The following is a letter, dated 20 March 2026, to the oficials raising important questions of concern. It is accompanied by their Technical Representation on Amended ToR to BPCL.
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To,
The Member Secretary
Expert Appraisal Committee (Industrial Projects-2)
IA Division
Ministry of Environment, Forest and Climate Change
Indira Paryavaran Bhawan, Jor Bagh
New Delhi – 110 003
Subject: Serious Omissions in the Amended Terms of Reference for the 9 MMTPA Greenfield Refinery and Petrochemical Complex at Chevuru Village, Gudlur Mandal, SPSR Nellore District, Andhra Pradesh by M/s Bharat Petroleum Corporation Limited – Request for Supplementary ToR Conditions – reg.
Reference: MoEF&CC Letter No. IA-J-11011/271/2025-IA-II, TOR Identification No. TO26A1201AP5101317A, dated 13 March 2026, granting an amendment in Terms of Reference to M/s BPCL for the above-mentioned project.
Sir/Madam,
We write with reference to the Amended Terms of Reference (ToR) dated 13 March 2026 issued by the Ministry of Environment, Forest and Climate Change to M/s Bharat Petroleum Corporation Limited (BPCL) for the proposed 9 MMTPA Greenfield Refinery and Petrochemical Complex at Chevuru Village, Gudlur Mandal, SPSR Nellore District, Andhra Pradesh.
The amended ToR has been examined in the context of the process configuration, scale of petrochemical operations, and the handling of hazardous substances inherent to such an integrated complex. Given the magnitude of the project and its proximity to inhabited and agriculturally productive regions, it is respectfully submitted that the appraisal process must adopt a **preventive and precautionary approach**, ensuring that all potential risks are fully identified and addressed at the ToR stage itself.
At present, certain aspects of the amended ToR would benefit from further strengthening to ensure that the subsequent Environmental Impact Assessment (EIA) is comprehensive and fully aligned with the objectives of environmental protection and public safety. We have attached a “Technical Representation on Amended ToR to BPCL” for your consideration. You may please refer to
1. Copy of MoEF&CC Amended ToR dated 13 March 2026 (File No. IA-J-11011/271/2025-IA-II)
2. Relevant extracts from MSIHC Rules 1989 (Schedule I and Schedule II substances)
3. CPCB Guidelines on Consequence Analysis for MAH Installations
In particular, there is a need to ensure:
Ø complete and transparent disclosure of all major products, intermediates, and hazardous chemical inventories associated with the proposed petrochemical processes;
Ø explicit consideration of storage, handling, and risk associated with hazardous substances;
Ø robust assessment of cumulative environmental impacts, including air, water, and marine impacts;
Ø incorporation of detailed risk assessment, consequence modelling, and emergency preparedness requirements within the ToR framework; and
Ø meaningful public consultation based on complete and comprehensible project information.
In view of the above, it is earnestly requested that this representation may kindly be placed before the Hon’ble Expert Appraisal Committee (Industry-2) at its earliest meeting. It is further requested that “supplementary ToR conditions” addressing the above aspects may be issued to the project proponent prior to the completion of the EIA study.
Given the scale and complexity of the proposed refinery–petrochemical complex, the appraisal process must emphasise “prevention of environmental harm and protection of public health”, rather than post-facto mitigation. Strengthening the ToR at this stage would significantly contribute to a more robust, transparent, and scientifically grounded assessment.
We submit this representation in the interest of ensuring that the project, if pursued, is evaluated with the highest standards of environmental diligence and public accountability.
Thank you for your consideration.
