Vipin Gupta S/o Sh. G.P Gupta, House No. 329, Galli No. 10 ... · the 31st Meeting of REAC scheduled on 16-18 March, 2015 and issue the Environmental Clearance. I will be grateful

Vipin GuptaS/o Sh. G.P Gupta,House No. 329,Galli No. 10 Burari, Delhi.

To, Date: 12.03.2015

The Director (IA-II),Ministry of Environment, Forest & Climate Change,Indira Paryavaran Bhawan,Lodhi Road, Jor Bagh,New Delhi-110003

Sub: Regarding Environmental Clearance for Karnal Unit-I Sand Mining

Project (Area: 941.0 ha), District Karnal, Haryana.

Ref: Query letter received from MoEF & CC dated 5th March, 2015.

Dear Sir,

This is for your kind information that as the above mentioned reference, I

am here by submitting the reply of the short-comings in hard copy as well

as in soft copy for your immediate reference.

I humbly request you to kindly consider the same and take up our case for

the 31st Meeting of REAC scheduled on 16-18 March, 2015 and issue the

Environmental Clearance.

I will be grateful to you for this act of kindness.

Thanking you.

Yours truly,

Vipin Gupta

Encl:

1. A copy of MoEF&CC Letter dated 05.03.2015

2. Short comings reply along with necessary Annexures.

SHORT-COMING REPLY

1. Detailed report regarding likely increase in productivity of

Agricultural land after mining (as informed by the PP on the

basis of Reports of some Institutes); The Expert may also send

a Report in this regard.

Attached as Annexure-I.

2. Onsite disaster management plan with complete mitigation

measures for disaster management.

The project is for sand mining from the riverbed of river Yamuna & its

paleochnnels which posses some hazardous situations. The

identification of harzard, risk and preventive on site mitigation

measures for the proposed project is given below:

(A) Hazard Identification

The purpose of hazard identification is to identify and develop a list of

hazards that are reasonably likely to expose people to injury, illness or

disease if not effectively controlled. Workers can then be informed of

these hazards and controls put in place to protect workers prior to

them being exposed to the actual hazard.

1. Nearness of River (Flooding)

2. Collapsing of Banks of River & banks of pit

3. Quick Sand Condition

4. Accidents due to Vehicular Movements and loading &

unloading of mineral

5. Earth Quake

6. Presence of poisonous insects & snakes

(B) RISK ANALYSIS

Risk analysis is done for:

Forecasting any unwanted situation

Estimating damage potential of such situation

Decision making to control such situation

Evaluating effectiveness of control measures


As the project is mine sand from the riverbed & its paleochannels

there is risk of flash floods in the riverbed area due to which the

workers at the site may get seriously injured or drowned.

2. Collapse of Banks of River & banks of pit

There is a risk of collapse of banks of riverbed & pits which will be

formed due to mineral excavation. Collapse of banks may injure the

workers/miners.


There are two things which may create the conditions to form

quicksand:

i. Underground water may seep-up and saturate the

sand, thereby reducing the friction between the

sand grains and giving the sand a liquid nature.

ii. Sand or another soil may be sifted by the force of an

earthquake so that friction is lessened and the

earth becomes unsteady.

This creates danger condition to the trucks plying near the river bed

and banks for transportation of minerals and also there will be a

chance of fall of human beings & animals in it.



The possibilities of road accidents are due to reckless or untrained

driver or overloading of trucks or in case pathway is not compacted

suitably, etc. Also during loading and unloading of minerals

workers/miners may get injured due to river bank collapse, over

thrown boulders/pebbles or due to carelessness use of hand tools, etc.

5. Earth Quake

As the area lies in seismic zone III which indicates moderate damage risk

zone but still there is a chance of it and due to which workers/miners

may get affected.

6. Presence of poisonous insects & snakes

Snakes & other poisonous insects might be present inside the sand

which is going to be excavated and there is risk that they might bite

the workers/miners working at the site, which can be dangerous.

(C) PREVENTIVE/MITIGATIVE MEASURES

Mitigation measures plays a vital role as these are proposed so that

any hazard having its potential impact on an individual or structures

can be prevented or to combat with the disaster.


During monsoon months and heavy rains the mining operations

will be ceased.

