Critique of Central Pollution Control Board (CPCB)’s Report on Timarpur-Okhla Waste to Energy Incinerator Plant

Critique of Central Pollution Control Board (CPCB)’s Report on Timarpur-Okhla Waste to Energy Incinerator Plant of Prithivraj Jindal’s JITF Urban Infrastructure Limited (Jindal Ecopolis)*




Waste Burning at Jindal’s Okhla Site: 2050 tons per day
Source of Waste: Municipal Corporation of Delhi (MCD) & New Delhi Municipal Council (NDMC)

Delhi’s Waste generation per day: 22526.265 tons per day (2008 CPCB study)
Generation of waste in the whole country: 362716.098 tons per day (2008 CPCB study)

April 2012
ToxicsWatch Alliance (TWA)
New Delhi

*Review of CPCB report by Anant Trivedi, Member, Technical Experts Evaluation Committee, CPCB is annexed
Critical Analysis of report of the Technical Experts Evaluation Committee, Central Pollution Control Board (CPCB) on the Timarpur-Okhla Waste to Energy Incinerator Plant

• The 31 page report of CPCB communicated on March 22, 2012 does not provide complete background of the Timarpur-Okhla Waste to Energy Incinerator Plant of Prithivraj Jindal’s JITF Urban Infrastructure Limited (Jindal Ecopolis). The report is based on three meetings of the Technical Experts Evaluation Committee held on April 26, 2011, August 11, 2011 and September 22, 2011 under the chairmanship of Prof. S P Gautam, Chairman, CPCB.
• The weakest part of the report is that it has done the technical evaluation of the plant after it has become functional. It should have been done prior to granting it permission. Representatives of GTZ (German Technical Cooperation) led by Dr. Juergen Porst, Senior Advisor stressed the need for a Disaster Management Plan in the very first meeting but it does not find mention in the recommendations of the report. This finds reference in the minutes of the meeting annexed with the report. It underlines the possibility of disaster from the Timarpur-Okhla Waste to Energy Incinerator Plant, which is situated in a residential area. It is noteworthy that a hazardous plant in Bhopal’s residential area that led to world worst industrial disaster in 1984 also did not have any disaster management plan.
• In the second meeting of the committee non-cooperative approach of the senior officials of Timarpur-Okhla Waste to Energy Incinerator Plant was condemned. Representatives of GTZ underlined that there was lack of transparency with regard to environmental and health impact on the neighborhood residents. It was also noted that the fugitive emissions and the expected emission of Dioxins and Furans has not been quantified. The characteristic of ash and required standards was not mentioned. Prof. T R Sreekrishnan, Department of Biochemical Engineering and Biotechnology stated that disposal option for incineration instead of bio-methanation proposed for green waste is in violation of what was mentioned in the Environment Impact Assessment report. Dr A B Akolkar, Director, CPCB emphasized that green waste refers to ‘biodegrdable waste’ and as per Municipal Solid Waste (Management & Handling) Rules, 2000 such wastes requires to be treated by composting/anaerobic digestion/vermin composting/other biological processing for stabilization rather than deriving RDF or by incineration. This clearly demonstrates that the Timarpur-Okhla Waste to Energy Incinerator Plant violates the Municipal Solid Waste (Management & Handling) Rules.
• At the third meeting the project proponent apprehended that the information that is submitted to the experts committee of CPCB might be used in the on-going case in the Delhi High Court. At this very meeting, in a shocking instance of ad hoc manner in which the Timarpur-Okhla Waste to Energy Incinerator Plant has been pursued, the project proponent introduced the representatives of Chinese technology providers from Hangzhou New Century Company Ltd of Hangzhou Boiler Group namely, Bian Jun, Zhang Xing Qun, Sun Diting and Zhou Yue and stated in his technical presentation that “ Ash generation shall be 10-15 % of the feed to the boiler and as per the agreement with the MCD the ash shall be disposed in Okhla MSW dumpsite.” There is reference on page 28 of the report that project proponent presented point wise clarification to the issues raised by the expert committee. This clarification does not respond to several issues raised at the earlier meetings of the expert committee such as a disaster management plan, the reason for change of technology after environmental clearance.
