By Vidhura Ralapanawa
The Trincomalee Coal Power Plant (TCPP), a joint venture between Ceylon Electricity Board (CEB) and Indian coal power giant NTPC, was planning to build a 500MW subcritical coal power plant in Sampur, in the Eastern coast of Sri Lanka. The Environmental Impact Assessment (EIA) of the project is replete with errors of omission and commission. It was rejected twice by the Central Environmental Authority (CEA) and submitted for the third time, and is rumoured that the conditional approval was granted due to government pressure. The Environmental Foundation filed court action against the project on the deficiencies of the EIA and the approval process, which was followed by an undertaking by the government that they will not pursue this project.
During April and May, I worked with a group of esteemed Sri Lankan scientists who analysed the EIA to try and understand the validity of it and the real impact of the power plant. Here are some of the issues that emerged from the analysis. This is in fact a very short summary whereas the full critique extended to over 50 pages.
a) The air pollution modelling is inaccurate
Dr Lareef Zubair, highlighted some of the key issues of the air pollution modelling in a must read article here. He highlights some errors that are so elementary that it begs belief. The most shocking is getting the wind direction of North East monsoon wrong, claiming that the wind comes from the South East, when multiple local datasets clearly show the North East direction. The monsoon is not called North East monsoon out of stupidity. (below images courtesy of Dr Zubair).
Another issue that arises out of the report is the images that show pollutants traveling either perpendicular or opposite direction to the wind direction. How such errors that can even be identified by school students got approval is a pertinent question, raising serious credibility of rigour of the whole EIA, and the TEC process.
In addition to the simulations by Mantec, another set of simulations were done by ITI and interestingly, these two does not match. The EIA is silent on which is accurate and does not even bother to explain the differences. ITI claims to have used one year data from a remote monitoring system (not appropriate for this type of work), without any type of validation. How this type of work passes as rigour is shocking!
Another issue raised by Dr Zubair is the lack of understanding and analysis in the EIA of the potential impacts of the pollutants, especially particulate matter in the atmosphere and how it changes the patterns of cloud condensation, impacting rainfall and solar radiation, especially on the Eastern slopes of the mountains. Such disruption of the North East monsoon (which provides the largest rainfall in Sri Lanka) will create significant environmental impacts across the whole country. These are not even discussed in the EIA.
b) The EIA does not address the key pollutants of coal power generation
In addition to SOx, NOx and particular matter (PM), the key pollutants of coal include heavy metals and mercury. These are not even identified as potential environmental challenges in the EIA. This is contrary to global practices – in fact, mercury pollution is heavily regulated in most countries including China. In the Sampur power plant design, some of the mercury will be released to the air (and then precipitated into ocean and land), and others into the water of the FGD and released into the ocean.
Mercury is an extremely harmful neurotoxin, that attacks developing foetuses, as well as attacking the brain, lungs and eyesight. It slowly accumulates in marine species, working its way through to larger fish species, and entering the human food chain. Why we want to poison one of our most bountiful fisheries with mercury must be questioned. The power plants refusal to introduce any technology to reduce mercury emissions also is shocking.
Another concern is heavy metals present in coal, and then in fly ash. While part of the fly ash is captured, about 2% will be released to the air and most of it will be deposited inland. This in a country where already farmer kidney health is compromised by heavy metals. It is noted that in Norachcholai, large quantities of fly ash and bottom ash are being open dumped by the CEB, which then gets blown into peoples houses creating a public health nightmare.
c) The EIA fails to properly assess the impact of water withdrawal
The power plant withdraws 2.2 Billion litres of water per day from Koddiyar Bay. With such a massive water withdrawal includes micro-organisms, fish eggs and larvae. The CEA appointed Technical Evaluation Committee (TEC) is brutal in its findings regarding this. Noting the TEC report is brutal in its assessment of its impact into the marine biodiversity, noting “the impact on micro-faunal diversity may be significant as they are likely to be sucked in with the inlet current endangering ultimately the entire ecology of the Koddiyar Bay as well as the near sea.”
It is perplexing how the CEA approved of a project that can destroy the entire ecology of one of the most biologically rich sites of the country. Forget water withdrawal, in many countries, siting a polluting coal power plant will not be allowed in such an important site in the first place. When queried upon the siting location, senior CEB personnel (both current and ex) noted that site was selected primarily due to location of a deep sea harbour, and no specific attention was given to biodiversity. One even went to the extent to say that it is others job to rank the important biodiversity hotspots and tell them! Well, this is the reason that a EIA is made – not merely to rubber stamp projects! The value of this area for biodiversity can be seen here. Some images of giant clams shown below.
The EIA notes that the erosion of the Koddiyar Bay is unavoidable if the project is implemented due to the fine grained sand particles in the bottom, and these will be also extracted with the water!
It must be noted that in USA and Europe, this scale of water withdrawal for ‘pass through’ cooling is not allowed. For example, US EPA notes that the benefit (primarily through avoided species death) of using ‘closed loop’ cooling towers is three times the cost to implement the same. Strangely, neither the TEC report nor the EIA even deem to explore this as an option.
d) The EIA does not provide a sufficient analysis of hot water discharge back into the ocean
According to the EIA, the Sampur power plant discharges 2.2 Billion litres of water back into the ocean at approx 38C at depth. Originally, this was to be discharged to the Shell Bay (East to the Koddiyar bay), a critically important biodiversity location, possibly the only space in Sri Lanka which is still home to giant clams, and as per NARA, including species that still have not been genetically identified. During the EIA approval, CEA recommended that the sea water discharge be done in the Eastern ocean, at a larger depth than originally envisaged.
