Indias first-ever environmental rating of coal-based power

plants finds the sectors performance to be way below global

benchmarks http://cseindia.org/content/india
%E2%80%99s-first-ever-environmental-rating-coal-basedpower-plants-finds-sector%E2%80%99s-performance

Centre for Science and Environments (CSE) Green Rating Project releases its
analysis and rating of Indias coal-based thermal power plants

47 plants, covering half of the sector and spread over 16 states selected for rating

Sector scores poorly on all parameters getting a mere 23 per cent score compared to
80 per cent that a plant following all best practices can get; 40 per cent of the plants
rated received less than 20 per cent score

Inefficient resources use and technological backwardness leading to high levels of

pollution says the rating report card. Immense scope for improvement

Plants operating at 60-70 per cent capacity only. If capacity utilisation is improved,
sector can meet additional power requirement without building new plants

West Bengal-based plant comes out at the top. Delhi- based NTPCs Badarpur plant
one of the most polluting in the country

Ratings and the study report Heat on Power released by M S Swaminathan, in

the presence of Ashok Lavasa, secretary, Union ministry of environment, forests and
climate change and Arvind Subramanian, chief economic advisor, Government of
India

New Delhi, February 21, 2015: Indian coal-based thermal power plants are some of the most
inefficient in the world -- says a two-year long research study by Centre for Science and
Environment (CSE). The study, done under CSEs Green Rating Project (GRP), is the first of its
kind rating of this industrial sector for its environmental performance and compliance.
CSE analysed and rated 47 coal-based thermal power plants from across the country on a variety
of environmental and energy parameters. About half of all the plants operating in 2011-12 were
selected for the rating.
Three top power plants were awarded for their overall environmental performance, while two
others received awards for their efficient use of resources such as energy and water. The awards

were handed over by M S Swaminathan, the father of Indias Green Revolution. The study
report was released jointly by Dr Swaminathan; Ashok Lavasa, secretary, Union ministry of
environment, forests and climate change; and Arvind Subramanian, chief economic advisor,
Government of India.
In a statement, CSE director general Sunita Narain said, The objective of the study was to give
a clear picture of the environmental performance of the sector. Our finding is that in India, where
the demand for power is increasing, power plants are performing way below the global
benchmarks. Given the rapid increase in coal-based power projected by the government, stress
on precious resources like water and land will increase and air and water pollution will worsen,
unless corrective measures are taken by the industry and policy-makers.
Speaking about the rating programme, Chandra Bhushan, CSEs deputy director general, said:
The Green Rating Project is one of the very few public-disclosure projects in the world in which
a non-governmental, non-industry organisation rates the environmental performance of industries
and makes the results public. We follow a robust and transparent process and the outcomes of our
ratings have been used by companies as well as policymakers to improve policies and practices.
The project, started in 1997, has so far rated five major industrial sectors of India pulp and
paper, iron and steel, chlor-alkali, cement and automobiles. The coal-based power sector is the
sixth it has rated.
What did the rating study find?
Our analysis essentially says that this sector has a lot of room for improvement, points out
Bhushan. The key findings of the rating exercise were:

The sectors overall score was a low 23 per cent (a plant adopting all the best practices
would have scored 80 per cent). The average efficiency of the plants in the study was
32.8 per cent, one of the lowest among major coal-based power producing countries.
Average CO2 emission was 1.08 kg/kWh, 14 per cent higher than Chinas.

The top performers were West Bengal-based CESC-Budge Budge, followed by JSEWLToranagallu (Karnataka), Tata-Trombay (Maharashtra) and JSW-Ratnagiri (Maharashtra).
They scored between 45-50 per cent. In addition, Tata-Mundra (Gujarat) received an
award for having the highest energy efficiency, while Gujarat Industries Power Company
Ltd (GIPCL), Surat, won an award for lowest water use.

A disappointing 40 per cent of the plants in the study received less than a 20 per cent
score, pointing to the dismal state of the sector.

Indias thermal power plants are estimated to withdraw around 22 billion cubic metre of
water, which is over half of Indias domestic water need. Even the plants with cooling
towers use an average of 4 m3/MWh; the average water consumption in Chinese plants is
2.5 m3/MWh.

Fifty-five per cent of the units were violating air pollution standards which are already
extremely lax particulate matter (PM) norms are at 150-350 mg/Nm3 (milligram per
normal metre cube) compared to Chinese norms of 30 mg/Nm3.

Fly ash disposal remains a major problem. Presently, only about 50-60 per cent of the 170
million odd tonne of fly ash generated by the sector is utilised; the remaining is
dumped into poorly designed and maintained ash ponds. Currently, about a billion tonne
of these toxic ashes lie dumped in these ponds, polluting land, air and water. By 2021-22,
the sector will produce 300 million tonne of fly ash every year.

