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M/s. Mateshwari Mintech Pvt Ltd

Address: Flate Number 706,

B- Block, Athena Building, Jaisingh

Highway,

Bani Park- 302016, Jaipur Rajasthan

Contact No: 9829044828

Mail Id: [email protected]

Ref. No.: Date: 31.01.2018

To,

The Director (Non Coal Mining-IA Division)

Ministry of Environment, Forests & Climate Change

Govt. of India, Indira Paryavaran Bhavan,

Jorbag Road, Aliganj,

New Delhi – 110 003

Subject- Proposed River Bed Mining Project of Bajri (Area: 247.10 ha) with production capacity 0.342 million

TPA at Tehsil & District Alwar (Rajasthan) by M/s. Mateshwari Mintech Pvt Ltd- Reg submission of EDS

(Essential Details Sought).

Ref: 1. MoEFCC File No. J-11015/372/2015-IA.II (M) & Proposal No IA/RJ/MIN/30932/2015

2. EDS issued by MoEFCC on 12.12.2017

Sir,

With reference to the aforesaid subject and above stated reference; we would like to inform your good self

that Final EIA/EMP Report for aforesaid mining project has been submitted to MoEFCC vide letter dated

31.10.2017. Thereafter, Essential details sought by MoEFCC on 12.12.2017.

Accordingly, we are here with submitting the reply of all of the points mentioned in EDS.

Therefore, we would like to request you, kindly consider our request and put up our aforesaid mining project

for consideration of EC in upcoming EAC Meeting agenda.

Thanking you with regards,

M/s. Mateshwari Mintech Pvt Ltd

Kshitiz Choudhary Authorized Signatory Enc as Above

EDS REPLY

1 | Page M/s. Mateshwari Mintech Pvt Ltd

Point No. 1: PP shall take note of the Minutes of the EAC delibrations for the month of October-2016

and November, 2017, wherein the committee observed the requirement of scientific

replenishment study for river sand mining proposal of Rajasthan State.

Reply Replenishment study has been done by Department of Geology, University of Delhi.

Replenishment study report is enclosed as Annexure II.

Point No. 2: Since Bajri in the State of Rajasthan is regulated as per the Hon’ble S.C. Court order dated

27.03.2014. PP may provide a clarification from State Mines Department mentioning the

production details, if any and a statement on whether illegal mining has been carried out

by PP or not.

Reply Letter has been received from State Mines Department vide their letter no

Anikha/Jai/Al/CC-II/Bajri/2017/51 dated 18.01.2018. Copy enclosed as Annexure III.

Point no.3 A Clarification may also be provided on the extent of lease to be considered in view of

DFO Certificate.

Reply Letter has been received from State Mines Department vide their letter no

Anikha/Jai/Al/CC-II/Bajri/2017/51 dated 18.01.2018. Copy enclosed as Annexure III.

Point no.4 The Proof of submission of conservation plan to Chief Wildlife Warden is required to be

submitted.

Reply Conservation Plan for Schedule I species from Forest Department is under process.

Correspondence with Forest Deptt dated 26.10.2017 is enclosed as Annexure IV.

Point no.5 Clarification may be provided on whether Addl CEO Zila Parishad is equivalent to ADM

rank or above.

Reply Letter has been received from District Collector, Alwar regarding clarification on above said

matter vide their letter no sths/vividh/2015/7570 dated 30.11.2017. Copy enclosed as

Annexure V.

12/13/2017 Untitled Page

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Essential Details Sought

Sno. Proposal No. Project Name ProjectSector Location Detail Company/Proponent Name Date of

submissionEDS

Reply

1 IA/RJ/MIN/30926/2015 Non-CoalMining

State: RajasthanDistrict: Alwar

Company: MATESHWARI MINTECHPVT LTD 30/11/2017

2 IA/RJ/MIN/30932/2015 Non-CoalMining



3 IA/RJ/MIN/70696/2015River Bed Mining Project of Bajri (Area-581.28 ha) with ProductionCapacity 1.65 Million TPA at Tehsil: Ramgarh, District: Alwar(Rajasthan) by M/s Mateshwari Mintech Pvt. Ltd.

