The below is a detailed evaluation of the EIA report, based on a community request from Ekta Parishad, a local NGO in Chhattisgarh.

Transcription

1 EIA Review of Nalwa integrated steel plant (NSPL) Background Nalwa integrated steel plant (0.198 MTPA sponge iron), located near village Taraimal, Raigarh district, Chhattisgarh proposes to expand its plant by another MTPA sponge iron capacity. The expansion proposal by the company includes iron and steel making, steel rolling sinter plant, coke oven, oxygen plant and producer gas plant, waste heat and char using power plant. The expansion project needs an environmental clearance from the ministry of environment and forests (MoEF). The term of reference (ToR) for preparing the environment impact assessment (EIA) report of the project was granted by the ministry on April 13, The EIA report of the project has been prepared by EMTRC consultants Pvt. Ltd. Public hearing of the project to incorporate the public opinion on the project is proposed to be held on March 7, The below is a detailed evaluation of the EIA report, based on a community request from Ekta Parishad, a local NGO in Chhattisgarh. Capacity The Company proposes to expand its steel making/processing capacity by MTPA 1. It has plans to increase its sponge iron plant, steel making shop, rolling mill, coal washery, etc. s processing capacity. The new inclusions in the expansion proposal include a Blast furnace, coke oven and an electric arc furnace in the steel melting shop. Name of the Unit Existing Capacity Proposed Addition Blast Furnace Nil TPA Sponge Iron Plant TPA TPA Sinter Plant Nil TPA Coke Oven Nil TPA Steel Making Shop(SMS); TPA Electric Arc Furnace (EAF) Steel Making Shop TPA (2*12 tons + 1*30 tons induction furnace) TPA (3*30 tons induction furnace) Rolling mill TPA TPA Coal Washery TPA TPA WHRB based CPP 8 MW 60 MW AFBC based CPP using coal, 16 MW 135 MW (CFBC) rejects Producer gas plant 1200 Nm 3 /hr 1200 Nm 3 /hr Oxygen plant 100 Nm 3 /hr 3000 Nm 3 /hr Anticipated Environmental Impacts Air: The Company proposes to establish the following air pollution control devices, 1 Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg 1

2 S No Name of the unit Air Pollution Control Device Stack height 1 Blast furnace Multiclone and 2 stage wet 48 venturi scrubber 2 BF Stock House Bag filters 30 3 DRI Plant dedusting Bag filters 30 4 DRI Kiln Electrostatic precipitator (ESP) 70 5 Sinter Plant dedusting ESP 45 6 Sinter Machine ESP 80 7 SMS (EAF) FES and Bag filters 60 8 SMS Plant Dedusting Bag filters 30 9 SMS (IF) FES and Bag filters SMS (IF) Dedusting Bag filters Rolling Mill none Coke oven lime scrubber Power plant (135 MW CFBC boiler) ESP 130 The study has used Briggs equation for air pollution modelling. In the modelling, each stack has been considered as a point source, baseline environment data of the area has been used as the background and the incremental pollutant values for each stack has been studied. Based on which the report mentions that no instance of exceedance of standard either due to proposed plant alone or when the plant contribution to the background air quality is observed. 2 Comments: The report fails to take into account the secondary emissions fugitive emissions from the coal storage and ash handling plant. Fugitive emissions are non captured emissions from the plant Emissions due to transport of raw materials, finished products etc has been calculated separately. An overall cumulative analysis of the air emissions from point sources, transport and fugitive emissions has not been calculated. For fugitive emission control at the wagon tippler and transfer points, the EIA report suggests an elaborate network of dry fogging system, air curtains and water sprinkling system. 3 However from CSE s green rating experience, dry fog system alone is not an efficient enough practice to control fugitive dusts in open coal storage areas. It is to be noted that in Indian steel industry, Particulate matter is the only pollutant that is regulated across different process stages in steel plant; SO 2 and NO x are seldom monitored. 4 The air pollution control devices mentioned in the table above (except for the scrubbers) are devices which controls only particulate matter emission. Water: 22,680 kilo litres/day water will be required for the expansion project, which will be taken from Mahanadi River and transported by pipelines. Permission to draw 20 million cubic meter (MCM) water per annum has been given by Chhattisgarh Government to the company. 2 Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg 40 4 Bhushan et al, 2012, Into the furnace the life cycle of the Indian Iron and Steel Industry, Centre for Science and Environment, pg 191

