- The EIA Does Not Disclose that the Proposed Power Plant’s Emissions of Air Pollutants Would Violate Japanese Ambient Air Quality Standards and Result in Excess Premature Mortality
The proposed Matarbari 2X600 MW Ultra Super Critical Coal Fired Power Project, Phase-2, (Unit 3/4) project has been financed by the Japan International Cooperation Agency (JICA) with five separate overseas development assistance loans. Tokyo Electric Power Services Co. Ltd (TEPSCO) has drafted the EIA for the project. On the principle that government-backed lending institutions should not finance projects that would fail to comply with environmental standards of the lender country, the impact of the proposed Matarbari 2X600 MW Ultra Super Critical Coal Fired Power Project, Phase-2, (Unit 3/4) must be measured against Japanese standards.
Table 4.13: Ambient air at different locations around the project site (Dry season) on pages 109-110 of the EIA provides the following information about baseline air quality.
Table 4.14: Ambient air at different locations around the project site (Wet season)
PM2.5 levels in the six samples collected at AQ-4 (Matarbari) average 19.9 µg/m3. PM2.5 levels in the six samples collected at AQ-5 (Dhalghata) average 17.9 µg/m3.
The Japanese ambient air quality standard for PM2.5 is a follows.
“The annual standard for PM2.5 is less than or equal to 15.0 μg/m3. The 24 hour standard, which means the annual 98th percentile values at designated monitoring sites in an area, is less than or equal to 35μg/m3. (Notification on September 9, 2009).”[1]
Because PM2.5 levels in Matarbari and Dhalghata exceed the Japanese ambient air quality standard for PM2.5 of 15 µg/m3, JICA and TEPSCO should have concluded that baseline air quality in Matarbari and Dhalghata do not comply with exceed the Japanese ambient air quality standard for PM2.5 and therefore no proposed major source of pollution may be located therein as the area lacks further assimilative capacity. Table 5.13: The impacts of air pollutants from exhaust gas on starting on Page 247 of the EIA predicts that Units 1-4 of project would cause an incremental increase in PM levels of 0.5 μg/m3 on an annual basis. Such increase would further exacerbate non-compliance at Matarbari and Dhalghata with the long-term (annual) Japanese ambient air quality standard for PM2.5.
The Japanese ambient air quality standard for SO2 is a follows:
“The daily average for hourly values shall not exceed 0.04 ppm, and hourly values shall not exceed 0.1 ppm (Notification on May 16, 1973).”[2]
An hourly standard for SO2 of 0.1 parts per million (ppm) is numerically equivalent to a standard of 262 μg/m3. Table 5.13: The impacts of air pollutants from exhaust gas on starting on Page 247 of the EIA predicts that Units 1-4 of project would cause a maximum incremental increase in NO2 levels of 322 μg/m3 on an hourly basis. As a result, air quality would violate the Japanese ambient air quality standard for SO2 by a substantial margin.
The Japanese ambient air quality standard for NO2 is a follows:
“The daily average for hourly values shall be within the 0.04-0.06 ppm zone or below that zone (Notification on July 11, 1978).”[3]
An hourly standard for NO2 of 0.04-0.06 parts per million (ppm) is numerically equivalent to a standard of 75.2 to 113 μg/m3. Table 5.13: The impacts of air pollutants from exhaust gas on starting on Page 247 of the EIA predicts that Units 1-4 of project would cause a maximum incremental increase in NO2 levels of 207 μg/m3 on an hourly basis. As a result, air quality would violate the Japanese ambient air quality standard for NO2 by a substantial margin.
