BEFORE THE HONOURABLE NATIONAL GREEN TRIBUNAL PRINCIPAL BENCH, NEW DELHI
Original Application no. 76/2019
State of Kerala & Others Respondent(s)
Report filed bv the Joint Committee constituted in Orieinal Application No. 7 612019.
Adv.Jog.v Scaria.
ADDITIONAL STA}TDING COUNSEL BEFORE THE HONOURABLE NATIONAL GREEN TRIBUNAL PRINCIPAL BENCH, NEW DELHI
Original Application no. 76/2019
State of Kerala & Others : Respondent(s)
VOLUME 1
Index \
SL NO Description Pages
I Report filed by the Joint committee constituted l-32 in OA No.7612019.
Dated this the 2"d day of November 2}lg.
SINDHU RADHAKRISHNAN €niet Environmental Engineqr Jow Scaria, Advocate Additional Standing Counsel BEFORE THE HONOURABLE NATIONAL GREEN TRIBUNAL PRINCIPAL BENCH, NEW DELHI
Original Application no. 76/2019
State of Kerala & Others Respondent(s)
VOLUME 2
Index
SL Description Pages NO I Annexure r - copy of the NGT order dated19.07.2019 r-4
2 Annexure II - copy of Minutes of the meeting conducted r-6 on 1310812019.
3 Annexure III - Copy of the Mining details furnished by 1-5 IWs. IREL.
3 Annexure IV - Copy of the Mining details furnished by 1- 16 IWs.KMML.
Dated this the 2"d day of November 2019.
Jogy Scaria, Advocate Additional Standing Counsel ?'$f*ffi':$\lt]' BEFORE THB HONOURABLE NATIONAL GREEN TRIBUNAL PRINCIPAL BENCHN NEW DELHI
Original Application no. 7 6f20l9
State of Kerala & Othen: Respondent(s)
Report frled by the Joint Committee Members, Smt. Sindhu Radhakrishnan, Chief Environmental Engineer, Kerala State Pollution Control Board (KSPCB) and Dr. Deepesh V, Scientist B, Centnal Pollution Control Board (CPCB), Regional Directorate, Bengaluruin the matter of Original Application No.7612019.
This report is submitted in continuation to the report submitted on 1810912019 by the Chief Environmental Engineer on behalf of the Joint Committee requesting one month additional time to collect releVant data and information to prepare the environmental damage assessment report. Due to paucity of data, report preparation was delayed and
delay in submitting the report may be kindly be accepted.
1.0 Background
The issue for consideration in the O.A No.76l2019 is the illegal mining carried out by lvl/s. Indian Rare Earths Limited (IREL) and Ms. Kerala Minerals & Metals Limited (Kl\ffvtr ) along the coastal area of Alappad and Chavara, in Kollam District, Kerala. As per the direction of tle Honorable National Green Tribund, a study report, on the beach erosions along the lQyamkulam - Neendakra coastal stretch and the contribution of beach sand extraction on tle extent of.wlnerabiliry prepared by National Centre for Earth Science Studies INCESS) has been submitted. The NCESS has conducted the study along 22 Km long coastal stretch extending from Kayamkulam inlet at northto Neendakaa inlet at south during February - March, 2019.
The main finding in the report submitted by NCESS that 'the severe erosion is attributed to the unsustainable mining practices that have been going on along the coast had been noted by the Honorable Tribunal in the Order dated 19-07 -2019 (Annexure I) and pronounced that Ms IREL and Ms KMML had mined excess quantity during the period 2001-2010 and 2010-2019.
As per the direction of the Honorable National Cr."o l.ibrroA in the above order a Joint Committee has been constituted with Dr. Deepesh V., Scientist B of Central onal Directorate, Bengahuu and Smt. Sindhu
HURADHAKRT'HNAN Environmental Enginee{e4=-' Radhakrishnan, Chief Environmental Engineer, Regional Office, Kerala State Pollution
Control Board, Thiruvananth4uram as members.
Beach sand along the eastern and westem coast of India is found to be rich in heavy minerals such as ihnenite, rutile, zircon, monazite, sillimanite etc. These minerals have considerable use in the production of various industrial products like titanium dioxide, ceramic, welding electrode, pigments, paint additives, etc. The major deposit along the west coast isthe Quilon depositknown as "Chavora deposits" along 22.5 Km length of Neendakara - Kayamkulam (NK) belt in Kerala. Chavara deposit, 'Q' grade ilmenite has high titanium oxide content. It is preferred worldwide due to its high titanium oxide content and less iron.
Neendakma - Kayarnkulam (NK) belt has been under mining since 1909 by various companies. Since 1965,IWs. Indian Rare Earth Limited (IREL), a Government of India undertaking under the department of Atomic Energy, succeeded in taking over the assets of 2 companies. Initially, their activities confined to mining and separation of heavy minerals from beach washings deposited by wave action. Later on the Atomic
Mineral Division, (Atomic Minerals Directorate for Exploration and Research) under the Department of Atomic Energy carried out geological exploration of the are4 and company started inland dredging operations since 1990.
The Neendakara Kayamkulam stretch was divided into 8 blocks (NK Blocks). Mining leases for NK Blocks I, III, V and VII was granted originally to KSIDC (Kerala State
Industries Development Corporation) and were subsequently given to IWs. KMML a public sector unit under the Govemment of Kerala. Mining lease has been renewed vide GO (MS) No. 2l4l20IllID dated 24-10-2011 for 20 years. Mining lease for NK Blocks II, IV, VI and VIII were granted to lWs. IREL vide G.O. No. l95l70tID of 3010511970. Afterthe expiry of mining leases in 1990, the mining leases of IREL were extended periodically for short periods. In 2005, vide G.O.(MS)No22/2005/ID dated 221212005 the mining lease was renewed to IREL with retrospective effect from 1990 for 20 years for NK Block II. Subsequently, vide G.O. (MS)No .3212006/ID dated L51312006, the period of the lease was extended till 2020. The mining plan was approved by Atomic Minerals Directorate (AI\D) vide AMD Approval No. AMD-20 190 - PMSG 134 dated l2l0lll99l.
SINDHU RADHAKRISH Chief Environmental Engineer according to various factors mentioned in the NCESS report zuch as wind velocity, wave action, season, etc. Inland mining: The coastal inland up to 100 m is permitted to be mined for the heavy minerals. The mining is done in the 4proved blocks by excavating the sand up to 3 to 7 m using earth excavators or by Dredge Wet Concentrator (DWC) method.
The mined sand from both cases is then transported to the mineral extraction plant where the heavy minerals are separated by gravity separation using hydro cyclones. For this process the sand is passed through a series of gravity separators albng with water.
The heavier particles are collected as raw material for further purification & separation.
The lighter particles are collected at the plant itself which are to be utilized for refilling excavated area.
Subsequent to the Honorable NGT order dated 19-07-2019, the Chairman of Kerala State Pollution Control Board (KSPCB) had convened a meeting on 13108/2019 with various stake holders concerned with the mining of heavy minerals from the Chavara coastal area and with technical experts in this field. The discussions were intended to sort out the problems in recovering mineral resource without causing further environmental damage.
It was explained by the Assistant Manager from Atomic Minerals Division (AMD),
Department of Atomic Energy that Chavara region in Kollam District is having a major mineral deposit extending225 Km length from Neendakara to Kayamkulam. Titanium content of more than 62% and low iron content minerals naturally occurs from High Tide Level (HTL) to 200 m towards east.up to the inland navigation channeU estuary called T S (Thiruvananthapurarn - Shoranur) Canal which is separating the present mining area from main land. From T S Canal to I Km east, heavy mineral potential is l0 % and up to 6 Km it is 6 - 7 .5 %. lWs. KMML and IWs. IREL together is carrying out mining in 8 blocks for which they are holding lease. The mineral deposit in the offshore is 7.5 - 9 m depth in Chavaraarea.
SINDHU RADHAKRISHNAN Chief Environmental Engineer According to the Senior Geologist from Mining & Geology Department, Atomic Mineral Division (AI\D) has explored 347 50 Ha of land for mining and mineral extraction. Out of which, 550 Ha has been given on lease to lWs. KMML (l lease) and lWs. IREL (4 leases). IWs. IREL has Environmental Clearance (EC) for 2 blocks,
whereas, lWs. KMML has not yet obtained EC. If the mining is conducted as per the approved Mining Plan, Environmental Impact Assessment, Environmental Clearance and according to the relevant statutes, the environmental damages could have been averted or minimized. As per the Mining Plan, provision is given only for manual mining using shovels and in pracfice the companies are using heavy .urttt movers for beach mining.
In the meeting, representatives of IWs. IREL reported that the percentage of heavy minerals received from beach washing has come down to 10 12 % after the devastating tsunam i in 2004. Representatives of IWs. KMML explained that they had
applied for Environmental Clearance and public hearing has been conducted. They also
reported that it is practically and technically not feasible to put back the tailing sand
after mineral separation. As per EIA report, it is committed that the tailing sand will be returned to beach as per the mining plan and none of the regulatory/ technical authorities had advised them not to return the sand to the beach.
The Director, Geological Survey of India (GSI) informed that a mobile gravity separator is being used in East African Countries, for beach mining. The unit travels in
one direction for about 500 m separating the minerals and depositing the rejects on the beach itself. The deposition of heavy mineral containing sand happens on the beach by wave action by the time one transit is over. hus mining can be done without disturbing
the beach. However, it was opined that this will be feasible for long beach stretches and
the available beach length in the present case is only 700 m.
As per the request of the Chairman, KSPCB, possibilities of offshore mining were also
discussed in the meeting. It was informed that the GSI has identified 2l blocks of sea bed in different sectors like Chavara, Varkala, etc. in Kerala. It was informed that the
sea bed is having 125 million Tonnes/ metre of heavy minerals at lm depth. The sea depth is 10 to 60 m extending up to I Km away from seashore with in average heavy mineral concentration of 18 %. As per a notification published by Government of India, the operating rights with respect to sea minerals, in offshore urea can be granted only to Government or Government owned public limited companies. The Senior Geologist informed thatoffshore mining shall be carried out as per 'Offshore Mineral Government of
lrry?lv $Pji[TL'Ji^t] India by auctions. Amendment in the act is required for this and there are some litigations pending.
It was decided in the meeting to make plans and proposals to mine offshore minerals and rebuild the beach using the reject sand and also to place the matter before Honorable NGT for consideration. Copy of minutes of this meeting is produced herewith as Annexure II.
l.l Prospect of mineral sand mining
According to the Indian Minerals Yearbook prepared by Indian Bureau of Mines (Blv1), Ministry of Mines, India is endowed with large resources of heavy metal minerals which occur along the coastal stretches and also as inland placers. The heavy minerals sand comprises a group of seven minerals: ilmenite, leucoxene (brown ilmenite), rutile, zircon, sillimanite, garnet and monante.In India there are five well defined zones rich in heavy metal rich sand deposits and one of the zone is in Kerala: 22 lffi stretch between Neendakara - Kayamkulam (NK) block, Kollam district, Kerala (known as 'Chavara' deposit after the main mining centre). The average grade of total heavy minerals inthese deposits is 10 -25 % of which 30 - 40% is ihnenite. Ilmenitereserve/ deposit in Kerala is in the following stretches.
Ilmenite rcsoarceil dqosiE in Kerala Million Tonnes
Chavara Barier beach 13.17
Chavara Eastern Extension (Phase-I) 17 .02
Chav ar a E astern Extens ion (Phase-II) 49.26
Trikkunnapuzha-Thotapally beach & Eastern extension 9.50
Alappuzha-Kochi 5.88 Brahmagiri (Phase I-V & NW extension), Odisha (For reference) 86.04
Mining and processing of beach sand are carried out by the IREL, a Government of India Undertaking; KMML, a Kerala State Government Undertaking and two Private Sector Producers N{,is V V Mineral, Thoothukudi, Tamil Nadu and IWs Beach Minerals Co. Pl,t. Ltd, Kuttam, Tamil Nadu.
It was reported that, IREL, Chavara, collected beach sand over a stretch of 22 kan between Neendakara and Kayamkulam in Kerala (Indian Minerals Yearbook,2018).
The unit has adopted wet mining operations using two Dredge and Wet Concentrator
(DWC) of 100 TP to exploit the inland deposits awa from the beaches.
I*o*u RADHAITF:pI' However, during site visit, IREL is employrng mining with earth movers instead of DWC. Chavara ilmenite is the richest in TiO2 content (75.8 % TiOz) and has great demand in India and abroad for manufacturing pigments. The sand deposits of OSCOM
(Orissa Sands Complex) at Chatrapur in district Ganjam extend along the coast of Bay of Bengal with an average width of 1.4 Km and average depth of 7 .5 m. Mining operations involve suction dredging to 6 m depth below water level on a much larger scale (500 TPH) augmented by a smaller sized (100 TPH) supplementary.
