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Jamnagar's Lakhota Lake: image courtesy Gujarat Tourism
The Union Ministry of Environment and Forests (MOEF) is set to rein in Gujarat’s rapid growth as a global refining-cum-petrochemicals hubs ostensibly to minimize the risk of air pollution in Sikka-Vadinar area of Jamnagar district. 
A team of experts operating under the aegis of Ministry of Environment and Forests has pitched for regional environment impact assessment (REIA) study of sulphur dioxide (SO2) emissions from refineries, power, fertilizer and other plants operating within a distance of 25 kilometres in the area.
The team made this recommendation after visiting Reliance Industries Limited’s (RIL’s) Jamnagar refinery-cum-petrochemicals complex on 11th January 2014. 
MOEF’s Expert Appraisal Committee (EAC), for industrial projects which had sent the team, has promptly accepted the team’s recommendation. MOEF has to now commission an independent REIA study.  
According to EAC’s minutes, “The Committee further decided that a Regional EIA Study would need to be carried out independently for all the Industries operating in the area; however, the EIA-EMP for the present project could be prepared while the REIA is undertaken.”
EAC affirmed: “The Committee was of the view that a cap of the SO2 emissions requires being examined in a regional context, this is especially in view of the fact that there are a few other industrial units (ESSAR Refinery, Fertilizer Plant, etc, operating within a 25km distance). Thus, a Regional Impact Assessment (REIA) Study would be required to assess and cap the overall SO2 emission load that could be permitted from the area.”
This proposal for ceiling on regional emissions might well lead to denial of environmental approvals to expansion projects of companies operating in the region or stipulation of stringent emission control and monitoring norms. Approvals for setting up of greenfield process plants in the area would certainly become difficult to secure. 
EAC says that RIL has committed that it would implement in REIA’s recommendations, as and when made available, at its Jamnagar Complex which it intends to expand in big way.
EAC has recommended to MOEF the terms of reference (TOR) for EIA study on RIL’s expansion project.  This would obviously be different from REIA and would like any other investigation commissioned by a project proponent.
  RIL had last year applied for TOR for its expansion project, which envisages increase in its refining capacity by 20 million tonnes per annum (mtpa) to 88.25 mtpa from the present 68.25 mtpa. This would further consolidate Jamnagar refinery’s status as the world’s largest refinery and India’s largest exporter of petroleum products. 
The project also provides for setting up of a few polymer plants and change-over of fuel for 450MW of total already approved captive power capacity of 2100MW from gas to coal. 
EAC’s visiting team (sub-committee, to be precise), observed: “They (RIL) have only one continuous ambient air quality monitoring station. Considering the large area, they should have at least 3 more AAQMS.”
It also noted that “On the whole, plant area housekeeping was found good except pet coke storage area in the refinery area and sulphur storage site at jetty area. At present, coke storage and sulphur storage area is uncovered.”
Jamnagar complex, spread over 7409 hectares, is split into zones – domestic tariff area and special export zone (SEZ). It is one of the world’s most integrated facility where one product or by-product of one steam is used as input by another stream in a long value chain. 
Noting that the complex’s total emissions are at present within the stipulated limits, EAC pitched for stipulation of unit/stack--wise emission standard for particulate matter, SO2, nitrogen oxides (NOx), etc.
EAC has specified that RIL should prepare an integrated EIA and Risk assessment report considering existing refinery, proposed expansion as well as petrochemical complex under implementation. 
EAC says: “Study report shall include the bulk storages with storage quantities, details of safety systems, safeguards provided against domino effect. Details of management of solid waste including catalyst& oily sludge, steps for mitigation of SO2 and NOx emissions, details of phosgene management (in case phosgene is to be produced) and model used for diffuser for discharge of saline water into sea.”
The comprehensive TOR recommended by EAC requires the company to submit an “action plan to cover the pet coke storage in the refinery area and sulphur storage site at jetty area.” 
The complex produces large quantities of sulphur and pet-coke as by-products of refining operations. 
The REIA initiative might trigger Ambani-Ruia tussle over expansion of their respective refinery-cum-petrochemicals complexes, both of which embraced latest technologies. REIA is also expected to cast its shadow over the projects of other companies such as the fertilizers expansion project of Gujarat State Fertilizers & Chemicals (GSFC).  
Essar Oil Limited (EOL), which operates a 20 million tonnes per annum (mtpa) at Vadinar, has ambitious plans to double the refining capacity as well as set up a slew of petrochemical units. EOL’s associate Vadinar Power Company Limited (VPCL) produces electricity and steam for the refinery.
GSFC is working on its proposal to undertake massive expansion of its diammonium phosphate/NPK complex fertilizers plant at Sikka.  Another Gujarat Government enterprise is currently expanding its coal-based power plant at Sikka. 
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