3 Comments: When the water requirement is only 8.27 million cubic metre per annum. The company has obtained a 20 million cubic meter water withdrawal permission which looks an odd case. The clearance for 20 million cubic metre has already been granted to the plant by state officials it is to be clarified by the company whether this water clearance has been given by the state authorities for only the expansion project or both the existing and expansion project. In any case the upcoming plant is a water inefficient plant. From CSE s green rating project experience, Indian s Best steel plant s specific water consumption was 6 cub.m/tonne of steel, for Global best steel plant it is 5 cub.m/tonne of steel while the NSPL s expansion requires This excess consumption by the plant is an indication that it might adopt old technologies. Waste Water: The Company proposes to construct the following systems for waste water treatment from different units 6, S N o Name of the unit Water Consu mption in Wastewa ter Generati on in Treatment System 1 Sponge Iron Plant settling tank wet dust scrubber; Gas Cleaning 2 Blast Furnace 55 nil plant; sludge pond 3 Sinter Plant 10 nil settling tank Steel melting shop and rolling settling tank; O&G 4 mill trap; scale pit 5 Oxygen plant settling tank 6 Coke oven 20 nil settling tank 7 Power Plant Producer gas plant 10 1 Neutralizing pit; O&G trap; sedimentation pits; ash storage dyke The water shall be reused for flaring in dryer kiln for drying raw materials. Coal tar Reuse Scheme used for slag granulation wet scrubbing in GCP sinter nodulising used for slag granulation used for BF slag granulation 100 per cent coke quenching 100 per cent ash handling and disposal also for dust suppression 5 CSE Green Rating Network 6 Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg 8

4 S N o Name of the unit Water Consu mption in Wastewa ter Generati on in Treatment System shall be sold as byproduct. Reuse Scheme 9 Utilities and misc. domestic sewage Total 945 (22680 kl/d) effluent treatment Reused for plant gardening Treated to meet the stipulated standards and then 100 percent reused or recycled within the plant premises. There will be no discharge outside the plant premises. Solid Waste: The solid waste utilization and management scheme of the plant is shown below, S.No Name of the unit Type Waste of Quantity (TPA) Sponge Iron Plant Dust Char Sinter Plant Dust Blast Furnace Slag Sludge and flue dust Steel Melting Shop Slag flue dust Rolling Mill mill scales 2000 Coke Utilization & Disposal Plan 100% dust will be used in Sinter Plant 100% char will be used for power generation 100% dust recycled in sintering process 100% Slag will be granulated and sold for cement making. 100% dust will be reused in Sinter Plant. 100% slag and dust will be given for metal recovery, then used in sinter plant to maintain basicity, converted to aggregates and used in road making. 100% dust will be reused in Sinter Plant. 100% reused in Electric Arc Furnace oven coke dust % reused in sinter plant 100% reused as per MOEF Notification Used in cement making, brick making, block making, aggregate making, Producer wasteland filling and road gas plant coal ash making. Unutilized portion of coal

5 S.No. Name of the unit Type Waste of Quantity (TPA) Utilization & Disposal Plan ash will be disposed in worked out coal mines. 8 9 Captive power plant flyash and bottom ash ETP, Settling tank, drains sludge % reused as per MOEF Notification Used in cement making, brick making, block making, aggregate making, wasteland filling and road making. Unutilized portion of coal ash will be disposed in worked out coal mines. Dried in SDB and 100% used as base material for road making, wasteland filling, filler materials in making embankments, flyovers, etc Comments: Though claimed, whether 100 per cent usage of all waste in the plant is a question because CSE s experience in the green rating of steel has seen very few plants which was recycling 100 per cent of its solid waste. Blast furnace slag, fly ash, bottom ash are said to be used in cement plants. However whether the cement plant which will use up all the waste generated has been identified or not remains a question as the EIA report does not mention any linkages with any nearby Cement Company. The existing Jindal power plant which is about 10 km away from the proposed steel plant could not sell its ash and is presently dumping its ash into its ash pond and nearby abandoned mines. In such a case where the waste will be stored until the identification of linkage remains a question The fate of 0.5 MTPA waste remains a question even if stored at a 2 m height the storage of 0.5 MTPA waste would require 26.7 ha land about 20 per cent of the project s expansion area. The Figure 2.2 Layout Plan of the Project (Showing existing plant and new land to be acquired for the expansion project) 7 in the EIA report points a pictorial ash disposal area however the area in hectares of the ash disposal pond is not discussed. Brick making, block making, aggregate making, etc. consume very negligible quantities of ash. Wasteland filling, road making, abandoned mine filling, etc. are discussed as options however if those areas has been identified are not mentioned in the EIA report. SMS Slag SMS slag is a concern in most steel plants of the country. Only 10 per cent of the slag can be reused in sinter plant. The remaining 90 per cent or 0.1 MTPA slag has to be used for road making. However the linkage (with any company) has been established to give away the slag material for road making has not been discussed. In that case till identification of a linkage the company owes the responsibility for the safe storage of the slag, whether the company holds the area necessary for handling 0.1 MTPA waste has not been discussed (0.1 MTPA if stored at 2 m height would require 5.6 ha land which is about 4 per cent of the total land required for expansion). 7 Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg 27

