Introduction: Project location

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1 Introduction: A coal washery project called the Rajan Coal Washery with a capacity of 0.96 million tonnes per annum (MTPA) is proposed to come up at Kharsiya, Raigarh (Chhattisgarh). Raghubeer Pradhan of Ekta Parishad, approached the Centre for Science and Environment (CSE) for a technical evaluation of the Environmental Impact Assessment (EIA) report. The EIA report has been prepared by Anacon Laboratories Private Limited, Nagpur. The coal washery is being proposed keeping in mind the expansion of thermal coal capacity of Coal India Limited. The beneficiation/washing process is known to enhance energy efficiency of power generation. The washed coal is proposed to be supplied to nine plants in the area, some steel plants and some power plants (page 2.6 of the EIA report). The estimated project cost is Rs 31 crore out of which Rs 18 lakhs has been set aside for the Environment Management Plan (EMP) (page 1.3). The project proponent submitted an application for getting the Terms of Reference (ToRs) for the EIA preparation in June 2010 (page 1.4). The project was discussed in three meetings of the State Environment Appraisal Committee (SEAC) and was finally categorised at a 'B1' project implying the project needs to carry out an EIA and hold a public hearing. The public hearing is scheduled for August 29, The report has collected baseline data for a period of three months from January-March 2011 (winter). Project location: The project is proposed at village Chote-Dhoumarpali, tehsil Kharsiya, Raigarh district in Chhattisgarh. The location is at Latitude 22 00' 9.59"N to N and Longitude E to E (page 1.12). While the nearest town to the village is Kharsiya, the nearest city is Raigarh and the nearest river is Mand (at a distance of 2.3 kilometers) (page 1.13). Study area villages are from Kharsiya, Gharghoda and Raigarh tehsils of Raigarh district and Malkhanoda and Dabhra tehsils of Janjgir-Champa district. The total population of the villages is 78,119 with 15 per cent Scheduled Castes (SC) and 27 per cent Scheduled Tribes (ST) (page 3.40). Employment rate in the study area is 30 per cent and marginal workers are 15 per cent of the total workforce (page 3.40). The plant is proposed to be built in an area of 8.1 hectare (ha) (page 1.3). An additional area of ha is required for railway siding which is to be used for transporting raw material, etc (page 2.3). Size of the project is 160 X 330 X 18 which implies the plant will operate for 330 days, 18 hours per day at 160 tonnes per hour throughput (TPH). The coal washery's source of raw material (coal) will be Chhal mines (at a distance of 24 km) or the Baroud mines (50 km) of SECL in Raigarh. An area of 10 km radius around the project site is taken as study area. The present land use of the location is described as private land and single crop agricultural land (page 1.13) at one point in the report but at another point the land use given is different. Land use pattern of the study area comprises of forestland, land under cultivation and cultivable waste mainly (page 3.2) (see Table 1: Landuse pattern of the study area).

2 Table 1: Landuse pattern of the study area Landuse Area (in ha) % area est land Irrigated land Un-irrigated land Cultivable waste Area not available for cultivation Total Major kharif crops in the project area are cotton and soya bean. The rate of production is given as quintals per acre per year (page 3.44). Gram, wheat, maize and vegetables are the secondary crops. The EIA report recognises that the landuse pattern of the project area will get permanently changed to industrial from low yielding single crop agricultural land (page 4.2). The plant construction will also permanently change the topography of the area. The mitigation measures given for the changes in landuse and topography of the area is given as greenbelt around the periphery of the plant area and within the plant (page 4.2). The plantation will be developed in about 2.67 ha of land. The flora and fauna of the study area has been assessed in the report (page 9.2). The main floral species found are: mango, ber, jamun, shisham, shaja, etc. Climbers and grasses are also common in the study area along with pulses, millets, oil seeds and grasses. Water use: The water requirement for the project is pegged at 90 cubic meter per day (m 3 /day) (page 2.3) (See Table 2: Water Balance). The source of water as mentioned in the EIA report is the coal mines and it is claimed that the plant will be 'zero discharge' (page 2.3). Table 2: Water Balance (in m 3 /day) Type Process water Waste System losses Process Industrial Domestic TOTAL

3 The wastewater generated will mainly be from the sanitary units provided to the workers (page 4.3) which will be treated/discarded using septic tanks or soakage pits. Settling pond is planned for storage and recycle of surface water to be used in the plant area. Sources of Pollution: The EIA report recognises four types of pollution that will be generated by the washery project air, water, solid waste and noise (page 2.11). The EIA report states that the waste generated will be managed and treated as per the standards and with minimal environmental impact (page 2.11). Dust is considered to be the main source of pollution during the construction phase of the project (page 4.2). The EIA report puts forth water sprinkling as a solution to abate/minimise dust. Socio-economic analysis: The positive impact from the project as specified in the EIA report are (page 4.11): increase in infrastructural resources, employment opportunities (direct and indirect), improving agricultural production and zero displacement. The negative impacts include impact on air, noise levels, land and water. Technical Review: There are several drawbacks in the quality of the EIA report. These drawbacks are presented below: 1. Land use: Land that will be acquired for the coal washery comprises of 12 per cent of forest land. The landuse figure given in the executive summary of the EIA report depicts the presence of two reserved forests in the study area - Rabo and Bargarh (page iii) (see Figure 1: Landuse figure as per the EIA). However, this point has been completely missed in the EIA report. Impact on this forest land is not discussed in the report. An adequate conservation plan for the forest area has to be drawn out for the reserved forest areas in the study area. It does not mention anything about the flora and fauna in the forests. The EIA report also fails to give an assessment of livelihoods dependent on these forests. Agriculture land in the study area comprises of 56 per cent. The impact prediction on agriculture land due to the project is not mentioned in the report. Mitigation measures talk of filling of low lying areas, reusing the excavated top soil for plantation and green belt development (page 4.2). The measures do not talk about improving the livelihood conditions or the agriculture yield of the fields in the study area. Nor does it take into account the number of livelihoods dependent on the agricultural land making the socioeconomic analysis extremely weak and incomplete. 2. Air pollution: During construction phase, huge amount of dust will be generated. This is bound to have an impact on the bio diversity as well as people residing in the nearby villages. Considering close to 3,000 tonnes of coal will be handled in the plant

