ANALYSIS

OF THE
RAPID ENVIRONMENTAL IMPACT ASSESSMENT
REPORT PREPARED FOR
The TATA Power Company Ltd.
1000 MW Coal Based Thermal Power Plant
AT Naraj Marthapur, Cuttack, Orissa

Prepared by:
Centre for Science and Environment
41, Tughlakabad Institutional Area,
New Delhi – 110 062
Background of the report
The Tata Power Company Ltd. is planning to set up a thermal power plant at
Naraj Marthapur, Cuttack, located in Orissa.
This report is a technical evaluation of the Environment Impact Assessment (EIA)
document submitted by Tata Power Company Ltd as part of the clearance
process for a 1000 MW coal based thermal power plant. The EIA has been
conducted by the Gurgaon -based SGS India Private Limited. The study area for
the EIA study is 10-km radius.

About CSE
Centre for Science and Environment (CSE) is an independent, public interest
research and advocacy organisation, which aims to increase public awareness
on science, technology, environment and development. The Centre was started
in 1980.
For more than two decades, CSE has been creating awareness about the
environmental challenges facing our nation. It has been:
• Searching for solutions that people and communities can implement
themselves,
• Challenging the country to confront its problems,
• Inspiring it to take action and,
• Pushing the government to create frameworks for people and communities to
act on their own.
About the project
The Tata Power Company Ltd. proposes to set up a coal based thermal power
plant of 1000 MW having configuration of 2x125 MW + 2x125 MW + 2x250 MW.
The area to be acquired for the siting of the project is around 400 Ha. EIA states
that out of the total power generation, 350 MW will be supplied to steel plant at
Kalinganagar, around 250 MW will be given to GRIDCO and remaining will be
sold on mrechant basis. The estimated cost of the project is Rs 49000 crores.
According to the EIA, project will consume 6 MTPA of coal (indian coal) and
96,684 m3 of water per day. The proposed plant will sourced water from the
Mahanadi, which flows west to east on the northern side of the site. The EIA
states that water will be drawn from Mahanadi at about 3 km from the proposed
plant site (pp15, chapter 2) but fails to provide intake point location.
There is large variation in flow from monsoon to non-monsson period in the
Mahanadi river, as per the estimation, percentage reduction in flow from
monsoon to non-monsoon is around 86%, considering monsoon flow at the
upstream of the Naraj barrage is 46474 cusec (113721878 m3/day) and non-
monsoon flow is 6292 cusec (15396524 m3/day). Inspite of large variation in
flows, river is extensively used for irrigation, city water supply and industrial
requirement.
If we consider the existing water stress on the river such as water requirement of
industries (1103712 m3/day), cuttack city (11000 m3/day) and Bhuneshwar city
(43000 m3/day), It has been estimated that above three activities are consuming
8 % of the total lean period flow (6292 cusec). In addition to this, water has also
been allocated to number of upcoming industries such as POSCO, IOCL, Lhoist
and ESSAR, which all together will cause additional stress of 4920962 m3/day. If
we consider existing and proposed water demand by industries, there would be
utilization of around 41% of the total lean flow including proposed power plant,
which will consumes water around 96684 m3/day. For calculation, water
requirement for Puri canal and irrigation has not been accounted due to lack of
data. If this is also accounted in the calculation, stress on the river will be far
high. However, EIA has not taken the pain for detailed investigation on water
availability and states “as per a separate study report conducted by
independent agency, adequate quantity of river water is available
throughout all season of the river and for all the year to come” see page
177.
EIA states, excess water from common mixing basin (CMB) will be discharged in
the upstream of the river after meeting the desired standard. But no explanation
on the quantity of effluent to be discharged in the river. Further, if wastewater is
discharged in the upstream, it means there would be high risk of contamination of
Puri canal and downstream users. Intrestengly, Cuttack city also sourced 110
MLD (million liter/day) of water from the Jobra Barrage, which is located in
downstream of the river. The question arises why CMB water is not used in the
plant if it is so good, why it is proposed to discharge in the upstream of river.
There is a contradictory statement given on liner material which is going to be put
in ash disposal pond. In page no 117, EIA states that inorder to avoid
groundwater contamination, clay will be used as liner material. However, in
capter 9, compliance with TOR, EIA states that LDPE liner will be provided to
prevent the leachate. EIA is also silent on the ash pond runoff. No contours
elevation map of ash pond is mentioned in the EIA to understand the runoff flow
pattern. The slope and elevation of ashpond area is very crucial because Puri
canal bisect the ash pond and power plant. Assuming, if runoff slope is towards
power plant, then there would high ash siltation risk to the Puri canal.
Project impact area (i.e 10 km) is highly ecologically sensative, most of the study
area is under wildlife Sanctuaries, National park and reserve forest, (more than
41 %), and hence assessment of biodiversity is very crucial and requires detailed
assessment. However, EIA report is poor in portraying the ground reality or
assessing the impact on the biodiversity. For biodiversity assessment, EIA
developer has listed down the flora and fauna names and failed to assess the
actual impact on the biodiversity.
The Chandaka wildlife sanctuary & National park is located at 4 km from the
project site and Nandankanan national park for the consevation of white tigers
and crocodile is located at 7.5 km, in addition to this, there are 7 reseve forest
located in the study area. According to EIA, sanctuaries and national park have
number of schedule 1 listed animals. Hence it is imperative that every aspects of
pollution need to be mitigated. Moreover, the Indian Board for Wildlife, which
is chaired by the Prime Minister, had taken a decision in January 2002 that
all areas within 10 km of the boundaries of national parks and sanctuaries
and the wildlife corridors would be declared as eco-sensitive under the
Environment (Protection) Act — 19861. This clearly shows that area is eco-
sensitive. According to the supreme court ruling, dated December 1, 2000, the
order prohibits polluting industries within a 10km radius of the Himayat Sagar and
Osman Sagar lakes in Hyderabad, which provides continuous water supply to the
twin cities of Hyderabad and Secunderabad.2
In India, till date except particulate emission, no standard has promulgated for
SO2 , Nox and Mercury emission for the coal based power plant. Hence, like
other coal based power plant, EIA developer has suggested mitigation measures
for particulate control only. Seening the sensitivity of area, quantum of emissions,
no mitigation measures have been suggested for gaseous pollutants.
The maximum daily requirement of coal for three units will be around 16,368
tonnes which is tranported to plant by rail and proposed to be stored in circular
coal bunker, which is consided as a good practice in controlling fugitive dust.
Further handling of flyash is good from the environmental point of view, which is
tranported pneumatically to storage silos. The flyash collected in silos will be
either disposed in wet slurry or in dry form using trucks (pp 22, chapter 2). But no
information is available on the capacity of silos. Around 30 ha of land has been
earmarked for flyash disposal but no information mentioned in the EIA on the
type of land to be diverted for flyash disposal.
Landuse –The EIA states that impact area which is 10 km radius of the project
site is predominely coverd by dense forest which accounts 32 % of the total study
area followed by agricultural land accounting 28%. Alltogether, forest land (both
dense and moderate dense) constitutes 41 % of the total area.
For project siting, apart from agricultural and private land (78%) see page 174,
plant will also divert 15 ha of forest land for siting of the project. It seems that
lands which are diverted for siting of project is primarly agricultural land followed
by grazing and forest land. Hence, the impact on land expected to be high such
as displacement of population, impact on grazing animal and silation of river and
canal.

