Environment Impact Report
Submitted to the Government of Kerala
by the Peoples’ Environment Fact finding Panel
on the treatment of Njunangar Stream of Pampa River
using contaminated ferrous chloride.
1. A team consisting of environmental and human right activists,
scientists and other experts on river system visited Pampa to study
the pollution caused to the Njunangar stream of Pampa River by the
entry of sewage waste from the septic tanks of the Travancore Devaswom
Board and the impact of chemical treatment using contaminated ferrous
chloride. Before undertaking such a trip, the samples of the River
sediments of the chemical treatment of the previous year was taken
from the pits near Njunagar stream on 15th December 2009, and on
analyzing, the following heavy metals found in excess of the limits
which circumstance compelled the team to take follow up action.
Sl.No. Parameters Unit Method
Result
1. Lead as Pb mg/kg USEPA
3050 B 67.35
2. Cadmium as Cd mg/kg USEPA
3050 B 2.10
3. Zinc as Zn mg/kg USEPA
3050 B 97.80
4. Manganese as Mn mg/kg USEPA 3050 B
158.79
5. Iron as Fe mg/kg USEPA
3050 B 32016.98
6. Chromium as Cr mg/kg USEPA
3050 B 85.81
2. The team comprising 1) Dr.N.Chandramohan Kumar, Head, the
Department of Chemical Oceanography, Cochin University of Science and
Technology (CUSAT), 2) Advocate P.K.Ibrahim, High Court of Kerala,
Former Chairman of the Local Area Environment Committee-Eloor-Edayar
3) Purushan Eloor, Periyar Malineekarana Virudha Samithi and former
member of the Local Area Environment Committee-Eloor-Edayar 4) Jacob
V.Lazar, member, Wild life Board and Treasurer, Peoples’ Union for
Civil Liberties, 5) Dr.Thomas P.Thomas, Department of Botany,
St.Thomas College, Kozhencherry 6) Dr.A.Latha, River Research Centre
and 7) V.N.Gopinathan Pillai, Vice President, River Protection Council
under the Convenorship of Mr.R.Ajayan, a prominent social and
environmental activist reached Pampa at about 11 a.m. on 20-12-2009
and inspected Njunangar Stream, Sewage Treatment Plant at Pampa and
collected river water samples and sludge of the previous year for
being analyzed.
3. The 176 km long Pampa River, originates from Pulachimalai in the
Western Ghats. Pampa is formed by the confluence of the Pampa Aar,
Kakki Aar, Azhuthai Aar, Kakkad Aar and Kallar. The river mainly
drains through Pathanamthita and Alappuzha districts before joining
the Vembanad lake. The Sabarimala shrine is situated in the Pampa Aar
catchment and Njunangar is a stream flowing near the Sabarimala shrine
and joining Pampa Aar downstream . The stream called Njunangar joins
at the point beyond Thriveni bathing ghat., All pilgrims are expected
to take bath in the holy river before starting the long climb to the
shrine. During the heavy pilgrimage season, the Pampa Aar turns into
an open drain of night soil, garbage, sewage and other human waste.
Pampa river has been identified as one of the most polluted rivers in
Kerala beyond limits. Around 35 local self governments depend on this
river for their drinking and irrigation needs.
4. According to people the tanks of the toilets and urinals at the
Sabarimala get filled within two weeks in pilgrim seasons and the
Njunangar stream virtually turn in to a sewage canal carrying human
excreta causing air and water pollution. The scene is horrific. The
water flow in the canal is very thin but the sewage discharge is
overwhelming. The stream becomes a sewage canal causing serious water
and air pollution all around its stretches. The only reason for such a
sad state of affair is the absence of a Sewage Treatment Plant at
Sabrimala. The septic tanks of the toilets and urinals, constructed in
hundreds permanently and thousands for temporary use, become
inadequate during season and thereby it overflows to the Njunangar
water stream rendering the water body into a sewage canal. This is
happening unabatedly over many years and all authorities concerned
namely the Travancore Devaswom Board, The Department of Irrigation,
Kerala Water Authority, The Health Department, Forest department, The
Pollution Control Board and the District Administration unfortunately
did nothing to find a permanent solution to this seasonal phenomenon.