• On page 29 of the report, decisions of the expert committee are stated. It records that project proponent’s point wise clarification will be reviewed by the experts committee members. It sought further technical observations within a period of 2 weeks beginning September 22, 2011. After that it concluded that a technical document along with the recommendations shall be forwarded to the Union Ministry of Environment & Forests. It is not clear from the CPCB’s report that project proponent’s point wise clarification has been reviewed by the experts committee members.
• It does not reveal as to on what date was the report submitted to the Union Environment & Forests Ministry. The report admits that it “does not evaluate the requirement or compliance of various clearances from the respective agencies” It disappoints by stating that it is “only based on the information provided by the project proponent”. It does not disclose the Terms of Reference of the Technical Evaluation Committee. Had this been indeed the case then this report would have appeared to be no more than a brochure or publicity material of the company in question. At many places the report appears incoherent because of inconsistent testimony of the project proponent, Jindal Ecopolis but makes several disclosures about the Waste to Energy Incinerator Plant which was not known earlier.
• The report is inconclusive with regard to the comparison between energy exported from the process and the energy that the process itself requires for its operation. It wants the project proponent to provide plant potential figure by dividing the exported (e.g. sold) energy minus the imported energy by the total energy demand for waste incineration process. Its calculation of the energy efficiency of the controversial plant is yet to be done. The report refers to production of 16 MW (not 20.9 MW) from RDF and biogas but while elaborating it discloses that the plant is not following the RDF and biogas route.
• Its recommendations states, “The proposed WtE plant is located in an urban agglomeration adjacent to populated areas.” It recommends that a provisional consent to operate for three months for trial run only which may initially be given so as to demonstrate that it complies with emission standards as claimed by the project proponent during deliberations before the expert committee at CPCB”. It emerges that these standards are ad hoc because it is based on the promise of the project proponent. CPCB further recommends, “Manual monitoring of stack emissions shall be carried out regularly for a period of 6 months, for parameters such as PM, HCL, SO2 and NOX to cross check with the online emissions values being reported”. It seems CPCB has been persuaded to believe that after 6 months the protest by residents, environmental groups and waste pickers will become silent; therefore, it need not be monitored after 6 months. These recommendations make it appear as if residents of Okhla will have to accept the fate of living in the hazardous environment of the waste to energy incinerator.
• The report reveals that the waste to energy incinerator facility has been designed to handle 10, 000 tons of municipal waste whereas the consumption is expected to be 1400 tons per day. Out of which about 1050 tons of segregated waste is being fed as fuel in the Waste to Energy boilers and the rest is sent to recycling industry or disposed at municipal landfill. On page 8, it is stated that “the rejects from MSW is approximately 253 TPD.” The report does not specify where recycling industry and municipal landfill are located, implying that the project proponent, Jindal Ecopolis has not provided any information about it. On page 3 of the report, it is admitted that the waste will be turned into Refuse Derived Fuel and then it will be combusted or incinerated at a temperature of more than 850 degrees C in order to arrest formation of Polychlorinated dibenzodioxins (PCDDs) or dioxins, a group of organic polyhalogenated compounds that are significant environmental pollutants. But it does not explain how it be ensured that PCDD formation has indeed not happened. Members of the PCDD family bioaccumulate in humans and wildlife due to their lipophilic properties, and may cause developmental disturbances and cancer. It became well known as a contaminant of Agent Orange, a herbicide used in the Vietnam War by USA. Prof. B. J. Alappat, Department of Civil Engineering, Indian Institute of Technology, Delhi underlined that incineration at lower temperature like 850 degrees C will lead to high concentration of volatile organic compounds in flue gases. He complained that the cross section of the boiler furnace was not provided that could have enabled understanding of of the path of flue gases and temperature profiles across the boiler.
