Gentle on critical pollution

After declaring 43 industrial areas in India as critically polluted and imposing a moratorium on their expansion, the Union Ministry of Environment and Forests is going easy on them. As many as 23 critically polluted areas have been removed from the moratorium list since last October on the basis of inadequate action plans submitted by the respective states.

Non-profit Centre for Science and Environment evaluated the pollution status of two such places—Vapi in Gujarat and Cuddalore in Tamil Nadu. It found that pollution in these chemical hubs continues to exceed norms, putting a question mark on the ministry’s intent to tackle pollution. An analysis of pollution data by Sanjeev Kumar Kanchan. Ankur Paliwal reports from Vapi and Sumana Narayanan from Cuddalore.


Gentle on critical pollution


Over a year ago, the Union Ministry of Environment and Forests (MoEF) undertook an exercise to assess pollution levels in some of the highly polluted industrial areas of India. It then released a list of 43 most polluted areas, terming them critically polluted, and imposed a moratorium on their expansion. The aim of the whole effort was to identify areas that required urgent intervention and pollution abatement measures. The exercise proved futile as these areas remain highly polluted and have brought no change in the lives of people living near them.

Take the case of 32-year-old Kisna, a fisher in the Daman district of Daman and Diu on the west coast of India. His source of living is threatened by pollution from nearby Vapi—the chemical hub of India in south Gujarat’s Valsad district. Vapi’s industries have severely polluted the Daman Ganga river, which is the lifeline of the fishers.

First list released 23 years ago
The exercise to identify critically polluted areas in India was undertaken for the first time in May 1989 in a meeting of chairpersons and member secretaries of the Central and state pollution control boards. At that time 24 critically polluted areas were identified, including Vapi, Ankleshwar and Ludhiana.

It was then decided that a comprehensive, time-bound programme would be evolved for these areas. Several review meetings followed but there was no improvement in the 24 industrial hubs. In 2009, CPCB collaborated with IIT Delhi and other institutes to evolve a new evaluation method and rank polluted areas—the Comprehensive Environmental Pollution Index (CEPI).
Kisna was once prosperous. He earned up to Rs 3,000 a day from the 10-12 kg of lobsters he used to catch from the river’s estuary. Now he has to travel up to 8 km into the Arabian sea and manages to catch just two to three kilogrammes of fish a day. He cannot go further because his boat is small; fishers with bigger boats have to travel beyond 22 km to get a good catch. Kisna’s earning has dwindled to Rs 600, most of which is spent on maintaining his boat and nets. Kisna’s biggest fear now is that he may end up working in one of the factories that took away his means of living.

“If the catch keeps declining like this, I may end up working as a daily wager in Vapi,” he says, untangling his fishnet and showing his meagre catch. “I have heard they pay just Rs 100 to Rs 150 for 12 hours of work,” says Ganesh, another fisher. About 1,500 fishers in Daman share the fate of Kisna and Ganesh.

Daman’s fisheries department confirms what the fishers say; fish catch in the area has reduced 50 per cent in the past decade.

In India’s east coast, people living near Cuddalore town in Tamil Nadu are facing a similar problem. The river Uppanar that flows through the area was used extensively for inland fisheries once. “When I was younger, fish were plentiful. Now we get only small fish; they don’t fetch much in the market,” says V Bhoopathy, a fisher from village Sangolikuppam. Cuddalore town has over 20 polluting industries. Their effluents are carried through a 2 km pipeline in the riverbed and discharged in the sea. Fishers say they can tell when highly polluting effluents are being discharged from the rising bubbles and the change in the colour of water.

New index for pollution

Both Vapi and Cuddalore figure prominently in the list of critically polluted areas released by MoEF in January 2010. Critically polluted areas are those where air, water and land pollution exceed the assimilative capacity of the environment, affecting human health. The exercise to identify such areas has been on since 1989 (see ‘First list released 23 years ago’ and ‘Timeline’). But it was based mostly on the observation data of state pollution control boards (SPCBs).