Yours sincerely,
Scientists for People
Dr K Babu Rao
Dr K Venkat Reddy
Dr D Rambabu
Dr Ahamed Khan
Dr P G Rao
Dr M Bapuji
Copy to:
1. The Member Secretary, Central Pollution Control Board, Parivesh Bhavan, East Arjun Nagar, New Delhi – 110 032
2. The Member Secretary, Andhra Pradesh Pollution Control Board, Paryavaran Bhawan, A-III, Industrial Estate, Sanathnagar, Hyderabad (AP)
3. The Regional Officer, MoEF&CC Regional Office, Green House Complex, Gopalreddy Road, Vijayawada – 520 010, Andhra Pradesh
4. The District Collector, Sri Potti Sriramulu Nellore District, Andhra Pradesh
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Contact for more on the subject and about the Group:
Dr Babu Rao email ID : [email protected]
DR M Bapuji email ID: [email protected]
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Technical Representation on Amended ToR to BPCL
By Scientists for People
1. Introduction and Purpose of this Representation
It is respectfully submitted that the amended ToR, including its Annexure-II (revised product pattern and unit capacities), contains serious and consequential omissions with respect to highly hazardous and toxic products, co-products, and process intermediates that are chemically inevitable given the units now listed, particularly the newly added Vinyl Chloride Monomer (VCM) unit (600 KTPA), the Chlor-Alkali Unit (360 KTPA), the Phenol-Cumene complex (300 KTPA + 265 KTPA), the Styrene Butadiene Rubber (SBR) unit (225 KTPA), and the Ethylene Vinyl Acetate (EVA) unit (162.5 KTPA).
The omission of these substances from the ToR product slate and EIA scope means that the Environmental Impact Assessment study, as currently directed, will not be required to assess the generation, storage, handling, or worst-case accident consequences associated with some of the most acutely hazardous chemicals that will be present at this complex. This representation requests that the Expert Appraisal Committee issue supplementary ToR conditions to remedy these omissions before the EIA study is completed and submitted.
2. The VCM Unit is a New Standalone Addition to the Project
The original ToR dated 16 September 2025 (TOR Identification No. TO25A1201AP5265337N) included a PVC unit (2×300 KTPA). The amended ToR now introduces a standalone Vinyl Chloride Monomer (VCM) unit of 600 KTPA capacity in Annexure-II, which did not exist as a separate unit entry in the original ToR. VCM is not listed as a product, intermediate, or sub-unit within the original ToR’s PVC plant description.
The distinction is not merely semantic. A VCM production unit is a full industrial complex comprising: a direct chlorination reactor, an oxychlorination reactor, an ethylene dichloride (EDC) purification train, a pyrolysis (cracking) furnace, and VCM separation and storage. It introduces, for the first time, industrial-scale chlorine chemistry on the project site. The addition of this unit transforms the project’s hazardous substance inventory in a qualitatively different manner from the numerical revisions to water intake or effluent generation that were the subject of the other amendments.
The public hearing conducted on 05 December 2025 was based on a project description that did not include the VCM unit as a standalone production facility. Communities in the vicinity of Chevuru Village were, therefore, not informed of the chlorine-chemistry hazards that the VCM unit introduces. The EAC’s direction for a newspaper-based written consultation under Para 7(III)(ii)(b) of the EIA Notification 2006, with a 30-day notice period, is an inadequate substitute for a fresh site-specific public hearing on amendments of this consequence.
3. Critical Omissions: Hazardous Substances Absent from the ToR Product Slate and EIA Scope
The product slate in Annexure-II of the amended ToR lists only saleable final products. It is silent on the following categories of substances that are chemically inseparable from the proposed production processes:
3.1 The VCM Production Chain: Chlorine, EDC, HCl, and Phosgene
The production of 600 KTPA of VCM by the universally adopted balanced oxychlorination process requires the following substances, none of which appear in the ToR product slate or EIA scope:
(a) Chlorine Gas (Cl₂): Chlorine is the primary raw material for VCM production via direct chlorination: C₂H₄ + Cl₂ → C₂H₄Cl₂ (EDC). For a 600 KTPA VCM unit, the stoichiometric chlorine requirement is approximately 480–500 KTPA, of which a significant portion is generated on-site by the 360 KTPA Chlor-Alkali Unit. Chlorine is classified as a Schedule I hazardous chemical under the Manufacture, Storage and Import of Hazardous Chemical (MSIHC) Rules, 1989, and is a Major Accident Hazard (MAH) substance requiring compulsory MAH notification, on-site and off-site emergency planning, and consequence analysis. It is also a Schedule 1 chemical under the Chemical Weapons Convention. A facility generating approximately 280–320 KTPA of chlorine constitutes one of the largest chlorine hazard inventories in peninsular India. The ToR contains no reference to chlorine generation, storage, or handling whatsoever.
