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AIPSN Position Paper on Uttarakhand Disaster

click here to read the English pdf of the AIPSN-PositionPaper17Feb2021-Ukhand-Disaster

AIPSN Position Paper on Uttarakhand Disaster

17 Feb 2021

 

The disaster in Chamoli District, Uttarakhand on 7 February 2021 morning, in the region around the Nandadevi Biosphere Reserve, saw a large volume of fast moving flood waters carrying ice and snow, rocks, debris and mud come rushing down from high-altitude mountains. At the time of writing on 14 February 2021, over 58 persons have tragically lost their lives and 148 persons are still missing. Most were workers in different projects in the area, along with some local villagers, and another 150 or so remain missing. Many workers are feared trapped inside the tunnel of the badly damaged under-construction ADB-funded 520 MW NTPC Tapovan hydro-electric project on the Dhauliganga river. The small Rishiganga 13.2MW hydel project on the Rishiganga river, about 4km upstream near the village of Raini where the famous Chipko movement started, was completely destroyed. At its peak, the flow was reportedly  around 30,000 cumec (cubic metres per second) with a 10-15 metre wave in narrow parts of the river. The deluge continued downstream past Joshimath where monitoring stations apparently showed the waters at more than 3 metres above the previous Highest Flood Line recorded during the infamous 2013 disaster in Uttarakhand resulting from extreme rainfall over several days and flash floods.  Several other hydel Projects nearby, such as the World Bank-funded 444 MW Pipalkoti dam still being built and the 400 MW Vishnuprayag dam, were also threatened but damage assessment is awaited.

The exact cause and circumstances of the disaster are yet to be fully determined. Based on what is currently known, the earlier speculation about a glacial lake burst is probably incorrect. It now seems, based on satellite imagery in India and abroad, and preliminary observations by specialist Indian teams from the Wadia Institute of Himalayan Geology (WIHG), Dehradun, that a large weakened section of a rocky section of the Raunthi mountain-top fell over on an over-hanging portion of a glacier, and carried along an avalanche of large  quantities of recently accumulated snow, rocks and debris. This massive avalanche-cum-landslide seems to have settled in the Raunthi river on the valley floor, blocking it for several days, and then bursting through in the deluge witnessed on the 7 February. Recent reports suggest formation of another large pool behind large amounts of accumulated rocks and debris, threatening another high river flow event.

It is indeed tragic that most of the dead so far seem to be workers in different infrastructure and hydro-electric power projects. According to both Central and State governments, these and other infrastructure projects were supposed to benefit the region. However, this has long been questioned by environmentalists, local residents as well as by many experts and civil society organizations that remain of the opinion that such projects should be scaled down and assessed carefully before being launched. Decisions need to be taken keeping in mind the precautionary principle in view of the fragile mountains, low carrying capacity of towns and other settlements in the area, and high risks posed by floods, landslides etc. At present, it is not known if there is any evidence pointing to these infrastructure projects having any role in triggering the rock and glacier break-off rock and related avalanche and landslide. But, as discussed below, they certainly contribute to the magnitude and impact of such disasters, which therefore can never be termed as purely “natural” disasters or “acts of god.”

Ironically though, in the present case, these very projects and those working on them, including local villagers, have themselves become victims of a disaster.

 

Role of Climate Change & Infrastructure Projects

Regardless of the issue of causation, this disaster is nevertheless a grim reminder of the potential impact and dangers of mindless so-called “development” projects, ignoring all warnings and expert opinion, brushing aside environmental assessments, and implemented badly, all without thought about consequences.

Two major aspects stand out which cause, or contribute to, similar disasters in mountain areas in India especially in the Western Himalayas, namely climate change and thoughtless infrastructure and other construction projects in the region.

Man-made global warming has resulted in rapid melting and shrinking of glaciers along with melting of polar ice caps. The Himalayas are often called “the third pole” since they are the third largest reservoir of fresh water in the form of ice and snow. More recent studies, both internationally and in India, have shown that melt rates are much higher at present than in earlier decades and, in India, more rapidly in the Western Himalayas than in the East. Glacier melt often leads to formation of glacial lakes or large pools of water. Sometimes under pressure or due to external forces or impacts, the barriers of these glacial lakes break, releasing large volumes of water leading to flash flooding downstream, as was earlier speculated in the present case. Rapid melting of glaciers in India therefore lead to large-scale instability in the Himalayan region with increasing probability of increase in river water flows and flash flooding, posing a serious but as yet poorly predictable threat and imminent danger to downstream settlements and infrastructure, besides medium-term hydrological impacts on the whole Indo-Gangetic basin.

On top of this, there has been, especially in recent times, an irresponsible rush to build numerous roads, power plants and other infrastructure in the region without adequately assessing the potential environmental and societal impact, addressing the geological and tectonic instability of the region, and the carrying capacity of settlements and the hills. The Himalayas are a young and unstable mountain range, located in the most earthquake prone seismological Zones IV and V, subject to frequent landslides, with cloudbursts and flash floods carrying tons of rocks and other debris, causing havoc even normally. Even the on-going unplanned expansion of towns and settlements, beyond their carrying capacity, is already adding pressure on the regional environment through larger populations, new buildings outside the town limits, new hotels, new road construction or widening, depletion or even disappearance of water sources, and tree felling leading to loosening of soil and rocks which increases landslips and rainwater run-off leading to floods in local streams and rivers.

 

Rash of construction projects

The current rash of construction projects, expedited and pushed through under the present government, has taken such destruction to new and dangerous levels. A massive number of hydro-electric projects are now under construction in the region. At present there are around 100 dams in the State with many more under construction. According to some estimates, over 450 hydel projects are planned, meaning there could be one project every few dozen kilometers! Several of these are supposed to be run-of-the-river projects but, in practice, also involve at least some impounding of water and/or much construction  activity. The construction of these dams and hydel projects involve tree-felling with lackadaisical compensatory afforestation, and a lot of construction, often using dynamite and other questionable techniques triggering further instability in already unstable hill regions. Construction debris are often simply dumped into the river in violation of procedure, or along the roadside in so-called “designated spots,” but frequently end up in rivers below, further blocking the river flow and raising the river bed, thus increasingly the potential for flooding.