As per the IBM's annual mineral yearboolg it is explained that, dry mining of beach washings laden with 40 - 70 o Heavy Minerals (Iiltr) are collected through front-end loaders and bulldozers for further concentration to 90 % HM at land based concentrators. Though dry mining is very simple and econo-ic, there is considerable opposition by local people for this form of mining for reasons that removal of sand would expose the land area to sea erosion.
As an alternate approach, IREL has adopted wet mining involving dredging and wet concentration (DWC) from inland areas away from the beach lines. In this mode, an artificial pond is created, the sand bed is cut and the slurry is pumped to spiral concentrdor for removal of quartzl silica.
As per the IBM yearbook, KMML collects seasonal accretions of heavy mineral sand from the beach front. The pit so formed gets filled by fresh accretions of heavy mineral sand. The rnineral sand is collected using bulldozers and wheel loaders and transported in trucks to Mineral Separation Plant (MSP).
2.0 Site visit & ground reality
In order to ascertain the ground realities, the joint committee supported by a team of Environmental Engineer, Assistant Environmental Engineer from KSPCB, Kollam district office and field staff from CPCB, Bengaluru conducted site visit & field survey along the coast of Alappad and Panmana Panchayat on 2210812019. The tearn visited the beach mining sites of lrrf/s IREL and IlOs KMML. The Alappad Panchayat office was also visited to gather information about the environmental issues caused due to beach sand mining.
At Vellanathuruth in Alappad Panchayat, about I Km length has been allotted to lWs. fnpl- for beach mining. It is located in l6ftward of Alappad Panchayat. Except for this
SINDHU RADHAKRISHNAN ;i;'"f Environmental Engineer early as in the yer wall protection. The sea wall is reported to have constructed as not observed. Two officers from rg77 -During the visit, beach mining operations were that beach mining operations were N4/s. IREL were present at the site. It was informed Minister of Kerala on temporarily halted for past 6 months on the direction of chief was going on using excavators, account of public complaints. However inland mining is under repair. front wheel loaders, other earth movers and was told that Dwc
Ilmenite, Rutile' zkcon, It was reported that lws. IREL separates minerals such as gravity separation'of the dredged Monazite, sillimanite and Garnet after washing and Tonnes of sand is dredged from the sand using hydro-cyclones. Approximatery, 1000 separation plant at vellanathuruth areaper day. IREL has an on-site primary mineral transported to the mineral separation beach. Heary minerals fractions are separated and part of the excavated prant. The tailings i*e seen heaped in the beach itself- some planted with coconut saplings' The (inland) ilea was seen refilled with tailing sand and permanent jobs for the people who have company has provided temporary/ contract/ as per the lease agreement' It was leased their land to them for a period of 3 years dredge coastal shore line to a reported that lws IREL has the Govemment pennit to maximum width of 100 m.
to the proximity of the The ground water in the wells of this area has salt content due by Kerala water Authority and if any sea and the water for drinking purpose is provided }rf/s. IREL- The seashore and sea shortage occurs, the water is supplied in tankers by wall in the area is also maintained by }vvs. IREL.
done in the site of lws' During the visit it was noticed that beach mining was being to IREL site, in the KMML in ponm ana areain panmana village. The site is adjacent mining staff were employed in northern part of panmana village. About 50 temporry earth movers were seen at transferring the heaped sand into trucks. Two front loading be from the displaced fumilies, the site. The conffactual mining staffs are reported to left over sand could be seen who have sold their land to the KMML. Large heaps of mined Neas. near this beach which was not utilized for refilling the
from the sea by the beach and T s canal is east of the minin g arca and is separated mining are4 the land inland mining areas at vellanathuruth & Ponmana. In the beach activities at beach front and had dwindled to a meager 50 m at Vellanathuruth. Minfu8 land over a period of time.
:s.??Yfi*IisE$mI' Beach mining activifies at Ponmona (KMML mining site)
Inland mining by IREL at vetlanatndth @Ifiip;id rtiiosa
H u RAD H AKRLS l{:ll\t sl N DH Engineer Chief Environmental Ponmana (KMML beach mining site)
H u s r N D $P,iif"T'r=sH |' Chief Environt sand tailing heop at LREL prtmary processing site, vellanarhuruth
Beach mining site of IREL, Vellononthuruth
As per NCESS reports, approval letter of mine plan, Govt. lease orders and EIA reports by the project proponent, only sustainable volume of sand shail be mined from the beach and proper reclamation / mine closure measures are to be followed for continuing the mining without causing harm to the environment. The ta4ing, which is more than 70 Yo of thecollected sand, shall be returned to the beach itself The indiscriminate removal of sand from the beach is the major reason for the beach erosion and in the NCESS
monsoon season when the beach
H u s, N D T lPl*f,.T J$l.t ); Cnitt Environ dated 01-03-2011 for mining m trvf/s. IREL obtained Ec vide F.No. LL-3612008-IA-III, villages in Kollam District' lg0 Ha areain Alappad, panmana and Ayanivelikulangara under water, Air & pnvilsnment They have obtained Integrated consent to operate day and having mineral protection Act for beach washing, for a quantity of 800 TonneJ has applied for Environmental clearance separation of 160 Tonnev day. Iws. IREL also In the case of KMML, for g Ha of land in Block II on mining lease valid ti1281212020. was conducted. They have not has applied for EC for block IIr and public hearing Environment Protection Act for applied for consent to operate under water, Air &
beach washing and mineral separation operations.
2.1 Specifrc obsenations based on the site visit:
are not returning the During the site visit ii was noticed that both companies tailing sand to the beach- near primary sand Heaps of tailing sand could be observe d at vellanathuruth site, ponman4 northern side processing facitity of IREL and at KMML mining
of Panmana village. refilling the leased inland , A part of the tailing sand was found to be reused for private property- mine ffie^at vellanath'rth. This reclaimed area was leased mechanical r Dwc for inland mining was found to be not in operation and In the case of DWc, the separation excavation using earth movers was observed. be deposited to the mined area of the minerals happen on-site and tailings will simultaneously. in Ponmana afea near to r Abandoned school and other struct*res were observed present KMML mining site' of Ponmana area' . Mangroves were observed along the T S canal side is located in the KMML o A locally famous temple Kattil Mekathil Durga temple mining site at Ponman4 Panmana village' were observed in the o constructed groins for promoting beach accretion Vellanathuruth and Ponmana beaches' are willing to lease out . As per the local people surveyed at vellanathuruttu they package offered by the company. their property to IREL because of the fair lease panchayath authorities- This fact was firrther confirmed by the Alappad owner within three years o As per the IREL lease, reclaimed site is returned to the per Govt. rates. APart from this and valuation of structures, trees, etc' are as relocation charges are borne by the company'
SINDHU RADHAKRISHNAN ;h"f Environmental Engineer 1l Temporary/ permanent employment is offered by the company to one member
of each displaced family.
As per the local people, KMML is purchasing private lands in the lease area and temporary job as mining staff is offered to one member of each displaced family.
Due to the unsustainable mining practices, there are environmental damages/
degradation to the area with respect to the following:
3.0 Environmental damage
The term environmental damage is linked with serious cases of pollution, contamination and loss to biodiversity and is often dealt with environmental liability regulations and through ecologicaV environmental compensation under the ambit of 'polluter pays principle'. The concept of ecological compensation is the charges to be paid for polluting environment and the charges are mrived on the basis of the ecologic-economic assessment of that particular environment.
On assessing the environmental damages, adequate ecological compensation is levied upon the defaulters to implement measures intended to restore, rehabilitate, decontaminate and enhance the concerned environment. Hence, the environmental compensation imposed for environmental damages essentially includes restoration/ rehabilitation expenses, fine/ penaltyi financial deterrent for the activities which caused the environmental damages and the expenses incurred for identrfying the extent of environmental de gradation.
Environmental damages due specific anthropogenic activities have far reaching effects on various habitats and ecosystems and also impair human's consumer & non-consumer values. Environmental damages significantly vary in terms of the damage's space, scop'e, level and magnitude. Due to this, significant indiceJor markers of environmental damage differ considerably and one of the initial steps of environmental darnage daunting task to understand and assess the extent of environmental damages, This also holds good on the fact that; it is quite a complicated task to correctly assess the benefits to emerge from the restoration measures as a rezult of implementdion of compensatory activities.
3.1 Environmental Damage Assessment
Environmental damage assessmept and compensation involves three modules. The first
and foremost step is to assess. the interim compensation for interirn/ temporary restoration process. This is assessed by quantrfuing the interim damages with the help of equivalency analysis. In the present case (unsustainable mining of black sand at beach front), reserye equivalency method can be used where potential interim environmental damages can be assessed in each compartment of habitat like air, water, land, flor4 faun4 etc. Potential damages calculated for each compartment sums up as the interim compensation for immediat e re storation measure s.
The equivalency analysis, selection of environmental indiceV markers and appropriate restorations always represent a repeated process. Thus, the initial decisions on the choice of equivalency approaches and restoration measures can be changed after gaining more knowledge about the nature of the relevant damage and the effective restoration. It is also highlighted that there is no established standard for any of the components of environmental equivalency analysis and so, it would be fully reasonable to consider any approach which promises to reach the appropriate restordion of type and amount through the most efficient way as the 'most correct' approach.
After the interim assessment, environmental restoration plan has to be made by a detailed investigation and appropriate restoration measures has to be zeroed on by a panel of environmental experts. The actual cost of such a restoration plan/ project has to be imposed on the defaulter. The third component of the environmental damage is the actual cost of studieV surveys/ investigationV discussionV monitoring/ reviews/ field visitV laboratory assessments, etc. carried out by the regulatory authorities and expert team assigned with the implementation/ monitorngl review of the restoration project. Therefore, environmental damage essentially includes following three components: a) Interim damage assessment and compensation for temporary restoration acfivifies. 'r b) Expenses with respect to long term restorafion/ rehabilitation plan. c) Cost associated with all studies, invatigations and reviews ossociated with damage (Nsessment and restoration activitiq
SINDHU RADHAKRISHNAN Chief Environmental Engineer 3.2 Interim damage assessment
The first step of damage assessment is to impose compensation on interim darnages emerged in each compartment of the habitat/ ecosystems. This include the cost of
resources, which has been impaired of its intended uses after the emergence of damage.
The matter in question is the unsustainable beach mining of black sand by lWs. Indian Rare Earth Ltd ([REL) and IWs. Kerala Metals &, Minerals Ltd (KMML) in Vellanathuruthu (Alappad PaRchayat), Ponmana (Panmana Panchayat) and Kovilthottam (Chavara Panchayat) in Kollam district, Kerala. The potential damage
assessment is limited to land and water funds. Due to unsustainable mining activities, damages are manifested on coastal land and the subsequent effects are, lossofland resources, deprived natural coastal protection, altered coastal micro climate, aggravated
beach erosion, effect on recreational/ cultural aspects, etc.
Damages are believed to be negligible on surface waters and ground water. The
environmental damages associated with coastal productivity, fauna and fish stock are to be investigated thoroughly to delineate any effects if exist in the restoration phase.
Similarly, health effect of such unsustainable mining requires a very detailed study as black sand deposits are associated with natural background radiation as traces of radioactive minerals occur along with other heavy metal minerals. The effect of mining on the background radiation needs a thorough investigation and implication on human health has to be elucidated.
In this report the interim damages are.assessed with respect to land resources and unsustainable extraction of mineral reserves. Any other damages on account of other
environmental components can be integrated with this assessment if required.
The damage assessment is confined only to 2001 - 2019 as there is great limitation in obtaining relevant data for the period prior to 2000. The committee has referred World
Bank document, "Methodology for calculating environmental damage assessment and relevant compensation" (World Bank, 20lI) developed for mining sector.
Potential environmental damages can be listed as following:
; Land destruction due to tailings
. Land lost due to unsustainable mining o Value of land
RADHAKRISHNAN SINDHU Engineer Chief Environmental
t4 Land plot dam age - Lost opportunities on account of: o Agriculture revenue lost o Recreational o Cultural o Traditional fishing a Damage due to unsustainable extraction of minerals
a Restoration expenses
a Ecological services lost o Natural coastal protection o Coastal micro climate control
3.2.1 Land deteriorationldestruction due to tailing
The following formula is applied for calculating damage to be caused to the surrounding environment because of the deterioration/ degradation/ pollution of the ground surface with solid wastes:
D(GS):QxMxCF(SW)
D (cs) Darnage to be caused by land reserve destruction or land surface deterioration. a Index of land reserve's relative value (0.3 for barren lands to 3.0 for land falling under ecologically sensitive zones).
