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Annual Environment & Social Monitoring Report (April 2012 to March 2013)

The Environmental and Social Performance Report is a document of the borrower. The views expressed herein do not necessarily represent those of ADB’s Board of Directors, Management, or staff, and may be preliminary in nature. Your attention is directed to the “Terms of Use” section of this website.

Environmental and Social Performance Report September 2013

IND: Mundra Ultra Mega Power Project

Prepared by SENES Consultants India Pvt Ltd.

Annual Environment & Social Performance Report – Tata Ultra Mega Coal Fired Power Plant, Mundra

Period: April 2012 to March 2013

Submitted to: Coastal Gujarat Power Ltd (CGPL)

Prepared by: SENES Consultants India Pvt Ltd.

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Table of Contents

1 Introduction ........................................................................................................................ 1

Background ......................................................................................................................................... 1

Objective ............................................................................................................................................. 1

ESPR Preparer .................................................................................................................................... 2

Environmental Management Plan (EMP) & Social Management Plan (SMP) Implementation ........ 2

2 Overall Project Status ......................................................................................................... 2

3 Compliance by CGPL with the Environmental, Health & Safety Requirements ............... 3

3.1 Compliance to IFC & ADB Requirements ......................................................................... 3

3.1.1 Environment Organization Structure & Capacity Building ............................................ 3

3.1.2 Integrated Management System (IMS) Development ...................................................... 3

3.1.3 Consent Management ...................................................................................................... 3

3.1.4 Coal Quality & Consumption ......................................................................................... 3

3.1.5 Fly Ash Management ...................................................................................................... 4

3.1.6 Hazardous Waste Management ...................................................................................... 4

3.1.7 Management of Cooling Water Discharge ..................................................................... 4

3.1.8 Performance of Waste Water Treatment Facilities ......................................................... 5

3.1.9 Flue Gas Emissions & ESP Performance ....................................................................... 6

3.1.10 Ash Pond Structural Integrity ......................................................................................... 6

3.1.11 Ground Water Monitoring .............................................................................................. 6

3.1.12 Ambient Air & Noise Quality Monitoring ....................................................................... 6

3.1.13 Green Belt Development & Mangrove Afforestation ...................................................... 7

3.1.14 HSE Management System ............................................................................................. 25

3.1.15 HSE Organizational Structure ...................................................................................... 25

3.1.16 Safety Awareness Programs/Plans ............................................................................... 25

3.1.17 Coal Storage & Handling - Fire & Safety Risks ........................................................... 25

3.1.18 Non-Ionization Radiation .............................................................................................. 26

4 Compliance by CGPL with the Social Requirements ...................................................... 31

4.1 Compliance to IFC & ADB Requirements ....................................................................... 31

4.1.1 Community Relations Organization Structure & Capacity Building ............................ 31

4.1.2 Grievance Redressal Mechanism .................................................................................. 31

4.1.3 Stakeholder Engagement Plan ...................................................................................... 32

4.1.4 Community Development Plan ...................................................................................... 32

4.1.5 Payment of Taxes and Cess to Villages......................................................................... 33

5 Compliance with Country Requirements ......................................................................... 44

6 List of Photographs ........................................................................................................... 52

List of Annexure

Annexure 1: Details of Project In-Use Facilities .................................................................................. 55

Annexure 2: Green Belt Development Details (Apr‟12 to Mar‟13) ..................................................... 56

Annexure 3: Blended Coal Quality Used (Apr‟12 to Mar‟13) ............................................................. 57

Annexure 4: Fly Ash Utilization Report for FY 2012-13 ..................................................................... 58

Annexure 5: Fly Ash Radioactivity Test Certificate ............................................................................. 59

Annexure 6: Fly Ash Radioactivity Test Certificate ............................................................................. 61

Annexure 7: Graphical Plot - Online Cooling Water Temperature Difference (2012-13) ................... 64

Annexure 8: Graphical Plot - Manual Cooling Water Temperature Difference (2012-13) .................. 64

Annexure 9: Continuous Emission Monitoring System – Statistical Data Analysis (2012-13) ........... 65

Annexure 10: Manual Monitoring– Statistical Data Analysis (2012-13) ............................................. 66

Annexure 11: Monitoring Data Interpretation of Condensate Cooling Water (2012-13) ..................... 67

Annexure 12: STP Treated Water Monitoring Results & Analysis (2012-13) ..................................... 68

Annexure 13: Project Site Windrose (Jan-Mar 2013) Overlaid on AAQ Network .............................. 69

Annexure 14: Graphical Representation AAQ Monitoring Results (Jan-Mar‟13) ............................... 70

Annexure 15: Project Site - Ambient Air Quality Profile (Jan-Mar‟13) ............................................... 72

Annexure 16: Village Level Day Time Noise Monitoring Plot (2012-13) ........................................... 73

Annexure 17: Village Level Night Time Noise Monitoring Plot (2012-13) ......................................... 74

Annexure 18: Annual Returns Submitted Under Factories Act ............................................................ 75

Annexure 19: Annual Returns Submitted Under Contract Labour Act ................................................ 78

Annexure 20: Annual Returns Submitted Under BOCW Act .............................................................. 80

Annexure 21: Safety Performance Monitoring (2012-13) .................................................................... 83

Annual Environmental & Social Performance Report (FY 10-11) – CGPL Power Plant, Mundra

September 2013 1 SENES

ANNUAL ENVIRONMENTAL AND SOCIAL PERFORMANCE

REPORT

(ESPR)

Reporting Period: April 2012 to March 2013

EPSR Completion Date: July 2013

1 Introduction

Background

Coastal Gujarat Power Limited (CGPL), a wholly owned subsidiary of the Tata Power

Company Limited will build, own and operate an ultra mega power plant at Mundra in

Gujarat. The project includes five supercritical units of 800 MW each, with total capacity of

4000 MW. The plant will use 12 Million Metric Ton Per Annum (MMTPA) of imported coal

as fuel, and sea water for once through cooling of condensers. Power will be evacuated

through six 400 KV power lines to benefits the states of Gujarat, Maharashtra, Punjab,

Haryana and Rajasthan.

The project has started in September, 2007. CGPL has sought financial loans from several

international banks including the International Finance Corporation (IFC) and Asian

Development Bank (ADB). As per the common term schedule to loan agreement between

CGPL and the Lenders; Tata Power has entrusted SENES Consultants to carry out

Environment Health Safety and Social (EHSS) compliance audits on a quarterly and annual

basis during the construction period.

Objective

The purpose of this Annual Environmental & Social Performance Report (ESPR) is to report

on CGPL‟s compliance with the Environmental and Social Performance Requirements of

IFC/ADB (including implementation of the Environmental Management Plan and the Social

Management Plan) and to asses any corrective actions implemented/proposed. The ESPR

encompasses implementation by CGPL of all phases of the Project. It includes:

Contact information for responsible individuals

Compliance by CGPL with environmental and social requirements for the Project

Environmental and social aspects of the Project under implementation

Occupational health and safety performance and significant incidents

Sustainable development initiatives and community relations



ESPR Preparer

Report prepared by: SENES Consultants India Pvt. Ltd.

Telephone: 022-27576298 / 32986995

E-mail: [email protected] / [email protected]/ [email protected]

Signature:

Report Date: July 2013

Environmental Management Plan (EMP) & Social Management Plan (SMP) Implementation

The following groups of the Tata Power Corporate Office and CGPL‟s on-site team are responsible

for EMP and SMP implementation:

Tata Power Corporate Office : Sustainability, Environment and Safety;

On-site team at Mundra: Safety & Environment; HR – Labour& Health; CSRHR - Land

Acquisition, CSR

2 Overall Project Status

COD for all 5 units declared withgeneration continued as per schedule for Unit#10, 20, 30 &

40.

Unit#50 :Turbine valves combination Turbine water induction Protection test completed on

15/02/13 and unit synchronized on 04/03/13. Coal Firing started on 23/02/13 first time in

unit#50 with COD declared on 21/03/13 following reliability tests. TG Building and UCB

(Simplex): Major civil works completed with IPS & painting works are in progress. HP

Piping Erection Works: 1882/1882 nos. joints welded. Insulation works in progress. Fire

Protection Systems (Minimax): HVW spray system piping erection in transformer yard and

MVW spray system in UCB and MV switchgear room commissioned. Ash handling system:

Bottom Ash HP & LP piping hydro test completed on 10/02/13. Clinker grinder erection

completed on 09/02/13. Bottom Ash system commissioned on 16/02/13.

External Linkages and Others: All 3 nos. 400KV double circuit lines are commissioned

The details of the in-use facilities for the project are presented in Annexure 1.



3 Compliance by CGPL with the Environmental, Health & Safety

Requirements

3.1 Compliance to IFC & ADB Requirements

This section in brief outlines the environmental performance of the project for the period FY

2012-13 in consistent with the IFC Performance Standards & EHS Guidelines, ADB

Summary Environmental Impact Assessment including Environmental Management Plan

developed for the project. The assessment and findings matrix has been presented in Table 1

for necessary reference.

A. Environmental Performance

3.1.1 Environment Organization Structure & Capacity Building

Onsite environmental management is currently driven by only a Senior Manager –

Environment and Executive – Environment. With the plant now in full scale operation it is

necessary to strengthen the onsite environmental management teamto address

environmental aspects of the project, facilitate regulatory liasioning and corporate

sustainability initiatives specific to the region.

3.1.2 Integrated Management System (IMS) Development

CGPL in coordination with an external consultant has prepared necessary documentation as

required for IMS certification; however the same is pending for review and final verification

by CGPL prior to initiating the certification process. With project now in full scale operation

CGPL to obtain IMS certification on a fast track basis and also to ensure that EMP

conditions, legal and lender EHS requirements are integral to the certified IMS.

3.1.3 Consent Management

CGPL is assessed to possess valid environmental permits/consents for project operations,

hazardous and biomedical waste management from Gujarat Pollution Control Board, MoEF

and is carrying out periodic compliance reporting to these regulatory authorities as required

under specific consent conditions

3.1.4 Coal Quality & Consumption

CGPL is currently utilizing blended coal (70% Ecocoal and 30% Melawan coal) for operation

of all the 5 units. Review of the coal quality and consumption records for the period 2012-13

reveal that the CGPL is currently in compliance to the project Environmental Clearance (EC)

requirement to this aspect. Additionally CGPL has also engaged an external agency (M/s

VishuddhaEnvirotech) to assess any possible environmental implications associated with the

use of such blended coal; however the report has not identified any potential environmental

risks in terms of increased coal consumption, augmentation of coal handling & transport

system and adequacy of existing pollution control equipment. CGPL need to update the



project EMP by incorporating the suggestions/recommendations made in the study

report on low calorific blended coal prepared by external consultant.

3.1.5 Fly Ash Management

Review of fly ash generation and utilization records for the period 2012-13 reveals that major

quantities (~92.3%) have been disposed as slurry form in ash ponds (total capacity~4.15

million tonnes) while the remaining (~7.6%) is being utilized through Binani and Ambuja

cement industries. With all 5 units now in operation and also considering the legal

requirement to meet the fly ash utilization target of 50% from first year onwards CGPL has

developed a draft action plan to fulfill this regulatory requirement. However in view of the

present situation it is important that the draft plan on fly ash utilization to be finalized on a

fast track basis to ensure compliance with relevant provision of Fly Ash Notification

dated 2009.

3.1.6 Hazardous Waste Management

Biomedical waste generated from the onsite CGPL Occupational Health Centre is being

managed through waste disposal facility operated by Distromed Bio Clean Pvt. Ltd at

Kuvadwa, Rajkot. With respect to biomedical waste management CGPL is found to be in

compliance with the relevant provision of Biomedical Waste (Management & Handling)

Rules 1998 (as amended 2011) having validauthorization, records maintained and annual

reports submitted to relevant authorities. Review of the 2012-13 annual report reveals

generation of ~227 kgs of biomedical waste which has been disposed at the aforesaid

Distromed operated facility through both incineration and autoclaving/shredding.

