Paryavaran Suraksha Samiti calls Gujarat govt's CRZ clearance to Mithi Virdi N-plant "unconstitutional"
Three senior environmentalists, Krishnakant, Rohit Prajapati and Swati Desai of the Paryavaran Suraksha Samiti, in a statement have alleged that the recent move of the the Gujarat government's department of environment and forest giving coastal regulatory zone (CRZ) clearance to the proposed 6000 MW Nuclear Power Plant (NPP) at Mithi Virdi "is an act of endorsing the illegal and unconstitutional act of the Nuclear Power Corporation of India Limited (NPCIL) and the Engineers India Limited (EIL)."
Signed by veteran Gandhian Chunibhai Vaidya and Shaktisinh Gohil, sarpanch of Jaspara village, and Arjunbhai Dabhi of Mithi Virdi, both leaders of the Bhavnagar Jilla Gram Bachao Samiti, the statement reads, "During and before the environmental public hearing (EPH) for the proposed NPP, villagers, local panchayats and voluntary organisations brought to the notice of the authorities that the EIL does not have necessary accreditation to prepare an Environmental Impact Assessment Report (EIA) for a NPP."
Yet, "in an instance of utter disregard and disrespect to the environmental law and the Constitution of India, NPCIL and EIL went ahead with the EIA study and the collector tried to go ahead with the illegal Public Hearing."
On March 5, 2013, the day of public hearing, the statement says, "about 6,500 villagers, local panchayats and voluntary organisations, raised this issues and sought clarification from the chairman of the public hearing, the then collector of Bhavnagar VP Patel." They failed to get "any answers to the important questions raised by them, and the EPH was held."
The statement adds, "The villagers were left with no choice but to walk out from the illegal, unconstitutional public hearing. NPCIL and EIL have since then continued to resort to the illegal practices. This is evident from its application and presentations for CRZ clearance to the authorities in Gujarat without submitting adequate documents and information."
The environmentalists recall, on June 11, 2013, while giving the so-called CRZ clearance to the NPP, the Gujarat Coastal Zone Management Authority (GCZMA) stated that the authority deliberated on the proposal of the NPCIL, "and after detailed discussion", it decided to "recommend to the Ministry of Environment and Forests, Government of India, to grant CRZ clearance for construction of intake, outfall facilities, jetty and desalination plant at village Mithi Virdi by NPCIL."
The environmentalists contend, the clearance was given "in a very casual manner, without asking for and reading the note on safety aspects, site clearance report, and without undertaking the site visit." They add, "The GCZMA has not taken in account basics, for instance eventualities like population increase in the immediate vicinity of the proposed plant."
The environmentalists comment, "It is unclear if the GCZMA is a victim of the non-transparent and secretive approach of NPCIL, which has not attached the report dated June 28, 2007 of the Site Selection Committee even in the EIA document and also to the GCZMA."
They quote the committee's report which stated that that lignite mining was being carried at a distance of 5 km towards south, that the ship-braking yard at Alang was at distance of 20 km on the southern side of the site, and that the the site was about 30 km from Bhavnagar city.
"On the southern side", the committee had noted, "a small check dam has been constructed to arrest rain water before flowing in to sea. There is hillock after the check dam. The Kalpasar Project, a multi-utility concrete dam across Gulf of Khambat is being planned just 18 km upstream of the site which may have bearing on the design of intake and outfall structure for the plant.”
The committee stated that “lignite mining is carried out nearby but as informed by state government the lignite is of poor grade and mining will be stopped if nuclear power plant is located in the region... Government of Gujarat had informed that there is proposal to develop Mithi Virdi as a port. Gujarat Maritime Board has agreed to shift the proposed port at least five km from the central line of reactor."
Then, the "Kalpasar Project authorities proposes a dam of 65 km in length and top width of 35 metres across the Gulf of Khambat of 18 km north the Chhaya (Mithi Virdi) site. This will (affect) the Nuclear Power Plant, especially due to sedimentation, flooding due to dam break, aspects of reservoir induced seismicity."
Further, the committee said, "The Ship Breaking Yard is touching the exclusion zone boundary of the plant. As per AERB Code, within sterilized zone upto 5 Km natural growth is permitted but planned expansion of activities, which will lead to an enhanced population growth are not allowed by administrative measures."
Saying that these aspects "have been brought to the notice", the committee stated, “A detailed seismotectonic study 300 km radius around site is to be carried out for the assessment of seismic hazards leading to determination of design basis ground motion parameters during design state. Seismotectonic status of offshore region will be included in this study in order to ascertain and offshore existence and extensions of lineaments and faults. Micro- seismic survey of the surrounding area will generate useful data for this purpose. In addition effect if any due to Kalpasar on seismicity should be taken into account at site evaluation stage.”.
Based on this, the committee recommended that a "detailed study be conducted to examine the effect of Kalpasar dam in the upstream of NPP site on the flooding of the proposed site due to breaking of dam in the event of an earthquake of very high magnitude as the Kalpasar dam is located over deep sited fault."