M Weight/ quantity of solid waste released (TonV year) cF(sw) Damage to be caused by I .0 ton of solid waste (Rs.)
The land reserve's relative value can be taken as 0.5 for barren lands, 1.0 for grass lands/ recreational plots, 1.5 for agricultural lands,2.0 for plantations, wetlands& coastal area,2.5 for forest lands and 3.0 for ecologically sensitive zones.
The amount of unit damage to be caused to the surrounding environment in the result of releasing of 1.0 ton of solid waste into the environment can be expressed by the sum of the expenses on removal, detoxification, disposal charges, cost of land polluted, expenses on hygiene and environmental restoration measures.
In tbis specific scenario, the solid waste generated is the mine tailing resulted from the beach mining/ washings. The black sand rich in ilmenite and other heavy metal minerals are processed on or off site to separate heavy metal rich fractions and taifing consisting
il13?:"tflls':$H)' of silica sand are deposited in surrounding treas as mounts or in trenches in the industry premises.
As per the recommendations of NCESS for srstainable mining, these mine tailing have to be deposited back to the beach to prevent further erosion of beach and to reclaim the lost beach due to mining activities. This is one of the requirement as per the approved mining plan and Government mining lease, where it is imposed that the reclamation of mined irea and progressive closrre of mine shall be done as per the plan. However, the industry representatives were of the opinion that depositing sand t"iliitg back to beach front was not viable for two main r@sons: a) loose sand depositions at beach front will be carried off by wave action and b) tailing deposition at beach front will reduce firther deposition of the heavy metal rich black sand and its heavy mineral content.
Hence, excessive extraction oft'beach sand using heavy erth moving equipment and non-deposition of sand tailings back to the extracted areas in beach front resulted in the loss of beach area. Or in other words the intensive beach mining operations and associated anthropogenic perturbations disturbed the natural beach formation, increased beach erosion and ultimately resulted in the destruction of beach front. The extent of land loss is evident from the Google Earth imagery.
Vellanathnruth (IREL beach mining site) 08-04-2019 Yellow reference line is 300 m long
SINDHU RADHAKRISHNAN ;ilil inuitonmental Ensineqr pah tir , PdtFn Crda _ :I)p6tr Spol)'gEi flc6r. tt|e &fE bctffl hro ptirE m trt gund
M+teDh: Gcrdta4ilhr tleafig:
f $.ce rafirtm
Vellanathuruth (IREL beach mining site) 29-01-2003
ti1e Pl0l Pdyg1 Gdi lDpath 3Ddltgon fthE e thc dstrrcc bctwclfr tyro trrtE sr the grurrd
t4+ terigilhl 0.+1 lCilEtgil eurdLrngth: 0.44 rcedngr A).E{t drgrras
Panmana (KMML beach mining site) 13-04-2019 Yellow reference line is 440 m long Panmana (Kllnfl, beach mining site) 29-01-2003
To calculate the exte,nt of damage, total mine tailings generated during the beach mining operation is required. Reports regarding quantity of beach washing, healy mineral conte,lrt, tailing generated etc have been called for from the concerned industries and it is attached as Annexure trt & tV. The complete detail of mine tailings generated by the beach washing by lWs. IREL and lWs KMML is not provided by the industries and is not available in the NCESS report of April, 2019. Hence, the quantity of mine tailings is calculated from the total sand excavated from beach washing / mining and the average heavy mineral (o/o) in the excavated sand. 1[s lsmaining sand after the extraction of minerals is taken as the tailing which has to be disposed of scientifically for reclaiming mined areas. Details of mine tailings generated by the industries are given bellow.
Pafiicularc IREL KMML Period of mining activity 2001-10 20lt-t9 2001-10 20tt-19 Mined volume (MI) 1643976 rl7 5784 1573070 r77892r Average heavy rhineral 54.47 30.s2 23 24.91 (rlM) (7o) Approx. mineral sand in 89s473.73 3s8849.28 361806.10 443129.22 the mined volume (I\[f)
Tailings generated based 748s02.27 .816934.72 1211263.90 1335791.78 ontheHM % (MI) 2 N O NNI+AKRIS HNAN There is a huge data gaps n% heavy metal contents in the mined sand \Mith respect to KMML, the heavy metal content (%) was calculated with limited datamade available to the committee. Data from 2008-09 onwards was provided by KMML and based on this o InvI content was calculated. For the decade 2001 -2010, only two data sets were available for the years 2008-09 and 2009-10 and from this heavy metal percentage o/o calculated (18.4 & 14.2 respectively). However, considering the huge gap in data for the period 200l'2010, approximate HM content of 23o/o was taken into consideration for calculating the mine tailings generated by KMML.
For calculating the environmental damages to land deterioration/ destruction/ pollution due to improper mine tailing disposal, following aspects have to be accounted/ considered.
No. Requirements Parficulars Remarles
1 Index of land 2.4 The land reserve's relative value can be taken reserye's relative as 0.5 for barren lands, 1.0 for grass lands/
value. recreational plots, 1.5 for agricultural lands,
2.0 for plantations, marine & coast al are4 2.5 for forest lands and 3.0 for ecologically sensitive zones.
2 Quantity of mine 156s436.99 Calculated quantity of tailings generated by tailings improperly lWs. IREL for the period from 2001-19. disposed (Tonnes) 2547055.68 Calculated quantity of tailings generated by lWs. KMML for the period from 2001-19. 3 Damage to be Rs. 99i caused by 1.0 tonne tonne mine
tailings disposed unscientifically.
context it is estimated that Rs.99l tonne is required for the removal and disposal of mine tailings using earth moving machineries. Since, this *irtd stretches of southern Kerala were once sand dunes, the best restoration effort is to stop beach mining and
allow sand dunes to develop along with the
-. ^ ti._re.L{N AN natural vegetation. In this context, a separate re-plantation is not considered. The total damage per unit failing is Rs 99/ Tonne.
Calculation for danrage to be caused to the land environment because of the
deterioration/ degradation of the ground surface with mine tailing: Industry > IREL KMML Period of mining 2001-10 20tl-19 2001-10 20lt-19 activity M:Quanaity of mine
tailing generated 7 48s02.27 8t6934.72 1211263.90 133s791.78 (Tonnes) Q:Index of land reserve's relative 2.0 2.0 2.0 2.0 value CF (SW): Damage to be caused by a tonne 99 99 99 99 of mine tailing (Rs.)
Damage to be caused by land reserve destrustion/ pollution 148203449.46 161753074.56 239830252.2 264486772.44 D(GS):QxMxCF (14.82 Cr) (16.18 Cr) (23.98 Cr) (26.45 Cr) (SUD for the period from 200I-2019
Damage to be caused to the surrounding environment because of the deterioration of the land surface with mine tailing and associated activities of IWs. IREL during the period 2001-2019:148203449.46 + 161753074.56 = Rs. 309956524.02 (30.995 Cr)
Damage to be caused to the surrounding environment because of the deterioration of the land surface with mine tailing and associated activities of lWs. KMML during the period 2001 -2019 :239830252.2 + 264486772.44: Rs. 5043f 7024.64 (50.43 Cr)
Other subsequent ecological cost arising from the land destructed by the specific activity can be assessed separately and added to the value obtained from the above equation for land deterioration/ destruction.
RADHAKRISHNAN SINDHU Engineer i ,rri;,ir;,!ii oFitu ci;"f Environmental iiI!ti i .-i-' ri i.::,r;j \..\, *-"."r f i'i ,' 3J.2 Cost of land/ beach lost due to beach mining lvf/s IREL was engagpd in btrh mining activities in two locatims, NK block IV (Vellmdurth) ild NK bbck tr (Ner Koviffiottm). i[/s KMML was c€nying ort beach mining in beac,h scctions in the NK block Itr (North & South of Kattil Mekkdlil Temple).
Photograph : KafrilMehfothil Temple Ponmana
The extent of beach arca lost/ affected by unzustainable beach mining by IREL and KMML is take,n from Google earth gtellite historic data with respect to the 2000 shoreline determined by NCESS in their April, 2019 report. The exte,nt of beach mining was determined by the geomorphologic changes observed in the Google earth historic satellite imagerl'over a period from 2003 to 2019. Accordingly, argas of 29047.8 and 105924.66 # were affected due to beach mining activities of IREL near Kovilthottam (NK block tr) and Vellanathuruth (NK block IV) respectively. The areas affected by beach mining by KMML were 180481.87 and 58304.31 mzat north and south of KattilMekil D HAKR!-S H A|l s I N D H U RA l'l ;hi.f Environmental Engineqr Beach area alfected due to mining acttvities by IREL (NK Block II) Beach area atfected due to mining activities by IREL (NK Block IV) No. I IREL 29047.8 m" (NI< block ID 134972.5 m" Rs. 66633204.05 r0ss24.66 # 0[K block IV) (6.66 Cr) 2 KMML 180481 .87 m'CNK block III) 238786.18 m' Rs. 1 17883961.34 58304.31 (l l.7e Cr) # t # Fair price of land Rs 49368/ Ares (100 m") vSINDHU RADHAKRISHNANgineqr En Ghief enuiilntental Beach area afficted due to mining activities by KMML (NK Bbck III -Ponmano, North of Kafril umple) Beach area alfectd due to mining aaivilies by BMML (NK Block III - Ponmona" South of Kafril tsmple) 3.2.3 Land plot damage Land plot danoge is.calculated on occount of dqrived or lost opporfrrnilics to utilizc the lnnd tor other purposes, if il was not damnged lt ne unsustainable mining activitics The nalrow coastal strip of land in question can be utilized for recreational purposes, fishing activities, cultivation of coconut trees and other purposes had it been not used for mining activities. These various other land use options are referred as 'lost opportunities" and all these deprived uses of land come with their respective value/ cost. srNDHu RADHAITLtj*II Area affec"ted dne to mining activities by IREL wtth rryect to lost coconut cultivolion Area alfected due to mining activities by KMML with rryM to tost coconut caltivation The Alappad and adjoining Panmsla is a narrow strip of land sandwiched between Arabian sea and inland.estuary (T S canal) which is rich with black sand deposits. This unique 22 Km long coastal land mass is one of the kinds ig Kerala with coastal waters, backwaters and sandy beaches with chmacteristic sand dunes. Alappad is a uniciue coastal ecosystem on a sand bar rich in heavy mineral deposits (approx. 