Non-CoalMining



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Essential Details Sought

Sno. Proposal No. Essential DetailsSought

on/ReplyDate

EdsLetter Status

1 IA/RJ/MIN/30932/2015

Earlier EDS raised were not replied and PP/ Consultant has ignored Ministry'squestions which is not appreciated. PP shall take note of the Minutres of the EACdeliberations for the month of October-2016 and November, 2017 wherein theCommittee observed the requirement of Scientific Replenishment study for Riversand mining proposals of Rajasthan state. Accordingly, PP/ Consultant maysubmit the required Scientific Replenishment study report along with earlierqueries

12/12/2017 Pending

2 IA/RJ/MIN/30932/2015 The correction have been made as per the instruction received 30/11/2017 Replied

3 IA/RJ/MIN/30932/2015

1. Since Bajri mining in the State of Rajasthan is regulated as per Hon'ble S.COrder dated 27.03.2014, PP may provide a clarification from State Mines Deptt.mentioning the production details, if any, and a statement on whether illegalmining has been carried out by PP or not. 2. A clarification may also be providedon the extent of lease to be considered in view of DFO Certificate. 3. The proofof submission of Conservation plan to Chief Wildlife Warden is required to besubmitted. 4. Clarification may be provided on whether Addl CEO Zila Parishad isequivalent to ADM Rank or above.

13/11/2017 Replied

4 IA/RJ/MIN/30932/2015 The correction have been made as per the instruction received 30/09/2015 Replied

5 IA/RJ/MIN/30932/2015 PP has not filled the mine lease area details in Si No. 10 of Form I and a lot ofcolumns left blank. Please revise the details and upload accordingly. 29/09/2015 Replied

mailto:[email protected]

http://environmentclearance.nic.in/User/EDS_Reply.aspx

http://environmentclearance.nic.in/User/EDS_Reply.aspx

Vinay Khandelwal

Typewritten text

Annexure I

Vinay Khandelwal

Typewritten text

Annexure II

Proposed River Bed Mining Project of Bajri, Area-247.10 ha with production capacity 0.342 million TPA

at Tehsil & District: Alwar (Rajasthan)

Replenishment Study Report

Prepared by Department of Geology, University of Delhi 1

REPLENISHMENT STUDY REPORT

1.0 INTRODUCTION

Environmental destruction is the price mankind has to pay for unsustainable development.

Alarming increase in indiscriminate sand mining has caused serious damage to the river

system. As the demand for sand increases in industry and construction, leads to indiscriminate

mining of sand from the rivers. The quantum of sand mined every year is several fold more

than what flows down and accumulate in the riverbeds. This situation creates a serious

environmental threat to the riverine system. On the other hand sand is an essential

construction material and it gives employment to a large sector in our state. So the complete

banning of sand mining is not a practicable solution to this multidisciplinary problem. A

balanced amount of sand mining enables the river to maintain its stability. There were several

studies reported in this regard, but most of the studies are related to environmental impacts

of sand mining rather than the study on sand inflow. The studies and the guidelines set by the

research organization on sand mining are based on the quantity of sand. Therefore, a study is

innovative to assess the sand inflow; which will help to assess the optimal sand removal. An

analytical approach to estimate the sand inflow is a viable method. The present study is an

analytical study to determine the sand inflow and there by the optimal amount of sand mining

that can be permit from the different mining pits of River. This study can use for settling the

guidelines for a sustainable future.

2.0 OBJECTIVES OF THE STUDY

This is intended for use to achieve the following regulatory and management objectives:

• to ensure that sand extraction is carried out in a sustainable way

• to maintain the river equilibrium with the application of sediment transport principles in

determining the locations, period and quantity to be extracted

3.0 SAND MINING IN THE STATE OF RAJASTHAN

According to clause (e) of Section 3 of the Mines and Minerals (Development & Regulation)

Act (MMDR) Act, 1957 and as per Rule 70 of the Mineral Conservation Rules (MCR), 1960; sand

is classified as minor mineral based on the end use. Mines and Minerals (Development &

Regulation) Act, 1957, under section 15, empowers the State Government to make rules in

respect of minor mineral. Mining Leases for the mineral Bajri are granted as provided in

Rajasthan Minor Mineral Concession (Amendments) Rules, 2012 notified vide Department

Notification No. F.14 (1) Mines/ Gr. II/ 2011 dated 23-05-2012 i.e. RMMCR, 1986.