• The CPCB report appears oblivious of the 254 page National Implementation Plan (NIP) prepared by Government of India in order to meet its obligation under Article 7 of the UN’s Stockholm Convention on POPs dated April 2011. On page 16 of this NIP, it reads: “The major contribution of PCDD/DF emission is from waste incineration and ferrous and non-ferrous metal production categories followed by heat and power generation sector. Waste incineration has 66.75% share of the total annual releases.” It further states, “The highest amount of PCDD/DF is released into residues 63.12%, followed by air emission which accounts for 32.66% of the total releases” The main source categories include waste incineration.” On page 96 of the NIP, it is stated, “There is no municipal solid waste incinerator operating in India.” It means the municipal waste plant at Okhla is the first of its kind. The NIP admits, “India has limited experience in the environmentally sound disposal of POPs.”The CPCB report fails to recommend “necessary measures to ensure that waste is recovered or disposed of without endangering human health and without harming the environment” as has been done in the EU Directive on Incineration of Waste. It is noteworthy that CPCB was one of the institutions involved in the preparation of the NIP.
• This report is based on the testimony of Jindal Ecopolis. It admits that the toxic leachate will be evaporated and the bottom ash will be land filled. Essentially, both means dumping of cocktail of pollutants in the land and in the air. Is this really a solution to waste management or is just a case of shifting surface waste into underground waste and airborne waste?
• The report is factually incorrect in stating:"In European countries, there are about 460 MSW incinerators with installed capacity of about 50 million tonnes per annum covering about 25 % of MSW generation. Some countries have set up facilities to treat more than 65 % MSW in incinerators" in the CPCB report. The fact is that they annot use incinerators (or even have to shut them down) because of high recycling rates, meaning 35 % by weight. The total amount of waste incinerated was 22% according to Eurostat in 2010. It is decreasing rapidly. There is no country that incinerates 65 % of its waste. The fact is that European Parliament has passed an unanimous resolution to eliminate use of this technology for MSW. The Council of the European Union “reiterated its conviction that waste prevention should be the first priority of any rational waste policy in relation to minimising waste production and the hazardous properties of waste” that finds mention in the EU Directive on the incineration of waste. MCD, Delhi Government and Union Urban Development Ministry do not have any waste prevention policy. EU Directive further states, “The distinction between hazardous and non-hazardous waste is based principally on the properties of waste prior to incineration or co-incineration but not on differences in emissions. The same emission limit values should apply to the incineration or co-incineration of hazardous and non-hazardous waste but different techniques and conditions of incineration or co-incineration and different monitoring measures upon reception of waste should be retained.” The project proponent claims that it is complying with EU standards but it is using the emission limits of the outdated EU Incineration Directive. The new EU directive on incineration IPCC 2010/75/EU has stringent norm in part 3 of annex VI. These standards could be more stringent if there is political will. This means that waste incineration in Delhi is unsafe. The report fails to underline that post incineration the distinction between hazardous waste and non-hazardous waste like municipal waste is lost with adverse environmental health consequences.
• The report indicatively but conservatively discloses the potential threats from numerous toxins that will be emitted. It reads: "The system proposed at Okhla is based on complete oxidative incineration where the input MSW is mainly converted into flue gas (containing gases & fly ash) and bottom ash/residues. The main constituent of flue gas is water vapour, nitogen, carbon dioxide and oxygen. The flue gas also contains particulate matter (fly ash) along with smaller amounts of CO, HCI, HF, NOX, SO2, VOCs, PCDD/F, PCBs and heavy metal compounds. A typical MSW incinerator generates bottom ash of about 10 % by volume (and approximately 20 to 30 % by weight) of the solid waste input. Fly ash quantities are generally much lower compared to bottom ash." At the second meeting of technical experts, Ravi Agarwal of Toxics Link submitted that “Fly-ash collected from air pollution control devices will attract the provisions of hazardous waste management. On page 5, the report reveals that although the environmental clearance was obtained for a plant based on incineration of RDF technology, the same has been abandoned and modified. Earlier, there was a pretention that biomethanation technology is also being used. That pretence has now been given up. “Since no provision has been made for installing bio-methanation plant, the facility shall not be able to handle green waste,” report reveals on page 6. This is a case of violation of environmental clearance conditions which were based on EIA that did its assessment based on in RDF incineration technology. This is blatant deviation from what was claimed in the Detailed Project Report.
• The report reveals that the project proponent is incoherent and inconsistent because while it submitted it has abandoned RDF on page 6, it continues to talk about 1047 TPD of RDF on page 11.
