Submission before the Panel holding Environmental Public Hearing on 18-8-2009 into the proposed 2640 MW coal fired Power Plant by M/s Nagarjuna Construction Company Limited (NCC), Hyderabad at Gollagandi and Baruva villages, Sompeta mandal, Srikakulam district, Andhra Pradesh.
The Human Rights Forum (HRF) is a citizens’ forum established with the objective of working for the protection of the Constitutionally guaranteed/internationally recognised rights of the people, and for the right of the people to propose and strive for new rights not yet recognised in national or international law. The right to a wholesome and dignified life is the touchstone for the rights that may be aspired for. In particular the Human Rights Forum works for the protection of the right to a clean and safe environment. HRF is a self-financed organisation whose members for the most part are from the professions of teaching, journalism and the law.
HRF believes that the public hearing being held today must be postponed because the comprehensive EIA report has not been made available in Telugu to the affected people. A mere summary cannot do full justice and will not be sufficient for the people to understand the environmental impact and take an intelligent stand in the matter. It is necessary that a Telugu translation of the full EIA report is made available to each village, and officials of the Revenue Department as well as the APPCB make themselves available to the people to explain matters to them and clear their doubts. Only then can a meaningful public hearing be held.
The EIA report as it stands does not reflect the full reality of the environmental impact. While saying that about 25 crore cubic meters of water will be pumped from the sea for the plant’s boilers annually, it does not say how much of it will be led back into the sea. It is known from experience with other such plants that the idea of cooling all the steam and re-using it does not work fully. There will be a considerable flow back into the sea. Notwithstanding the cooling towers, such water will be 5 to 10 degrees centigrade warmer than the sea. This will have the effect of heating the sea water over a period, thereby affecting the breeding of marine life.
The drawal of water on such a scale also has negative impact on breeding of marine life. This aspect of environmental impact finds no reference in the EIA report, but it will have drastic effect on the livelihood of coastal fishing people. Similarly, though there is reference to the emission of sulphur dioxide, there is no reference to the possibility that it may result in acid rain over the years. Though some reference is made to the effluent ash containing mercury and other heavy metals, there is no discussion of their poisonous impact on the surroundings. Thus, the EIA report is incomplete, which fact the people would know if it is made available in Telugu.
It is a matter of common knowledge that the lands being made over to the Nagarjuna Construction Co. Ltd (NCC) contains a huge water body or swamp called ‘beela’ in local parlance. It is of extent about 1200 acres out of the about 1900 acres (762 hectares) that is being handed over to the said Company. This is not being officially acknowledged.
The land is being described as ‘waste land which is useless for cultivation’. It is useless for cultivation because it contains a water body. The NCC indirectly acknowledges this where it says that the flow of water obstructed by the plant (which would in fact have collected in the ‘beela’) will be drained by constructing channels and let into a reservoir to be constructed by them. But the map provided by them along with the EIA report shows only the ash pond and no water reservoir in the 762 hectares leased out to them. It is therefore clear that all the water will be drained into the sea. This will be major loss to the more than 1000 farmers in about 25 villages who are regularly drawing water from the ‘beela’ for their crops. And for the 300 fishing families of Manikyapuram who are making a living catching fish in the swamp. Though this does not directly concern the environment, we are pointing out this fact to buttress our contention that the NCC, with the active assistance of the Government, is hiding more than it is revealing. Such a non-transparent situation is not at all conducive to any democratic exercise such as the environmental public hearing.
The HRF finds the REIA report as an Engineered Impact Assessment and not an objective Environmental Impact Assessment. Consultants have chosen to give up professional ethics for business interests.
In addition to major loopholes in environmental regulation in favour of polluting industries and utter lack of enforcement, even the TOR prescribed by the Expert Appraisal Committee are not comprehensive and do not reflect the world-wide concern towards Global Warming. With a large number of coal-based power plants on the anvil and several of them based on imported coal with higher sulphur content, it is high time the MOEF begins to enforce implementation of DeSOx and DeNox systems to reduce emissions from the power plants. While the world over use of Mercury is being strictly regulated and is taken out of use even for clinical thermometers, no limits are being set for power plants that are the largest emitters.
