014 Esmr 05

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

September 2013
IND: Mundra Ultra Mega Power Project
Prepared by SENES Consultants India Pvt Ltd.
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.
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
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
September 2013 1 SENES

ESPR Preparer
Report prepared by: SENES Consultants India Pvt. Ltd.
Telephone: 022-27576298 / 32986995
E-mail: mdakhore@senesindia.com / riyer@senesindia.co/ spramanik@senesindia.com
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. Tentative
Item Aspect Assessment Recommendations Status
No closure date
1 Old Green Belt Development In line with EC requirement a total 116.7 ha of Continue with the green belt development To March 2017
project area (coal stockpile, coal conveyor, ash efforts to fulfill EC requirement of sustain
pond etc.) has been covered under green belt covering 1/3rd of project area under green
development for the periodApril 2012 -March belt.
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.
2 Old Mangrove Afforestation CGPL in collaboration with Gujarat Ecological Closed -
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.

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No closure date
3 Old Integrated Management Reportedly a Consultant has been engaged by With Unit#5 now operational from Mar-13 Open December
System (IMS) Development CGPL to prepare relevant documentation with onwards it is recommended that necessary 2014
respect to the development of IMS for the project. efforts are made by CGPL to obtain IMS
Review of IMS revealed gaps in terms of the legal certification for the project. In this regard
register which was not updated to incorporate the internal audit and verifications to be
relevant environmental, health and safety related initiated by CGPL in coordination with the
commitments and conditions specified in the external consultant on a fast track basis.
covenants with the financial institutions, IFC
Environment & Social Performance Review Ensure that EMP conditions and lender
Summary, IFC EHS Guidelines for Thermal EHS requirements (as outlined in the
Power Plants, Environment and CRZ clearance lender loan agreement with CGPL,
etc. In view of the assessment CGPL has updated Performance Standards, EHS Guidelines
the IMS legal register with compliance to etc.) forms an integral part of the finally
clearance/consent conditions is reportedly to be approved IMS.
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.
4 New Blended Coal Use In order to address the uncertainties associated Update the project EMP through Open December
Implications with project coal supply due to increase incorporation of the recommendations 2013
inMelawancoal prices being imported from made with respect to the “Study on the
Indonesia, CGPL has opted for trial use of blended Assessment of Low Calorific Blended
coal varieties viz. Sathui, Columbian, SM and Coal” by M/s VishuddhEnvirotech.
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

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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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No closure date
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 - Closed -
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.
6 Old Blended coal consumption Coal utilization records for the period 2012-13 - Closed -
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

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No closure date
complying with the EC condition.
7 Old Ash Pond Capacity The ash ponds in operation have a capacity 4.15 - Closed -
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.
8 Old Fly Ash Utilization With project now in full scale operation from The draft action plan on fly ash utilization Open October 2013
Mar‟13 onwards CGPL has made efforts towards to be finalized on a fast track basis to
maximum utilization of fly ash. This includes: ensure compliance with relevant provision
 Setting up Chemical Terminal Trombay Ltd. to of Fly Ash Notification dated 2009.
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

Sl. Tentative
No closure date
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 Closed
Department of Atomic Energy, GoI following
analysis of fly ash samples collected from ash
ponds reveals concentration of radionuclides in
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 4 th year onwards. 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 Chemical sludge generated from ETP is by default Proactively liase with GPCB to facilitate To -
Management considered as a hazardous waste and therefore amendment to the “Consolidated Consent sustain
authorization for the generation, storage and & Authorization” with respect to ETP
treatment/disposal (through authorized vendors) sludge disposal.
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.
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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No closure date
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 - To -

cooling water (near ash silo bridge) for the period sustain
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.

Sl. Tentative
No closure date
12 New Model Conformity Study & As per the legal requirement CGPL need to carry Observations/recommendation made as - June 2014
Shore line Erosion out a model conformity study to validate the part of the model conformity study to be
thermal and salinity dispersion modeling incorporated in the EMP and accordingly
previously undertaken by NIO during the project implemented.
marine environment impact assessment.
Reportedly this study is to be undertaken by Undertake shoreline erosion study
CGPL through a third party following operation of following completion of the dredging of
all the 5 units. the cooling water discharge channel.
In view of the above and also with the COD of the

5th unit declared on 22nd 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.

