During the recent Sardar Sarovar Dam (SSD) induced flood disaster in areas downstream of the dam in Gujarat, the dam operator, SSNNL (Sardar Sarovar Narmada Nigam Limited) violated its own Flood Memorandum (FM) 2020[i] in multiple ways.
The FM-2020 titled “Disaster Management Plan – 2020” provides detailed information about how the dam operation is to be done during South West Monsoon 2020, that is from June 1, 2020 to Oct 15, 2020, or whenever the monsoon has withdrawn. It is published by SSNNL’s Flood Control Cell and carries the names of six highest functionaries of SSNNL on second page: Chairman, Managing Director, Jt MD, Director (CAD), Director (Canal) and Director (Civil). It says Officer in charge of Flood Control Cell of SSNNL is Executive Engineer (Narmada Project Main Canal Division-2) and the FM-2020 is compiled by Superintending Engineer, Narmada Project Design Circle.
An earlier version of the Flood Memorandum for 2018[ii] is also available, which is useful as it has some additional information.
As we wrote earlier, the massive, tragic floods that SSD downstream area faced during Aug 29-Sept 2, 2020 were caused by sudden release of over 10 lakh cusecs of water from SSD and that it was completely avoidable, man made disaster.[iii] We also showed that SSNNL has provided no official response, that the response from four former Gujarat government officials does not help, in fact it totally supports what SANDRP wrote and that SSNNL also drained out at least Rs 85 crores from the spillways of SSD, as it could have generated that value of power in just ten days.[iv]
Key features of Sardar Sarovar Flood Management Some key features of the SSD flood management from the FM 2020 are listed below.
How CWC helps in flood forecasting The flood forecasting system for Narmada Basin is being looked after by Superintending Engineer, Hydrological Observation Circle, (CWC), Gandhinagar through his Executive Engineer, Tapi Division (C.W.C.) at Surat. (Para 2.2.1)
- FM-2020 provides a number of Performa for information and record keeping. For example, para 2.10.1 provides: “C.W.C. Daily/12 Hourly Flood Forecast – Performa” where CWC provides the quantum (MCM) water flow into SSP expected in next 6, 12 and 24 hours.
- Para 2.10.2 provides: “C.W.C. Warning Notice for flood at Mandleshwar – Performa” This provides estimated discharge past Mandaleshwar on given evening and the quantum (MCM) inflow into SSP in next 24 hours.
- Para 2.10.3 provides: “C.W.C. Warning Notice for danger level at Golden Gate Bridge – Performa” provides current and forecast water level of Narmada river at Bharuch in the next 9-12 hours. All three (2.10.1-3) Performa described above are from Executive Engineer Tapi Division of CWC.
SSNNL flood management The Focal Officer for Sardar Sarovar Dam is Superintending Engineer (Headworks), Kevadia Colony and is responsible for: “Keeping constant watch over the flood situation, flood warning, monitoring flood discharges through concerned project authorities, formulating flood forecast as and when required conveying these warning including conveying inflow forecast and flood level forecast from C.W.C. or the case may be in advance to the concerned Revenue and Police authorities for alerting and evacuating people of the area likely to be affected by the incoming floods if necessary.” (Para 2.3.1 & 188.8.131.52)
- “Hourly rainfall data to be taken from intervening stations from IS to SSP during the time of rainfall (Moderate to Heavy). Hourly rainfall data of stations of NCA / CWC have to be kept in the format. Bargi dam, Tawa dam, Indira Sagar Project, Omkareshwar Project station water levels, inflow and outflow on hourly basis have to be taken. Also, gauge discharge curves from U/S projects of SS dam at Hoshangabad, Barginagar, Tawanagar, Mandleshwar, Mortakka, Kankrana Bridge, Rajghat, and Khalghat Bridge also need to be taken hourly. Necessary arrangement need to be made for the acquisition of data for entire duration of monsoon period.” (184.108.40.206/ 2.11.2)
- “It is mandatory to request CWC to forecast the flood from intervening catchment (ISP to SSP). Focal officer –SE (Headworks, Kevadia Colony) fully responsible for gate operation and flood management irrespective of any supporting order done.” (220.127.116.11/ 2.11.6)
- “The Flood Control Cell shall also obtain the weather forecast and rainfall data etc. from Indian Meteorological Department. The water levels and forecast has to convey in morning after 8.00 A.M. to the concern officers.” (2.11.7)
- “As a part of Flood Warning Arrangements, the SSNNL has been linked with point- to-point speech circuit (i.e. Hot line) with the control rooms at Vadodara and Gandhinagar during 1st June to 31st October.” (2.11.11)
- “The focal officer shall be issuing authority of flood warning etc…” (2.3.8)
- SSNNL to downstream Districts Para 2.10.4 provides: “Issue of Flood Warning Notice to release water from Sardar Sarovar Dam to D/S of Narmada River- Performa” from SE (Headworks-Kevadia Colony) SSNNL, mentioning SSP level, storage, inflow, possible gate opening, from time and date, quantum of outflow and possible water level at Garudeshwar and time for the same. This is for alerting the river bank villages and towns in Narmada, Vadodara and Bharuch districts.
