Introduction

The Environmental Statement (ES) is an environmental audit report submitted by industries to the concerned State Pollution Control Board (SPCB) under Section 15 of the Environment Protection Rules,1986. As per the International Chamber of Commerce, the environmental statement is defined as “a management tool comprising of a systemic, documented, periodic, and objective evaluation of how well the organisation is performing in safeguarding the environment by facilitating management control of environmental protection and assessing compliance with company policies”.

All industries requiring consent order under the Water (Prevention & Control of Pollution) Act,1974, Air (Prevention & Control of Pollution) Act,1981, and Hazardous Wastes (Handling and Management) Rules, 1989, should submit environmental statements to the concerned SPCBs. The timeline for submitting the environmental statement is in the month of September every year, for the previous financial year. An environment statement contains the data for the current as well as previous financial year.

Purpose of the Environmental Statement

 

 

The environmental statement has the details of raw material consumption, pollution emitted into the environment and the environmental protection measures that are being adopted by the industries. In the wake of resource scarcity arising out of frequent usage of resources, there is a need for optimising the essential resources that are used by the industries. For this reason, regulatory authorities should keep track of resource consumption by the industries and ensure they adhere to the rules and regulations prescribed by the Ministry of Environment, Forest and Climate Change (MoEF&CC).

Sections of Environmental Statement

An environmental statement has been divided into several sections each section bears data for different category of environment.  

Section

Details

Part -A

General details of the plant

Part-B

Water and raw material consumption

Part-C

Pollution generated

i) Air

ii) Water

Part-D

Hazardous material used, generated and disposed

Part-E

Solid waste used, generated and disposed

Part-F

Characteristics and quantum of hazardous and solid waste, and methods adopted to dispose them.

Part-G

Impact of Pollution control measures on conservation of natural resources and consequently on the cost of production

Part-H

Investment for environment protection and abatement of pollution

Part-I

Miscellaneous - any other particulars for improving the quality of the environment

 

Thermal Power Plants and Fly ash

Thermal power plants use coal as primary input raw material to produce power. However, coal is considered to be a dirty fuel as it is seen as a highly polluting source right from mining to power generation. Burning of coal creates ash which is carried out through the flue along with gas - this is otherwise known as fly ash; remaining ash collected at the bottom of the boiler is called as bottom ash. The composition of ash differs depending on the quality of coal. Carbon, sulphur, nitrogen are some of the commonly found elements in ash along with few heavy metals like arsenic, mercury, etc. These heavy metals escape via the flue, but once the flue gas is released into the atmosphere its presence can cause widespread pollution and affect the health of living organisms. The amount of fly ash generated depends on the ash content in the coal. Higher the ash content, higher the amount of fly ash. Further, the age of coal determines the ash content - older the age of coal, lower the ash content.

Utilisation of fly ash generated by the thermal power plants has been mandated by the MoEF&CC. Fly ash can be used as a substitute for raw materials in many places such as manufacturing of cement, bricks, tiles, few other construction materials, and also used in mine backfilling and as a soil amendment in agriculture since fly ash has certain essential minerals in it. The utilisation of fly ash has been monitored by the Central Electricity Authority (CEA). A report on generation and utilisation of fly ash should be submitted to the CEA at the end of every financial year. This report serves as a tool to keep track of fly ash generation and to keep a check on the pollution.

 

 

Case study of SDSTPS

 

 

Sri Damodaram Sanjeevaiah Thermal Power Station (SDSTPS) is located in Nelatur Village which is 23 Kms from Nellore District of Andhra Pradesh. It has a capacity of 1600 MW (2x800MW). The analysis is made using the environmental statement acquired through RTI requests.

As stated previously, Part -E of the statement contains details of solid waste generated from the power plant. Solid waste generated from the thermal power plants include fly ash, plastic waste, ferrous scrap, non-ferrous scrap, stationery items, discarded spare parts, wood waste, and STP sludge.

Analysis of environmental statements of SDSTPS shows that for two consecutive years of 2015-16, 2016-17, only fly ash was considered and no other solid waste was mentioned.

Secondly, when the environmental statements are analysed along with fly ash utilisation report of 2015-16, there are variations in reporting on data related to solid waste, especially for the year 2015-16. Also, only the details of the quantity recycled or re-utilised within the unit (i) and sold (ii) (refer image 2 & 3) remains the same, all the other data including total generated ash differs in both the statements.

1. Data for fly ash generation and utilisation in the year 2015-16

2. Environmental statement of 2015-16

3. Environmental statements for the year 2016-17

This implies, potential under-reporting. Further, a mismatch in data could amount to non-adherence of Fly ash Utilisation Notification by MoEF&CC. Under-reporting will lead to suppression of details regarding fly ash utilisation.

Detailed visualisation of the documents pertaining to SDSPTS can be found in this link.

The above analysis of the environmental statement of SDSTPS and fly ash utilisation highlights the lacunae in monitoring and compliance procedures. It highlights the need for a mechanism requiring cross-checking to ensure adherence by thermal power plants. Cross-referencing of a single data gives us a clear picture about the compliance of the power plants in relation to the monitoring by regulatory authority.