Sl. Tentative
No closure date
13 New Flue gas emission Statistical interpretation of flue gas emission Perform calibration of SO2 analyzer at dry - September
records (for criteria pollutants viz. PM, SO2 and 6% excess oxygen in accordance to the 2013
NOx)available from Continuous Emission provision of WB guidelines.
Monitoring System (CEMS) for the period 2012-
13 reveals that the 98th percentile values3 for NOx Perform surrogate monitoring of the
(153.14-460.44mg/Nm3) to be in compliance to following parameters based on initial
the WB standards specified for such pollutants i.e. calibration to assess environmental
750 mg/Nm3. However for SO2 the 98th percentile performance:
value of only Unit#3 (2159.97 mg/ Nm3) in one
case is found to be slightly higher than the WB  Particulate Matter: Ash and heavy
standard of 2000 mg/Nm3 as specified for this metal content of fuel; maximum flue
pollutant. As in SO2the PM concentration in flue gas flow rate; minimum combustion
gas was found to be exceed the 50 mg/Nm3 temperature; and minimum excess
standard specified for this pollutant in two cases oxygen level.
with values of 70.79 mg/Nm3and  Sulfur dioxide: Sulfur content in fuel;
68.01mg/Nm3computed for Unit#1 and Unit#2 minimum excess oxygen level.
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
3
98th percentile represents the value below which 98 percent of the observations may be found.

Sl. Tentative
No closure date
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 - August 2013
During visit to the project ash disposal area it was Facilitate repairing of the damaged ash
Integrity and Leachate
observed the concrete tiling of one of the ash pond concrete tiling on a fast track basis.
Collection
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.

Sl. Tentative
No closure date
15 New Operation of Sewage The operation of STPs at the labour colony were Facilitate on a fast track basis the complete - January 2014
Treatment Plant (STP) found to be adversely affected due to corrosion replacement of the piping network for
and severe damage of the iron piping network and labor colony STPs with rust proof or PVC
control valves of STP water inlet to the aeration pipes. Also as discussed in Sl.No.14
tank, flocculation chamber etc. prepare and implement periodic inspection
checklists to monitor the performance of
waste water treatment facilities viz. ETP
and STP.
16 New Effluent Monitoring Review of monitoring records for ETP treated - To sustain
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.
17 New Sewage Treatment and Review of the monitoring records of the treated Evaluate the performance of the STPs with - September
Analysis water quality for the STPs installed and operated respect to the treated water monitoring 2013
at the project site and labor colonies (old and new) results and plan necessary interventions, as
was not indicative of satisfactory and effective necessary to ensure conformance with the
performance. BOD levels in over 50% of the treated water standards specified.

Sl. Tentative
No closure date
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 CGPL continues to carry out with the monitoring Undertake ash pond leachate analysis for - September
near Ash Pond of bore wells (~10 nos) installed near ash pond to fluoride. 2013
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

Sl. Tentative
No closure date
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 Review of village level ambient air quality -
Monitoring 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. Tentative
No closure date
20 Old Noise Monitoring Ambient noise monitored by CGPL for the period - To -
2012-13 near 6 villages identified as potential sustain
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.

Sl. Tentative
No closure date
21 New Community CGPL has developed and implemented an CGPL to maintain copies of stakeholder August 2013
Complaints/Grievances “Environment Dashboard Program” to document interactions/communications with respect
and report on a weekly basis a) any non- to environmental issues/concerns raised by
compliance related to permits/consent b) legal the community.
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.
22 New Resource Augmentation & With plant now in full scale operation there liesa Based on the assessment, CGPL to Open December
Capacity Building need for enhancing the capacity its onsite enhance its capacity to handle 2013
environment management team is assessed to be environmental aspects of the power plant
required. operations within and outside the power
plant premises, liaise with environmental
regulators, as well as supporting corporate

Sl. Tentative
No closure date
environmental sustainability initiatives in
the region.
23 Old Consent/Permit Management CGPL has applied for Consent to Operate (CTO) - To -
to GPCB for all its 5 operating units. Although sustain
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.

