Uniformed Debate and Motivated Propaganda

The anti Rampal environment activists’ and a section of civil society continues its less informed unprofessional propaganda against imported coal based Rampal Power Plant under implementation by BIFPCL (A Bangladesh India JV Company).

The propaganda got fresh momentum following BIFCPL concluding contract with its EPC Contractor BHEL after it achieving financial closure (loan from EXIM India).

National Commitment to Protect the Sundarbans (NCPS), Bangladesh Parables Andolon (BAPA) and Doctors for Health and Environment (DHE) organized press conference in Dhaka for launching a study report by global environmental group Greenpeace.

The findings of the study suggested,

"About 6,000 people will be victims of premature deaths and 24,000 babies will be born underweight if coal –fired thermal power plant is implemented in Rampal."

Greenpeace specialist from Myanmar on Skype informed the press meet that the impact would happen over 40 years lifetime of the power plant. The report also stated that, the coal –fired power plant at Rampal upazila in Bagerhat will increase 24-hour average ambient levels of nitrogen dioxide in nearby localities which is up to 25 percent over the current national urban average and sulphur dioxide level up to 50 percent over the urban average.

The report further stated,

“Emissions limits for sulphur dioxide, nitrogen oxides, dust and mercury, a specified in the tender documents, are five to ten times higher than the best regulatory practice and technical state -of the –art emissions level. The plant could emit high levels of mercury, a potent neurotoxin that damages children’s brains and nervous systems and it could be sufficient to render fish unsafe to eat over an area of approximately 70 square kilometers around the power plant.

"Emission limits for sulphur dioxide, nitrogen oxides, dust and mercury, as specified in the tender documents, are five to ten times higher than the best regulatory practice and technical state-of-the-art emission levels," it added. Additionally, 10,000kg of mercury over the life of the plant could end up in coal ash pond, which is subjected to flooding. The additional mercury will pose further risks to the aquatic food chain.

Additionally, 10,000kg of mercury over the life of the plant could end up in either the coal ash pond, which is subject to flooding. This additional mercury will pose further risks to the aquatic food chain of the Sundarbans and the Bay of Bengal, impacting millions of people.”

The findings of the study report can create confusion and panic among the people of Bangladesh if these are not contested and clarified with actual analysis of Rampal Power plant. It is well understood that BIFCPL and client engineer were very much aware of the standard plant design and Bangladesh Department of Environment (DOE) conditions of approval of EIA while incorporating basic tender specifications in the tender document. The EPC Contractor BHEL will prepare detail design, specify the equipment upon approval of the client and would proceed to procure the equipment for construction. We are not sure which documents were the basis of the Greenpeace study. Even a very experienced Coal Fired Power plant developer and operating company like ONGC and EPC contractor like BHEL would construct a substandard power plant. World reputed Engineering and Consulting Company FISCHER would not approve any such plant which would cause adverse impacts on environment.

Media report quoting one of the activist stated that the pollution may even impact regions from Narshingdi to Kolkata. Few hundred coal fired power plants are in operation globally and many are still being built. Few may have isolated issues but most are not causing harmful impacts on the environment. Technology is advancing every day of coal fired power generation restricting emissions and pollutions. RPP is outside the exclusion zone of Sundarbans mangrove -14 KMs away from the outer periphery and 70 Km from the region earmarked for UNESCO world heritage. RPP is a Bangladesh government approved project. Government remains totally committed for the welfare and wellbeing of the citizen. The issues raised by activists and UNESCO have been duly addressed and responded over and over again. Still based on reports of theoreticians and academics repeatedly raising issues for panicking people through media is highly irresponsible.

Rampal power plant is BPDB, Bangladesh and NTPC, India 50-50 joint venture. It is a 2x660 MW imported coal fired power plant being designed for using super critical technology with added measures for SOX, NOX, Ash and Mercury removal devices. The design philosophy implicates project company restricting emissions and pollutions well below Bangladesh Environment law and International regulations.

Before responding the fresh concerns raised by the activists let us review global scenario. The abundance of coal and its diverse availability in more than 70 countries of the world makes it fuel of choice for power generation in most countries.

Echoing with fellow Chemical Engineer Dr Kazi Bayezid Kabir of BUET Chemical Engineering department the writer acknowledges that coal is a very complex molecule which contains mostly carbon with some hydrogen, sulphur, nitrogen, oxygen and some non-combustible constituents. Burning coal produces carbon di-oxide water vapour, sulphur dioxide and oxides of nitrogen in the flue gas, which contains oxides of various metals.

