General Notes
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SHIPYARD CUM CAPTIVE JETTIES INCLUDING LNG TERMINAL at Nana Layja, Kutch District, Gujarat KUTCH G U J A R A T CLARIFICATIONS TO MoEF OBSERVATIONS APRIL 2017 Submitted By SPPL AND GIMCO INFRASTRUCTURE LEASING & FINANCIAL SERVICES LIMITED (IL&FS) - DEVELOPER/PROMOTER EIA Consultant: L&T INFRASTRUCTURE ENGINEERING LIMITED (Formerly Known as L&T-RAMBØLL CONSULTING ENGINEERS LIMITED) C1121310 CLARIFICATIONS TO MoEF OBSERVATIONS 1 As per page 2-3 of EIA report, it is mentioned that project was falling in forest land. Pl. give the status of stage -1 forest clearance As per the latest revised project layout subsequent to GCZMA clearance, the project facilities are planned only on 181 HA of reclaimed land and no onshore land or forest land is involved. The latest layout has been developed after public hearing and GCZMA appraisal process as briefed below. I. Initially, Shipyard cum Captive Jetties including LNG Terminal is proposed to be developed in an area of about 336 Ha; out of which approximately 181 Ha will be reclaimed land. The balance 155 Ha is onshore area, among 155 ha approximately 79 Ha of land is under project proponent possession and remaining 76 Ha is of government land which was to be applied.During public consultation with stakeholders, concern raised regarding onshore government land to be applied belongs to forest department. Since proponent has to apply for this land, an alternative layout was prepared by excluding the forest/government land with an area of 260 Ha i.e., 181 Ha of reclaimed land and 79 Ha of onshore land available with the project proponent was prepared and submitted to Gujarat Coastal Zone Management Authority (GCZMA) for CRZ recommendation. II. Subsequently, During GCZMA appraisal process, committee advised to keep the onshore land intact and hence development of project facilities were shifted completely to reclaimed land and layout was revised to an area of 181 ha. Therefore, project development does not involve any forest land. The revised layout superimposed on CRZ demarcation map prepared by NIO is enclosed as Appendix 1. 2 Fix the land for the proposed activity and give details of Survey nos. of land. Project development is planned on reclaimed area of sea of 181 ha avoiding onshore area requirement. No survey numbers are applicable. 3 Submit a declaration (if applicable) that any changes that were made in the layout were a result of the recommendations made in the Public hearing report and the recommendations of the Gujarat CZMA The declaration is enclosed as Appendix 2. 4 Give the impact of temperature differences on the ecology of the impact zone at sea From the proposed Shipyard cum captive jetties including LNG terminal, 3.0 MLD of treated wastewater is proposed to be disposed into sea along with return cooling water discharge from the power plants, reject brine from 60 MLD Captive Desalination plant, CETPs treated discharge of SEZ through common marine outfall system. A mathematical model study on advection and dispersion has been conducted to understand the dispersion pattern of the plume, increase in ambient concentration of temperature, salinity and other parameters etc., to identify the suitable location for disposal of treated wastewater and assess the impact on ecology due to proposed outfall location. Page 1 The Outfall location is proposed at 2.3 km into sea at (-) 10.3 m CD at sufficiently deep water with effective diffuser arrangement to ensure dilution and faster attainment of ambient condition. The excess temperature is extracted at 100 m and 500 m radius from proposed outfall location. The excess temperature is found to be stabilising over the time. The excess temperatures do not exceed 0.15oC and 0.200C beyond 500 m and 100 m of the outfall point. In the project region, the seasonal variation in seawater temperature and salinity is observed more than the predicated excess temperature and salinity. The species located in these areas are well adapted to the seasonal variations and thus discharge of return cooling water may not have impact on ecology in the outfall zone. As per USEPA guidelines, the maximum acceptable increase in the weekly average temperature resulting from artificial sources is 1oC during all seasons of the year, providing the summer maxima are not exceeded. The excess temperature falls well within the acceptable limits as specified in USEPA guidelines. 