12.05.2024.
To,
Sri P. Ranjit Basha
The Collector,
Kurnool District.
Subject: Representation for Revision of Draft Environmental Impact Assessment (EIA) for TGV SRAACL, Gondiparla Village, Kurnool District – Request for Public Hearing Post Revision
Respected Sir,
The Human Rights Forum (HRF) is a citizens’ forum established with the objective of working for the protection of the constitutionally guaranteed/internationally recognized rights of the people.
We hereby submit this representation to request your urgent intervention for the revision of the draft Environmental Impact Assessment (EIA) report on the proposed expansion of the TGV SRAACL project located at Gondiparla village.
Upon careful review of the currently available draft EIA report, we have identified significant omissions and a lack of crucial information that is essential for the public to make an informed assessment of the potential environmental and social impacts of this project. The absence of this key data severely impedes our ability to provide meaningful feedback and participate effectively in the environmental clearance process.
Specifically, the draft EIA report fails to adequately address the hazards and risks of several chemicals used and produced. One example is the highly hazardous Tetrafluoroethylene monomer. Its storage and handling risks are not presented in the EIA. It can explode on exposure to air/oxygen. The project’s proximity to the Telangana border necessitates the inclusion of the potentially affected population and environment in that state within the scope of the impact assessment. Not including is against the spirit of the Rio Declaration, 1992, that gave the right to participate to the people. This project involves violations of the Montreal Protocol and the Stockholm Convention.
The technology for PTFE manufacture is complex and engineering-intensive, and the company is unlikely to have the know-how for the proposed products. Mandate the project proponent to disclose the source of their PTFE manufacturing technology and the credentials of their design engineering consultant, including their track record in implementing similar projects.
Fatal accidents are very common in the chemical industry in AP due to inadequate designs. Any poor design could lead to a major disaster in this plant. Last year a leak of a solvent killed 17 and injured 39 in Escientia Advanced Sciences Private Limited, Achyutapuram in Anakapalli district. Inadequate design of a stirred reactor, a simple equipment, killed 10 workers at Porus Labs, Akkireddygudem in Eluru district.
The EIA report has not disclosed the use of surfactant needed in the polymerization to produce PTFE. There are hardly any PTFE manufacturers not using a surfactant to aid polymerization. Fine powder PTFE cannot be made without use of a surfactant. Fluorinated chemicals used as surfactants are persistent, bio accumulative, and cause varieties of cancers and are already affecting the entire planet.
Detailed assessment of potential impacts on local water resources, including the contamination of Tungabhadra and Krishna rivers, is left out of the EIA. As such, India has a problem of PFAS contamination of river waters, and the NGT PB is hearing a Suo motu case OA 548 of 2024 on the PFAS contamination of water resources in India based on a publication by IITM. We learned that a 250 g leakage of PFAS per day can contaminate the entire Krishna waters, rendering them unfit for drinking water.
The precautionary principle should be invoked to protect the people and the environment. The onus is on TGV SRAACL to produce evidence of no harm and not merely deny.
- Comprehensive analysis of air and noise pollution levels during construction and operation phases, along with proposed mitigation measures.
- Thorough evaluation of the project’s impact on local biodiversity, including flora and fauna, and any potential loss of habitat.
- Detailed plans for waste management, including hazardous waste disposal.
- Assessment of the potential social and economic impacts on the local community, including displacement, livelihood changes, and impact on local infrastructure.
- Clear and detailed information regarding the proposed pollution control technologies and their efficacy.
- A comprehensive risk assessment and disaster management plan.
- Details of the public consultation conducted during the EIA preparation process and how the feedback was incorporated.
- Given these significant gaps in information, the present draft EIA report is incomplete and does not fulfil the requirements for a transparent and participatory environmental clearance process. Providing such an inadequate report to the public undermines the very purpose of the EIA, which is to ensure informed decision-making and protect the environment and the interests of the local communities.
Therefore, we respectfully request your esteemed office to:
- Order an immediate revision of the draft EIA report to include all the necessary information and address the shortcomings identified above.
- Ensure that the revised EIA report is made readily accessible to the public in a timely manner, allowing sufficient time for thorough review and understanding.
- Conduct a public hearing on the revised EIA report to provide an opportunity for the community to voice their concerns, seek clarifications, and provide valuable feedback after having access to complete and accurate information.
We believe that a comprehensive and transparent EIA process, culminating in a meaningful public hearing based on a complete report, is crucial for ensuring sustainable development and safeguarding the environmental and social well-being of Kurnool District.
We look forward to your prompt and positive response to this representation and your intervention to ensure a fair and transparent environmental clearance process for the TGV SRAACL project.
U.G. Srinivasulu (HRF Andhra Pradesh State vice-president)
Paani (HRF Kurnool District Committee member)
Kurnool,
12.05.2024.