  • May 1989: First list of critically polluted areas released after the 29th conference of Central and state pollution control boards. Vapi is in the list
  • December 2009: CPCB evaluates 88 industrial areas using comprehensive environmental pollution index (CEPI)
  • January 2010: MoEF releases list of 43 critically polluted areas on the basis of CEPI; imposes moratorium on expansion, setting up new industries in these areas until SPCBs submit mitigation action plan
  • October 2010: States submit mitigation action plans. Moratorium lifted in five critically polluted areas, including Vapi, Coimbatore and Tarapur
  • February 2011: Moratorium lifted from eight more areas, including Cuddalore, Navi Mumbai, Ludhiana, Agra and Aurangabad
  • March 2011: Moratorium lifted from seven more areas, including Faridabad, Ghaziabad and Noida
  • May 2011: Moratorium lifted from three more areas with conditions. These are: Mangalore, Greater Cochi and Bhadravati. Moratorium on other areas to stay till September 30, 2011
This changed in 2009 when the Central Pollution Control Board (CPCB), in collaboration with IIT-Delhi and experts from premier environment institutes, devised a scientific method to evaluate and rank polluted areas. It is called the Comprehensive Environmental Pollution Index (CEPI). The index was used to assess 88 industrial clusters in the country (see ‘Measure of pollution’, Down To Earth, January 15-31, 2010). CPCB chose these clusters after asking state governments to forward a list of polluted areas on the basis of pollution data. CPCB also monitored pollution in these clusters before finalising the list. All the 88 areas have highly polluting industries, which include power plants, mining areas and chemical, pharma and dye factories.

For CEPI evaluation of the clusters, data on land, water, air pollution, ecological damage and waste management in these areas was taken into account. The industrial clusters were ranked on a scale of 0-100. A high score indicated high levels of pollution and environmental degradation. After the evaluation, 43 areas which scored 70 points and above were declared critically polluted (see ‘Pollution score card’ on left).

Vapi’s score was 88.09, next to Ankleshwar, ranked first with a pollution index of 88.5 points. Cuddalore scored 77.45 and was ranked 16th (see ‘India’s top 10 polluted areas’).

Activists and some of the state governments have, however, been critical of the evaluation. Delhi non-profit Centre for Science and Environment (CSE), which analysed the CEPI evaluation found that areas where mining is rampant, like Bellary in Karnataka and Jharia in Jharkhand, were not even assessed.

  • Plan for remediating contaminated groundwater
  • Measures to reduce air pollutants like volatile organic compounds and benzene
  • Plan to reduce pesticides and heavy metals in water sources
  • Proposal to assess quality of groundwater and surface water, and impact of pollution on people
  • Action plan proposes discharging CETP’s wastewater directly into the sea without assessing its impact on fisheries and marine ecology
The evaluations had other shortcomings—SPCBs do not have adequate database and there is no transparency in data collection and tabulation of affected population. What followed the release of the list came as a shock for those campaigning against pollution near industrial areas.

Moratorium, a formality?

At the time of announcing the list of critically polluted areas, MoEF had put a ban on expanding existing industries or setting up new ones in these areas. The ministry also asked the respective SPCBs to submit mitigation action plans for these areas in eight months. All plans were submitted by October, 2010.

But before any significant change in pollution levels could be seen on the ground, the ministry lifted the moratorium on Vapi and four other critically polluted areas in October. Eighteen more areas were taken off the moratorium list between February and May this year. The ministry justified the decision, saying it was based on initiation of works mentioned in the mitigation action plans submitted by states. “The purpose of the moratorium was to sensitise the state governments and identifying the problem. pollutionThe moratorium was lifted only after a review of the action plans,” says R S Cori, scientist with CPCB, who was closely involved in the CEPI study. While accepting that many of the areas where moratorium was lifted are not meeting norms, Cori says reduction of pollution levels is a long process and results cannot be seen overnight. Besides, there were other concerns—industry associations objected that the moratorium was affecting their growth and that they were being unfairly punished because of some polluting units in their areas. CPCB has formed a steering committee, which meets every two months to review pollution reduction.