6 Transport: Iron ore will be purchased from mines located in Orissa. Limestone, quartzite, dolomite and Mn ore will be purchased from Mines located in Chhattisgarh and Madhya Pradesh. The materials will be transported by rail and unloaded at Railway Siding of NSPL near Kirorimal Nagar railway station (which is about 12km from NSPL). 8 Coking coal shall be imported. Run of Mine Coal will brought from captive coal mines of NSPL located in Gare (Block IV/6) through common conveyor. Finished Products will be transported up to the railway siding by road. The transport of the above discussed will add on to an additional 570 multi axle vehicles along the two lane road which already has about 419 vehicles plying along. The EIA report suggests the two lanes to be converted to a 4 lane road to cope up with the additional traffic. 9 Comments: The efforts taken from the company s side to convert the existing 2 lane to 4 lane has not been discussed in the report. Whether National Highway Authority has permitted the expansion has also not been discussed. The transport of ash and slag for disposal to railway sidings also require transport, however their numbers have not been included in the traffic or transport analysis. Cost of the expansion project: Rs.3500 crores 10. CSR costs: The Company has earmarked 5 per cent of the project cost for undertaking CSR activities (Rs.175 crores) The CSR activity of the company includes development of 100 acres charagaha land for Taraimal gram panchayat, establishing a veterinary health care centre, ITI training centres, rooftop rainwater harvesting structures, anicuts on nallahas, organising annual agriculture fairs, training programs/demonstration projects for converting household organic waste into manure, traditional handicrafts promotions programs, sponsoring sports and educational activities, mobile dispensary park, garden development; local temple renovation, etc., footpath, road dividers, traffic light maintenance, etc., village pond renovation, building secondary school, technical institute, higher secondary schools, etc. 12 Land Required for Expansion: 120 hectares land will be acquired for the expansion project ha is private land in the area. 13 A break up of the land usage is not discussed. R&R: No displacement of human settlement is involved says the executive summary. 14 However, the report discusses the amount of compensation to be paid to the land losers. The compensation amount varies between 6 to 10 lakhs depending on the type of land. The numbers of land losers have not been discussed. Comments: The compensation amount is specified as 6 to 10 lakhs, however whether its per acre, or per hectare, etc. are not mentioned in the EIA report. 8 Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg 32 9 Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg 25

7 Tree cutting: Site clearing for establishing the proposed project will involve tree cutting. There are about 3000 trees on the identified land. The identified land is not forest land. Permission of Tree Cutting Officer (State Forest Department) shall be obtained to cut trees. While planning the layout it has been ensured that maximum trees are retained. Many trees will be also transplanted. 33 per cent land shall be developed as greenbelt. About trees shall be planted on 38.5 ha land area. This will mitigate the adverse impact of tree cutting. 15 Overall Comments: The EIA report mentions that there are 70 other industries in the area within 25 km radius of the project. 16 (Index page mentions these industries to be within 10 km radius of the project 17 ) An overall impact analysis of industries in the area has not been done. The expansion project also involves clearing of trees which are currently acting as a sink to the pollution from the nearby industries. Therefore there is a greater need to go in for a cumulative impact and carrying capacity study of the area before letting new projects. 15 Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg Anon, 2011, EIA Report of Integrated Steel Plant Village Taraimal, Raigarh, Chattisgarh Nalwa Steel & Power Limited, EMTRC Consultants Pvt. Ltd., Delhi. pg ix