1
http://economictimes.indiatimes.com/rssfeeds/2647173.cms as accessed on 7 March
2008.
2
Times News Network, January 17, 2002
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, a rapid EIA with one-season data
collection is insufficient.
Impact of the project on local air quality
Coal based thermal power project ranks top in air pollution, water consumption
and in generation of solid wastes. 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 mentioned that
particulate emission from stacks after ESP is 100 mg/Nm3 (see pp29, chapter 2,
table 2.6), which works out to 1972 tonnes of particulate emissions per annum
(calculated based on gas flow rate and diameter of the stacks).
SO2 and NOx emissions: The EIA has estimated the SO2 emissions as
approximately 164 tpd (see pp 28, chapter 2). This estimation has been
crosschecked and verified by CSE, by using information provided on coal
consumption, and sulphur content in coal. However, while the EIA mentions that
LDO & HFO 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 to 2.5%). If we
consider from LDO & HFO, SO2 emission would be around 166 tpd. On annual
basis, LDO & HFO will add 847 tonnes of SO2, which has not accounted in the
calculation in the EIA. On annual basis, both coal and fuel oil will add 60,590
tonnes of sulphur dioxide in the atmosphere. Being an ecologically sensitive
area and close to sanchuary and National park, no point source mitigation
measures has been suggested. Studies show that SO2 emissions even at low
concentrations of 5-20 µ g/Nm3 can be detrimental to some kinds of plants – for
instance chickoo, litchi, cashew, mangoes etc.3 They can cause decrease in the
yields, chlorophyll loss and greater leaf fall. The impact of SO2 emissions is even
higher under humid and high wind conditions.
Similarly no point source mitigation measures has suggested for NOX emission
as power plant will add 18,186 tonnes of NOX per year to the ambient air (see
pp 29, chapter 2, table 2.6). NOx emissions can be detrimental at low
concentrations of 3-20 ppm.4 The report has not suggested any mitigative
measures.
Mercury emissions: Mercury emissions from the power plant have been
completely overlooked by the EIA. There is no mention whatsoever – no