In exercise of the powers conferred by Section 15 of the Mines and Minerals (Development &

Regulation) Act, 1957 (Central Act No. 67 of 1957), the State Government of Rajasthan made

rules for regulating the grant of quarry license, mining lease and other mineral concessions in





respect of minor minerals. As per the Notification of Government of Rajasthan dated 28

February, 2017, “Bajri” means weathered detritus consisting of graded particles of varying

sizes obtained from loose weathered rock material from the provenance, usually found in river

beds or basins or paleo channels, also covers river sand.

The following provisions interalia for the mining of Bajri/sand is applicable that:

I. As per Rule 18 (Amended Rules, 2012) of RMMCR, 1986 clause 32 stipulates “In case of

mining lease of mineral Bajri, the lease/ leases shall abstain from mining beyond depth of

3.0 m from the surface and below the water in such a manner that natural path of river/

nallah is not altered”.

II. As per notification no. F-14(1) Mines/Gr11/2012 dated 21 June, 2012 from Dy. Secretary to

Government of Rajasthan clause 3 “No person shall excavate Bajri beyond the depth of

3.0 m from the surface below the water level of river/nallah and within 45 m of any rail/

road bridge.”

4.0 STUDY AREA

District Alwar is situated at the northern part of Rajasthan and is mineral based district and is

a part of national capital region. Most part of alwar district falls on GT Sheet No. 54A, 54E &

53D. Alwar falls from delhi – jaipur rail line & lies on the highway no. 21 in between Delhi –

Jaipur. Alwar has ten tehsils & all are rich in minerals. The study area is Alwar tehsil lies in Alwar

district of rajasthan.





Location map

Figure 1: Google earth image showing the location of proposed blocks for mining

5.0 GEOLOGY, GEOMORPHOLOGY, LITHOLOGY: -

The study area Alwar Tehsil comes under Alwar district in the northeast bordering Haryana,

covers an area of 8380 km2, falling in survey of india degree sheets 54A, E and 53 D. Large area

of the district, however, falls in the degree sheet 54A and forms a part of the national capital

region. The average annul rainfall is 577mm. The district is characterized by a mature

topography of more or less fiat topped hills forming the northern continuation of main aravalli





range. Major part of the district is occupied by folded hill range which are densely forested and

host the famous Sariska Game Sanctuary. While the eastern and northern, flood plain support

intensive agriculture productions making alwar an agriculturally prosperous district of

Rajasthan.The district comprises precambrain metamorphic and igneous rocks, belonging to

the mangalwar complex of the bhilwara supergroup (Archaean) and Raialo, Alwar and

Ajabgarh Groups, in ascending order superposition, belonging to the Delhi super group (Lower

to middle proterozoic) and post. Delhi igneous intrusive auulvium and Aeolian sediments mask

the older formations. Geomorphologically, the district is classified into six geomorphic units

namely younger dune, older dune, oldest dune, older flood plain, palaeo – channel and

denudational hill . Three river basins namely the sabi river Basin, the Banganga River Basin and

the Barah River Basin have been superimposed over the geomorphology in this map. Natural

hazards map shows areas prone to industrial pollution, water logging. Salinity and gully, wind,

soil erosion etc.

Figure 2: Drainage map of the study area





Table 1: Production of River Sand (Bajri)

Year Block Length (meter)

Width (meter)

Average bed

thickness (meter)

Total Excavation in Cu.meter

Recoverable volume in Cu.meter

1st year Block-I Block-II Rest nadi and nala

7000 6500 10000

25 26 20

0.5 0.5 0.5

87500 84500 100000

78750 76050 90000

2nd year Block-I Block-II Rest nadi and nala

7000 6500 10000

25 26 20

0.5 0.5 0.5

87500 84500 100000

78750 76050 90000

3rd year Block-I Block-II Rest nadi and nala

7000 6500 10000

25 26 20

0.5 0.5 0.5

87500 84500 100000

78750 76050 90000

4th year Block-I Block-II Rest nadi and nala

7000 6500 10000

25 26 20

0.5 0.5 0.5

87500 84500 100000

78750 76050 90000

5th year Block-I Block-II Rest nadi and nala

7000 6500 10000

25 26 20

0.5 0.5 0.5

87500 84500 100000

78750 76050 90000

6.0 IMPACTS OF SAND MINING

Sand mining has an adverse and destructive impact, at the same time it has some positive

impacts also. It observes that the removal of sand from the riverbeds in a sustainable way can

improve the river health.