While this answers some of the challenges of hot water discharge, it still raises significant questions. First and foremost, what is the biodiveristy in the new location, and what impact would it have is not explored. The second, and more importantly, the limited approach used in the EIA for thermal plume dispersion analysis (undertaken by Lanka Hydrolic Institute – LHI).
As a respected scientist noted, the LHI analysis is based on turbulant seas where the hot water and cold water will mix evenly, thus reducing the enhanced temperature zone. However, if the mixing is week and the discharge depth is shallow, the highly buoyant water comes to the surface very quickly and generating a thin layer of warm water; the rate of mixing depends on background stratification, current shear, wind speed, and surface heat flux. A layer of warm water layer on top can have serious implications to biodiversity and oxygen supply for benthic communities below, and persistence of such conditions leading to severe hypoxia.
Of course, this is currently played out in the Norachcholai power plant, where during February-April, the hot water discharge creates a surface layer of warm water for about 4 kilometres according to fishermen due to the stillness of the water due to weak winds.
For sedimentation transportation analysis, the EIA relies on mere 2 week analysis of currents, which is grossly inadequate,leading to the comment, “The study time is not sufficient to evaluate the currents and bottom sediment transports. Currents reverse seasonally due to monsoons, and tides and high-frequency waves in the bay vary with spring-neap cycle (14 days). Bottom stresses depends (drag ~velocity squared) on bottom currents and also surface-wave driven particle motions especially in shallow areas.” The bottom line is that the data gathering and analysis is wholly inadequate to make the claims of no-impact for such a critical project.
d) The EIA fails to account for human impact
The EIA notes that the site does not have any communities or settlements and only consists of a few abandoned tanks and buildings. This was merely true for the time the EIA was done, because it was a high security zone. But since 2015 March, the people have gone back and resettled. There are two schools, multiple houses, a medical center next to the coal dump and the fly ash storage area is a tank. The water withdrawal line crosses through the old Hindu cemetery and Koddiyar Bay now holds two thriving large fishing wadiyas and few smaller ones. The people supposedly interviewed by the EIA team cannot be found, and seems to come from addresses that do not exist!
This substantial change by itself by itself should have prompted the CEA to reject the EIA.
e) Where is the coal unloading jetty?
The EIA strangely omits any mention of the coal unloading jetty, noting that it is not part of this project. This omission is not correct, as the project cannot progress without the jetty. Locating it in Koddiyar bay is problematic since as the TEC already notes, the erosion is unavoidable already with the water withdrawal. The EIA does not go into issues of coal spillage (it is alleged that approx 6-10% of coal is spilled in Norachcholai during unloading) and impact even of smaller quantities on rich biodiversity of the area.
A bigger issue is of the capability for ships to dock during the monsoon season. The village fishermen are adamant that this is not possible during the monsoon, a position concurred by NARA specialists I met. This is also validated by the tide patterns noted during that time (available in journal publications). Based on this, it appears that one of the fundamental problems faced by CEB at Norachcholai (and what leads to significant environmental damage and hardship to people in the community), of massive coal storage, will have to be repeated in Sampur!
f) Where does the pollution go?
The problem with the air pollution analysis in the EIA is that it assumes that if you only have a tall enough chimney, the problems disappear. This is totally incorrect assumption. Most of the pollutants emitted by the project will be landing within the country due to wind patterns as well as within our ocean zone. Dispersion merely delays the impact, which is significant in a plant run on 24 x 365 x 30 years!
g) Not understanding mitigating technology
The EIA does not cover the possible mitigating technologies that are currently available and can substantially reduce the environmental impact. It seems like the team which did the EIA does not know these even exist. An NTPC representative once mentioned to me that they have added more environmental protection than they do in India. This is not surprising as India’s track record for environmental protection in coal power plants is quite low, and sulfur capture being almost non-existent. In fact, the green rating noted above rated the CEB partner NTPC the lowest in the rating scheme.
Current pollution prevention technologies available and not used in EIA include:
1) High efficiency plants (Sampur project is 33% efficient. Even in sub-critical technology, this low efficiency is no longer used, with countries looking at minimum 38-39%. More common is super critical (>41%) with many countries looking at close to 50% efficiency if they go for coal. India as a nation has the lowest efficiency coal power plants (32.8% overall).
2) Closed loop cooling towers to reduce the impact of water withdrawal
3) Use of limestone to FGD output water to reduce acidity
4) SCNR to reduce NOx emissions (added in the conditional approval)
5) Activated carbon injection (mercury reduction)
6) burner optimisation (NOx reduction)
7) Bag filter (PM reduction)
8) Dry sorbent injection (acid gases reduction)
9) Treatment of FGD water for mercury pollution prevention (added in conditional approval)
h) What happens without coal?
Coal proponents claim that without coal we would face dire danger. This is an extraordinary statement. There are plenty of technologies available which are cheap and less polluting. Their insistence of coal or nothing is what creates the power crisis of Sri Lanka more than anything else!
These are merely some of the issues of the EIA, It is sad to note that in addition to Mantec, the Indian company, a lot of Sri Lankan scientists have participated in the making of this report including institutions such as ITI and LHI. Sri Lanka’s EIA industry is doing well at the expense of its people and environment, the two groups that it is supposed to safeguard.
(The writer Vidhura Ralapanawe is a sustainability specialist and environmentalist.)