(b) Ethylene Dichloride (EDC / 1,2-dichloroethane): EDC is the essential and irreplaceable intermediate in VCM production. It is produced in the direct chlorination and oxychlorination reactors, purified, and thermally cracked to yield VCM and HCl. For a 600 KTPA VCM plant, the circulating EDC inventory is approximately 1,050–1,100 KTPA. EDC is classified as a probable human carcinogen (IARC Group 2A), is listed under Schedule I of the MSIHC Rules 1989, and requires site-specific storage safety assessment and worker carcinogen exposure monitoring. EDC is not listed in the ToR product slate, the amended Annexure-II, or in any EIA scope direction issued by the EAC.
(c) Hydrogen Chloride (HCl): HCl is co-produced in equimolar stoichiometric quantities with VCM during the thermal cracking (pyrolysis) of EDC: C₂H₄Cl₂ → C₂H₃Cl (VCM) + HCl. For a 600 KTPA VCM unit, approximately 320–330 KTPA of HCl is generated. In the balanced process, this HCl is recycled to the oxychlorination reactor. However, any operational imbalance, including shutdown of the oxychlorination unit, product quality failure, or startup/shutdown scenarios, generates surplus HCl requiring scrubbing, flaring, or sale. HCl is an acutely toxic, highly corrosive gas classified under Schedule I of the MSIHC Rules 1989. Its generation, routing, and emergency disposal route must form part of the EIA scope. It is absent from the ToR.
(d) Phosgene – worst-case accident consequence of VCM storage: VCM decomposes on combustion or fire to produce HCl and phosgene (COCl₂). Phosgene is one of the most acutely lethal industrial toxic chemicals known, lethal at concentrations below 10 ppm with delayed pulmonary oedema effects. It is a Schedule 1 substance under the Chemical Weapons Convention. In the event of a fire involving VCM storage at this facility, phosgene generation is a foreseeable worst-case consequence that must be modelled in the consequence analysis required under the EIA for Major Accident Hazard installations. This consequence analysis cannot be conducted without explicit recognition of phosgene as a potential release product in the ToR. It is currently absent.
3.2 The Chlor-Alkali Unit: Missing Co-Products
The Chlor-Alkali Unit (360 KTPA capacity) is listed in the unit capacities table. The electrolysis of brine produces three substances in fixed, inseparable stoichiometric ratios: chlorine, sodium hydroxide (caustic soda), and hydrogen. The product slate lists “Caustic Hypo” (783.2 KTPA), sodium hypochlorite, a downstream derivative, but does not disclose the primary electrolysis products. The following are absent:
(a) Chlorine Gas: As elaborated in Para 3.1(a) above, approximately 280-320 KTPA of chlorine will be generated by this unit. It is not listed.
(b) Hydrogen Gas (H₂): Every chlor-alkali unit generates hydrogen gas as an inseparable co-product at a rate of approximately 28 kg H₂ per tonne of caustic soda produced. At 360 KTPA unit scale, this amounts to approximately 9,000-10,000 tonnes per annum of hydrogen. Hydrogen is extremely flammable, has a very wide explosive range (4-75% v/v in air), and has a minimum ignition energy of 0.017 mJ, among the lowest of any industrial gas. Its generation, storage, utilisation route (refinery hydrotreating or fuel use), and explosion consequence analysis must be part of the EIA scope. It is not mentioned in the ToR.
(c) Net Caustic Soda / Sodium Hydroxide (NaOH): The primary product of chlor-alkali electrolysis is caustic soda. The ToR discloses “Caustic Hypo” (sodium hypochlorite) as a listed product but does not disclose the total caustic soda produced, the volume consumed internally (in effluent neutralisation, oxychlorination scrubbing, etc.), and the volume available for sale. This information is necessary to determine the overall mass balance of the chlor-alkali unit and the nature of effluents from caustic handling.