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. Tentative
No closure date
1 Old Health & Safety As discussed in Sl.No.3 of Table 1 CGPL is in the CGPL to obtain IMS certification for the Open December
Management System process of obtaining certification for Integrated project for the fast track basis. 2014
Management System (IMS) developed for the
project operations. Currently necessary Operational health and safety
documentation has been prepared and is awaiting plans/procedures developed integral to the
finalization through verification and internal IMS to be updated to incorporate
audits by CGPL prior to IMS certification occupational health and safety
evaluation. In this regard keeping in view of IFC requirements outlined in the IFC General
requirement it is necessary for CGPL to ensure and Thermal Power Plant EHS Guidelines
that documentation incorporates relevant
occupational health and safety provision of the
IFC EHS Guidelines for Thermal Power Plants
and General EHS Guidelines.
2 Old HSE Organizational CGPL has a dedicated O&M team assigned with To
Structure the responsibility of managing operational health sustain
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.
3 Old Permitting/Licensing CGPL has been assessed to possess valid license To
requirements under the Factories Act, Contract Labour Act, sustain
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

Sl. Tentative
No 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- Assess and evaluate i) fire safety December
alone study through M/s VishuddhEnvirotechto preparedness at West Port due to increased 2013
assess the environmental and social implication coal storage and handling and ii) potential
associated with the use of blended coal. The study safety risk, if any due to increase in ICHS
identifies that the use of blended coal will be operational time.
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.
5 Old Safety Performance CGPL continues to monitor safety performance of To
Monitoring its project through constant supervision of sustain
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.

Sl. Tentative
No 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 - With all 5 units now under operation there exist Closed
Fire & Safety Risks 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.
7 New Health & Safety Incidents A fire incident occurred at CGPL coal conveyor Facilitate improved housekeeping at the Open TBS
near West Port on 27th Jan‟13 and required ICSH area through use of fixed/mobile
triggering of mutual aid scheme supported by vacuum systems integrated with cyclone
Adani, HPCL etc. to control the emergency. separators and bag filters.
Nearly 180m length of the conveyor at ground
level was affected by fire possibly to have resulted Update the HSE Plan to incorporate the

Sl. Tentative
No closure date
from ignition of coal spilled at the bottom due to recommendation made as part of the Coal
a) lack of conveyor maintenance and supervision Conveyor Fire Investigation Report viz.
by the sub-contractor and/or b) frictional heat hood design modification, infra-red heat
generated from conveyor belts/rollers detection etc.
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.
8 Old Non-ionizing radiation Considering the potential occupational risks CGPL to coordinate with PGCIL to assess Open October 2013
related to EMF exposure from power transmission the EMF related occupational health and
lines as per the provision of IFC EHS Guidelines safety risk from operations of transmission
for Thermal Power Plant CGPL in coordination grid to develop an EMF safety program.
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.

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. Tentative
Item Activity/Sub Activity Assessment Recommendations Status
No closure date
1 Old Benefits: Employment (direct 17 shops are still in operation while 15 have  CGPL to verify and track the socio
and indirect), Procurement, closed due to lack of business. The number of economic condition of the PAFs and
Temporary shops, Hiring vehicles rented, shops provided as well as other families living in the village during
vehicles contracts awarded are expected to reduce the GIS mapping which is under way.
significantly post construction phase reducing  CGPL to ensure extension of any such
Shops were allocated in 2008- the opportunities for the PAP/PAFs/locals benefit to at least one member of
09 and 2010. There were total which was expressed by various groups and PAFs/land sellers/land loser‟s family.
of 47 shops and owners of individuals from the affected villages in  Those PAFs/land sellers/land losers who
whom 10 were land different forums. All PAFs (ordinarily residing have not benefitted and are ordinarily
sellers/losers while there were in the area) have not been covered by residing within the area should be
94 workers (excluding owners) procurement and direct and indirect prioritized for extension of benefits
in the shops. 141 persons were employment. The coverage is about 26 percent. especially of income generation activities
benefiting from shops. Vehicles This also includes the beneficiaries merely due of CGPL.
are being hired from 6 to certain amount of land aggregation occurring  Other vulnerable PAFs to be given
PAFs/PAVs. Firemen Training prior to or during the land purchase process preference include SC/ST, women
was provided to 13 PAVs, 8 are from PAFs. headed households, disabled, minority,
employed and 3 PAFs/PAVs and others so identified.
were sent for Fire Dozer Current database of all PAPs and their family  Average earning of PAPs/PAVs engaged
training of whom all employed members is more comprehensive than the by entrepreneurs in carrying out their
with Adani Group. earlier database and consists of details such as business should not be less than the
name, relationship with head of household, age, minimum agricultural
gender, caste, educational qualifications, wages/nonagricultural wages in the
income, current place of residence, occupation, district.
etc.
To ensure that all PAFs are covered for
A system for tracking benefits (from all CGPL livelihood restoration, PAFs database

