India’s coal power sector continues to disregard water norms: CSE report

CSE surveyed over 154 GW coal power capacity and found about half of freshwater-based power plants were non-complying with 2015 water norms; most of them belonged to state-owned companies

By Sugandha Arora Sardana
Published: Monday 21 June 2021

India’s coal-fired power plants have rampantly flouted 2015 water consumption norms.

The results of the survey, in a report titled Water Inefficient Power have flagged the severe non-compliance by coal power plants to these legally binding units of water consumption.

The report highlights how the water-guzzling coal power industry is ignoring water regulations. Six years after the water consumption norms came in, there is high non-compliance observed in the sector, which continues to withdraw enormous amounts of water.

According to the 2015 norms (revised again in 2018), plants installed before January 1, 2017 were required to meet a specific water consumption limit of 3.5 cubic metres of water per MWh; plants installed after January 1, 2017 had to meet the norms of 3 cubic metres of water per MWh along-with adopting zero liquid discharge. 

Additionally, all freshwater-based plants were required to install cooling towers and subsequently achieve the norm of 3.5 cubic metres of water per MWh. All sea water-based plants were exempted from meeting the norms.

Deadline ignored

The water consumption norms for coal power plants were introduced in 2015 alongwith emission norms. The coal power plants were supposed to meet the water norms by December 2017.

Though timelines for emission norms for the sector were revised twice by the ministry — once in 2017 and more recently in 2021 — water norms implementation and compliance was completely overlooked. This is when several power producing regions of the country have been facing acute water shortages and water pollution because of power plants’ effluent discharge.

CSE found that many power plants continue to flout the norms in absence of any firm action.

Major findings

In order to ascertain the country-wide compliance status, CSE researchers collected data on specific water consumption from a variety of sources: Field surveys conducted in a few states; filled-in questionnaires received from a few power plants; filing Right to Information to various State Pollution Control Boards; annual environment statements of power plants and information available in the public domain.

Specific water consumption (SWC) data obtained for the last three years was averaged out for the purpose of analysis. In the case when data was not available for all three years, the SWC value for the year it was available was considered.

  • High non-compliance observed

CSE study surveyed over 154 GW coal power capacity comprising 132 coal power plants. This is about 75 per cent of total installed coal power capacity in India.

Excluding seawater-based plants from the surveyed capacity, almost half the plants did not comply with the specific water consumption norms of 3.5/3 m3 per MWh. 

Category Capacity (in GW) No. of plants
Complying 64 GW 55
Non-complying 59 GW 54
Non-complying (CT* based) 42 GW 36
Non-complying (OTC** based) 17 GW 18
Exempted (seawater based) 31 GW 23



CT* – Cooling tower; OTC**- Once-through cooling 

  • State-owned plants are consuming excess water

Private plants did fairly well in terms of compliance; several state-owned plants were found to flout water consumption norms more. Of the 59 GW of non-complying capacity, a major percentage (about 65 per cent) comprised state-owned plants.

On the other hand, of the 64 GW of complying capacity, a major percentage (about 53 per cent) included private-owned plants.

In the non-complying category, a major capacity included state-owned plants belonging to Uttar Pradesh Rajya Vidyut Utpadan Nigam Ltd (UPRVUNL); Maharashtra State Power Generation Co (MahaGENCO); Rajasthan Rajya Vidyut Utpadan Nigam Ltd (RRVUNL); Gujarat State Electricity Corporation Ltd (GSECL); Chhattisgarh State Power Generation Company Ltd (CSPGCL); Andhra Pradesh Power Generation Co  (APGenco); Telangana State Power Generation Company Ltd (TSGenco); and Madhya Pradesh Power Generation Company Limited (MPPGCL).


  • Uttar Pradesh and Maharashtra possessed maximum non-complying plants

Among surveyed capacity, Uttar Pradesh and Maharashtra had the most non-complying coal power plants. The non-compliance in Uttar Pradesh can be attributed to the age of plants and inefficient practices; also many older plants — including Obra, Parichha, Anpara, Rihand and Singrauli — are freshwater-based once-through plants.

Non-complying plants in Maharashtra also possessed older units commissioned before 1997, including MahaGENCO’s Koradi, Nashik and Chandrapur TPS.

In Madhya Pradesh, non-complying plants included MPPGCL’s Shree Singaji; Sanjay Gandhi; Satpura (Unit 6-9) and NTPC Khargone and in Rajasthan, RRVUNL’s Suratgarh, Kota and Chhabra plants were found to be non-complying.

  • Old and inefficient freshwater based once-through cooling plants continue to operate without installing cooling towers

In June-July 2019, the Central Pollution Control Board issued directions to freshwater-based once-through plants (about 17 GW capacity) to install cooling towers and comply with the standards by June 30, 2022. CSE found that all once-through-based power plants in India are old and polluting plants, built before 1999.