3.3 Phenol-Cumene Production: Cumene Hydroperoxide (CHP)
The product slate lists Phenol (300 KTPA) and Cumene (265 KTPA, revised per licensor input). Phenol production from cumene proceeds universally via the Hock process, in which cumene is oxidised to cumene hydroperoxide (CHP) as the obligatory intermediate, which is then acid-cleaved to yield phenol and acetone. CHP is an organic peroxide classified as a Class 5.2 substance (organic peroxide, Type D) under the United Nations Dangerous Goods classification and under MSIHC Rules 1989 Schedule I.
CHP is prone to exothermic, self-accelerating decomposition at elevated temperatures, and its uncontrolled decomposition has caused catastrophic explosions at petrochemical facilities globally. CHP inventory at a 300 KTPA phenol plant is typically in the range of hundreds of tonnes at any given time. Its generation, maximum standing inventory, temperature control requirements, and decomposition consequence analysis must be explicitly required by the ToR and addressed in the EIA’s risk assessment chapter. CHP does not appear anywhere in the ToR or amended product slate.
3.4 Styrene Import and Storage for SBR Unit
The amended ToR increases the SBR unit capacity from 160 KTPA to 225 KTPA, with the remark “with Styrene Import.” Styrene is an aromatic monomer that is not produced within this complex, it will be imported and stored on-site. For a 225 KTPA SBR unit, the styrene requirement is approximately 100-110 KTPA. Styrene is classified as a probable human carcinogen (IARC Group 2A), is a flammable liquid (flash point 31°C), and is listed under MSIHC Rules 1989.
Styrene also undergoes spontaneous exothermic polymerisation if inhibitors are not maintained, a known cause of storage tank incidents. The ToR does not disclose the annual styrene import volume, the maximum storage inventory, the inhibitor management protocol, or the vapour emission estimates from styrene storage tanks. Andhra Pradesh already experienced an uncontrolled release of styrene vapours from a storage tank in May 2020 that killed several residents in the neighbourhood. A dedicated styrene hazard assessment and fugitive emission quantification must be added to the EIA scope.
3.5 Vinyl Acetate Monomer (VAM) Import and Storage for EVA Unit
The EVA unit (162.5 KTPA) requires vinyl acetate monomer (VAM) as the co-monomer with ethylene. VAM is not produced within the complex and will be imported and stored on-site at approximately 80-90 KTPA. VAM is classified as a possible human carcinogen (IARC Group 2B), is highly flammable (flash point −8°C), and is an acutely toxic vapour at low concentrations. Like styrene, VAM can undergo spontaneous exothermic polymerisation in storage. The ToR contains no disclosure of VAM import, storage, or hazard management, and the EIA is not directed to assess VAM-related risks.
3.6 SO₂ Generation from Sulphur Recovery Unit Tail Gas
The Sulphur Recovery Unit (SRU, 2×275 TPD, revised from 2×270 TPD due to a change in crude mix) processes H₂S-rich acid gas from the refinery to recover sulphur by the Claus process. The Claus process tail gas contains unconverted SO₂ at concentrations requiring tail gas treatment (typically by the Shell Claus Off-gas Treatment, SCOT, or equivalent process). The ToR does not name a tail gas treating unit, does not quantify SO₂ emissions from the SRU tail gas, and does not require the EIA to include SO₂ generation in the cumulative air quality impact assessment for the complex. Given that the complex also includes a 185 MW Captive Power Plant (CPP), the combined SO₂ burden from CPP stack and SRU tail gas requires integrated air quality dispersion modelling that is currently not directed by the ToR.
3.7 Chlorinated Organic Hazardous Wastes from EDC/VCM Purification
The purification of EDC and VCM in the VCM production train generates chlorinated organic by-products, principally 1,1,2-trichloroethane, chlorobutadienes, trichloroethylene, and other chlorinated heavies and lights, that are classified as Schedule I hazardous wastes under the Hazardous Waste (Management and Transboundary Movement) Rules, 2016 (as amended). These streams require incineration in a high-temperature hazardous waste incinerator or disposal at an authorised facility. The quantity, characterisation, and disposal route of these chlorinated waste streams are not mentioned in the ToR and are therefore not required to be addressed in the EIA or the Environment Management Plan (EMP).
