Fact-finding Report on Role of UCIL and Effect of Uranium Mining in AP Villages – NAPM, HRF, RSV

August 11, 2018

National Alliance of Peoples’ Movements (NAPM)

Human Rights Forum (HRF)
Rythu Swarajya Vedika (RSV)

Andhra Pradesh

Fact Finding Report

“The “essence” of the fish is its “being,” water… The “essence” of the freshwater fish is the water of a river. But the latter ceases to be the essence of the fish and so is no longer a suitable medium for existence as soon as the river is made to serve industry, as soon as it is polluted by dyes and other waste products and navigated by steamboats, or as soon as its water is diverted into canals where simple drainage can deprive fish of its medium of existence.”

– Marx and Engels, The German Ideology

A team of the above three organizations visited the affected villages of Kottala, Mabbuchintalapalle, Kanampalle during the months of June and July 2018 to observe in person the sufferings of the farmers and villagers due to arrogant violations of environmental law and regulations. The “essence” of the people here is their groundwater. With that polluted the existence of people there is now a question. The team also observed the lapses in construction and operation of the tailings pond. It measured the radiation levels at the pond and also in villages.

Observations of the team are highlighted here briefly as bullet points.

1.UCIL is opaque and arrogant towards people. History of UCIL is a history of lies and ill treatment of tribals of Jharkhand. Here also we got the same picture from the villagers.

 

2. Recent exposure by Sri Rajnish Rai, IPS former CVO of UCIL shows the extent of deep rooted corruption at UCIL. According to his report about Rs970 crores was swindled at UCIL, Tummalapalle unit. The proposed original cost of the project was Rs1029.57 crore. Based on these numbers one can guess how efficient UCIL officials are in swallowing public money. Opacity of the company does not give us any information on how much of public money is spent this project till now.

 

3.When a student from Chennai called for information and clarifications, Sri S R Pranesh, GM (Mill) talked about the information reaching vested interests. BHP a multinational mining corporation that produces uranium also has plenty of information on its website about its activities, environmental performance, regulatory information etc. Major Anti-nuclear NGOs are present in the countries of its operation. But the corporation cannot conceal most of its information due to law and empowered citizenry.The website is: https://www.bhp.com/environment/regulatory-information

 

4. UCIL annual reports and information on AERB website indicate the failure of process technology implemented in the uranium mill. It took more than 5 years of trial and error to get some production of Uranium. All the incompletely extracted uranium ore and un-reacted chemicals used for extraction of uraniumfrom the ore have been dumped in the unlined tailings pond all these years.

 

5. Right from the start of the mining, neighbouring communities were facing problems. First the groundwater table receded to deeper levels due to continuous loss of groundwater into the mine. People had to go for new deeper bore wells at a great cost for their income level. It was a financial burden. The uranium content of the groundwater started rising. Now as per APPCB recent data the uranium concentration in groundwater ranges between 690 – 4000 ppb, that is far above the WHO limit of 30 ppb.

 

6. Groundwater contamination is evident, banana crop is withering, layers of salt are depositing on the soil irrigated. Groundwater analysis is also showing heavy increase in TDS content at many farms and in villages. Yet, UCIL uses unethical and unscientific denialist argument with the support of BARC in news paper notification stating, “Higher salinity and Total Dissolved Solids (TDS) contents in some groundwater samples have been reported and do not show any discernible pattern to link such occurrences, if any, to the operations of UCIL.” This is a classic case of manipulating science against the people.

 

7. At every opportunity UCIL tries to portray itself as a victim of imaginary anti- nuclear NGOs. In a public notification issued, UCIL blames NGOs saying “It is also reported that some NGOs are actively participating in mobilizing public opinion against smooth operations of UCIL.” Also, in reply to show cause notice of APPCB, they stated “However, the motivated efforts by some anti-nuclear NGOs continue to disrupt UCIL operations at times as being seen presently at Tummalapalle. UCIL wishes to reassure the State administration and all stakeholders of its commitment to adopt all possible measures to uphold the spirit of sustainable uranium production striking a right balance in efforts, linking the technological, economic, environmental and social aspects.”