Ash slurry, which has toxic heavy metals, was found in river and reservoirs of 20 plants.
Test done CSE lab found that nearly 40 per cent of the plants did not meet the basic total
suspended solid (TSS) norms for effluents discharged by them. 60 percent plants had not
installed effluent and sewage treatment plants

Thirty-six of the 47 plants were unable to meet the MoEFs mandated target of utilising
90 per cent of the solid waste (ash) generated average use was only 54 per cent.

The performance of the NTPC Ltd., the largest coal-power producing company in
India, was found to be below par. NTPC did not disclose its data, and hence was
rated based on a primary survey and publicly available information. The six plants
of NTPC that were rated received scores of 16-28 per cent. The poorest of the lot
was Delhis Badarpur plant.

The rating study methodology

Industries assessed under the GRP project are awarded leaves for their performance the highest
being five leaves and the lowest being none. In the current rating, only four plants scored
between 40 and 60 per cent and received the Three Leaves award.
The project selected a diverse group of plants from all regions, of various vintages, sizes and
technologies and owned by all major companies, including state and central ones, to ensure as
wide a representation as possible. GRP is a participatory process -- companies voluntarily
disclose data and permit the GRP team to independently scrutinise the plants and their records.
The plants were rated on around 60 parameters covering everything from coal and water use and
plant efficiency to air and water pollution and ash management. Local community views and
impacts on them were given due weightage along with the plants compliance record and
environment policies. The ratings involve comparing the performance of the plants against the
best practices.
Priyavrat Bhati, programme director of CSEs Sustainable Industrialisation team (which is
behind this rating project), said: The most striking part of the ranking is that 20 plants did not
get a single leaf, which is a reflection of their particularly poor environmental performance.
Some of the plants did not want to participate. Yet, we assessed them on the basis of field-level
surveys and publicly available data.

He added: We were encouraged by the transparency showed by a number of state-owned plants

that voluntarily disclosed data despite being inefficient and highly polluting.
What is the way ahead?

National norms for PM are very weak and need to be brought in line with global
standards.

National norms for SOx, NOx and mercury are absent and need to be established with
short breathing room to install new abatement technologies.

Monitoring by regulators should be strengthened they should be given more powers

(including imposing stiff penalties) to enforce compliance.

Ash policy should support higher usage of ash. Utilisation targets for individual plants
should keep in mind scope for utilisation.

Coal washing capacity needs to be doubled to meet increased use.

Regulations/incentives to ensure improvement in capacity utilisation.

Approvals for new capacities should be only for supercritical/ultra supercritical plants.

Old inefficient plants should be closed at an aggressive pace.

Efficiency improvement schemes like Perform, Achieve and Trade (PAT) should be
strengthened with ambitious targets and more thorough analysis of plants performance.

The dispatch order (i.e. the sequence in which plants are asked to supply power) should
ensure polluting plants are not called first because they are the cheaper.

Clearances given to new capacities should be based on best achievable water

consumption practices and levels.

Water tariffs should increase to curb excessive use.

Said Chandra Bhushan: The good news is that environment damage can be limited
technologies exist to cut air pollutants, while ash generated from burning coal can be gainfully
used. We found some of the plants implementing these technologies. However, a concerted effort
by the industry and regulators is urgently required.
Narain added: The bottom line is that we cannot afford to continue discounting the
environmental and health costs of polluting coal-based power plants. This is the clear message
from our rating. We hope that the industry and government will listen to this message and act on
it.

 For more on this, please contact Anupam Srivastava, asrivastava@cseindia.org /

9910093893.

Air pollution emissions

For permitting purposes, air pollution sources are grouped based on size and location into major
and minor attainment area sources, and major and minor non-attainment area sources. A large
new power plant using a combustion technology is likely to be a "major source" (as defined in
clean air laws), so minor sources will not be discussed in this summary. This discussion includes
power plants that burn fuels including coal, natural gas, industrial residues, or wood.
An attainment area is an area where the national ambient air quality standard for a particular
pollutant is being met. A non-attainment area for a particular pollutant is an area where the
ambient air quality standard for the pollutant is not being met.
The air quality impacts of any proposed major new source must be thoroughly reviewed before it
is issued permits to construct or operate. A major new source proposed in a non-attainment area
must meet stringent conditions (specified below) so that it does not further degrade air quality in

