What is the proof that Sterlite is polluting Thoothukudi? This disingenuous question is put forward by corporate hitmen and spin-masters who want to discredit the protests that have erupted in Tamil Nadu now..Well, here’s the proof. In this series, I will present evidence of harm to the environment and human health caused by Sterlite's operations. To do this, I will use data put out by Sterlite or other official data and studies commissioned by Sterlite, TNPCB or the Courts. (Read Part 1 here.).The second in the series, this article highlights how Tamil Nadu Pollution Control Board (TNPCB) allowed Sterlite to locate its factory in a dangerous place – near densely populated urban neighbourhoods. And there is evidence of how Sterlite made that bad decision worse by failing to check air pollution, failing to develop an adequate greenbelt that could have offered some mitigation, and how it continues to make false claims about its compliance with the law..Copper smelters are significant sources of air pollution. When one thinks of a factory, one looks only at the chimneys, thinking the chimney is the major source of air pollution. But the chimney – also known as the smokestack – is only one part of the story. The bigger part of the story is what is called ‘fugitive emissions’..\r\tLearn more about smokestacks and fugitive emissions\r\tClick on the collapsible panel to open and close it.\r\t\r\t\t\r\t\t\t\r\t\t\t\t\r\t\t\t\t\tClick here\r\t\t\t\r\t\t\t\r\t\t\t\t\r\t\t\t\t\tA tall chimney can protect a local community from the acute effects of air pollution by ejecting the poisons at, say, 75 metres above ground. However, this does not make the pollution disappear. The pollutants will only travel downwind to spread to other places nearby.\r\t\t\t\t\tIn the case of copper smelters, which emit sulphur dioxide (SO2) along with other poisonous metals and gases, the SO2 emissions will get converted into toxic-laden dust (particulate matter) and acid gases, that will travel as a descending plume in the airshed.\r\t\t\t\t\tSo in Thoothukudi, if the prevailing wind blows east at a modest speed of 1 km/hour, the plume from Sterlite's smokestack will spread over Thoothukudi town within six hours. Thoothukudi town centre is about 6 km from Sterlite's chimneys. Six hours after the first release of poisoned air from Sterlite's smokestack in, say February or March when the wind is still blowing east, the poisons will be manifest as mild to severe health effects in Thoothukudi town.\r\t\t\t\t\tIdeally, your air should not have any detectable quantities of SO2. SO2 is destructively acidic. It will tear into the soft tissues of your lung and turn it into jelly and drown you in your own juice. This is not an exaggeration.\r\t\t\t\t\tSterlite is legally permitted by TNPCB to discharge 1.2 tonnes of SO2 per day into Thoothukudi's air. But smelters and copper refineries are complex machineries. The SO2 that is emitted from chimneys is never at a steady rate. It goes up and down depending on a variety of factors.\r\t\t\t\t\tA minor change in, say, the sulphur content of the copper concentrate, can cause a spike in the emission of sulphur dioxide. Such unintended gas releases will be vented through the chimney and end up far away in Thoothukudi town. And then you have the case of intentional releases.\r\t\t\t\t\tThe best copper smelters have hiccoughs – when a copper smelter has a digestive problem in one of its many furnaces, it will have to release the excess gases generated through the chimney. Such releases can last from less than a minute to tens of minutes. If it lasts more than a few minutes, that is sufficient to suffocate populations living downwind of the factory.\r\t\t\t\t\tThe way the best in the world deal with such emergencies is by siting copper smelters far away from human habitation so that the toxic fumes descend on lands that don't matter. In the case of Sterlite's smelter, any accidental release through the smokestack will descend on Thoothukudi town depending on atmospheric conditions.\r\t\t\t\t\tSterlite's first cardinal sin was picking the wrong site. An ultra red category, air pollution-intensive industry should not have been located in close proximity to a densely populated urban area.\r\t\t\t\t\tFugitive emissions: The ones that got away\r\t\t\t\t\tToxic gases are like criminals. Just as only a small fraction of the criminals get caught, only a fraction of the toxic gases from factories are trapped by pollution control devices.\r\t\t\t\t\tFugitive emissions of toxic gases from a factory happen at or near ground level, and are difficult to control. Every time a furnace is opened for charging, gases escape. Vehicular movement results in resuspension of road dust. Joints, flanges, valves, storage sheds, containers storing and transporting chemicals, the act of loading and unloading material are all sources of fugitive emissions.\r\t\t\t\t\tThe US Environmental Protection Agency estimates that fugitive emissions of sulphur dioxide can be up to 6% of the total sulphur charged as part of copper concentrate into furnaces. For Sterlite, that could mean up to 90 tonnes of sulphur released as SO2 and other compounds.\r\t\t\t\t\tPeople living in the immediate vicinity are more likely to be harmed by these ground level emissions than the smokestacks. That is why you have the people from Kumareddiapuram, Therku Veerapandiapuram and Meelavittan complaining of clothes getting dirty when they are hung out to dry, about black dust on leaves, of dust-caked feet, of films of dust on water, and of the first rains bringing down black water from the roofs.