All this shows how undemocratic UCIL is. It is a public sector company run with public money, but wants all people to shut their eyes and mouths whatever the officials of the company do, even if it hurts their lives. No one is above criticism in a democracy. Dissent is a fundamental characteristic of Democracy. Prof Howard Zinn originator of peoples’ history said, “Dissent is the highest form of patriotism.” For Benjamin Franklin “It is the first responsibility of every citizen to question authority.” Dr P M Bhargava eminent scientist in an article in The Hindu on “The importance of dissent in democracy” said “In a democracy, non-governmental organisations provide a platform to civil society to dissent in an informed and reasoned manner.”These corrupt officials do not value democracy and accuse anyone raising questions about their functioning. Working in a uranium plant does not give them any higher rights over regular citizens. In fact they are environmental criminals by law trying to cover up their crime.

 

8. Our visit to UCIL Tailings Pond at Kottala made it obvious that there is no lining of any sort to the pond to prevent seepage. How thoroughly UCIL officials can lie and regulators fail to take them to task, is evident from this sentence in their reply to APPCB show cause notice. “On the issue of lining of Thickened Tailings Disposal (TTD) area – called Tailings Pond (TP), it is clarified that the TP is lined with appropriate clay material with desired thickness attaining stipulated permeability (AERB guidelines).” It is an absolute lie. First, they are disposing the tailings as slurry in the tailings pond and not using TTD. Anyone visiting the tailings pond can identify that. The EIA put up for public hearing in 2006 proposed TTD as the method of tailings disposal.

But UCIL has neither implemented its proposal nor the permissions issued by MoEF&CC and APPCB specify such disposal. Lining of TP is not a onetime activity, but an ongoing activity till the closure of the pond at the end of operations. There is no lining activity at the pond now. Abutments of the pond are unlined and are not even cleared of bushes and plants. AERB has no guidelines on thickness of the lining. UCIL should produce the Tailings pond permission/approval issued by AERB with conditions on lining. Consent for construction of the Tummalapalle Tailings Pond, AERB issued on 31 March 2011 has no such details. What is the desired thickness worked out by UCIL based on AERB guidelines? Which AERB guideline has specified the thickness of the lining or presented a method for arriving at desired thickness? The claim made makes us wonder whether UCIL officials really understand what they are saying. It is mostly talk big to cover up ignorance and failure as there is no agency to shut them up from talking nonsense.

Prof E. I. Robinsky of U Toronto developed the concept of Thickened Tailings Disposal in 1973 at the Kidd Creek Mine at Timmins in Canada. Original vision of central thickened discharge (CTD) was realized only in 1995 after several iterations of thickener upgrade. However, it is successfully implemented in very arid regions of Australia. Using TTD eliminates the need for construction of high and costly confining dikes and dams. If UCIL is using TTD as claimed then why are they building a Tailings dam with borrowed soil at a cost of about Rs 35 crores?

A Robinsky publication concludes “the thickened tailing disposal system provides the following advantages over the conventional system.

 Any chosen disposal area can accommodate considerably more tailing than could be accommodated by conventional storage systems.

  •   Overall cost of tailing disposal is reduced substantially through the elimination of confining dikes, the reduction in size of tailing and return water pipelines, and the elimination of pipe abrasion by pumping at low velocity. Finally, reclamation procedures are simple and automatic.

  The environmental impact is small. Dusting is inhibited and seepage potential greatly reduced by the elimination of the slimes pond and the provision of a self-draining sloped surface. Safety is enhanced through the elimination or reduction in size of the perimeter confining dikes.”[E. Robinsky, “Thickened Tailing Disposal in Any Topography” in Don Donaldson and Benny E. Raahauge (Eds.), “Essential Readings in Light Metals, Volume I, Alumina and Bauxite”, Springer International Publishers, p933-937, 2016]

9. After going round the tailings impoundment, “Tailings Management Facility (TMF) or Tailings Storage Facility (TSF)” in technical terminology, we have not found any evidence that it is designed by any professional consultant. Regulatory authorities should demand UCIL to produce planning and design documentation for the TMF at Kottala and reveal the consultants. When we look at the design documents of private corporate companies available on the Internet, we fail to understand the secrecy in sharing information with even with regulatory agencies.