3
Sagar Dhara, 2006, Risk Appraisal Study, Sponge Iron Plants, Raigarh district, Cerna Foundation,
Hyderabad, p 30
4
Sagar Dhara, 2006, Risk Appraisal Study, Sponge Iron Plants, Raigarh district, Cerna Foundation, Hyderabad, p 30
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 1494 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 emissions5, 65 per cent of the
industrial greenhouse gas emissions6. The proposed plant will release 6 million
tonnes of carbon dioxide per annum (calculated at the rate of 997 gms of
CO2/kWh of power generated).
EIA has monitored the air quality of the study area and concluded that all the
paramaters (SPM,RSPM, SOX and NOX) are well withien the standards. But
table 3.6 summary of ambient air quality monitoring results, clearly indicate high
level of RSPM at Mundali (project site), Narag (1.5 km from project site),
Ramdasnagar (2 km), Bidyadharpur (4 km) and all these locations have RSPM
level is around 70 microgram/Nm3 against standard of 100 microgram/Nm3. If
this is the scenario, then once the plant starts its operation, the RSPM will
increase as all these sites are close to project and under the influece of probable
wind direction. However, EIA fail to comment on this issues and concluded that
background level is well within the standard.
Wind pattern – Except particulate control no mitigation measures has been
suggested for SO2 and NOX. On annual basis, particulate matter (after ESP),
SOX and Nox emission will be 1972 tonnes, 60590 tonnes and 18186 tonnes
repectively. Seening the wind movement pattern (see pp 37, chapter 3, table
3.1), it can be concluded that in winter, most predominant wind direction is North
East, hence pollutants will be carried toward south west, which is predominently
covered by dense forest such as Chandaka wildlife sanctuary (elephant reserve)
and other reseve forest. In post monsoon, most predominat wind direction is
North east and west. If this is the secenario, then pollutants will again travel
towards dense forest and towards the human settlement (i.e. towards east). In
summer and monsoon season, cuttack city and human settlemnt in the north
east will be affected by the pollutants because predominant wind direction is
south-west.
Predicting air impact - EIA has been conducted in the summer hence for air
polluting sector winter is considered as the best time to understand the air
pollution impact. In winter atmospheric tubulance is less hence pollution impact
will be far higher with respect to summer. EIA has estimated the ground level
concentration (GLC) for 24 hour for particualte and gaseous pollutants (see page
120, chapter 4, table 4.3) and concluded that there will be no impact on the air
quality. However, no information are availabe on daily wind pattern. Various
literature and books indicates that wind movement varies from day to night,
season to season and place to place. Hence arriving on colclusion based on 24
5
Anshu Eashwar et al, TERI Energy Data Directory and Yearbook, Tata Energy Research Institute, New Delhi, p 168
6
R.P Shukla et. al. 2003, Environment: Issues and Challenges in Thermal Power Generation, Indian Institute of
Management, Ahmedabad, India, p 4
hour GLS seems unscientific. According to the table 3.1, most predominat wind
also varies throught the year. EIA also mentioned that most predominant wind
direction are towards west and south west which blows during summer and
monsoon. In summer, air turbulace is generally high and as a result of this
pollution problem is less, similary in monsoon pollutants get washed off due to
rain, If this is the secenario, then, EIA developer must have calculated the GLS
for all the season. If not, then GLC during winter is crucial from environmental
angle, which has not been estimated in the EIA.