CGPL possess valid hazardous waste authorization (expiring on May 2016) from GPCB as

occupier of the facility generating the following hazardous wastes viz. used oil, discarded

chemical containers, spent ion exchange resins, chemical sludge from waste treatment, waste

residue containing oil, spent solvents etc. Also as required under the provision of Hazardous

Waste (Management, Handling &Transboundary Movement) Rules 2008 CGPL is

continuing with the submission of annual returns specifying details of hazardous waste

disposal to GPCB in prescribed format.

ETP sludge (identified as hazardous waste under Hazardous Waste Rules) generated from

effluent treatment is being disposed in lined ash pond instead of the GPCB authorized TSDF

facility of M/s SEPPL as required under the waste authorization issued. The ETP sludge has

been analyzed to be of non-hazardous nature and the same has been communicated to GPCB

to seek necessary amendment in the waste authorization. CGPL to proactively liase with

GPCB to facilitate amendment of the “Consolidated Consent & Authorization” issued

with respect to ETP sludge disposal.

3.1.7 Management of Cooling Water Discharge

The online monitoring of cooling water temperature near ash silo bridge and manual

monitoring near retaining wall for the period 2012-13 reveals a maximum temperature



difference of 5.6ºC and 6.3°C respectively. This is found to be in compliance with the

temperature difference standard of 7ºC specified at the cooling water discharge point by EC

Amendment condition dated 5th April‟07.

With all five units in operation CGPL is also in the process of engaging NIO for carrying out

validation modeling for temperature and salinity dispersion at the cooling water discharge

location. In this regard it is recommended that the EMP is updated based on the NIO Model

Conformity Study output. Given the potential concerns raised by nearby fishing villages viz.

Tragdiwith respect to increase in shoreline erosion from dredging activities it is also

recommended that CGPL undertakes assessment and evaluation of shoreline erosion

(near outfall channel discharge) following completion of the dredging of the cooling

water discharge channel.

3.1.8 Performance of Waste Water Treatment Facilities

Sewage generated onsite is being managed through commissioning and operation of sewage

treatment plants (STPs) at the labour colonies (2 X 250 KLD capacity) and project site.

However the performance of STPs installed at the labor colonies were found to be adversely

affected due to corrosion and leaks in the piping network and control valves. Hence it is

necessary for CGPL to undertake immediate replacement and/or repair of the labour

colony STP pipeline network at the same time develop and implement periodic

inspection checklists to evaluate the performance of the waste water treatment facilities.

Further review of the STP treated water monitoring records for the period 2012-13 reveals

non-conformance with respect to TSS and BOD values analyzed. The average value of TSS

(34.74 ppm) and BOD (33.43 ppm) computed for STP treated water at the old labor colony

for the above period was also found to be exceeding the standards specified for these

pollutants i.e. 30 ppm and 20 ppm respectively. In view of this it is recommended for CGPL

to conduct periodic inspection of the STPs, supervise O&M vendor performance and

capability and evaluate the treated water monitoring results to plan necessary

interventions, as found to be necessary.

An effluent treatment plant (ETP) of capacity 250 KLD has been commissioned and

operational since April ‟11 to treat the run-off/drainage from coal stockpile, boiler blow down

and condenser cooling water (for once through cooling system). Review of effluent (ETP

treated water in guard pond and condenser cooling water discharge) monitoring records for

the period 2012-13 in nearly 95% of the cases reveals compliance to the parameters specified

by CPCB for Thermal Power Plant Effluents under Environmental Protection Rules 1986.

However the average temperature difference for condensate cooling water for Nov‟12 (5.3ºC)

and Feb‟13 (5.3ºC) were found to slightly exceed the standard temperature difference of 5°C

specified for such effluent.



3.1.9 Flue Gas Emissions& ESP Performance

CGPL performs regular monitoring of flue gas emissions both online using Continuous

Emission Monitoring System (CEMS) and manually to check conformance with the emission

standards specified by World Bank Group Guidelines for Thermal Power Plants at same time

evaluating the performance of electrostatic precipitators (ESPs) and low NOx burners

installed as air pollution control devices.

Statistical analysis of online monitoring data for flue gas emission for the period 2012-13in

most cases (~95%) reveals compliance in to World Bank emission standards except for the

98th

percentile value of a) particulate matter (PM) which in two cases was found to exceed

the emission standard of 50 mg/Nm3 and b) SO2 in one case was found to exceed the standard

of 2000 mg//Nm3 specified for these pollutants. Although periodic calibration of pollutant

analyzers are being undertaken by CGPL considering the frequent shut down and

maintenance requirements of the power generation units it is necessary for CGPL to

perform calibration of flue gas pollutant measurement equipment in accordance to the

provision of World Bank Group Guidelines for Thermal Power Plants.

Interpretation of manual monitoring results in all cases reveals compliance to the World Bank

emission standards.

3.1.10 Ash Pond Structural Integrity

Damage of concrete tiling of the ash pondas observed in few areas has the potential to affect

the soil and ground water quality of the ash pond area and surroundings. In this regard it is

recommended that CGPL facilitate the repair of the damaged ash pond tiles on a fast

track basis at the same time perform periodic inspection of such facilities to assess their

overall performance.

3.1.11 Ground Water Monitoring

The quality of ground water near ash pond area is being assessed by CGPL through regular

monitoring of the bore wells installed within the project site. The ground water conforms to

IS 10500 drinking water standards for all parameters except for fluorine, total dissolved

solids and chloride. More than 90% of the samples recorded fluoride levels higher than the

standard value of 1.5 mg/l which is likely to be contributed by fly ash leachate based on

which it is recommended that CGPL undertakes ash pond leachate analysis for fluoride.

3.1.12 Ambient Air & Noise Quality Monitoring

CGPL continues to assess the potential impacts of the project construction and operation on

ambient environment through monthly monitoring of baseline air and noise quality at various

receptor locations. The receptor locations have been selected based on their proximity to the

project facilities viz. coal conveyor, coal stockpile etc, predominant wind direction and

topography.



Review of village level ambient air quality monitoring data reveals compliance to National

Ambient Air Quality Standards (NAAQS) except for PM10 (122.5-133.8 µg/m3) which is

found to exceed the standard (100 µg/m3) specified for this pollutant in all cases. This is

typical for coastal locations in this region.

Day time noise level monitored at the receptor locations were found to be in compliance with

the day time noise standards with slight exceedance noted for Vandh village. However for

night time the noise level at all locations exceeded the night time standards and was primarily

high in case of Vandh village which is located in close proximity to Adhani and CGPL coal

conveyors. In view of this CGPL has already adopted necessary control measures viz. use of

closed conveyors, peripheral green belt development etc. and is also carrying out periodic

monitoring to assess the efficiency of the management measures and plan necessary

intervention, as may be required.

3.1.13 Green Belt Development & Mangrove Afforestation

Green belt development program has been implemented by CGPL throughout the project site

particularly near the ICSH area, ash pond etc. which have been identified as potential fugitive

emission sources. For the period 2012-13 a total of 106737 saplings have been planted over

an area of 116.7 ha with an average survival rate ~88%. This represents only 10% of the

project area (1242 ha) as compared to 33% which is required to be covered under green belt

in accordance to the EC requirement. CGPL need to sustain with the green belt

development progress to ensure compliance with the EC condition.

In addition to green belt development CGPL has also undertaken mangrove afforestation

along with Gujarat Ecological Commission and KantiyajalTavar Vikas Samiti (KTVS)at coastal

village of Kantiyajal encompassing 1000 ha of land thereby complying with the CRZ

clearance requirement.



Table 1: Environmental Compliance Assessment & Findings

Sl.

No Item Aspect Assessment Recommendations Status

Tentative

closure date

1 Old Green Belt Development In line with EC requirement a total 116.7 ha of

project area (coal stockpile, coal conveyor, ash

pond etc.) has been covered under green belt

development for the periodApril 2012 -March

2013 through plantation of 106,737 saplings with

anaverage survival rate of ~88%. Of 33% of the

total project area (1242 ha) to be covered under

green belt, the current progress is about 10%. The

details of the green belt development undertaken

for the period Apr 2012 -Mar 2013 is presented in

Annexure 2.

Continue with the green belt development

efforts to fulfill EC requirement of

covering 1/3rd

of project area under green

belt.

To

sustain

March 2017

2 Old Mangrove Afforestation CGPL in collaboration with Gujarat Ecological

Commission (GEC) and KantiyajalTavar Vikas

Samiti (KTVS) has effectively implemented

mangrove afforestation program in nearly1000ha

of land in the coastal village of Kantiyajal,

Bharuch district thereby complying with the CRZ

clearance provision. Routine maintenance

activities including gap filling through

replacement of mangrove species that failed

survival will be undertaken by CGPL over the

period of next 2 years.

Closed -



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3 Old Integrated Management

System (IMS) Development

Reportedly a Consultant has been engaged by

CGPL to prepare relevant documentation with

respect to the development of IMS for the project.

Review of IMS revealed gaps in terms of the legal

register which was not updated to incorporate the

relevant environmental, health and safety related

commitments and conditions specified in the

covenants with the financial institutions, IFC

Environment & Social Performance Review

Summary, IFC EHS Guidelines for Thermal

Power Plants, Environment and CRZ clearance

etc. In view of the assessment CGPL has updated

the IMS legal register with compliance to

clearance/consent conditions is reportedly to be

tracked through the existing Tata Power

Compliance Management System (CMS).

Presently the IMS documentation under

finalization by the selected Consultant based on

inputs from CGPL and audit recommendations.

With Unit#5 now operational from Mar-13

onwards it is recommended that necessary

efforts are made by CGPL to obtain IMS

certification for the project. In this regard

internal audit and verifications to be

initiated by CGPL in coordination with the

external consultant on a fast track basis.

Ensure that EMP conditions and lender

EHS requirements (as outlined in the

lender loan agreement with CGPL,

Performance Standards, EHS Guidelines

etc.) forms an integral part of the finally

approved IMS.

Open December

2014

4 New Blended Coal Use

Implications

In order to address the uncertainties associated

with project coal supply due to increase

inMelawancoal prices being imported from

Indonesia, CGPL has opted for trial use of blended

coal varieties viz. Sathui, Columbian, SM and

Ecocoal. The primary purpose of the trial use is to

facilitate selection of the correct coal blend to

meet optimum power generation keeping in view

Update the project EMP through

incorporation of the recommendations

made with respect to the “Study on the

Assessment of Low Calorific Blended

Coal” by M/s VishuddhEnvirotech.

Open

December

2013



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environmental considerations and cost benefit

analysis. Reportedly as part of this trial run CGPL

has selected coal blend comprising of 70%

Ecocoal and 30% Melawan for use as fuel for the

project. In view of this it has been recommended

that CGPL carries out study through an external

consultant to assess the potential EHS implications

of use of this blended coal.

In line with the audit recommendation CGPL has

undertaken a study during Feb-13 through M/s

VishuddhEnvirotech to assess the potential

environmental and social implication of blended

coal use (70% Ecocoal and 30% Melawan coal).

The study has not revealed any potential

environmental risks in terms of increased coal

consumption, augmentation of coal handling &

transport system and existing pollution control

equipment etc. The study assesses the need of

increase in operational time of Internal Coal

Handling System (ICHS) and increase in handling

of coal quantities at the West Port resulting from

blended coal use. The assessment also recognizes

adequate storage and fugitive emission control

facilities at the West Port to cater to the additional

coal load and this will be further supplemented by

the existing Port Service Agreement with M/s

Adani Port.



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Potential health and safety implication of increase

in coal quantities to be handled at West Port and

increase in operating time of ICSH has been

discussed in the Table 2 of “Health & Safety”

section

5 Old Quality of blended coal Review of quality reports for blended coal used

during the period 2012-13 reveal ash and sulfur

content to vary within 4.24-8.60% and 0.26-0.76%

respectively. This is found to be in compliance

with the EC condition which require ash and

sulfur content in coal to be ≤10% and ≤1%

respectively. Unit wise details of the quality of

blended coal used for the period 2012-13 have

been presented in Annexure 3.