4. Consolidated Table of Missing Hazardous Substances
The following table summarises the substances omitted from the amended ToR product slate and the corresponding EIA scope deficiency:
Missing SubstanceSource ProcessApprox. QuantityHazard ClassificationEIA Scope DeficiencyChlorine (Cl₂)Chlor-Alkali Unit (360 KTPA)~300–320 KTPA generatedMSIHC Rules 1989 Schedule I; Chemical Weapons Convention Schedule 1; MAH notification mandatoryPrimary raw material for VCM/EDC production; catastrophic toxic release on failure; no consequence analysis possible without explicit ToR coverageHydrogen Gas (H₂)Chlor-Alkali Unit (co-product)~9,000–10,000 TPA generatedHighly flammable; explosive; MSIHC Rules 1989 Schedule IIInseparable co-product of every chlor-alkali plant; severe explosion hazard; generation, storage and disposal route not disclosedCaustic Soda / NaOH (net)Chlor-Alkali Unit (primary product)~360–400 KTPA generatedCorrosive; hazardous wastewater burdenPrimary product of chlor-alkali electrolysis; net production, internal use, and sale volume not disclosed in product slateEthylene Dichloride (EDC / 1,2-dichloroethane)VCM production chain — direct chlorination and oxychlorination~1,050–1,100 KTPA circulating inventoryIARC Group 2A probable carcinogen; MSIHC Rules 1989 Schedule I; listed hazardous substanceEssential and irreplaceable intermediate for 600 KTPA VCM; large standing inventory; carcinogen exposure risk for workers and surrounding communitiesHydrogen Chloride (HCl)EDC thermal cracking (VCM production)~320–330 KTPA co-producedHighly toxic corrosive gas; MSIHC Rules 1989 Schedule ICo-produced in equimolar quantities with VCM during EDC pyrolysis; recycled in balanced process but toxic on release; no disposal route disclosedPhosgene (fire/accident scenario)VCM storage/fire decompositionWorst-case accident consequenceAcute lethal at ppm levels; Chemical Weapons Convention Schedule 1; MSIHC Rules 1989VCM decomposes on combustion to produce HCl and phosgene; mandatory in consequence analysis for MAH installations; omitted entirely from EIA scopeCumene Hydroperoxide (CHP)Phenol/Cumene production chain (Hock process)Intermediate inventory at Phenol unit (300 KTPA)Class 5.2 Organic Peroxide; explosive decomposition risk; MSIHC Rules 1989 Schedule IObligatory intermediate in Hock process; explosive decomposition at elevated temperature; responsible for several catastrophic petrochemical accidents globally; not named in ToRStyrene (imported raw material)SBR polymerisation unit (225 KTPA)~100–110 KTPA import and storageIARC Group 2A probable carcinogen; flammable liquid; MSIHC Rules 1989Required in large quantities for SBR production; stored on-site; vapour emission and cancer risk for workers; storage inventory not disclosed in ToRVinyl Acetate Monomer (VAM) (imported)EVA unit (162.5 KTPA)~80–90 KTPA import and storageIARC Group 2B possible carcinogen; highly flammable; toxic vapourCo-monomer for EVA production; imported and stored on-site; flammable/carcinogen hazard; not disclosed in ToR or product slateSO₂ from SRU tail gasSulphur Recovery Unit (2×275 TPD)Significant; unquantifiedCPCB-listed air pollutant; health hazard at ppm levelsClaus process tail gas contains unconverted SO₂; tail gas treating unit not mentioned in ToR; no SO₂ generation estimate provided for CPP/SRU combined impact assessmentChlorinated organic wastesEDC/VCM purification trainsSignificant hazardous waste streamsPersistent organic pollutants; Schedule I, Hazardous Waste (Management) Rules 2016EDC and VCM purification generate chlorinated heavy ends and light ends, classified as Schedule I hazardous waste; disposal route not covered in ToR EIA scope
5. Additional Concerns Regarding the EAC Appraisal
5.1 Adequacy of Public Consultation Procedure for VCM Addition
The EAC has directed the project proponent to conduct public consultation under Para 7(III)(ii)(b) of the EIA Notification 2006, obtaining written responses through newspaper advertisements with a 30-day notice period, to cover the proposed amendments. This procedure, intended for minor amendments to projects already subjected to public hearing, is inadequate where the amendment introduces a new, standalone VCM production facility entailing industrial-scale chlorine chemistry. The communities of Chevuru Village and surrounding mandals in SPSR Nellore District are entitled to be specifically informed of, and heard on, the introduction of chlorine, EDC, and VCM hazards in their vicinity through a fresh, site-specific public hearing and not merely a newspaper advertisement seeking written responses.
