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India: Letter to Ministry of Environment and Forests re serious anomalies in the EIA report for the Mithi Virdi Nuclear Power Plant

27 February 2013

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Paryavaran Suraksha Samiti
c/o 37 Patrakar Colony, Tandalja, Vadodara 390 020, Phone/Fax: 0265-2320399
Email: tokrishnakant at gmail.com, rohit.prajapati at gmailc.om

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27 February 2013

To,
Smt. Jayanthi Natarajan
Minister of State for Environment and Forests
Paryavaran Bhavan, CGO Complex, Lodhi Road, New Delhi – 110 003

The Secretary
Ministry of Environment & Forests, Government of India
Paryavaran Bhavan, CGO Complex, Lodhi Road, New Delhi - 110 003.

The Chairman
Central Pollution Control Board
Parivesh Bhawan, CBD-cum-Office Complex, East Arjun Nagar, DELHI - 110 032

The Member Secretary
Central Pollution Control Board
Parivesh Bhawan, CBD-cum-Office Complex, East Arjun Nagar, DELHI - 110 032

The Zonal Officer
Central Pollution Control Board
Parivesh Bhawan, Opp. VMC Ward Office No. 10, Subhanpura,
Vadodara - 390 023

The Chairman
Gujarat Pollution Control Board
“Paryavaran Bhavan” Sector 10-A, Gandhinagar - 382 010

The Member Secretary
Gujarat Pollution Control Board
“Paryavaran Bhavan” Sector 10-A, Gandhinagar - 382 010

The Regional Officer
Gujarat Pollution Control Board
Plot No. 1154/2, B, Ghogha Circle,
Pattani Road, Bhavnagar - 364 002

The Chairman / The Collector
Environment Public Hearing Committee of Bhavnagar

Subject: Following serious anomalies in the EIA report for the Mithi Virdi Nuclear Power Plant prepared by Engineers India Limited, request to immediately cancel the Environmental Public Hearing.

Reference: Our letter dated 22 February 2013 - Demand to cancel the scheduled Environmental Public Hearing as well as rejection of the EIA report of the Mithi Virdi Nuclear Power Plant prepared by ‘Engineers India Limited’ consultants for ‘Nuclear Power Corporation of India Limited.’ Engineers India Limited do not have necessary accreditation.

Madam/ Sirs,

This follows our earlier representation dated February 22, 2013 pointing out how an un-accredited consultant, Engineers India Limited(EIL) was appointed by the Nuclear Power Corporation of India Limited to prepare the Environment Impact Assessment (EIA) report for proposed 6000 MW Nuclear Power Plant at Mithi Virdi area of Bhavnagar district, Gujarat. While we seek the cancellation of the public hearing for the plant, we bring to your notice serious anomalies which have come to fore.

First, the Terms of Reference for the MoEF at point no. 7 clearly mention that “The study area should cover an area of 10 km radius around the proposed site for conventional pollutants and 30 km radius for radiological parameters.” Instead the EIA report categorically mentions that 30 Kms for radiological areas of the study will be undertaken in future, the radiological survey is yet to be carried out for 30 Kms area and have not been carried out as stipulated by MoEF in the Terms Of Reference (TOR).

But this has been clearly violated. No villager/village panchayat in the 10-30 kms radius has been informed or served notice for the public hearing as the rules stipulate by the concerned authorities.

The EIA report clearly states that the study has been done only within 10 km radius and it is in future further studies will be conducted. The report itself mentions:

Page 283

“Areas Surveyed

Radiological survey will be done up to a radial distance of 30 km around the plant. Generally, samples from various environmental matrices will be collected from the survey area. The indicator organism like goat thyroid will be collected from selected area (as per the requirements of AERB). Different types of samples will be collected from the terrestrial and aquatic environs of the 30km study area covering, soil, cereals, pulses and vegetation samples. Typically around 1000 samples will be collected and analysed every year. List of sampling locations, frequency of sampling and different types of samples to be monitored during post project period in different area will be worked out as per the requirements of AERB.

Page 383

“11.1.3 MONITORING RADIOLOGICAL PARAMETERS AROUND MITHIVIRDI

Comprehensive radiological survey will be conducted by Health Physics Division (HPD) of Bhabha Atomic Research Centre in the zone of radial distance of 30 km and the same will be continued till the life of Mithivirdi NPP for monitoring of radiation impacts and to establish that the radiation dose, in the public domain are within the prescribed limits of AERB.”

Thirdly, the EIA report mentions that a detail of the de-commissioning of the plant is explained in the section 4.3.11 of Chapter 4, as stipulated.

But there is no section 4.3.11 in the Chapter 4 of the EIA report and the sections are only upto section 4.3.10. We understand that the said details have not been gathered and the study remains incomplete as there is no mention of that in the EIA report.

Sr. No. TOR of MoEF TOR Compliance Our contention
7 The study area should cover an area of 10 km radius around the proposed site for conventional pollutants and 30 km radius for radiological parameters Study on conventional pollutants covered in Section 3.4 of Chapter – 3 & Study on radiological parameters covered in Section 3.5.11 of Chapter – 3 of EIA report The study is incomplete, villages in the area 10-30 kms not notified about public hearing.
35 Issues relating to de-commissioning of the plant and the related environmental issues should be discussed De-commissioning of the plant is explained in Section 4.3.11 of Chapter – 4 The study is incomplete, section mentioned is not in the report.

We demand that:

  • The concerned authority should immediately cancel the EPH as EIA is incomplete.
  • The concerned authority should immediately reject the EIA of Mithi Virdi Nuclear Power Plant of NPCIL prepared by EIL as EIA is incomplete.
  • The concerned authority should apologise to the people of Gujarat for such a grave mistake allowing EPH on an illegal and incomplete EIA.
  • The concerned authority should pass stricture against NPCIL and consultant EIL for such an illegal action on their part.

Expecting your positive and prompt response.

Krishnakant , Rohit Prajapati, Swati Desai
Activists
Paryavaran Suraksha Samiti