- Closed -

6 Old Blended coal consumption Coal utilization records for the period 2012-13

reveals consumption of 5.72 million tonnes of coal

per annum which is found to be in conformance to

the threshold limit of 12 million tonnes per annum

(MTPA) as specified in the project EC. However

with all 5 units in operation since Mar-13 onwards

and considering the use of low calorific blended

coal it is anticipated that annual consumption is

likely to be >12MTPA. Review of the M/s

Vishuddh study report reveals that the coal

consumption (considering a 315 day operation)

will be about 14.16 MTPA but given the plant will

be operated at 80% PLF the annual coal

requirement will be around 11.33 MTPA thereby

- Closed -



Sl.


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closure date

complying with the EC condition.

7 Old Ash Pond Capacity The ash ponds in operation have a capacity 4.15

million tonnes (MT) and is designed for imported

coal characterized by ash content of 15% (worst

case) with total ash generation of 1.80 MTPA.

Now with the use of blended coal characterized by

ash content of 5.2% (maximum), the M/s

Vishuddh study report indicates that the total ash

generation will be around 0.66 MTPA which is

comparatively lesser than the earlier projected

quantity. Hence in view of the above discussion

augmentation of ash pond capacity is not

envisaged due to coal quality changes.

- Closed -

8 Old Fly Ash Utilization With project now in full scale operation from

Mar‟13 onwards CGPL has made efforts towards

maximum utilization of fly ash. This includes:

Setting up Chemical Terminal Trombay Ltd. to

support CGPL in its fly ash utilization efforts.

Signed agreement with Binani, Ambuja and

Sanghi Cements for fly ash collection and use.

Exploring possibility of fly ash use in road

construction (in consistent with IRC

specifications) and export to Middle East

countries.

In addition discussion is in progress with Sanghi

Cements for setting up a stand-alone grinding unit

The draft action plan on fly ash utilization

to be finalized on a fast track basis to

ensure compliance with relevant provision

of Fly Ash Notification dated 2009.

Open October 2013



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by the later which if implemented can address the

challenge of 100% fly ash utilization.

The possibility of use of fly ash in road

construction and export to Middle East countries

have not met with much success. This is further

substantiated by the 2012-13 yearly report on fly

ash generation and utilization (as submitted to

MoEF) which reveals ash usage of only ~7.6% for

the period primarily achievedthrough Binani,

Sanghi and Ambuja cement industries. This is

likely to pose a significant challenge to CGPL

with the 5th unit now being in operation and also

considering the legal requirement1 to meet 50%

utilization of fly ash from 1st year onwards

following commissioning.

CGPL has prepared a draft action plan to ensure

compliance with the Fly Ash. The fly ash

generation and utilization report as submitted to

MoEF for 2012-13 is provided in Annexure 4.

9 Old Fly Ash Radioactivity Radioactive test certificate provided by

Department of Atomic Energy, GoI following

analysis of fly ash samples collected from ash

ponds reveals concentration of radionuclides in

Closed

1 In accordance to relevant provision of amended Fly Ash Notification dated 2009 all new coal and/or lignite based thermal power stations and/or expansion units

commissioned after this notification is to achieve 100% utilization of fly ash from 4th

year onwards. http://moef.nic.in/downloads/public-information/2804.pdf

http://moef.nic.in/downloads/public-information/2804.pdf



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the following range:

Uranium-238: 32.14±1.9 Bq/Kg

Thorium-232: 29.31±1.8 Bq/Kg

Radium-226: 58.13 ±5.0 Bq/Kg

Potassium-40: 100.3±6.6 Bq/Kg

The results were found to be in compliance with

the safe limit specified by Atomic Energy

Regulatory Board2 for K-40 and Ra-226 in fly ash

i.e. 4000 Bq/Kg and 1000 Bq/Kg respectively with

no potential risks identified to this respect. Refer

Annexure 5 for Ash Radioactive Test Certificate.

10 Old Hazardous Waste

Management

Chemical sludge generated from ETP is by default

considered as a hazardous waste and therefore

authorization for the generation, storage and

treatment/disposal (through authorized vendors)

for the same has been obtained by Order No.

AWH-43991 dated Oct 21, 2011 from the GPCB.

Although it is required that the sludge is disposed

through GPCB authorized TSDF of M/s SEPPL

presently it is being disposed in the ash pond. In

this regard it has earlier been recommended that

CGPL undertake analysis of the sludge for the

presence of hazardous components, if any and

seek necessary amendment to the CTO condition

as found to be necessary.

Proactively liase with GPCB to facilitate

amendment to the “Consolidated Consent

& Authorization” with respect to ETP

sludge disposal.

To

sustain

-

2 Atomic Energy Regulatory Board, Radiological Safety Division, Dept. of Atomic Energy, Govt. of India letter no AERD/RSD/28/2002/6007 on dated. July 26, 2002



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In view of the above CGPL has got the ETP

sludge analyzed for hazardous characteristics (if

any) through M/s Kadam Environmental

Consultants during Mar-13. Review of the report

indicates that the sludge is of non-hazardous

nature and the same has been communicated to

GPCB vide letter dated 4th June 2013 for

necessary response and action. The ETP sludge

testing report has been provided in Annexure 6.

11 Old Cooling Water Discharge Review of the online temperature records of

cooling water (near ash silo bridge) for the period

2012-13 revealed an average temperature

difference varying within3.07ºC-4.76ºC with

maximum difference 5.60ºC. Manual monitoring

undertaken by CGPL of cooling water at final

discharge point (near retaining wall) indicates an

average temperature difference varying from

1.49ºC to 5ºC with maximum difference of 6.3 ºC

computed. In both the cases the values are found

to be in conformance to the temperature difference

standard of 7ºC at the cooling water discharge

point specified by the MoEF EC Amendment

dated 5th April‟07. The online and manual cooling

water temperature values for the period 2012-13

has been graphically presented in Annexure 7&8

respectively.

- To

sustain

-



Sl.


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12 New Model Conformity Study &

Shore line Erosion

As per the legal requirement CGPL need to carry

out a model conformity study to validate the

thermal and salinity dispersion modeling

previously undertaken by NIO during the project

marine environment impact assessment.

Reportedly this study is to be undertaken by

CGPL through a third party following operation of

all the 5 units.

In view of the above and also with the COD of the

5th unit declared on 22

nd March 2013 CGPL has

initiated discussion with NIO to carry out

validation modeling for temperature and salinity

dispersion with respect to cooling water discharge.

CGPL has already received proposal from NIO to

this regard and reportedly work order for the same

is to be released shortly.

Further given the potential concerns raised by the

fishing village (Tragadi) inhabitants of potential

shoreline erosion from operation and maintenance

of cooling water outfall channel it is necessary for

CGPL to scientifically assess and evaluate any

such possible impacts through a third

party.Reportedly the shoreline erosion study will

be undertaken by CGPL following completion of

dredging of the cooling water discharge channel.

Observations/recommendation made as

part of the model conformity study to be

incorporated in the EMP and accordingly

implemented.

Undertake shoreline erosion study

following completion of the dredging of

the cooling water discharge channel.

- June 2014



Sl.


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13 New Flue gas emission Statistical interpretation of flue gas emission

records (for criteria pollutants viz. PM, SO2 and

NOx)available from Continuous Emission

Monitoring System (CEMS) for the period 2012-

13 reveals that the 98th percentile values

3 for NOx

(153.14-460.44mg/Nm3) to be in compliance to

the WB standards specified for such pollutants i.e.

750 mg/Nm3. However for SO2 the 98

th percentile

value of only Unit#3 (2159.97 mg/ Nm3) in one

case is found to be slightly higher than the WB

standard of 2000 mg/Nm3 as specified for this

pollutant. As in SO2the PM concentration in flue

gas was found to be exceed the 50 mg/Nm3

standard specified for this pollutant in two cases

with values of 70.79 mg/Nm3and

68.01mg/Nm3computed for Unit#1 and Unit#2

respectively. In all other cases the pollutant

concentration of SO2and PM is found to be

compliant with the emission standards specified

under World Bank Group Guidelines for Thermal

Power Plants.

The quantity of SO2 emission (75.42 TPD)

calculated in terms of tonnes per day (TPD) for

the period 2012-13 complied with the mass based

standards of 500 TPD as outlined in the World

Perform calibration of SO2 analyzer at dry

6% excess oxygen in accordance to the

provision of WB guidelines.

Perform surrogate monitoring of the

following parameters based on initial

calibration to assess environmental

performance:

Particulate Matter: Ash and heavy

metal content of fuel; maximum flue

gas flow rate; minimum combustion

temperature; and minimum excess

oxygen level.

Sulfur dioxide: Sulfur content in fuel;

minimum excess oxygen level.

-

September

2013

3 98

th percentile represents the value below which 98 percent of the observations may be found.



Sl.


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Bank Group Guidelines for Thermal Power Plants,

1998. Though periodic calibration of SO2 and

other pollutant analyzers is carried out by CGPL

to ensure representativeness of the data collected,

the same need to be based considering dry 6%

excess oxygen as referred in the WB Guidelines.

Interpretation of manual monitoring results (2012-

13) indicates compliance to pollutant standards

specified viz. PM (23.2-39.0 mg/ Nm3), SO2

(573.8-1328.5 mg/Nm3) and NOx (245.0-294.1

mg/Nm3).

The statistical analysis of CEMS and manual

monitoring data for 2012-13 is presented in

Annexure 9&10respectively.

14 New Ash Pond – Structural

Integrity and Leachate

Collection

During visit to the project ash disposal area it was

observed the concrete tiling of one of the ash

ponds was damaged exposing the liner material. In

view of this and also considering the full-fledged

operation of the project, it is important that CGPL

performs periodic inspection of pollution control

equipment and treatment facilities to ensure proper

functioning and performance of such

facilities/equipment‟s.

Facilitate repairing of the damaged ash

pond concrete tiling on a fast track basis.

- August 2013



Sl.


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closure date

15 New Operation of Sewage

Treatment Plant (STP)

The operation of STPs at the labour colony were

found to be adversely affected due to corrosion

and severe damage of the iron piping network and

control valves of STP water inlet to the aeration

tank, flocculation chamber etc.

Facilitate on a fast track basis the complete

replacement of the piping network for

labor colony STPs with rust proof or PVC

pipes. Also as discussed in Sl.No.14

prepare and implement periodic inspection

checklists to monitor the performance of

waste water treatment facilities viz. ETP

and STP.

- January 2014

16 New Effluent Monitoring Review of monitoring records for ETP treated

water (stored in guard pond) and condensate

cooling water (once through cooling system) for

the period 2012-13in most cases (~95%) revealed

compliance to the CPCB Effluent Standards

specified for Thermal Power Plant under

Environmental Protection Rules 1986. However

the average temperature difference for condensate

cooling water for Nov‟12 (5.3ºC) and Feb‟13

(5.3ºC) were found to slightly exceed the standard

temperature difference of 5°C specified for this

effluent. The monitoring records of condensate

cooling water has been statistically interpreted and

presented in Annexure 11.

- To sustain

17 New Sewage Treatment and

Analysis

Review of the monitoring records of the treated

water quality for the STPs installed and operated

at the project site and labor colonies (old and new)

was not indicative of satisfactory and effective

performance. BOD levels in over 50% of the

Evaluate the performance of the STPs with

respect to the treated water monitoring

results and plan necessary interventions, as

necessary to ensure conformance with the

treated water standards specified.

- September

2013



Sl.


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samples monitoredwas found to be exceeding the

standard specified i.e. 30 ppm. The average BOD

levels in the treated water samples generally

ranged within 11.96-33.43 ppm. The monitoring

result of STP treated water for the period 2012-13

is presented in Annexure 12.

18 New Ground Water Monitoring

near Ash Pond

CGPL continues to carry out with the monitoring

of bore wells (~10 nos) installed near ash pond to

assess the potable quality of ground water. Heavy

metals viz. arsenic and mercury which were earlier

absent as part of the bore well monitoring program

was also being monitored by CGPL since Nov‟12

onwards.