In 2019, a Master of Science graduate from the Institute of Energy, University of Dhaka, and Research Assistant at the Nanoscale Research Laboratory, Department of Biomedical Engineering, The University of Texas, published a study using air pollutant disperion modelling to predict the health effects of expected air pollutant emissions of the proposed Matarbari coal-fired power plant (Units 1-4). This study concluded the following:
“This study reports the probability of increased mortality of people within the political border of Bangladesh due to the emission of fine particulate matter with diameters of 2.5 microns or less (PM2.5) from the Matarbari coal power plant (MCPP). A Gaussian plume dispersion model has been used for this estimation. The PM2.5 emission rate data are unavailable as the construction of MCPP is still in its initial stage; therefore, the anticipated PM2.5 emission rate has been estimated based on data from a number of coal-fired power plants in India and China. To make this study more meaningful, two different emission rates have been considered representing the best case and worst-case scenarios. In both cases, the intake fraction has been found to be 0.12×10−2, and the value of relative risk varies between 1.134 and 1.374, respectively. Finally, it is estimated that approximately 11.5 million people inside Bangladesh will be exposed to the PM2.5 emission from MCPP, and between 7,667 and 17,675 people will experience premature death every year.”[4]
The EIA failed to disclose the existence of this study, and the extent of annual premature deaths this study predicts that the proposed Matarbari coal-fired power plant (Units 1-4) would cause.
- The EIA proposes a coal ash disposal facility that is contrary to international best practice
Page 54 of the EIA describes an ash pond that would be constructed for the final disposal of more than 240,000 tons per year of coal combustion residues that would be generated by the project:
“Ash pond
“Ash will be disposed at 1st Ash Pond area the first after the commencement of Operation for Units 1/2. This 1st Ash Pond is designed/planned to be satisfied with the necessity capacity at least 5 years operation for Units 1/2. (Area of this 1st Ash Pond is 429,000m2 (Ave.)). After fulfill of ash in 1st Ash Pond, ash will be disposed in the remaining Ash Pond area continuously. In this regard, the Partition Wall will be constructed between the 1st Ash Pond and remaining
Ash Pond. The design of Partition Wall had been completed under the Units 1/2 Project, and the volume of the Partition Wall will be 248,000m3.
✓ The area of overall Ash Pond is 2,554,000 m2 (Ave),
✓ The average bottom elevation is MSL +1.0m.
✓ The top of Dyke in circumference of ash pond is MSL +14.0m.”
However, the proposed coal ash pond would likely violate international best practice with respect to its proposed location and design.
The proposed coal ash pond may lack adequate separation between the base of the ash pond and the upper limit of the upper most aquifer
Because of toxic constituents in coal ash, coal ash disposal facilities may not be located where such toxic constituents would be in close contact with important natural resources, such as aquifers and wetlands.
For the protection of aquifers, the United States Environmental Protection Agency imposes the following standard:
“40 CFR § 257.60 Placement above the uppermost aquifer.
“(a) New CCR landfills, existing and new CCR surface impoundments, and all lateral expansions of CCR units must be constructed with a base that is located no less than 1.52 meters (five feet) above the upper limit of the uppermost aquifer, or must demonstrate that there will not be an intermittent, recurring, or sustained hydraulic connection between any portion of the base of the CCR unit and the uppermost aquifer due to normal fluctuations in groundwater elevations (including the seasonal high water table).”
It is known that groundwater exists in the project area and is used by the local community. Page 118 of the EIA states:
“The quality of groundwater has been tested two locations Matarbari and Dhalghata union during pre-monsoon and monsoon period. The locations for water samples has been selected in such a way that it would represents the situation of groundwater status in study area.”
Note that according to page 54 of the EIA, the average bottom elevation of the proposed coal ash pond is only 1 meter above mean sea level (MSL). Therefore, unless the upper limit of the uppermost aquifer that provides groundwater to the community at Matarbari and Dhalgata is at least one-half meter below MSL, then there is no possibility for the proposed coal ash pond to maintain an adequate separation between the base of the coal ash pond and the upper limit of the uppermost aquifer requiring protection. Bore log data in the Appendices of this EIA or the 2013 EIA should provide information about the depth of the water table at locations where groundwater samples were taken.
The proposed coal ash pond would likely be located in wetlands
For the protection of wetlands, the United States Environmental Protection Agency imposes the following standard:
“40 CFR § 257.61 Wetlands.