4 every day, sprinkling of water is inadequate in terms of mitigation measure that is being proposed by the project proponent. Air pollution levels are already very high in Chhattisgarh. This is mainly the result of the fast paced industrialization. Air quality data from the Chhattisgarh State Environment Conservation Board or other any secondary source has not been quoted in the report. This raises a question on the sanctity of the air quality impact prediction. The report does not specify if the loading and unloading areas for the coal are open or closed. Open areas for loading/unloading of coal will give rise to dust and air pollution. These have to be closed in order to decrease the air pollution. Transportation of beneficiated coal and middling is using trucks (page 4.6). The report estimates that on an average 116 trucks will ply in and out of the plant (page 4.7). But the report does not mention if the trucks will be covered or not and using what material. This has a huge potential to aggravate air pollution/dust levels. The report does not specify the trips these trucks would cover or the distance covered. A proper mitigation plan for traffic control and dust generation should be worked out. Also such increase in number of trucks would lead to accidents. The current scenario of accidents in the area is not furnished in the report which is an important factor to be considered. Figure 1: Landuse figure as per the EIA

5 3. Water balance: given in the report states that the source of water will be coal mines. However details regarding how much water is produced in the mine, how it is stored and how it will be reused is absent in the report. The distance between the mine and coal washery is not specified and no details of how this mine water will be transported are given either. Also while the EIA report says coal mine water is the source, the executive summary of the EIA says water will be sourced from bore well/river Mand (page i). Thus there is a clear contradiction within the report itself on the source of water for the coal washery. The bore well/mine water that the project claims to use is ultimately ground water; hence the project will indirectly impact the ground water regime of the area. Also, there is no assessment of the flow in the River Mand (for assessing water availability) and the competing users for the river water. The water balance in the report does not specify how the plant will be zero discharge as it claims. Accounting of makeup water is not specified in report either. Coal yard drainage will be stored in a separate sump and separate drains will be used to carry this drainage to the sump (page 4.15). What ultimate use this coal yard drainage will be put to is not specified in the report. Hence the water balance is inadequate. 4. Cumulative impact: Already coal mines, power plants, steel plants, etc., exist in the vicinity of the proposed washery. These do have an impact on the surrounding environment of the area. The coal washery will only add to this impact. The EIA report has not studied the cumulative impact on the nearby areas. It has predicted impacts based on only its own activity. The report also does not specify location of other industries in the nearby areas. 5. Impact on water bodies: River Mand flows at a distance of only 2.3 km from the project site (page i). The coal washery is bound to have an impact on the river especially if at one place it claims to withdraw water from the river for use. This impact has been completed neglected by the report. The River is used for domestic purpose by many people in the surrounding areas hence the impact on the river cannot be neglected and a proper mitigation plan has to be given in order to protect the River Mand.. 6. Employment generation: The project proposes to employ skilled and semi-skilled people during construction and operation phase (page 2.6). While no number is specified during construction phase, the report estimates the requirement of 65 people during operation phase (page 2.7). No concrete plan regarding hiring people and what percentage will be the local population has been drawn out in the EIA report. 7. Solid Waste: The solid waste generated from the coal washery operations will consist of shale, sand, stone, etc. (page 4.10). The quantity of this solid waste is not specified in the report. The waste will be stacked in a reject dump as per the EIA report and hence will not have any impact (page 4.10).

6 8. Socio-economic impact: The report specifies the socio-economic impact of the project both positive and negative and also gives the mitigation measures for the latter (page 4.11). But the EIA report does not specify the budget allocation for the same or the time frame in which it would be accomplished. Thus the analysis is incomplete and not concrete. 9. Rainwater harvesting: The EIA report states that the washery will exercise rainwater harvesting over an area of 8.1 ha (page 8.6). This water will be used to recharge ground water. However, the report does not give details about the number and location of rainwater harvesting structures or the recharge pits. 10. Corporate Social Responsibility (CSR): The report gives details of budget allocation for various CSR activities (page 8.8). Five lakhs will be set aside for CSR: education 0.5 lakhs, health care 2 lakhs and community welfare 2.5 lakhs. Also a recurring expenditure of Rs 10 lakh will be allocated towards community welfare every year. But there are no details of specific actions/facilities that will be provided under each of these heads and how long will it take to implement the same. Important questions to be asked: 1. What is the impact of the project on the forests in the area? What is the mitigation plan for the same? 2. How will the agricultural productivity in the region be improved as claimed by the project proponents? 3. How many people in the area are dependent on forests/agriculture for their livelihood? 4. What is the source of water for the coal washery? 5. How is the plant zero discharge? 6. How many industries/mines exist in the area and what is the cumulative impact of all these activities on the resources in the region? 7. What budgetary allocations have been made for infrastructure, educational and medical facilities in the region and what is the time frame of their implementation? 8. What kind of employment opportunities will be offered/guaranteed to the local population?

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