Over the years, these projects have led to large-scale protests by villagers, environmentalists and experts. In the wake of the 2013 Uttarakhand disaster, a Supreme Court appointed expert committee recommended cancellation of most of the proposed projects, which a second Committee appointed also endorsed. A third hand-picked committee thereafter appointed overturned these recommendations, but many projects thus approved continue to be under disputation. A leading expert, and Chairman of the SC-appointed committee, has opined  that no dam or hydel project should be taken up in the para-glacial zone of 2,200 metres altitude or above on safety grounds.

Massive road construction is also underway, notably under the Rs.14,000 Crores Char Dham Project started in 2016 linking the four major pilgrimage sites in Uttarakhand with over 900 km of roads including the Char Dham Mahamarg highway, hotels and other infrastructure. Environmental clearance for the project was obtained in 2018 through aggressive push from the highest levels of the central government, who also amended the EIA Notification 2006 to exempt road projects under 100km in length from EIA. Using this subterfuge, the Char Dham Highway project was divided into 53 projects of under 100km length and given clearance without any environmental appraisal using the kind of norm-twisting modifications proposed in the Draft EIA 2020 Notification!

A majority of members of the packed High Powered Committee to review the project recommended keeping the road width to 10 metres, involving cutting of the hill upto 24 metres, as earlier approved by the Supreme Court which, however, had later ordered restricting road width to 5.5 metres but work had meanwhile speedily covered a substantial length of the highway at the larger width. Road cutting and scooping of hillsides have been done in a non-standard and dangerous manner including through dynamiting, often with almost vertical slopes against all protocol and sharply increasing prospects of landslides, and without stabilization and fresh plantation to help bind the slopes. Debris is also very often dumped carelessly and ends up in the river below. Speed, greater profits for the companies involved, and the headlong rush to build infrastructure, not safety, is clearly the priority.

Besides the direct damage caused in the already unstable region, all this only worsens impacts of future flooding events. Debris raises the river bed, increasing chances of flooding and submergence of riverside infrastructure and townships as happened in the 2013 disaster. Debris also enters dams and power plant races reducing dam life and damaging generating equipment.

 

Way forward

With the rationale of boosting tourism in the region, regardless of carrying capacity and fragility of the mountain ecosystem, Kedarnath town, which suffered extensive damage in 2013, is being rebuilt with little thought to the impact on the surrounding environment and the vulnerability of the town to further flooding and other events like in 2013. Alternative suggestions such as building residential infrastructure at lower altitudes with regulated pilgrim traffic to the temple have been brushed aside.

Monitoring and observation of this region for extreme weather events, landslides and slope instability, and glacial observation, is also almost non-existent.

While there is some indication that there is some slowing down of dam-building and hydel projects in the region, in so many other ways various highly risky and environmentally damaging infrastructure projects continue to be undertaken in this eco-sensitive area. It is essential that this disastrous course be reversed without delay; otherwise we will be left only with post-disaster analyses in future.

 

In light of the tragedies of the 2013 and 2021 disasters in the Himalayan region of Uttarakhand, a safety and environmental review should be urgently conducted of all hydro-electric, road building and infrastructure currently underway and planned, based on which these should be suitably modified or cancelled.

 

 

For clarifications contact:

D. Raghunandan 9810098621

P. Rajamanickam, General Secretary, AIPSN gsaipsn@gmail.com, 9442915101 @gsaipsn

 

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Press Release of the statement on AIPSN Response to Draft EIA Notification 2020

Click here for AIPSN-Press-Release-Statement-on-EIA-2020-July3

 

Press Statement on

AIPSN Response to Draft EIA Notification 2020

            It is deeply regrettable that the Union Ministry of Environment Forests & Climate Change (MoEFCC) has decided to press ahead with the Draft EIA Notification 2020 (hereafter Draft EIA 2020), despite many Organizations and Experts calling for extending the period for responses beyond 30 June 2020 given the continuing restrictions related to the Covid-19 pandemic. These restrictions have prevented grassroots level consultations, especially with nature-dependent and marginalized communities, that are required for fruitful public participation in discussions on Draft EIA 2020.

Nevertheless, the All India Peoples Science Network (AIPSN), comprising 40 Peoples Science Organizations in 25 States/UTs, has held extensive consultations to the extent possible and has submitted its considered Response to Draft EIA 2020. While our response (click here or here ) contains clause-by-clause critiques and recommendations, a brief summary of salient points is presented here.

            The present Government, since it first took office in 2014, has embarked on a determined course to severely dilute Environmental Regulations and norms in India, and weaken monitoring by regulatory agencies, so as to advance the “ease of doing business” and give corporates greater freedom to set up and run projects at the cost of the natural environment, and at the expense of lives and livelihoods of hundreds of millions of people dependent on it.  Environmental Regulations and systems for appraisal, approval and monitoring of projects have been painstakingly built up over the years under pressure from civil society organizations, affected communities and experts in the environmental and broader scientific community, all of whom have sought sustainable development while protecting the natural environment which sustains life itself.

Unfortunately, far from tightening these norms and closing the many loopholes that have crept in under pressure from vested interests, Draft EIA 2020 has further weakened environmental regulation, and reduced transparency and accountability. In fact, several provisions specifically seek to circumvent National Green Tribunal (NGT), High Court and even Supreme Court rulings based on EIA 2006 and objecting to many Orders/Notifications issued from time to time.

The major objectionable changes sought to be introduced through Draft EIA 2020 include:

 

●        re-classification of various types of Projects, with a number of them potentially having considerable environmental impact being placed in Category B2 under which no Appraisal or public consultation/hearing is required: eg. Oil and Gas exploration (such permission was given in the fertile Cauvery delta region leading to farmer uproar in Tamil Nadu and subsequent withdrawal of permission), Water Aerodromes, River Waterways and other projects requiring dredging of river beds (cleverly dropped in Draft EIA2020 from the definition of “capital dredging” which it clearly is), Construction and Area Development Projects of 20,000-50,000 sq.m area (NGT had earlier ruled against an attempt to exempt projects of 20,000 to 150,000 sq.m , therefore this attempt in Draft EIA2020); and “linear projects” which would only be appraised and public consultations held in those districts of National Park, Sanctuaries or Coral Reefs through which they pass (exempting huge tracts through which pipelines etc may traverse)

●        another set of Projects with significant environmental impact are now exempted from obtaining Prior Environment Clearance, (a provision originally meant for artisan groups such as Potters etc for excavating of clay) such as Solar Photo Voltaic (SPV) power projects, Solar Thermal power plants, Solar Parks, coal and mineral exploration, and another vague category of “R&D Projects,” Minor Irrigation Projects of upto 2000 ha command area, Hazardous Waste recycling units etc, Defence and Explosives Manufacturing Units,