Sl. Tentative
No closure date
programmes) has been linked to the database of should be utilized to identify PAPs/family
PAFs and details of benefits for each member member for one of the following:
of PAF has been listed as of previous audit i. Vocational/Occupational Training
(Oct-Dec 2012). (after undertaking needs assessment
for identified group of PAFs)
“Rules For Business Opportunity To Local ii. Business Opportunities (under rules
Community” to address business opportunities for business opportunities)
and employment related issues for PAFs, has iii. Scholarships
now been finalized by CGPL. This is focused iv. Self Employment
onproviding business opportunities in the non- v. Timeframe for follow up plan for
core business activities of the company. The implementation.
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

Sl. Tentative
No closure date
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 The feedback from beneficiary communities, Some of the initiatives are being initiated by Ongoin
interventions. Vaccination PRI Members and demand for duplication or CGPL for strengthening the Gaushala which g Long
camp for cattle in one village, inclusion of other villages in the same may take some time to stabilize . Term
Camel Vaccination (665 nos.) demonstrate the success of the programme4.
The establishment of Animal Care Centre
camp, dung collection, The coverage of total livestock has increased
which can be run on a chargeable basis may be
Formation of Gaushala trusts from 850 cattle in TundaVandh in 2007 -08 to one of the viable options, which can give thrust
for 2 villages, fodder covering roughly 3059 livestock (cow, for Revenue generation and also the ownership
distribution at the two buffaloes and Ox) belonging to 397 owners in among the cattle owners. It shall be made
Gaushalas, construction of Tunda-Vandh and MotaKandagra villages5 in mandatory that the cattle owners shall
Boundary walls, weigh bridge 2012-13. contribute from their own.
etc for VandhTunda and There are a few concerns related to
construction of Boundary walls sustainability in the long run for the programme
for MotaKandagraGaushala. due a number of reasons including wastage of
Fodder distribution as drought fodder, stray cattle from the villages and cattle
mitigation in 4 other villages from non affected villagers relying on facility
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.

Sl. Tentative
No closure date
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 Livelihood Grant distribution as well as Some indicators need to be developed for Ongoin
Fishermen: Coverage under livelihood interventions with the fishermen tracking the benefits in terms of increase g
livelihood support for communities in three settlements (Tragadi, in income, improvement in standard of
TragadiBundar was 317 TragadiBandur and Modhva) has been living and lifestyle, reduction of health
persons in 1st phase. undertaken by CGPL. problems etc. Currently the beneficiary
Livelihood coverage 66 Other CSR interventions were initiated for lists have been made for each of the
persons in 2nd phase for income generation such as milk collection activities and the number of individuals it
Tragadi Village mainly for under dairy programme, drip irrigation, well covers, which could also be covered under
Pagadiya (foot fishermen). recharge the Community Satisfaction Assessment
Livelihood coverage total The supplementary list (for non land owning during the Social Audit.
coverage 500 (350 given households) has been prepared for families
fishing kits @Rs. 10570 and indirectly affected from loss of common For example one of the key outcomes for
150 given fishing nets). property resources and private & government livelihood support was debt reduction in
Diary programme in 5 villages; land, non land based livelihood dependents, Modhva village according to the villagers
milk collection of 2190 litres encroachers and vulnerable groups and the while led to higher earnings as catch was
daily from 147 livestock benefits provided by CGPL to address these sold in the open market. Earlier the

Sl. Tentative
No closure date
owners. losses. For example payment of Livelihood fishermen/women used to take loans from
Well Recharge (12 farmers in grant to fishermen from Tragadi, middlemen to buy fishing equipment and
three villages), Farm Bunding TragadiBundar and Modhva settlements, were forced to sell catch to the middlemen
(67 farmers), Drip distribution of fodder for livestock owners, etc. at below market rates. Similarly for NRM
Demonstration benefiting 6 Beneficiary list for each of the other interventions the outcome there is an
farmers, Check Dam at Nana programmes such as milk collection which is improvement in agricultural practices
Bhadiya coverage for entire part of dairy programme, Bio Gas, NRM which needs to be documented through
village. activities, Sanitation units, Vartika, etc. 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 Capacity building and training has been SHGs are being formed and this shall be Ongoin
in the affected villages has provided both in-house as well as formally to taken to the next level for involving them g
increased from nil in 2008 to train SHG members. Linkage of the Women with Income Generation activities. Most of Longter
13 in 2009 with 197 members SHGs to the Government ProgrammeSakhi the SHGs are linked with the Bank and m
and to 28 SHGs in the villages Mandal (Commissionerate of Rural functioning smoothly. Here there is a need
of VandhTunda, Development GOG) has been undertaken for of engagement of specialized agency who
MotaKandagra, Tragadi, Nana accessing credit for women members for self- can handhold these SHGs for better
Bhadiya and Modhva with 368 employment. institutionalization and options for
members in 2013. livelihood generation.
Project Vartika (Forward Linkage with
Ahmadabad based consultant) has been initiated An internal monitoring has to be
and about 76 women from various SHGs from undertaken on a regular basis to see what
Vandh, Tunda and MotaKandagra are involved is the average work in terms of hours and
in completing orders obtained through the earnings from it and whether these are
„Vartika‟. The women have already completed viable for the women or not.
two orders at the time of the last audit.