Threat to Human Civilisation from Coal:
There is increasing scientific evidence against use of Coal for generation of power. Leading scientists are not only issuing statements against setting up any new coal fired power plants without carbon capture and storage facility, but also participating in civil disobedience actions of people.
Carbon dioxide released into atmosphere continues to remain airborne for more than 1000 years as the graph presented below shows. So, what is released today keeps warming the earth for more than 1000 years. There is no way to remove it from the atmosphere once it is released. The only option is to reduce/eliminate release of CO2.
India is currently the fourth largest emitter of CO2 annually and the seventh largest in terms of cumulative emissions. From the number of project proposals for coal fired power plants in the pipeline it is clear that India continues to increase its share of CO2 emissions in future too. This is one aspect why the project should not be considered fro environmental clearance.
Another major reason for opposing the project is environmental injustice.
Environmental Justice:
Environmental Justice is the fair treatment and meaningful involvement of all people regardless of caste, language, region, religion, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.
Fair treatment means that no group of people, including a caste, ethnic, or a socioeconomic group, should bear a disproportionate share of the negative environmental consequences resulting from industrial, municipal, and commercial operations.
Meaningful involvement means that:
(1) Potentially affected community residents have an appropriate opportunity to participate in decisions about a proposed activity that will affect their environment and/or health;
(2) the public’s contribution can influence the regulatory agency’s decision;
(3) the concerns of all participants involved will be considered in the decision making process; and
(4) the decision makers seek out and facilitate the involvement of those potentially affected.
Environmental justice is achieved only when everyone, regardless of caste, culture, or economic status, enjoys the same degree of protection from environmental and health hazards and equal access to the decision-making process to have a healthy environment in which to live, learn, and work.
In the present case the people, especially in the 0-50 km in the neighbourhood of the project site are disproportionately exposed to toxic air pollution especially of toxic heavy metals such as mercury, lead and arsenic, with hardly any benefit accruing from the project. The power produced in the project is not likely to be made available to the villagers in the neighbourhood. If the company obtains Merchant power plant status, even the people of AP may not get to use power produced in the plant.
The plant burns about 12.5 MTPA of coal. It is equivalent to 11.36 kg per every Indian per year. Are the officials in MOEF, the experts on various committees for EC process, PCB officials and the people in power promoting these plants in the name of development willing to take their fair share of toxic burden?
| S. No | Metal emitted | Content in Coal, mg/kg REIA Table–2.6 (B) | Quantity/Indian, mg @85% PLF |
| 1 | Mercury | 0.5 | 5.68 |
| 2 | Lead | 207 | 2351.5 |
| 3 | Arsenic | 0.3 | 3.408 |
| 4 | Chromium | 75 | 852 |
| 5 | Zinc | 109 | 1238 |
Coal fired power plants are being now called ‘Death Factories’. Several epidemiological studies have been conducted and published on the damage to health of people living near these power plants. These plants are the single largest source of mercury air pollution. Mercury is a highly toxic metal that, once released into the atmosphere, settles in lakes and rivers, where it moves up the food chain to humans.
Mercury is a potent neurotoxin particularly damaging to the development of the foetus, infant and the young child. Mercury emissions also enter the aquatic species, bioaccumulate and enter human body on consumption of fish etc. “On average, for each 1000 lb of environmentally released mercury, there was a 43% increase in the rate of special education services and a 61% increase in the rate of autism. The association between environmentally released mercury and special education rates were fully mediated by increased autism rates.” (Environmental mercury release, special education rates, and autism disorder: an ecological study of Texas, Raymond F. Palmer, Steven Blanchard, Zachary Stein, David Mandell, Claudia Miller, Health & Place 12 (2006) 203–209)
Coming to the quality of the REIA report, it is as usual biased in support of the project and is not an objective impact assessment. Some of the glaring errors in the report are brought out.