●        defence and national security projects, including projects deemed to be “strategic” by the Central Government,” are to be exempt from Appraisal and public hearings, with the added proviso that that “no information relating to such projects shall be placed in public domain:” classified information of military/security projects need not be disclosed, but external aspects with impact on environment such as area covered, construction in coastal regions, air pollution and/or liquid effluents discharged etc should be disclosed and appraised; further, the declaration of some projects as “strategic” is vague, non-transparent and open to misuse for hiding all kinds of projects from public scrutiny

●        notice period for public to respond to Public Consultations reduced from the earlier already inadequate 30 days to a mere 20 days now

●        among the most egregious provisions of Draft EIA 2020 related to violations i.e. projects starting construction or operations or expansion/modernization without receiving prior Environment Clearance (EC) would henceforth be given post-facto EC and permitted to continue after paying small fines: (the Vizag LG Polystyrene plant was operating without EC and was seeking post-facto approval) NGT and Supreme Court  have repeatedly ruled post-facto EC to be violative of environmental laws, and Draft EIA 2020 attempts to subvert these rulings by incorporating such provisions in the Notification  

               

 

For clarifications contact:

P. Rajamanickam  9442915101    D. Raghunandan  9810098621

 

 

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Comments and observations from AIPSN on draft EIA notification 2020

Click here to see the email submission of this response to MoEF&CC

Click here for the pdf of the submitted response

AIPSN Response to Draft EIA Notification 2020

AIPSN Organization, is a Network of 40 major State-level Member Organizations and is the largest network of organizations working on science and society issues focusing mainly on S&T policy, impact on people particularly the poor and marginalized, and promotion of scientific temper. We were among those who had asked for an extension of the earlier deadline for submitting responses to the Draft EIA Notification 2020 to the Ministry of Environment, Forest and Climate Change (MoEFCC) and are grateful for the extension till 30 June 2020. However, it would have been better if some more time had been given to enable wider consultation and more intensive discussions, which have been highly constrained during the Covid19 pandemic and the various restrictions imposed during it. In any case, we are submitting our Response based on internal deliberations and discussions with different grassroots groups and communities within the constraints of time and Covid19-related restrictions.

In broad terms, we have been observing that the MoEFCC has been issuing various notifications and orders, besides taking many decisions that dilute earlier environmental regulations. Perhaps these steps are being taken because the Union Government feels that this will assist in raising the rank of India in international “Ease of Doing Business” indices. However, in our considered opinion, these dilutions have had a negative impact on the environment and on the lives and livelihoods of hundreds of millions of people dependent on it. It has also emboldened manufacturing, mining and infrastructure industries to start projects and conduct operations in an environmentally destructive manner and without consideration for affected communities. We feel the Draft EIA Notification 2020 too is yet another step in the same general direction and further dilutes rather than strengthens environmental regulations in India which is the true mandate of the MoEFCC. We also wish to point out that all these measures put together will have a cumulative impact on India’s Sustainable Development Goals targets which the country has committed itself to in international fora.

With this background, we offer the following responses to different specific provisions in the Draft EIA Notification 2020 (henceforth Draft EIA 2020) for your consideration and also insist that the responses received and discussions be placed transparently in a public accessible website.

 

  • Introductory Paragraphs: At the outset, Draft EIA 2020 begins by giving a background referring to the earlier EIA Notification 2006, the necessity it spelled out for Prior Environmental Clearance (Prior-EC) by the Centre or the concerned State, the 2017 Notification dealing with violations especially starting construction, undertaking expansion or making modifications, and various Judicial and NGT rulings calling for strengthening of monitoring and compliance. It is then stated that the main purpose of Draft EIA 2020 is to “lay down the procedure to bring such violation projects under the regulations in the interest of the environment at the earliest point of time rather than leaving them unregulated and unchecked, which will be more damaging to the environment.” However, detailed perusal of the different provisions made in Draft EIA 2020 show, as discussed further below, that in fact Draft EIA 2020 does not strengthen compliance with environmental regulations but dilutes these very provisions and condones violations, thus weakening environmental protection and regulation.

 

2)  Clause 3: Definitions– Some definitions in Draft EIA 2020 have serious implications. While these have discussed under relevant Clauses where they appear, brief mention may be made here at the outset itself.

 

  1. Clause 3(8) Capital Dredging is defined as “removal of virgin material from the sea bed” alone, and does not cover non-maintenance dredging of river beds, contrary to EIA Notification 2006 which covered both. This is important because capital dredging of river beds for new projects can have considerable environmental and social impact especially on fishers and others. It is strongly urged that the term Capital Dredging include sea as well as rivers and other fresh water bodies.
  2. Clause 3(16) Corporate Environmental Responsibility (CER) defines it to mean that part of the Environment Management Plan (EMP) which the project holder is mandated to implement in the immediate surroundings of the Project arising ether out of the public consultations/hearings or the EIA conducted for the Project. This is an unnecessarily restrictive definition of CER. The EMP covers what the Project holder is required to do as part of the Project itself and should be counted as part of Project Costs, whereas CER should be what the project holder does over and above the EMP as a part of the company’s responsibility towards the environment and society in general, much like Corporate Social Responsibility.

 

  • Clause 4(3) defines Permissible Construction work before Prior-EC/EP as erecting fencing around the project site, but allows “leveling of land without tree felling” and “geo-technical investigations if any.” Levelling of land can fundamentally alter the use of the land after such activity and should not be permitted. Geo-technical investigations which could include test-wells, mineral prospecting could also have serious, even irreversible impact on the environment and should not be permitted without Prior EC/EP.