10.Stewardship of the Tailings Pond is vital for safety. We learnt that UCIL has no qualified official named to manage the tailings pond on day to day basis. Tailings Facility management is a highly professional job requiring specialized knowledge and experience. Normally, experienced geotechnical/tailings engineers function as managers for the tailings pond management. But only technicians and workers are present at the UCIL tailings pond. No record keeping of any data is evident from our inquiries. No regular monitoring and inspection are done to check the integrity of the tailings disposal facility. There are not even piezometers to monitor the water level in the pond. Without rudimentary procedures in place, they talk of meeting International practices. What a joke!

Geoffrey Blight summarizing the management failures, at several dams that breached concluded:
 “There was complacency about the state of safety of the dam.

  •   There was a lack of knowledge and understanding of how tailings damsfunction and what affects their safety. The decision to store large volumes ofwater on top of the dam could have arisen from this ignorance.
  •   There were no regular inspections or assessments of the dam’s state ofsafety. In this regard, the lack of piezometers was a major shortcoming.
  •   There was obviously no emergency action plan that the operators of the dam were aware of. They were poorly trained and nonplussed when theemergency confronted them.”
    All these lapses are present in the management of UCIL Tailings Pond and there is every likelihood that it would fail in due course. It is a frightening prospect that could result in loss of life and property and extensive contamination of land and water.

 

11.UCIL denies any seepage from the Tailings Pond. We observed that as we put water above the edge of the tailings pond all the water simply disappears down the soil of the abutment. There are no monitoring wells near the pond to detect contamination. Some bore holes away from the pond dug for different purpose are being wrongly projected as monitoring bore wells made as per international practices.

First necessity to properly locate the monitoring wells is the hydrogeological map of the area. No such map was produced and shared with APPCB/MoEF. The condition (x) in the EC issued was to conduct groundwater modeling study and submit the report to MoEF. Inspection report dated 4 January 2017 by Regional Office, MoEF, Chennai recorded: “PP informed that groundwater modeling studies has been assigned to M/s NGRI, Hyderabad. Further, informed that ground water modeling studies has been completed and the report is likely to be received by January, 2017.” PP means project proponent UCIL. They are able to get away because neither CPCB/MoEF nor APPCB have any guidelines on monitoring wells for tailings management facilities. US EPA’s “RCRA Ground-Water Monitoring Technical Enforcement Guidance Document” of September 1986 says:

“In order to immediately detect releases as required by the regulations, the owner/operator must install downgradient detection monitoring wells adjacent to hazardous waste management units. In a practical sense, this means the owner/operator must install detection monitoring wells as close as physically possible to the edge of hazardous waste management unit(s). The two drawings in Figure 2-1 (A and B) illustrate the concept of the placement of wells immediately adjacent to hazardous waste management unit(s). Note: the placement of wells relative to the units shifts as a function of the direction of ground-water flow”

“Downgradient monitoring wells must be located at the edge of hazardous waste management units to satisfy the regulatory requirements for immediate detection. The placement of detection monitoring wells along the downgradient perimeter of hazardous waste management units must be based upon the abundance, extent, and the physical/chemical characteristics of the potential contaminant pathways. The depths at which contaminants may be located and at which downgradient wells must be screened are functions of (1) geologic factors influencing the potential contaminant pathways of migration to theuppermost aquifer, (2) chemical characteristics of the hazardous waste controlling its likely movement and distribution in the aquifer, and (3) hydrologic factors likely to have an impact on contaminant movement (and detection).”

“Upgradient monitoring wells are to provide background ground-water quality data in the uppermost aquifer. Upgradient wells must be (1) located beyond the upgradient extent of potential contamination from the hazardous waste management unit to provide samples representative of background water quality, (2) screened at the same stratigraphic horizon(s) as the downgradient wells to ensure comparability of data, and (3) of sufficient number to account for heterogeneity in background ground-water quality.”

