MUDD - Seminar academic paper_Kosasthalaiyar River & EIA (2020)

Indian Journal of Environmental Protection

Indian Journal of Environmental Protection: The parameter involved in affecting the environment, despite EIA - the industry affecting the primary resource (Kosasthalaiyar river): a reassessment at the outskirts of Chennai R.P.Harini Manipal School of Architecture and Planning, Manipal Academy of Higher Education, Manipal, Karnataka, India E-mail: harinirparch@gmail.com The paper formulates different strategy, policy that are available for the construction of the industry and which cause hazard to the environment. On understanding the parameter that cause pollution to the environment, from literature study - the laws and guidelines involved, that is, the environmental policies and environment impact assessment and the land acts which are evolved through years has to be restructured to attain a model of strategy for better effect, that is, the industry not hazardously affecting the environment. This framework is derived from studying different cases at the outskirts of Chennai; analyzing and critically addressing the case that are the cause and effects of encroachment, the industrial effluent, affecting the air, water and environment, settlement around; also, critically affecting the primary resource of the place (Kosasthalaiyar river) that has the major impact on the eco-life and biodiversity of the surrounding. .

Introduction Environmental impact assessment is done to evaluate a project whether it is feasible to be equipped in the selected land parcel or not. Each project has its own criteria of taking up EIA, whereas the stage of screening is followed in the process to understand the project and its critical aspect of polluting the environment. In many projects the process of screening is done in three ways according to the projects specification/ intension to deteriorate the environmental condition: full EIA directly, preliminary EIA only, or

guidance, and practice. To envision the parameters that includes the factors that does not affect the ecology, even while industry come up (considering the development).

Despite having a process and a formulation framework for EIA, that are, 1. Screening 2. Scoping 3. Impact analysis 4. Mitigation 5. Reporting 6. Review of EIA 7. Decision making 8. Post monitoring of the project

preliminary EIA followed by full EIA Findings lead us to ensure that the land take impacts are quantified and made explicit in preliminary EIA reports. Land conversion/ land take away/ land reclaimed are terms to engage with assess the need for utilization, we need to acknowledge the pattern of utilization of land to understand the use of the land in that urban space/ land parcel.

Comparing different projects together will determine the land reclaimed in EIA provides a basics for understanding the ways to improve EIA policies,

the current scenario of the environment, which is hazardously affect, upon following all the abovementioned criteria be the gap, protecting the environment restructuring the aspects including those parameters which is left out is critical. Thus, the paper aims to find the other parameters that are the reason for the industry to pollute the environment.

Indian Journal of Environmental Protection

because of which those industry that is causing environmental destruction in the recent times.

Objectives of the study

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To map the industry and analyze the effects and pressure it puts to the surrounding settlement and ecology i.e., to acknowledge the environmental imbalance that is created by these industries.

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Identifying those land take spots/ industry that was converted and constructed even after negative environment impact assessment (moving away from the stipulated benchmark)

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To formulate the parameters about the topic (e.g. parameter – Illegality. Monetary relaxation), to check EIA in line with the process that will not affect the settlement and ecology around, adversely, on construction of the industry.

Methodology

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Decide on a topic - The parameter involved in affecting the environment, EIA Vs land conversion of the industry: a reassessment at the outskirts of Chennai (Kosasthalaiyar river)

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Identify the question - Cause and the parameter for construction of an industry occurs despite having EIA, that in recent times cause adverse effect on the environment.

Indian Journal of Environmental Protection

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Identify the literature that you will review – Literature on industry land take by the industry, secondary data on how the industry emissions cause hazard to the environment, land take vs the impact on the environment, comparing the different industry, (different cases at the outskirts of Chennai)

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Manage your refences – eligibility, limitations – The industry that cause at most adverse effect to the environment in multiple aspect Is considered.

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The literature is critically analyzed.

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Understanding and summing up the literature in a table format to analyze case-based issue.