• The CPCB report categorically states on page 5 that the reciprocating stoker type boilers are installed which are designed for incineration of low calorific value municipal waste. The efficacy of such reciprocating stoker type boilers are not known for Indian conditions and requires to be verified. But it does not go further than this as it does not state when and how will the evaluation of its efficacy and its verification be done. The project proponent has claimed that installation of 3 WTE boilers of 45 ton/day will ensure smooth function. Article 3 (4) of EU Directive on Incineration of Waste defines incineration: “‘incineration plant’ means any stationary or mobile technical unit and equipment dedicated to the thermal treatment of wastes with or without recovery of the combustion heat generated. This includes the incineration by oxidation of waste as well as other thermal treatment processes such as pyrolysis, gasification or plasma processes in so far as the substances resulting from the treatment are subsequently incinerated. This definition covers the site and the entire incineration plant including all incineration lines, waste reception, storage, on site pretreatment facilities, waste-fuel and air supply systems, boiler, facilities for the treatment of exhaust gases, on-site facilities for treatment or storage of residues and waste water, stack, devices and systems for controlling incineration operations, recording and monitoring incineration conditions”. This definition includes boilers.
• The report states that the auxiliary power consumption to run the plant is 3 MW to 3.5 MW.
• It discloses that in case of forced shut down of the boilers, no measures have been provided for vetting the odorous gases from storage and processing areas.
• The report does not reveal that the technical evaluation of the Timarpur-Okhla Waste to Energy Incinerator plant was undertaken after the site visit by Union Environment & Forests Minister on March. 31, 2011. The Minister promised irate residents of Okhla who gathered at the plant site that he would inquire into how no resident or civil society people turned up at a public hearing conducted by the Delhi Pollution Control Committee (DPCC) before the construction of the plant was begun. The proceedings of the fake public hearing drafted by DPCC were given to the Minister. The Environment Impact Assessment was not made available to the public until March 2011.
• The first environmental clearance was given in 2007. The Union Environment Minister asked Chairman, CPCB present at the site to examine these concerns in front of the residents. Delhi Pollution Control Committee (DPCC) officials present admitted to in front of the Minister that only two of their own staffers were present for the hearing conducted in 2007.
• The CPCB report is callous towards the residential colonies, including Sukhdev Vihar, Haji Colony, Gaffar Manzil, Jasola Vihar, Noor Nagar, Masih Garh, Johri Farms, and Sarita Vihar, hospitals such as Holy Family, Fortis-Escorts, Apollo Indraprastha, the Okhla Bird Sanctuary and the Assola Wildlife Sanctuary that fall within 10km radius of the waste to energy incinerator plant site. The report appears to be protecting the interest of Jindal Ecopolis company that is pursuing unsound technological paths with total disregard towards the health of the citizens although the company does not have any previous experience in waste management or energy generation from waste.
• It fails to underline that energy generated from waste incineration cannot be deemed renewable energy. It is does not reveal that waste incineration is a green house gas emitter as per Kyoto Protocol. 'Municipal solid waste is not considered to be a renewable energy source since it tends to be a mixture of fuels that can be traced back to renewable and non-renewable sources,' said Mark Radka, currently Chief of the Energy Branch, Division Technology, Industry and Economics for the United Nations Environment Programme (UNEP). Waste to Energy is non-Renewable Energy-
• The report does not situate the issue in its right context. Sixteen years after the Municipal Corporation of Delhi (MCD) shut down its waste-to-energy power incinerator plant at Timarpur, the Timarpur Waste Management Company Private Limited (TWMCL), a subsidiary of the Infrastructure Leasing and Financial Services (ILFS) proposed to built a plant based on the failed Refuse Derived Fuel (RDF) technology. A Memorandum of Understanding between MCD and ILFS was signed by D K Mittal, IAS the CEO of TWMCPL and Rakesh Mehta, the then Commissioner of MCD on 14 March 2005.
