safe technological framework for handling such hazardous chemicals is an unacceptable risk, potentially leading to catastrophic industrial accidents, leaks, and widespread pollution, akin to the recent tragedy at Sigachi Industries in Telangana where over 50 lives were lost.
- Questionable Compliance Record: TGV SRAAC Ltd.’s past environmental compliance record raises significant doubts, with reports indicating concerns about adherence to regulations and the current expansion proceeding under questionable environmental clearances.
- Suppression of Public Voice: We were unjustly prevented from participating in the public hearing, with individuals reportedly subjected to physical assault and removal from the venue. This suppression of democratic participation has been widely covered by local media and undermines the transparency and legitimacy of the appraisal process.
- Our Urgent Plea to the Expert Appraisal Committee:
- In light of the profound risks and deficiencies outlined, we respectfully but firmly urge your esteemed committee to take the following decisive actions:
- Reject the Current EIA Report: The existing EIA is demonstrably incomplete, lacks verifiable data, and fails to adequately assess critical environmental and health impacts. We demand its outright rejection and the mandating of a new, truly comprehensive, and transparent EIA that fully discloses all risks associated with PFAS, HFC-23, and other pollutants, alongside robust, verifiable plans for their safe management.
- Demand Verifiable Proof of Technology: TGV SRAAC Ltd. must furnish concrete evidence of a credible technology partnership or a formal licensor agreement that guarantees safe, proven, and environmentally responsible PTFE production. Without such assurance, this project cannot be permitted to proceed.
- Impose a Moratorium on Environmental Clearance: A complete moratorium on environmental clearance must be imposed until TGV SRAAC Ltd. can unequivocally demonstrate its ability to produce PTFE without the use or release of highly toxic PFAS chemicals, including PFOA or GenX. The global scientific consensus on the harm caused by these chemicals necessitates extreme caution.
- Ensure Genuine Public Consultations: The voices of the directly affected local communities, particularly those dependent on the Krishna River, are paramount. We demand that transparent and inclusive public hearings be conducted to genuinely address our concerns and ensure full accountability.
- Mandate Stringent Krishna River Protection: Any consideration of project approval must be contingent upon the implementation of the most stringent conditions to prevent any form of pollution to the Krishna River. This must include continuous, independent monitoring mechanisms and severe, enforceable penalties for any violations.
- A Solemn Appeal for Protection:
- We wish to unequivocally state that we are not inherently opposed to industrial development. However, such development cannot, and must not, come at the irreversible cost of our health, the future of our children, and the ecological integrity of our sacred Krishna River. The harrowing accounts of cancer, birth defects, and widespread environmental destruction caused by PFAS chemicals globally serve as a chilling premonition we desperately seek to avoid for our villages and towns.
- The Expert Appraisal Committee holds the immense responsibility and power to safeguard the lives and livelihoods of millions. We implore you to exercise this authority by ensuring that TGV SRAAC Ltd.’s project undergoes the most rigorous scrutiny, adhering to the highest international standards of safety, transparency, and environmental stewardship. As the Telugu people, we place our profound trust in your committee to act as the unwavering guardians of our environment and collective well-being.
- Do not allow short-term industrial ambitions to imperil the long-term health and prosperity of our communities. We humbly and urgently appeal for an appraisal process that unequivocally prioritizes the health and purity of the Krishna River, which sustains nearly nine crore people, above all other considerations.
Sincerely,
U G Srinivasulu, +91-9985558251
K V Jagannatha Rao, +91- 9440112551
,Y Rajesh, +91-9966631796
13.07.2025,
Adoni/Srikakulam/Amalapuram.