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Literature – background information, systematic review (Davide Geneletti) (Environment Impact Assessment - Draft 2020) (India: Impact Of The Amended Environment Impact Assessment (EIA) Notification 2016, 2017).

Figure 1 Detailed methodology of the research

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Critically synthesis the case – evidence, inclusion, and exclusion with the eligibility criteria (limitation)

Case study selection criteria - Data (secondary based): 

From John Gerring and Jason Seawright, the case selection category relates more to extreme casebased study (Case study research) (Dr)i.e., in comparing to the other listed case studies, one major case will have high intensity of affecting the environment.

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Critical intense case is focused upon to understand the space and examine the existing condition of exploitation. This theory of selection criteria is majorly used in the cause-effective category.

Indian Journal of Environmental Protection

Selection was also based on the parameters that evolved from the literature reading (The growing environmental issues of Chennai).

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The natural gradient is from west to east and the rivers drains to the sea at Bay of Bengal, the encroachment of the cluster industry happen obstructs the flow and cause flood during the rainy season.

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Six villages around these factories Ennore thermal power plant, North Chennai coal fly ash pond, Bharat petroleum oil industry. All the chemical effluents are drained into the Kosasthalaiyar river.

1. Land take/ encroachment 2. The effluents from the industry crossing the permissible limit 3. The case affecting the major/ primary resource 4. The other factors: 

Water pollution

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Air pollution

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Affecting the eco-life in the primary resource (industrial effluent, affecting the major resource)

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All the above affecting the settlement nearby.

Case study – 1 (Group of industry at the Ennore creek)

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The projects and its impacts on the environment: The Kosasthalaiyar river is the major water source at the north part of Chennai, the origin of the river is from Andhra Pradesh flowing in accordance with the natural contour across Tamil Nadu and drains into the Ennore creek.

This river stretches up to 136 km long,

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According to the study by the National Green Tribunal during December 2017 observed, the major water source, that is the Kosasthalaiyar river is the most polluted water course in the entire district – it is said that, the river is more polluted than the industrial effluent.

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From the survey that the National Green Tribunal took, it was observed that 20 samples were collected all over the area and five samples were set to cross the permissible limit, that is, the lead, mercury, arsenic composition, contained higher in the river (zooming into the environmental problems of a growing chennai, n.d.).

Figure 2 Coal fly ash contaminating the Kosasthalaiyar river water, altering the hydrology and affecting the potability of the water. Photo source: Amirtharaj Stephen/ PEP collective

Figure 3 Polluted Kosasthalaiyar contains mercury, lead, and arsenic above the standard level for discharge of industrial effluents into inland water. Photo source: Amirtharaj Stephen/ PEP collective

Indian Journal of Environmental Protection

Figure 4 Left: 2009 map of the estuary; Right - 2016 map - The propose new map by the state coastal zone management authority

Indian Journal of Environmental Protection

Case study – 2 (Sun Pharma at Pudhupet) The projects and its impacts on the environment: The industrial effluent from Sun pharma is emitted during and along the rains. The polluted surface water drains into a small pond called Sitheri, which then flows into Pudupet thangal, Hanumanthakuppam eri and then to the Madurantakam eri. The water that is polluted is the major reason for the agricultural well and canal irrigated cropland to get abandoned in the Malaipalayam village.

The water underground is also affected due to the seepage of these effluents into the ground water table.

The wetland near the Vedanthangal bird sanctuary is a source of water to the birds that inhabits the place but because of this effluent mix into the water source it is poisoning the water source of about ten thousands of birds coming here every year (Video documentation Pollution at pudhupet village by Sun pharma).

Figure 5 Demarcation of the eco-sensitive zone; Source: Aville organisation

Figure 6 Demarcation of sun pharmaceutical limited; Source: Aville organisation

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Case study – 3 (MFL - Madras fertiliser limited at Manali)

Case study – 4 (Kattupalli port expansion plan, Ennore, Pulicat region):

The projects and its impacts on the environment: This industry is a public sector that works under the administrative control of union ministry of chemical and fertilizers, MFL. Since 1971, it has been involved in the commercial production of ammonia (used in the production of urea, which is the key ingredient in the chemical fertilizers produced by this plant), urea and NPK (nitrogen, phosphorous, and potassium) fertilizers.