  Lifting the moratorium was not justified. How can it be lifted on the basis of some paper work without analysing the ground situation, which has not changed?  
Paryavaran Suraksha Samiti
Environmentalists criticised the ministry’s decision. “Lifting the moratorium was unjustified. How can it be lifted just on the basis of some projections on paper without analysing the ground situation, which has not changed?” asks Michael Mazgaonkar of non-profit Paryavaran Suraksha Samiti that works in Gujarat.

A K Nema, professor at IIT-Delhi, says if an area is already choked with pollution, allowing new industries can have serious impact on the environment and human health. “I think the ministry should consider re-imposing the moratorium in these areas, else the whole purpose will be defeated,” says Nema who was involved in the CEPI evaluation.

Questions have also been raised over the efficacy of the mitigation action plans of the states. CSE analysed two of the critically polluted areas—Vapi and Cuddalore. Vapi was chosen because it is second in the list of critically polluted areas after Ankleshwar. While the moratorium in Ankleshwar is still in force, the one on Vapi was lifted. Cuddalore was randomly selected from the list of areas where moratorium was lifted.

The CSE analysis shows pollution levels in the two areas are still way above the permissible limit.


Vapi’s action plan inadequate

The Gujarat Industrial Development Corporation estate of Vapi has a total of 832 industries of which around 759 are polluting ones. Of them, 653 are in the red- category list of CPCB. Seventy per cent of the 759 factories include those making dyes, dye intermediates, pesticides, chemicals and pharmaceuticals. The remaining are mostly paper mills, plastics and food processing units. The water pollutants from these industries include ammoniacal nitrogen, phenolic compounds, benzene, pesticides, heavy metals, cyanide, arsenic and organic as well as inorganic pollutants. Prolonged exposure to these can prove fatal.

imageIn its mitigation action plan, Gujarat PCB mentioned some works initiated to bring down the levels of these pollutants. These include reduction of pollutant load on Vapi’s Common Effluent Treatment Plant (CETP) and its capacity upgrade because effluents entering and leaving the plant were not meeting the prescribed norms. In November last year, the Vapi Waste and Effluent Management Company (VWEMCL), managed by the industry association, upgraded the capacity of the CETP from 55 million litres a day (MLD) to 70 MLD. But this may soon prove inadequate as effluent reaching the CETP is increasing every year. It was 48 MLD in 2009; it is 60 MLD now.

VWEMCL has also installed a Fenton (a reagent) Activated Catalytic Carbon Oxidation plant to oxidise wastewater having pollutants that do not break down easily. Such pollutants use up more dissolved oxygen in the water and are a threat to the fish.

imageOther measures initiated under the mitigation action plan include installation of flow meters by every industrial unit to regulate effluent discharge to the CETP, and checking of illegal discharge of highly polluted effluents in open areas.

But these measures have only marginally improved the effluent quality discharged into the Daman Ganga river; the pollution levels still exceed the norms. For example, CPCB’s periodical monitoring data shows the chemical oxygen demand (COD, measure of oxygen depletion in water caused by organic pollutants during decomposition) of the effluent discharge at the Vapi CETP outlet is 500-800 mg/litre; the maximum permissible limit for it is 250 mg/l. CSE’s Pollution Monitoring Laboratory tests found that COD level in the effluent at the CETP outlet was 1,500 mg/l, which is 600 per cent of the norm (see table: ‘Effluent quality at Vapi’s CETP outlet’). The tests conducted in April 2011 also show presence of heavy metals like mercury and poisonous compounds like arsenic and cyanide.

imageCSE also collected water samples 300 metres upstream and 300 metres downstream of the CETP outfall and five to six kilometres downstream of CETP at Kachigam dam (see satellite image p26). The results showed presence of high levels of mercury and oil and grease (see table above). High levels of organochlorine and organophosphorous pesticides were also detected.