50 - 200 m wdth) and just 0.5 to l.5m above mean sea level. This make the village vulnerable to slightest of perturbatlqqs caused either by natural or mthopogenic factors. Heavy qtNNHU RADHAKRISHNAN minerals, coconut palrns and fisheries are the major natural resources of the rea. The :rea was bordered by sandy beaches with sand dunes in the past and at present most of the shoreline is bordered with seawall along the entire stretch, except in the beach mining sites. Scattered mangrove patches are there at the eastern side of the land mass along the backwater. The entire coastline of Alappad falls in a well-defined sediment cell extending from the Kayamkulam breakwater in the north to Neendakkare inlet in the south. The area is dotted with several temples and many are in the leased mining sites. The area was severely affegted by the infamous tsunami of 200 4 and extensive damages were reported in the area. The lost opportunities or the deprived uses of this coastal strip of land due to unsustainable beach mining are the following: 3.2.3.1 Agricultu re: gain from coconut cultivation The sandy coastal area supports luxurious growth of coconut palms and is evident from the Google earth satellite imagery of 2003. Due to intensive mining activities, the coconut pahns were destroyed over a period of time. The economic loss from the vanished coconut tree cover in this coastal area has to be assessed. However, there are no baseline data on the extent of coconut cultivation and the yield in this locality. Therefore, the economic gain from these coastal coconut grooves has to be calculated by the theoretical yield per unit land. Normally,IT5 to 400 trees are grown in a hectare of land and around 75 nuts per tree is the average yield from a single tree. In this scenario, it is assumed to be a non-intensive cultivation of coconut palms in the area with 110 trees per hectare with annual yield of 50 nuts. Thus the average gain from coconut patms in one hectare (10000 m2; of coastal land is Rs.44000i year if the fair price of coconut is Rs 8/-. The other resources derived from the coconut tree like biomass, coir and timber is assumed to be around 5 Yo ofthe annual gain and hence, the total unit gain per hectare is Rs. 462001- per year. Damages caused to the land that had been previously utilized for recreationaV agriculturaV or any other 'lost opportunities'is: D(LP):A(LT+c) D(LP) Damage caused to the land that had been previously utilized for recreational/ agriculturaV or any other 'lost opportunities'(Rs). " A Area affected by direct impact (-') LT Average ta:< on land paid to the Govt. per unit land (Rs / 100 m5 G Cost of the lost opportunities (to be gained from recreationaU agriculturall or any other activities) from unit land (Rs.i year) ,z Particulars IREL KMML Period/ duration of mining activity 2001-t0 | 20tt-r9 2001-10 | zot l-19 A: Area affected by direct impact (*1 977 47 .33 2883s7 .4 LT : Average tax on land paid to the Govt. Rs.1/ Are (l Are: 100 mrl year per unit land (Rs./ 100 m2) Rs. 100i 10000 m' lyear G : Cost of the lost opportunities (to be gained from coconut plantation) from unit Rs.46200/ 10000 tf I veau: land D(LP):A(LT+c) Damage caused to the land that had been 452570.1 1335094.76 previously utrlaed for agricultural (Coconut palms) (Rs/ year). Total damages (Rs) for the period 2001-19 8598831.9 25366900.49 (19 years) (0.86 Cr) (2.54 Cr) 3.2.3.2 RecreationaU cultural cost: The unique coastal morphology of a narrow strip of land sandwiched between sea and estuary is an important factor which enhances the tourism potential and associated recreational activities. Industrial activities like mining and associated operations in contrary will affect the recreational value of such places. Therefore, the areaaffected by the rnining attracts environmental cost with respect to the lost recreational potential. Bequest and existence values have to be taken into account while calculating the cost of lost recreational opportunities. However, in practice, it is very difficult to assign monetary values for such concepts and usually travel cost method (TCM) or willingness to pay (VffP) approaches are used to determine the value lost recreational opportunities. Similar is the case of culturaV spiritual values as the areas have more temples and cultural centers. Due to intensive mining activities, the aesthetic attributes ffie compromised and recreational potential has been destroyed over a period of time. Due to the mining activities, temples were isolated and cultural centers were abandoned, resulting in the deprivation of cultural values. However, the approaches like TCM and WTP requires comprehensive studies and scientific surveys over a period of time covering various sections of the society across all income groups. Such studies are exhaustive, requires time and resources1o get utilizable data for such monetary valuations. In this scenario, on interacting with a small to be assumed with the extent of willingness to pay expressed by the local people to enjoy the natural and cultural landscape of the locality, had it been preserved properly. Recreational valae assigned by local populalion Recreation value is a bequest/ existence value and it is hard to fetch price for such entities. It is assumed that, l0% of the local people population is willing to payRs. 20l person to enjoy the aesthetic value of coastal region with beaches and lush green cover of coconut trees for 120 days ur a year. Therefore l0%o of population (5066 people) visiting the beaches for 120 dayp in year spending Rs.2Olperson: Rs.'121584001- (1.21 Cr) per year. Recreational valae assigned by oatstotion people If same number of people (5066) comes from outstation localities for 30 days in a year spending on an average of Rs. 100i- per person, then the approximate recreational value placed on the area by outstation people is Rs. 15198000/- (1 .52 Cr)per year. Cultural value ossigned hy the local population rc% of population (5066 people) visiting the temple and cultural centers for 96 days in a year spending Rs. 10/ person: Rs. 4863360/- (0.4s cr) per year. Total cost of lost opporhrnities on account of recreational and culfural purposes is: 1 2 1 58400+1 5 I 98000+ 4863360 : Rs. 322197 60/- per year. Therefore the above cost projected for 2001-19 (19 yean) :612175440 (61.22 Cr\ The above cost may be divided equally among IREL and KMML, which is Rs. 306;A87720.00 (30.61 Cr). 3.2.4 Damage due to unsustainable extraction of minerals In case of illegaU unsustainable extraction operations, the total amount of damage shall be calculated by below formula: D(tE):QxP+RE D(rE) Extent of damage to be caused by lllegall unsusfainable extraction of mineral resources (Rs). 4 a Volume of illegally extracted mineral resources Gvil) P Market rate or price of mineral resources (Rs.) RE Expenses on restoration measures (Rs.) N ln the April, 2019 report submitted by NCESS, it is clearly pointed out that both IREL and KMML have not adhered to the sustainable mining quantities already recommended by NCESS in previous study reports of 2012 & 2013. It is also maintained that the unsustainable mining extraction beyond the recommended quantity resulted in severe erosion of beach and coastal stretches. Had the industries, exercised caution while mining, the present situation of loss of beach could be prevented. In the report, NCESS has calculated the excess quantity mined by both industries which is 50 o/o more than the recommended limits during 20I0-I9. The value of minerals extracted over the recommended quantity has to be recovered from the defaulting industries. The base price of minerals extracted shall be used to calculate the damage. Though, black sand is rich in seven heavy minerals (ilmenite, leucoxene, rutile, zncon, sillimanite, garnet and monazite),lion share of production is through ilmenite. Hence, base price of ilmenite is used to calculate the damages due to lllegaU unsustainable extraction of minerals. For the purpose of calculation, the heavy metal content (%) of the mined beach sand is taken as 54.47 E 30.52 for IREL for 2001-10 & 20II-I9 periods respectively. For KMML the heavy metal content taken are 23 & 24.91 o/o for 200 l - 10 and 201 1- 19 respectively. As per the Indian Minerals Yearbooks 2011,2017& 2018 (Part [II: Minerals review), prepared by Indian Bureau of Mines, Ministry of Mines, Govt. of India; IREL produced Quilon (Q) grade Ilmenite prices from the period 2008-17, varies from 3775 to 6000/T (2003-11) andl700 to 222501T (2011-i+1. The price range was Rs. 5850 to 151201 T during 2015-17. Therefor the ilmenite price of IREL varied from Rs. 1700 to 22250 during the period20l3-I7 . The average price calculated for ilmenite produced by IREL during 2008-17 is Rs 10390.56/ T. KMML produced ihnenite price for the above period is limited for 2008- 09,20lI-I2 and 2012-13 as per the Indian Minerals Yembook 2017 & 2018. The average price based on the prices during the above period is Rs.15275l tonne. SINDHU RADHAKRISHNAN Chief Environmental Engineer Period of mining 2001-2010 2011-2019 activity Industry IREL KMML IREL KMML Mined quantity ( 9r3326 873997* 653219 988297 m3) Sustainable mining limit recommended by 7s000 7s000 48600 7 4500 NCESS (-' I year) Excess quantity 3r7797 238326 273997 215819 mined/ extracted (s72030 (42893e.13 MT) (493139.8 MT) (388471 MT) (-') MT) Heavy metal Yo 54.47 23.0 30.52 24.91 a _ Mineral content in the 233643.r3 113422.r5 118561.3 142492.6 excess quantity mined MT P : Avg. price of 10390.s6 1527 5 mineral resources 4306.7 5 4306.7 5 (Rs./ MT) Extent of damage to be caused by unsustainable extraction of 1006242550. I 3 488480629.r8 r23r9r 8301.33 2r76574465 mineral resources (100.60 Cr) (a8.85 Cr) (r23.19 Cr) (2r7.66 Cr) (Value of excess mining) (Rs) D(IE)-QxP RE : Expenses on restoration To be assessed separately measures (Rs.) * KMML has not given mining quantityfor 2001-02 Value bf excess extraction of minerals for IREL: Rs 1006242550.13 + 1231918301.33 = 2238160851.46 (223.82 Cr) Value of excess extraction of minerals for KMML: Rs 488480629.18 + 2176574465.00 = 2665055094.18 Q66.51 Cr) Jaaq N 4.0 Total interim environmental damages No. Damage components IREL KMML I Damages caused by land reserve 309956524.02 5043r7024.64 destruction (Tailing) (30.995 Cr) (50.43 Cr) 2 Cost of land affected bv 66633204.10 117883961.30 unsustainable beach mining. (6.66 Cr) (11.79 Cr) a J Damage caused to the land that 8598831.90 25335360.60 had been previously utilized'for (0.86 Cr) Q.Sa Cr) Coconut cultivation 4 Total cost of lost opportunities 306087720.00 306087720.00 on account of recreational and (30.61 Cr) (30.61 Cr) cultural purposes (2001- 19) Total Environmental damage 69,12,76,280 95,36r24,067 (l+2+3+4) (69.12 Cr) (95.36Cr) 5 Value of excess extraction of t006242550.13 488480629.18 mineral resources (200 1 -20 1 0) (100.62 Cr) (48.85 Cr) 6 Value of excess extraction of 1231918301.33 217 657 4465.00 mineral resources (20 I | -2019) (123.19 Cr) (217.66 Cr) Total value of excess mining 223r81,60,851 266r50r55r094 (s+6) (223.81 Cr) (266.51 Cr) Summary of damage assessment a) Interim damage assessment and compensation for temporary restoration activities calculatedfor IRELfor'the period 2001-19 is 1ts.69,12,76,280 (69.12 Cr and the total value of excess mining 223,81,60,851 (223.81Cr) b) Interim damage assessment and compensation for temporary restoration activities calculated for KMML for the period 2001-19 l's Rs. 951361241067 (95.36 Cr) and the total value of excess mining is 266,50,55,094 (266.51 Cr) 4.1 Long term restoration plan and assessment of ecological services Damages with respect to lost beach front have to be levied from the defaulters in the form of actual restoration expenses. The restoration plan hdS to be made after consulting with environmental & domain experts. Since, this process is an in-depth study demanding resources and time; this has to be taken up separately. Along with this the on account of deprived ecologicale services offered by beach if it had not been ,r,'/:{*r7:' ' }Z-'tl H PA I(P.I3H}IAN H u RAD l)-J :"; ;i n." t "{fro Enginee' Cnint Environrnental disturbed by mining activities (services like natural coastal protection, primary productivity, services of coastal wetland, etc.) has to be taken up and assessed. 