Tuesday, March 4, 2008

Syngenta's Goa Public Hearing Report

200 acres of Land where Syngenta is located is singnificant for MAND being populated with adivasi people and also the very important part of their homeland taken over by then Ciba Company then in 1969. Click here for the sale deed copy.

It is due to this reason primarily that this Syngenta's Public Hearing report is published here for the benefit of wider public interest and informed debate.This project led to first revolt of Liberated Goa in the decade of 1960s leading to prison terms to number of people from Dhulapi and Mangado villages. Chief reason being the leadership of the movement that time - Jan Sangh compromised for reasons yet to be known. Their leader in Goa - Shanbag too was ditched by its leadrship at higher level and left to languish in prison. Plant was errected fianlly after tremendous protests with police protection when Dayanand Bandodkar was Goa's first Chief Minister in 1971. Ciba Geigy- the pesticides company and Zuari Agro Chemical the India business house - Birla's fertilizer plant came to Goa in the decade of 1960s both occupied traditional adivasi lands on leased from different agencies - Church on one occasion of Corlim and Communidade on Sancoale to Birlas. Both the plants has relationship with agriculture - Chemical Pesticides and Chemical Fertilizers.

Santa Monica got hold of these land from Portuguese Colonial Regime that had confiscated these lands from adivasis as they refused to get converted to Christianity. it would have been good for the Church to return the land legally back to the adivasis than to lease it out to notorious Swiss Multinational producing dangerous pesticides.

This Swiss Multinational Syngenta's expansion plans threatens to siphon off 5000 cubic meters of water from Public Works Department pipeline per day. 1 cubic meter is equal to 1000 litres. It will also release 5000 cubic meters of effluent per day in Cumbarjua Canal that connects both Mandovi as well as Zuari rivers - Goa's two prominent rivers.

Its effluent in River Rhine in Switzerland was responsible for declaring it as biologically dead. Read on this government document to believe. Original document is available at Goa State Pollution Control Board (GSPCB), Panjim, Goa.

You can file your objections with GSPCB Member Secretary till March 30 2008. Read on...

Proceedings of the Environmental Public hearing held on 29/02/08 at 11.00 am at Old Goa Residency Hall, Old Goa with respect to M/s Syngenta India Ltd., santa Monica Works, Corlim, Ilhas, Goa, Survey no. 28, Corlim, Tiswadi Taluka, North Goa District, for their proposed expansion of the activities by manufacturing two new Active ingredients viz. Mandipropamide and o-Substituted Phenyl Amide (OPA) and also for expanding the facilities for the manufacture of Thiamethoxam and AE Phenol.

This Public Hearing is conducted as per the Revised EIA Notification dated 14/09/06. The Addl. Collector – I, North Goa, Shri Swapnil Naik welcomed the public for the Environmental Public hearing, and requested the public to present their views/ objections/ suggestions if any, after the applicant gives its presentation, and the same will be recorded and forwarded to the concerned Regulatory Authority, for obtaining Environmental clearance.

The representatives of the applicant have thereafter made a Power Point presentation by examining the contents thereof in Konkani language.

Thereafter the chairman called upon those present to seek information or clarification on the project from the applicant, if desired.

Accordingly, the following individuals have raised the issues / gave suggestions which are as under:

It was brought to the notice of the Committee that the date for submission of written objections is stated ass 30 days from the date of conducting of Public Hearing.

Shri Uday Rane stated that:
Since the last 30 years this company is existing and has benefited the people of the State and fully supports the same as it will provide employment to the local people.

Shri Floriano Lobo, Chairman Goa Env. Action Group stated that:
He is not against development, but his organization is for development and progress.
He desired to know whether there would be progress or destruction of the ecology due to the expansion of the plant, more specifically with regards to the flora and fauna present in the State and shown in the clip during the presentation.

He questioned on the emissions from the incinerators that will be dispersed and how they will affect the nearby villages. Particularly, effects if dioxins and furons will be felt only after 20 years. The destruction removal efficiency and capability of the incinerators should be checked and certified by the Pollution control Board.

