Thermal Power Plants Continue Flouting Environmental Regulations: The Case of Shifting to Closed Cycle Cooling Systems

Official documents[1] show that as of Nov 2019, four years after the standards were notified as legally binding and two years after the deadline to implement them had passed, 13 thermal power plants continued to be in clear violation of the standards requiring all non-coastal power plants to shift to closed cycle cooling. And that they had little intention of complying.

 

Regulations in 2015 Bring Hope

In Dec 2015, the MoEFCC notified regulations which for the first time placed limits on the emissions of SO2, NOx and Mercury from thermal power plants (TPP), as well as on the amount of water they could use. The standards for emission of particulate matter were made more stringent. These regulations also required new TPPs (installed after  1 Jan 2017)  to maintain zero waste water discharge and required all TPPs who used open cycle cooling, also called once through cooling, to shift to a closed cycle, cooling tower based cooling system.

These regulations, though they did not fully address the pollution problems from TPPs, were an important step in the right direction and were welcomed with great hope. The Notification required all power plants to meet the norms by Dec 2017.

Violations Galore

Unfortunately, almost none of the norms have been followed. Not only that, power plants have tried to evade implementation of these norms with all kinds of excuses, have tried to delay, dilute and simply ignore the norms. The Ministry of Power (MoP) has often stood by the TPPs in this.

The latest evidence of this comes in relation to the norms that require all TPPs to shift to a closed cycle cooling system.

What Is Closed Cycle Cooling

In thermal power plants, a large percentage of the energy obtained by burning fuel is lost as waste heat.  In coal based plant this can be as high as 65%. This heat needs to be removed from the steam that drives the power plant to ensure efficient operation of the plant and in most cases is done with the help of water.  An open cycle cooling system is where the TPP takes in water from a source like a river or a lake, uses it to cool the steam and releases the water back into the water source. This water is now at temperature higher than the water source as it has absorbed the heat from the TPP. This process needs massive amounts of water to be drawn, which can have significant impact, even though it is retuned back. Discharge of heated water too has several adverse impacts.

To cut down on the withdrawals, a closed cycle system is used. In this case, water that has absorbed the heat of the TPP is not released back to the source, but is itself cooled in the cooling towers. In cooling towers, part of the hot water evaporates and this helps in cooling it down. The cooled water is sent back to the TPP to cool the steam once again. This leads to much lesser withdrawals but more water is “used” due to evaporation in the cooling towers.

Each system has its advantages and disadvantages.

Total Non-compliance

Official documents obtained by Sunil Dahiya, Analyst, CREA under RTI and made available to us show that as late as Nov 2019, that is four years after the notification and two years after the expiry of the deadline to meet the norms,  49 units of 13 power plants with a capacity of 12,144 MW were still operating on open cycle cooling, in complete violation of the law of the land, as contained in the MoEFCC notification.

The names and capacities of the violators are given below. It should be mentioned that not all units from each of these plants are based on open cycle cooling. Unitwise details are not being given here.

Thermal Power Stations with Once Through Cooling System

Sr.No.	Developer	Name of Plant	State	Capacity (MW)
1	UPRVUNL	Anpara TPS	Uttar Pradesh	1630
2	NTPC	Farakka STPS	Bengal	1600
3	CSPGCL	Korba West TPS	Chhatisgarh	840
4	RRVUNL	Kota TPS	Rajasthan	850
5	UPRVUNL	Obra TPS	Uttar Pradesh	1094
6	UPRVUNL	Parichha TPS	Uttar Pradesh	220
7	NTPC	Rihand TPS	Uttar Pradesh	1000
8	PSEB	Ropar	Punjab	420
9	MPPGCL	Sanjay Gandhi TPS	Madhya Pradesh	1340
10	GSECL	Sikka Rep TPS	Gujarat	120
11	NTPC	Singrauli STPS	Uttar Pradesh	2000
12	Tenughat VN Ltd	Tenughat TPS	Jharkhand	420
13	GSECL	Ukai TPS	Gujarat	610
	TOTAL			12144

Source: Letter No. 30-5/1/2019/ St. Th dated 21^st Nov 2019, written by R.K. Das, Under Secretary, Ministry of Power, Government of India, to Nidhi Khare, Jt. Secretary, MoEFCC, Government of India. (Obtained by Sunil Dahiya, Analyst, CREA under RTI)

Ministry of Power Justifies Violation, Requests Exemption

What is even more of concern is that the Ministry of Power (MoP)  is effectively justifying these violations, condoning them, and has appealed to the MoEFCC to exempt these power plants from the norms. The letter quoted above is a letter from the MoP where it has sought the exemption, and  has given several reasons to justify the same. These include technical non-feasibility  due to lack of space and layout restrictions, and that such shift to closed cycle cooling will lead to “decrease in unit efficiency,  higher emissions and  increase in water consumption”.  They also argue that these units are old and “reducing in numbers”.

This entire set of reasoning is specious. We won’t get into a detailed discussion of these reasons here as it would take lot of space.  Here, it is sufficient to mention that the significance of these arguments is quite overstated by MoP;  that there are numerous benefits of shifting to closed cycle cooling that are not mentioned; and that there are serious impacts of continuing with the open cycle cooling that are also not factored in by MoP.

As in any choice, there is always a trade-offs, and so there is between open and closed cycle cooling. It should be noted that the advantages of closed cycle were significant enough that the Government of India notified that all new non-coastal TPPs commissioned after 1 June 1999 would be based on closed cycle cooling[2]. In 2015, the MoEFCC notification required that any remaining TPP still operating on open cycle should shift to cooling tower based closed cycle cooling. This decision of MoEFCC in 2015 was taken after considering all the factors that MoP is bringing up now. So MoP is just bringing up old justifications which were considered and found not significant.

To elaborate, when these norms were put out as draft notification, the MoP and others had been given a chance to give their comments and they had had detailed discussions with the MoEFCC. Even after the norms were notified, the MoP raised these very same points (related to shift to cooling towers) in June 2016, along with points related to some other norms in the notification. (Documents accessed under RTI). It is noteworthy that the MoEFCC did accept some of the feedback from MoP and changed some norms related to coastal power plants. But for all others, MoEFCC squarely rejected MoPs arguments and the notification stayed as it is. A legally binding regulation.

Yet, it is amazing that the power plants have chosen to ignore it totally. Clearly, they can do this only because they seem to have the backing of the MoP. MoP’s actions also indicate a condoning of the blatant non-compliance and violation of the law of the land. Moreover, by taking up again and again the same arguments with the MoEFCC, the MoP makes it appear that such norms – notified by another arm of the government after due consultations and considerations – are something that need not be taken seriously, that can continue to be evaded, debated and are essentially negotiable. Imagine if an ordinary citizen did this.

In fact, MoP has been playing this role in many of the other norms notified in the same notification too: the SO2 norms, the NOx norms, the specific water consumption norms. We will highlight these in a subsequent blog.

This is a clear indication that the ministry of power considers itself superior to the ministry of environment in the unsaid hierarchy that prevails in the system. The complete lack of any action against the non-compliance, and the total silence and acceptance of these actions by the MoEFCC only indicates that MoEFCC is willing to accept this secondary position and abdicate its responsibilities and duties.

 

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[1] Documents obtained by Sunil Dahiya, Analyst, CREA under RTI and made available to us.

[2] EPA Notification [GSR 7, dated Dec. 22, 1998] Amending the Environment (Protection) Rules 1986.