Review of the analytical results for the period Jan-

Mar‟13 reveals compliance to IS 10500 standards

except for the following parameters viz.

Fluoride: Nearly 90% values exceeded

standards (1.5 mg/l) with fluoride concentration

generally varying within 1.16-6.43 mg/l;

Total Dissolved Solids (TDS): Nearly 73% of

samples analyzed exceeded the standards (2000

mg/l) with values generally ranging within

1592-7720 mg/l; and

Chloride: Nearly 55% of the samples were

found to exceeds the IS standards (1000 mg/l)

with values varying within 293-3698 mg/l;

Heavy metals in most of the cases were found

Undertake ash pond leachate analysis for

fluoride.

- September

2013



Sl.


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to be below detectable limit (BDL) except for

iron which exceeded the standards in 10% of

the samples analyzed with values varying

within 0.12-2.57 mg/l.

TDS and chloride values are found to be in line

with the baseline ground water quality discussed

in the project EIA. However the presence of high

concentration of fluoride in majority of the

ground water samples can possibly result from

leaching of fluoride from fly ash disposed in ash

pond.

19 Old Ambient Air Quality

Monitoring

Review of village level ambient air quality

monitoring data (Jan-Mar‟13) reveals compliance

to National Ambient Air Quality Standards

(NAAQS) except for PM10 (122.5-133.8 µg/m3)

which is found to exceed the standard (100

µg/m3) specified for this pollutant in all cases.

This is typical for coastal locations in this region

(considering location of AAQ station near Tragadi

coastal village).

The windrose for the study period has been

overlaid on the AAQ network on Google image

(refer Annexure 13) while the ambient air quality

monitoring results for said period both at village

locations and project site have been graphically

presented in Annexure 14 & 15 respectively.

-



Sl.


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20 Old Noise Monitoring Ambient noise monitored by CGPL for the period

2012-13 near 6 villages identified as potential

receptors reveals compliance to the day time noise

standard (55 dBA) with the average values

varying within 53.7-55.9 dB(A). The slight

exceedance to the day time noise levels has only

been observed at Vandh village.

Theaverage night time noise levels at the village

locations varied within 47.7-50.9 dB(A) thereby

exceeding the night time noise standards of 45

dB(A) at all locations. The highest exceedances

were observed for noise monitored at Vandh

village. Arid climatic conditions along with the

proximity of Vandh village to the coal conveyors

of both Adani and CGPL are possibly contributing

to these noise levels. In view of this CGPL has

already implemented appropriate control measures

and management programs viz. use of closed

conveyors, monthly monitoring of noise at nearby

villages, implementation of a grievance register to

address community concerns on project EHS

aspects etc.

The graphical presentation of noise level recorded

at nearby village receptors with respect to day and

night time noise standard for 2012-13 is presented

in Annexure 16 and 17.

- To

sustain

-



Sl.


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21 New Community

Complaints/Grievances

CGPL has developed and implemented an

“Environment Dashboard Program” to document

and report on a weekly basis a) any non-

compliance related to permits/consent b) legal

notices received from regulatory authorities c)

complaints received from communities d)

environmental incidents and e) regulatory visits.

In addition the above a commitment was made to

improve the GRM through the implementation of

an online computerized Grievance Redressal

Management System which has been implemented

as of April 2013.Efforts made and actions taken

by CGPL towards redressing such community

grievances are being collated and shared with the

communities and related stakeholders. Although

necessary documentation with respect to

“Environment Dashboard Program” is being

maintained by CGPL Environment Department,

the copies of stakeholder interactions on

environmental issues/concerns resolved were not

available with CGPL during the audit survey.

CGPL to maintain copies of stakeholder

interactions/communications with respect

to environmental issues/concerns raised by

the community.

August 2013

22 New Resource Augmentation &

Capacity Building

With plant now in full scale operation there liesa

need for enhancing the capacity its onsite

environment management team is assessed to be

required.

Based on the assessment, CGPL to

enhance its capacity to handle

environmental aspects of the power plant

operations within and outside the power

plant premises, liaise with environmental

regulators, as well as supporting corporate

Open December

2013



Sl.


Tentative

closure date

environmental sustainability initiatives in

the region.

23 Old Consent/Permit Management CGPL has applied for Consent to Operate (CTO)

to GPCB for all its 5 operating units. Although

CTO has been obtained for Unit#1 CGPL has

sought necessary amendment for the same vide

application dated 11th Jan‟12 which is still

pending. With no further communication received

from GPCB regarding the Unit#1 consent

amendment and approval of consent for the

remaining units it is now considered to be under

deemed approval.

Periodic compliance reporting of project EC and

CTO conditions to regulatory authorities‟ ( MoEF

and GPCB) and submission of annual returns as

required under Hazardous and Bio-Medical Waste

Rules is being continued by CGPL. Additionally

ambient air quality pollutants concentration are

being electronically displayed at the CGPL main

gate and monitoring data uploaded at the Tata

Power website as part of CGPL environmental

compliance reports. For further details refer Table

4.

- To

sustain

-



B. Health & Safety Performance

With the augmentation in safety staffing by CGPL, proper implementation of specific plan

and procedures, communication between the contractor workers, safety training and

awareness, incident reporting, visual aids etc. CGPL continues to demonstrate considerable

improvement of onsite health and safety performance.The detailed assessment of the annual

health and safety performance is presented in Table 2 while subsequent sections provide a

brief overview of the same.

3.1.14 HSE Management System

CGPL has adopted the health and safety system (with guidance form Dupont) that includes

well defined performance standards, procedures and guidelines (HIRA, SCAR, etc.), safety

awareness programs (Safety Time Out) and establishing key performance indicators (e.g. lost

time incidents, severity rate, near miss etc.), which are used to track compliance with Health

and Safety (H&S) targets.Now with project operations CGPL need to obtain IMS

certification on a fast track basis and ensure operational plans/procedures are in

consistent with the occupational health and safety requirements outlined in the IFC

EHS Guidelines.

3.1.15 HSEOrganizational Structure

With project now in full scale operation CGPL has in place a dedicated O&M team

comprising of Dept. Heads, Line Managers, and Operational Contractor Representatives etc.

and is being presently being provided handholding support by the construction HSE team to

manage operational health and safety risks.

3.1.16 Safety Awareness Programs/Plans

Specific health and safety plans and onsite emergency plan have been developed &

augmented on regular basis by CGPL and communicated to contractors including the

operations team. The plans outline the policies and strategies, the organization, resources and

documentation required, the HS risk management principles, and reporting requirements.

With project under operation potential health and safety risks is currently limited to activities

like switchyard “hot line washing”, insulation, floor grating etc. for which necessary work

permits are being issued, audited and activities supervised by a dedicated project O&M team.

Various plans/initiatives viz. Safety Intervention Audits, Process Safety Management

System, implementation of safety time out program & PSUSR checklist etc. have been

implemented by CGPL to ensure continual improvement in project operations as well.

3.1.17 Coal Storage & Handling - Fire & Safety Risks

In view of the fire accident at the CGPL coal conveyor near West Port and subsequent

investigation CGPL need to update the HSE Plan to incorporate the recommendation

made as part of the Coal Conveyor Fire Investigation Report with respect to hood

design modification, infra-red heat detection etc.



3.1.18 Non-Ionization Radiation

CGPL in coordination with PGCIL need to assess the occupational risks related to EMF

exposure from power transmission lines as per the provision of IFC EHS Guidelines for

Thermal Power Plant and develop and implement an EMF safety program.



Table 2: Health & Safety Compliance Assessment & Findings

Sl.


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closure date

1 Old Health & Safety

Management System

As discussed in Sl.No.3 of Table 1 CGPL is in the

process of obtaining certification for Integrated

Management System (IMS) developed for the

project operations. Currently necessary

documentation has been prepared and is awaiting

finalization through verification and internal

audits by CGPL prior to IMS certification

evaluation. In this regard keeping in view of IFC

requirement it is necessary for CGPL to ensure

that documentation incorporates relevant

occupational health and safety provision of the

IFC EHS Guidelines for Thermal Power Plants

and General EHS Guidelines.

CGPL to obtain IMS certification for the

project for the fast track basis.

Operational health and safety

plans/procedures developed integral to the

IMS to be updated to incorporate

occupational health and safety

requirements outlined in the IFC General

and Thermal Power Plant EHS Guidelines

Open December

2014

2 Old HSE Organizational

Structure

CGPL has a dedicated O&M team assigned with

the responsibility of managing operational health

and safety risks of the project and is currently

being provided handholding supporting by the

constructions HSE team. The overall HSE

organizational structure has therefore been

assessed to be adequate in order to meet the

project health and safety commitments.

To

sustain

3 Old Permitting/Licensing

requirements

CGPL has been assessed to possess valid license

under the Factories Act, Contract Labour Act,

Building & Other Construction Workers Act with

annual returns found to be submitted for the period

2012-13 under the provisions of the Act. Copies of

To

sustain



Sl.


Tentative

closure date

returns submitted have been presented in

Annexure 18, 19 and 20.

4 New Use of blended coal As earlier discussed CGPL has carried out a stand-

alone study through M/s VishuddhEnvirotechto

assess the environmental and social implication

associated with the use of blended coal. The study

identifies that the use of blended coal will be

leading to the increase in coal handling capacity at

West Port and augmentation of operational time of

ICSH. Although the study report specifies that

environmental implication associated with the

aforesaid deviations can be adequately managed

by CGPL utilizing current resources it has not

assessed the health and safety implications

associated with such change. This particularly

gains significance with the recent fire incident at

the CGPL coal conveyor near Adani West Port.

Assess and evaluate i) fire safety

preparedness at West Port due to increased

coal storage and handling and ii) potential

safety risk, if any due to increase in ICHS

operational time.

December

2013

5 Old Safety Performance

Monitoring

CGPL continues to monitor safety performance of

its project through constant supervision of

contractors by dedicated and qualified health and

safety personnel and documenting the same in the

form of monthly SHE report. Further targets set as

part of the Annual Safety Action Plan are assessed

for each quarter to evaluate safety performance in

terms of actual progress/achievement. The status

of safety performance indicators for the period

2012-13 is presented in Annexure 21.

To

sustain



Sl.


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closure date

In addition to the above CGPL has also introduced

a “Spot Audit & Surveys” program for critical

O&M activities viz. hot work, confined space

entry etc. which is currently being implemented

through a dedicated Safety Committee formed

comprising of Dept. Heads, Line Managers, and

Operational Contractor Representatives. This has

been further supplemented by daily Safety

Intervention Audit Team (SIAT) surveys and

Safety Time Out program being implement by

CGPL Operations Team.

6 Old Coal Storage and Handling -

Fire & Safety Risks

With all 5 units now under operation there exist

potential fire and safety risks associated with the

transfer, storage and handling of large quantities

of coal for the project. Relevant measures have

already been taken by CGPL to facilitate removal

of hot spots from coal stockpiles through adequate

compaction and regular water sprinkling.In

Additionally CGPL is continuously monitoring

CO in coal mills (high temperature zone) and have

installed rupture disc in the milling system.

Closed

7 New Health & Safety Incidents A fire incident occurred at CGPL coal conveyor

near West Port on 27th Jan‟13 and required

triggering of mutual aid scheme supported by

Adani, HPCL etc. to control the emergency.

Nearly 180m length of the conveyor at ground

level was affected by fire possibly to have resulted

Facilitate improved housekeeping at the

ICSH area through use of fixed/mobile

vacuum systems integrated with cyclone

separators and bag filters.

Update the HSE Plan to incorporate the

Open TBS



Sl.


Tentative

closure date

from ignition of coal spilled at the bottom due to

a) lack of conveyor maintenance and supervision

by the sub-contractor and/or b) frictional heat

generated from conveyor belts/rollers

An incident investigation has already been

undertaken by CGPL with improved housekeeping

& maintenance, fire hydrant installation, increase

in conveyor ground clearance, provision of

standby water tanker, enhanced supervision etc.

being proposed as probable mitigation measures.

recommendation made as part of the Coal

Conveyor Fire Investigation Report viz.

hood design modification, infra-red heat

detection etc.