A. Negative Impacts

Taking into consideration the places of occurrences of the adverse environmental impacts of

river sand mining, Kitetu and Rowan (1997) classified the impacts broadly into two categories

namely Off- site impacts and On-site impacts. The off-site impacts are, primarily, transport

related, whereas, the on-site impacts are generally channel related. The On- site impacts are

classified into Excavation impacts and water supply impacts. The impacts associated with

excavation are channel bed lowering, migration of excavated pits and undermining of

structures, bank collapse, caving, bank erosion and valley widening and channel instability. The

impacts on water supply are reduced ground water recharge to local aquifers, reduction in

storage of water for people and livestock especially during drought periods, contamination of

water by oil, gasoline and conflicts between miners and local communities.





B. Positive Impacts

Sand deposition eventually leads to reduction in conveyance capacity of river leading to flood

in rivers. Proper dredging of sand keeps the bed at the desired level. Thus if dredging is not

done, due to continuous deposition of sand, the depth of river may get reduced. This will result

in flooding of water and loss of properties. Riverbeds are major sources of clean sand. It is

observed that the demand of sand for house construction has been increased drastically which

is reflected well in exponential rise in the number of terraced and tiled houses. Collecting sand

from rivers and its distribution has become an industry giving job opportunities for thousands.

Ministry of Environment, Forests & Climate Change (MoEFCC), Government of India, in the

Sustainable Sand Mining Management Guidelines, 2015 has identified the following impacts on

account of sand and gravel mining:

I. Extraction of bed material in excess of replenishment by transport from upstream

causes the bed to lower (degrade) upstream and downstream of the site of removal.

II. In-stream habitat is impacted by increase in river gradient, suspended load, sediment

transport, sediment deposition. Excessive sediment deposition for replenishment

increases turbidity which prevents penetration of light required for photosynthesis

and reduces food availability of aquatic fauna.

III. Riparian habitat including vegetative cover on and adjacent to the river banks controls

erosion, provide nutrient inputs into the stream and prevents intrusion of pollutants in

the stream through runoff. Bank erosion and change of morphology of the river can

destroy the riparian vegetative cover.

IV. Bed degradation are responsible for channel shifting, causing loss of properties and

degradation of landscape, it can also undermine bridge supports, pipe lines or other

structures

V. Degradation may change the morphology of the river bed, which constitutes one

aspect of the aquatic habitat.

VI. Degradation can deplete the entire depth of gravelly bed material, exposing other

substrates that may underlie the gravel, which could in turn affect the quality of

aquatic habitat. Lowering of ground water table in the flood plain because of lowering

of riverbed level as well as river water level takes place because of extraction and

draining out of excessive ground water from the adjacent areas. So, if a floodplain

aquifer drains to the stream, groundwater levels can be lowered as a result of bed

degradation.

VII. Lowering of the water table can destroy riparian vegetation.

VIII. Excessive pumping of ground water in the process of mining in abandoned channels

depletes ground water causing scarcity of irrigation and drinking water. In extreme

cases it may create ground fissures and subsidence in adjacent areas

IX. Flooding is reduced as bed elevations and flood heights decrease, reducing hazard for

human occupancy of floodplains and the possibility of damage to engineering works.





X. The supply of overbank sediments to floodplains is reduced as flood heights decrease.

XI. Rapid bed degradation may induce bank collapse and erosion by increasing the heights

of banks.

XII. Polluting ground water by reducing the thickness of the filter material especially if

mining is taking place at top of recharge fissures.