- Para 2.11.0 is about Kevadia Colony Control Room.
- “The S.E. N.P. Design (Dam and Powerhouse) circle will be responsible for flood forecasting calculation based on CWC forecast, release from Omkareshwar project, gauge observations from Mandleshwar to SS dam, and rainfall observations in intervening catchment area below OSP to Sardar Sarovar Dam.” (Para 2.11.1) and “assist SE (Headworks), Kevadia Colony for flood management as per CWC and NCA guidelines.” (Para 2.3.2)
- “A Central Flood Control Cell (SSNNL) in “Narmada System Control Room” is set up every year from 15th June to 15th October or up to one week after withdrawal of monsoon. The Chief Engineer (Main Canal), SSNNL Gandhinagar shall be the Central Controlling Officer and will act as a coordinator amongst Controlling Officers and SSNNL management… According to available information / data, necessary steps are required to be taken up to avoid any damage to the canal system / human lives.” (2.12.0) (Emphasis added.)
- News reports about flood damage, inundation to be responded to. “In the event of any news items appearing in the newspapers regarding flood damages including inundation etc. in any area, the concerned Superintending Engineer should immediately take stock of situation and issue necessary press release clarifying the actual situation. Intimation to this effect should immediately be sent to Flood Control Cell. Gandhinagar and concerned Chief Engineer of the project.” (2.13.1)
- Section 2.15 is about “Operation of gates and rule curve levels for Sardar Sarovar Dam”.
- Para 2.15.2 mentions “The Rule Levels are dynamic… past experiences of observed storms, the downstream hazards, safe carrying capacity of the downstream channel and other restrictions, if any. The project officers are also requested to review and finalize the Rule Levels for this monsoon based on the inflow data, water requirements for irrigation, water supply and power generation for the year reservoir losses etc. in consultation with CE (Dam & Vadodara) and get it approved from the Government.” Emphasis added.
- Para 2.15.3 is important as it mentions that when rule curve need to be breached or water is to be released, “concurrence of the concerned Chief Engineer may please be obtained”. While deciding this, among the points that “should be examined critically by the concerned field officers in consultation with respective Chief Engineer” includes “to reduce the downstream hazard potential.” (Emphasis added.)
- Para 7.2.4 is about “Action to be taken by the Executive Engineer, Tapti Division, (C.W.C.), Surat and other Officers.” It says the EE-Tapti Division of CWC (Surat) has to take action to “The Flood Level forecast of GARUDESHWAR & BHARUCH (Golden Bridge) shall be conveyed to the Officers” listed.
- Annexure 7A is about: “Statement showing villages (D/S of SS DAM) affected by floods of Narmada River on the basis of Gauge Level at Garudeshwar Gauge Site.” It mentions three kind of signals: White (Alert), Blue (Ready for Evacuation) and Red (Immediate Evacuation). The levels are provided for Garudeshwar Gauge when these respective alerts are to be issued for each of the villages that are listed as flood vulnerable.
- Annexure 7B is similarly with respect to Bharuch gauge site.
- The Flood Manual could have provided much greater sensitivity towards the downstream areas and added the constraint of ensuring that the dam operation has to be done in a manner to ensure that the downstream flood or damage possibilities are avoided/ minimized.
Does NCA have any role in SSD flood management & gate operation? It is clear on reading the FM-2020 that the Narmada Control Authority (NCA) as such has no role in SSD flood management and gate operation on day to day basis. In the entire 437 page FM-2020 or 540 page FM-2018, there is handful of mention of NCA, but only in the context of some guidelines. The FM makes it clear that the entire responsibility and decision making about the SSD flood management and gate operation is decided at the SSNNL level. So, for instance it says categorically: “Focal officer –SE (Headworks, Kevadia Colony) fully responsible for gate operation and flood management irrespective of any supporting order done.” (Para 18.104.22.168/ 2.11.6) There are several such instances that make it clear that in gate operation and flood management, SSNNL alone is responsible, even in its own eyes.