8 Old Non-ionizing radiation Considering the potential occupational risks

related to EMF exposure from power transmission

lines as per the provision of IFC EHS Guidelines

for Thermal Power Plant CGPL in coordination

with PGCIL need to develop and implement an

EMF safety programas recommended in the earlier

audit findings. This also finds mention in the

Environmental and Social Policy & Procedures

(ESPP) for Power Grid Corporation of India Ltd

(PGCIL) which refers to various guidelines in this

regard key being the American Conference on

Government and Industrial Hygienist (ACGIH)

and International Commission on Non-Ionizing

Radiation Protection (ICNIRP) where the

maximum normal human exposure (up to 24 hrs a

day) has been defined at 1,000 mG or 100 μT.

CGPL to coordinate with PGCIL to assess

the EMF related occupational health and

safety risk from operations of transmission

grid to develop an EMF safety program.

Open October 2013



4 Compliance by CGPL with the Social Requirements

A brief summary of the social performance of the project for the period 2012-13 in consistent

with IFC & ADB requirements and applicable legislations which is to be supported by

detailed assessment and findings in table format is provided in Table 3.

4.1 Compliance to IFC & ADB Requirements

The social performance of the project is briefly outlined in this section for the period 2012-13

in consistent with the IFC Performance Standards. The matrix of assessment and findings is

presented below in Table 3 for necessary reference.

4.1.1 Community Relations Organization Structure & Capacity Building

The CR Dept consists of three staff members. Six staff members from Tata Power

Community Development Trust (TPCDT) are also involved in implementing CSR activities

at CGPL. Some of the CSR activities are implemented directly by CGPL, while most of the

CSR activities have been implemented jointly with specialized project partners such as

Pratham, AKRSP etc., which are providing qualitative and quantitative results. The

documentation process has now been developed.

With the project now in full scale operation and also due to increase in the operational area of

CSR activities, strengthening of the existing CR team is required to enhance focus on these

areas:

Documentation and Reporting

SHG/artisans and entrepreneurship

Education

Livelihood Generation.

4.1.2 Grievance Redressal Mechanism

A commitment was made by CGPL to improve the GRM through the implementation of a

online computerized Grievance Redressal Management System which has been implemented

as of April 2013. A Software “Tbits” already in place for CGPL has been extended to

communities for GRM from April‟13. Concerns raised earlier have been addressed with the

current software. A sample of grievances update on the Tbits site is attached as Annexure 17.

Disclosure of the addressed grievances to the communities is currently verbal. The features

include:

i. Uniformity

ii. Accessibility to all relevant depts. heads.

iii. Automatic up-gradation of grievance to next level if not addressed within 7 days.

iv. Status of grievances can be updated only by the official making the entry.

v. Consolidation of grievances for monthly or quarterly period.



GRM currently being followed is thus stronger than the one being previously followed and

commented upon earlier.Currently oral feedback or replies are made to the person raising the

grievance

4.1.3 Stakeholder Engagement Plan

A dedicated coordinator is placed in the Community Information Centre (CIC) which is

functioning under the aegis of Community Relations (CR)-CGPL. CIC is one of those

aspects, where the community comes with their suggestions and/or complaints.

Documentation and reporting has become more comprehensive, and is being carried out by

Project Partner called “Fourth Wheel”. Current reports including Social Audit Reports,

Project reports from partner NGOs, internal reports, Minutes of meetings, photo

documentation, Annual Project Report from the partner NGOs etcare prepared, printed and

maintained regularly as per requirement. A chronology of events (Engagement/meetings etc)

related to Fishermen till May‟13 is prepared and maintained. Documentation of key events

has also been undertaken alongwith preparation of the beneficiary lists. Some reports are one

time reports, others are quarterly or annual. Documents and database of Land

Sellers/Titleholders has been prepared and maintained by CGPL.

A direct communication with the communities in the local language through newsletters to

highlight programs and individuals success stories can be showcased to bring innovative

programs of CGPL to a wider audience and for replicability by others. These include Bio gas,

solar lights on boats and other public areas, bios gas in school for cooking mid day meals,

fodder distribution, etc.

CIC should also be enhanced to meet the requirements as were envisaged during the planning

and setting up of the CIC. There seems to be a gap between the planned role of the CIC and

its current functioning. The CIC can be given more manpower and current staff employed can

be sent for various training programs to improve and enhance their ability to meet the

planned objectives and roles of CIC.

4.1.4 Community Development Plan

Community Development Plan (CDP) has been prepared in fulfillment of IFC requirements.

CDP is based on the thematic areas identified and approved for CSR interventions for Tata

Power and contains all programs and initiatives by CGPL at Mundra.

There is both internal and external monitoring of CSR activities. A small section in the

CDPto include monitoring can be added. The CDP with Annual Business Plan (ABP) will be

the basis for CSR activities for the following year. Annual status report of completed

activities should be provided for the preceding years. The ABP developed by CGPL

encompasses the need of the communities, commitments of CGPL that are required to

comply with the commitments to lenders, and those even beyond the compliance

requirements. This is also periodically reviewed by CGPL.



4.1.5 Payment of Taxes and Cess to Villages

As per the Government of Gujarat‟s notification taxes/cess be paid to villages was as follows:

Tunda: Total Rs. 12243167/- paid (for 2008-12 Rs. 6577261/- paid in addition to one time

charge for plant layout of Rs. 3620880/-).

Kandagra: Total Rs. 5665906/- paid for 2008-2012.

Nana Bhadiya: Payment has been deferred as amount estimated by the Sarpanch was much

higher than that calculated as per the government norms. Sarpanch has been asked to clarify

on the same. CGPL will pay the amount as per the norms and rules of the government after

clarifications are received from Sarpanch, Nana Bhadiya.



Table 3: Social Compliance Assessment & Findings

Sl.

No Item Activity/Sub Activity Assessment Recommendations Status

Tentative

closure date

1 Old Benefits: Employment (direct

and indirect), Procurement,

Temporary shops, Hiring

vehicles

Shops were allocated in 2008-

09 and 2010. There were total

of 47 shops and owners of

whom 10 were land

sellers/losers while there were

94 workers (excluding owners)

in the shops. 141 persons were

benefiting from shops. Vehicles

are being hired from 6

PAFs/PAVs. Firemen Training

was provided to 13 PAVs, 8 are

employed and 3 PAFs/PAVs

were sent for Fire Dozer

training of whom all employed

with Adani Group.

17 shops are still in operation while 15 have

closed due to lack of business. The number of

vehicles rented, shops provided as well as

contracts awarded are expected to reduce

significantly post construction phase reducing

the opportunities for the PAP/PAFs/locals

which was expressed by various groups and

individuals from the affected villages in

different forums. All PAFs (ordinarily residing

in the area) have not been covered by

procurement and direct and indirect

employment. The coverage is about 26 percent.

This also includes the beneficiaries merely due

to certain amount of land aggregation occurring

prior to or during the land purchase process

from PAFs.

Current database of all PAPs and their family

members is more comprehensive than the

earlier database and consists of details such as

name, relationship with head of household, age,

gender, caste, educational qualifications,

income, current place of residence, occupation,

etc.

A system for tracking benefits (from all CGPL

CGPL to verify and track the socio

economic condition of the PAFs and

other families living in the village during

the GIS mapping which is under way.

CGPL to ensure extension of any such

benefit to at least one member of

PAFs/land sellers/land loser‟s family.

Those PAFs/land sellers/land losers who

have not benefitted and are ordinarily

residing within the area should be

prioritized for extension of benefits

especially of income generation activities

of CGPL.

Other vulnerable PAFs to be given

preference include SC/ST, women

headed households, disabled, minority,

and others so identified.

Average earning of PAPs/PAVs engaged

by entrepreneurs in carrying out their

business should not be less than the

minimum agricultural

wages/nonagricultural wages in the

district.

To ensure that all PAFs are covered for

livelihood restoration, PAFs database



Sl.


Tentative

closure date

programmes) has been linked to the database of

PAFs and details of benefits for each member

of PAF has been listed as of previous audit

(Oct-Dec 2012).

“Rules For Business Opportunity To Local

Community” to address business opportunities

and employment related issues for PAFs, has

now been finalized by CGPL. This is focused

onproviding business opportunities in the non-

core business activities of the company. The

key features include:

i) Definitions of PAPs and PAVs

ii) Preference to marginalized/vulnerable

categories

iii) Listing of some examples of business

opportunities

CGPL has framed rules for business

opportunities. Based on the discussion with the

concerned officials regarding the features of the

policy, the pre requisites for implementation of

the rules for business opportunities are:

i. PAFs to be given preference.

ii. Match the definitions and rules to the

database of PAPs.

iii. Identify PAFs for providing business

opportunities.

iv. Forming a Cross Functional Team for

should be utilized to identify PAPs/family

member for one of the following:

i. Vocational/Occupational Training

(after undertaking needs assessment

for identified group of PAFs)

ii. Business Opportunities (under rules

for business opportunities)

iii. Scholarships

iv. Self Employment

v. Timeframe for follow up plan for

implementation.



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application of the policy and rules and

implementation of the policy and rules

v. List of PAVs interested in Business

opportunities.

vi. Tool or checklist for criteria for PAV.

vii. Exceptions to requirements.

viii. Disclosure of the Policy to the

communities.

ix. Time line for coverage of all PAFs has to

be set in the Policy and Rules.

2 Fodder distribution and Related

interventions. Vaccination

camp for cattle in one village,

Camel Vaccination (665 nos.)

camp, dung collection,

Formation of Gaushala trusts

for 2 villages, fodder

distribution at the two

Gaushalas, construction of

Boundary walls, weigh bridge

etc for VandhTunda and

construction of Boundary walls

for MotaKandagraGaushala.

Fodder distribution as drought

mitigation in 4 other villages

The feedback from beneficiary communities,

PRI Members and demand for duplication or

inclusion of other villages in the same

demonstrate the success of the programme4.

The coverage of total livestock has increased

from 850 cattle in TundaVandh in 2007 -08 to

covering roughly 3059 livestock (cow,

buffaloes and Ox) belonging to 397 owners in

Tunda-Vandh and MotaKandagra villages5 in

2012-13.

There are a few concerns related to

sustainability in the long run for the programme

due a number of reasons including wastage of

fodder, stray cattle from the villages and cattle

from non affected villagers relying on facility

Some of the initiatives are being initiated by

CGPL for strengthening the Gaushala which

may take some time to stabilize .

The establishment of Animal Care Centre

which can be run on a chargeable basis may be

one of the viable options, which can give thrust

for Revenue generation and also the ownership

among the cattle owners. It shall be made

mandatory that the cattle owners shall

contribute from their own.

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4 CR team of CGPL has been asked by non beneficiary villages to supply fodder in their villages.

5 Figures are as per the periodic livestock census maintained by CGPL for Gaushala fodder distribution.



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covering 3350 animals.

for fodder, difficulty in procurement of fodder,

and maximum benefits being derived by a few

villagers owning a large proportion of cattle

using the Gaushala. A Sustainability Plan for

the Gaushala Initiative has been prepared by

CGPL to address these issues.

A significant proportion of the CSR

expenditure around 39 % (Rs. 4.17 crs from

total CSR budget of Rs. 10.56 crores for 12-13)

has been spent on the activity. Budgetary

allocation has been made for the current year

2013-14 for the activity.

3 Other Livelihood Interventions

Fishermen: Coverage under

livelihood support for

TragadiBundar was 317

persons in 1st phase.

Livelihood coverage 66

persons in 2nd phase for

Tragadi Village mainly for

Pagadiya (foot fishermen).

Livelihood coverage total

coverage 500 (350 given

fishing kits @Rs. 10570 and

150 given fishing nets).

Diary programme in 5 villages;

milk collection of 2190 litres

daily from 147 livestock

Livelihood Grant distribution as well as

livelihood interventions with the fishermen

communities in three settlements (Tragadi,

TragadiBandur and Modhva) has been

undertaken by CGPL.