Top Twelve Energy Consuming Countries 
Global Energy Statistical Yearbook 2016

Country	Consumption (Mtoe )
China	3101
USA	2196
India	882
Russia	718
Japan	435
Germany	305
Brazil	295
South Korea	280
Canada	251
France	246
Iran	244
Indonesia	227

Top Twelve Electricity Generation Countries
Global Energy Statistical Yearbook 2016

Country	Generation (Twh)
China	5682
USA	4234
India	1368
Russia	1062
Japan	995
Germany	638
Canada	632
Brazil	586
France	569
South Korea	546
United Kingdom	338
Saudi Arabia	336

Top Coal Producing Countries 
Global Energy Statistical Yearbook 2016

Country	Production (Mt)
China	3538
USA	820
India	764
Australia	471
Indonesia	387
Russia	349
South Africa	248
Germany	186
Poland	136
Kazakhstan	107
Colombia	86
Canada	62

Top Coal Using Countries
Global Energy Statistical Yearbook 2016

Country	Consumption (Mt)
China	3732
India	990
United States	730
Germany	232
Russia	207
Japan	190
South Africa	179
Poland	131
South Korea	130
Australia	118
Kazakhstan	87
Turkey	78

China, United States and India are the top three energy consuming countries, power generation and consuming countries. The following discussion would evidence that off all fuels coal is the principal contributor to energy mix.

Changing Paradigm

Global Energy Mix: 
BP Group of Chief Economist Spencer Dale Statistical Review of World Energy

Fuel	Contribution %
Oil	33.0%
Coal	30.0%
Gas	24.0%
Renewable	2.8%
Nuclear & Others	10.2%

Renewable Energy: Solar, wind tidal, wave and biomass energy are covered under renewable energy. Hydroelectricity is often considered separately. Though considerable emphasis is given on renewables its contribution to global energy mix is merely 2.8% now. The worldwide activities in 2015 led to 385 growth of new energy coming from renewable though it hardly changed the overall contribution to global energy mix. China has moved ahead of Germany and United States as the largest producer of solar energy. Wind remains the top source among the renewable sources.

Country Wise Energy & Power Scenario:

China, USA and India are by far the three larger energy consuming, electricity generating and consuming countries. The changing paradigm of primary fuel use, advanced technology use for efficient energy use will largely dictate which direction the global scenario would move. Although these countries like others have started moving towards renewable energy but the reality evidence that fossil fuels (Oil, coal and natural gas) would continue dominating energy generation for decades ahead.

China: Over the past decade and a half Chinese GDP grew in double digit and consequently it became the highest power generation and consuming country. It also became major polluter and emitter for relying mostly on fossil fuels for power generation. The growth rate has been slowed down over the last couple of years and energy consumption growth has also been restricted. Chinese government has adopted a policy now for more efficient, self-sufficient, green and innovative energy production and consumption. They have announced Energy Development Strategy Action Plan (2014-2020) .

The features of the plan are-

• Capping primary annual energy consumption to 4.8 billion tonnes
• Limiting annual growth rate of below 3.5% till 2020
• Limiting annual coal consumption to 4.2 billion tons until 2020.
• Increasing the contribution of non-fossil fuel t0 15% by 2020 targeting achieving 20% by 2030
• Contribution of natural gas will be raised to 10%
• Contribution of coal would be kept below 62%

USA: According to EIA 4.08 trillion kilowatt hours (kwh) electricity was generated in 2016. 65% of the generation came from traditional fossil fuels (coal, natural gas, petroleum or other gases), about 20% was contributed by nuclear energy and 15% from renewable sources including hydroelectricity.

Fuel	Contribution %
Natural Gas	33.00%
Coal	30.40%
Nuclear	19.70%
Renewable	14.90 % (Hydropower 6.5%, Wind  5.6% , Biomass 1.5%,Solar 0.9% and Geothermal 0.4%)
Petroleum	0.6%
Other Gases	0.3%
Other non-renewable sources	0.3%
Pumped storage hydroelectricity	0.2%

India: BP statistical review 2016 on Indian Energy Market 2015 stated the following

• Increasing consumption of coal (+4.8%), oil (+8.1%), renewables in power (+13.7%) and nuclear (+9.5%) outweighed declines in hydro (-4.9%) and gas (-0.1%)
• Coal remained the dominant fuel contributing 58% of India’s primary fuel consumption.
• India’s share in global coal consumption exceeded 10% in 2015 the highest share ever.
• Renewable power grew by 13.7% in 2015 as the second highest increment ever.
• Energy intensity (the amount of energy required per unit of GDP) declined by 2% in 2015.

