To
Chairman
Expert Appraisal Committee (EAC)
Union Ministry of Environment, Forests & Climate Change
Government of India
New Delhi
Chairman
Bihar State Pollution Control Board (BSPCB)
Government of Bihar
Patna
Through Lalit Kapur, Member Secretary, EAC, Director, Ministry of Environment & Forests
Date: September 7, 2014
Subject- Objectionable approval to rejected Integrated Common Hazardous Waste Treatment, Storage, Disposal and Recycling Facility by M/s Ramky Enviro Engineers Ltd at Koilwar-Babura Road Bhojpur, Bihar
Sir,
With reference to an advertisement by Bihar State Pollution Control Board (BSPCB) in The Times of India Patna edition dated September 6, 2014 for the proposed public hearing on the Environment Impact Assessment of the proposal for Integrated Common Hazardous Waste treatment, storage, disposal and recycling facility by M/s Ramky Enviro Engineers Ltd at Koilwar-Babura Road Bhojpur, Bihar, it is deeply disturbing that this violates the Expert Appraisal Committee (EAC)’s own recommendations besides all existing environmental norms in the rule book including Hazardous Wastes (Management, Handling and Trans-boundary movement)) Rules, 2008 and Bio-Medical Waste (Management and Handling) Rules, 1998. The proposed facility is in an ecologically sensitive zone. The hazardous waste-cum-biomedical waste facility admittedly gives birth to risks of all cancers and specifically of stomach, colorectal, liver and lung cancer that increases with closer proximity to incinerators.
I submit that the attached Minutes of the 118th Meeting of the EAC held on 8th-9th November, 2012 reveals that the EAC concluded that M/s Ramky Enviro Engineers Ltd the project “Proponent has not justified selection of the site and also there is a habitation at about 200 m from the site which is not advisable for this type of Hazardous waste handling and incineration activity.”
I submit that the proposed Integrated Common Hazardous Waste treatment, storage, disposal and recycling facility is being sited exactly adjacent to Sone river in the vicinity of residential areas of the village in the proximity of Koilwar-Babura Road Bhojpur in area of 57.24 acres of agricultural land.
I submit that the manner in which EAC at its 125th Meeting held on 10th -12th June, 2013 has gone against its own wisdom to assign Terms of Reference of the Environment Impact Assessment (EIA) for public hearing is quite enigmatic. It is evident from the recommendations for Sampling Locations specified for hazardous waste treatment, storage, disposal facility (TSDF) that the ground water samples should be collected at least up to a distance of 5 KM from the TSDF location. This in effect is an admission that at least 5 KM zone of the proposed facility is an ecologically sensitive and vulnerable zone. According to US Environment Protection Agency (USEPA), toxic emissions like Dioxins travel long distances in the atmosphere and is found on plants, in water, soil, grazing animals and humans.
I submit that the grounds on which EAC reached its inference at its 118th Meeting remains quite valid and scientific based on deep understanding of far reaching implications of incinerator facilities. It is quite manifest that the project proponent has misled the EAC regarding facts about the location of the proposed hazardous waste facility to ensure that EAC reverses its considered verdict about the inappropriateness of the site in question. The Terms of Reference no. (viii) provided to the project proponent states “Examine the details of monitoring of Dioxin and Furan”. This reveals that the proposed facility will emit dioxins and other harmful pollutants. Dioxin is the common name for 75 toxic chemicals that are unwanted by-products of manufacturing and combustion processes when chlorine and carbon-containing materials are combined. It must be noted Bihar State Pollution Control Board (BSPCB) does not have the required infrastructure to deal with such toxic chemical emissions which has been so lethal that it was used as a chemical weapon by USA against Vietnam under the Brand name Agent Orange whose after effects continues to trouble both the war veterans of USA and Vietnam.
I submit that Garbage and medical incinerators have been identified as the largest sources of dioxins in the US Environmental Protection Agency (USEPA)’s reassessment reports on dioxin in 1994/2004. Dioxin particles are stored in fatty tissue and will accumulate to create “buildup” when low-level exposure is continual. The International Agency for Research on Cancer (IARC) concluded that dioxin is a human carcinogen. Non-Hodgkin_ s lymphoma and cancers of the liver, lung, stomach, soft and connective tissue have been associated with dioxin.
Even at very low exposure, at levels of parts per trillion, dioxin causes immune system damage, hormone disruption, and reproductive and development effects. Some newer emission control devices have been effective in decreasing recorded dioxin air emissions from incinerators, but there is no safe level additional exposure to dioxins. This is because the average daily dioxin intake for is already 200 times higher than what the US EPA defines as a safe dose for adults. Those most at risk of receiving the highest concentrations are babies. Studies also show elevated levels of dioxin in the blood of people living near municipal solid waste incinerators when compared to the general population. Residents in Indian cities are rightly alarmed at the prospect of these incinerator plants coming up in their city.