5.0 Finding and Suggestions A. Environmental damages assessed by the joint committee may be recovered from the defaulting industries with suitable modification in assessment if required and may be utilized for making a restoration plan and its implementation. B. The State Board opines that the value of excess minerals extracted even though comes under environmental damage has already been accrued to the public as both companies are fully owned by Government. Hence the committee leaves open the question of whetherthe amount is to be recovered as damages. C. The above assessment is not including the deprived ecological services of the land I beach existed previously in the mining areas. The biggest hurdle in such damage assessment studies is the lack of proper baseline datato compare with the present scenario. In this scenario also, the baseline conditions/ data collection was the most difficult part.Hence, it is suggested that, provisions may be made to compile all relevant baseline datal conditions at the proposal stage of all projects. This aspect should be included in the EIA/ EMP report, EC, etc., so that it can be readily referred' in case of future environmental damages due to that project. D. The quantity of tailing sand available in stockpiles need to be surveyed and estimated. The tailing sand must be used immediately for restoration of eroded beaches. It is expected that the available sand is not sufficient for restoring the entire atea lost. The companies must submit mine closure plans specifying the method of restoration of sandy beaches. E. It is unlikely that beach mining can be conducted without erosion. The beaches in this area are subject to seasonal erosion and acpretion. Assuming the mean shoreline position is steady in the absence of mining, it is clear that the net removal of heavy minerals would cause erosion. Therefore it is necessary to find alternatives for recovery of valuable minerals without damaging the beaches.The companies must submit mining plans for offshore dredge mining and use of silica sand tailings therefrom for complete restoratiopof beaches. F. Mining using mobile gravity separator in the shoreline also may be explored. The present mining practices are totally unsr$ainable and should be discontinued till other zustainable and viable options are made to tap the mineral resources. G. Offshore mining by suction dredging already being done by IREL at OSCOM Odisha shall be implemented in the mining fields of IREL & KMML in Kerala. The mineral budgeting ptudies done by AMD, points out ,good deposits of minerals extending up to 1 Km in the sea. Possibility of offshore mining shall be explored and beach mining may be stopped till the restoration projects are completed. H. Inland mining may be, allowed only with dredge wet concentration (DWC) method, where the tailing will be deposited in the pit simultaneously with mining. This will reduce the unscientific disposal of tailing and will have some accountability on the sand tailing. I. Since, it was opined by many experts that offshore mining by suction dredging and mobile gravity separator will not be viable for short stretches of beaches, the industries may be allowed to explore engaging a common facility for offshore mining. In order to facilitate offshore mining, a window of two years may be given to stop all existing mining practices and completely shift to offshore mining. J. Comparing to other beach mining sites in Tamil Nadu, the beach erosion is at a higher magnitude at Alappad & Panmana due to its unique geographical location. If the mining continues unabated, the inland waterways bordering the mining sites will merge with the sea and subsequent after effects may have far reaching effects on the ecology of the area. :mH'*:llirl':$H) Dr Deepesh V Smt. Sindhu Radhalffishnan Scientist B Chief Environmental Engineer Contral Pollution Control Board, Kerala StatdPollution Control Board, Regional Directorate, Bengaluru BEFORE THE HONOURABLE NATIONAL GREEN TRIBUNAL PRINCIPAL BENCH, NEW DELHI Original Application no. 76/2OLg State of Kerala & Others Respondent(s) VERIFICATION We, Sindhu Radhakrishnan, aged 50 years, D/o Sri. R. Radhakrishnan Nair, Chief Environmental Engineer, Kerala State Pollution Control Board, Regional Office, Thiruvananthapuraln, and Dr. Deepesh V, aged 42 years, S/o Valsan VelacherY, Scientist B, Central Pollution Control Board, Regional Directorate, Bengaluru, do hereby verify on this the 2"d day of November 2019, that all what is stated above are true and correct to the best of our knowledge, information and belief. Dr. Deepesh V., Smt. Sindhu nadnarcf$?lan Scientist B Chief Environmental Engineer Central Pollution Conffol Board. Kerala State Pollution Confrol Board, tu r Court l{o' I l Item No. O6 : BEFORE THE NATIONAL GREEN TRIBI'XAL PRINCIPAL BENCH, NEW DELIII Original APPlication No'7 6 I 2Ol9 Authored bY Vishnu Varma News item published in "Indian Express" Titled of impact of sand mining" " !7 -year-old's video gets Keralatalking f hearing: 19.O7 .2019 HOIT'BLE MR' WSTICE ADARSH IN'UAR son:sup uR. Jusrrcg 1'P: y-lr-{9Pi: ;difi; rm- .rgstrcE K. RAuArGrsIrNArr' MEMBER ExPERT uEllBER noi'ir,p DR. nAcrr IIATDA' ..= 'F'r,. -::-' For Applicant(s): NONE t I ForRespondent(s):Mr.NisheRajenSh.onker,AdvocateforKerala.:t;r ' Mr..lory S"^tia, Advocate for KSF€B +i :'' *l :tf ''' _:ta-.# {t"- .. --1-r'n- been furnishecl vide e-mail dated 2. AccordinglY, such a rePort has in the report 17,O7,2OI9, though the rePort is of Aprit 2}Ig'Findings are as follows: 7"r;;;;[5':;$i]', -,,,9i Etrvirorrrn "7. Cortctuslons and Recommendatlons: A preliminary study on the eroston along the Neendakara- Kayantkula.m coo,stal stretch and the contributton of bea"ch sand extraction on the extent of uulnerability was caried out during February-March 2019. The present stud!/, euen though carried out within a short period has uttlised olt the releuant data needed for assessing the present status / stability of the coast. The field data collected as part'of this study along with the qrchiued data with cEssA/cESS and otLter secondary data collected from uarious sources haue been synthesized and integrated to haue q. comprehensiue understanding of the present state. The salient conclusfons are Q"s below: \ The bng-term shoreline changes computed from the aerial photograph/ satellite imageries for.Tthe period lg68i0l9 shou,rs severe'' erosion of the mining sites of IREL qnd KMML. The shoreline retreats are to the extent of a25 m,382 m and. 142 m respectiuelg at vellanathuruthu (IREL mintng stte), Ponmana (KMML mtning site) and Kouilthottam (IREL mintng site). During the period of 2000-2019 the shoretine has receded bg 243 m,227 m and 57 m respectiuely at V ellanathurutLtu, P o nmqn a and K o u iltho tt am mining s lte s. Crltlcal exqmlnatlon of the shlft ln nearshore depth contours durlng the 79gear period of 2OOO to 2079 utiltstng bathgrnetric charts prepared bg CESSAfC^ESS ln"zOOO, 2OlO q.nd. 2079 has reuealed that there has been a shoreward shlft {n lsobo'ths particularlg the shqllow water lsobaths of 2-7O m- The extent of deepening of the neq'rshore qreq.s is more pronounced off Ponmana and. Vellanqthuntthu tndicc,tir';g severe erosion ln the neq.rshore oreo's. pentsal of the mlnlng do;ta provlded bg the two public $ sector companles M/s, IREL and. I{,MML conclusluelg shout that the mlnlng uolumes durlng the last two decad.es utz-2OOO -2O7O and 2O1O -2079 haue been cotr.std,erablg hlgher tho,n the sustainable minlng guantltg recommended bg CESS/VCESS. The seuere erosion fs o.ttrlbuted to the unsusta inable mlnlng practlces that haue been golng on along thds coa.st-" (emphasis added) 3. Thus, the report shows that mining volurnes have far exceeded the sustainable mining quantitF ProPosed. The excess quantity is noted as follosrs: .T6{b& 71 Excess ryantiQ mined w IREI, an4 KMML during the period' of 2OOI-201O and 2OIO-2O19 FSUs Iftning, Auerage minin4 Permisszble Excess quanedes for 9 guanfuU q:uo;ility quanfiry ge s (nf) WVear) (n&/ gear) minad for I ueans lmx) 2001-2010 KMML *8.73.997 *r"o9.254 1,5A,O00 4r 5,46.573 mg (9,83,824 IREL ,i+i*..:+ 9.13.326 LO1.48r p,6*w MT) Bhl 17.87.323 t,98.59t MT) 20rc-zo19 rwrtL 9,98,297 1,a9,81tr m? ffi . llF,'; 19 me 6,53,219 *4 ;6 m.s a'.t: 1,9t,391 ..:r :,,i:ijjrr-j::_::lj . r|n 1CI6,0 m cnd ISM m n?yj etd,2012) 4. In view of absve, $re constitute a joint Committee with representatives fronn the Central Pollution Control Board (CPCB) and the State p,ollution control. Board. tsP€Bl to determine the arnount of compen'Eation to be rccovettd for darrage to the environment by r,rnsu$tainable illegal mining. Such a report may be furnished within twornonth$bye.mailatir+ciciql-nght+€;or'.irl.Itisopentothe conc€rfled regulatory authorities to recover the comPensation by foltowing due Procedure of law. P{<> RESIr,NAT OFNCE /9 A copl, of this order be sent the CPCB and the sPcB by e-mail for "o compliance. List for further consideradon on 16' t2 '2OI9 ' Adarsh Kumar Goel' CP S.P. Wangdi, JM K. Rarnakrishnan, JIvl : .':. ' :,:. Dr. Nagin Nanda, Elt{ ''Iul1' 19' 2019 Original APPlication No .7 6 I 2OI9 .,1, DV f l- ' atq' MINUTES OF TIil MEETING CONDUCTED ON 13/08/2019 N''[ .CENNBCTTON WTTU IUN rcSUBS NBLAIBN TO NEACH MINING'IN TIIE C Meeting started at Z.Lo pm. Chairman presided over the meeting. Member the meeting. Secretary was also present. The following offrcers attended t) Dr. L, SheelaNaii' ''' : - ' S'c. F& GrouP Head, NCESS Co & : Group ," 2) R. V. Viswanath , : - General Manager (TS), IRBt ' Chavara :. \' General Manager & Hea4 Chavara" , i 3) Sri. S. SurYa Kumar '.t,: IREL director :' 4) S'ri. T. S., Shaji Assistant Managing Survey of India ,, 5) Dr.'Mathew:JosePh. Diiector, Geological 6) Sri: Baiju Sebastian Senior'Geologist, Minin g & Geology DePartment 7) Dr. J. Ansari CSIR - NIIST, ThiruvananthaPuram 8) Sri. S. Anil Kumar Superintending Engineer, Harbour Engineering D ePzrtlrant, ,, - ThiruvananthaPursrrl , ,'. ; . ' ri : General Manager, 9) 'Sri. V. AjaYakrishnan $I\4[t{. , 10) Sri. S. Karthikeyan Assistant General Manager, Mines 11) P. K. Baburajan Chief Environmental Engineer, Head Offi ce, ThinrvananthaPuram- LZ) 'SrL M. P. ThrideeP Kumar Environmental Engineer, Head Office, ThinrvananthaPuram. 