Here, not only the air is polluted due to the emission of from the industry, but also the machineries creates sound even during the nights creating an unlivable condition, also the groundwater contamination is seen in this place due to the industry.

The people living at the village of Harikrishnapuram is facing all this issue, the increasing deteriorating condition led them to protest the industry. On which the industry reduces the emissions then but eventually they tend to release high amounts of ammonia again. At Manali the air and water pollution make it unfit to be inhabited.

But the CPCB and the TNPCB's ambient air monitoring stations which is located near to the fertilizer industry did not find any abnormal ammonia levels and the levels were within permissible limits (cro).

Marine Infrastructure Developer Private Ltd. (MIDPL), Gautam Adani owned company expansion, worth – 53,031 crores. The expansion encroaches the river and surrounding land, with its ten-fold expansion of the existing cargo handling capacity of the port.Area details about the port: Total area – 2,472.85 hectares, includes,133.50 hectares of existing port, 761.8 hectares of government land, 781.4 hectares of private land, Proposed - Sea reclamation of 796.15 hectares. The chemical from the power plant and the waste from the factory emitted has polluted the river water. Also, the projects around the area claims to release hot water from the power plant and brine from the desalination plant into the Ennore creek and Kosasthalaiyar river (muddying-the-waters/article28811402.ece).

Justification for the case – selection: From an article of ‘Letmebreathe’ - (The growing environmental issues of Chennai) the study lists

Indian Journal of Environmental Protection

down the factors affecting the outskirts of Chennai: Ministry of Environment, Forest, and Climate Change 1. Water crisis in Chennai, the reservoir that was (MoEF & CC) has identified 88 industrial clusters in the country, of which 43 industrial clusters were identified the cause of 2015 flood, dried up. as Critically Polluted Areas (CPA) based on the 2. Chennai surpasses Delhi in air pollution. 2019 Comprehensive Environmental Pollution Index (CEPI).

In Tamil Nadu, 7 industrial clusters were identified one 3. Kosasthalaiyar river more dangerous, industrial among which is the Ennore industrial cluster, near effluent Manali (Evaluation of CEPI Score and action plan CEPI area of Manali, Tamil Nadu, 2019).

4. The 300 feet high Kodungiyur dump yard.

The Central Pollution Control Board brought the Comprehensive Environmental Pollution Index CEPI during 2009-10, provides a standard CEPI score for each area within the state, when the score is greater than 70, then the area is identified as Critically Polluted Areas (CPAs) and if in case the score is between 60 and 70, the area is identified as Severely Polluted Areas (SPAs) (Evaluation of CEPI Score and action plan CEPI area of Manali, Tamil Nadu, 2019)..

The CEPI score of this industrial cluster is 76.32, it is considered to the critically polluted area according to the CPCB, due to which the new establishment of industry and expansion of the existing industry is not permitted in this critically polluted area.

These cluster of industries at and near the western Ennore creek is termed as red industries by the TNPCB, during the 2015-16.

Comparison of case studies: Case 1

Project – industry (case study)

Group of industry affecting the Kosasthalaiyar river: - Ennore thermal power plant - Coal industry - Bharat petroleum oil factory - North Chennai ash pond

Parameters consider (already there)

Encroachment of industry in the no construction zone, Industrial effluent, Major water resource pollution, (Kosasthalaiyar river) Air pollution, Affecting the eco-life in water

Issues identified

- The Kosasthalaiyar river, most affected - 6 villages around the space - Eco-life of the river - Encroachment of the river by the industry at the mouth of the river - Water and air pollution - Effluent from the industry

Environment affected

Fisherman 6 villages around Endangering the eco – life; water body gets polluted.