XIII. Choking of filter materials for ingress of ground water from river by dumping of finer

material, compaction of filter zone due to movement of heavy vehicles. It also reduces

the permeability and porosity of the filter material.

XIV. Removal of gravel from bars may cause downstream bars to erode if they

subsequently receive less bed material than is carried downstream from them by

fluvial transport

XV. Ecological effects on bird nesting, fish migration, angling, etc.

XVI. Direct destruction from heavy equipment operation; discharges from equipment and

refueling.

XVII. Bio-security and pest risks.

XVIII. Impacts on coastal processes.

7.0 SEDIMENT TRANSPORT

Sediment transport is the movement of organic and inorganic particles by water. In general,

the greater the flow, the more sediment that will be conveyed. Water flow can be strong

enough to suspend particles in the water column as they move downstream, or simply push

them along the bottom of a waterway. Sediment transported I river as bedload, suspended

load, and wash load.

8.0 BEDLOAD

Bedload is the portion of sediment transport that rolls, slides or bounces along the bottom of

a waterway. Bedload occurs when the force of the water flow is strong enough to overcome

the weight and cohesion of the sediment 12. Approximately 5-20% of total sediment transport

is bedload 10.

9.0 SUSPENDED LOAD

The suspended load is the amount of sediment carried downstream within the water column

by the water flow. Suspended loads require moving water, as the water flow creates small

upward currents (turbulence) that keep the particles above the bed. Larger particles are more

likely to fall through the upward currents to the bottom, unless the flow rate increases,

increasing the turbulence at the streambed. In addition, suspended sediment will not

necessarily remain suspended if the flow rate slows.





10.0 WASH LOAD

The wash load is a subset of the suspended load. This load is comprised of the finest suspended

sediment (typically less than 0.00195 mm in diameter). The wash load is differentiated from

the suspended load because it will not settle to the bottom of a waterway during a low or no

flow period.

11.0 SEDIMENT DEPOSITION

Sediment is necessary to the development of aquatic ecosystems through nutrient

replenishment and the creation of benthic habitat and spawning areas. These benefits occur

due to sediment deposition – when suspended particles settle down to the bottom of a body

of water. This settling often occurs when water flow slows down or stops, and heavy particles

can no longer be supported by the bed turbulence. However, it should be noted that while

sediment is important for aquatic habitat growth, it can cause environmental issues if the

deposition rates are too high, or too low.

Figure 3: Photographs during visit

12.0 METHODOLOGY ADOPTED

The scientific solution for the crisis of sand mining needs an optimisation of sand removal.

Knowledge of sand inflow at each section is the key part of determination of optimal sand

removal.

To determine this sand inflow an analytical study is carried out by using bed load transport

model. The bed load transport can be estimated using different analytical model such as

Mayer-Peter‘s, Einstein‘s Model, Shield‘s Formula, Du-Boy‘s Formula etc. The present study

deals with the Meyer-Peter‘s computation. For this, the sample of sand from different critical

locations, flow data, and other river characteristics were used.

A. Meyer – Peter’s equation





Meyer Peter‘s equation is based on experimental work carried out at Federal Institute of

Technology, Zurich. Mayer Peter gave a dimensionless equation based, for the first time, on

rational laws. It is given by

Qs = actual discharge in cumec, Q = discharge in cumec if sides were frictionless N ‘= Manning‘s coefficient for plane bed N = actual value of Manning‘s coefficient for rippled bed w = specific weight of water in kN/m3 S = bed slope of channel D = depth of flow in m ws =specific weight of sediment particles in kN/m3 d = grain diameter in m g = acceleration due to gravity qs = rate of bed load transport per unit width of the channels in kN/m3

The present study used the Meyer-Peterson‘s model for the estimation of bed load transport

because of its wide acceptance and simplicity in computation. Other models give reliable

estimates for manmade channels like canals. But the present study considered with river body,

in which the former equation is relevant.

A sediment balance for the three blocks prior to the start of dredging was determined. The

river characteristics such as area of flow, velocity of flow, slope, discharge and sediment

concentration are collected. The sediment load samples were collected from the upstream and

the dowstream of propsed minning block. The sediment load samples gives the estimate of

sediment getting deposited in the block and the sediment getting transported.