The authorities have shown interest only in short term measures
exploiting the short memory of the people and lack of their collective
action. The short term measure over the last two years under the
recommendations of the Kerala State Pollution Control Board was to
treat the Njunangar stream using contaminate ferrous chloride obtained
from Cochin Minerals and Rutiles Ltd. as flocculent for sedimentation
purpose.
5. What is shocking is the use of this contaminated ferrous chloride
under the recommendation of the Pollution Control Board which has the
information about its potential imminent damage to the environment.
The concern of the people increased multifold on seeing various
reports appeared in the Press and electronic media. It is in this
background the panel visited Pampa to place the facts and myth before
the public and concerned authorities for a permanent solution to the
problem.
6. Contaminated ferrous chloride is a waste effluent of the Cochin
Minerals and Rutiles Ltd., Edayar. The raw effluent was being
discharged into Periyar River causing massive fish kill. The effluent
is bluish, greenish or reddish. The change of colour from blue to
green and to red shows different chemical forms of iron which include
the oxidation of ferrous to ferric states and various complexes of
ferrous and ferric in different pH ranges. The ferrous salts are
highly reducing and when discharged into the water, the ferrous iron
salts undergo oxidation absorbing dissolved Oxygen from river water
and thereby decrease the dissolved Oxygen level in the water. The raw
effluent from CMRL contains toxic heavy metals such as Zinc, Lead,
Mercury, Cadmium, Copper, Nickel, Manganese, Hexavalant Chromium etc,
along with a high concentration of ferrous chloride. These heavy
metals were found in the samples of the river sediments taken from the
outlet of CMRL in Periyar. The Local Area Environment Committee
appointed by the Pollution Control Board on the directions of the
Supreme Court Monitoring Committee on hazardous waste and management
were able to bell the cat and Cochin Minerals and Rutiles Ltd was
booked for violating the provisions of the hazardous waste (Management
and Handling) Rules 1989 and Water (Prevention and Control of
Pollution) Act, 1974. The Committee recommended for closure of the
unit, but it was allowed to function only on the undertaking that the
unit shall not discharge the raw effluents to the Periyar.
7. The Cochin Minerals and Rutiles Ltd. was the supplier of this raw
effluent namely contaminated ferrous chloride to the Cochin Chemicals
Ltd. of Dr.Sivasankara Pillai who is said to be the Godfather of the
environmental scientists and Engineers of the Pollution Control Board
and other consultants elsewhere. This unit had obtained authorization
under hazardous waste (Management and Handling) Rules 1989, for 5
years from 30.3.2002, but found no hazardous waste disposal facility.
The unit had no consent under Water (Prevention and Control of
Pollution) Act, 1974. It was found not complying with any conditions
of authorization issued under the hazardous waste (Management and
Handling) Rules, 1989. The premises of the unit and adjacent land are
found as hazardous waste disposal site. Trade effluents of other
companies were found discharged in this unit. The unit had not filed
any return to the Pollution Control Board as required under the
authorization issued under hazardous waste (Management and Handling)
Rules , 1989. Under the circumstance, Local Area Environment Committee
ordered the closure of the unit and even recommended to cancel the
accreditation given to Dr.P.Sivasankaran Pillai as an accredited
environmental consultant.
8. The sewage treatment system at Sabarimala cannot be treated as a
seasonal affair. It has to be a permanent ongoing process having due
regard to the number of devotees visiting every month. The devotees at
Sannidhanam on the first week days of every month are around 50000. On
other days there are devotees and other staff. The sewage generated
at Sabarimala Sannidhanam including the sewage of the seasonal
generation should go for a biological treatment of permanent nature at
Sabarimala itself by establishing a sewage treatment plant of adequate
capacity. Such a plant once installed and stabilized will run without
any interruption and can treat the sewage of fluctuating quantities
including the quantity during the peak season. This simple mode of
sewage treatment is economical and environmental friendly. It does not
even remotely cause any environmental pollution and it can easily be
maintained efficiently without any failure. One fails to understand
why this time tested environmental friendly technology is not insisted
to overcome the problem of pollution of such a magnitude of biological
waste at Sabarimala. It is this aspect which needs to be probed to
find out the vested interest of those who advocate chemical treatment
of sewage using contaminated ferrous chloride.
9. The sediments of the sewage treatment plant are manure by itself.
It can be flushed out to the forest without the fear of causing any
environmental damage to the forest. There cannot be any dispute in
the scientific community or for that matter among any environment
activist that biological sewage treatment technology is not practical
having regard to the volume of waste in particular seasons.