The parent company was responsible for the destruction of life in River Rhine in Switzerland.
Whether the company would train its workers to fight the fire and control the disaster if it occurs.

Shri Durgadas Gaonkar – Dhulapi Village, President of Gawada, Kunbi, Velip and Dhangar Federation stated that:

Population consists of 95% tribal people which does not make a mention in the report.
The land where the company stands is agricultural area.

The company has not benefited the local people as only 3 people are employed from Dhulapi village out of 1500 population. The presentation does not show these these figures.

The land belongs to the villagers but the people of this village are not benefited by this company.
He raised the following queries- REIA report is prepared in summer of 2005. as per the new Notification the report should be prepared under the EIA, the same is outdated and has requested to re-conduct the Public Hearing.

Phosphamidon and Monocrotophos are infamous chemicals that Syngenta voluntarily agreed to phase out on a country to country basis several years ago and replace with newer generation pesticides, he desired to know whether Monocrophos was deregistered for all uses in USA in 1988.

Is GSPCB aware about the company’s predecessor responsible for the watershed event where the Rhine river was declared biologically dead due to the company’s discharges.

Has the Govt. authorities checked whether the workers working in the plant have received proper training and information about the hazards to the toxic chemicals

Whether the local authorities and the State authorities are provided with the detailed information about the chemicals used in the plant

Whether the residents of adjacent villages of Dhulapi and Mangado are made aware about the hazards of the toxic chemicals used in the plant.

Whether regular check ups of the machinery were made and replace the damaged parts and faulty instruments.

Whether there are facilities with the GSPCB for cross checking of the production.

Why the Syngenta wants to start the new production only in Goa and why not in other branches of the company

Why there is no mention of the World Herritage site at Old Goa which is just 2.5 kms from the plant is not mentioned in the REIA report.

Why Salim Ali Bird Sanctuary is not referred in the REIA.

He also submitted written objections.

Mr. Edwin De Sa – professor of Physics, Goa University, residing opposite the Syngenta Plant, stated that:

His bedroom is located opposite the plant of M/s Syngenta and in the last five years it is not possible to keep the windows of the room open due to the smell emanating from the factory and has lowered the quality of life. He questioned the company authorities regarding the same on a number of occasions, but has not received a satisfactory reply.

The figures shown in the EIA and the presentation are impressive. However, the methodology adopted to obtain them is not specified in the report. All parameters are functions of time.

He stated that monitoring stations should be installed in the villages and he offers his own house as a sampling site for air pollution. He stated that the monitoring should not be restricted to the company premises only.

Particularly carbon emissions from the incinerator are responsible for the smell. During the night the wind blows towards the residential houses and emissions generating smell disturb the sleep of the residents in the vicinity. All the gaseous effluents are received by the residents.

He desired that continues monitoring of gaseous emissions / effluents should be carried out.
Desired that GSPCB should monitor all effluents discharged in the Cumbarjua canal.

Effluents is discharged into the Cumbarjua canal and the pesticides are likely to accumulate in the canal that connects both Mandovi and Zuari rivers, and there is difference in time in tidal movements.

Dr. Joe D’Souza – Ex-Professor of Goa University stated that:
Monitoring of the Sampling is done in the opposite direction of the wind and hence does not reflect the actual values.

The company has stated regarding the Central Excise and foreign Currency earnings due to operation of the plant.

Employment opportunities are not given to the locals. Most of the revenue goes to the Central govt. and only 3% of he revenue benefits the State.

The changing in the scientific data after two years does not make any difference.
There are lot of anomalies in the report, on consistency in the readings of the parameters is contradictory to each other. All the figures are contradictory in nature and are full of discrepancies.

GSPCB does not have equipments to detect the heavy metals and pesticides and gaseous metals.
The Pollution Control Board should also carry out its own Environment Impact Assessment and not to depend only on the EIA reports submitted by the Company.