Freshwater based once-through plants withdraw enormous amounts of water and are also lagging behind behind in meeting emission norms. Many of these plants were identified for retirement before but have not yet retired.

They continue to operate, with no plan to upgrade or install either emission control equipment or cooling towers.

The old once-through plants include Bandel TPS; Chandrapura TPS; Dr Narla Tata Rao TPS; Korba III (Korba East); Mettur TPS; Neyveli TPS and Obra TPS.

  • Status of compliance to zero liquid discharge (ZLD) of newer fleet not inspected

About 21 GW freshwater-based coal capacity (comprising 40 units) was commissioned after 2016 and had to follow zero liquid discharge, according to the norms. Most new units have come up in Maharashtra, Chhattisgarh and Madhya Pradesh.

A significant number of these units belonged to National Thermal Power Corporation Ltd (NTPC). With regard to the ZLD norm, there is no information on whether these newer plants followed the ZLD condition laid down in the 2015. Currently, on-ground monitoring and inspection is not carried out by regulatory authorities to check compliance with respect to zero discharge.

  • Flaws identified in self-reported data and reporting format

The report analysed the authenticity of the specific water consumption data that is self-reported by power plants to regulatory authorities in m3 / MWhr, alongwith water consumption break-up consumed in the process, cooling, domestic, ash handling, etc.

CSE found several loopholes in self-reported data and data format being followed across states to report specific water consumption in environment statements.

1. Many plants continued to underreport or report their specific water consumption incorrectly to authorities: Specific water consumption (SWC) value should reflect the entire water being consumed by plant in all its sections, i.e. process, cooling, domestic, ash handling, etc.

It is seen that many plants, instead of reporting plant-specific water consumption, either reported their plant water consumption or process water consumption per unit of product in specific water consumption section of the environment statement.

In such cases, the specific water consumption is much less for it accounts for only water consumption in one section of the plant and can be misrepresented as the overall plant’s specific water consumption, leading to underreporting.

Also, a few plants under-reported the values or gave incorrect figures.

2. No uniform format was followed by power plants across states or within a state for submitting water consumption data: It is observed that many plants skip providing data, especially on specific water consumption in their environment statements.

They only provide water consumption break-up, which is of no relevance when it comes to identifying plant’s compliance and non-compliance.

Many plants did not give their water consumption in process, domestic or ash handling section or left the column blank, making it difficult to understand the actual water consumption in different sections of the plant. 

3. Self-reported data not monitored and verified by independent agency: Self-reported data is not monitored and verified either by the state pollution control boards or any other independent third party agencies.

In such a scenario, there is high probability of data manipulation and under-reporting. Plants might continue to underreport and operate with specific water consumption higher than the limit, leading to excessive water wastages.

There is an urgent need for a uniform reporting format, robust monitoring and implementation plan for these plants across all states.

Way ahead

Based on the above findings, CSE recommended a slew of measures in its report to expedite compliance with the 2015 norms, along with better and accurate accounting of reported water consumption data, these measures include the following:

  • Review implementation of water consumption norms and issue clear deadlines to non-complying plants; ensure zero-discharge implementation as per norms
  • Prioritise implementation of norms in water-scarce regions
  • Prioritise decommissioning of old and inefficient freshwater-based once-through cooling plants 
  • Cross-verification and monitoring of self-reported water consumption data by third party agency through annual water audits
  • Adoption of uniform format by all plants to report water consumption and compliance data in environment statements
  • Periodic calibration of raw water meter and submission of calibration report to regulatory agency
  • Document best practices of water-efficient complying plants with low specific water consumption (less than 2.5 m3 / MWh) and those that have successfully achieved zero discharge
  • Evolve systems of effective deterrence to ensure compliance with water standards
  • Robust and effective policy to encourage use of treated municipal sewage to reduce freshwater consumption in power plants

Needless to say, this sector has a massive water footprint and therefore, all efforts must be made to mitigate this impact. Coal power plants are huge guzzlers of water and are responsible for about 70 per cent of the total freshwater withdrawal by all industries in India. Indian power plants with cooling tower consume twice as much water as their global counterparts.

According to CSE’s recent estimates, about 48 per cent of the country’s coal-fired power generation capacity is located water-scarce districts. Coal-power plants in water-scarce regions such as Nagpur and Chandrapur in Maharashtra; Raichur in Karnataka; Korba in Chhattisgarh; Barmer and Baran in Rajasthan; Khammam and Kothagudem in Telangana and Cuddalore in Tamil Nadu have already been facing water scarcity.

There is scope of reducing the sector’s water demand by ensuring implementation of the 2015 standards and addressing the challenges related to accurate reporting of data, old inefficient once-through cooling plants and implementing zero discharge in newer plants is huge.

If implemented rigorously, the standards can drastically reduce overall water consumption of the sector and will make Indian plants water efficient.

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