 

  • Clause 5. Category B2 Projects exempt from Appraisal and Public Hearing     Several types of Projects and activities have been placed by Draft EIA 2020 under Category B2 under which no examination by the Appraisal Committee at either Centre or State/UT level is required, and Prior-Environment Permission (Prior-EP) may be obtained at the relevant level without such Appraisal. Such Projects are also exempt from the requirement for Public Hearing/Consultation. Various types of Projects or Activities placed under Category B2 as Listed in the Schedule include many Projects/Activities with significant impact on the environment, as well as in most cases and on human lives and livelihoods as well, and hence require EIA, Appraisal and Public Hearing. Therefore, the following types of Projects/Activities listed in the Schedule under Category B2 should be shifted to Category B1 (or as otherwise indicated) requiring EIA, Appraisal and Public Hearing, with brief justification for such a shift with additional comments being offered against each:

 

  • Item 2a) Oil & Gas Exploration: Even exploratory drilling can have serious environmental and related human impact as evidenced by public protests in the fertile Cauvery delta region in Tamil Nadu against permissions given earlier this year. The very recent blowout and fire at OIL Well No.5 in the Baghjan Oil Fields also saw an adjacent exploratory workover, with subsequent order by the Assam State Pollution Control Board to close all OIL wells in the area in view of the perceived risk in the whole region, although the order was later withdrawn for reasons best known to them. Further, if exploration yields positive results, this increases likelihood of EC being granted for actual drilling and operation of oil/gas wells with even further environmental impact especially in ecologically sensitive areas. Thus such Projects/Activities be shifted to Category B1.

 

  • Item 10f) Foundries, Rolling Mills etc: Such Projects, which are not too small, may also be problematic and may be shifted to B1.

 

  • Item 16) Chlor-Alkali/Halogen Units: Plants with capacity < 300 tons/day have been placed in Category B2 provided they are located within Industrial Estates. However, since many Industrial Estates are located near population centres, or population centres have come up near these Estates, proper EIA and Appraisal should be done under Category B1.

 

  • Item 32) Water Aerodromes for Commercial Use can have considerable environmental impact on coastal or river/lake ecosystems and therefore should be removed from Category B2 and placed in Category B1.

 

  • Item 34) Various EEZs, Industrial estates: Estates/Zones over 500 ha and without any Projects of Categories A and B1, along with Estates/Zones of any area if it houses at least 1 Category B2 Project, are in Category B2 which is an over-generous leeway given, for instance Estates/Zones of massive size with potential for causing huge environmental damage would be exempt from appraisal! Only Estates/Zones under 500 ha with only Category B2 Projects should fall under this Category.

 

  • Item 37) Capital Dredging for Inland Waterways Projects can have considerable ecological damage along river banks and river beds and require Appraisal. Anomaly arises in the case of Inland Waterways classified as B2 because “Capital Dredging” has been defined wrongly as applying only to sea-based projects (as discussed above), so these should be shifted to Category B1.

 

  • Item 42) Construction & Area Development Projects have been a contentious issue for long. The government had earlier exempted all area development, housing and other construction projects between 20,000 and 150,000 sq. metres from the need to obtain environmental clearances, placed them under the purview of local authorities which would integrate environmental requirements into building bye-laws and approvals. This was however overruled by the NGT as a violation of the 2006 Notification. Draft EIA 2020 now attempts to skirt this ruling by placing Projects of 20,000-50,000 sq.mts of built-up area in Category B2 and exempting them from Appraisal, while requiring only Projects of 50,000-1,50,000 sq.mts of built-up area to seek Appraisal. Such Projects have also been exempt from Public Hearing. It is recommended that all Projects having more than 20,000 sq.mts build-up area be placed in Category B1, and all Projects with built-up area more than 1,50,000 sq.mts be placed in Category A.

 

  • Clause 5(7) Defence, Security and “Strategic” Projects This clause specifies that all projects concerning national defence and security, or involving “other strategic considerations as determined by the Central Government,” shall require prior EC/EP from the Ministry whatever the original category of the project, which is understandable since defence is exclusively a Union subject. However, it is disturbing that the clause further states that “no information relating to such projects shall be placed in public domain.” There are two distinct unacceptable provisions here.

First, many such projects such as shipyards, testing ranges, coastal military bases etc can and do have considerable ecological and social impact. It is a patent infringement on the right to life and livelihoods of affected communities that they do not have access to any information based on which they could object to or otherwise voice their concerns with respect to such Projects. Military or intelligence matters relating to specific projects need not be placed in the public domain but other relevant facts such as area and number of villages to be covered, discharges into the air and onto land, sea, river or other water bodies etc should be disclosed so that affected parties may assess potential ecological and social impact.

Secondly, blanket authority bestowed on the Central Government to deem any project as involving “strategic considerations” allows for too much leeway to arbitrarily declare all sorts of Projects such as, for instance, nuclear power plants, oil wells and rigs etc as “strategic” and hence escape public scrutiny.

Non-military facts relating to military/security Projects should be made available in the public domain, and this Clause should not permit declaration of other types of projects as “strategic.”

The related provision in Clause 14(1)c stating that the “Regulatory Authority may decide on the feasibility and requirement of Public Hearing and/or consultation in the case of defence projects” should also be amended in line with the above.

 

  • Clause 7 State/UT Environment Impact Assessment Authority It is often found that the State Pollution Control Board (PCB) acts as the Secretariat of the State/UT EIA Authority, and Project Proponents often apply to it for, and obtain, permission to set up or operate, even without Prior EC/EP, as happened with the recent LG Polymers Vishakhapatnam. Case. A specific para should therefore be added to this Clause to the effect that State/UT PCBs or any other Agency are not authorized to act on behalf of the State/UT EIA Authority and are not empowered to grant EC/EP

 

  • Clause 14(2) Public Consultation exempts a wide variety of Projects from Public Consultations whether in the form of written submissions or in the form of Public Hearings. This is not only highly objectionable from the point of view of environmental protection which is the goal of the various Environmental Acts and the EIA Notifications, it is also completely unacceptable in a democracy. As stated while discussing the B2 Category of Projects above, many of these Projects potentially have considerable environmental and social impact, and it is inconceivable that potentially affected people and other stakeholders are not given an opportunity to voice their concerns and objections. Exemptions from Public Consultations/Hearings should therefore be withdrawn for the following types of Projects.
  • Projects covered by this include “all Category B2 Projects and activities,” already discussed such as No.s 10(f), 16, 17, 19, 20, 21, 23, 24, 25, 27, 36, 40 within Notified Industrial Estates, and No.s 42 and No.43 (Construction and Area Development Projects, and Elevated Roads respectively) in the Schedule, defence/security and other “strategic” Projects as discussed above, and “all linear Projects under item 31 (oil and gas pipelines) and 38 (Highways) in Border Areas.”
  • It may specifically be noted that highways in border areas need not be linear, especially in mountain areas and may indeed have considerable environmental impact in ecologically sensitive areas such as in mountains, glacial areas etc.
  • Further, it is stated that for “linear projects” passing through a National Park or Sanctuary or Coral Reef or other Ecologically Sensitive Area public consultation “shall be limited to [these district (s)].” As is well known, such Projects can also cause substantial ecological damage in adjoining districts as well, so this provision should be withdrawn.
  • Such blanket exemptions from public consultations and public hearings are abhorrent under the relevant Environmental Protection Acts and should be dropped from Draft EIA 2020.
  • Appendix-1 Clause 3.1 under the head Procedure of Public Consultation, states that a “minimum notice period of twenty days shall be provided to the public for furnishing their responses,” compared to the 2006 Notification under which this period was 30 days. It is difficult enough for local affected people such as fishers, coastal people, tribals and hill peoples etc to study all relevant documents, without being pushed into a small window of a mere 20 days. It is suggested that the Notice period for public consultations/hearings be extended to 60 days.
  • Public Hearings/Consultations and consent of gram Sabhas should be mandatory in all Scheduled Areas as per the Panchayats (Extension to Scheduled Areas) Act 1996.