There is a mechanism/warning system of heavy rains and

discharges from the upstream dams. (A letter has been obtained

from Executive Engineer, Indri W/S Division, Karnal dated

10.02.2015 in this regard is attached as Annexure-II)

Prior information will be given to workers as per the advance

intimation received from concerned authority.

2. Collapse of Banks of River & Banks of Pit

Mining will be done in a systematic & scientific manner while making

proper benches.

In case of river bed: Mining will be leaving a safety zone of total of

1/4th of the width of the river from the banks for bank protection.

In case of paleochannels: Mining will be done leaving safety a barrier

zone of 7.5 m around the lease for off river bed blocks (paleochannels)

also it is proposed that banks of the mining area (paleochannels) will

be sloped to its angle of repose at 45o in a very gentle manner so that

there is no pit left which can pose any danger to collapse. Further, to

stabilize the slope plantation with shrubs, grasses & trees will be done

as mentioned in reference to Question no. 5.


The only way to avoid quick sand condition is by avoiding mineral

lifting below water table, which is not allowed in this case. Mining will

be done in layers rather than going for maximum depth at one time.

However, quick sand condition may occur due to natural reasons. The

following mitigation measures will be provided:

Area of “quick sand” conditions will be identified and warning

sign will be provided for the same, if observed.

Fencing will also be done around the quick sand areas, if

observed.



All transportation within the main working shall be carried out

directly under the supervision and control of the management.

The Vehicles will be maintained/ repaired and checked

thoroughly by the competent person.

A statutory provision of constant education, training etc. will be

provided for reducing the incidents of such accidents.

Overloading will not be permitted and will be covered with

tarpaulin.

The maximum permissible speed limit will be ensured.

The truck drivers will have valid driving license.

The truck shall be brought to a lower level so that the loading

operation suits to the ergonomic condition of the workers.

The loading shall be done from one side of the truck only to

avoid over throw of materials.

The workers shall be provided with gloves and safety shoes

during loading.

5. Earth Quake

As the area lies in Seismic zone-III, following protective measure for

the same has been proposed:

Pit slopes will be stabilized by plantation as proposed in

reference to Question No. 5 which will prevent collapsing of

pit slopes during earthquake.

Evacuation plan for the workers at site including contract

labours will be developed.

“Emergency Helpline Number” will be displayed at all levels.

Mock drills regarding earthquake condition will be conducted

and arranged for the miners/workers by the concerned

department/authority, Karnal.

6. Presence of poisonous insects/snakes and other emergency

A regular tie-up with a nearby hospital (fully equipped with

doctors, medicines, anti-venoms, medical equipments etc)

will be ensured.

Ambulance will be made available at the site all the time

(during mining hours) for emergency purpose.

On Site Disaster Management Plan

In spite of the above mitigation measures disaster may happen. In

case a disaster happened, the proponent prepared an Onsite Disaster

Management Plan which is as follows:

This deals with action plan for high risk accidents like subsidence,

flood, and inundation in mines, seismic activities, etc. and emergency

plan proposed for quick evacuation, ameliorative measures to be taken

etc. The capability of lessee to meet such eventualities and the

assistance to be required from the local authorities is described.

The complete mining operation will be carried out under the

Management and control of experienced and qualified Mines

Manager having Certificate of Competency to manage the mines

granted by DGMS.

During heavy rainfall the mining activities will be closed and

workers will be evacuated.

All persons in supervisory capacity will be provided with proper

communication facilities to facilitate evacuation.

Injured person will be provided with FIRST AID facility which

will always be kept at nearby hospitals.

A person will be deputed to be in continuous touch with

District/local authority level office, for the timely dissemination

of message like releasing of water from dam (Hatnikund

Barrage), heavy rainfall etc. as received from IMD and take

precautionary action to prevent any consequential disaster.

“Disaster Warning System” as developed will be strictly

implemented in line with advance communication from

concerned authority as given in Annexure-II.

Identification of nearby hospitals with route & contact number

for emergency assistance.


labours will be developed and they will be kept in nearby

shelters.


3. Details of compensation proposed to be given to farmers as per

R&R Policy of the State Government along with pert chart

showing acquisition and returning land for cultivation after

mining activity.

The R&R plan prepared for the Project is inculcated from National

R&R Policy, 2007 as per the land holdings present in the area.

There are mainly three components in the said policy (a) Land

compensation (b) Economic rehabilitation of project affected

families and (c) Development of skills for the displaced persons.