Inconsistencies:
Several inconsistencies are found in the REIA report and a few are listed here.
Coal feed rate for the plant:
Coal requirement for this proposed plant @85% PLF is given as 1415 TPH (Page C2-14). But under emission calculations presented in Annexure XIII at the same PLF coal consumption is shown as 1602.564 TPH. Table – 2.8 (Page C2-27) gives coal consumption as 1600 TPH.
At the rate of consumption of 1415 TPH the plant on stream time = 12500000/1415 = 8834 Hours/year = 368 days/year
So, the coal consumption rate of 1415 TPH is absurd. If we take the figure 1602.564 TPH as appropriate, we get 12500000/1602.564 = 7800 Hours/year. REIA report is silent on the basis for the design and how they have arrived at this number. Specific coal consumption data for the proposed super critical technology is also not provided to check how the annual coal consumption is arrived at.
Specific coal consumption = 1602.564/2640 = 0.607 Ton/MWh = 0.607 kg/kWh Sulphur dioxide generated in the plant @85% PLF = 12500000 x 0.8/100 x 64/3 = 200000 TPA 0% PLF = 14600000 x 0.8/100 x 64/32= 233600 TPA
Ash Utilization/Disposal:
It is claimed in Table 4.12 that the entire 5.25 MTPA of ash generated will be completely utilized from 3rd year of operation onwards. It does not appear to be a realistic projection considering the breakup figures given in the table and also the absence of cement plants in the area that can make use of the fly ash to such an extent. Also several coal based power plants are proposed in Srikakulam and Visakhapatnam districts and are in various stages of implementation. The NTPC power plant near Visakhapatnam that has been in operation for the last several years is unable to totally utilize the ash even now. Export of ash overseas to the extent of 2.1 MTPA from 3rd year onwards does not appear feasible. Transportation costs lead the economic barriers, which limit the shipment of Coal Combustion Product’s to within about a 50-mile (80-kilometer) radius of the power plants.
Emissions:
The World Bank has prescribed emission standard of 2000 mg/m3 for SO2 for projects funded by it in India. It also stated that the maximum permissible emission level would be 0.2 tonnes per day per MW up to 500 MW and 0.1 tonnes per day per MW for each additional MW over 500 MW, but not more than 500 tonnes per day for any plant. Accordingly,for a 2640 MW plant maximum permissible SO2 emission = 0.2 * 500 + (2640 – 500) * 0.1 = 100 + 214 TPD = 314.0 TPD
Actual emission from the proposed plant = 25641 kg/hr (Page AXIII-1) = 615.384 TPD
Quantity of flue gas generated is calculated in Annexure XIII based on flue stack diameter and an assumed velocity of 25 m/sec. (44.18 m2 * 25 m/sec = 1104.5 m3) It is incorrect. The actual quantity of flue gas should be based on stoichiometry and combustion calculations.
The MIT report on “The Future of Coal” provides some material balance data on subcritical, supercritical and ultra-supercritical coal fired power plants. One set of data for an ultra-supercritical 500 MW plant is reproduced below.
The REIA should have provided data in such a format. Using the above data the quantity of stack gas could be easily calculated as shown below.
Total air fed to the boiler = 1680 + 265 = 1945 TPH
Coal feed = 164 TPH
Specific Air usage for combustion = 1945/164 = 11.86 T/T
Stack gas generated for 2640 MW = 2200 x 2640/500 = 11616 TPH
Average molecular weight of stack gas = 37 kg/kgmole
Stack gas for 660 MW = 11616/4 = 2904 TPH = 78486.5 kgmole/hr= 1759196 Nm3/hr = 488.66 Nm3/sec
In the absence of data for the actual quantity of flue gas, concentration of SO2 and NOx are calculated using the value given in REIA to check whether the emission standards are met or not.
SO2 concentration in flue gas = 25.641*109 /(4*1104.5*3600) = 1612.15 mg/m3
It shows that maximum permissible emission quantity for sulphur dioxide exceeds WB limit by 96% at 85% PLF. At 100% PLF situation is much worse.