Indian Journal of Environmental Protection

Case 2

Case 3

Case 4

Project – industry (case study)

Sun Pharma industry at Pudhupett ai

MFL (Madras fertiliser lmt. At Manali)

New port expansion at the Kattupalli – industrial effluent nearby.

Parameter consider (already there)

Water pollution (affecting undergrou nd water), Industrial effluent, Affecting wildlife

Air pollution, Noise pollution, Water pollution Ground water contaminat ion

Industrial effluent, Air pollution, Encroachm ent of industry,

Issues identified

Undergro und water get affected - Effluent from the industry Affecting the settlement around

Settlement around Hazardous gas emission

- Effluent from the industry affecting the coastal zone - Water pollution - Air pollution

Pudhupeta i villagers

Settlement around the factory at Manali

Settlement around the Kattupalli area where port expansion happens

Environm ent affected

Results: The environmentally sound Ennore creek started facing a lot of issue during the 1970s, as and when the industries started raising up. These industries, its effluent is not treated properly instead it is drained directly into the river, which eventually is drained into

the sea and endangers the aquatic ecosystem, settlement around, thus the natural wealth of the western creek is immensely degraded.

Pharmaceutical and Agro-based Chemical Division India (ICI): The huge horizontal spread - complex of pharmaceutical industry releases the mixed liquid effluent consists of chemicals to the sea after treating its organic constituents of the effluent in an activated sludge system.

Ennore Thermal Power Station (ETPS): 420 KLD of trade effluent is generated by the Ennore thermal power plant from demineralization plant (DM) and as ash slurry 38,400 KLD of trade effluent is generated. These effluents are treated and is drained into Buckingham canal. The ash slurry is let into ash dikes constructed in the 230 acres area at 1.25 km western side of the plant, which was initially pumped into the sea. The seawater is pumped from the Ennore creek at the rate of 17, 60,000 kilo litres/ day by the unit to cool the condenser, after which the hot water is drained in the creek.

The unit has 5 cooling towers to get recycled cooling water, due to sand dune formation it is difficult to get and to reduce thermal pollution; the sea water is taken by the thermal power plant as coolant and release back hot water into the sea. Everyday almost about 8,000 tons of coal is burnt (when all the units in the station are working) due to which 40% ash (3,200 tons of ash) should be disposed-off the station, the fly ash is discharged into the sea in slurry form.

North Chennai Thermal Power Station (NCTPS): From DM plant regeneration, blow-down and ash slurry, 55,800 kilo litter per day (KLD) of trade effluent is generated by North Chennai Thermal Power Station. The ash dykes built with the area of 1000 acres where the ash slurry is discharged to. The cooling water is drained into the Buckingham canal which flows into the Ennore Creek, having given a consent to drain water into the sea.

After complaining against the industry to not drain water into the canal by the fishermen community, the TNPCB has hampered the industry to directly drain water into the canal. Meanwhile open pre-cooling channel (width up to 130m for about 2.5 Km, which totals a distance of 4.5km including the creek) was proposed by the central water

Indian Journal of Environmental Protection

and power research station, Pune; brought in by TNEB tripropylene glycol, propylene oxide of about 175 tons, to reduce thermal pollution (V.Shanthi, 2009) 80 tons, 10 tons and 1000 tons every month, respectively.

Manali Crude Oil Refining: Madras Refinery Limited (MRL) is a public based company, processes the imported crude oil containing sulphur 1.8-2.5%, the atmospheric distillation unit divides the crude into overhead product, Heavy naphtha cut, Superior kerosene cut, Diesel cut and atmospheric residue.

The Chennai Petroleum Corporation: This CPC years back to 1963, processing Imported crude of Refinery I - 2.8 Million metric tons/ annum (MMTPA) Refinery II - 1.5 MMTPA and Indigenous crude of Refiner II - 2.2 MMTPA From the refineries the capacity of processing sums up to 6.5 MMTPA from refinery I and II. By processing crude oil; (LPG, petrol feed stock, motor spirit, light aromatic naphtha, aviation turbine fuel, superior kerosene, linear alkyl benzene, high speed diesel oil, lube oil base stock, fuel oil, low sulphur heavy stock, bitumen, sulphur, carbon block feed stock and wax), by-products were produced.