Other CSR interventions were initiated for

income generation such as milk collection

under dairy programme, drip irrigation, well

recharge

The supplementary list (for non land owning

households) has been prepared for families

indirectly affected from loss of common

property resources and private & government

land, non land based livelihood dependents,

encroachers and vulnerable groups and the

benefits provided by CGPL to address these

Some indicators need to be developed for

tracking the benefits in terms of increase

in income, improvement in standard of

living and lifestyle, reduction of health

problems etc. Currently the beneficiary

lists have been made for each of the

activities and the number of individuals it

covers, which could also be covered under

the Community Satisfaction Assessment

during the Social Audit.

For example one of the key outcomes for

livelihood support was debt reduction in

Modhva village according to the villagers

while led to higher earnings as catch was

sold in the open market. Earlier the

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owners.

Well Recharge (12 farmers in

three villages), Farm Bunding

(67 farmers), Drip

Demonstration benefiting 6

farmers, Check Dam at Nana

Bhadiya coverage for entire

village.

losses. For example payment of Livelihood

grant to fishermen from Tragadi,

TragadiBundar and Modhva settlements,

distribution of fodder for livestock owners, etc.

Beneficiary list for each of the other

programmes such as milk collection which is

part of dairy programme, Bio Gas, NRM

activities, Sanitation units, Vartika, etc.

fishermen/women used to take loans from

middlemen to buy fishing equipment and

were forced to sell catch to the middlemen

at below market rates. Similarly for NRM

interventions the outcome there is an

improvement in agricultural practices

which needs to be documented through

change in cropping, increase in yield etc.

The impact of each of the program /

project must be documented so that the

success of the project could be

highlighted.

4 SHG/Artisans : SHGs formed

in the affected villages has

increased from nil in 2008 to

13 in 2009 with 197 members

and to 28 SHGs in the villages

of VandhTunda,

MotaKandagra, Tragadi, Nana

Bhadiya and Modhva with 368

members in 2013.

Capacity building and training has been

provided both in-house as well as formally to

train SHG members. Linkage of the Women

SHGs to the Government ProgrammeSakhi

Mandal (Commissionerate of Rural

Development GOG) has been undertaken for

accessing credit for women members for self-

employment.

Project Vartika (Forward Linkage with

Ahmadabad based consultant) has been initiated

and about 76 women from various SHGs from

Vandh, Tunda and MotaKandagra are involved

in completing orders obtained through

„Vartika‟. The women have already completed

two orders at the time of the last audit.

SHGs are being formed and this shall be

taken to the next level for involving them

with Income Generation activities. Most of

the SHGs are linked with the Bank and

functioning smoothly. Here there is a need

of engagement of specialized agency who

can handhold these SHGs for better

institutionalization and options for

livelihood generation.

An internal monitoring has to be

undertaken on a regular basis to see what

is the average work in terms of hours and

the earnings from it and whether these are

viable for the women or not.

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At present all women are involved in specific

skill sets used traditionally by women within

the area. The area has both entrepreneurs as

well as private agencies that give work on a

piece rate basis.

While there is ample scope the

handwork/handicraft market needs to be

explore and developed to enable women to gain

profitability from handicrafts and handwork.

Therefore more options are required to be

explored developing handwork and also various

activities not necessarily confined to handwork.

WSHGs performance and effectiveness

has to be worked out for a longer time

period with different activities.

Collaboration with various depts. working

with WSHG such as Social Welfare

Department, DRDA, Kutch, Projects of

Rural Development dept aimed at WSHG,

etc to be explored by CR Dept. to enable

women to get the support and benefits of

government microfinance and

microenterprise schemes and projects.

5 Civil Infrastructure/Amenities:

Access roads, community halls,

enclosure of cremation grounds

and Gaushalas, drainages lines,

solar lights, Panchavati garden,

cricket ground, etc. 312

Sanitation units were provided

in VandhTunda. 6 Bio gas unit

installations with the support of

GAICL.

TragadiBundar: CGPL has

provided basic amenities such

as water for drinking and

domestic use, mobile toilets,

Infrastructure provided in each of the villages is

utilized by all the villagers and assets created

such as access roads, Seating platform (Tunda)

cricket Stadium (Vandh) panchavati garden

(Vandh) community halls (Vandh, Tunda, Nana

Bhadiya) and enclosure of specific property

such as cremation grounds (Vandh,

MotaKandagra, Nana Bhadiya) were utilized by

all. In Nana Bhadiya Prayer hall and separate

toilets for boys and girls used by all primary

students. In Nana Bhadiya here is a demand for

separate community hall for SC and STs.

Handing over of completed civil infrastructure

to the community has been done to ensure that

the responsibility of its operation and

Identifying and Monitoring the increasing

number of transient families who have in

migrated needs to be undertaken. This can

be done jointly with the Panchayat

members form Tragadi Village as the

Bandar comes within the village.

Duplication of activities in terms of those

government schemes which are approved

and to be implemented through

government depts. and Panchayat should

be avoided wherever possible as this may

lead to dependency of the community on

CGPL.

On

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access roads, and temporary

school by YMC.

Modhva: CSR activities

provided includes RO Plant,

solar lights for boats (65 nos.

benefiting 400 Group

members) and in public areas, 3

wells for drinking water; health

camps and capacity building of

VDAC members to understand

and address issues pertaining to

their community.

maintenance rest with the Panchayat.

The process for planning and implementing

civil infrastructure is transparent and

participatory. Feedback was invited from the

community and inspections were carried out

during the construction to ensure quality of the

civil works. This should be maintained.

For larger works such as roads,

involvement of concerned Governments

depts. to enable future maintenance and up

gradation as the expenditure involved in

repairs or upgradation may not be financial

viable for the Panchayat.

Bio Gas plant has been set up in one

school at Nana Bhadiya. The activity can

be taken up for the government schools in

all PAVs as an initiative under green

energy. This activity will support the

school in reducing the costs and time in

procuring fuel for cooking mid day meals.

This activity can again be initiated with the

support of Government sponsored

program.

Bio Gas units to be installed at household

level for the entire village as a flagship

programme for green energy, in support of

ongoing Government scheme.

6 Other CSR activities:

Education „ShikshaSarthi‟

Interventions by CGPL for specific activities

centre‟s around 5 schools. For broader

There are a few children in each of the

class who are not literate. For such

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Education Flagship Programme

through Pratham6 (NGO)

covers talukas of Mandvi and

Mundra; motivating students

through distribution of school

kits in 45 primary schools

covering 850 students; setting

up of Computer kiosks in 5

schools with NGO Partner

HiWel7, special programmes on

and for educational awareness,

safety, environment, Gandhi

Jayanti, etc, English speaking

classes have been organized.

objectives achievement the reach of the

education programmes is larger and covers

talukas of Mandvi and Mundra as in

SikshaSarathi.

The programmes and activities such as RO

Plants in schools, bio gas (one school),

computer Kiosks implemented have been

appreciated by the Schools, Principals and

teachers as well as the community.

The communities‟ perception that there has

been an improvement in education and related

activities due to CGPL is reflected in the

increase in the Community satisfaction index

for education in the social audit reports (TISS8

in 2011 and MGLI in 20129which has been

discussed briefly in the audit report Oct-Dec

2012).

The nature of change in the knowledge and

learning due to specific activities such as

special programmes and computer kiosk has not

been adequately reported or documented.

students CGPL to conduct special

coaching in the Government schools of

PAVs villages to enable these students to

acquire skills in reading, writing and

Maths, although this is being covered in

the ongoing SikshaSarathi Program which

is covering most of the nearby schools.

The high student teacher ratio in

government schools prevents the teachers

from giving more attention and time to the

weaker students. The students are able to

use the PLS to improve learning among

the weaker students through Playground

Learning stations PLS by HiWEL.

Computer Kiosks should be set up in

Government schools in a 10 kms radius.

Tangible gains made in terms of

improvement in enrollment and retaining

rates within the schools, overall

improvement in educational standards and

participation of the community in the

Term

6Pratham is the largest non-governmental organization working to provide quality education to the underprivileged children of India. Pratham was established in 1994 to

provide education to the children in the slums of Mumbai city. 7 Hole in the Wall Education Ltd.

8 Social Audit Report by Tata Institute of Social Sciences 2011

9 Social Audit Report by Mahatma Gandhi Labour Institute has been conducted and report submitted to CGPL in 2012 in compliance of requirement by MOEF.



Sl.


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education of children needs to be reported

and documented.

The change brought about by the various

educational programs and perception of

the communities should be documented

and shared with the concerned district

officials.

7 Health: Building and

Strengthening Healthcare

facilities including drinking

water and sanitation: RO Plants

have been provided in 8

villages. RO plants were

provided in 30 government

schools of MandviTaluka; 7

School health camps were

conducted covering 954

students and community health

camps were conducted in 4

villages with coverage of 918

people.

RO Plants and sanitation units were activities

that were very successful and in demand from

other villages for replication. The RO plant

supplies water to the entire village. During

consultations with villagers and Sarpanchs it

emerged that some water related health

problems have reduced after installation of RO

Plants. This could not be verified through

independent data.

Health programmes aimed at betterment of

student‟s health and regular monitoring has

been seen as a good practice. Under school

health programmes (once a month for a year)

specific health issues were identified in each of

the schools and subsequent health camps were

held for treating the specific problems among

the identified students.

In Vandh and Tunda, health camps were not

seen as providing critical health care facilities

while in Modhva and Tragadi it has been

CGPL to conduct more number of

Community Health Camps, including in

the schools. CGPL can also tie-up with a

specialized agency that can cater to the

health needs of the community in

conjugation with CGPL.

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valued. Currently the problem in VandhTunda

is that of getting aid in emergencies and for

diagnosing of major medical issues due to

lacunae in the transportation and availability of

medical services in the area.

The expenditure involved in seeking private

health care at distant places is high due to

expenses incurred in transportation as well as

medical care.



5 Compliance with Country Requirements

The project has received Environmental Clearance from MoEF, Forest and Coastal

Regulation Zone Clearances from the Gujarat Department of Forests & Environment and

Consent to Establish from the Gujarat Pollution Control Board. Further CGPL has also

obtained EC from MoEF for expansion of the proposed project to 4150 MW including

amendment of the EC conditions dated 5th

April 2007. CGPL has also obtained deemed

Consolidated Consent and Authorization (CC&A) for operation of five units from Gujarat

Pollution Control Board (GPCB).

Inspection or review of CGPL‟s environmental and safety compliance provisions for the

project does not reveal any non-compliance. Preliminary assessment does not indicate any

significant deviations / non-compliance with respect to national laws on social issues. No

other regulatory compliances have been assessed to be required for implementing EMP. With

all units currently under operation the key EC, CRZ and CC&A conditions have been

reviewed in terms of its environmental and social implication with its compliance and/or

action status being outlined in the Table 4 below.



Table 4: Status of Project EC, CRZ and CC&A Compliance & Action Status

Sl.

No. Summary of Key Condition Compliance/Action Status

A Environmental Clearance dated 2nd

Mar’07 & Corrigendum dated 26th

Apr’11

A.1 Imported coal consumption shall not

exceed 12 million tones per annum and

ash and sulphur content in the coal to be

used in the project shall not exceed 10%

and 1 % respectively

Refer to Sl.No.5 & 6 of Table 1 for

details.

A.2 One tri-flue and one bi-flue stacks of

275m each shall be provided with

continuous online monitoring

equipment‟s. Exit velocity of 25m/sec

shall be maintained.

One tri-flue and bi-flue chimney have

been erected and has been operational

from August and December 2011

respectively.

Continuous Emission Monitoring System

(CEMS) has been installed and data

recorded for all operational units (Refer

Annexure 9). Manual monitoring results

for the period 2012-13 indicates that

average flue gas velocity to be 24.8m/sec

which is found to be in compliance with

exit velocity specified in the EC.

A.3 High efficiency ESPs with efficiency not

less than 99.9% shall be installed to

ensure that PM emission does not exceed

100 mg/Nm3.