• After the MOU, the Unique Waste Processing Company, a subsidiary of ILFS in collaboration with the Andhra Pradesh Technology Development Center (APTDC) incorporated the Timarpur Waste Management Company Limited (TWMCL) in April 2005. TWMCL, a special purpose vehicle entered into a 25-year concession agreement with the MCD and NDMC under a Public Private Partnership framework to set up a 650 tons-per-day (TPD) Refuse Derived Fuel (RDF) processing facility, a 50 TPD bio-methanation plant, a 6 MW power plant, and a 6 million gallons per day sewage treatment plant at a total cost of Rs. 591.27 million.
• The report does not explain how project proponents expanded their activity to include Okhla in south Delhi. In December 2006, the TWMCL changed its name to Timarpur-Okhla Waste Management Company Private Limited (TOWMCL). The waste is to be supplied by the Municipal Corporation of Delhi (MCD) and New Delhi Municipal Council (NDMC). It does not state that consequent to the Competitive Bidding process, Jindal Urban Infrastructure Limited (JUIL) was selected as the successful bidder and TOWMCL was transferred to JUIL. The project operation contract was awarded to JUIL), a subsidiary of Jindal SAW Ltd on January 1st 2008. JUIL announced that it will use all the power generated from the project for captive use. JUIL said, “We intend to use the entire power generated by TOWMPL for Captive Power Consumption for manufacturing units of our parent company M/S Jindal SAW Ltd. at Mundra, Gujarat by having access to wheeling facility” in its letter dated October 20 , 2008 to the Union Ministry of New and Renewable Energy (MNRE). At the second meeting of technical experts, A K Dussa, Director, MNRE misled the members by stating that similar projects are operated near the population in the countries.
• CPCB report’s glaring failure lies in its inability to take note of the MNRE’s File Notings dated 3.2.2010 that reads: “The Power Purchase Agreement (PPA) also has a clause according to which M/S TOWMCL can use the entire power for its captive use. This clearly is not in accordance with the tender/bidding conditions according to which entire power was to be sold to the Delhi Transco at quoted tariff.” This makes the project doubly illegal.
• The report states that JUIL was renamed JITF Urban Infrastructure Limited which is branded as Jindal Ecopolis, which has taken the project from TOWMCL on BOOT (Build, Operate, Own and Transfer) basis.
• The report fails to take cognizance of the Environmental Impact Assessment (EIA) that was meant for a 650 tons-per-day (TPD) processing plant to generate 225 tons of Refuse Derived Fuel (RDF) and a 50 TPD bio-methanation plant at Timarpur, North Delhi, a 1300 tons-per-day processing plant for generating 450 tons of RDF per day, a 100 TPD bio-methanation plant and a 16 MW power plant at Okhla, South Delhi. Together it claimed to manage 2,050 TPD of mixed municipal waste. The project has been expanded to process 643,500 tons of MSW per year and produce 222,750 tons of RDF per year and 5000 m3 of biogas daily. The revised project is Rs. 204 crores. It was Rs. 174.26 crores earlier. These glaring deviations and alternations in the project design from the EIA report and the conditions laid down while granting the environmental clearance should have been examined by the CPCB report. This has not been done.
• The report ignores that Municipal Corporation of Delhi (MCD)'s Waste Master Plan 2021 wherein it is categorically mentions, Incineration of "RDF is often an option when emission standards are lax and RDF is burned in conventional boilers with no special precautions for emissions". Pradeep Khandelwal, Superintendent Engineer, MCD stated that the proposed Waste to Energy Plant has been planned for a capacity of 1300 MT/day in his submission on September 22, 2011 before the Experts Committee. The project proponent states that it will deal with 2050 MT of waste per day. The discrepancy in these figures is quite glaring.