5 Conservation plan for sand dune and turtle to be prepared in consultation with the Wildlife Department of the State Government The study report for Sand Dune and Sea Turtle Nesting which includes conservation plan was submitted to State wildlife department by GCZMA (communication of GCZMA to State Wildlife Department is attached as Appendix 3). The study report & conservation plan drawn for sand dunes & turtle nesting was reviewed by the Wildlife department and provided their recommendation to GCZMA for according CRZ recommendation. Subsequently, GCZMA accorded CRZ recommendation vide Ref.No. ENV-10-2015-152-E (T Cell) dated June 29, 2016. The recommendation by Wildlife department is included in the GCZMA letter referred above and the relevant part is reproduced below; Page 2 6 Details of the air pollution control measures to be undertaken for the coal handling berth and well as bulk cargo handling berth. As a part of development plan, two bulk cargo handling (coal) berths are proposed. Dust suppression equipment will be provided for efficient control of dust pollution on environment during storage and handling of Coal at berth and stockyard. An efficient dust suppression system will contain dust particles before it is airborne. Following different type of dust suppression system is proposed at different locations as detailed i n Table 6-1. Table 6-1 Details of Dust Suppression System S. Dust Suppression Location No. System 1 Ship Unloaders Dry Fog System 2 Stacker cum Reclaimers Dry Fog System Swivelling plain Water 3 Coal Stackyard Sprinkling 4 Transfer Towers Dry Fog System Ship Unloaders Dust at the ship unloader is generated when grab drops coal into the hopper. It is proposed to provide Dry Fog Dust Suppression System which is more effective system than simple sprinkling to contain this. The Dry Fog Type Dust Suppression System operates on the Agglomeration Principle i.e.; air borne dust particles are enveloped by a fine Dry Fog (Droplet Spectrum of 0 to 10 microns), the innumerable collisions of dust particles with that of equalized droplet of water in the fine Dry fog makes the Dust particles Agglomerate, become heavy enough and fall back on to the running stream of material. In effect fine Dust of even respirable type (less than 3 microns) is suppressed even before it is air borne. Transfer Towers Dust emission in the transfer tower will be little less than in Unloaders but slightly higher than in stockyard. Hence dry fog dust suppression system will be provided at all transfer points along the conveyor. Stackers cum Reclaimers On board stacker cum reclaimers, it is proposed to provide Dry Fog Type Dust suppression system as well. Coal stockyard Water sprinkling system at high pressure with swivelling type nozzles will be installed to cover entire stockpile. Nozzles will be installed on pipes at different levels from ground. Nozzles will be installed along stockpile at regular intervals to cover stockpile height and width. While stacking / reclaiming Coal nearest two sprinklers will be operated to control dust generation due to discharge / reclaiming. At other areas of stockpiles, two sprinklers at a time will be operated sequentially to control dust generation due to winds. The schematic layout of Dust Suppression System (DSS) at coal stockyard is shown in Figure 6-1. Page 3 Figure 6-1: Schematic arrangement of Dust Suppression System around Coal Stackyard In addition to the above green belt is planned along the stockyard area. There is a multipurpose / general cargo berth proposed in the project to service SEZ requirements. The commodities that will be handled at this berth are not expected to generate dust. However it is proposed to use water sprinkling by means of tankers periodically at this berth area. 7 It was noted that ground level concentration of particulate matter seems to be in higher side. Therefore, reduce the ground level concentration of particulate matter by taking various onsite air pollution control measures. Kindly furnish the details The air pollution control measures to be adopted are as follows: 1. Greenbelt development along the coal stockyard and development of green areas in the project site 2. Covered conveyor galleries for transport of coal from berth to coal stockyard 3. Dust suppression system with various types such as Dry Fog system, Plain water system etc., at all susceptible areas of dust pollution during coal handling and storage. 4. Trucks proposed for break bulk cargo transport susceptible for fugitive suspension will be covered with tarpaulin 5. Enough stack height for shipyard process and Sub merged combustion vaporiser (SCV) for LNG regasification (standby technology). After adopting the above control measures, prediction of ground level concentrations due to coal handling, storage and also other sources of air pollution such as shipyard process stack emissions, LNG regasification SCV stack emission and vessel emissions during berthing time were carried out by using AERMOD software. The incremental concentrations predicted at the selected receptor locations are given in Table 7-1. Page 4 st Table 7-1: 1 24-hour Average Incremental & Resultant Concentration of PM10 & PM2.5, SO2 and NOx Location 1st – Highest 24-Hour Average Incremental Concentration in µg/m3 No. PM10 PM2.5 SO2 NOx AAQ1 2.74 1.83 1.98 4.19 AAQ2 11.23 7.49 0.15 0.30 AAQ3 4.81 3.21 0.27 0.33 AAQ4 3.26 2.16 1.18 2.28 AAQ5 2.81 1.87 0.28 0.22 AAQ6 2.94 1.96 0.15 0.18 AAQ7 0.04 0.02 0.06 0.10 AAQ8 1.33 0.89 1.22 1.25 It may be noticed from above table, incremental concentration due to proposed project is minimal and resultant concentrations are well within the NAAQ standard.