\r\t\t\t\t\r\t\t\t\r\t\t\r\t\r.So what is the proof that Sterlite is causing air pollution?.1. What the Supreme Court found.On April 2, 2013, the Supreme Court reported that: “The NEERI reports of 1998, 1999, 2003 and 2005 show that the plant of the appellant [Sterlite] did pollute the environment through emissions which did not conform to the standards laid down by the TNPCB under the Air Act.”.2. The company's compliance with legal norms for emission through the chimney stacks.On the morning of March 23, 2013, thousands of people in Thoothukudi town experienced symptoms varying from mild discomfort to extreme suffocation. A number of women reported miscarriages, and several people including people exercising or walking in the open were hospitalised. The symptoms they reported were in line with exposure to sulphur dioxide..Air pollution monitors attached to the company's Sulphuric Acid Plant 1 convey their readings in real-time to a server maintained by CARE Air centre of the TNPCB. The data for the period 2 am to 11.15 am on March 23 confirms that the company's emissions were far in excess of permissible levels..At 2 am, and from 9.15 am to 11.15 am, SO2 emissions were at least double the permitted levels of release. See Table below:.3. What the ambient air quality data says.In June 2011, NEERI submitted a report to the Supreme Court. The report found concentrations of PM10 in excess of prescribed norms on four different occasions and three different locations. Concentrations of PM2.5 exceeded prescribed norms on two occasions at two locations..[Note: PM10 refers to particulate matter or dust particles that are less than 10 microns in width. PM2.5 refers to particulate matter or dust particles that is less than 2.5 microns in width.].Further, NEERI reported that, “The maximum fluoride concentration (5ug/m3) was observed at SAP-G storage tank (Phosphoric acid plant) whereas minimum fluoride contamination (2ug/m3) was observed at LPG storage and east RHF spray pond (Table 9.6). There is no standard stipulated for fluoride parameter.”.NEERI fails to mention that according to the World Health Organisation, “it has been recognized that fluoride levels in ambient air should be less than 1 ug/m3 to prevent effects in livestock and plants…”.At between 2 and 5 ug/m3, none of the samples of ambient air taken by NEERI in any of the locations sampled meet the WHO Guideline value for fluoride levels in ambient air..The fluoride levels recorded by NEERI outside the industry premises are also in excess of WHO Guideline values, and ranges from 2 times above limits to 6 times above levels considered safe for plants, ruminants and human health..Lest this be seen as a mere aberration, a compilation of all ambient air quality monitoring results obtained from the TNPCB through RTI reveals that between January 2007 and January 2012, ambient air quality inside and outside factory premises was consistently above levels considered safe in one or more locations. The Sterlite township and the All India Radio (AIR) sampling locations were the worst affected..Sterlite Air Effluent Violations - 2007 to 2011 on Scribd.4. Green belt.A green belt denotes the development of a vegetation barrier to arrest air pollution. To be effective, the belt has to be adequately thick, with the right kinds of trees and shrubs, to match the magnitude of pollution. In 1994, TNPCB issued a No Objection Certificate allowing Sterlite to begin the process of obtaining approvals for setting up a 60,000 tonne per annum copper smelter. Condition No. 20 of the NOC required the company to develop a 250 metre greenbelt along the fenceline..On August 12, 1994, Sterlite requested TNPCB to relax the greenbelt condition as 150 acres of land will be required just to develop a 250 metre wide greenbelt. Six days later, the obliging TNPCB decided to arbitrarily bring down the width from 250 to 25 metres..A report of the National Environmental Engineering Research Institute (NEERI), Nagpur, submitted to the Madras High Court in November 1997 found that even this 25 metre tree belt was not developed. It also found that the “green belt width should have been decided on scientific basis vis-a-vis actual requirements for effective air and noise attenuation.”.In 2011, the situation had not changed much. NEERI's submission to the Supreme Court noted that “The present status of greenbelt developed within the industry premises covers only 12.1% [13.1 ha out of a plant site of 102.5 ha] of the industry area as against 25% stipulated in the EC, and 0.7% area is under development.”.In fact, the violation was even more egregious. By 2011, the company was operating a 1200 tonne per day plant for which Environment Clearance (EC) was obtained 9 August, 2007. The company claimed to have 172.17 ha to accommodate its expansion and the pollution control infrastructure required. Specific Condition (vii) of the EC stipulates that “Green belt of adequate width and density around the project site shall be developed in 43 ha out of total 172.17 ha as per CPCB guidelines in consultation with DFO.”.NEERI chose to ignore this Environment Clearance! As per this EC, Sterlite's greenbelt in 2011 was only 7.6% against the stipulated 25%..On 01.01.2009, the company obtained EC to set up a new 1200 tonne per day smelter. That EC expires in December 2018. That EC required the company to develop a greenbelt over 72.35 ha out of 194.78 ha total area..In repeated submissions to various authorities, Sterlite claims to have developed 43 ha greenbelt including a tree belt of adequate width around the perimeter of the proposed copper smelter..A visit to Kumareddiapuram, the site of the ongoing agitation, will make it clear that there is not a single standing tree along the northern, western and southern boundaries of the new site..Nityanand is a Chennai-based writer and social activist and has been involved in the campaign against Vedanta Sterlite's pollution..Views expressed are the author’s own.