ESP erection commenced and completed

for Unit#1, 2, 3, 4 & 5. Interpretation of

CEMS and manual monitoring data

recorded for all 5 units during 2012-13

reveals compliance to PM emission

standard specified in EC (Refer

Annexure 9 & 10).

A.4 Adequate dust extraction and dust

suppression system such as bag filters and

water spray systems in dusty such as coal

and ash handling areas shall be provided.

Fixed water sprinklers have been

provided and operated near coal stockpile

area to control fugitive dust generation.

Dry fogging system and water sprinklers

have been installed at coal conveyor and

at junction towers to control fugitive

emissions.

Fugitive emissions at ash handling areas

viz. ash silo is being controlled through

installation of bag filters.



Sl.


A.5 Fly Ash shall be collected in dry form and

shall be used in a phased manner as per

provision of the notification on Fly Ash

Utilization issued by the Ministry III

September, 199910

and its amendment. By

the end of 9th

year full fly ash utilization

should be ensured. Unutilized ash shall be

disposed off in the ash pond in the form

of High Concentration Slurry.

Refer Sl.No.8 of Table 1 for details with

respect to fly ash utilization.

A.6 Rain water harvesting shall be practiced.

A detailed scheme for the rain water

harvesting to recharge the ground water

aquifer shall be prepared in consultation

with Central ground water Authorities/

state ground water board and a copy of

the same shall be submitted within three

months to the ministry.

Rain Water Harvesting plan has been

approved by CGWB.

A.7 The treated effluents shall conform to the

prescribed standards before discharge

Regular monitoring of ETP treated

effluent is being carried out by CGPL for

parameters specified in the World Bank

EHS Guidelines, 1998. For further details

please refer to Sl.No. 16 & 17 of Table 1.

A.8 Regular monitoring of ground water in

and around the ash pond shall be carried

out and records maintained

Regular monitoring of ground water is

being carried out by CGPL from 10 bore

wells located near the ash pond area and

records maintained. In line with the

earlier audit recommendation arsenic and

mercury is also being monitored in bore

well water from Nov-12 onwards and is

found to be below detectable limits. For

further details please refer to Sl.No.18 of

Table 1.

A.9 Ash pond shall be lined with impervious

lining

The ash pond has been provided with

impervious lining comprising of HDPE

and reinforced concrete. Observation

made with respect to the damaged ash

pond concrete tiling requires CGPL to

undertake repair of the same on an

10

The 1999 Notification has been amended by Fly Ash Notification 2003 by which 100% utilization of fly ash

need to be ensured from 4th

year onward instead of 9th

year as per the earlier notification.



Sl.


immediate basis and perform periodic

inspection of such facilities to identify

and report any environmental concerns.

For further details refer to Sl.No.14 of

Table 1.

A.10 Suitable system shall be provided to

reduce water temperature at the final

discharge point so that the resultant rise in

the temperature of receiving water does

not exceed 7°C over and above the

ambient temperature of the receiving

water body.

Refer to Sl.No.11 of Table 1 for further

details related to cooling water discharge

temperature.

A.11 Criteria pollutant levels including NOx,

RSPM (PM10 & PM2.5), SOx (from stack

and ambient air) shall be regularly

monitored and results displayed in your

website and also at the main gate of the

power plant.

Monthly ambient air quality monitoring

of criteria pollutants is already under

progress at the project site and nearby

villages (both upwind and downwind) viz.

Tunda, Vandh etc. Also in view of the

complaints raised by MASS – an NGO,

and earlier audit recommendations

ambient air quality is being regularly

monitored by CGPL at Tragadi fishing

village from Jun‟12 onwards (Refer

Annexure 14). The air quality data so

obtained is being electronically displayed

at the main gate of the plant while the six

monthly compliance reports bearing both

ambient and continuous emission

monitoring data has been uploaded at the

Tata Power website11

.

A.12 Conservation and development of

mangroves species found in this area shall

be taken up with a conservation plan duly

approved by State Forest Department.

The “Mangrove Afforestation Program”

has been undertaken by CGPL in

collaboration with Gujarat Ecological

Commission (GEC) and KantiyajalTavar

Vikas Samiti (KTVS) from Oct‟10 and

has been effectively implemented in

~1000 ha land in the coastal village of

Kantiyajal, Bharuch district thereby

complying with the EC condition.

A.13 A 100m wide green belt will be

developed all around the plant, ash pond

Nearly about 116.7 ha of the project site

has been covered under green belt

11

http://www.tatapower.com/cgpl-mundra/environmental.aspx

http://www.tatapower.com/cgpl-mundra/environmental.aspx



Sl.


and township covering 1/3rd

of the total

project area under green belt development

development for the period 2012-13. For

further details please refer to Annexure 2.

A.14 Leq noise level should be limited to 75

dB(A) and regular maintenance of

equipment to be undertaken.

Regular monitoring of Leq noise level is

being carried out by CGPL both at

various location within project and village

location to check conformance with noise

standard specified for both industrial and

residential area. Review of results

obtained for the project site locations for

the period 2012-13 reveals compliance to

both day (75 dBA) and night time noise

(65 dBA) standard specified for industrial

area with values varying within 57.8-67.7

dB(A) and 51.6-58.6 dB(A) respectively.

A.15 It shall be ensured that an in-built

monitoring mechanism for the schemes

identified under CSR activities are in

place and annual social audit shall be got

done from the nearest government

institute of repute. The project proponent

shall also submit the status of

implementation of the scheme from time

to time.

In house monitoring mechanism for CSR

activities are in place. Community

Satisfaction Index and Community

Awareness Index Survey through Tata

Institute of Social Sciences in March

2011.

Social Audit has been undertaken and the

report submitted in December‟12 by the

Mahatma Gandhi Labour Institute

Ahmadabad Gujarat. It has been

submitted to the MOEF as of

February‟13.

SENES is auditing the project‟s

environmental and social risk

management on a quarterly basis.

B Consolidate Consent & Authorization (CC&A) for Unit#1

B.1 Install online opacity meter and online

monitoring facility and operate regularly

and maintain the record on daily basis

Refer to section A.2 and A.3

B.2 No ground water shall be used for the

project coming under dark zone even in

lean season without permission of

competent authority

Sea Water Reverse Osmosis (SWRO) has

been commissioned and operated by

CGPL since Sep‟11 to meet the water

requirement and to discontinue ground

water consumption to meet labor camp



Sl.


potable water requirements.

B.3 Adequate dust extraction system such as

cyclones/bag filter and water spray

system in dusty areas such as in coal

handling, ash handling and other places

shall be provided to control fugitive

emission.

Refer to section A.4. Additionally to

control fugitive emissions from coal

stockpile and conveyor the following

measures has been implemented:

Construction of wind barrier along the

facility boundary wall near the coal

conveyor.

Installation of physical barriers along

coal conveyor.

Development of green belt at the

ICSH area.

B.4. The industry shall take adequate measures

for control of noise levels from its own

sources within the premises so as to

maintain ambient air quality standards in

respect of noise to less than 75dB(a)

during day time and 70 dB (A) during

night time.

Refer to section A.14

B.5. The concentration of the air pollutant

parameters in the ambient air within the

premises of the industry shall not exceed

the limits specified as per national

Ambient Air Quality Emission Standards

issued by Ministry of Environment and

Forest dated 16th

November-2009.

Monthly ambient air quality is being

regularly monitored at 3 locations within

the project site vizlabour colony, CGPL

hostel and near the main gate of the

project site (Refer Annexure 15).

Interpretation of the Jan-Mar‟13

monitoring results of ambient at the

aforesaid locations revealed conformance

to National Ambient Air Quality

Standards (NAAQS) except for the

average concentration of 106.8µg/m³

recorded for PM10 near main gate. This

can be possibly attributed to the fugitive

dust generated from movement of

vehicles and vehicular emission further

contributed by arid climatic conditions.

B.6 Further CGPL by its application dated 11th Jan 2012 has requested for amendment of

certain specific CC&A conditions by GPCB. The amendment is sought regarding-

production capacity of electricity, utilization of fly ash, installation of air pollution

control equipment in coal conveyor, recording intake and outfall flow volumes,

generation of industrial effluent and domestic sewage and conformance to flue gas



Sl.


emission norms and industrial effluent standards. As discussed earlier although

consent application for remaining units has been made by CGPL by Dec‟12 the same

is still pending given the delay in the GPCB Technical Committee meeting to discuss

the amendment sought by CGPL in the CTO conditions issued for Unit#1;. With no

further communication received from GPCB regarding the consent amendment and

granting consent to the remaining units within four months of such application it is

now considered to be under deemed approval.

C CRZ Clearance dated 25th

Apr’07 and amendment dated 9th

Mar’10

C.1 Regular monitoring of thermal dispersion

to be carried out and report submitted to

the Ministry

Refer to Sl.No.12 of Table 1 for details

regarding model conformity study.

C.2 The fishing activities and movement of

fishermen on the coast should not be

affected. Appropriate measure such as

bridges or walkways over the channel

should be provided.

Constructed access road as alternate road

for Tragadi harbor from Balaji Salt pan

Bund.

Constructed access road with bridge over

outfall channel from Tragadi Village to

Tragadi Bandar.

2 boats handed over to Modhva Gram

Vikas Samiti on 24th Jan, 12. The corpus

of Gram Vikas Samiti is Rs.90000/- in

March 2012 collected to take the

development activities in the village.

CSR activities initiated in Tragadi,

TragadiBunder, and Modhvavillage .

Refer Table 3 for further details.

C.3 No Objection Certificate from the Gujarat

State Pollution Control Board should be

obtained before starting the project

Consent to Establish (NOC) obtained by

CGPL on 17th

July, 2007.

C.4 It shall be ensured that the cooling water

before discharge shall confirm to the

standards laid down by Gujarat State

Pollution Control Board and Central

Pollution Control Board.

Refer section A.10.

C.5 Continuous monitoring of the temperature

at the discharge point should be provided.

Regular online monitoring of cooling

water temperature is being carried out at

the bridge constructed over the outfall

channel near the ash pond area. In this



Sl.


regard CGPL has also engaged a

monitoring agency to undertake regular

monitoring of cooling water discharge

parameters near outfall point from Apr‟12

onwards. For further details please refer

to Annexure 7& 8.

C.6 The canal should be constructed in such a

manner that no percolation takes place to

the ground water.

The outfall channel of total length 4.3 Km

is lined with impervious material to

prevent any cooling water percolating to

ground water aquifers.

C.7 The end of discharge weir shall be

designed to ensure that the tidal water

does not find its way into the pre-cooling

channel. Further, it shall be ensured that

the hot water discharge is uniformly

spread over the radial region in front and

mixing of warm water with the ambient

receiving water is maximum.

Procurement of services for installation of

discharge infrastructure was verified to be

in compliance with these requirements

and meet the required standards. This is

further substantiated by the cooling water

temperature recorded for the period 2012-

13.