13.0 ESTIMATION OF SAND DEPOSITED FROM BLOCKS PROPOSED FOR MINING

Blocks has been selected on the basis of maximum deposition of sand. Sand inflow estimation

has been done by taking discharge data, depth of flow at different point in each cross-section,

slope, manning’s coefficient, and average size of the sand in each block. This river has a

meandering course and velocity of flow is 0.1 to 0.6 m/s and results in settling of fine sediment

which is suitable for construction. This in turn causes the development of good sand mining

locations. As this river is seasonal only monsson period (june-sept) is considerded for study.

During monsoon period the velocity of flow is observed high and is around 0.6m/s. Thus

assumption is made that 70% of sand transported is deposited during monsoon period. The

rate of deposition is calculated based on this by assuming a width of 100 m from which sand





removal takes place daily during the monsson period. To maintain equilibrium of the river the

amount of sand extracted should be less than the amount of sand deposited.

Table 2: Production of river sand(Bajri)

Year Bench Mineral in Tonnes

1st year Block I Block II Rest Nadi and nala

110250 106470 126000

2nd year Block I Block II Rest Nadi and nala

110250 106470 126000

3rd year Block I Block II Rest Nadi and nala

110250 106470 126000

4th year Block I Block II Rest Nadi and nala

110250 106470 126000

5th year Block I Block II Rest Nadi and nala

110250 106470 126000

Total 17,13,600

1.Block I

Figure 4: Google earth map showing the Block 1 proposed for minning of Bajri

Table 3: Estimation of sand deposited in Block 1

Month sediment

load/hr Sand

deposition sediment load/day

sediment load/month

sediment load/month

qs(kg/m/hr) (kg/m/hr) qs'=qs*24*widt

h (tonnes)

Jun 500 350 840000 25200000 25200

Jul 580 406 974400 30206400 30206.4

aug 590 413 991200 30727200 30727.2

Sep 570 399 957600 28728000 28728

Annual sediment load 114861.6





2.Block II

Figure 5: Google earth map showing the Block 2 proposed for minning of Bajri

Table 4: Estimation of sand deposited in Block 2

Month

sediment load

Sand deposition

sediment load/day

sediment load/month

sediment load/month

qs(kg/m/hr) (kg/m/hr) qs'=qs*24*width (tonnes)

Jun 460 322 772800 23184000 23184

Jul 540 378 907200 28123200 28123.2

aug 580 406 974400 30206400 30206.4

Sep 550 385 924000 27720000 27720


3.Rest Nadi and nala

Figure 6: Google earth map showing the Block 3(Rest nadi and nala proposed for minning of Bajri





Table 5: Estimation of sand deposited in nadi and nala

Month

sediment load

Sand deposition

sediment load/day

sediment load/month

sediment load/month

qs(kg/m/hr) (kg/m/hr) qs'=qs*24*widt

h (tonnes)

Jun 580 406 974400 29232000 29232

Jul 620 434 1041600 32289600 32289.6

aug 650 455 1092000 33852000 33852

Sep 640 448 1075200 32256000 32256


14.0 CONCLUSION

The rivers of Rajasthan are ephemeral in nature and therefore there is need to look at the issue

of replenishment of these rivers from different perspective. The rivers are not replenished

annually as is the case of perennial rivers and therefore the concept of annual replenishment

based mine capacity does not apply for the rivers of Rajasthan. There is need to consider

appropriately for change of the policy applicable for annual replenishment of rivers vis-à-vis

mine capacity permits in case of Rajasthan.

River flow during rainy season & remaining times it gets dry. So scientific study report is

possible in that case where, flow of river occurs annually or in perennial rivers. Study was

conducted only in three-month rainy season. So, approx. 4 to 5 years will have required for

proper scientific replenishment study. Therefore, calculation was done based on Meyer –

Peter’s equation formula.

As the demand of sand is increasing it is recommended to remove sand from the blocks as per

the proposed sediment load. The sediment deposition in that area is more than the proposed

load for removal. So the removal of that amount of sand will not degrade the health of the

river.

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Vinay Khandelwal

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Annexure IV

Vinay Khandelwal

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Annexure V

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