13) Smt. Simi. P Environmental Engineer, District Office, Kollam. 14) Smt. Saritha. R Assistant Environmental Engineer, Head Office, ThiruvananthaPuram. .i,\ -\- A!- ilificl j ;-;i i i: j ?,}.e,u"$l:$$5':$'::" a( t:.- =Jzlv!')..-tvv-- introduce and requested everyone to welcomed all the officers Chairman the was convened for discussing informed that the meeting themselves' Chairman issuesrelatedtobeachminingandtofuIdasolutionfortheissues.Hesaidthatthe mineralresourceshavetob".""ou",.dwithoutcausingenvironmentaldamage' out ttre above in a practic:'i be promoted How to carry Cffshcre mining has to meeting way is the intention of this qf Atomic Energy Minerals Division' Departrnent Sri: T' S' Shaji' Atomic Chalara reei11 navtne a mineraldeposits in that area' explained the details' of l from Neendakara to Kayamkulan' deposit nr aZZ'S km stretch . major'mineral m'upto low iron content tom ttl contpnt is more thxt 629/oand lo.Z00 Titanium is 10 % and east' heavy mineral potential Frorn T' S' Canal to 1 km T. S Canal, Kerala deposit * it is 6 ; i1''5o/o'':sedimentation upto 6 km, : ]:l: ]::- in 8 together carrying out mining Ltd & Indian Rare Earth Ltd' Minerals & Metals 7'5 - deposit in the offshore is holding lease. The mineral blocks, for that ttrey are 9m dePth in that area' d lhe beadt accrdion rde ofmireals one cordrcted $dy on cbainnar a.sked wbeftrer any tffH Dr. L sheeraNar, c'"w r'1 c*T:)T:P:if-ff fte'' peno ffi ary gdf' rcgarding tfs 'Ert during ' as$ad*pt'ru*'ryt*"*tit "ati'eOm3linneacfrwastring:**.Tl""*Cltairra admodel o$ conduoed ' 700 rn The deuras colleeEdlt*a*Unpnofle $ldyisnotsoreliable" opinedtr*fu decoltededtasedonrnodel rate when sea wall is happened to the accretion Chairman then asked what ' Sea wall is nqt help the beach building' :constructed. She replied that sea wall will will not take place in to sea wall mineral deposition t for protecting the land' Due thatareaandthedepositionwillbetakenelsewherewheretheseawallends. to be submitted before Secretary that the sime has chakman informed the Member the Hon'ble NGT' the Mining & Geology DePt' exPlained Shri- Brju Sebastain, Sr'Geologis! of tand for sand has exPlored 347 50 hectares following; i+tr4in"rai Division N -J_- c rNi. i er 550 hectares has grven for lease. .mining for mineral extraction. Out of which mining- KMML has one lease and IREL has 4 lease. KMML does not hold EC for IREL is having EC for one or two blocks. For conducting sand mining, a Mining plan has to,be submitted by the project proponent and approved by Indian Bureau of ${lnes (IBM). In that Mining Plan all do's and donots are clearly mentioned. If : the project proponent conduct mining as per the Act, Rules, Mining Plan, EC, there will not,arise any problem r.elated to the same. For example, in Mining Plan, piovision is ,given 'for using shovel and cq-_1yine out hand mining. But these , be restricjed. companies are using'nrachineries for mining. Bgach washing fhould tnland mining shlt,be promoted,,For the same they have to purchase land and after recovering the minerals, reject sand can be put back. ' , ' :IREL explained that,the,mineral part separated during beach, washing only .l,O-IZoh,. May be Z0 or 30 years back the concentration was,higher. But, after Tsunami taken place, the percentage getting from beach washing is only IU-I2a/o-' IREL has conducted a study on this through NCESS- Ancl at present beach is not there, 500 m already gone as per study report. KMML offrcials explained that their intention is to recover the natural resources fbr the sake of nation's wealth. They will not ever go against the law. For , getting EC, ,I(il41\4L :has; :doner everything. Submitted application for the same .before the MoEF, State PCts has conducted public hearing :ul''20l7 and all the people supported the project. CSIR - NtrST is our consultant. Chairman pointed out that KMML has already conducted beach mining to a large exfent. Erosion took pl'ace due to that mining.,It, is a fac1, Then KMML said that mining alone is not,the reason' for erosion of beach of that area. On the southern side of Kollam also beach eroded. is the construction of the lateral transport of AKR1SHNAN *-t'uf Engineer *--r"-ul^^re E are putting back sand " Chainnan asked KMML officials that whether they practically and technically it is not after separation of minerals. They replied that Chainnan questioned feasible tg put back the sand after mineral separation. and asked the same to all the whether any technical authority advised on the matter advise on the same' officers present. All replied that.they have not given any that in Dr. Mathew Joseph, Director, Geological Sunrey of India informed unit for beach East African countries, they are using a mobile gravity separation the beach- The unit sand. mining depositing reject sand back for renourishing redeposition of healy travels from south to north for a 500 m in one direction. The be ca:ried out without minerals, taken place before to next transit. Mining can the Director to disturbing the enviionment of the beach. Chainnan requested provide the details to the Board for issuing necessary directiolls- : ' '' ' ) everywhere Sr. Geologist opined that in India it is not easy to allow mrning fl and issued lease as in that cor:ntry because we are following some Rules and Acts is for mining. Chairman explained that that issues have to be sorted out as it ultimately for the land welfare and for decreasing the environmental damage' is onlY 700 m All opined that long stretches could not be mined as there '- avarlable for mining- report Dr. J. Ansari", Senior, soientist, NIIST" infonned that ,in tr.,EIA But there submiued for EC, it is agreed that the remaining sand shall be put back. is no condition being insisted in the EC regarding this' Sr. Geologist informed'that for carrying out mining, first prepare a mining plan, afteri that EIA report is submitted, then based on EIA report'Ec is being given. In that EC there is condition that mining has to be carried out as per the Mining plan. Mining Plan is not a static one and it can be changed as per EIA and got re approved from the concerned authorities. Chairman asked Dr. Ansari whether the Mining plan has been amended in the based on the EIA ther issues noticed during EtA are reflected / i,"r',1". -q'- D{g ti r,- I !i '-l'i .,..,. l r:,'.r ii I il .:,1 i r,i i'i'ri,;ll!'i'::L l''iiiIJiiii'i i ;= li ilii ; ''|': "' ' =';i SINDHU RADHAKRIS'III 4rlt-g"^.rAt 9 Mining plan, i.e., whether modified Mining plan has submitted for EC. Ih. Ansili replied that it has not come to his notice till date. Chairman informed this matter will be taken up by the Board and will inform the concerned authorities. Qhainnan questioneid whether instead of beach mining, the explore the possibilities'of offlshore mining. Sr. geologist e4plained that offshore mining has to be, carried out: as per the Offshore Mineial Development and : Regulation Act, 2,002. The license is being issued by the Government'of India. :,issued Earliei licenses were to explore 65 blocks. Later Government of India cancelled the licenses and ordered henceforttu 'i, ,ho,rld be dorr" as per aiiction. Amendment on the same also not yet come. Cases related to this are pending before the Honlble Court. So at present exploring offshore mining is not possible. Chairman said.that for the time being legal aspects of the suune- it may be brought to the notice of the Hon'ble NGT ana will be sorted out. But the technical aspects and other related issues have to be taken up. GSI official replied that they have conducted a feasibility study of seabed and identified 21 blocks in different seotors like Chavara sector, Varkals sector etc , and that.is,having 125 rrnLlion,tonnes/ meter of heavy minerals. At present study :conducted at'1 ,m.depth,seabed. The sea depth,(bathymetry) is 10 m but can go upto 60 m depth and can go up to 1 km away from seashore. Started working near the seashore also. 18 % heavy minerals is present in these deposits. Dredging cost will be economical. tsut Govemment of India has to grve permission. Chairman : .asked the quantity of heavy mineral deposit available in Chavara area. GSI official replied that in whole Kerala it is g.5 million tons and in Varkala and Chavara region it is 3 million tons. IREL official informed that on the 7ft of July z}Ig,Government of India has published a notification that the Central Governnent hereby prohibits grant of operating rights with respect of the atomic minerals near the offshore area in the country including 62 blocks to any person except Govt or Govt Public limited -5_ t'^-,-,"ntal srND(;RADHIT5P*yISlNUnu Enginee.r Chief Environr *r*xuAr T land considered as the extension of the gompanies. offshore deposits wil be be issued by Kerala Govt' sr' Geologist deposit. Leases for offshore mining can by IBM. chairman asked IREL to provide informed that the lease is being given the details. officials- Provided chairman srrught one more clarification from why not use reject sand aft:t_:**ating perrr,rission is granted f9r offshoie mining, pointed tnethe beachesDeacnes destroyedos by mining? He the I 8 % hearry minerals,, to rebtrildrebtntcl to explore the possibility of the same- out, that all official have , for the delay,in issue of ,chair,rnan then asked Dr- Ansari what is the reason was notised and 'so the EC to KMIW;. Dr.. Ansari . replied that a 'violation .Sideredbytheviolationcommittee. application has to be csnsrdereo Dy rn( Hon'ble NGT has ordered -chairman inf,ormed that in several cases, the It is calculated to be higber leving Enviionnrental compensation,for violations' damage' than profits made by causing environmental the public protest is mainly due smt. simi, EE, DO, Kollam informed that returning the land to the public that was to the reason that the companies are not that the retun:lng of land etc is not takei:i &i.rm them for rease. chairrnan replied NGT .is whether environmental damage relevant..,The,matter,beforel,the,,Hon'ble ocourred and thatwilt be Board's conoern. suitable plans for sea bed area chainnan concluded with advice on making should take the said mining, ffid re-building beaches eroded' Both companies ' matters very seriously to avoid penalties. The meeting comes to an end at 3'00 pm' l'f lP'|J-' -e- 4trnornr^- JE md -l 047Glffi70L-5 Phone j |REL (tNDtA) LIM|TED s-+€ (Formerly Indian Rare Earths Limited) Fax )] o476-2680141 (eTrTd {T{mr{ Eh'I SGEF-JI / A Gov,t. of tndia Undertaking) 5+d I [email protected] qE{T, Email J *ttrfr - 691 593, +Tf, {T3il[, e{r{d i{sr{c Chavara, Kollam 691 583, Kerala I www.irel.co.in - State, INDIA website J Cf N : U15100MH1950cOt008187 lso 9001 :2015, lso 1400 r:2o1,5 & OHSAS 18001 :2oo7 companv 32,1 1 / CH/MNG/PCB 12019 26.09.2019 The Chief Environmental Engineer, ,, Kerala State Pollution Control Board, Regional Office, Thiruvanathapu ram Sub: Submission of data regarding the beach mining Ref. email OA No 7612019 dated 16.09.19. Sir / Madam, We hereby enclose our reply for the details sought regarding the beach rnining, vide your e-mail referred above, for your kind perusal. Thanking you, Yours faithfully For IREL (lndia) Limited, Chavara Unit wl 7try) Chief General Manager & Hea'd qATv qrqfdzr:"dr? qrat a /207, fi antqr W i qta vsnAq gr€ - 4oo o2B Regd. office: Plot No.1207, veer savarkar Marg, p Near siddhivinayak Temple, - 400 028. 