Upon treatment, the effluent is used to develop the internal green belt, civil works, fire hydrant system that is about 60% per unit of the effluent and the remaining, that is 40% per unit is discharged into the canal. The ambient air quality for Sulphur dioxide and nitric oxide exceeded in 3 sampling station and maintained its standards in all the other 8 stations.

The industry utilizes 20 KLD of water for domestic purposes; 500 KLD of water for cooling and 4800 KLD of water processing; thus, it generates 15 KLD of sewage and trade effluent of 4500 KLD. The sewage is treated, disposed through septic tank and dispersion trench arrangement, similarly the trade effluent is treated and is drained into the sea.

Tamil Nadu Petro Products (TNPP) Ltd: From every other industry the unit generated sewage and trade effluent of about 100KLD and 310 KLD. The sewage is treated in the STP having screen pit, oil removal tank, collector tank, equalization tank, aeration tank, settling tank and sludge drying bed, whereas the trade effluent is treated and drained into the sea. On salt purification the unit produce non-mercury bearing brine sludge which is disposed as landfill. Despite the effluent being drained into the canal before which few parts of it is utilized for irrigation purposes of the place.

Fertilizer Plant: The unit produces ammonia, urea, NPK Complex Fertilizer and Bio-fertilizer at Madras Fertilizers Limited (MFL). The unit utilizes 1,350 KLD, 28,260 KLD, 1,350 KLD of water for domestic, cooling and for processing, this sewage of 360 KLD and 8,400 KLD trade effluent is generated, where the treated effluent is drained into the channel, near by the unit, Red Hills lake.

Calcium carbonate sludge and the used catalyst is generated from the unit as hazardous waste, the liquid eluent is drained into the canal which contains; ammonia The Madras Petrochemical Plant, Chemical phosphate, urea, fluoride, and suspended solid particles Production: (V.Shanthi N. , 2009).

This generates petroleum jelly, transformer oil and other products of petroleum, the liquid waste from the These were the industry which was affecting the Ennore plant is treated in DCDA (Double Contact Double creek during the 2009 according; after which carrying Adsorption) system, this eventually produces acid forward the CPCB experimented the environmental sledge (Franklin, 1975) and the sledge stored in a large quality monitoring through EPA, with samples made at lagoon at Ennore. location from center, this was rated via Comprehensive Environmental Pollution Index (CEPI) observed from Organics limited: the samples taken, during 2017 at the critically protected Polyols and propylene glycol are generated by the unit area. in the industry; of about the quantity of 1000 tons and 650 tons, respectively every month. By-products such According to CPCB the ambient air and the water quality as propylene dichloride, dipropylene glycol, of the till 2013, 2017 and was maintained good after that,

Indian Journal of Environmental Protection

that is, it was said to be not polluted from the prescribed For Surface Water Quality, permissible limits considered standards of National ambient air and water quality. (as per IS10500, Drinking Water Standards), collected surface water samples have been. The analysis of the For Air Ambient Quality, the maximum and minimum sample results indicates that the pH ranges in between concentrations for PM10 was 84.7.-g/m3 and 41.2- 7.3 to 7.9, which is well within the specified standard of g/m3 respectively. The maximum and minimum 6.5 to 8.5. concentrations for PM2.5 were recorded as 41.3-g/m3 and 20.4-g/m3 respectively. The maximum of SO2 is The range value of total hardness varies from 355 to 845 21.8 g/m3 and minimum of SO2 is 8.6 g/m3. The mg/l. The maximum hardness (845 mg/l) was recorded maximum and minimum concentration of NO2 is 30.6 at Buckingham Canal Upstream Water and the minimum of 355 mg/l was recorded at Amullavoyil Canal g/m3 and 13.4 g/m3 observed at.