• The report does not deal with Waste incineration -- including waste pelletisation or RDF, pyrolysis, gasification systems -- technologies that produce pollutants which are detrimental to health and the environment. Incineration is expensive and it does not eliminate or adequately control the toxic emissions from chemically complex municipal discards. The latest incinerators too release toxic heavy metals and persistent organic pollutants like dioxins. In fact the US Environment Protection Agency (USEPA) has in its Dioxin reassessment stated that "dioxin is carcinogenic to humans" and the "risk of getting cancer from dioxin is ten times higher than reported in 1994." Dioxins and furans’ means all polychlorinated dibenzo-pdioxins and dibenzofurans including Tetrachlorodibenzodioxin, Pentachlorodibenzodioxin, Hexachlorodibenzodioxin, Hexachlorodibenzodioxin, Hexachlorodibenzodioxin, Heptachlorodibenzodioxin ,Octachlorodibenzodioxin, Tetrachlorodibenzofuran, Pentachlorodibenzofuran, Pentachlorodibenzofuran, Hexachlorodibenzofuran, Hexachlorodibenzofuran, Hexachlorodibenzofuran, Hexachlorodibenzofuran, Heptachlorodibenzofuran, Heptachlorodibenzofuran and Octachlorodibenzofuran. The report does inform that “Flue-gas from MSW incinerator may contain trace quantities of halogenated aromatic hydrocarbons, polycyclic aromatic carbons, benzene, toluene and xylene and PCDDs/F. These are formed from precursor compounds generated in the furnace during incineration of wastes containing chlorinated hydro carbons already present in the waste or formed in the furnace. These compounds are formed through de-novo synthesis in the low-temperature range (400-250 degrees C) during cooling phase in the presence of particulate matter.
• The report is silent on how waste incineration transfers the hazard characteristics of waste from the solid form to air, water and ash. It also releases new toxins through the process of breakdown of existing compounds and the formation of new ones which were previously not present in the original waste stream, besides making others like heavy metals mobile and more leachable. Far from eliminating the need for a landfill, waste incinerator systems produce toxic ash and other residues. On page 13, it is stated that “concentrate residue is proposed to be incinerated along with MSW”. It is also stated that “The total ash generation in the boiler is expected to be 15 % of the feed quantity i.e. 1047 X 15 % = 157 tons per day (TPD) of which generation of fly ash (40 % OF 157TPD) would be about 63 TPD.” The CPCB observes that “quantity of bottom residue may be more than the reported figures.” On page 5, it has been stated, “A typical MSW incinerator generates bottom ash of about 10 % by volume (and approximately 20 to 30 % by weight) of the solid waste input.” It is also observed that “ETP sludge will be generated from treatment of water for which the proponent has not made any arrangement for handling, storage and disposal of the same”. These projects disperse incinerator ash throughout the environment and subsequently enter our food chain.
• CPCB observes that “The proponent could not provide study details with respect to the environmental aspects on movments of feet of vehicles used to carry 1300 MTD of MSW besides transportation of recyclables, inert materials etc and incinerator residues. The same needs to be evaluated besides availability of parking space, storage, loading and unloading etc.” It does not state when this evaluation will be done. Like company’s design document, the CPCB report deals with emission of dioxins and heavy metals sketchily. It does not mention the method to deal with such emissions. Dioxins are the most lethal Persistent Organic Pollutants (POPs) which are associated with irreparable environmental health consequences.
• It does not refer to the failure of a similar incinerator-cum-power generation plant at Timarpur, Delhi. It required waste with a net calorific value of 1462.5 kcal/kg. The calorific value of the waste used was 600-700 kcal/kg. The Jindal Ecopolis plant is designed to work for a waste which has calorific value of 1000- 1400 Kcal per Kg, as per the CPCB report. The report does not explain how the calorific value has increased dramatically to meet the designed capacity. The Comptroller and Auditor General of India (CAG)’s annual report of March 1990 observed, “The Refuse Incinerator-cum-Power Generation Plant installed by Ministry of Non-Conventional Energy Sources in March 1985 remained inoperative since its installation. The Ministry failed to utilise or dispose off the inoperative plant and incurred an expenditure of Rs 1.25 crore (US$ 278,000) on maintenance and insurance of the plant.” The project was officially scrapped in July 1990. It became a symbol of the colossal failure of MCD and Ministry of New & Energy (MNRE), formerly called Ministry of Non-Conventional Energy Sources. The plant was demolished in 2006 to escape continued embarrassment faced by the authorities that continue to promote waste to energy policy.
• The report fails to recall the order of Delhi High Court in April 2001 on the plant's failure. The court had taken issue with the procurement of the incineration plant at a cost of Rs 20 crores from a Danish firm Volund Milijotecknik in 1985 and said, "No order should have been placed for procurement of the plant unless its utilities were completely known." The CPCB report feigns ignorance about it.