The results depicted in the data do not contain bio-accumulation of the pesticides produced in animals but only general chemicals present in the environment.

There is no co-relation with the environmental data presented at the hearing.

Goa State pollution Control Board has no instruments to detect the presence of heavy metals and pesticides.

The GSPCB has issued consents for higher production level and the company actually only produces 10% of the capacity.

The expansion would require higher storage facilities for solvents and catalysts. Higher requirements of chemicals would also increase the transportation on roads which could lead to accidents. The EIA report does not speak regarding the same.

The EIA report does not state the methodology and the study carried out to state that Cumbarjua canal has the carrying capacity of 5000 cum/day of effluent generated by the company.

Prof. Tushar Anveker – St. Xaviers College, Mapusa, stated that:
The data provided in the EIA report to be verified by an Independent agency agency before granting permission for expansion.

Adv. Nilesh Shirodkar – ex-employee of Syngenta stated that:
All the environmental parameters should be controlled and at least 50% employment should be given to the locals as such expansion of the project should be allowed.

Dr. Claude Alvares, Director, Goa Foundation
stated that:
Since all the employees of the company are present in the hall for public hearing, there is probably nobody attending to the plant and this could be dangerous to the public. He objected to the employees of the company occupying front rows for the hearing and said that this was a company hearing and not a public hearing.

He desired to know whether the company informed the Ministry of Evn. & Forest, Govt. of India had rejected the expansion proposal of the company. As per the 73rd amendment of the constitution, project rejected by the Village panchayat cannot be allowed as the panchayat has to grant permission under section 68 of the Panchayat Act.

Since the last two-three years there have been over 73 Public hearings in Goa and he has attended more than 30 of them and not a single project is rejected by the Ministry and this one is only a circus. Environmental clearances are issued on the basis of cash given to the concerned Minister.

He informed the public that within 3 to 4 months Clearance will be issued by the MOEF irrespective of the objections of the village Panchayat and the people attending the hearing today.

He desired to know whether the company had commenced any construction activity including land development, cutting trees etc. as the same is under the EIA Notification prior to obtaining Environmental Clearance.

Why is the company submitting the REIA done in 2005. As per the Revised Notification of 2006 there is no provision for REIA report. The company should carry out a detailed EIA report for all seasons and then come for public consultations.

The incinerator is utilized for the disposal of chlorinated waste and hence the EIA report should have stressed on the monitoring of he dioxins released from the incinerator an the impact in the vicinity on the water, air, land, flora and fauna. However the EIA report is silent on the same and only one stack analysis report from a laboratory in Belgium has been annexed.

He wondered whether the company would apply the same standards which are applicable in Switzerland to their unit in Goa. He further stated that this proposal would have been rejected in Switzerland.

At present there is no laboratory in the country which can carry out dioxin monitoring and analysis in the country. Central pollution Control Board has recently established a small facility. The monitoring as presented in the report is done by the company itself.

The laboratory recognized by the MoEF are not authorized to carry out EIA studies and the work carried out by the said laboratory is not permissible and illegal, and hence this report cannot be considered for taking decision on the expansion of the plant.

The EIA should be repeated as it has failed the tests especially with regards to monitoring of dioxins and their impact on the environment. It is the responsibility of the company to prove that they are not releasing dioxins in the atmosphere. The method adopted in the report with regard to destruction of dioxins is unacceptable and the company should utilize the formula prescribed by the United States Environment Protection Agency (USEPA). The method adopted in the EIA report on basis of analysis of ash from the incinerator is not acceptable and is not an international practice. He deplored the erecting of three incinerators for burning of hazardous waste and said that this is not an environmentally sound practice.

As per the provisions of the Hazardous Waste (Management and Handling) Rules, which came in force in 2003, it is mandatory for the company to follow a waste reduction and recycling policy. However, the report is silent in this regard.