the non-attainment area. A major new source locating in an attainment area must undergo a PSD
(prevention of significant deterioration) review to ensure that it will not significantly diminish air
quality in the attainment area, and leaves room for other emission sources.
Emissions of the following air pollutants require air permits: total suspended particulates,
particulate matter less than ten microns (PM10), lead, sulfur dioxide, nitrogen oxides, carbon
monoxide, volatile organic compounds and any of the hazardous compounds listed in Chapter
NR 445, Wis. Adm. Code [PDF exit DNR].
The processing of an air permit application for a large power plant follows these steps:
1. Submittal of a complete application
The applicant must submit a complete application before the review process begins. The
application must include all pertinent information, including site location, facility
configuration and design, fuel composition and burning rates, air pollutant emission rates,
air pollution control equipment design and efficiency, and an analysis of the impact the
source will have on air quality. A permit application is complete only when all of the
required information has been received.
2. Department review and preliminary determination
The Department has 120 days to review the permit application and make a preliminary
determination as to whether it may be approved. A permit application may be approved if
the proposed source meets certain conditions, such as the following.
o It will meet all applicable emissions limitations.
o It will not cause or exacerbate a violation of an ambient air quality standard or an
ambient air increment. Ambient air increments (or PSD increments) represent a
margin of air quality that may not be used by any new source that locates in an
attainment area. Increments are applied to preserve air quality in attainment areas.
o It will not degrade the air quality in an area enough to prevent the construction or
operation of another source for which an application has already been filed.
In addition, attainment and non-attainment area major sources must meet other conditions.
1. Attainment area sources (PSD review)
o The source must use the best available control technology (BACT) to control
emissions of each applicable air contaminant. BACT is determined by comparing
the performance of similar units permitted recently.
o The source must not adversely affect air quality related values of any National
Park, wilderness area, etc. These values may include visibility or other
characteristics.

o The permitee must carry out air quality monitoring to measure its effects on air
quality.
2. Non-attainment area sources
o The source must offset any increases in emissions by obtaining emission
decreases from other sources that are in, or significantly affect, the air quality in
the non-attainment area. The total for the area of emissions of the non-attainment
pollutant(s) after the offsets must be less than the total emissions allowed in the
area before the permit application.
o The air pollutants from the source will be emitted at the lowest achievable
emission rate (LAER) [a technical determination] for each non-attainment air
contaminant.
o All other sources in Wisconsin controlled by the permit applicant must meet all
applicable air pollution control requirements.
o For major sources proposed to be located in carbon monoxide or volatile organic
compound non-attainment areas, the benefits of the construction of the source
must outweigh the environmental costs imposed by the source's location.
Public comment and final determination

The department publishes a legal notice describing the preliminary determination in a newspaper
widely circulated in the project area. The public has thirty days from the publication date to
comment on the proposed permit. If requested, the department may hold a hearing on the
proposed air permit at which verbal comments will be accepted. It can be combined with a
hearing on an EIS, if one is prepared.
Based on the preliminary determination, and on any information received during the public
comment period or at the public hearing, the department determines whether the criteria for
issuing the permit will be met. Then the department either issues or denies the permit, or sets
conditions in the permit to ensure that all criteria will be met.
Wastewater discharge
The DNR administers the National Pollution Discharge Elimination System (NPDES) permit
program of the federal Clean Water Act. This law requires that anyone who proposes to discharge
pollutants to waters of the state (both surface and ground water) must first obtain a permit, which
limits pollutant discharges to protect water quality.
Any proposed discharge permit must include a public notice. In addition to providing comments,
five or more individuals may request a public informational hearing, which must be held before
the Department makes a final determination on the discharge permit.

In addition to any federal requirements for an industrial category, Wisconsin has numerical
standards for many substances, some of which could be of concern at power plants. Examples
are chemicals like chlorine that are added to control fouling. These might be present in the
blowdown. Wisconsins antidegradation law applies to any new discharge, requiring more
restrictive limits than those in force for an existing facility.
An additional concern for a steam cycle power plant would be the discharge of heat. Any new
plant would be issued a permit that includes heat restrictions to protect aquatic life in the area
affected by the discharge.
Power plant cooling water intakes must be designed to meet state and federal laws to minimize
the number of organisms drawn through the power plant cooling system. For example, the
velocity of the intake water is limited to protect fish larvae and other small organisms.

Drinking water & groundwater

Many power generation facilities use large quantities of water to produce steam to operate the
steam turbine-generators and condense the steam for reuse. This water may be obtained from
surface waters, groundwater or treated wastewater. When large quantities of water are required,
the facility is required to obtain approval from the Department for the water withdrawal or
diversion. A consumptive use exceeding 2 million gallons per day requires an approval under
standards set in s. 281.35, Wis. Stats. [exit DNR] This approval is coordinated with permits for
pumping groundwater and/or discharging wastewater.
Any groundwater withdrawal over 70 gallons per minute requires an approval from the
Department, per s. 281.17, Wis. Stats. [exit DNR] The purpose of this review is to prevent
potential, adverse impacts to groundwater availability to public utility wells. Requests for
approval for diversions from surface waters are generally reviewed in the Department's regional
offices.
Waterway & wetland permitting
Navigable waters are those with a bed and banks that are capable of floating on a recurring
basis - a shallow-draft recreational watercraft. Those streams appearing as perennial or
intermittent on U.S.G.S. topographic maps are generally navigable. The navigability status of
any stream or pond should be determined early in the site planning process.
Any project that would affect a public waterway may require a permit under the authority of Ch.
30, Wis. Stats. [exit DNR]. These activities could include cooling water intake structures,
wastewater discharge structures, and grading along the banks of state waters. Ch. 30 is intended
to protect public rights in navigable waters.
Additionally, permits may be required for activities that may affect wetlands under the
requirements of ss. 281.36, Wis. Stats., Ch. NR 103, Wis. Adm. Code, and Ch. NR 299, Wis.