Upstream Water. Chlorides at all the locations were ranging in between 528 and 1131 mg/l. Fluorides are ranging in 0.26 and 0.36 mg/l and are found to be within the permissible limit. Nitrates were found to be in the range of from 0.5 – 60.4 mg/l. The range value of Total Dissolved Solids (TDS) concentrations was found between 1710 to 4128 mg/l. Dissolved Oxygen was ranging in between 5.3 and 6.1 mg/l. Arsenic, Lead and Mercury were found Below Deductable Limits. Iron was ranging in between 0.58 and 1.64 mg/l. Microbial contamination ie Total Coliform found in between 500 and 900 MPN/100 ml and Faecal Coliform found in between 140 and 900 MPN/100 ml.

For Ground Water Quality (Central pollution control board - Survey), permissible limits (as per IS10500, Figure 7 Air quality as precribed from national ambient air Drinking Water Standards). Collected ground water quality, Source: tnpcgov.in samples have been analyzed. The overall minimum and For the above-mentioned samples, the maximum maximum of analysis results of the PH ranges between concentration was recorded at NATCO Pharma 7.3 to 7.7, which is well within the specified standard of Limited, and the minimum concentration was recorded 6.5 to 8.5. at CPCL, Manali and all the results are within the limit prescribed by CPCB The range value of total hardness varies from 165 to 490 mg/l. Chlorides at all the locations were ranging in The concentrations of Ozone were observed between between 273 and 358 mg/l. Fluorides are ranging in 0.17 7.7-45.5 μg/m3 and under the limits of180 μg/m3 as and 0.22 mg/l and are found to be within the permissible specified by CPCB standards. The concentrations of limit. Nitrates were found to be in the range of from 8.4 Ammonia were observed between 22.0 – 51.3 μg/m3 – 65.4 mg/l. The range value of Total Dissolved Solids and under the limits of 400 μg/m3 as specified by CPCB (TDS) concentrations was between 936 to 1516 mg/l.

Dissolved Oxygen was ranging in between 5.9 and 6.6 standards. CO, Benzene, Benzo (o) mg/l. Arsenic, Lead and Mercury were found Below Pyrene, the concentrations of CO, Benzene, Benzo (o) Deductable Limits. Iron was ranging in between 0.19 and Pyrene (BaP), were below the detectable limits. The 0.49 mg/l. Microbial contamination ie Total Coliform concentrations of Lead, Arsenic, in all locations were found in between 17 and 500 MPN/100 ml and Faecal below detectable limits during study period. The Coliform found in between < 2 and 120 MPN/100 ml concentrations of Ammonia were observed between (Environment monitoring report, critically polluted BDL – 14.5 ng/m3 and under the limits of 20 ng/m3 as area, pre-monsoon season, 2017). specified by CPCB standards.

Indian Journal of Environmental Protection

Despite of all these observations that is taken with account to the samples, said that the standards are maintained and followed. But the industrial pollution due to cluster of industries present at the Western Ennore creek, is huge in terms of producing wastewater, liquid effluents, sewage and solid waste drained into the sea, canal; the wastewater is not safely disposed instead these effluents are treated and are disposed in the canal and rivers, which flows directly into the sea.

Toxic pollutants discharged into the marine environment which endangers the environment to the living resources, ecosystem, hazardous to human health, hinders the marine activities including fishing also, reduces the quality of sea water.

Despite comprehensive environmental pollution index CEPI, the samples were taken, the air and water ambient quality water under the permissible limit; the effluent these industries discarded as a whole is considered to harm the Kosasthalaiyar river by the cluster of industries present, adversely.