ETP sludge of pH is 12.5 and is dumped in the Dharbandora quarry. Permission for the same has not been granted by the Goa State pollution Control Board. The same is in violation of the hazardous waste Rules; as such the company should be shut down as per the provisions of the Hazardous Waste (Management and Handling) Rules and Supreme Court Orders.

The 73rd minutes of the Expert committee states that the company should produce authorization from Goa State Pollution Control Board for disposal of sludge from their ETP in a quarry at Dharbandora and also obtain permission from PWD for additional water requirement. Both these have not been produced.

He desired to know as to why is the company not harvesting rain water. The analysis report of the ground water indicates that the same meets standards for physico – chemical parameters. He desired to know why the ground water does not meet the drinking water standards, as the disposal of sludge or operation of the unit caused ground water contamination.

The EIA report is total failure and the same has to be re-drafted.

The company has not disclosed its profits and it appears from the opposition of the local villagers that the local population has not benefited from the project.

The villagers residing in the nearby vicinity have not been informed and trained on the Disaster Management Practices.

Monocrotophos was de-registered in USA 20 years ago. The company still manufactures the same in Goa plant.

Dr. Dhume – Environment Action Group stated that:
Copy of the Public Hearing minutes should be available in the Panchayat.

If there is any effect on the Environment due to the operation of the factory then it should be shut down.

Mr. Anand Shirvoikar stated that:
As per the EIA report the samples were collected in summer 2005. he desired to know why the same are not collected during monsoons.

He desired to know whether the monitoring was done during the day or the night.
He desired to know the amount of trees present before the commencement of the plant and the present status.

The smell from the factory comes in the mornings and late evenings and the stack monitoring has not been carried out during that period.

Mr. Deepak Karmalkar – Computer Engineer and Environmental Teacher – Old Goa stated that:

He sought information regarding the company from the Internet and it reflected as follows: 4 million gallons waste was dumped in Atlantic Ocean, 4 lakh tons of DDT has been dumped in Tanzania. 30 tons of 35 different types of chemicals dumped in the river Rhine killing fish.

Explosion in the pesticide plant in Pakistan.

What disaster management plan has been prepared if disaster takes place in the area, no information is given as to where and how the people will run.

Monocrotophos is an insecticide and extremely toxic to birds and used as bird poison and harmful to humans.

Mr. Soter D’Souza – Member of Peaceful Society, Madkai stated that:
The EIA report prepared by the company has to be assessed by the Environment department.
Since there will be expansion there will be increase in capacity of storage of chemicals.

The report does not mention the species which has become extinct due to the operation of this plant. In case of accident what would be the impact and effect on human life.

How many Goans will be employed by the company.

Whether this expansion project was rejected in any part of India.

Impact on the infrastructure along the transportation route not reflected in EIA report.

Shri Venkatesh Chodnekar stated that:
Monitoring should be carried out during all the seasons only then EIA report should be taken into consideration.

Shri Raghuvir Naik stated that:
There is always gas leakage at nights. Inquiry at the gate is futile as the company officials do not entertain the complaints of the local people.

Siren is rung for the safety of the employees and not for the safety of the villagers. Mock drill has to be conducted for the safety of the villagers.

For the last 35 years the company has not done anything for the benefit of the villagers.

Dr. Kashinath Jhalmi – Ex-MLA stated that:
Since the project is for expansion, the details of the chemical reactions, baseline data etc for the new products has not been included in the EIA report. A detailed report has to be placed before the public as per the amended EIA notification particularly with regards to the impact on environment due to manufacture of new products. Public Hearing should be re-conducted as these important facts are considered in the report.

A comprehensive EIA report should be prepared with all the required information should be prepared giving all the relevant data.

Shri Mathany Saldanha stated that:
The total details of the new products should be submitted.

What are the standards adopted in other parts of the World where such products are manufactured, the same standards should be adopted at this facility.

The report should not be prepared by the company but should be prepared independently by Goa State Pollution Control Board and Central pollution Control Board.