5.2 Captive Power Plant: Independent Air Quality Assessment Required
The CPP capacity has increased from 100 MW (original ToR, September 2025) to 185 MW (amended ToR). This 85% increase in CPP capacity materially changes the project’s stack emission profile, SO₂, NOx, and fine particulate matter (PM₂.₅), in a coastal air-shed that already receives emissions from the refinery furnaces and process heaters. The EAC noted this increase as “significant” in its deliberations of 23 February 2026 but did not direct a separate air quality impact assessment for the revised CPP. The ToR should specifically require: (a) CPP stack emission estimates for SO₂, NOx, CO, and PM₂.₅ based on the 185 MW capacity and fuel specifications; (b) Gaussian dispersion modelling for CPP emissions, integrated with the refinery/petrochemical complex emissions, at the 24-hour and annual scale; and (c) compliance assessment against CPCB emission standards for captive power plants.
5.3 Benzene Production Increase: Dedicated Assessment Required
The amended product slate increases benzene production from 38 KTPA (original ToR) to 285 KTPA, a 7.5-fold increase. Benzene is a confirmed human carcinogen (IARC Group 1) and a listed Schedule I substance under the MSIHC Rules 1989. A 285 KTPA benzene production and storage facility is one of the largest in India. The ToR should specifically require: (a) benzene storage tank fugitive emission estimates; (b) occupational benzene exposure assessment for workers in the benzene storage, loading, and dispatch areas; and (c) ambient benzene concentration modelling for surrounding communities, with health risk quantification against WHO and CPCB guideline values.
6. Specific Supplementary ToR Conditions Requested
In view of the foregoing, it is respectfully requested that the Expert Appraisal Committee issue the following supplementary ToR conditions to BPCL, either as an amendment to the amended ToR dated 13 March 2026 or as specific directions to the EIA consultant:
Condition 1: Comprehensive Hazardous Intermediate and Co-Product Assessment
The EIA shall include a dedicated chapter on all hazardous intermediates, co-products, and imported raw materials present at the complex. At a minimum, this chapter shall cover and quantify: (a) Chlorine (Cl₂), generation rate, maximum on-site inventory, storage design, and consequence analysis for toxic release scenarios (including lethal distance modelling per CPCB guidelines for MAH installations); (b) Ethylene Dichloride (EDC), circulating inventory, storage conditions, worker carcinogen exposure assessment, and spill consequence analysis; (c) Hydrogen Chloride (HCl), generation rate, internal routing, and toxic release scenario modelling; (d) Hydrogen Gas (H₂), generation rate from Chlor-Alkali unit, utilisation/disposal route, and explosion consequence analysis (including BLEVE scenario); (e) Phosgene, worst-case fire/decomposition scenario involving VCM storage, with lethal dose contour mapping; (f) Cumene Hydroperoxide (CHP), maximum standing inventory, temperature control design, and decomposition consequence analysis; (g) Styrene, annual import volume, maximum storage inventory, spontaneous polymerisation risk, and fugitive vapour emission assessment; (h) Vinyl Acetate Monomer (VAM), annual import volume, maximum storage inventory, and fire/vapour release scenario.
Condition 2: MAH Notification and On-Site/Off-Site Emergency Plans
The project proponent shall confirm the MAH notification under Rule 5 of the MSIHC Rules 1989 to the District Collector, SPSR Nellore and the Chief Inspector of Factories, Andhra Pradesh, covering all Schedule I and Schedule II substances that will be present on-site above threshold quantities. The EIA shall include a preliminary On-Site Emergency Plan (OSEP) and confirm that an Off-Site Emergency Plan (OSEP) will be prepared in coordination with the District Administration before commissioning.