 

  • Clause 19 (1) I d: Validity of Prior-EC or Prior-EP for mining projects has been extended from 30 years in EIA 2006 to 50 years covering the entire expected life of the Project, all of which has been inexplicably placed under Construction/Installation phase.  During this prolonged period, most of which would definitely cover operation of the mine, all sorts of changes and modifications would take place, with potential environmental impact. It is recommended that Prior-EC/EP be provided for 30 years after which the project holder be required to seek fresh EC/EP based on updated information.

 

  • Clause 22: Violation Cases These contain some of the most egregious provisions of Draft EIA 2020, effect of which is to gloss over violations, pave the way for their regularization, and enable continuous operation of violators without having to worry about Environmental rules or Regulatory Authorities, all at the cost of the environment. Violations of course, as defined in the Draft EIA 2020 itself, refers to Projects that have started construction, installation or even operations, or expanded or modernized beyond the limits permitted, without Prior Environmental Clearance or Prior Environmental Permission.
  • Clause 22(1) states that violations would be taken cognizance of based on application of the project proponent itself, reporting by any Government authority, found during the Appraisal process, or found during application by the Regulatory Authority. The Clause should be amended to also take cognizance of violations being brought to the attention of relevant authorities by local residents, civil society organizations, lawyers or other stakeholders who have, amazingly, been excluded from this provision.
  • Subsequent Paras of Clause 22 spell out various means and methods for the regularization of such Projects, despite their flagrant violation of Environmental Laws, clearly in the knowledge of the project proponents since any industrialist knows that Prior EC/EP is required. Only those Projects that are simply not permissible in the area concerned, or those Projects that are environmentally not sustainable in the area, in other words such projects that would not have obtained Prior EC/EP had they applied for it, would be closed down. These various means include fines, mandatory environmental remedial measures for damage caused etc.
  • These provisions clearly amount to post-facto regularization of violations and grant of EC as, for instance, is being pursued in the case of LG Polystyrene in Vishakhapatnam which had been operating for years without EC. The effort made by the Ministry in 2017 through a Notification towards the same end, albeit as a one-time amnesty provision, had been struck down by the NGT. The very idea of post-facto EC was declared by the Supreme Court as late as April 2020 to be “in derogation of the fundamental principles of environmental jurisprudence and is an anathema to the EIA Notification.” The attempt by Draft EIA 2020 to give this provision a backing through a fresh Notification is ethically atrocious and is bad in law. These entire provisions should therefore be removed. If at all such a provision is required to be made, in view of the Ministry and regulatory Authority turning a blind eye over the years to perhaps hundreds of such violations, then it should be a one-time amnesty provision with a time frame of not more than 1 year from the date of Notification with a strict stipulation that no future violation will be tolerated at any cost.
  • The same applies to Clause 23 as well.

 

  • . Clause 26: Projects exempt from requiring Prior-EC/EP   Some of the projects covered by this Clause are intended to permit artisanal activities such as extraction of potters’ clay etc. Surprisingly, however, many projects with known and considerable environmental and social impact have also been included under this Clause. It is strongly urged that the following types of Projects be removed from this Clause and placed under the Schedule for Category B1 or B2 Projects (after being amended as suggested here):
  • Clause 26(14): Solar Photo Voltaic (SPV) power projects, Solar Thermal power plants and Solar Parks, which have well-known environmental impacts including diversion of agricultural land, excess demand on subsoil water etc.
  • Clause 26(15): R&D Activities for Activities in Schedule is too broad a categorization. For instance a Fast Breeder Reactor or a Test Well may also be described as an “R&D Project.” This sub-category should be better defined
  • Clause 26(19): Coal and non-coal mineral prospecting which can cause considerable ecological damage, quite apart from the larger extraction projects that may follow
  • Clause 26(21): Minor irrigation Projects with command area upto 2000 ha should not automatically be exempt from Prior-EC/EP
  • Clause 26(24)(a, b): Secondary metallurgy Units are not free of air pollutants, effluent streams and solid wastes including metals, and cannot be exempt from Prior EC/EP
  • Clause 26(24)(c): Recycling Units registered under Hazardous & Other Waste Rules 2016 involve considerable toxic and other wastes, and certainly should not be exempt from Prior EC/EP
  • Clause 26 (25)(a): Re-rolling Mills with Pickling especially of the scale mentioned will certainly involve effluent streams and will require Prior EC/EP
  • Clause 26(36): Defence Manufacturing units or strategic units for explosives etc: the idea that Units under the Ministry of Defence do not require Prior EC/EP is astounding to say the least, since it can be nobody’s case that these Units do not cause pollution. Such Units should be required to obtain Prior EC/EP based on disclosure of such information relating to pollutants generated and measures taken to reduce discharge of pollutants as per relevant industry standards. This is especially so since the Schedule (Item 30) lists explosives etc Projects under Category B1, assuming these to be non-Defence Units?
  • Clause 26(39): Maintenance dredging should clarify that (as per the suggested amended Definition of Capital Dredging) that this does not apply to dredging and removal of virgin material from beds of rivers, lakes or other fresh water bodies.