Shri Amol Navelkar stated that:
The questions raised by the public during the hearing should be addressed and a Hearing should be held afresh.

Shri Atchut Dulapkar stated that the attendance sheet has not been stamped by the Goa State Pollution Control Board.

Shri Pandurang Kukalkar, General Secretary of Gawada, Kunbi, Velip and Dhangar Federation stated that:

The presentation does not show any houses in the vicinity of the plant but only shows the ecology around.

The rain water which is accumulated in the lake near the plant damages houses.

He desired to know the employment opportunities given to his community. He desired to have first hand information on the functioning of the plant.

The company should adopt the village adjoining to the plant and strive for the development of the village.

Shri Tushar Usgaonkar stated that:

The plant started operation in 1970s and as off now the pollution control equipments are being modified. If there has to be development then precautions have to be taken for controlling the pollution levels and standards should be prescribed.

Factory should be allowed to expand and measures should be taken to control the pollution, so also pollution could be provided to the local people.

GSPCB and the Govt. should ensure that pollution measures should be monitored.
He fully supported the expansion proposal of the company.

Shri Goraknath Kerker stated that:

The operation of the company has not benefited the locals and they have to suffer due to the smell generated from the operation of the plant.

He also desired to know what measures the companyhas taken in case of emergency. He strongly opposed the expansion of the project.

Mrs. Pritam Gaonkar stated that she is a representative of the Self Help Group and was invited by M/s Syngenta for a meeting and were requested to support the expansion project.

Clarification of the Company

Shri Rajiv Aunde, representative of M/s Tera clarified as follows:

♣ The Ministry of Env. & Forests has published a manual on Preparation of EIA. The said Manual prescribes the methodology and Procedures/ and locations of monitoring.

♣ Efforts has been made to prepare the EIA report as specified in the Manual of MoEF and have an impartial and scientific assessment.

♣ Since this company does not have expertise in all fields, they have outsourced the work to experts in the relevant fields.

♣ Dr. Nayak, Professor and Head, Department of Marine Science, Goa University, has carried out monitoring of the Cumbarjua canal, and the modeling for the same has been done by Dr. Anand – Ex-Dy. Director and head, ocean Engg. Dept., National Institute of Oceanography, Risk Assesment studies has been carried out by D.K. Joshi. Consultant. Terra Firma.

♣ The stack analysis report for dioxins has been carried out by SGS India Pvt. Ltd. And analyzed in Belgium. The same agency carries out dioxin monitoring for CPCB and Maharashtra pollution Control Board. He agreed that chlorinated waste is incinerated and hence frequency of dioxins monitored needs to be increased. He agreed to include it in EMP.

♣ The company has installed a highly sophisticated incinerator supplied by M/s thermax which is reputed company. The said incinerator has five levels of pollution control systems. The incinerator meets all the guidelines prescribed by the Central pollution Control Board. The pollution control measures include rapid quenching, two wet scrubbers and an electrostatic precipitator. Considering this level of pollution control equipment it is highly unlikely that particulate organic carbon can be emitted from this incinerator is responsible for the same.

♣ He further clarified that the World Heritage Site and the Dr. Salim ali Bird Sanctuary has been mentioned in Item 3.1.1, page 54 in the chapter on land and Environment and in Form I submitted to MoEF.

♣ Regarding new generation of pesticides – Dept. of Agriculture, Govt. of India has published a list of 140 pesticides that are permitted in the country. Some of these have already banned in the developed countries.

♣ The older generation of Pesticides i.e. organo chlorine requirement was applied and 5 kg per hectares and were persistent. The applications of second generation of pesticides are bio-degradable, non-flammable, non-oxidizing and non carcinogenic and have LD 50 more than 2000 mg/Kg. they are also odorless. Their application is at the rate of 100 gms/hectare. Hence the requirement of pesticide would drastically reduce. The country is getting access to such higher technology pesticides through this project.