• CPCB ignores the “White Paper on Pollution in Delhi with an Action Plan' prepared by the Union Ministry of Environment and Forests. The relevant part of the paper reads:"The experience of the incineration plant at Timarpur, Delhi and the briquette plant at Bombay support the fact that thermal treatment of municipal solid waste is not feasible, in situations where the waste has a low calorific value.”
• The CPCB report is silent on how the project violates UN conventions to which India is a party. It violates the Stockholm Convention on POPs because it calls for elimination of incineration technologies because they emit POPs.
• The report ignores the recommendations of the Chairman, Parliamentary Standing Committee (PSC) on Energy who wrote to the Union Ministry of Non-conventional Energy Sources (now renamed as Ministry of New & Renewable Energy) on June 14, 2005 seeking review of Waste to Energy Programme and supporting ban on economic incentives for such projects. The PSC was headed by Gurudas Kamat. The current Chairman is Mulayam Singh Yadav.
• The report appears influenced by the incineration industry in choosing not contest reference to term waste incinerators as 'renewable energy' projects is not only fraudulent but also dangerous. Municipal solid waste is not considered to be a renewable energy source since it tends to be a mixture of fuels that can be traced back to renewable and non-renewable sources. The advocates of incinerators prefer to pre-empt segregation and recycling efforts being made by municipalities and communities around the world.
• CPCB forgot about how the earlier Timarpur waste to energy incinerator plant too was based on a technology imported from Danish firm Volund Milijotecknik. The plant was designed to incinerate 300 tonnes of municipal solid waste every day and generate 3.75 mw of power. But the waste didn't have enough calorific value and the plant was shut after 21 days of operation. The calorific value of the waste remains the same.
• The CPCB report fails to dwell upon the current project’s journey of claims from 6 MW, 15 MW, 16 MW to 20.9 MW. Initially, TWMCPL had planned to generate 6 MW of electricity from the project at Timarpur, Delhi using the same failed technology in its new incarnation as a technology developed by the Technology Information, Forecasting and Assessment Council (TIFAC), Ministry of Science & Technology.
• The CPCB report feigns ignorance about the failure of this technology in Andhra Pradesh. SELCO International Ltd’s Refuse Derived Fuel (RDF) incineration technology based waste to energy project at Elikatta village, Mahbubnagar, Andhra Pradesh lies defunct. A Fact Finding Survey team comprised of K Babu Rao, former scientist at the Indian Institute of Chemical Technology, Hyderabad, Narasimha Reddy Donthi, Chief Advisor, Chetana Society, Hyderabad and Gopal Krishna of TWA, New Delhi visited the plant site on August 1, 2011 to ascertain it and witnessed the rusted and non-functional condition of the plant.
• CPCB report steers clear of the fact that fiscal incentives for projects of power generation from MSW through new technologies violates Supreme Court’s Order: The court has put a stay on subsidy for waste to energy projects except 5 pilot projects based on Biomethanation technology. The Timarpir-Okhla project is getting incentives from the government although the court has stayed it. This applies to waste to energy incinerator projects in Delhi’s Narela-Bawana and Ghazipur being constructed by Ramky Company and GMR Company of 36 MW from 4000 tons of MSW and 10 MW from 1300 tons of MSW respectively.




















Annexure
Okhla Timarpur Waste To Energy Plant






Review of Technical Evaluation






Anant Trivedi
Member, Technical Evaluation Committee
Central Pollution Control Board



April 2012




Review of Technical Evaluation
The technical evaluation report poses a few pertinent questions of worry which the citizens need to have addressed before we go too far into the project. Some of these are listed below.
Disposal Of Toxic Waste
- The Okhla plant has a capacity of 2050 tpd of domestic waste input. However the plant design allows upto 10,000 tpd of input for incineration.
- Toxic bottom ash quantity produced will be 20-30% of input. This amounts to at least 410 tpd rising to a maximum of 3,000 tpd.