10. The process that takes place in biological treatment needs to be
understood to appreciate its merit and advantages. It is a simple
method of treatment with anaerobic digestion followed by aerobic
reactions to achieve the prescribed standard for discharge. A sewage
treatment plant before putting it to use required to get stabilized
which now by the advance of technology requires only less than a week.
In olden days for a biological treatment to stabilize the number of
days taken was 45 but that was by using cow dung as nutrient for
bacteria growth. Now bacteria are readily available in the market
which can stabilize the biological treatment units in 5 days time. The
fact that once the biological treatment is started and stabilized it
runs without any hindrance on an un-assumable minimum cost and it
operates faultlessly giving the required result. This being the merits
of the biological treatment system, one fails to understand why the
Pollution Control Board is not eager to insist the Travancore Devaswom
Board to establish Biological Sewage Treatment Plant/Plants of
adequate capacity.
11. It is a matter of common knowledge that prior to the invention of
biological treatment technology the chemical treatment was in use
which is called as Chemically Enhanced Primary Treatment (CEPT). In
this treatment the sediments contained many environmental pollutants
which had raised serious concern owing to the damage it caused to the
environment. As the concern for the environment protection grew, the
countries made the standard for discharge more and more strict which
ultimately resulted in going for biological treatment system, as it is
observed that in biological treatment system no additional pollutants
are generated than what is contained in the sewage namely the
Phosphates, Nitrates etc. The Pollution Control Board being an expert
body cannot be said to be ignorant of these facts. However why the
Pollution Control Board still remains a spokesperson of chemical
treatment? This question raises serious doubt on the integrity of the
persons who recommend chemical treatment using contaminated ferrous
chloride in every season rather than insisting for a permanent sewage
treatment plant which can take care of the sewage treatment
irrespective of the seasonal variation.
12. Before coming to the issue in relation to the prose and cones of
the use of contaminated Ferrous chloride for water treatment, it is
profitable to understand the very nature of contaminated ferrous
chloride supplied for water treatment by Dr.Sivasankara Pillai of
Cochin Chemicals. The contaminated Ferrous chloride is an industrial
waste of the CMRL, Edayar. This industrial waste is purchased by
Cochin chemicals and is marketed in the name of Envirofloc which is
technically called as ferrous chloride by the Pollution Control Board.
The contaminated ferrous chloride contain heavy metals such as zinc,
iron, led, mercury, cadmium, copper, nickel, total chromium,
manganese, Hexavalant chromium etc. The Cochin Chemicals, without
removing its heavy metals contents, market the same as en Envirofloc/
ferric chloride. The contaminated ferrous chloride/Envirofloc/ is a
hazardous waste being a chemical in the class E category of the
Schedule 2 of the Hazardous Waste (Management, Handling and
Transboundary) Rules 2008, and required in law to be dealt with as per
the provisions of the Hazardous Waste (Management, Handling and
Transboundary) Rules 2008. It is a Hazardous Waste under E3 and E4
having regard to its corrosive and toxic character regardless of
concentration limit. Class E 3and E4 category of the Schedule 2 of the
Hazardous Waste (Management, Handling and Transboundary) Rules 2008
waste is explained thus:
“Corrosive
Wastes which may be corrosive, by chemical action, will cause severe
damage when in contact with living tissue.
Toxic
Waste containing or contaminated with established toxic and or eco-
toxic constituents.”
13. The contaminated Ferrous Chloride has above 20% acidity and hence
corrosive .Further it is toxic and cannot qualify the Toxicity
Characteristic Leaching Procedure (TCLP Test). The use of ferrous
chloride is therefore a serious violation of environmental law and
permitting the use of contaminated ferrous chloride in violation of
Hazardous Waste Management Handling and Transboundary Rules 2008 by
the Pollution Control Board amounts to the fence eating away the crops
by itself.