Sl. Tentative
No closure date
At present all women are involved in specific WSHGs performance and effectiveness
skill sets used traditionally by women within has to be worked out for a longer time
the area. The area has both entrepreneurs as period with different activities.
well as private agencies that give work on a
piece rate basis. Collaboration with various depts. working
with WSHG such as Social Welfare
While there is ample scope the Department, DRDA, Kutch, Projects of
handwork/handicraft market needs to be Rural Development dept aimed at WSHG,
explore and developed to enable women to gain etc to be explored by CR Dept. to enable
profitability from handicrafts and handwork. women to get the support and benefits of
Therefore more options are required to be government microfinance and
explored developing handwork and also various microenterprise schemes and projects.
activities not necessarily confined to handwork.
5 Civil Infrastructure/Amenities: Infrastructure provided in each of the villages is On
Identifying and Monitoring the increasing
Access roads, community halls, utilized by all the villagers and assets created going
number of transient families who have in
enclosure of cremation grounds such as access roads, Seating platform (Tunda)
migrated needs to be undertaken. This can
and Gaushalas, drainages lines, cricket Stadium (Vandh) panchavati garden
be done jointly with the Panchayat
solar lights, Panchavati garden, (Vandh) community halls (Vandh, Tunda, Nana
members form Tragadi Village as the
cricket ground, etc. 312 Bhadiya) and enclosure of specific property
Bandar comes within the village.
Sanitation units were provided such as cremation grounds (Vandh,
in VandhTunda. 6 Bio gas unit MotaKandagra, Nana Bhadiya) were utilized by Duplication of activities in terms of those
installations with the support of all. In Nana Bhadiya Prayer hall and separate government schemes which are approved
GAICL. toilets for boys and girls used by all primary and to be implemented through
students. In Nana Bhadiya here is a demand for government depts. and Panchayat should
TragadiBundar: CGPL has separate community hall for SC and STs. be avoided wherever possible as this may
provided basic amenities such Handing over of completed civil infrastructure lead to dependency of the community on
as water for drinking and to the community has been done to ensure that CGPL.
domestic use, mobile toilets, the responsibility of its operation and

Sl. Tentative
No closure date
access roads, and temporary maintenance rest with the Panchayat. For larger works such as roads,
school by YMC. The process for planning and implementing involvement of concerned Governments
civil infrastructure is transparent and depts. to enable future maintenance and up
Modhva: CSR activities participatory. Feedback was invited from the gradation as the expenditure involved in
provided includes RO Plant, community and inspections were carried out repairs or upgradation may not be financial
solar lights for boats (65 nos. during the construction to ensure quality of the viable for the Panchayat.
benefiting 400 Group civil works. This should be maintained.
members) and in public areas, 3 Bio Gas plant has been set up in one
wells for drinking water; health school at Nana Bhadiya. The activity can
camps and capacity building of be taken up for the government schools in
VDAC members to understand all PAVs as an initiative under green
and address issues pertaining to energy. This activity will support the
their community. 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: Interventions by CGPL for specific activities There are a few children in each of the Ongoin
Education „ShikshaSarthi‟ centre‟s around 5 schools. For broader class who are not literate. For such g Long