Vapi’s waste management utility, however, claims there is improvement in the effluent quality. For instance, COD level of treated wastewater has been reduced to 500-800 mg/l in 2010-2011 from 800-1200 mg/l in 2004-2009, says D C Sharma, chief executive officer of VWEMCL. “Vapi mostly has small industries. It is difficult for them to manage CETP inlet norms as most of them do not have high-end technology. When inlet norms are not met, water with high COD levels flows out of the CETP,” says Sharma. He adds that very soon the CETP will bring COD levels further down to 350-400 mg/l by upgrading effluent treatment plants of each industrial unit.

imageIndustry owners have, meanwhile, demanded that pollution standards should be relaxed for chemical industries. “We are doing our best. If CPCB has a magic formula for reducing pollution and COD levels give it to us,” says Mahesh Pandya, former president of the Vapi Industrial Association.

Vapi’s waste management utility has a solution, as mentioned in the action plan. It has collaborated with the National Institute of Oceanography and has proposed a 22 km-long under-sea pipeline that will carry the treated effluent from the CETP and discharge it deep in the sea. “The effluents will be widely dispersed and we can achieve 100 per cent dilution of effluent this way,” says Sharma. Fishermen in Daman oppose the proposal. “We have already lost the fish in the estuary because of the toxic discharge into the river. The pipeline will kill the fish in the sea,” says Premabhai S Prabhakar, a leader of the fisher community.

  Activists and states say CEPI method of evaluating pollution status has shortcomings  
The action plan misses some important measures. CSE analysis shows Gujarat PCB’s action plan makes no mention of any review study of existing surface water quality and its impact on people and ecology. It does not provide for any impact assessment study on fish due to discharge of polluted water into the sea. The plan does propose reverse osmosis (RO) technology for treating non-biodegradable effluent, but it has not been implemented yet. The review studies and installation of RO technology are vital for pollution abatement.

Groundwater contaminated

The mitigation action plan also gives a miss to the contaminated groundwater in and around Vapi. In 2005, a Supreme Court monitoring committee had ordered the Gujarat government to seal all contaminated wells and borewells and make drinking and irrigation water available to people. The committee identified indiscriminate dumping of hazardous waste in the open as the source of contamination.

imageThe state authorities sealed many borewells, but are yet to make drinking water available to all. Water for agriculture is yet to be arranged. Vapi’s waste management company removed 10,000 tonnes of hazardous waste from the illegal dumping sites to the hazardous waste treatment facility in Vapi in November last year, but no action has been taken to decontaminate the water.

Ground water quality in villages of Vapi – as tested by CSE Lab
Place of monitoring COD ** TDS TSS F Fe Nitrate Mercury O&G
Standard (mg/l)-
- 500 - 0.6-1.2 0.3 45 0.001 10*
1 Vathiavad  village, (Rata)- handpump -- 1646 (329%) 14 1.53 (127%) 2.11 (702%) 69.84 (155%) 0.011 (1051%) 5.6
2 Desaivad village, (Rata)-
10 772 (154%) 141 0.69 BDL 16.99 BDL 2.8
3 Gala Masala (handpump) 20 1312 (260%) 178 0.69 0.08 BDL 0.083 (827%) 10.40 (104%)
4 Dungri Falia (borewell) 80 2140 (400%) 288 0.64 0.03 20.30 BDL 25.20 (126%)
Source: Water quality tests performed by CSE Laboratories, New Delhi * O&G standard for Inland surface water **COD tests performed at Choksi Laboratories TDS- Total Dissolved Solids, TSS- Total Suspended Solids, Fe- Iron BDL- Below detection limit Some of the figures have been rounded off

A visit to three affected villages revealed many people are still drinking the contaminated groundwater. Rata village near phase III of the industrial estate has around 1,100 families, but only 200 of them have easy access to safe drinking water.