“(a) New CCR landfills, existing and new CCR surface impoundments, and all lateral expansions of CCR units must not be located in wetlands, as defined in § 232.2 of this chapter, unless the owner or operator demonstrates by the dates specified in paragraph (c) of this section that the CCR unit meets the requirements of paragraphs (a)(1) through (5) of this section.
“(1) Where applicable under section 404 of the Clean Water Act or applicable state wetlands laws, a clear and objective rebuttal of the presumption that an alternative to the CCR unit is reasonably available that does not involve wetlands.
“(2) The construction and operation of the CCR unit will not cause or contribute to any of the following: (i) A violation of any applicable state or federal water quality standard; (ii) A violation of any applicable toxic effluent standard or prohibition under section 307 of the Clean Water Act; (iii) Jeopardize the continued existence of endangered or threatened species or result in the destruction or adverse modification of a critical habitat, protected under the Endangered Species Act of 1973; and (iv) A violation of any requirement under the Marine Protection, Research, and Sanctuaries Act of 1972 for the protection of a marine sanctuary.
“(3) The CCR unit will not cause or contribute to significant degradation of wetlands by addressing all of the following factors: (i) Erosion, stability, and migration potential of native wetland soils, muds and deposits used to support the CCR unit; (ii) Erosion, stability, and migration potential of dredged and fill materials used to support the CCR unit; (iii) The volume and chemical nature of the CCR; (iv) Impacts on fish, wildlife, and other aquatic resources and their habitat from release of CCR; (v) The potential effects of catastrophic release of CCR to the wetland and the resulting impacts on the environment; and (vi) Any additional factors, as necessary, to demonstrate that ecological resources in the wetland are sufficiently protected.
“(4) To the extent required under section 404 of the Clean Water Act or applicable state wetlands laws, steps have been taken to attempt to achieve no net loss of wetlands (as defined by acreage and function) by first avoiding impacts to wetlands to the maximum extent reasonable as required by paragraphs (a)(1) through (3) of this section, then minimizing unavoidable impacts to the maximum extent reasonable, and finally offsetting remaining unavoidable wetland impacts through all appropriate and reasonable compensatory mitigation actions (e.g., restoration of existing degraded wetlands or creation of man-made wetlands); and
“(5) Sufficient information is available to make a reasoned determination with respect to the demonstrations in paragraphs (a)(1) through (4) of this section.”
In its description of the baseline environment, page 136 of the EIA attests to the prevalence of wetlands in the project area:
“Due to salinity the amount of cultivated land in the study area is low. The huge amounts of wetland are used for salt cultivation during dry season. Apart from these some wetlands are used for fish cultivation. Aquatic vegetation in salt cultivation area is rare. Some aquatic vegetation is found in the fish firm [sic] area. a total 42 plant species recorded from this site. The most common species are Shapla, Kachuripana, Mulsi, Nukha, Hydrolea, Kolmi, Dholkolmi, Kachu, Helencha, and Heicha shak. A rare occurrence of Hogla also recorded in the wetland.”
There is no information in the EIA that would support: 1) a clear and objective rebuttal of the presumption that an alternative to the proposed ash pond is reasonably available that does not involve wetlands; and 2) a finding that the proposed ash pond would not cause or contribute to significant degradation of wetlands.
The design of the proposed coal ash pond lacks a required leachate collection and removal system
Because toxic constituents in coal ash seep and accumulate in the bottom of a coal ash disposal facility, a leachate collection and removal system is required to prevent such accumulation. With respect to coal ash disposal facilities, the United States Environmental Protection Agency imposes the following standard:
Ҥ 257.70 Design criteria for new CCR landfills and any lateral expansion of a CCR landfill.
“(a) (1) New CCR landfills and any lateral expansion of a CCR landfill must be designed, constructed, operated, and maintained with either a composite liner that meets the requirements of paragraph (b) of this section or an alternative composite liner that meets the requirements in paragraph (c) of this section, and a leachate collection and removal system that meets the requirements of paragraph (d) of this section. ….