For clarifications contact:

  1. Rajamanickam 9442915101 D. Raghunandan  9810098621
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AIPSN Statement on Assam Gas Blowout and Fire

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AIPSN Statement on Assam Gas Blowout and Fire

PSU Oil India Limited’s (OIL) natural gas Well No.5 in its Baghjan Oil Fields in Assam’s Tinsukhia District in Eastern Assam, less than a kilometre from the ecologically rich and fragile Dibru-Saikhova National Park and Biosphere Reserve with several other ecological hotspots in close proximity, suffered a blowout i.e. an uncontrolled release of natural gas, on 27 May 2020, throwing up huge quantities of gas at high pressure into the air. On 9 June 2020, due to yet undetermined reasons, fire erupted at the well and spread quickly over a distance of at least 5km towards the north-east.  The fire has caused deaths of at least 2 firemen, and maybe others in nearby villages, and wreaked havoc on the surrounding ecosystem with extensive damage to human life, habitat, livelihoods and well-being, especially affecting crops, soil, vegetation, water bodies and aquatic life, wildlife especially birds, and micro-organisms. Many nearby houses have been gutted and over 7000 villagers have been evacuated to 12 relief camps.

OIL had called in experts from the Singapore-based Alert Disaster Control Company to assist in controlling the blowout, a day before the fire broke out. Now additional experts from the US and Canada have also been flown in. Heavy machinery and other equipment are being brought from ONGC facilities elsewhere in the region and in AP. An action plan has apparently been prepared and operations are underway to both control the fire and cap the well, a process expected to take about 4 weeks.

This still unfolding incident has once again focused attention on several inter-related aspects namely, frequent industrial disasters and poor safety record of companies in India, continuing dangerous dismantling of environmental regulations by the Central Government, leading to recurrent massive ecological damage along with loss of human lives, livelihoods and habitat.

 

Blowout and Fire

Baghjan 5 is one of the most prolific gas reservoirs of OIL. It produces around 80,000 standard cubic metres per day (SCMD) of gas from a depth of 3,870 metres at a pressure of 4,200 pounds per square inch (PSI), much higher than the normal producing pressure of around 2,700 PSI.

Oil or gas blowouts are relatively rare in modern times, but not unknown, due to improved drilling techniques, better drilling fluids to contain well pressure, and advances such as blowout preventers (BOP pronounced B-O-P not bop). BOPs are extremely heavy valves or similar mechanical devices which physically sit on the well mouth and prevent any venting of gas, oil or internal piping etc from the well, while also enabling pumping in of drilling fluids to maintain pressure balance. Changes in pressure of gas or oil in wells due to many possible reasons cause ‘kicks’ which can be sensed by operators through several indications during drilling operations. If such ‘kicks’ are not controlled, ultimately through deployment of the BOP, then a blowout results.

According to OIL, servicing and repairs of the well-head were taking place at Baghjan 5 on the fateful day.  The well had been ‘killed,’ i.e. production had been stopped and the BOP had been removed to facilitate repairs. Simultaneously, ‘workover’ or test-drilling was underway at an adjacent new sand or deposit. Suddenly, gas started oozing out of Well No.5 and soon broke through the temporary cement barrier and turned into a full-scale blowout.

Again according to OIL spokespersons as quoted in several publications, the first response to the blowout, namely capping the well by replacing the BOP under cover of a water umbrella, continues to pose a huge challenge and high risk because of “very limited space and non-availability of open space above the well head.” This points to a defective design of the well and rig set up. OIL will now have to deploy a heavy hydraulic transporter for capping the well, then pump in drilling mud, and provide for the water umbrella by building a special temporary reservoir in the nearby Dangori river and laying pipelines to the well. This further underlines poor standing arrangements for emergency situations.

Why and how the blowout happened in a killed well is being investigated by OIL, although 2 OIL employees at the site have been suspended for undisclosed reasons. The Assam Government has set up an Inquiry by a senior bureaucrat into the incident.

However, only an independent Inquiry by a Committee of Experts, free of pressures from the powerful PSU OIL, the Central and State Governments, and other regulatory authorities, preferably under judicial supervision, can properly bring out all the reasons behind the disaster and the responsibilities of various organizations and institutions involved.

Since OIL has numerous wells in the region which contribute all of OIL’s crude oil and close to 90% of its natural gas, the lack of OIL emergency response teams and infrastructure within the region is a matter of grave concern, and prompted massive protests in all these locations. OIL’s apparent and continuing lack of in-house expertise in oil/gas blowouts and similar emergencies despite over 100 years of operations in India, first as Burmah Oil, then in Joint Venture with OIL in 1961 and finally as a fully government-owned entity since 1981, as demonstrated in earlier blowouts in the region in 2004 and other accidents, is another matter of concern. OIL needs to urgently address safety and emergency preparedness and response, especially in the 18 other wells in the Baghjan Oil Field and a total of 59 wells in Assam, where public anger and fear is at a peak, after the weak and delayed response by OIL to the Baghjan disaster.

 

Damage to human life, livelihoods, habitat and health                

                The gas blowout spewed out a mix of propane, methane, propylene and other gases which spread over a fairly wide area about 5km in the windward direction. For many days, villagers complained of eyes burning, headaches, gas condensate settling on crops, land and water bodies. While several villagers have reported health complaints, there are to date no confirmed deaths of villagers from the gas or the subsequent fire. Monitoring of health effects will obviously have to continue over an extended period of time. Families of two firemen who apparently died by drowning while attempting to escape from the fire have been assured compensation by OIL.

Around 50 houses in the vicinity have been fully or partially burnt and a few thousand families are now sheltered in relief camps. Rehabilitation of all these families along with reconstruction of homes and compensation for damage incurred will obviously have to follow soon.

Many more people too have been badly affected by damage to their crops, land, livestock and livelihoods. Gas condensate and combustion residues carried over a wide area by wind have been deposited on land, agricultural produce and water bodies. Land used for cultivation of areca nut, banana, tea and bamboo, may have suffered considerable damage even affecting future crops. The Brahmaputra and several smaller rivers are in flood during the monsoons, and have brought condensate into farm lands, water bodies and even homes. The famous Maguri-Motapung Wetlands or beel, located inside the Dibru-Saikhowa Reserve and only 2km from Baghjan 5, has been badly affected, threatening the food supply and livelihoods of almost all households around the beel. Considerable harm has thus been done to human livelihoods and habitat, and to the highly sensitive ecology of the area.

 

Ecological damage

The entire region is home to many reserve forests, wildlife sanctuaries, protected water bodies, forests and other ecosystems. The Dibru-Saikhowa Biosphere Reserve in Assam links up with Namdapha National Park and Deomali Elephant Reserve in Arunachal Pradesh, together forming a large wildlife corridor in the Indo-Myanmar Biodiversity Hotspot.