Total area of lease is as per LoI is 941.00 ha out of which River bed

land considered for mining is 763.00 ha and Agriculture land

(Paleochannel) is 178.0 ha. To assess the losses of the project

affected people due to the mining, a survey was done and it was

found that there is no ST population as well as there are no

hutments in the lease area. Thus no compensation on account of

resettlement shall apply. Also employment to one person from each

land owner on priority basis will be given. In addition, annual

compensation Rs.1, 80, 000 per ha (for paleochannel/ agriculture

land) till the land is not returned to them and Rs.35, 000 per ha till

the end of lease period for barren land will be given to the land

owners to compensate for the loss of product. Also the top fertile

soil which has been stacked separately, will be spread on the

excavated land again to make it fertile and then will be returned to

the original land owners. Also in this regard manure will be

provided to the farmers for better agricultural practices. The

development of skills of the youth of the nearby villages will be

enhanced by providing vocational training to them through nearby

institutes. Towards this, an amount of Rs. 15 Lakh per annum has

been earmarked in the CSR including scholarship to the students

and vocational training.

4. A plan for providing potable drinking water in villages namely

Chandrown, Garhpur, Tapu, Nagal, Kamalpur, Garhi-Birbal and

other having high fluoride in water.

RO water system/ water purifiers will be installed and provided in

the villages for drinking water purpose. An affidavit regarding the

same has been attached as Annexure-III. Towards this, an amount

of Rs. 5 lakhs per annum has been allocated.

5. Proposed Plan with map for 7.5 m green belt as proposed by

the PP between mining land and adjacent Agricultural land.

A plan is proposed for green belt development in the 7.5 m barrier

zone between the mining land & adjacent agricultural land. It is

proposed that pits of the mining area will be sloped to its angle of

repose at 45o in a very gentle manner so that there is no chance of

slope collapse which can pose any danger to human being or

animals. The process of simultaneous reclamation will be

continued till the mining is over. Also plantation is proposed on the

slopes of the pit to stabilize them and which also makes the area

greener. List of species proposed to be planted is given below:

Sandy Clay Loam Binding Plants for Green Belt in Safety Zone of

Mine Lease

The green belt to be proposed on the earthen bund in 7.5 m safety

zone around the mine lease in Paleochannels of Yamuna River will be

composed of trees, shrubs and grasses. This green belt will bind the

sandy loam soil of earthen bund in safety zone and would not allow

the run off with eroded soil in mined areas. These plants are

recommended in research papers for soil conservation as well as

recommended by CPCB for the green belt. The selected plants as soil

binders over the bund in 7.5 m safety zone of mine lease is given

below:

A. Grasses

Bothriocloa intermedia

Cenchrus setigerus

Chrysopogon fulvus

Saccharum bengalense

B. Shrubs

Bouganvillea sp.

Ipomoea fistulosa

Nerium odorum

Sesbania sesban

Salix caprea

Ricinus communis

Poinciana pulcherrima

C. Trees

Acacia nilotica

Prosopis juliflora

Butea frondosa

Albizzia lebbek

Alstonia scholaris

Anthocephalus cadamba

Azadirachta indica

Cassia fistula

Cassia siamea

Lagerstroemia flosreginae

Leucaena macrophylla

Pithecolobium dulce

Also plan with a map for the same has been made and attached as

Annexure-IV.

6. Proposed Protective measures in respect of Project located in

seismic zone-III as part of Disaster management plan.

The proposed project lies in Seismic zone III which is classified as

Moderate Damage Risk Zone.

Hazard Identification: Earth Quake

Risk Analysis:

Earth Quake

As the area lies in seismic zone III which indicates moderate damage risk

zone but still there is a chance of it and due to which workers/miners

may get affected.

PREVENTIVE/MITIGATIVE MEASURES

As the area lies in Seismic zone-III, following protective measure for

the same has been proposed:

Pit slopes will be stabilized by plantation as proposed in

reference to Question No. 5 which will prevent collapsing of

pit slopes during earthquake.


labours will be developed.


Mock drills regarding earthquake condition will be conducted

and arranged for the miners/workers by the concerned

department/authority, Karnal.

************

ANNEXURES

Documents

Vipin Gupta S/o Sh. G.P Gupta, House No. 329, Galli No. 10 ... · the 31st Meeting of REAC scheduled on 16-18 March, 2015 and issue the Environmental Clearance. I will be grateful