Addressing The Concerns Raised by Greenpeace Study Report

SOX, NOX, Mercury Emissions

We cannot agree that the extent of emissions from Rampal Power Plant highlighted in the report is based on current information. The EIA report predicted 819 g/s of SOX and 490 g/s of NOX emission per unit of the power plant. These meant approximately 52,000 tonnes of SOX and 15,500 tonnes of NOx per annum considering 100 % plant factor (PF). But the power plant wont just burn the coal and release to environment whatever it produces upon burning. EIA report mentions installations of Flue Gas desulphurisation plant (FGD)which would extract 90% of SOX resulting in an emission of 8.19 g/s of SOX from each unit ( 520 tonnes of SOx per annum from the plant). The section 58 of the DOE approval letter of EIA for the Rampal Power Plant stated,” without installation of 275 meter high chimney, effluent treatment plant (ETP), waste water treatment plant (WWTP) , settling pond , desalination plant, API oil water separator , high efficiency electrostatic precipitator (ESP) , “closed loop” flue gas desulphurisation plant (FGD) ,low knox burner , online air and water quality monitoring system and other pollution control equipment and obtaining Environmental Clearance Certificate the proponent shall not start operation of the plant. “

We are not sure whether Greenpeace study report took into notice the DOE conditions set it its approval letter of approval of EIA of the project. FGD uses sorbents ( usually lime /wet lime stone). The Japanese technology of Double flow scrubber type FGD using wet limestone, forced oxidation can have removed up to 98% SOx.Low –Nox burner using selective catalytic reduction (SCR) unit can reduce up to 92% of NOx.

The Japanese technology of Double flow scrubber type FGD using wet limestone, forced oxidation can have removed up to 98% SOx.Low –Nox burner using selective catalytic reduction (SCR) unit can reduce up to 92% of NOx.

Dr Kazi Bayezid an academic of BUET after reviewing various data and information observed that the air around Rampal Power plant location now has 9.1 microgram/cubic metre SOx. Use of FGD in RPP will restrict SOx emissions from the plant below1.5 microgram/cubic meter. So the air in Rampal and surrounding area after commissioning of RPP cannot have more than 10.6 -11.00 microgram /cubic meter of SOx . Can this cause any impact on Sundarban at 14 km away? Bangladesh environmental law permits emission up to 80 milligram/cubic meter.

Dr Bayezid also assessed the NOx emission in post RPP period. The present of NOx concentration around Rampal plant location is 18 microgram/cubic meter. Commissioning of RPP built to design parameters and use of low Nox burners would add another 4 microgram/cubic meter of Nox . The Environment law 1997 has permissible limit of 100 microgram /cubic meter.

Bayezid's study clearly negates the uninformed debate of SOx , Nox emissions clearly issues post RPP .

We have noticed that Greenpeace study has made Mercury emission a huge issue. Mercury is present only in traces in coal. It is usually less than 0.5 mg/kg (ppmw). Unlike other trace elements mercury is volatile in nature. The emission of mercury would largely depend on the quality and composition of coal used. It can vary from 0.2mg/kg to 0.5mg/kg. Installation of SCR can be useful in trapping mercury in addition to those trapped in FGD. Mercury emissions can be reduced to 90-95% by SCR.

Another major concern of coal fired power plant is ash- fly ash and bottom ash and ash disposal. 100% fly ash will be collected through dry ash collection system collection system and supplied to cement factories of the region. As contingency arrangement an ash pond will be provided for. Using high concentration slurry disposal system (HCSD) ash will stored in semi concentrated form negating possibility of ash escaping to surface or subsurface water. Hence the concerns raised in Greenpeace report about ash and mercury escaping into water from potential flooding. The embankments around the power plant area will also be built above the highest flood level experienced during Tsunamis.Bottom ash collected in the boiler can be used in internal road construction and land fill. 

Multi-stage closed loop water recycling system would ensure limited use of water. Central Eluent Monitoring System (CEMS) will monitor quality of water discharged to the water way to ph7 level. Only 0.05% of the water flowing at the leanest period in Posher River will be used as make up water, Effluent treatment plant operation will be centrally monitored also.

IFC standard of effluent discharge differential temperature ( intake to discharge ) of 2 degree Celsius would be maintained. Continuous Emissions Monitoring System (AAQMS) will monitor

• Flue gas temperature
• Nox, Sox, O2 and Oxides of Carbon Emission

Ambient Air Quality Monitoring System (AAQMS) will monitor air quality around the plant.

Conclusion

We are not sure what made Greenpeace make such conclusion that RPP in its lifetime of operation would cause a death of 6000 people and premature birth of 24,000 underweight Childs.Such observations can create unnecessary panic. The government of Bangladesh must instruct the local activists launching the report to come up with detail scientific explanations how such uninformed report could be let out in media without verifying the contents for accuracy.

Client Engineer or Project Company has not approved the plant design yet.EPC contractor will submit detail design, specification of equipment and documents for review and approval. Project Company will get approval of DOE complying with the conditions of approval of EIA . The above detail analysis negates the concerns raised in Greenpeace report. Hundreds of coal plants operating in different parts of world do not create such nuisance. Quoting few non-performing coal plants can be set as standard for RPP for which Government of Bangladesh is more committed than any other stake holder for ensuring environmental protection.

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Written By Saleque Sufi, an expert in energy sector infrastructure development, planning, construction management and operation in Central and South Asia and Australia, also served as an adviser to the petroleum ministry of Afghanistan.