The Dibru-Saikhowa Biosphere Reserve also includes the Maguri-Motapung Wetlands, rich in aquatic flora and fauna including the endangered Gangetic Dolphin, at least one of which has been found dead. Waters in the Wetland have reportedly turned blue and yellow due to the contamination. The Reserve and Wetland are famous for their resident as well as migratory birds, butterflies, wild cats and feral horses. Since the Reserve is close to the confluence of the Brahmaputra and other rivers of the North-East such as the Lohit, Dibru, Dibang and Siang, contamination from condensate and combustion residues is likely to spread widely through these rivers. Substantial parts of this ecosystem may even have suffered permanent impairment. Damage to wildlife, bio-diversity, water bodies and the broader ecosystem in the area requires systematic and careful assessment so that remedial action may be planned and initiated.

The management plan for the Maguri-Motapung beel highlights oil leaks as a potential hazard to the ecosystem and, having seen the damage from a gas blowout, one can imagine the impact of a blowout at any of the oil wells in the area which would be far greater. The National Board for Wildlife (NBW) during earlier inspections in the area had warned against further expansion of oil drilling activities in this region.

 

Reckless Environmental Clearances

Ironically though, the same NBW recently on 24 April 2020 permitted use of part of the nearby Dehing-Patkai Elephant Reserve for opencast coal mining by North-Eastern Coal Fields (NECF), a subsidiary of Coal India Limited, and a much wider area for underground coal mining. This underlines a sharply increasing trend encouraged by the Central Government to indiscriminately allow extractive industries and infrastructure projects in forests, sanctuaries and protected areas, and to dilute rules and regulations to enable the same.

Thus, the Ministry of Environment & Climate Change (MoEFCC) gave Environmental Clearance as recently as 11 May 2020 for exploratory drilling by OIL for hydrocarbons in as many as 7 locations in the Dibru-Saikhowa National Park. OIL justified this by saying it would “not enter the National Park” but use Extended Reach Drilling (ERD) from a plinth 1.5km outside the Park boundary at a pre-existing well head but reaching into a new well drilled 3.5km under the surface of the Park. Commentators have alleged that this clearance was granted without careful scrutiny by experts. Such extensive exploration and subsequently extraction of oil and/or gas further threatens the sensitive ecosystem of this area and exposes the region to much higher risks of accidents such as the recent Baghjan blowout and fire.

Actually, whether the actual well mouth is inside or just outside the Park, matters little if a blowout or leak occurs. At Baghjan for instance, gas from the blowout and the resultant fire spread over several kilometres of Park and Wetland, and affected bodies and ecosystems far and wide due to condensate being carried in the wind and entering river systems. The hasty and blanket clearances given by MoEFCC without rigorous environmental assessment by experts also emboldens project holders, especially large and powerful PSUs and corporate houses, to ignore environmental considerations, abandon precautionary measures, and turn a deaf ear to public concerns and protests. The Draft EIA Notification 2020 proposes to regularize such blanket environmental clearances for exploration.

To add fuel to the fire of reckless hydrocarbon exploration and extraction, the Directorate General of Hydrocarbons (DGH) announced an Open Acreage Licensing Policy (PALP) in June 2017 which essentially allows private entities to apply for exploration in sites of their choosing. Bidders are required to have only a mere 1 year experience in exploration and related activities, opening the door to inexperienced and unqualified companies merely chasing profits at the cost of the environment and local populations. If even large 100 year-old companies like OIL find it difficult, or do not care, to take adequate safety precautions, one shudders to think what may happen if rank novices enter this sector.

 

Demands                            

The following demands arise from the above:

  • Independent Inquiry by a Committee of Experts led by a sitting Judge or under judicial supervision, should look into:
    • the design and layout of OIL Baghjan Well No.5 and related infrastructure, safety measures and emergency preparedness at the site and in the Baghjan Oil fields in general
    • operational errors and capabilities of OIL personnel on the spot at the time of the blowout, especially of those related to safety and emergencies
    • what if any early warning indications or ‘kicks’ were detected and measures if any taken to prevent the blowout
    • reasons for failure to quickly cap the well after the blowout, and
    • how and why the fire was caused, and precautions if any, taken to prevent it.
    • possible contribution to the blowout by the adjacent workover in a new ‘sand’ outsourced by OIL to M/S John Energy
  • Inquiry Committee should also:
    • assess and recommend compensation and other measures to be undertaken by OIL and costs thereof related to loss of life, livelihoods, habitat and health problems caused by the Baghjan gas blowout and fire
    • assess and recommend measures to be undertaken by OIL and costs thereof related to environmental damage in the area and remedial action
  • Safety Audit should be conducted, preferably by the above Independent Expert Committee, especially as regards emergency preparedness and response, of all other wells in the Baghjan Oil Field and at other OIL sites in the North East
  • OIL be required to deposit with appropriate authorities an amount of Rs.100 crore to cover costs of interim compensation to affected persons for loss of life, homes, crops, livestock and livelihoods, and for immediate clean-up of worst affected parts of the Dibru-Saikhowa National Park and Maguri-Motapung Wetlands pending more detailed assessment by the Inquiry Committee

 

15 June 2020

 

Contact

D.Raghunandan 9810098621

Isfaqur Rahman 7002525784

 

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AIPSN Statement on LG Vizag Styrene Leak

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AIPSN Statement on LG Vizag Styrene Leak

Styrene vapours leaked from the LG Polymers Plant in R.R.Venkatapuram, Vizakhapatnam District, in the early hours of 7th May 2020. The Plant manufactures different materials such as Engineering Plastics, Polystyrene and Expanded Polystyrene using Styrene as raw material, bringing the Plant under the Manufacture, Storage and Import of Hazardous Chemical Rules, 1989 and the Chemical Accident (Emergency Planning, Preparedness and Response) Rules 1996.   The Plant had been shut since 25th March under nationwide Lockdown announced by the Central Government.    Many aspects related to the circumstances of the Leak and its possible causes have come to light from local and national media, from analysis by technical experts, and information from the international literature about styrene and production of various materials from it.

 

Causes and Effects of Leak

Several thousand tons of liquid Styrene was stored in tanks at the plant. Styrene storage should be at 20 degrees C, but temperature controls at the tank were apparently malfunctioning. It appears that chemical inhibitors such as Tetra-Butyl-Catechol (TBC), used to prevent self-polymerization of styrene, had not been added in the tank, and sufficient quantities were also not available in the plant, although both are standard practice and mandatory as for hazardous industries. Other prescribed precautions and maintenance had also not been taken, and some other sensors and controls were also in poor condition. Further, safety audit, safety drills and trial runs were not conducted as they should have been after prolonged shut-down.