As regards the ship breaking yard, it said, it is "presently located at outskirt of the plant boundary 2 km away from the centre of the 6th reactor building", hence, the restriction of the growth of population in the sterilized zone (5 km area) "is required to be maintained by administrative action" And as for lignite mining, "surface mining, as done in Kudankulam project, can be permissible up to the start of plant."
Environmentalists wonder why this information is not crucial for the GCZMA. "While the Environmental Appraisal Committee (EAC) of the Ministry of Environment and Forest has sought the clarification regarding the issue of accreditation of EIL for NPP, GCZMA has hastily decided to grant conditional clearance to the project without even checking the mandatory accreditation certificate of the EIA consultant", they underline.
Yet, "in an instance of utter disregard and disrespect to the environmental law and the Constitution of India, NPCIL and EIL went ahead with the EIA study and the collector tried to go ahead with the illegal Public Hearing."
On March 5, 2013, the day of public hearing, the statement says, "about 6,500 villagers, local panchayats and voluntary organisations, raised this issues and sought clarification from the chairman of the public hearing, the then collector of Bhavnagar VP Patel." They failed to get "any answers to the important questions raised by them, and the EPH was held."
The statement adds, "The villagers were left with no choice but to walk out from the illegal, unconstitutional public hearing. NPCIL and EIL have since then continued to resort to the illegal practices. This is evident from its application and presentations for CRZ clearance to the authorities in Gujarat without submitting adequate documents and information."
The environmentalists recall, on June 11, 2013, while giving the so-called CRZ clearance to the NPP, the Gujarat Coastal Zone Management Authority (GCZMA) stated that the authority deliberated on the proposal of the NPCIL, "and after detailed discussion", it decided to "recommend to the Ministry of Environment and Forests, Government of India, to grant CRZ clearance for construction of intake, outfall facilities, jetty and desalination plant at village Mithi Virdi by NPCIL."
The environmentalists contend, the clearance was given "in a very casual manner, without asking for and reading the note on safety aspects, site clearance report, and without undertaking the site visit." They add, "The GCZMA has not taken in account basics, for instance eventualities like population increase in the immediate vicinity of the proposed plant."
The environmentalists comment, "It is unclear if the GCZMA is a victim of the non-transparent and secretive approach of NPCIL, which has not attached the report dated June 28, 2007 of the Site Selection Committee even in the EIA document and also to the GCZMA."
They quote the committee's report which stated that that lignite mining was being carried at a distance of 5 km towards south, that the ship-braking yard at Alang was at distance of 20 km on the southern side of the site, and that the the site was about 30 km from Bhavnagar city.
"On the southern side", the committee had noted, "a small check dam has been constructed to arrest rain water before flowing in to sea. There is hillock after the check dam. The Kalpasar Project, a multi-utility concrete dam across Gulf of Khambat is being planned just 18 km upstream of the site which may have bearing on the design of intake and outfall structure for the plant.”
The committee stated that “lignite mining is carried out nearby but as informed by state government the lignite is of poor grade and mining will be stopped if nuclear power plant is located in the region... Government of Gujarat had informed that there is proposal to develop Mithi Virdi as a port. Gujarat Maritime Board has agreed to shift the proposed port at least five km from the central line of reactor."
Then, the "Kalpasar Project authorities proposes a dam of 65 km in length and top width of 35 metres across the Gulf of Khambat of 18 km north the Chhaya (Mithi Virdi) site. This will (affect) the Nuclear Power Plant, especially due to sedimentation, flooding due to dam break, aspects of reservoir induced seismicity."
Further, the committee said, "The Ship Breaking Yard is touching the exclusion zone boundary of the plant. As per AERB Code, within sterilized zone upto 5 Km natural growth is permitted but planned expansion of activities, which will lead to an enhanced population growth are not allowed by administrative measures."
Saying that these aspects "have been brought to the notice", the committee stated, “A detailed seismotectonic study 300 km radius around site is to be carried out for the assessment of seismic hazards leading to determination of design basis ground motion parameters during design state. Seismotectonic status of offshore region will be included in this study in order to ascertain and offshore existence and extensions of lineaments and faults. Micro- seismic survey of the surrounding area will generate useful data for this purpose. In addition effect if any due to Kalpasar on seismicity should be taken into account at site evaluation stage.”.
Based on this, the committee recommended that a "detailed study be conducted to examine the effect of Kalpasar dam in the upstream of NPP site on the flooding of the proposed site due to breaking of dam in the event of an earthquake of very high magnitude as the Kalpasar dam is located over deep sited fault."
As regards the ship breaking yard, it said, it is "presently located at outskirt of the plant boundary 2 km away from the centre of the 6th reactor building", hence, the restriction of the growth of population in the sterilized zone (5 km area) "is required to be maintained by administrative action" And as for lignite mining, "surface mining, as done in Kudankulam project, can be permissible up to the start of plant."
Environmentalists wonder why this information is not crucial for the GCZMA. "While the Environmental Appraisal Committee (EAC) of the Ministry of Environment and Forest has sought the clarification regarding the issue of accreditation of EIL for NPP, GCZMA has hastily decided to grant conditional clearance to the project without even checking the mandatory accreditation certificate of the EIA consultant", they underline.
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