Condition 3: Integrated Air Quality Impact Assessment Including CPP and SRU
The EIA air quality chapter shall include: (a) stack emission estimates for the 185 MW CPP, disaggregated by pollutant (SO₂, NOx, CO, PM₂.₅, PM₁₀); (b) estimated SO₂ and H₂S emissions from the SRU tail gas stream, and details of the tail gas treating unit to be installed; (c) integrated Gaussian dispersion modelling for the entire complex, combining CPP, process furnaces, SRU, flare stack, and fugitive emissions, with 24-hour and annual concentration contours for all criteria pollutants; and (d) ambient air quality impact at the nearest habitation, school, and health facility within a 10 km radius.
Condition 4: Benzene Fugitive Emission and Health Risk Assessment
The EIA shall include: (a) estimated benzene fugitive emissions from the 285 KTPA benzene storage and loading infrastructure, calculated using US EPA AP-42 or equivalent methodology; (b) ambient benzene concentration modelling for surrounding communities; and (c) incremental lifetime cancer risk (ILCR) assessment for workers and the nearest community receptor, benchmarked against WHO guideline values and CPCB standards.
Condition 5: Chlorinated Hazardous Waste Generation and Disposal Route
The EIA shall quantify the generation of chlorinated organic waste streams from EDC/VCM purification, including chlorinated heavies, lights, and spent catalyst, and shall specify the proposed disposal route with reference to a designated facility authorised under the Hazardous Waste (Management and Transboundary Movement) Rules 2016 and amendments thereof.
Condition 6: Fresh Site-Specific Public Hearing for VCM and Chlorine Chemistry Additions
Given that the addition of a standalone 600 KTPA VCM unit introduces industrial-scale chlorine chemistry, with attendant MAH substances including chlorine, EDC, HCl, and phosgene, that was not part of the project at the time of the 05 December 2025 public hearing, the EAC is respectfully requested to direct a fresh, site-specific public hearing at Chevuru Village / the nearest accessible venue in SPSR Nellore District, in accordance with Para 7(I)(III)(i) of the EIA Notification 2006, in lieu of or in addition to the newspaper-based consultation directed under Para 7(III)(ii)(b).
Condition 7: Revised Greenbelt Justification
The amended ToR reduces the greenbelt from 33.3% (703.34 Ha, as in the original September 2025 ToR) to 30% (632.89 Ha, as directed by the EAC). The EIA shall provide site-specific justification for the adequacy of a 30% greenbelt as an air quality attenuation buffer and safety distance, based on dispersion modelling results and risk contour analysis for the hazardous substances on-site. If the dispersion modelling or consequence analysis demonstrates that the 30% greenbelt is insufficient to contain the impact zone for any toxic or flammable release scenario, the greenbelt shall be restored to 33.3% or such greater extent as the modelling requires.
7. Conclusion
The proposed BPCL refinery and petrochemical complex at Chevuru, SPSR Nellore, is a project of enormous scale and consequence for the region. This representation does not question the grant of the amendment in ToR or the project’s administrative regularity. It is submitted solely in the public interest and in the interest of scientific and regulatory completeness of the EIA process, which will determine the environmental safeguards applied to this complex for the entirety of its operational life.
The ToR is the foundational document of the EIA process. An EIA is only as complete as the scope given to it. If the ToR does not require the assessment of chlorine hazards, phosgene consequences, EDC carcinogen exposure, or chlorinated waste disposal, the EIA will not assess them. The supplementary conditions requested in this letter would not delay the project; they would ensure that the EIA, when submitted, provides the Expert Appraisal Committee and the Ministry with the information needed to grant or condition Environmental Clearance on a fully informed basis.
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Scientists for People is a group of scientists, including many who had worked for CSIR for decades, working in the two Telugy states, focusing on isues of public concern, and defending people’s rights, related to environment and industrial accidents.
Contact for more on the subject and about the Group:
Dr Babu Rao email ID : [email protected]
DR M Bapuji email ID: [email protected]