This shows that the diversionary balloon that an anonymous person described as “A top Gujarat government insider, who has worked for umpteen number of years in the state’s huge Narmada and water resources establishment” was trying float through the CounterView article dated Sept 11, 2020[v] was clearly trying to mislead the people about the SSNNL’s responsibility for the SSD operation that lead to the avoidable Bharuch flood disaster during Aug 29-Sept 2, 2020. The “top Gujarat Govt insider” tried to sell this idea that SSNNL “have “no say” in the release of the waters, which may have allegedly caused flooding of Narmada in Bharuch” and that it was NCA that should be held responsible. SSNNL’s own FM-2020 nails how misleading and wrong the contentions of this anonymous “top Gujarat government insider” are. We of course support the demand of this insider that “SSNNL should share NCA directions on its website or through a press note”, and urge SSNNL to also share the rule curve and other relevant information urgently. However, beyond that such misleading attempts by anonymous insiders must be condemned.
Did SSD release 10 lakh cusecs or 15 lakh cusecs? As per the CWC hydrographs that we shared in our Sept 2, 2020 article, and as per the 4-Retired officials note, SSD released upto 10.72 lakh cusecs of water at maximum during Aug 29-Sept 2, 2020 episode. However, we also note that the peak water level reached, as per the CWC hydrographs we shared, at Garudeshwar was 33.1 m or 108.6 feet and at Bharuch it was 10.72 m or 35.17 feet. Now if we go through the FM-2020 & FM-2018, we notice that water flow at these levels is much higher.
For example, as mentioned in Annex B (starting on P 41, part I in FM-2018) titled “Statement of Gauge Discharge at Garudeshwar and Corresponding Gauge at Golden Bridge, Bharuch” we notice that flow corresponding to level of 33.2 m at Garudheshwar is 35205 cumecs or 12.4 lakh cusecs. Similarly flow corresponding to Bharuch level of 10.73 m or 35.2 ft is 44500 cumecs or 15.7 lakh cusecs.
Similarly, if we see statement 1.5.0 in FM-2020 titled “STATEMENT SHOWING YEARWISE MAXIMUM RECORDED FLOOD AND GAUGES FOR RIVER NARMADA FROM 1948 TO 2019” we note that the flood on 17 Sept 1961 corresponded to Bharuch water level of 35.2 feet, similar to this year, when flood quantum was 15.3 lakh cusecs. Similarly flood on Aug 10, 1981 corresponded to Garudeshwar water level of 108.5 m, similar to this year, the discharge in that year was 14.83 lakh cusecs. It is true that the river bed and river cross section conditions and hence carrying capacity of river at specific levels would have changed over the years. However, since we also note that these flood quantum matches with the flood quantum mentioned at specific level achieved this level, we would rather go by these indications. All this seems to indicate that the peak discharge this year may be closer to 15 lakh cusecs, much higher than what CWC hydrograph or SSNNL supported report may suggest.
Number of affected villages The FM-2020 also provides list of villages and towns that would be affected at different levels of downstream water levels at Garudeshwar and Bharcuh. The full list of downstream flood vulnerable towns and villages includes 28 villages of Narmada district (5 in Tilakwada taluka and 23 in Nandod Taluka), 13 in Vadodara district (6 in Karjan taluka, 3 in Dabhoi taluka and 4 in Sinor taluka) and 49 in Bharuch district (14 in Bharuch taluka including Bharuch city, 15 in Ankaleshwar taluka, 19 in Jhagadia taluka and 1 (Hansot) in Hansot Taluka). In all there are 90 villages or towns that are vulnerable to floods in the downstream area.
Out of these, if we go by the number of villages below 108.6 feet water level at Garudeshwar and 35.17 feet water level at Bharuch, we note that 34 villages & towns should have been affected this year, including one village (Chandod) in Dabhoi taluka, one village in Sinor taluka, one village in Nandod taluka, 2 in Karjan taluka, 6 in Bharuch taluka, 14 in Ankaleshwar taluka and 9 in Jhagadia taluka, total of 34 villages and towns spread over 7 talukas in three districts.
However, the list of possible affected villages given by SSNNL in the FM-2020 may not be accurate. To illustrate, the list contains only 4 villages of Sinor Taluka that can be affected by the highest flood level and in the current year, only one of these, namely Madhi Devasthanam should have been affected. However, there are a number of newspaper reports (one of them below) which lists the 11 villages of Sinor Taluka that were flooded during the SSD induced floods, the list does not include Madhi Devasthanam, but includes two others in SSNNL Sinor taluka list. One can give more such illustrations from Dabhoi, Karjan and other talukas.
It seems that FM-2020 is as callous and cruel in listing of affected villages as it is in operating the SSD. It is also disturbing that over ten days after the disaster, we do not see any report, either on Gujarat State Disaster Management Authority’s website or SSNNL website or any information about the number of affected villages and extent of impact on each village.