- Additionally there will be toxic flyash of about 10% of the bottom ash.
- None of the landfill sites have the capacity to take in so much toxic waste and mulba has been dumped every where including all public spaces – so what is proposed to safeguard public health from this toxic substance?
- Rag picker community will continue to work in the landfill site unaware of the danger to their health. How are they proposed to be protected?
- This is highly toxic waste and should be buried for a long period in a landfill site – about 50 years. Since the nearest landfill is about 12 km from the site, this will be transported in open trucks and thus cause a lot of pollution during the journey for vehicles following and then it is most likely to be dumped in the open in landfill site. What is proposed to prevent ash flying around in the air during the journey to landfill site?
- Tughlakabad landfill has been consumed by dumping mulba illegally. So where will this go? MPD 21 clearly says where landfill sites are allowed.
- For toxic waste which is sold to for brick making, what safeguards are incorporated for safe transport, and for the workers who will work with this material. Are we looking at another Asbestos type disaster? With another 3 plants proposed Delhi will be ringed with a ring of highly toxic waste.
Disposal of waste water from leachate
The plant will use upto 2400m3 of water, as per the declared figures on a plant capacity of 2050 tpd. This figure would rise to 8500m3 of water, at full design capacity of 10,000 tpd. After treatment in the onsite plant, this waste water will be fed back into the DJB system for purification. This water will contain toxic heavy metals and other harmful substances. DJB does not deploy technology for removal of any of these substances and hence these will get released into the domestic drinking water system. What safeguards are proposed to safeguard public health from this dangerous drinking water?

Plant Capacity Increase
All estimates of inputs and waste output and transportation plans must be based upon the design capacity of a plant. The design capacity must have built in components which can handle the maximum stated design capacity. Project proponents must show how they will cope with upto 10,000 tpd of MSW and all the pollutants resulting from it. The figures quoted are: 2050 tpd (EIA), 1400 tpd (report), upto 10,000 tpd.
- The authorised capacity can be different, but there must be clear rules to say how a plant’s capacity will be increased i.e. after fresh authority It cannot be left to the project operator to increase at will?
- The plant is supposed to produce 16 mgw of energy of which 2.5 is said to be for internal consumption (a variance from EIA which said 50% usage). This is based on 1400 tpd. So much more energy will be produced from 10,000 and will this not be an incentive for the proponent to generate and sell more without permission? Will the Min Renewable Energy subsidy (1.5 cr/Mw energy) be an incentive to burn more?
Estimates of pollutants released into air
The estimates are very lose since there are no standards laid out by CPCB. They say 30 spm level is guaranteed. Similarly very attractive figures are quoted for NOX, SO2, Heavy metals….How will this be monitored and compliance enforced? Delhi’s ambient is yet to be defined, but spm levels are already far in excess of quoted in any day. The pollution released into the air, will be a frightening amount affecting a catchment area of about 2 km radius resulting in a slow destruction of the respiratory system with the young and elderly most vulnerable.

Analysis of flue/ stack gases
Which are the designated laboratories for testing of samples collected during commissioning (presently going on)? How and where will dioxin and furan samples be tested? This needs to be clearly stated.
- What standards are specified for testing of the samples by these labs?
- So far no monitoring equipment has been installed in neighbourhood areas, as stipulated in the report, to monitor the pollution released. When will this happen and how will the samples from these be monitored?
- There is no independent body set up to oversee the monitoring and testing process. This cannot be left to DPCB as they have proved repeatedly that they are vulnerable to influence by plant proponents (e.g. common biomedical plant monitoring).
- CPCB specifies procedures for upto 6 months when ‘proving’ of the pollution controls is taking place. What happens after this if there is no independent agency with citizen involvement to ensure compliance?
Safety for personnel at the site
The report says that many rag pickers will be trained to remove plastics and other pollution causing items from a moving grate in an environment which will be enclosed and will be a reasonably high temperature to enable drying of waste.
- They propose to spray a deodorant in the area to prevent foul smell.
- Is there any free medical care provided at the factory? Are their arrangements at nearby hospitals to take care of accidents suffered by rag pickers and other workers? Is there any medical insurance cover provided for the workers and their families??