14. It is this Hazardous Waste that is used directly in Njunangar
stream under the guise of water treatment. This chemical is used as a
coagulant for settling the Phosphatic and Nitrogenous contents of the
sewage as settled solids. But in the process, the heavy metal contents
of the contaminated ferrous chloride such as zinc, iron, led, mercury,
cadmium, copper, nickel, total chromium, manganese, Hexavalant
chromium etc. also get settled as solids with Phosphatic and
Nitrogenous contents of the sewage. The solids thus settled which
contain heavy metals is discharged to the open environment causing
serious damage to the living organisms. Discharge of sediments
containing heavy metals cannot be legally allowed to be discharged
into the open environment when it has the characteristics of a
hazardous waste. Unfortunately, unmindful of this serious infraction
of law, Pollution Control Board is permitting to pump the settled
solids containing heavy metals periodically to the nearby forest. Why
this illegal and prohibited activity is being allowed to take place,
who is the beneficiary and at what cost are questions that
Mr.Jayaprasad, the Chairman and the last word in Pollution Control
Board has to answer.
15. The Chairman of the Board characterized the sewage sludge after
chemical treatment as “manure as such” (compost) and “a soil
conditioner” and therefore found no fault with its disposal to the
forest. He however made a caveat when Dr.Viswas Mehta who was the Ex-
Chairman of the Pollution Control Board challenged the claim of
Mr.Jayaprasad that sludge after chemical treatment is as such a
manure. He clarified that if there is any difficulty for marketing the
sludge as manure; the same can be subjected to aerobic/anaerobic
digestion and then disposed as manure and soil conditioner. Dr.Viswas
Mehta then posed a question that if sewage sludge is manure as such,
why the sludge should be treated again “if it already is a stable
manure/soil conditioner”. This and other question that where does the
sludge analyzed by the Board etc. remains still unanswered. On
enquiry it is learnt that the Pollution Control Board in fact have
not conducted Toxicity Characteristic Leaching Procedure (TCLP) test
nor sludge analysis to come to a finding that the sediments after
chemical treatment does not pose any environmental damage. The Board
however permitted the use of contaminated ferrous chloride for water
treatment and the disposal of waste generated there from into forest
and other open areas. The use of contaminated ferrous chloride and
disposal of the solid waste after the treatment into the land and
water will find its way ultimately to the human being and other living
organisms. The toxicity effect of excess Zinc is gastro intestinal
distress, diarrhea, pancreatic damage and anemia. The excess Nickel is
a carcinogenic and dangerous to aquatic life. Cadmium is a highly
toxic both to plants and animals. Cadmium toxicity causes kidney
damages. Chromium is a carcinogenic and it damages kidney and liver.
Exposure to Copper will affect the fertility and embryonic sensitivity
in the living organism. Lead is highly toxic substance, which can
cause reduced IQ, attention deficit disorders, impaired hearing,
kidney damage, increase in BP, fertility problem, nerves disorders
etc. The toxic effect of exposure to iron leads to abdominal
discomfort, lethargy, fatigue and shrinkage of liver followed by
fibrosis and cirrhosis. When these heavy metals enter into the food
chain, a very serious and hazardous phenomena called ‘Biological
magnification or amplification’ of these toxic chemicals take place in
the end consumers of the food chain. This is the beginning of such
disastrous cycle in the ecosystem that cannot be allowed in any case
for the sake of public health.
16. The sewage pollution from Sabarimala is mainly that of coliform
bacteria count in the water. Coliform count is expressed as either
total coliform or faecal coliform per 100 millilitre of water. Faecal
coliform count is nearly half of total coliform count. Coliforms are
present in the faeces of warm blooded creatures. Once it is discharged
by the warm blooded creatures like animals and human beings, it does
not survive beyond 48 hours. It is bound to die by exposure to air and
sunlight. The coliform bacteria cause diarrhea, septicemia, thrombotic
microangiopathy and urinary tract infection. The presence of coliform
in water is indicated by the presence of pathogens and the various
pathogens/bacteria is the cause for diseases such as Nematode worms,
Anthrax, Dysentery, Tuberculosis, Paratyphoid fever, Typhoid fever,
Food poisoning, Bacillary dysentery, Tapeworms, Cholera,
Poliomyelitis, hepatitis. The total coliform count permissible in
water for public bathing is 2500 per 100 ml. The coliform count has to
be however zero in drinking water. The use of contaminated ferrous
chloride cannot remove pathogens and therefore the diseases that
pathogens causes cannot be prevented. Ferrous chloride is a coagulant
that only helps in the settling of the suspended particles in the
sewage and it is not effective in reducing the coliform count in the
stream. The coliform count can be reduced only by disinfection
process. The discharge of water after biological treatment cannot
cause any BOD problem and therefore there is no threat to aquatic
life. The best solution to treat the biological waste is the
technology of biological treatment only compared to the threat of
diseases that can be caused to human beings by heavy metals.