Sl. Tentative
No closure date
Education Flagship Programme objectives achievement the reach of the students CGPL to conduct special Term
through Pratham6 (NGO) education programmes is larger and covers coaching in the Government schools of
covers talukas of Mandvi and talukas of Mandvi and Mundra as in PAVs villages to enable these students to
Mundra; motivating students SikshaSarathi. acquire skills in reading, writing and
through distribution of school The programmes and activities such as RO Maths, although this is being covered in
kits in 45 primary schools Plants in schools, bio gas (one school), the ongoing SikshaSarathi Program which
covering 850 students; setting computer Kiosks implemented have been is covering most of the nearby schools.
up of Computer kiosks in 5 appreciated by the Schools, Principals and
schools with NGO Partner teachers as well as the community. The high student teacher ratio in
HiWel7, special programmes on The communities‟ perception that there has government schools prevents the teachers
and for educational awareness, been an improvement in education and related from giving more attention and time to the
safety, environment, Gandhi activities due to CGPL is reflected in the weaker students. The students are able to
Jayanti, etc, English speaking increase in the Community satisfaction index use the PLS to improve learning among
classes have been organized. for education in the social audit reports (TISS8 the weaker students through Playground
in 2011 and MGLI in 20129which has been Learning stations PLS by HiWEL.
discussed briefly in the audit report Oct-Dec Computer Kiosks should be set up in
2012). Government schools in a 10 kms radius.
The nature of change in the knowledge and
learning due to specific activities such as Tangible gains made in terms of
special programmes and computer kiosk has not improvement in enrollment and retaining
been adequately reported or documented. rates within the schools, overall
improvement in educational standards and
participation of the community in the
6
Pratham 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. Tentative
No closure date
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 RO Plants and sanitation units were activities CGPL to conduct more number of Ongoin
Strengthening Healthcare that were very successful and in demand from Community Health Camps, including in g
facilities including drinking other villages for replication. The RO plant the schools. CGPL can also tie-up with a
water and sanitation: RO Plants supplies water to the entire village. During specialized agency that can cater to the
have been provided in 8 consultations with villagers and Sarpanchs it health needs of the community in
villages. RO plants were emerged that some water related health conjugation with CGPL.
provided in 30 government problems have reduced after installation of RO
schools of MandviTaluka; 7 Plants. This could not be verified through
School health camps were independent data.
conducted covering 954 Health programmes aimed at betterment of
students and community health student‟s health and regular monitoring has
camps were conducted in 4 been seen as a good practice. Under school
villages with coverage of 918 health programmes (once a month for a year)
people. 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

Sl. Tentative
No closure date
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.
Summary of Key Condition Compliance/Action Status
No.
A Environmental Clearance dated 2nd Mar’07 & Corrigendum dated 26th Apr’11
A.1 Imported coal consumption shall not Refer to Sl.No.5 & 6 of Table 1 for
exceed 12 million tones per annum and details.
ash and sulphur content in the coal to be
used in the project shall not exceed 10%
and 1 % respectively
A.2 One tri-flue and one bi-flue stacks of One tri-flue and bi-flue chimney have
275m each shall be provided with been erected and has been operational
continuous online monitoring from August and December 2011
equipment‟s. Exit velocity of 25m/sec respectively.
shall be maintained. 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 ESP erection commenced and completed
less than 99.9% shall be installed to for Unit#1, 2, 3, 4 & 5. Interpretation of
ensure that PM emission does not exceed CEMS and manual monitoring data
100 mg/Nm3. 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 Fixed water sprinklers have been
suppression system such as bag filters and provided and operated near coal stockpile
water spray systems in dusty such as coal area to control fugitive dust generation.
and ash handling areas shall be provided. 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.
No.
A.5 Fly Ash shall be collected in dry form and Refer Sl.No.8 of Table 1 for details with
shall be used in a phased manner as per respect to fly ash utilization.
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.
A.6 Rain water harvesting shall be practiced. Rain Water Harvesting plan has been
A detailed scheme for the rain water approved by CGWB.
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.
A.7 The treated effluents shall conform to the Regular monitoring of ETP treated
prescribed standards before discharge 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 Regular monitoring of ground water is
and around the ash pond shall be carried being carried out by CGPL from 10 bore
out and records maintained 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 The ash pond has been provided with
lining 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.
No.
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 Refer to Sl.No.11 of Table 1 for further
reduce water temperature at the final details related to cooling water discharge
discharge point so that the resultant rise in temperature.
the temperature of receiving water does
not exceed 7°C over and above the
ambient temperature of the receiving
water body.
A.11 Criteria pollutant levels including NOx, Monthly ambient air quality monitoring
RSPM (PM10 & PM2.5), SOx (from stack of criteria pollutants is already under
and ambient air) shall be regularly progress at the project site and nearby
monitored and results displayed in your villages (both upwind and downwind) viz.
website and also at the main gate of the Tunda, Vandh etc. Also in view of the
power plant. 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 The “Mangrove Afforestation Program”
mangroves species found in this area shall has been undertaken by CGPL in
be taken up with a conservation plan duly collaboration with Gujarat Ecological
approved by State Forest Department. 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 Nearly about 116.7 ha of the project site
developed all around the plant, ash pond has been covered under green belt
11
http://www.tatapower.com/cgpl-mundra/environmental.aspx