I submit that in February 2014 the 27th report of the Parliamentary Committee on Urban Development has recommended that incinerator plants should be stopped in all residential areas across the country in its report to the Parliament. Incinerators cause serious environmental and health problems to the people living not only near them but even to those who live several kilometers away from the source like the proposed facility.
I submit that the advertisement of the Bihar State Pollution Control Board (BSPCB) reveals that the proposed hazardous waste facility will also incinerate bio-medical waste which is governed under Bio-Medical Waste (Management and Handling) Rules, 1998 which provides that “Bio-medical waste shall be treated and disposed of in accordance with Schedule I, and in compliance with the standards prescribed in Schedule V.” Schedule I provides Categories of Bio-Medical Waste. Schedule V provides Standards for Treatment and Disposal of Bio-Medical Wastes. It is noteworthy that the Schedule –II of the Municipal Solid Wastes (Management and Handling) Rules, 2000 lays down the compliance criteria stating “Bio-medical wastes and industrial wastes shall not be mixed with municipal solid wastes and such wastes shall follow the rules separately specified for the purpose.” The proposal is in contravention of this criteria.
I submit that the attached 15 July, 2013 judgment of the Hon’ble Delhi High Court is quite germane in this regard. The Hon’ble High Court judgment refers to ‘The summary of “Epidemiological Studies on Adverse Health Effects Associated with Incineration” would show that medical waste incinerators are a leading source of dioxins and mercury in the environment and there is link between incinerator emissions and adverse health impacts on incinerator workers and residents living around the incinerators.’ (Source: http://www.delhicourts.nic.in/Jan13/P.K.%20Nayyar%20vs.%20UOI.pdf)
Hon’ble Court’s judgment reads: “Both older and more modern incinerators can contribute to the contamination of local soil and vegetation with dioxins and heavy metals. In several European countries, cow‟s milk from farms located in the vicinity of incinerators has been found to contain elevated levels of dioxin, in some cases above regulatory limits. Increased levels of dioxins have been found in the tissues of residents near to incinerators in the UK, Spain and Japan. At an incinerator in Finland, mercury was increased in hair of residents living in the vicinity. Children living near a modern incinerator in Spain were found to have elevated levels of urinary thioethers, a biomarker of toxic exposure. “ It notes that “After 2 years of operation of incinerator, dioxins levels were found increased by about 25% in both groups living between 0.5 to 1.5 and 3.5 to 4.0 km away (201 people) of people. In the repeat analysis, the increase was in the range of 10-15%”.
The judgment records that “Mothers living close to incinerators and crematoria from 1956 to 1993” showed “increased risk of lethal congenital abnormalities, in particular, spinal bifida and heart defects, near incinerators: increased risk of stillbirths and anacephalus near crematoria”.
I submit that with regard to “Residents from 7 to 64 years old living within 5 km of an incinerator and the incinerator workers” the judgment observes, “Levels of mercury in hair increased with closer proximity to the incinerator during a 10 year period”.
I submit that the judgment of the Hon’ble High Court found that “Residents living within 10 km of an incinerator, refinery, and waste disposal site” showed “Significant increase in laryngeal cancer in men living with closer proximity to the incinerator and other pollution sources”. It observed that the “Residents living around an incinerator and other pollution sources” showed “Significant increase in lung cancer related specifically to theincinerator”. The “People living within 7.5 km of 72 incinerators” displayed “Risks of all cancers and specifically of stomach, colorectal, liver and lung cancer increased with closer proximity to incinerators”.
In view of the above mentioned facts, the public hearing for the project is scheduled for 16.10.2014 at 11 AM at Ambika Sharan Singh High School, Jamalpur, Post- Naya Mohammadpur, District- Bhojpur must be cancelled failing which there will be massive resistance from the villagers due to imminent public health crisis.
In view of these facts, I seek your urgent intervention to address the issue of environmental and public health rights of the present and future generations of residents of villages on the Babura-Koilwar road in Bhojpur, Bihar.
Thanking You
Yours faithfully
(Gopal Krishna)
ToxicsWatch Alliance (TWA)
Mb: 09818089660, 08227816731
E-mail:gopalkrishna1715@gmail.com
Web: www.toxicswatch.org
Cc
1 Dr. M.L. Sharma, Member, EAC
2 Shri R. Radhakrishnan, Member, EAC
3 Dr. M.V. Ramana Murthy, Member, EAC
4 Dr. R. Prabhakaran, Member, EAC
5 Dr. Anuradha Shukla, Member, EAC, Central Road Research Institute (CRRI)
6 Shri S.K. Sinha, Member, EAC, TNP&ANI GDC, Survey of India
7 Shri Y.B. Kaushik, Member, EAC, Central Ground Water Authority
8 Ms. Mita Sharma, Member, EAC, Central Pollution Control Board
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