Adm. Code. The standards set in NR 299 and NR 103 require the applicant to demonstrate that
they have considered practicable alternatives that avoid and minimize wetland impacts, and that
the project will not have significant adverse impacts to wetland functions and values.
Solid waste & landfills
For some power plants using solid fuels (primarily coal) a new landfill may be needed to receive
ash and other solid wastes. All new landfills and expansions of existing landfills must obtain both
state and local approvals before construction. The state licensing process and the negotiation or
arbitration of local approvals are two separate but concurrent processes.
The state licensing process, administered by the DNR, is a technical review to determine if the
proposed landfill site and design meets all applicable public health and environmental standards.
The local approvals process considers the local economic, social and land use impacts of the
proposed facility. The applicant negotiates local approvals with affected local units of
government. That process is overseen by the Waste Facility Siting Board, which arbitrates local
approvals upon the landfill applicant's request.
A guidance report entitled Electric Utility Pre-CPCN Approvals and Applications (WA-606)
[PDF] released in 2004 helps summarize waste-related requirements for proposed large electric
generation facilities of 100 megawatts or more.
State approval process

The state approval process includes the following five major steps mandated by Wisconsin State
Law.
1. Initial site inspection
2. Initial site report
3. Feasibility report
4. Plan of operation report
5. Construction documentation
The feasibility report is the most critical step required for a new landfill (or expansion of an
existing landfill). Obtaining a favorable feasibility determination from the DNR virtually assures
the applicant that from a technical standpoint the landfill can be developed. The feasibility of the
facility is primarily based on a hydrogeological investigation, the proposed engineering design,
an evaluation of the waste management alternatives, the need for facility, and compliance with
location and performance standards.

Landfills cannot be located within a floodplain or too close to surface water, highways, public
parks, or water supply wells. They cannot have a negative impact on endangered or threatened
species, critical habitat, or areas of natural, scientific, historic, or archaeological significance.
For a solid-fueled power plant, the Wisconsin Environmental Policy Act (WEPA) process applies
to the feasibility determination. It must consider impacts caused by any landfill required to
dispose of ash or other solid waste. After the process has been completed, the reviewer
summarizes the feasibility report and issues a public notice of completion that:
1. asks the public for comments on the proposal; and
2. informs the public of the opportunity for an informational or a contested case hearing on
the technical feasibility of the proposal.
If no hearing is requested, or if an informational hearing is requested, a feasibility determination
is written. If a contested case hearing is held, the feasibility determination must be made within
90 days after the contested case hearing. It is conducted like a court trial with witnesses,
including the DNR reviewers, testifying under oath. This type of hearing is intended to address
the technical issues of site feasibility including the need for the landfill and its ability to meet
design and performance standards, protect public health, welfare, and the environment.
If a facility is deemed feasible, the applicant submits a Plan of Operation, which must meet
performance standards and include specific design elements to address potential impacts. If a
plan of operation is approved, the applicant may construct the landfill.
If a construction documentation approval is received, the applicant may apply for a license and
begin accepting waste upon receiving it.
Local approvals process

In addition to the state licensing process, the applicant must obtain any applicable local
approvals. These include any permits or approvals required by pre-existing local ordinances
(zoning variances, building permits, etc.). Although local approvals are only needed before
construction, as a practical matter, most applicants do not proceed with a plan of operation until
the local approvals are resolved.
The local approvals process has two major steps - negotiation and state arbitration. An applicant
for a new or expanded facility must apply for local approvals before submitting a feasibility
report to the DNR. Affected municipalities within 1,200 feet the proposed landfill, and the
county may negotiate with the applicant. The site owner may offer design, financial and
operational incentives to the municipality in pursuit of a negotiated agreement.
Operational issues that may be negotiated include:

hours of operation;

waste materials accepted;

nuisance control;

lighting;

vehicle routes and access;

aesthetic screening and fencing;

recycling efforts;

private well monitoring and replacement; and

post-closure site use.

Economic issues include:

payments to local governments for local costs of regulation;

fire control;

road maintenance;

payments in lieu of taxes;

economic protection of neighboring property owners for loss of property value; and

establishment of a local advisory committee.