JSW Utkal Steel Limited, an Indian steel company, has proposed an integrated steel plant for the production of 13.2 MTPA crude steel near the Paradip port in Jagatsinghpur district, Odisha, India. The steel plant is proposed to have a 900 MW captive power plant, a 10 MTPA cement plant and captive jetties with a capacity of 52 MTPA handling capacity.
CREA analysed the EIA report as well as health impacts of the proposed project and found:
Shortcomings in EIA report:
- The EIA compares the three-season average to daily PM10 levels. This comparison is skewed as there is a significant difference between the aforementioned data points. While the daily PM10 standard is 100 μg/m3, the annual standard is 60 μg/m3. Therefore, seasonal and cross-seasonal averages should always be compared to annual rather than daily standards. As part of the EIA report, 50 readings per station were collected across seasons to assess ambient air quality. According to the CPCB protocol, 50 or more days of monitoring in a year should be compared to the average annual concentration (CPCB, 2020)
- The EIA report misses out on accounting for incremental PM2.5 from the plant operation. These PM2.5 particles are the most harmful part of the particulate pollution and should be integral to Environment and Health Impact Assessments.
- The EIA report also misses out on accounting for Mercury (Hg) or any other heavy metal from the plant operation, which should have been reported in the Environment and Health Impact Assessments.
- The EIA report uses an air pollution dispersion model, which doesn’t account for secondary particulate formation, PM2.5 formed from SO2 and NOx emissions. These formed secondary PM2.5 make up a more significant component of the total PM2.5 emission load from any fossil fuel combustion facility (Dahiya & Myllyvirta, 2021). Accounting for secondary particulates make the predicted PM levels from the plant multiple times higher (CREA, 2021). Therefore, the ignorance of secondary particulate formation leads to a significant underestimating of the total pollutant concentrations
- Lime Kiln, Cement Plant, and a few other combustion sources have entirely omitted data on NOx emissions without any explanation. Combustion of any fuel produces NOx emissions, which should be accounted for to ensure environmental impact assessments are comprehensive and nuanced.
High Emission Load in Critically Polluted Region:
Paradeep, Jagatsinghpur (~5- 10 km aerial distance from the proposed ISP site) is known as one of the most polluted geographies in India and has been classified as a severely polluted area under the Comprehensive Environmental Pollution Index (CEPI)(OSPCB, 2020). The average PM10 and PM2.5 levels in 2018 for Paradeep area were respectively reported at 119 (36-317) ug/m3 and 48 (16-161) ug/m3 as monitored by the Odisha State Pollution Control Board, which are higher than the prescribed annual permissible limits of 60 ug/m3 and 40 ug/m3 for the pollutants.
The total emission load was at 12,700 kg/day for PM; and 43,600 kg/day for SO2 for the entire industrial cluster of 15 Red category industries in the area at Paradeep. On the other hand, the emission load from the proposed ISP is estimated at ~25,800 for PM and ~31,900 kg/Day for SO2, respectively, Making the project a highly polluting source within the same district.
The above-presented data highlights that:
- The proposed project site is just 5-10 km away from the already severely polluted area of Paradeep and receives pollution from the region resulting in already high air pollution levels at the proposed project site as reported in the EIA report and mentioned in the earlier section.
- The emission load of the proposed plant will be ~2 times the emissions for the entire cluster at Paradeep for PM and 2/3rd for SO2, which means that the air quality will deteriorate further, resulting in severe health impacts and extension of the intensity and geographical reach of already existing CEPI area in the Jagatsinghpur district.
- The air pollutant emissions would be responsible for an estimated 94 deaths per year (95% confidence interval: 65 – 129). Air pollution would also lead to a projected 180 emergency room visits due to asthma, 160 preterm births and 75,000 days of work absence per year.