“Screening the entire thickness of the uppermost aquifer will not allow the owner/operator to obtain depth-discrete water quality data. Instead, the owner/operator should use shorter well screens in order to obtain depth-discrete water quality data.”

The above information from international regulatory literature, should make it obvious that UCIL hardly knows anything about monitoring wells and wants to bluff its way in the poor regulatory system we have. BARC based on analysis of groundwater samples collected wrongly from the existing bore holes claimed non- contamination and openly invited anyone to collect samples from the so called monitoring wells and prove contamination during the 9 April 2018 meeting held at UCIL premises. It badly taints the image of BARC. There is plenty of literature on monitoring wells, their design, construction and location. A mere bore hole does not make a monitoring well.

We visited the affected villages and farms and interacted with men, women, youth and children. Watched a goat die from drinking groundwater. Several women complained about irritation, rashes, skin allergies, unwanted skin growth, bone weakness, giddiness, body pains and even kidney and urinary complications. People irrespective of age and gender complain various health disorders such as joint pains, knee pains, muscle pains, signs of dental fluorosis among children, osteoarthritis, rheumatoid arthritis; severe forms of anemia etc., People are using pain killers such as diclofenac and Ibrufen 600 mg regularly to get relief from pain. These tablets are widely sold in village grocery shops. Medical experts say that prolonged usage of these pain killers results in kidney failure. We are also informed about the death of 3 UCIL employees below 45 years dying from cancer.

1) Sri G. Ramanjaneyulu – age 45 – died of Brain Tumor. He worked in the Uranium mine for 8 years both at Jadugoda and Tummalapalli

2) Sri Venkateswarlu – age 30 – died of stomach cancer in Feb 2018. He was working in the mine for 3 years. Graduate trainee – village Mydukuru

3) Sri Maheswara Reddy- age 30 – was treated for cancer in NIMS died around 2013. He had worked in UCIL for 4 years.

Development of impotency among men is also reported.

Sri Sadrak – CMC, Vellore diagnosed impotency- now working in mine

An young unmarried employee confessed to a member of the team about his suffering from impotency.
Health Dept is not keeping track of the spreading problem.

We have also watched the farmers explain about loss to banana plantation because of use of contaminated groundwater for irrigation. Large patches of white salt layer deposits are clearly visible. But UCIL makes pseudoscientific explanations for changes in groundwater quality, exonerating itself. Pity, our regulatory agencies are unable to assert and act to check false claims of UCIL.

12. Our team measured radiation levels at the tailings pond and also in villages with the help of Dr Soumya Datta, Physicist from Delhi. There is a big discrepancy in the radiation levels UCIL recorded as part of the compliance report to RO, Chennai and our measurements.

13.UCIL reaches its blockbuster performance in the following claims made in reply to APPCB show cause notice. They are really innovative and excel the tobacco companies in creating doubt in public mind. “The growth track of the Company which includes innovative ways of uranium production and improved measures towards environment, already outlined in Jharkhand has received wide support of the public and the State administration. Such continued success of receiving public appreciation is largely attributable to UCIL’s core philosophy of sharing relevant information to the stakeholders.” Extensive amount of news articles and TV coverages on ill effects of UCIL operations at Jadugoda are all certificates of their performance.

“The operational practices adopted by UCIL, especially related to tailing impoundment have been acclaimed internationally. International Atomic Energy Agency (IAEA) has also commended this effort of UCIL and has considered it as a center for international training on uranium mining and processing facility.” Such is the honesty and integrity of UCIL. Regulatory agencies do not care to verify and question UCIL for false information. MoEF Notification 2006 has a provision to cancel the EC issued for giving false information.

UCIL should produce documentary evidence of its international acclaim for which operational practices. Is it for operating the TMF as a mere waste dump? We have written to IAEA to send a copy of the commendation issued to UCIL. Why UCIL has not issued any press release on such recognition?