17. The justification of the Pollution Control Board for recommending
chemical treatment is that it is an effective measure to treat water
in short time. Recent studies in the water treatment field suggest
that the use of titanium dioxide as semi conductors can be subjected
to photo catalysis and this process can be used for water
purification. Titanium dioxide being not present in the waste ferrous
chloride, the photo catalysis is not possible by the use of ferrous
chloride. Adding titanium dioxide in to the ferrous chloride will not
help the process of photo catalysis since the application of titanium
dioxide in the form of a powder suspended in water to be purified
requires additional operation for separation of two phases, and
requires immobilization of photo catalysts. Deposition of fine
titanium dioxide powder on glass surfaces is the most common solution.
18. Water purification by the use of titanium dioxide does not require
ferrous chloride as it is not a coagulant for this purpose. The
direction of the Chairman to use titania also along with Ferrous
chloride is a strange science. The stand of the Chairman, some how to
use ferrous chloride under one pretext or the other, and for that a
new chemicals combination not used elsewhere is also directed to be
applied is totally unacceptable without any proof. In fact Water
purification by the use of titanium dioxide does not require ferrous
chloride as it is not a coagulant for this purpose.
19. If at all treatment with Ferric chloride is the only method of
water treatment, the same can be done with industrial grade ferric
chloride. Industrial grade ferric chloride is freely available in the
market and is cheap and that does not have heavy metal contents as
seen in the Ferric chloride of Dr. Sivasankara Pillai. This aspect is
completely brushed aside obviously with vested interest at the cost of
environment and health hazard.
20. In short, the chemical treatment using contaminated ferrous
chloride is an act inviting an environmental calamity making the
proverb “burning the house to kill the rat” literally true when there
are effective technology in vogue for combating the menace of coliform
bacteria with time tested proved technology. The Pollution Control
Board unfortunately at the earnest indulgence of its Chairman has
thrown to winds all the provisions of the environmental laws. The
chairman of the Board has virtually made the environmental laws an
onlooker. By doing so he has acted against public interest and
directions of law which he is statutorily bound to give effect. This
state of affair cannot be allowed to go even for a moment.
In the above circumstance, the people’s environmental fact
finding
panel recommends the following measures before the Government.
a) Direct the Pollution Control Board to ban river water treatment in
the state whether it be in Pampa or elsewhere using contaminated
ferrous/ferric chloride/Envirofloc.
b) Direct to remove the temporary bund constructed across the
Njunangar stream and allow the stream to have its natural flow so
that the air pollution and water pollution by retaining the polluted
water in bund can be reduced
c) Direct the Travancore Devaswom Board to establish biological sewage
treatment plant/plants at Sabarimala Sannidhanam of adequate quantity
for treatment of sewage from the toilets and urinals and make it
functional throughout.
d) Direct the Travancore Devaswom Board to ensure the sewage treatment
plant at Pampa operational by curing all its defects.
e) There are pits filled with sludge after the chemical treatment in
river bunks and forest areas.Direct the Travancore Devaswom Board to
remove these sludges of the chemical treatment of the previous years
to a Temporary Storage Disposal Facility (TSDF)
f) Issue order banning septic tank overflow to Njunangar stream and
prosecute the persons including the officials of the Pollution Control
Board for abetting the pollution in the Njunangar stream.
g) Issue a direction to the Pollution Control Board not to permit the
use Envirofloc/contaminated ferrous chloride except for treatment of
industrial waste and ensure its solid waste for disposal at TSDF.
h) Direct to assess the environmental impact consequent to the use of
contaminated ferrous chloride/Envirofloc by the Department of chemical
oceanography and department of Toxicology and Department of
Environment of the Cochin University of Science and Technology.
Dated this the 25 December 2009.
Convenor Mr.R.Ajayan.
Members Dr.N.Chandramohan Kumar.
Advocate P.K.Ibrahim,
Purushan Eloor,
Jacob V.Lazar,
Dr.A.Latha
Dr.Thomas P.Thomas,
V.N.Gopinathan Pillai,
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