Sirens meant to alert nearby residents of a leak, were not sounded and no timely guidance was issued regarding precautions or remedial measures either to nearby residents or the authorities.

The sudden imposition of the Lockdown by the Central Government may also have contributed to these problems. This was implicitly acknowledged by the Centre issuing such instructions to all industries, however only after the LG plant leak. At the same time, LG Polymers had passes and time during the lockdown to take precautionary measures, but apparently did not.

Thus LG Polymers appears to be responsible for serious lapses and gross negligence, directly contributing to the massive Leak.

On 7th May, temperatures in the Styrene tank started rising, triggering auto-polymerization and leading to a runaway reaction with rise of temperature and pressure, rate of vaporization and exothermic reaction releasing heat, all feeding each other. At some point, the safety valve blew, releasing styrene vapours high into the air over a long time till the leak was brought under control.

Styrene vapours spread over about 3km from the plant in the direction of the wind, and modeling suggests that styrene levels in the air may have reached 1100ppm in the immediate vicinity of the Plant, 130ppm at 1km distance, and 20ppm at 2-3km from the plant. Although Styrene exposure at low levels may pass out of the body through urine, higher exposure levels than, say, 100ppm over 8 hours specified as maximum in factories, are known to be toxic. However, short- and long-term effects of the extremely high levels of exposure seen during the Leak are not known, and need to be rigorously monitored and necessary treatment extended.  Effects on animals, plants, water bodies and soil also need to be monitored and remedial action taken.

 

Regulatory Violations

The most shocking aspect concerning the LG Polymers Vizag Plant is that it had been operating without Environment Clearance (EC) from 2004 to 2017, either from the Union Ministry of Environment & Climate Change (MoEFCC) or from the State Environment Impact Assessment Authority (SEIAA) as required under the EIA Notification 2006. LG applied for EC when it sought to expand capacity of the plant in 2018. AP SEIAA objected stating ECthat the plant did not have prior EC. In an Affidavit filed with SEIAA in May 2019, LG admitted this violation but stated that it had obtained permission from the AP Pollution Control Board. SEIAA referred the case to MoEFCC stating that the plant fell under Category A requiring EC from MoEFCC under the “Violations” category. At some point, LG Polymers seems to have withdrawn its application for expansion, and MoEFCC has shown the case as “Deleted” on its website in November 2019 with a noting that the company “seems to be no longer interested.” However, the Plant continued operating without Environmental Clearance, but with permission from APPCB.

APPCB has no authority to grant such permission without EC from either MoEFCC or SEIAA under the EIA notification 2006. It may further be noted that the Draft EIA Notification 2020, currently awaiting public response, seeks precisely to legalize all such violations and grant them post-facto approval. The LG Polymers case is a text book case why such violations should not be tolerated and why the relevant provisions in Draft EIA Notification 2020 should be withdrawn.

NGT and the Supreme Court have both often ruled against post-facto Environmental Clearance, with SC observing that “the concept of an ex post facto EC… is an anathema to the EIA Notification.” The role of APPCB, especially how it granted permissions to LG Polymers knowing that the company did not have prior EC, is a serious matter, and should be investigated and action taken.

Taking suo motu notice of the LG Polymers Vizag leak, NGT has slapped punitive damages of Rs.50 crore on LG Polymers pending a full assessment of the harm to life and environment caused by the leak, on the grounds that there is a prima facie “failure to comply with the Rules and other statutory provisions… [and that] the statutory authorities responsible for authorizing and regulating such activities may also be accountable for their lapses.”

It may also be noted that the Plant was situated in the midst of heavily populated residential areas, which was not the case when the Plant was established in 1961. Over the years, residential colonies were permitted to come up in the plant vicinity, which is also in violation of regulatory provisions. Here, the Vizag city authorities and State government should have exercised greater vigilance and prevented the settlements coming up.

 

Demands            

In light of the above, AP Jana Vijnana Vedika and All India Peoples Science Network demand that:

 

  • detailed and impartial inquiry, free of influence by Central or State governments or related agencies, be conducted by the Expert Committee appointed by NGT on the Leak;
  • the LGT Inquiry Committee should identify the direct and proximate causes for the Leak, identify lapses and negligence by LG polymers, and fix responsibility as regards:
    • condition of the plant and likely failure of different controls, sensors and gauges
    • failure to sound the siren to warn nearby residents and also to provide timely guidance for precautionary and remedial measures to be taken by residents
    • adequacy of maintenance activities and results during the lockdown period
    • flaws in plant operations especially on May 6 and 7 contributing to the Leak
  • violations of the relevant Regulations governing hazardous materials and industries
  • the LGT Inquiry Committee should also look into the impact of the Leak on human health, milch animals, poultry and other animals, vegetables, plant life, water bodies and soil in affected areas, with assistance of such medical, scientific and technical experts as required, and also recommend rigorous monitoring of this impact, treatment and remedial measures as required at the cost of LG Polymers
  • based on the above, the NGT Inquiry Committee may also recommend compensation by LH Polymers to workers and affected people
  • based on all the above findings, NGT may impose suitable costs on LG Polymers to cover compensation, remedial action, health monitoring and treatment, and penalties
  • Inquiry Committee may also identify violations of the applicable EIA Notification 2006 and also identify failures or collusion by regulatory authorities especially APPCB in this regard and, based on this, NGT may recommend penal or other action in this regard
  • since a Magisterial Inquiry Committee and other inquiries have also been set up, it is strongly urged that terms of reference of these do not overlap with those of the NGT Committee, and the former be directed to focus on subjects not covered by the NGT
  • responsibility should also be fixed for allowing residential areas to come up in the vicinity of the Plant in violation of Regulations and various orders of the Supreme Court and NGT
  • the LG Polymers Plant should be shut till it obtains Environmental Clearance from the MoEFCC and, if granted, shifted to a suitable industrial estate/area at least 5km away from human habitation
  • workers at the LG Polymers Vizag Plant should be paid in full for the period of lockdown and till such time as final decision is taken regarding its closure or re-starting after shifting

 

 

 

For further details contact

D.Raghunandan 9810098621

Srinivas 9848025687

P.Rajamanickam AIPSN Gen Sec 9442915101