The proposed WB emission standards for NOx are 750 mg/m3 (365 ppm), 460 mg/m3 (225 ppm) and 320 mg/m3 (155 ppm) for coal, oil and natural gas based power plants respectively.
In the present REIA, NOx emission is calculated based on CPCB norm of 9 kg of NOx per tonne of coal consumption and rate of NOx = 14423 kg/hr = 4006 g/s (Annexure XIII). CPCB norm itself is questionable and far above any set by developed countries.
Based on the flue gas flow rate of 817 Nm3/s for each flue, NOx content in the flue gas = 4006*1000/ (4*1104.5) = 906.75 mg/Nm3
NOx emission concentration limit is above the WB norm of 750 mg/m3.
| S. No | Component | Rate @85% PLF | Rate @100% PLF | Concentration in Flue |
| 1 | Sulphur dioxide | 25.64 TPH | 29.95 TPH | 1612.15 mg/m3 |
| 2 | Nitrogen oxides | 14.42 TPH | 16.85 TPH | 906.75 mg/m3 |
So emission of SO2 from the proposed plant is exceeding even the World Bank maximum emission limit of 500 TPD for any plant. How is the balance of 115.384 TPD of sulphur dioxide removed from the flue gases? In case of NOx WB emission standard of 750 mg/m3 is exceeded.
Recent environmental regulations have forced electric utilities to use low-NOX burners (“low-NOX” is a designation for burners that greatly reduce nitrogen oxide emissions). These burners leave some coal unburned, which leads to higher free carbon contents in fly ash and makes the ash unsuitable for use in cement and concrete applications.
Heavy Metal Emissions:
Basis: Coal consumption is 12.5 MTPA @85% PLF and 14.6 MTPA @ 100% PLF
Quantity of heavy metal emissions from the proposed plant are calculated based on the given data and presented in the table below.
| S. No | Metal emitted | Content in Coal, mg/kg REIA Table–2.6 (B) | Quantity emitted, TPA | |
| @85% PLF | @100% PLF | |||
| 1 | Mercury | 0.5 | 6.25 | 7.3 |
| 2 | Lead | 207 | 2587.5 | 3022.2 |
| 3 | Arsenic | 0.3 | 3.75 | 4.38 |
| 4 | Chromium | 75 | 937.5 | 1095 |
| 5 | Zinc | 109 | 1362.5 | 1591.4 |
These toxic metals once released into the environment continue to circulate for ages and do not get eliminated. Damage to all life from these emissions will be enormous.
It takes only tiny amounts of mercury to cause serious medical problems: Just one part of mercury in a million in some human tissues is enough to cause health problems, studies have shown.
A study by Minnesota, Michigan and Wisconsin, USA found that one drop of mercury falling in rain a year can contaminate fish in a 20-acre lake as these fish absorb the mercury and concentrate it in their tissues. One drop is about the amount in a fever thermometer.
Occupational exposure limits for Mercury:
Vapour (all forms except alkyl) ACGIH TLV = 0.025 mg/m3 TWA
Aryl and inorganic compounds ACGIH TLV: 0.1 mg/m3
ACGIH BEI: Urine: 35 g/g of creatinine; Blood: 15g/L end of week/end of shift
Acid Rain:
Acid rain is formed when compounds including NOx and SO2 are dissolved in atmospheric water, decreasing the pH of rain from normal levels of 5.6 to a pH in the range of 3.0 to 4.0. Acid rain can negatively impact vegetation by removing mineral nutrients from leaves and by degrading the waxy cuticle that protects the leaf from desiccation and absorption of additional pollutants.
Likewise, the addition of acids to soils can result in the release of aluminum ions from soil minerals, causing aluminum toxicity in plants. Generally, concentrations of SO2 and NOx in air that exceed 0.5 mL L–1 are known to be inhibitory to plant growth. Instances of acid rain have begun in India already. The yellow spots developed on the terrace of a building due to acid rain are visible.