Sl.
No.
and township covering 1/3rd of the total development for the period 2012-13. For
project area under green belt development further details please refer to Annexure 2.
A.14 Leq noise level should be limited to 75 Regular monitoring of Leq noise level is
dB(A) and regular maintenance of being carried out by CGPL both at
equipment to be undertaken. 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 In house monitoring mechanism for CSR
monitoring mechanism for the schemes activities are in place. Community
identified under CSR activities are in Satisfaction Index and Community
place and annual social audit shall be got Awareness Index Survey through Tata
done from the nearest government Institute of Social Sciences in March
institute of repute. The project proponent 2011.
shall also submit the status of Social Audit has been undertaken and the
implementation of the scheme from time report submitted in December‟12 by the
to time. 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 Refer to section A.2 and A.3
monitoring facility and operate regularly
and maintain the record on daily basis
B.2 No ground water shall be used for the Sea Water Reverse Osmosis (SWRO) has
project coming under dark zone even in been commissioned and operated by
lean season without permission of CGPL since Sep‟11 to meet the water
competent authority requirement and to discontinue ground
water consumption to meet labor camp

Sl.
No.
potable water requirements.
Refer to section A.4. Additionally to
B.3 Adequate dust extraction system such as
control fugitive emissions from coal
cyclones/bag filter and water spray
stockpile and conveyor the following
system in dusty areas such as in coal
measures has been implemented:
handling, ash handling and other places
shall be provided to control fugitive  Construction of wind barrier along the
emission. 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 Refer to section A.14
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.
B.5. The concentration of the air pollutant Monthly ambient air quality is being
parameters in the ambient air within the regularly monitored at 3 locations within
premises of the industry shall not exceed the project site vizlabour colony, CGPL
the limits specified as per national hostel and near the main gate of the
Ambient Air Quality Emission Standards project site (Refer Annexure 15).
issued by Ministry of Environment and Interpretation of the Jan-Mar‟13
Forest dated 16th November-2009. 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.
No.
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 Refer to Sl.No.12 of Table 1 for details
to be carried out and report submitted to regarding model conformity study.
the Ministry
C.2 The fishing activities and movement of Constructed access road as alternate road
fishermen on the coast should not be for Tragadi harbor from Balaji Salt pan
affected. Appropriate measure such as Bund.
bridges or walkways over the channel Constructed access road with bridge over
should be provided. 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 Consent to Establish (NOC) obtained by
State Pollution Control Board should be CGPL on 17th July, 2007.
obtained before starting the project
C.4 It shall be ensured that the cooling water Refer section A.10.
before discharge shall confirm to the
standards laid down by Gujarat State
Pollution Control Board and Central
Pollution Control Board.
C.5 Continuous monitoring of the temperature Regular online monitoring of cooling

at the discharge point should be provided. water temperature is being carried out at
the bridge constructed over the outfall
channel near the ash pond area. In this

Sl.
No.
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 The outfall channel of total length 4.3 Km
manner that no percolation takes place to is lined with impervious material to
the ground water. prevent any cooling water percolating to
ground water aquifers.
C.7 The end of discharge weir shall be Procurement of services for installation of
designed to ensure that the tidal water discharge infrastructure was verified to be
does not find its way into the pre-cooling in compliance with these requirements
channel. Further, it shall be ensured that and meet the required standards. This is
the hot water discharge is uniformly further substantiated by the cooling water
spread over the radial region in front and temperature recorded for the period 2012-
mixing of warm water with the ambient 13.
receiving water is maximum.

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 Photo 15: Electronic Display of Ambient Air Quality
channel

Annexure 1: Details of Project In-Use Facilities

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

Area Area
Plants planted Cumulative Cumulative Survival
Months Covered Covered
during month plants planted Plants survived Rate (%)
(acre) (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)
Max Average
7
6
Temperature Difference (°C)
0
Apr-Jun'12 July-Sep'12 Oct-Dec'12 Jan-Mar'13
Annexure 8: Graphical Plot - Manual Cooling Water Temperature Difference (2012-13)
Max Average
7
6
Temperature Difference (°C)
0
Apr-Jun'12 July-Sep'12 Oct-Dec'12 Jan-Mar'13

Annexure 9: Continuous Emission Monitoring System – Statistical Data Analysis (2012-13)
Statistical Apr-Jun'12 July-Sep'12 Oct-Dec'12 Jan-Mar'13