“The rest are either forced to drink the contaminated water or walk at least one km to reach the nearest drinking water source,” says Jayendra Bhai Patel, sarpanch of Rata.

  Mitigation action plans submitted by states do not pledge enough to reduce pollution levels  
CSE collected water samples from two places—Vathiavad and Desaivad localities in Rata village, and from Dungrifalia and Gala Masala villages along the Dharampur road in Vapi. The tests showed pesticides in concentrations exceeding bottled drinking water standards prescribed by the Bureau of Indian Standards (see table above). Pollutants, including iron, dissolved solids and mercury, were also detected.

To get rid of the solid waste, the Vapi administration has proposed a co-processing plant where plastic waste would be burnt in cement and steel plants. “But the industry waste is sometimes still found dumped at several illegal places like Bill Khadi, a rivulet,” says Rohit Prajapati, a Vadodara-based environmental activist. Sharma says VWEMCL has constructed a barrage to divert Bill Khadi’s water to CETP.

Concern over air pollution

Pollution in Vapi’s air is palpable. “In winters, we have to stay indoor because the air becomes suffocating and the eyes start itching,” says Devli Ben of Vathiavad in Rata village.

The Gujarat PCB is responsible for monitoring air pollution, but it does not have monitoring facilities for pollutants like volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls and vinyl chloride, released by industries. Many of these pollutants are carcinogenic and released by chemicals, dyes, paints, pharmaceuticals and other industries using organic chemicals. For monitoring VOCs, CPCB has given the contract to Vadodara-based Gujarat Environment Management Institute. Monitoring of PAHs, polychlorinated biphenyls and vinyl chlorides has been outsourced to a private firm. An official of the environment institute admits that the levels of VOCs, arsenic, nickel and ammonia exceed standards.


Gujarat PCB only monitors sulphur dioxide (SO2), nitrogen dioxide (NO2), respirable suspended particulate matter (RSPM) and suspended particulate matter (SPM). Air pollution monitoring data of the PCB shows that while SO2 and NO2 meet the permissible standards, RSPM levels hover in the range of 70-120 µg/m3 against the standard of 80 and SPM in the range of 150-200 µg/m3 against the standard of 100. Gujarat PCB says there is 80 per cent improvement in the ambient air quality over the past two years, but its mitigation action plan does not have clear cut proposals. It merely mentions “proper air pollution control measures, adoption of cleaner fuels, plantation and cleaner technology” as some of the broad areas, for which a five-year deadline has been set.

  Despite court orders all families in Vapi’s affected villages are yet to get drinking water  
G V Patel, regional officer, Gujarat PCB says all industries in Vapi have air pollution control equipment, and “we keep taking disciplinary action against them”. But he refused to reveal the names of three factories that were issued closure notices recently. After the submission of the mitigation action plan, around 200 industries have converted to natural gas, others are still using fuel oil.

CSE analysis of the action plan shows Vapi failed to give a clear plan on lowering levels of VOCs, benzene, PAHs and polychlorinated biphenyls, which is required urgently. Though the government and industry association have taken some measures to curb pollution, a lot still remains to be done. “If the government seriously cares about improvement in Vapi, it should re-impose the moratorium and not lift it till all parameters are met,” says Prajapati.


Projections misleading

CSE also evaluated PCB claims that the mitigation action plan will reduce Vapi’s pollution index to 61.88 (severely polluted). It found that even if one goes by SPCB’s claim that air quality has improved and the affected population is less than 100,000, the CEPI index for air would reduce from 74 to 67 and not 39 as projected (see table above). The plan also ignores the impact of pollutants on health and ecology, despite visible water pollution. By skipping these vital factors, the indices for water and land were lowered to 56.25 and 33. CSE analysis shows even if all the measures mentioned in the action plan are factored in, Vapi’s CEPI score will reduce to 84 (critical), not 61.88 points. This means Vapi will remain a critically polluted area as it has been for the past 23 years.

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