6 List of Photographs

Photo1: Mangrove Plantation at Kantiyajal Photo 2: Green Belt Plantation at Coal Stockpile

Photo 3: Plantation along conveyor belt Photo 4: Wind Barrier set up at ICSH area

Photo 5: Water Sprinkler at Junction Tower Photo 6: Cooling water discharge location



Photo 7: Lined ash pond with ash slurry Photo 8: Damaged ash pond concrete tiles

Photo 9: Corroded Piping Network of Labor Colony STP

Photo 10: Conveyor section affected by fire Photo 11: Conveyor belt rollers damaged by fire



Photo 12: Fixed Water Sprinkler at Coal Pile Photo 13: Bore Well near Ash Pond area

Photo 14: Temperature Monitoring probe at outfall

channel

Photo 15: Electronic Display of Ambient Air Quality



Annexure 1: Details of Project In-Use Facilities



Annexure 2: Green Belt Development Details (Apr’12 to Mar’13)

Months Plants planted

during month

Cumulative

plants planted

Cumulative

Plants survived

Survival

Rate (%)

Area

Covered

(acre)

Area

Covered

(ha)

Apr-12 78 126729 120700 95.24 195.00 78.91

May-12 6650 133379 127350 95.48 195.98 79.31

Jun-12 1495 134874 128845 95.53 196.98 79.72

Jul-12 5375 140249 128085 91.33 202.18 81.82

Aug-12 150 140606 123925 88.14 202.18 81.82

Sep-12 150 140606 123925 88.14 202.18 81.82

Oct-12 3650 144256 125925 87.29 203.3 82.27

Nov-12 6090 150346 125672 83.59 207.82 84.10

Dec-12 4000 154346 125672 81.42 210.07 85.01

Jan-13 5300 159646 130972 82.04 215.37 87.16

Feb-13 5000 164646 135972 82.58 220.37 89.18

Mar-13 68799 233445 204771 87.72 288.37 116.69



Annexure 3: Blended Coal Quality Used (Apr’12 to Mar’13)

Month U#10 U#20 U#30 U#40 U#50

Sulfur Content in Blended Coal Used

Apr-12 0.36% - - - -

May-12 0.34% - - - -

Jun-12 0.26% - - - -

Jul-12 0.38% 0.29% - - -

Aug-12 - 0.68% - - -

Sep-12 0.34% 0.36% - - -

Oct-12 0.29% 0.27% 0.38% - -

Nov-12 0.76% 0.64% 0.76% - -

Dec-12 0.61% 0.56% 0.63% - -

Jan-13 0.53% 0.52% 0.56% 0.46% -

Feb-13 0.59% 0.60% 0.62% 0.61% -

Mar-13 0.29% 0.26% 0.29% 0.29% 0.27%

Ash Content in Blended Coal Used

Apr-12 6.77% - - - -

May-12 6.13% - - - -

Jun-12 5.46% - - - -

Jul-12 5.80% 5.14% - - -

Aug-12 - 8.60% - - -

Sep-12 5.52% 5.80% - - -

Oct-12 5.47% 5.47% 5.60% - -

Nov-12 5.82% 6.04% 5.84% - -

Dec-12 5.27% 5.21% 5.43% - -

Jan-13 5.11% 5.36% 6.23% 4.24% -

Feb-13 4.97% 4.99% 5.00% 4.99% -

Mar-13 4.74% 4.65% 4.75% 4.75% 4.85%



Annexure 4: Fly Ash Utilization Report for FY 2012-13



Annexure 5: Fly Ash Radioactivity Test Certificate



Annexure 6: ETP Sludge Analysis Results



Annexure 7: Graphical Plot - Online Cooling Water Temperature Difference (2012-13)

Annexure 8: Graphical Plot - Manual Cooling Water Temperature Difference (2012-13)

0

1

2

3

4

5

6

7

Apr-Jun'12 July-Sep'12 Oct-Dec'12 Jan-Mar'13

Tem

pe

ratu

re D

iffe

ren

ce (

°C)

Max Average

0

1

2

3

4

5

6

7

Apr-Jun'12 July-Sep'12 Oct-Dec'12 Jan-Mar'13

Tem

pe

ratu

re D

iffe

ren

ce (

°C)

Max Average



Annexure 9: Continuous Emission Monitoring System – Statistical Data Analysis (2012-13)

Sl.No Statistical

Parameter

Apr-Jun'12 July-Sep'12 Oct-Dec'12 Jan-Mar'13 Standards

Unit#1 Unit#1 Unit#2 Unit#1 Unit#2 Unit#3 Unit#1 Unit#2 Unit#3 Unit#4 Unit#5

A. Particulate Matter (mg/Nm3)

1 Average 26.63 35.27 33.98 27.00 36.00 26.00 28.96 33.93 25.00 34.86 39.85 50.00

2 98th Percentile 37.33 70.79 68.01 48.00 46.00 39.00 49.92 47.40 43.48 46.32 43.29 50.00

B. Sulphur Dioxide (mg/Nm3)

1 Average 66.09 252.82 1059.43 583.07 643.06 844.15 574.03 849.54 1149.70 636.20 640.22 2000.00

2 98th Percentile 152.91 820.28 1833.62 860.30 1178.69 1277.10 868.68 1309.26 2159.97 1639.66 839.60 2000.00

C. Nitrogen Oxides (mg/Nm3)

1 Average 92.13 162.20 234.75 215.42 276.40 102.24 134.36 228.12 265.73 133.30 194.29 750.00

2 98th Percentile 153.14 425.54 381.64 445.34 353.72 172.82 284.14 324.54 460.44 287.91 214.31 750.00



Annexure 10: Manual Monitoring– Statistical Data Analysis (2012-13)

Sampling Date Unit#1 Unit#2 Unit#3 Unit#4

mg/Nm³ mg/Nm³ mg/Nm³ mg/Nm³

Particulate Matter (PM)

30-Jun-12 24.6 - - -

16-Aug-12 - 27.8 - -

12-Sep-12 24.3 19.5 - -

2-Oct-12 12.7 29.3 - -

2-Nov-12 13.9 15.8 18.9 -

3-Dec-12 18.5 9.2 15.3 -

2-Jan-13 28.9 34.9 21.8 -

1-Feb-13 38.5 31.7 29.4 35.4

1-Mar-13 23.9 34.3 37.4 42.6

Average 23.2 25.3 24.6 39.0

WB Limit 50 50 50 50

Sulfur Dioxide (SO2)

30-Jun-12 201.058 - - -

16-Aug-12 - 645.4 - -

12-Sep-12 225.7 207.6 - -

2-Oct-12 210.8 245.1 - -

20-Nov-12 225.1 252.3 262.8 -

3-Dec-12 281.4 224.2 267.1 -

2-Jan-13 1195.48 1212.64 1169.74 -

1-Feb-13 1232.66 1224.08 1246.96 1281.28

1-Mar-13 1018.16 1392.82 1083.94 1375.66

Average 573.8 675.5 806.1 1328.5

WB Limit 2000 2000 2000 2000

Nitrogen Oxide (NOx)

30-Jun-12 344.4 - - -

16-Aug-12 - 575.7 - -

12-Sep-12 280.9 233.7 - -

2-Oct-12 239.9 280.9 - -

3-Nov-12 262.4 237.8 244.0 -

17-Dec-12 258.3 239.9 252.2 -

2-Jan-13 254.2 233.7 243.95 -

1-Feb-13 303.4 274.7 278.8 239.85

1-Mar-13 313.65 276.75 282.9 250.1

Average 282.1 294.1 260.4 245.0

WB Limit 750 750 750 750



Annexure 11: Monitoring Data Interpretation of Condensate Cooling Water (2012-13)

Parameters Unit May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Jan-13 Feb-13 Mar-13 Standards

pH - 7.8 7.0 7.2 8.0 8.3 8.2 8.1 8.1 8.1 8.1 8.2 6.5-8.5

Temperature Diff. °C 0.3 0.5 1.7 2.5 4.1 4.9 5.3 4.8 3.6 5.1 4.9 5.0

Free Available

Chlorine mg/l BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 0.5



Annexure 12: STP Treated Water Monitoring Results & Analysis (2012-13)

S.No.

Sewage Treatment Plant at Project Site Sewage Treatment Plant at Labor Colony (Old) Sewage Treatment Plant at Labor Colony (New)

Suspended

Solids BOD 3 days at

27ºC Residual

Chlorine Suspended


27ºC Residual

Chlorine Suspended


27ºC Residual

Chlorine

ppm (w/v) ppm ppm ppm (w/v) ppm ppm ppm (w/v) ppm ppm

1 12 14 6.6 84 61 7.2 36 10 1.4

2 18 10 3.2 39 34 7.4 24 8 3.4

3 8 7 1.2 24 18 9.8 28 25 3.5

4 10 12 1.8 14 18 3.2 26 19 2.6

5 7 9 1.9 37 19 3.4 18 44 8.2

6 6 7 2.1 28 15 7.4 32 28 4.6

7 13 12 306 26 22 123 28 21 88.5

8 22 11 288 64 152 39.8 27 42 47.3

9 29 18 156 44 59 30.6 39 67 BDL

10 12 17 2.04 88 63 25.9 52 38 32.2

11 18 13 9.2 38 33 21.2 36 25 37.4

12 15 10 6.3 42 28 34.1 28 14 28.6

13 20 7 7.4 28 18 24.7 24 18 13.7

14 16 12 9.8 43 41 18.1 36 38 15.9

15 22 14 14.3 35 22 21.6 18 15 12.6

16 10 13 12.4 24 28 13.3 12 14 6.9

17 18 17 8.5 18 19 17.3 22 22 16.8

18 14 10 8.9 14 18 2.14 16 24 12.9

19 15 13 10.7 13 15 7.9 18 17 14.5

20 10 9 14.6 15 19 1.36 14 17 24.6

21 14 15 17.3 18 17 2.05 22 10 17.2

22 11 9 4.9 35 28 7.2 15 13 4.6

23 14 16 7.1 28 22 3.1 16 10 7.1

Avg. 14.52 11.96 39.14 34.74 33.43 18.77 25.52 23.43 18.39



Annexure 13: Project Site Windrose (Jan-Mar 2013) Overlaid on AAQ Network



Annexure 14: Graphical Representation AAQ Monitoring Results (Jan-Mar’13)

0.0

20.0

40.0

60.0

80.0

100.0

120.0

140.0

160.0

Moti Khakar Mota Kandagara

Nana Bhadiya

Tunda Vandh Siracha Tragadi

Co

nce

ntr

atio

n (µ

g/m

3)

Villages

PM10 NAAQS

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70.0


Nana Bhadiya


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g/m

3)

Villages

PM2.5 NAAQS



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Villages

SO2 NAAQS

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ntr

atio

n (µ

g/m

3)

Villages

NOx NAAQS



Annexure 15: Project Site - Ambient Air Quality Profile (Jan-Mar’13)



Annexure 16: Village Level Day Time Noise Monitoring Plot (2012-13)

0

10

20

30

40

50

60

Moti Khakar Mota Kandagra Nana Bhadiya Vandh Tunda Siracha

Apr-12 May-12 Jun-12 Jul-12 Aug-12

Sep-12 Oct-12 Nov-12 Dec-12 Jan-13

Feb-13 Mar-13 Day time Standard



Annexure 17: Village Level Night Time Noise Monitoring Plot (2012-13)

40

42

44

46

48

50

52

54

Moti Khakar Mota Kandagra Nana Bhadiya Vandh Tunda Siracha

Apr-12 May-12 Jun-12 Jul-12 Aug-12

Sep-12 Oct-12 Nov-12 Dec-12 Jan-13

Feb-13 Mar-13 Night time Standard



Annexure 18: Annual Returns Submitted Under Factories Act



Annexure 19: Annual Returns Submitted Under Contract Labour Act



Annexure 20: Annual Returns Submitted Under BOCW Act



Annexure 21: Safety Performance Monitoring (2012-13)

Sl.No Performance Indicators Apr-12 May-12 Jun-12 Jul-12 Aug-12 Sep-12 Oct-12 Nov-12 Dec-12 Jan-13 Feb-13 Mar-

13

1 Induction Training

Attendees 1642 2655 2300 2432 1947 1415 1347 1301 1859 1421 1164 832

2 LTIs 0 2 3 0 1 0 0 0 0 0 0 0

3 First Aid Cases 69 63 78 63 39 45 39 31 39 40 35 41

4 Medical Treatment

Cases(MTC) 0 0 0 1 0 0 0 1 0 0 0 0

5 Safe Man Hours Worked

till last fatality/LWDC 2099760 1834580 1035528 1606108 564584 1343252 1195928 833400 877536 907260 919316 819212

6 Total Person Hours Worked 2099760 1977600 1859248 1606108 1409960 1343252 1195928 833400 877536 907260 919316 819212

7 LTI Frequency Rate 0 1.01 1.61 0 0.71 0 0 0 0 0 0 0.38

8 Severity Index 2.79 2.78 2.76 2.79 2.72 2.74 2.71 2.75 2.76 2.76 2.78 2.76

9 Fire Cases 7 4 1 7 7 5 5 2 0 2 1 0

10 Near Misses 65 42 36 20 33 34 31 18 17 11 48 52

11 Fatality 0 0 0 0 0 0 0 0 0 0 0 0