0 1. the beach mining for the Past 20 Years The quantity of raw sand collected from sand and the heavy mineral content in the from Vellanathuruthu - Ponmana area are as follows: Quantity mined HM% 91443 80.2 141444 78.5 79.6 2001-02 74.0 2002-03 145928 65.4 9561 1 57.1 157 494 54.3 43.9 2006-07 8034 67676 54.4 250021 34.4 27 1 2009-1 0 206395 30.7 2010-11 221024 1 08205 33.0 2011-12 266 2012-13 117349 26.0 2013-14 90026 33.8 2014-15 47 120 2015-16 0 33.0 2016-17 1 3938 2017 -18 0 2018-19 0 area is transported and fed to The beach washings collected from the Vellanathuruthu (which is located at a distance of 18 km) the Minerar separation prant at rREL, chavara other lease hold areas for recovery of heavy along with the raw sand collected from for the quantity of heavy minerals recovered minerals, hence no separate data available from the beach washings' plant which coi-rtains tailing sand from all The waste sand from the Mineral separation pran approved by AMD, Hyderabad & IBM' the areas has been used, as per the Mining plant to out pits. In 2014 a mini separation Bengaruru, for the recrarnation of the mined q area was set up ild # upgrade the mineral sand collected from the vellanathuruthu plant has been usiru br that the tailing sand generated from the mini separation refilling the ihined out pits at Vellanathuruthu itself' washing since zJ14 and Approximate quantity of tailing sand generated from beach is tabulated below: utilized for refilling in mined out pit'in Vellanathuruthu Year Tailing sand generated from the beach washing (approx) in tones 2013-14 45000 2014-15 23000 of beach 2015-16 No collection washings 2016-17 6000 of beach 2017-18 -No collection washings of beach 2018-19 No collection washings - 2. proPosed to be mined. : Map attached 3. Copy of the agreement attached 4. IREL has not conducted any health studies -il \r- E frrclon i n, orncr i F a 5. Reports of anv studv conducted on backqround radiation Pre-Operational Radiological Monitoring at the proposed Mineral Separation Plant site of IREL, Chavara at Vellanathuruthu coastal region of Kollam District. Kerala The pre operational radiological monitoring of the proposed mining area at Vellanathuruthu region was carried out by Health Physics unit (HPU) of IREL Udyogamandal along with HPU of IREL Manavalakurichi.. The site is located in the Alappad village of Karunagappally block and lies between the latitude of N 9" 02' 44 to 9" 03'74 and longitude 76' 50'61 to 76" 56'77. External Gamma radiation monitoring An extensive radiation suivey of the mining area was carried out using a sensitive Geiger Muller tube detector integrated with Global Position System (GPS) and a pocket size radiation survey meter (RadEye PRD) which incorporates a high sensitivity Nal(Tl) detector with an integrated photo multiplier tube. Measurements were recorded at 1 m above the ground level. .Gamma ray exposure rate at eighteen locations along with latitude and longitude values is given in Table 10. Table : External Gamma radiation monitoring SL Location Radiation Field Latitude Longitude No (pGy/h) 1 Pushpamangalam House 0.4 9.0244 76.5139 2 Kunnumpurath House 1.7 9.0244 76.5129 3 Thuppassery House 1.7 9.0267 76.5112 4 Thekke thuppassery 2.0 9.0271 76.5115 5 New mining area 1.2 9.0285 76 51 08 6 Panda rath u ruth 1.7 9.0300 76.5096 7 Mukkumpuzha junction 05 9.0308 76.5122 8 Panamoottil 1.2 9 0305 76 5095 9 Haribhavanam 11 9.031 0 76.5093 'si'"llliiAL iriFiil 9 9.0328 7e5(F 10 ntappad Govt L.P School 1.7 1.7 9.0357 76.5073 11 Alappad Church 9.0374 76.5061 12 Panikkar Kadav 0.7 9.0362 76.5069 13 Kurusum Moottil 2.7 \ 9.0348 76.5677 14 Nishayalam 1.4 l1 li I 76.5095 il ' 1.3 9.0314 i, i 15 Kollampurath I 1.3 9.0314 76.5095 16 Edayil House 9.0318 76.5080 17 Padattedath 1.35 \: 1.4 9.0320 76.5084 18 Ramanamadam orruoHu RADlsS':$s)' :';;; Environ: \rlrrv' -. The Kerala ^llinersls artd_lfcrci_i (;4 lri. Govt. o! Kerci!t; {'. ,,i,t,r,-.;.._;r., Minernl Scperation Ljnit Kts v jLtjt nttain, Ll fu x y n1s I{-tvIML p / MS 1 Min* s / CB / {} X ala, ,!. lndia ?,8,Aq.2AW g*049, ?6f32727 F.-ssnitr : Dear Sir /f,,latlam F-*f; - Yt:rir offi?ce c*n.*uni*sti*n {*-rnai|} dtriz3.tlg!.aff) sub: Lsetails *al\*d fbr r*gard ingb*a*hr.varhings c*rh*t]*n {e-mait} dtd 15.fir}^Z$}a} _ 1) D':ta rv6;:rding b'*ack vrasldngs ccillriction ancl lteavy mjnera] r.et*verec, ts enrtrosecl" {F"nnexur* I} ?J }rlap show'ir:g beach washings c*?lecti*'ilreas is enclosed.[Annt; 4) It is uneiers1'*rsd fhat Nl':e stucies irave L:eencarried r:r.it b3r E,t\F,cof DAE.iJowelee r the rcp*rfs az-e n*t availabl* tc us. 5i RarL Thanking you, nerals & Mr:tals Ltd.. 3 O Ia.eg$. Otfice : Krslktnt. Distnr_'r i' 1" ' , ^iqu,N c,\i.iDh,u il; i''o't'ttt it'.tnt en j) w 2*{}8 KMWL, *riSaged f{C}155 tnr carryi:rg oret sand budgeting sluciies lor its s:a. rv*shings rollectian arr;rs in Z8\3 t*r sustainahle dev*Jopnlent, '{.hit stiidv 1,1,rs condi:cled *ver fw* seasons" The repwtx'as in:pienlent*ci fronr Seftembei 20 -i *l':lverels' As pe:" th* r*portthe quantity ilf searn,ahings permiffi*d p*r year is, 1, ?:4,LAfr T"4T and tI.,* sarffie is being {aljaz,ot*d ffi*arh Cailecti*n ffulTj 7008 - *g 35?,6S? ztlt* - 11 7.411- 1.2 374,3.44 z*12 - L3 4t]1,557 7,*13-Z*L+ 212,2?,9 2{}14-2*'15 218,1*6 45,194 zfr16-?ft17 3.L3,147 2*17 -7,*18 2fi79-z0l,g+ \'.1.':1.1 i .:,i:t ,t ^ ,.i.,:!: ;(: :lt!:::ii::,..t.:t1...,.,:;i,;;.,.i M{h}E&AE" Pft.fi D {-T CTX*W FX{U M 7^&*E Year Praenucfi*m ffrcenite &ntile Zinccn SiIlixmanite 2008-20fi9 47,,51fr '?'r$98 z,+45 fl 7"409-24ffi 44,3*0 4"r 2,592 0 2,R q? n 7,*Tfr-Z{}11 qv, / 1v 2,413 2,838 2{}11-',2012 43,4fr3 2,&fr{' 5,2\3 s39 2{12-20}.3 45,240 1,fi5fi 3,96{} 1,265 ?,frrT-2fr74 62,850 ?,33* 3,635 J.,27{) 2AL4-2415 55,05CI '2,638 4,7 68 LAlZ 2A3,5-2*n{3 55,630 7.,775 5,346 'tt.4 =a{. 2*L6-Z{)'3,7 55,4fr4 2,4fr5 +,784 6CI0 28L7-z,fij".fr 56,757 '2,434 4,844 7t31 ')*f 1 3ilr.8-?019 26,1,40 1,,548 +,7 67 Ll.L ,t 5r t^r-l1rRl:'#NAN I F\ln- , -_e r..epl Ker:ffilu fulineruls aild IIet'ils Ltd' i::; ,...i" :? TFze {&. t}rsvt. r.'f fter*ln Uwdertak'mg) h'Tjneral Sc:Peratictl Unit SPlend*ur Spreating K*viLtl xstl;rn:., Ch a-;ara K*itram"-691 S&3,Kerala, S' India 1!1r:{}47 6/1$&*047 , ?68}fi4&, 2?}827}-7 Fsx:tJ/+7{t'268WJ E-z'*211 ; rjgntnis G kmrni'eom { CXtd : tJ 1 4I0!KL 1 972SGC0{}2399 p^Er,*/* r*s ry/:" 53 20Lg b e& r\45 I ! J ffilfrel2*1e T* TF{n g{f;,&.m, Op*rating Flar:ts Saf*ty Division, Fft*mk frr*rgy F,egu tatctry ffi oa nd, r, 14 iya m*k {Skavan-h,,4n usl'lakthln*ga ild*rylha!* 4A* **4, h*aharas'ntra. Jrt t Sub: l-iselth Fhyslcs Rep*rt fcr the l?nd QTffi -2ff18' lune Fleese fi',td encnrs*d thc llild qu*rter Healtli Fhysics fteport dur[ng April }OLg tu TfrZg frr the tr4ine rai S*parati*rl Ur"rit of Tire Kerala lr4inerals and Metals Ltd, Chavara, K*liarn, K*ratra, Tl:anking y*tt, Ycurs faithfc"rll,/, F*r Ttre Kerala Y,\irz*rals ar:d Meta?s ttd" Assi:tar-rt fieneral $franag*r & l-{On {ft"45} F,tgr1.{.-}flire:S agl. , w&-691383.1:io}larir]jisrtit e: & us26B(t733 i QUARTfrRLY F{TALTF{ PffiYs}{S TlEP*ftT FOR hj#ru OAH ffirAfH sAru# fi#Eruffi'ffiAl-S {ES{\4} FP^CTL'TY l,Jem* nithe facility: ftit/s T[ie K*rala ?,,4i.nerais and ?,4*tals Ltd, tl4"S" -Jnit" Loe ation af the facility: Chavar a, I{ci{an:. Kar ala " ?*ri*d *{ rep*fting: April 2C19 t$ June Z0'Ig {lne{ eua rt*rI 3."# m*fiY, S?A?tsTtc5. Average fij*.of Al*rsons C*ff*rtive dsse l"rTaxinrurn individual ktdiu;iduatr nrcn?tsreei {person-r'*Sv} :.:.:tY #qse{m5v} ftegallar !7 AF fi,2*5 fttJARTEft gg fi;35 Temp*rary htil - * h. rrt fiJil i\it 6tutt Regular L7 4.8 e*r*tslatlve an 4"14 8.4 th*Year htil Tenrp*rary rufi tvt{ lq,l _"_-i- il e.1 {ru&tvg*\LhL tr058 STAT{sT*Cs. persofis in ayrar-ZfrLg Regular **s* fulnre than ftaut"ge & \mbv t Cant....2 2 :n u s i t''1 T^PlJ.st:[H] 6r,i.t Environr Z"# NiT*NAZITH HT**ICI-IEN TAILIN€S DETAILS. 3, pcp Feed froncentrate Frodue*d Tailings wf{r} 485S 9fr7 "5L5 3890.49 t&*nazrte % A,L Q"4 Traces ?",Wst ifn Feed eonc*ntrate Piodueed Tallings aniri &&92"4 2*51s 586,9 'l {}rr Manazite % 0.66 a-,$) \J Traces 3" Srg MBfl" MateriaB q**ntity{fifiT} , t*nnazite Ys . Feed 24579 2.8 Nnn Mag ** 734L fr"2 lVsn: trsnductings &L83" 4"7 Sieve Waste 550 8.X8 t{n**}te Vrryduct -7)A1 ,t J.?-.I. 0.2 F,utite'#r*duet r{il &. XZr **n^Sltl1waanite p! a nt_ at*riala QuantitytMTl Wjsnaz|t* % te*d Nan : r*ndurting 4e 83St 4.V8 Tire*n Fr*&uqt 848.5 0.2 5?llicnaruite s_,1 ' ruitr Wet table Taillngs bbSu Tnaces &0fr {+4 x* K*cycBed In lf,np &zT4p far {r,srth*r red,,veryof niinerals. C*nt 3 I 2'1 IVIETHOD OF DISPOSAL OF MON AZTTEEITRICHEI)TAI1ITiE d *isp*seel in trenches within the prant b.ouirr?-,., S"* m&ffig&Tfi#ru f\4#ruffi#ffifiruG jLTS ffiHSt {* wirichever is appticabiei l**nall"E*vx ':/; 3-4 0.3.5 , Prg Cpncentratisn plant \". fu?ineraX prCIeess6ng {Fhysical h*lnena! separaticn and/or chenricai processing} P 6eneraX bac$ {ant"..".4 */l ^ rt a1 i",'-r[i F'l': , t. iiAD.1:,:;ii ,gineer nrir rrtit t'-' bru-t Environ Radiation level i-ocatisn *T$tsnium Figmeart Unit {micro €raylhour} ir*n *xidr slurry tan]< &, csrifteetntgftrangeis in A-cid relerlerctir:n pSar;t * *r: ccntact L8.25 T?r* r*turn u,'ater pipeline in the ovarh*arJ inan 30-58 oxide s+l*rag* t.ank * on contaet ,r Tlre lron *v,ir]* s{urry plpeline !nthe *verk*,adirion 2.5-3 *xide st*rage tank * *n contact F..s.ol {Signature af th frY"hn, Operating F[ants iaf ety *ivisEon, htar*re Fn*r6y V,egulat*ry &nard, rya l'|i'urp7l*y H h a r"l -A n &nr*xhakth ? n a g a r, t'&urr&*i- 4*# **4, Y,rt*karas?ztra" t/ ' 't()\q'riliAN J'' ne er ?[l3'?Y'1;::.i'lll '.t -t 07-0!l-2015 E o'd 3rk {Ei rdfuqa) resz ,*F ; E -sr _.- I reus@) * snr'# H;'; tu#!ilffiilT'Rru ^- *t" **+-i'fu, *ffi',J : y ffir,, FF,,r.YaiFfAf, €-+fffidf,ErErirr==rr t Pntewya*m rfkFg gFft iliu., ;I5+*afrfil=il"#ffiHffiffiS*'Tfrq Al;nAc o5i lr# tEn',ilftr 156 ffi t,,r 6.---_ r_. _r a. P; * hiT rf,rG{ r'.s +ctr fr., qim h. +rEil;H;_r'il f"f D tn e*rrcise oFpower confer#il;" crause (Devgloptn.nt Sectlon I Yii:::fs- a n.gur.tion) Ast, r 5 of Mines and Lsso, lndia order-No. t,L1#t::192-ot- ttt. rui,,il il,, ,l,_of s. fI condtttons F* u# of approvtt: f. fiI qRnF verals*srq rrtufrqq t frffi 3'rqfi +m11 q€ *ili*ur r esT 0 s + *n"$-ffiffi r 7Ala5e, Ter$il. m+tfre rfu f- r ,. +G-r- r . . t llmenite, ;;;,,;ffi;# Rutile. I eucnxana jh-l ?:__ partlff B ;i#-,:J'ff _tr',Jfl I l':?,T:i,,?r:11?:.ffiof ririt scheduf. or'r,,rrvi?ril") iilfl,_.,"lJ ffi [,:fl :j#Hl: ^.i[i ** +cd z frf,rtr .b +4ffi Er+rq(mm*-.