According to TNPCB; Water prevention and control of pollution act, 1974 the sections - 4, 17, 20, 21, 23, 24, 25, 26 (Constitution of State Board; Function of state board; Power to obtain information; Power to take samples of effluents and procedure to be followed in connection therewith; Power to entry and inspection; Prohibits the pollution of a stream or well by disposal of polluting matter etc; Restrictions on new outlets and new discharges) the documentation including sampling the water quality to address the effluent that was emitted from the industry is worked on whereas the section – 27, 28, 29, 30, 31, 32, 33 A and B, 43, 44, 58, 64 action is not taken with respect to section 24 and 25 (Refusal or withdrawal of consent by State Board; Appeals; Revision; Power of State Board to carry out certain works; Furnishing of information to State Board and other agencies in certain cases; Emergency measures in case of pollution of stream or well; Power to give directions; Appeal to National Green Tribunal; Penalty for contravention - provisions of section 24; Penalty for contravention - provisions of section 25 or section 26; bar of jurisdiction) (Tamil Nadu Pollution Control Board, n.d.)

According to Air prevention and control act 1981 the section – 4, 17, 19, 20, 21, 22, 22A, 23, 24, 25,26, 31, 31A (SPCBs constituted under section 4 of the Water Act; Functions of the State Boards; Power to declare air pollution control areas; Power to give instructions for ensuring standards for emission from automobiles; Restrictions on use of certain industrial plants; Persons carrying on industry, etc. not to allow emission of air pollutants in excess of the standards laid down by State Board; Power of Board to make application to court for restraining persons from causing air pollution; Furnishing of information to State Board and other agencies in certain cases; Power to entry and inspection; Power to obtain information; Power to take samples of air or emission and procedure to be followed in connection therewith; Appeals; Power to directions) even after the appeals and direction section – 37, 38, 54 (failure to comply with the provisions of section 21 (or) section 22 or directions issued under section 31A, Penalties for certain acts, Power to state government to make rules) (Tamil Nadu Pollution Control Board, n.d.)

The UN Summit held in September 2015 resolves 169 target and the 17 goals that falls under the Sustainable Development Goals (SDGs). India is a signatory of the 2030 Agenda, committed to achieve SDGs. Under the target SDG goal of 12.4, Tamil Nadu Pollution Control Board (TNPCB) proposes in the year 2019-20 to increase the AAQ stations to be spaced more in number. That is from 38 stations the count is increased to 63 stations by adding 25 New CAAQMS. For RRZ River regulation zone the ministry of forest and environment initialized a blueprint, this draft of river zone notification was sent to the state government to know their views with respect to the draft. This draft was under the ambit of EPA, 1986. Under this draft there where three zones proposed to restrict construction, riverbank to the outer edge of the floodplain and beyond (500m from the highest flood level in the recent 50 years.) the limit will extend up to 1km from the out limit of the prohibited zone. Also, a buffer zone of 3km which is a restricted activity zone is provided that is, only certain activities such as traditional organic farming and recreational activities that do not request boat jetties will be permitted (Ramamoorthy, 2016).

Indian Journal of Environmental Protection

Discussion: Sampling Stations: The sampling station at the overall India is 63 and now is increased to 79 station, where in the at Manali the stations that takes the CEPI was consider to have increased 3 sample stations so as to get the accurate reading.

Some sample points among the marked is influenced according to the surrounding behavior which is a critical aspect of the observation. The PM10 and PM2.5 check exceeds the permissible limit in the sample of AAQ because of the vehicular emission nearby, as the sample station is near the place where the traffic intensity was more (Evaluation of CEPI Score and action plan CEPI area of Manali, Tamil Nadu, 2019).

Addressing RRZ that remained as a draft: Other case relooked regarding the RRZ in the Indian context is the Mahanadi, were the river is encroached, even at the no construction zone demarcated by the environmentalist the mark is overruled by filling the river line with sand. This is because of the RRZ notification that is not into action (Ramamoorthy, 2016).

Figure 8 The sample stations at Manali (SW - Surface Water, GW - Ground Water, AAQ - Ambient Air Quality) (Evaluation of CEPI Score and action plan CEPI area of Manali, Tamil Nadu, 2019)

This being another issue in the India itself with respect to this river regulatory act, if in case this act which demarcates all the eco-sensitive zone with respect to the rivers to have restriction on construction that happens at these zones can be restricted. In our case the pollutants are drained into the creek, but if the RRZ notification was

Indian Journal of Environmental Protection

in action then these activities can be illegalized and water course, air, environment; almost 6 industrial set up easily restricted. in the same zone.