“(d) The leachate collection and removal system must be designed, constructed, operated, and maintained to collect and remove leachate from the landfill during the active life and post-closure care period. The leachate collection and removal system must be:
“(1) Designed and operated to maintain less than a 30-centimeter depth of leachate over the composite liner or alternative composite liner;
“(2) Constructed of materials that are chemically resistant to the CCR and any non-CCR waste managed in the CCR unit and the leachate expected to be generated, and of sufficient strength and thickness to prevent collapse under the pressures exerted by overlying waste, waste cover materials, and equipment used at the CCR unit; and
“(3) Designed and operated to minimize clogging during the active life and post-closure care period.”
There is no information in the EIA indicating that the proposed coal ash pond would include a leachate collection and removal system.
The design of the proposed coal ash pond lacks a required groundwater monitoring system
Because toxic constituents in coal ash often breach liners beneath coal ash disposal facilities, it is necessary to monitor groundwater quality to detect any breach early enough to allow effective remedial actions in response to a breach. With respect to groundwater monitoring systems, the United States Environmental Protection Agency imposes the following standard:
“40 CF § 257.91 Groundwater monitoring systems.
“(a) Performance standard. The owner or operator of a CCR unit must install a groundwater monitoring system that consists of a sufficient number of wells, installed at appropriate locations and depths, to yield groundwater samples from the uppermost aquifer that:
“(1) Accurately represent the quality of background groundwater that has not been affected by leakage from a CCR unit. A determination of background quality may include sampling of wells that are not hydraulically upgradient of the CCR management area where: (i) Hydrogeologic conditions do not allow the owner or operator of the CCR unit to determine what wells are hydraulically upgradient; or (ii) Sampling at other wells will provide an indication of background groundwater quality that is as representative or more representative than that provided by the upgradient wells; and
“(2) Accurately represent the quality of groundwater passing the waste boundary of the CCR unit. The downgradient monitoring system must be installed at the waste boundary that ensures detection of groundwater contamination in the uppermost aquifer. All potential contaminant pathways must be monitored.
“(b) The number, spacing, and depths of monitoring systems shall be determined based upon site-specific technical information that must include thorough characterization of:
(1) Aquifer thickness, groundwater flow rate, groundwater flow direction including seasonal and temporal fluctuations in groundwater flow; and
(2) Saturated and unsaturated geologic units and fill materials overlying the uppermost aquifer, materials comprising the uppermost aquifer, and materials comprising the confining unit defining the lower boundary of the uppermost aquifer, including, but not limited to, thicknesses, stratigraphy, lithology, hydraulic conductivities, porosities and effective porosities.
“(c) The groundwater monitoring system must include the minimum number of monitoring wells necessary to meet the performance standards specified in paragraph (a) of this section, based on the site-specific information specified in paragraph (b) of this section. The groundwater monitoring system must contain:
“(1) A minimum of one upgradient and three downgradient monitoring wells; and
“(2) Additional monitoring wells as necessary to accurately represent the quality of background groundwater that has not been affected by leakage from the CCR unit and the quality of groundwater passing the waste boundary of the CCR unit.”
It is clear that the proposed coal ash disposal facility does not include a groundwater monitoring system that meets these requirements. Table 7.1: Mitigation of Impacts of the EIA starting on page 276 lists only the following Management Effort with respect to groundwater monitoring: “2) Ground water – Monitoring of water levels and water quality at wells in residential areas.” The proposed monitoring of water levels and water quality at wells in residential areas is not a groundwater monitoring system consisting of a sufficient number of wells, installed at appropriate locations and depths, to accurately represent the quality of background groundwater that has not been affected by leakage from the proposed coal ash pond and accurately represent the quality of groundwater passing the waste boundary of the proposed coal ash bond (such wells must be located at the waste boundary that ensures detection of groundwater contamination in the uppermost aquifer).
[1] Ministry of Japan – Environmental Quality Standards in Japan – Air Quality. http://www.env.go.jp/en/air/aq/aq.html
[2] Ibid.
[3] Ibid.
[4] Ahmed, S. I. U. (2019). Qualitative assessment on premature human mortality due to the emission of fine particulate matter from the Matarbari coal power plant. Environmental Quality Management, 29(2), 51-55.
