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Escalating Ecocide in the Kudremukh National Park
Chapter2a

Chapter II
NEERI Report - Analysis

NEERI REPORT NOT ACCEPTABLE IN ITS PRESENT FORM
i) Deep mining issues not addressed (in 1.3.1 page 1.7) Comprehensive Environment Impact Assessment Report (CEIA) of mining by KIOCL - prepared by NEERI, it is clearly mentioned that the primary ore being mined will last for only for another 6 years at the present rate of mining.
Mineable Reserves (Page 1.5, Sec. 1.2.3)
The original mineable reserves at Kudremukh after taking into account the techno-economic factors were estimated at 362 million tons of weathered ore. For the present figure of mineable reserves, the figures of 362 million tons needs to be reduced by the quantity of ore that has already been extracted during past 20 years period of mine working. Taking in to account the ore quantity of 243 million tons that has been mined out upto 31.12.1999, the available mineable reserves as on 1.1.2000 work out to 119 million tons.
Considering the fact that only 119 million tons of mineable reserves are left as on 1.2.2000, and at the present rate of mining the ores will be exhausted in about nine years time.
The report also says that estimates have indicated a presence of about 310 million tonnes of mineable primary ore, below the weathered ore, which is expected to last for about 20 years. This can be mined only by deep mining and not by open cast method adopted at present.
Deep mining is an entirely different ball game from open cast mining, as the Kudremukh area is the 3rd wettest region in the world with heavy rains torpeding for 4 months in a year. The issue of flooding of deep mines by rain waters and plans for pumping out floodwaters from the deep mines and its impact on environment are not at all addressed in the CEIA.
Deep mining also involves use of different category of explosives than that are being used presently. The issue of deep mining, requires sesmological studies and earthquake prediction etc., since the area is considered as an earthquake prone area.
The CEIA recommends extension of lease, but has not dealt with the subject and the likely impact of deep mining in the chapters relating to identification of impacts, prediction of impacts and environmental disaster management.
The CEIA makes absolutely no reference to these problems and thus offers no remedial measures, whatsoever.
Except in one para, the CEIA (page 2.42) has discussed the deep mining subject as followsFor the Except in one para, the CEIA (page 2.42) has discussed the deep mining subject as followsFor the mining of primary ore, blasting will be required. Due to adotpion of latest blasting techniques as is being practical presently, the blasting is not excepted to generate higher levels of noise.
Certainly NEERI was not hired to give generalised complacent views on such a serious subject as impact of blasting in deep mines !
ii) Increasing of Lakhya tailing dam
In 1.34 (page 1.11) of the NEERI Report, the present height of Lakhya tailings dam (100 mts.) and its capacity 320 million tonnes are discussed. Since the tailings have more or less filled to the capacity of the dam, the CEIA says there are plans to build one more dam in Kachigehole or Singsarahole or raise the height of Lakhya dam by another 15 mts.
But impact studies, enviornment impact statement, and management plans are not discussed for the proposed dams to be built in Kachigehole or Singasarahole or raising of Lakhya dam height all of which are a part of the same project. The CEIA says that there is a separate EIA for Kachigehole dam.
The truncated approach for a single project is not tenable. Since no impact statements for Kachigehole dam, Singasara dam and raising of Lakhya dam, which are part and parcel of the KIOCL project are not made available in the present NEERI report, it cannot be accepted in its present form.
iii) Accidents and Mishaps are not addressed in CEIA
The history of development of dams and slurry pipes etc., are discussed, in the CEIA. But shockingly the CEIA has not discussed the mishaps that have occurred in the recent past where in the spillway of the Lakhya Dam had given way causing incalculable damage down stream upto Bhadra Reservoir.
As evidenced, in the Directory of National Parks and Sanctuaries, Karnataka, Management for Status and profiles, published in 1994, by Indian Institute of Public Administration.
(Page no. 48)
1992 part of Lakhya dam gave way, causing damage down stream
The State Government had appointed MD of Karnataka State Construction Corporation as a member of the enquiry committee vide G.O. No. ID 223 MM 91(P) dated 8.9.92 to enquire into circumstances that led to damage to Lakhya dam and determine the agencies responsible for the lapses and fix the responsibility.
Five times the slurry pipeline had leaked in the recent past. The latest slurry pipeline damage which resulted in gushing of slurry from 2 feet hole in the pipe at Kanyalu in July 2000. This left large deposits of slurry (4,000 tonnes) in fields and Ennehole stream because black and the effluents were carried for a length of 20 kms. down stream.
The Lakhya dam mishap was also viewed seriously and enquiry committee was constituted to enquire into the circumstances that led to the breach and to determine the agencies responsible for the lapses and fix the responsibility.
The CES Report has also questioned the structural safety of the earthen dam.
But shockingly the CEIA, prepared by NEERI, has avoided these questions and therefore no remedial measures are discussed in the CEIA Report, which is a serious lapse on the part of NEERI.
iv) Slurry pipe damage exposes NEERIS incompetence to address environmental issues.
It is believed the NEERI team conducted their environment impact studies for one year at the site. They have not bothered to look into the poor maintenance of the slurry pipe, which runs a length of 67 kms. to Mangalore Port crossing forest areas, agricultural fields and streams. Due to poor maintenance, thick vegetation had grown all along the pipeline and obviously no periodic inspections were carried out to check the condition of the 20 year old pipes. Predictably the ill maintained pipes gave way and huge quantities of Iron Ore concentrate gushed out of the pipe during July 2000. The company was ill-prepared in its environmental disaster management. It took over four months for the company to rectify the damage by felling 781 trees enroute the slurry pipeline.
The accident happened in July 2000 and shockingly the CEIA of NEERI submitted in November 2000, fails to mention the above accidents in its report. The identification of hazards - 6.01 under chapter Environmental Disaster Management (6.0) does not even discuss these associated problems from related activities. NEERI has given a clean chit to the company!!
The CES Report has also pulled the alarm chain, while mentioning that several instances of leakage of pipeline to Mangalore Port, resulting in spillage to streams and forests.
The NEERI-CEIA, ought to have looked into all the environment impact aspects and address them. The dangers of the slurry pipeline has been overlooked in their report, which has caused phenomenal damage to the environment. This aspect is another good example of NEERIs incompetance to address serious environmental issues.