Air quality of industrial areas are above the standards permissible limit table by the environment ministry; hence creating hazardous environment condition. Group of industry affecting the Kosasthalaiyar river: Ennore thermal power plant, Coal industry, Bharat petroleum oil factory, North Chennai ash pond all these industrial set up on one ground forming cluster together pose as a red zone area on polluting the environment.

Figure 9 The portion of river during the 2017

Figure 10 The portion of river filled with sand (supposed to be treated as with the natural format that was existing)

Industries at Manali relating to the Delhi issue:

Figure 11 Air ambient quality that exceeds the permissible limit Source: (Coastal resource center, 2019)

Delhi is the most polluted with respect to the air quality index that prevailed at the region after taking the samples. But the AQI in Chennai surpasses the AQI that is attained during the 2019. The complex at the Ennore creek has fertilizer, petrochemical, chemical, pharmaceutical industries and automotive manufacturing units, thermal power plant of north Chennai, ash ponds etc., these industrial complex drains out the pollutants to the Kosasthalaiyar river directly or Figure 12 The CEPI score of the industrial estate at Manali, Source: the effluent is drained out into the canal, it eventually (Evaluation of CEPI Score and action plan CEPI area of Manali, Tamil Nadu, 2019) flows to the western creek.

This Industrial Complex comprises of 17 industrial units among which 8 are considered to be large-scale industries which are termed as red industries by the Tamil Nadu Pollution Control Board, this includes crude oil refinery, petrochemical, heavy chemical, fertilizers, pharmaceuticals, and chlorine-alkali production.

Also, the encroachment by the industry at the western creek, the mouth of the river which is supposed to be the no development zone. To legalize all these issue the state coastal zone management authority proposed a new map which do not show the estuary that was encroached – almost 6,500 acres of the river that was seen in the 2009 map is not depicted in the new map, 2016, which legalize the construction.

Of all the industries studied the table depicts the critical All of these put together polluting the Kosasthalaiyar aspect of looking into the Ennore creek which relates to river in a major format. Also, being the source of water the encroachment at the creek, industrial effluent and livelihood for the fisherman, now posing as a threat crossing the permissible limit and polluting the natural

Indian Journal of Environmental Protection

to the entire zone (effluent is evidently seen); water ecosystem is at danger. The rainwater drains at this river, due to block is also not possible endangering the entire zone for floods and various other issues.

The eco-sensitive model:

Figure 13 The model that must be incorporated to sustain the ecology and industrial settlement in a long run together

The on-going process, is under the convenience of the factory to build on the land, only considering the factor of revenue generation. The scenario that occurs upon reviewing the policy based on the parameters that affect the environment, while constructing the industry. This is done to attain the balanced vision of industry coexisting by supporting the livelihood of the people. This model includes the environmental factors and the inhabitants settled nearby; not to affect these upon construction of the factory to build the economy.

Conclusion: T e lesion From the cumulation of the study the model that was addressed by the state secretary to include the environmental condition in the model. By considering the strategies and environmental policies; restructuring the existing EPA adding to the eco-sensitive model.

Inclusive of the RRZ draft notification if it gets formulates and impose its restriction on the projects

will less frequently affect the river line, aquatic ecosystem, and the settlement around. Environment protection act and environmental impact assessment can be worked with efficacy which will regularize many of the critical issues that the industry generates, that are threat to the environment.

As discussed in the above section it is also observed that the CEPI score is getting higher through the years, this is because of the less sample points at the critical nodes.

The sample points though increased through the years it is not placed at the right points hence they are influenced by various other factors, so, not only increasing the sample points but also spacing them at the correct critical point is an influential factor to understand how the industries adversely affect the environment. Also, from the TNPCB the framework that was not followed with respect to prevention and control of air and water must be regulated (section 24 and 25), else penalization/ monetary penalization must be strictly lined.

Indian Journal of Environmental Protection

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