Acid rain destroys ecosystems, including streams and lakes, by changing their delicate pH balance making them unable to support life. Acid rain can destroy forests, devastate plant and animal life, and eat away at man-made monuments and buildings to effectively destroy our natural and historical treasures.
Impacts on Crops:
Chemical air pollution is often manifested in two general forms: photochemical smog and acid rain, both of which can adversely impact vegetation. Photochemical smog is the product of chemical reactions driven by sunlight and involving NOx of urban and industrial origin and VOCs from either vegetation (biogenic hydrocarbons) or human activities (anthropogenic hydrocarbons). Ozone (O3) and peroxyacetylnitrate (PAN) produced in these complex reactions, can become injurious to plants and other life forms depending on concentration and duration of exposure. Indeed, ozone is phytotoxic, and some plant species are more sensitive to it than are humans (USEPA 1996).
Plants are capable of a number of innate enzymatic processes that effectively detoxify chemical pollutants. However, when the concentration of chemical pollutants in plant tissue exceeds their innate detoxification mechanisms, processes including photosynthesis, water regulation, and respiration are impaired, reducing growth and development. In addition, accumulation of chemical pollutants in plant tissue can result in deleterious genetic mutations, which can greatly reduce the fitness of the organism and its offspring. (Draft EIA, Desert Rock Power Plant, 2007)
“Air Pollution Impacts on Crops and Forests” – A Global Assessment published by Imperial College Press in 2003 contains a chapter on “Impacts on Vegetation in India” by Madhoolika Agrawal. In the conclusions it is stated, “National air quality data clearly shows that SO2 and SPM are currently the most important pollutants in India… Coal based electric generation and transportation are the most important contributors to air pollution. Meteorological conditions in most parts of the country are favourable to O3 formation which is emerging as a major threat to crop loss due to the long range transport of precursor emissions.
A substantial body of observational and experimental evidence has been collected within India to show that current levels of air pollution are impacting significantly on the local vegetation. Both annual crops and perennial plants show variable degrees of susceptibility to present levels of air pollution.”
Studies conducted by Benares Hindu University in the Singrauli area with about 10000 MW or more of coal fired power generation indicated crop losses to the extent of 40 percent.
Transmission Lines:
Power produced in the plant is proposed to be evacuated at 765/400kV level. No details are given. Construction of transmission lines requires work area for tower footings, a 10 ft wide right of way for moving the machinery and personnel for executing the work. So, there are impacts during construction as well as operation. Considerable acreage of agricultural land is lost. The loss of land, may be to the extent, of about 7.5 acres per kilometer of transmission line.
The REIA report is entirely silent on this aspect. The terms of reference also does not include this aspect, as if it is unrelated to the project. For example, Draft EIA for Desert Rock Power Plant, New Mexico has a 210-page long chapter on the Environmental consequences with a considerable portion dealing with transmission lines, evaluation of alternatives, construction and operation time emissions, impacts on birds, land, and visual etc in a very detailed manner. REIA is incomplete without covering the transmission aspects. Why this aspect is delinked from the REIA and not included in TOR is unclear?
Conclusion:
In view of theabove lapses in the REIA for the project, and the immense potential for pollution and damage to human health, likely loss of livelihood to fisherfolk from loss of aquatic life, to farmers from loss of a precious irrigation source and crop yields, we strongly oppose giving environmental clearance for the proposed plant.
With other proposals for similar capacity coal fired power plants at Bhavanapadu etc, adjacent to the present study area, the combined impacts should be considered for environmental clearance. Impact areas for both plants will have a fair amount of overlap area.
Environmental clearance for all future coal fired power plants should impose SO2, NOx and Mercury and heavy element removal systems. It is environmental injustice to permit companies to make profits at the cost of public health in the name of energy security.
We also reiterate our request to postpone the hearing until the full EIA report and all relevant information is made available in Telugu to all the affected villages.
VS Krishna
State Secretary
Human Rights Forum (HRF)
18.08.2009
Baruva, Srikakulam district