♣ The Company has stopped manufacture of Monocrotophos. The Material Safety Data Sheet of the raw materials required for the new products is available with the company. The raw materials are non-explosives and non-carcinogenic.

♣ The waste reduction methods adopted by the company would be included in the report. The company has got inplant controls such as segregation, holding tanks, ISBL pits. The effluent is detoxified using solvents extraction, hydrolysis and cooking. Only effluents which are 70% biodegradable are sent to the ETP.

♣ The Company has established a R & D centre. The company has 35 manufacturing sites out of which only 4 sites have R & D centers and one of them happens to be in Goa.

♣ The chapter I and IV of the REIA report has all the relevant information about new products and the processes.

♣ The Company has three levels of safety measures which include computerized DCS control system, online monitoring, double scrubber and condenser provided for vents. The reactors are covered.

♣ All drivers are trained for accidents and disaster management and the company has a separate crew to deal with road accidents. This crew has helped during various road accidents occurred in the State.

♣ He stated that that siren is an early warning system and off site emergency plan been prepared and available with the District Magistrate in case of natural disasters like earthquakes, such early warnings are not available and yet we have to take care of our elders.

Shri Ulhas Joglekar of M/s Terra Firma stated that the Country is predominantly dependent on agriculture and it is necessary to phase out older generation pesticides and produce new generation pesticides.

Dr. G.N. Nayak, Head, Dept. of Marine Science, Goa University stated that he has worked on river Mandovi, Zuari and Cumbarjua Canal since 1988. He has carried out four projects for MoEF, govt. of India on the same.

He stated that our riverine system is monsoon controlled and also pollutants are washed during the monsoons. Hence pre-monsoon is the best period to carrying out sampling analysis. Sampling has been carried out during pre-monsoons in the year 2005 and 2007 and the methodology adopted is the same as carried out to the earlier 4 projects. He said that there is no doubt about the quality of the data and the same could have been published in international journals if it was not being carried out for the company. He also stated that he has studied Mayem Lake environment with reference to mining impact and such report was used in the Court of Law to take appropriate steps to control pollution entering the lake.

Dr. Anand, Ex-Dy. Director, Head, Department of Ocean Engineering, National Institute of Oceanography, Goa stated that the software used for modeling purpose has been developed at M/s Environ Software pvt. Ltd., Bangalore and has been extensively used in the R & D and sponsored programmes by the National Institute of Oceanography and its regional centers in Mumbai and Kochi. Also this model is being used by the Environ Software for various consultancy projects sponsored by Reliance industries ltd., at Jamnagar and other prestigious projects in India. Input for the model is based on 15 days continues measurements art designed locations in the Cumbarjua canal covering parameters, tides, currents, chemical and biological parameters. Results of the modeling studies reveal that there is a good flushing in the Cumbarjua canal; hence possibility of any stagnation is unlikely. Answering to the question of 5000 cum/day discharged quantity. It is clarified that with good engineering solutions it is possible to achieve the 5000 cum/day discharge. For this purpose, the total discharges has been split into two separate discharges of 2500 cum/day each and taken by two separate pipelines and discharged within the extreme boundaries of Syngenta with the help of two separate designed diffuser systems. With this arrangement, the model results show that the released effluent at these two discharged locations attain the ambient quality within around + 50 meters on either side of the diffuser.

Since there has been a discrepancy in a the advertisement and brought to the notice by the public, 30 days time has been given to file the objections/suggestions from the date of Hearing and the objections received will be then forwarded to the concerned regulatory authority to the Goa State pollution Control Board. The Company has objected to the same.

Recorded minutes were read out to the public in English and Konkani and Subsequently after receiving suggestions and as agreed were signed by the Addl. Collector – I and Assistant Environmental Engineer, GSPCB.

131 no. of people present for the Hearing have signed the attendance sheet.

On this 29th day of February, 2008

(Shri Swapnil Naik)
Addl. Collector – I. North Goa


(Shri Sanjeev Joglekar)
Asstt. Env. Eng., GSPCB

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