Did SSNNL create a flood disaster in 2019 too? According to FM-2020, the peak flood released by SSP in 2019 was on Sept 10-11, 2019 when due to 8.47 lakh cusecs (23985 cumecs) discharge, water level reached 97.05 ft at Garudeshwar and 31.89 ft at Bharuch. The danger level at Bharuch being 23.98 ft, the actual water level was almost eight feet above the danger level.
In 2019, spillway discharge at SSP started on Aug 9, at low level of around 1710 cumecs and spillway discharge never completely stopped till Oct 13. The peak discharge on Sept 10-11 could have been reduced to some extent if higher discharge was started a few days earlier. However, till Sept 9, discharge was lower than 10000 cumecs, while water level was rising fast. This then lead to a situation of sudden jump to doubling of discharge from Sept 10 that continued till Sept 15, by then the SSP water level was all the time over 136 m, going on to 138.34 meter by Sept 15. Unfortunately, no questions were asked then and that possibly made SSNNL engineers bolder this year to straightaway start with over 10 lakh cusecs from the day one on Aug 29.
How SSNNL violated its own Flood Memorandum 2020 The FM-2020 provides elaborate information and communication SOPs (Standard Operating Procedures) that can be used by SSNNL (the organisation clearly responsible for SSP dam operation) to accurately forecast the inflows and hence possible outflows from SSD. These outflows can then be limited to ensure that Narmada river flow at Golden Bridge, Bharuch is below say 16036 cumecs (5.66 lakh cusecs), since any flows above this level at Bharuch leads to river crossing the danger level as per FM-2020 (section 1.8.0). The way SSD was operated before Aug 28 and after Aug 28, 2020 makes it clear that absolutely no attempt was made to ensure this basic condition is met. The SSNNL had the benefit of all the information we highlighted in earlier two articles, in addition to the elaborate information system that it got advantage of from CWC and NCA as mentioned in its own Flood Memorandum for 2020 as highlighted above.
SSNNL has also clearly violated the conditions given in its FM-2020: “to reduce the downstream hazard potential” and “to avoid any damage to the canal system / human lives”. There is nothing on record directly or indirectly to show that SSNNL made absolutely ANY attempt to achieve these conditions. On the contrary, the way it operated the power houses since Aug 26 (or even earlier), it is clear that it made absolutely no effort to achieve these basic objectives that has to be the central theme of flood management and gate operation, besides safety of the dam itself.
The FM-2020 also provides elaborate system of alerts (white, Blue and Red) for each of the vulnerable villages and towns that FM has listed (that listing itself is seriously problematic, and those responsible for such callous listing of vulnerable villages and towns in downstream areas should be held accountable). There is again absolutely no evidence to show that this elaborate system was followed to alert and evacuate the affected population before the suddenly rising flood waters affected them.
The FM-2020 in section 2.13.1 clearly states: ““In the event of any news items appearing in the newspapers regarding flood damages including inundation etc. in any area, the concerned Superintending Engineer should immediately take stock of situation and issue necessary press release clarifying the actual situation.” The news papers, television channels and other internet media are full of news about the massive flood disaster that the SSD downstream area faced starting on Aug 29 and disaster dimensions are still unfolding. But we have seen no press release of any kind on SSNNL website or on its official social media organs like twitter handle. SANDRP has repeatedly written about this in public media which has been published with tag to SSNNL, which has been published by news media like Counterview and First India newspaper among others. But there has been absolutely no response from SSNNL anywhere. This is yet another violation of the FM-2020.
In Conclusion It is once again clear that SSNNL has violated every principle of prudent flood management in its operation of SSD during current monsoon. Now it is clear that it has violated its own Flood Memorandum in multiple ways. As highlighted above, SSNNL created a flood in 2019 monsoon too when water flow at Bharuch crossed the safe limit of 5.66 lakh cusecs and reached 8.47 lakh cusecs for prolonged period stretching over several days. This year SSD has created even bigger disaster with flows possibly reaching upto 15 lakh cusecs. Only an independent investigation (not by current or former government officials) that fixes accountability and provides lessons for future can help if we are not to see this repeated in years to come. Else the trends are clear. We hope the people of Gujarat, media judiciary, NDMA or others are watching and will take appropriate action.
Himanshu Thakkar (firstname.lastname@example.org)
POST SCRIPT 1. 170920: SSD is full in the morning of PM Modi’s birthday, like last year. Immediately after the morning achievement, the gates were opened to release water to downstream. https://in.news.yahoo.com/video-sardar-sarovar-dam-reaches-125656059.html