* , +r frqur @ sf'r $€ril Eo';r of h *nm,- fr ilan* trnl i 'r'r\r ** E d,ffiHtr?r M/s' Ker:alaa MlneralsMrnerarq en,{ . - :"t"t i' t- D lim (rwMtl chavara grant of lease or rcdificationb'"l^y"lds shail furnrdr the detaid ot h ;i;! feasers'r'rE uvIJy s",-rrare govemment fOr feCOfd. Govemment tto Drrector, AryrD D j I D 3' qrER, qgr Ffds fir qfr fi- Tfo,- frq,n + sf*tmrrr-'r! un*fudtr"Ettrry frqr t mn*r"d,rqaoterrr *i t | TheT-H.T.tr*r lessee shatf submit |- a copf of fease ieed, executed Directorate for record, as per the extant rures to this t I ; I 4' H-Tflru;wti F'rq frerltudr ft Ts qrd 3it{ rs+ Erqlt if ffi*il-'i.TY,yqsE{#=;ffi*ff$ I\ Ite Government whil_e gpntjngthe ID mining fease o I taken ciri or wnite irpt*.nting ttre It Plan). ,sining s. !) fg+ it('ff(,rr(rF{, +w '5qt (FfupT gtstzoog 5 irqnuD frsrT, ,D *. rqr.srrtEr ri. o) 6 3rqciqt # u=E*m qfrnrrfi $ dHds . frhrr | $F€r w,.sfr D + Rq (rqffi 3if{ 3Tdfrca s} $fi M/s KMML Chavara shafl ilsf tr,".T as per D Ener.gy (Radiation protection! .Tt",1^: lFRl th.e provis,o*-* oroJ,. o. No. izio ci.r# copy of the same may be J:,,0,._ ffi;;ffi:lx t sent AMDhilT, and IBM for:: records. t6. T{frq s,frt fr{ne. t frtlrrywrr qHq F{q +i+* * D fdtFIFc T{trsifr qr Rur $Frgr * ffiqr Gnnn The monazite ridr concen produced lD from the.mineraf separaflon praht stored sepbrately as per the sharl tions from AERB. Ll D 7' fu,1| ."ftnR-+ y.* {u^rT FEsrT +r qrd,. r,.\3t{ rd-r\.fsr.rr{ -F 1957 *, 3it4d :Jfr-frqiF, SHrdt + fi h|f,,Fl The disposal of mona:T.:::Tlg: ' is cuhj.ct to the conditions I and afso the provisions of ficences bybv nrnb under ,fron_- Act, tgsz. | -rJ.. I ; p... I 3rrril $.fir Bilfi sr;q ffil qErrr 3:frn/fu + nr{d S frnr C + g',a .'r\ )refrrl Ti3tq 1at*6 3,r.}=.d, {etrl qq .niGf 6I filqtdilf,f * P[an prejudice to any is approoed without any , bther __ _rr..wr,.E rL, ure made by the Government r;,JHH:l of fndia, state Governmenf',,n.rrrJlil;ffirJ::t 9 or any other authority. 9. g @rfl STffdn-fT(grJn?ff gJFr de mr* fF :rrrF--- A _ . NEXURE d T5 1960 qFrcr ilrqr HGil. ila d{eror JTFJfrqrq5 lrgeei{"t ,fti{qnur) $ti *# Jftrn ir,w enr 3tfrqFr 3nfi + !f+* sr;q rqdq1 lu fi erff * TnFfi,rr aff *'rar tr : t he Mintng Plan (lncluding Progressive t M.tne closure plf n) does not t the Mines u,:'""Tif b""lH,lli,'"""T -=T;l,fiTl tyrttT ;:i"" (co,servatio4)+;fi};#l t- iffillllllli?,lffl TJ.:'*: l* :::':l*;ffiH#:Iiffi Act re'o, etc. I ;TT[illH',,'"? t I t ro' fr' EI|;f 3tfrfrrfi, 1952 'ftqa + iqdq 3rh 3:fl+ Jr$a ffiT(r * 3ik I p|_s1fl trFr frg Sr g+ar en rq* n:(e, siiEffi:fir 3it{stK srnqrn ffi I *FaqF,3tFFEh, 1ss2 *+. Et-ttdRT qqErd";'ffi-'iqqrErd rrrq qttrfufi 3rrdqrda qn'i ffidr-; ftqr I ) I ines Act, fgS2 and Rules and ) ice of openingr,appoirrtment ) Mines Act, fSS2 shall be comp 11. ) fr' EF|ET 3trdtTtttqrrnft ]a?- TFr?',..- -.r, ^ ^ | ) ) ) tt'mg$fl ! ) fr'snfthar nrfil nr h*-.fi qfi frr$ A*narq+ar + ry I) {E- Fti + 3rrftT il,tr The executton of. PFn (incfudfng pr $hing reistve Mine closure pl n) shall be I subiected to vacatio{r or protriuitory oro.rrTnot if any. I 13. EIFFr WTTTf, 3ndtrdr wffi1 h f EilET t srfrfrq4 19s2 qqrqftd EET fir fuqiqr ;lr;Tr frTr t H'i erqr 59ry I ffir'il afi tuqr il 3rgd6 +t m+rs #'u"'H fur at;Tr aT('lrr I I 1es2 llTJj[?'#::i"X."ij"^1ff1,::9 Yln:'.oct, in the contents orthe Mining pran thffiJll:"T;:T:':il"iy[ffJ,':,:tfre proposals for rectification hai ',^r b..lnL-^- --r- -, *i-::T.'.T::::l,l'i il;;]il-;;;;r ;ili;T:*:T ;q have been withdrawn with imfiediate*' effect. 1c' sE ffifr m T{ur fr qr qrql rrqr gaa H' 3TrstJHr EFT4EnET f fi q{dr 3r+tFur 3r?Fn aezf 6t trqir. +.ffi 'r$ 3W+. il il firrrFrf, +,1 36;faa F|FFTFT ssr{ * tE e} urqrnr tr it any stage' it is observed that the information furnished in the Minins pfm documgnt arg incorrc"+ ^r r+riar--.- ( 15..T6 grgdtFT EF|;T fir4 3it{ F{q qFfffi +ren Hl €;Fr Tgr fd +,l ) sf# ti-H, sftr ' t 3id#a TiFdfur 3,rqlffir .r{ t t tar,"tt!= E{rrr ftqr rrqr q} Hr ;rsarr 3lfr l qg w ffi rr$ fi frrnr #T rsar + iriq f ilfrHt rli This ), apprp assoclated actlvities ls i.rtrirt.d to the mlntng as shown t l?ffi::fl on the.statutory prans under rure 28 t- ,.,rp-o.Tribiltyr..;.',ff 'r.';rf.Tr::rt:f ;"n:n**tl* nd with reference to the lease map ,nH D oc,.r pfans furnished I 1G. erEil frriTfi, EfEFT 3Trffi$H arqrr qanr rd+ traim; o6t4t2o1o + qflfr t .,Fta vn Iolt':{urslss=ffqtufr(rq q+s ilt Bt i;'rft* 2t2o1o t Er #g-'ild ..il I fofF # H #'# ffi;ffi fr.srEfr t'a;6 q(fu # w,,q,fr r*, t*r 1T{F qr$F Firfrni*r r.srs t fi frqr Fn n;n urqqrl TheT3fl- contfnts D of circular No. ]zlzoto issued by the,chief *rf,ro,,er of tttnes, fBM, vor vr datfd t :'::i:J[j:J:'-l'Tll_1" _110-{ttuefso-cc6,n 06.oq-zoro shalr be ffi:,;i#ff :i:ff ;H,'lJl":: Hl',:r,yf,#?*:l'L:r:di]ffiffirr'.- er','vus' Jrlr€ I bggn witHdrawn. ' . h;il.j..'i.;tohave il rz, fr' frffi @rdT fir4 + qE q'qr D dfua tu +'q.tt frl qr6l;T ;rfr Fr H al freflq., (rsiH$ t Rfur f sHUft *t f,i gu IrEftT +T FqFrm w rm* tr ' That if mg during the operation of mlnes, it lq fouod that exlsting being laws are not 'l't Director, AMD may suspend the approval by givfng the I refevant asons In writlng. )r tt'LT dr$ Tnsr qffid t Fldr H FRT d.iq e' h' -- fr g+ar*.''e-rl frt*rn', T*s,mr t-{rdH +t tr 3 I i: rhe m_ethod of minins/mirjins, D thls*:.,:*t:"":,Uj'_..TI:lr:F, the informagon in regard shall be sent to the Director, AMDittyderabad. , rs.ftt?*: il Hq-{rErd h BdI sfr srfuf.d qft,frfr EFFT 3fk i-ir, rToe, dsnrdT dftd frnrj sik m+cr d rfis sil s* frtrr Fuff facifities shall be accorded to any authorized representatlve of the Director, inspect AMD to )' the mine and the processing plant, concemed records and registers at any tlme. t 20. sffss3ff{. 1gg8 * ftJIF )atr, + ri--r{- -.o-JC-}-- 6- .\ SI|'i DHU RAD'rAKRISFTNAN i Ei'ti.r en"ironmental Engineer ANNEXURE -I5 troq t'il gT EFfin 3lld|-rf,Io*, €F{ dE 3rc+dn qrd ild fr Jil*ffir star + t'sd + $nR Fs#I t't sfr fihrn, (,('qs Tt ffi + R(, t9 TsiP+il ffi gq trq-d fir orqrr The Flnancial Assuranttit o required under fe 23F to the Regtonat of MCDR, lggg shourd be subrnitted controfler of Mines, lndian eur.iu ;iil;;r D done' withln six mohths Bangafore, if arready n6t from the ipp-u.t of thts plan Mlne cfosure rtniiiis (includtng progressive Pfan) endorsing a copy of the D same to Director, AMD for record. 9 2r.si*fun qq'r sI w'Hfr frfr {q*r sT*dq s,' Es rit{ I EI|;r duTr rgrfrhra'+t etfir Enflr H fi sfr Bfrm, RqtrCf, t6rd6 +t m il 1eiftrfiturcl copy of statutory notices, which will be sent by the D KMMl{havara to rndian Bureau of General of lvtinei safetv, I iljffi::.ott*or win afso be endorsed to Director; AM4 D zz' tr{rilT qfr# + ddE * (rt-trg1 ffi fr(, {d*r EFF' Jrrq;rdr err sraq}aa D Btr Trqr H *w?lt qiaft-* FTr+t f F*-{t $ru F-8 il il'# D Eilq I * The statutory returns In the prescribed f.g.rmat, in respect I the minllt plan of atomic mln€rats'!-'r'|- for which is approved byAMD '-' ':" ,. I rrtriid; #;;H- F-8 and H-g- a}n Tgr rrcfu I +' fr(' E,-d. D ''.qfqrr ffiffi fit 3it{ T*F,- ffi + sEfl|t dlqtr EFrfr Tg + rtrtr+rur "*. E + iEiq f-(rQ-fis * rfira + Fq il$ I pr the remaintnrr"rr.leilod ;r:;*,, 0 f renewat (s) of iining lease as per a "iirting I ''B ze'(ryqs 3nR d?itn -ufrhrq, 2015 #I rrRT:l 1(il) fi 3h?ilil fr*t + smi$ D rtk qA (rir %rrdtqFT in1'q ffi + D I rmulated under Sestion_11(B) of MMDR e able and this approvitl is subjest to revlsion 9 D I D qrG gffR/Govemrnent of India L'-r.. li"t / 1.,*.*:$5':$i:' \ ;3 a- \_ E sfrfrfr copy to: D D :'iL".,;''fi ::;Tffi##:;:x,';l:ff tl;^*,oo,Keasavadasapuram,partomparace 2' controlfer Fea.nal of Minei, lil; Bureau t Tumkrrr'le Road,yeshwantpur, of Mrnes,:s' Industriaf suburb,su Bangarore -560 , stage, 3' The Director, Bangafor€'Regron,-oir.ao' 022 t c"n.rar of Mrnes safety, (100ft1 Road, 4th B Btock, No.S, 14th Marn 'A'24,ranria'tuagar,Koramangra, Bengaruru - D 4' shrlJacob Punnen' s6oo34 RQp, Thrruvananthapuram, Kerafa-6g5 003. D D !" I D -lI tl it \ t (rnrq ft qfr6R) D (P,S..Parihar| a. .J t / DIRECTOR D. D I t D t D ID a A\\ D I .t 9 D dr- s D t I I TABLE 15 RAW SAND MINING DETAILS FROM 2OO8-09 tO 2OI8- 19 Beach Collection (t"f[) Beach Collection Inland Collection Year Transported (lv{T) (MT) TotalfMT) Openine stock 110.000 2008 - 09 220,000 258,9M 22,636 28r,540 2009 - l0 208,000 204,2A4 632r3 267,4r7 2010 - 11 175-000 250,762 19,531 zto2e3 20rr - 12 195,000 l52,2Al 76,',|U 228985 2012 - l3 194,000 139,928 133,663 273,591 200,000 33,156' 527.79t 2013 - 14 212,229 282Ar3 494,&2 134,000 1E5,361'+ (521,873'l 2014 - 15 218,106 489,128 707,234 134,000 zzaJ79.]' (812,321\ 2015 - 16 45,194 5M,948 592,142 2016 - 17 134.000 I13,147 92,8ffi 205,953 2017 - 18 134,000 47,375 17,822 65_197 2018 - 19 134.000 219,698 212,979 432,677 *The quantity is ttre prs-concentrat€s from PCPs which has to be deducted from the raw sand collection, since it is the out-put of.the PCP for **The additional quantrty (18536lNfD is taken from handling of old d.tmp workings better resovery of minerals. The later stock in ttre dump yard at PCP I will be apx 220179M.T **+The above additional quantity taken from handling of dumps for better recovery of minerals & stock is nil at PCP I stock yard 200g49 b Z}fi -l 8 data from state DMG's audit certificate attached as Annexure 2 1 . Inland collection of 92,806 MT in 20t6-17 includes 23288 MT from Intand Warerways Auttrorities canal dredging, P*e 44 Mining plq of NK Block trI of 203.902 Ha for the plan pefiod from 2016-17 w2020-21 T. KARTHIKEYAN .rz* RADHAKRISHNAN SIIiDHU neer j iiitr Envi ronme nt'al Engr i Minirp Plan hehb 50 i M/s. Kemla Mirerals and Metals Ltd., iGhavara, Kdlam j Submitted Aryust 2015 Jrcob Punne,n, ANT'MPA'RCIP'5':N1O : i watered using a Hydrocyctone and ilte sand will be loaded by wfieel loaders b i transport to Pre-Concentrator plant. i The flow diagram br pre concenfratircn unit is shown in PlaF No.22. ;h) Indicate quantum af development and tonnqe and grude of produaion eryeded pil-lrie :No developrnnt work is reguired because there is no overburden TABLE NO 2I PROPOSED OF'RAUU SAND.PRODUCilOil PROGRAT FOR BLGK 3 mf Or? Sde.ibh Ssbgffitc t3 Yq PftT6.E otrrdtsdtrr Ions qe Otr E F rsf wR.FjR 201 1-12 Ov. Second wAR 2012-13 Ortr,R Third YEAR nr314 owR trorth 9EACH 201+15 WASHNG NIL 1,34,580 NIL il,L ffi, ,A''NAflA trorth w(wLnDf 201+15 tAn N'L 5,50,(X)0 NIL N'L fltt trotth ?01+l5 fOTAL NIL 6,8+5fl) N//L ffiL Fifrh BEACH 'Y'L 201+16 WASH}IG NIL 1,34,580 NIL NIL ML PANNA}JA & Flfrh Ko/.il'fiOTT ?01+16 tr 6,50,000 N|iL NIL H'L trifrtl 201+.16 IIlSth- NllL 7.84,sfl) NIL N/,L NIL \ a tl (' ),(X)0 Tonsfear. [.:^-or^T^3*-o'l E glvs in thefidlwtng dnwings on Pietr. llo. t I ::H rya[5t iuJtg utt(;t {r7ti s. la case sf 'A'clasE mlaes ry RADHAKRTSHI-I| slNDHu Engineer ;iil.'d,nvironmental