Sl.No Standards
Parameter 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)

Unit#1 Unit#2 Unit#3 Unit#4
Sampling Date
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
mg/l BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL BDL 0.5
Chlorine

Annexure 12: STP Treated Water Monitoring Results & Analysis (2012-13)
Sewage Treatment Plant at Project Site Sewage Treatment Plant at Labor Colony (Old) Sewage Treatment Plant at Labor Colony (New)
Suspended BOD 3 days at Residual Suspended BOD 3 days at Residual Suspended BOD 3 days at Residual
S.No. Solids 27ºC Chlorine Solids 27ºC Chlorine Solids 27ºC 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)
PM10 NAAQS
160.0
140.0
Concentration (µg/m3)
120.0
100.0
80.0
60.0
40.0
20.0
0.0
Moti Khakar Mota Nana Tunda Vandh Siracha Tragadi
Kandagara Bhadiya
Villages
PM2.5 NAAQS
70.0
60.0
50.0
40.0
30.0
20.0
10.0
0.0
Kandagara Bhadiya
Villages
September 2013 70
SO2 NAAQS
90.0
80.0
70.0
60.0
50.0
40.0
30.0
20.0
10.0
0.0
Kandagara Bhadiya
Villages
NOx NAAQS
90.0
80.0
70.0
60.0
50.0
40.0
30.0
20.0
10.0
0.0
Kandagara Bhadiya
Villages

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

Annexure 16: Village Level Day Time Noise Monitoring Plot (2012-13)
60
50
40
30
20
10
0
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)
54
52
50
48
46
44
42
40
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)

Mar-
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
13
Induction Training
1 1642 2655 2300 2432 1947 1415 1347 1301 1859 1421 1164 832
Attendees
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
Medical Treatment
4 0 0 0 1 0 0 0 1 0 0 0 0
Cases(MTC)
Safe Man Hours Worked
5 2099760 1834580 1035528 1606108 564584 1343252 1195928 833400 877536 907260 919316 819212
till last fatality/LWDC
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

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Annual Environment & Social Monitoring Report

(April 2012 to March 2013)

Environmental and Social Performance Report

IND: Mundra Ultra Mega Power Project

Prepared by SENES Consultants India Pvt Ltd.

Period: April 2012 to March 2013

Submitted to: Coastal Gujarat Power Ltd (CGPL)

Prepared by: SENES Consultants India Pvt Ltd.

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

ANNUAL ENVIRONMENTAL AND SOCIAL PERFORMANCE

 Contact information for responsible individuals

September 2013 1 SENES

Report Date: July 2013

2 Overall Project Status

September 2013 2 SENES

3 Compliance by CGPL with the Environmental, Health & Safety

3.1 Compliance to IFC & ADB Requirements

3.1.1 Environment Organization Structure & Capacity Building

3.1.2 Integrated Management System (IMS) Development

3.1.3 Consent Management

3.1.4 Coal Quality & Consumption

September 2013 3 SENES

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

3.1.5 Fly Ash Management

3.1.6 Hazardous Waste Management

3.1.7 Management of Cooling Water Discharge

September 2013 4 SENES

3.1.8 Performance of Waste Water Treatment Facilities

September 2013 5 SENES

3.1.9 Flue Gas Emissions& ESP Performance

3.1.10 Ash Pond Structural Integrity

3.1.11 Ground Water Monitoring

3.1.12 Ambient Air & Noise Quality Monitoring

September 2013 6 SENES

3.1.13 Green Belt Development & Mangrove Afforestation

September 2013 7 SENES

Table 1: Environmental Compliance Assessment & Findings

September 2013 8 SENES

Presently the IMS documentation under

September 2013 9 SENES

In line with the audit recommendation CGPL has

September 2013 10 SENES

September 2013 11 SENES

In addition discussion is in progress with Sanghi

September 2013 12 SENES

The possibility of use of fly ash in road

CGPL has prepared a draft action plan to ensure

September 2013 13 SENES

September 2013 14 SENES

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

September 2013 15 SENES

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

Further given the potential concerns raised by the

September 2013 16 SENES

The quantity of SO2 emission (75.42 TPD)

September 2013 17 SENES

Interpretation of manual monitoring results (2012-

The statistical analysis of CEMS and manual

September 2013 18 SENES

September 2013 19 SENES

Review of the analytical results for the period Jan-

September 2013 20 SENES

TDS and chloride values are found to be in line