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On perusal of the clarification raised to the industry by RO on 27.07.2022 in lieu to the observations, reply submitted by project proponent to the clarification on 27.07.2022, the comments on the reply submitted by, RO, Ludhiana-IV vide note dated 27.07.2022.
The reply submitted by the industry and the comment of RO on observation mentioned at point no. 1, 2, 3 and 5 were not satisfactory.
Furthermore, from the reply submitted by the industry and thereupon comments by RO, LDH-IV, the following discrepancies are not yet redressed:
1. As per the previous consent to establish (NOC) granted to the industry on 22.03.2019 as well as the Environment Clearance granted by SEIAA, Punjab dated 03.12.2018, the total trade effluent generation from the unit would be 148 KLD to be treated through ETP; out of which 120 KLD treated effluent would be recycled and remaining 28 KLD would be discharged onto land for plantation. However, the industry has applied for generation of effluent @ 21 KLD to be treated through ETP and disposal onto land for plantation area only, which is not in consonance with the EC and the CTE granted to the industry. Also, the RO has reported that the ETP installed by the industry is of 60 KLD treatment capacity.
2. Further, the RO has reported that the industry has not installed Online Continuous Effluent Monitoring System at the outlet of ETP as per condition of EC granted to it. The industry has mentioned in the EC compliance report submitted by it that ‘The quantity of trade effluent is less than 50 KLD and the industry has achieved ZLD as such OCMS is not required at this stage’, which is not in line with the guidelines for Online Continuous Monitoring Systems for Effluent issued by CPCB dated 07.11.2014. Also, as the industry is discharging its treated effluent onto plantation, therefore, it is not achieving ‘ZLD’ status as per the Table-3 Foot Note point 2. Wherein it has been specified that ‘For industries achieving Zero Liquid Discharge by utilizing effluent for irrigation/gardening will have to install Real time monitoring systems’.
Also, in the last CTO granted to the industry under the Water Act, 1974, a special condition was imposed to the effect that the industry shall install online continuous monitoring system of effluent on the outlet of the ETP and shall connect the same with PPCB & CPCB server, within 01 month. The industry is required to submit compliance of the said conditions.
3. The NOC regularisation fees (Rs. 49,200) as well as penalty fees (Rs. 8400 under each act )as reported by the Regional Office is not verified and linked with the online application.
4. The industry has not submitted revised building plans of its unit approved under the Punjab Factory Rules, 1952 by the competent authority.
5. As per the EC granted to the industry, it was required to spend Rs.78 lakh towards CER activities, however, it has mentioned only expenditure of Rs. 25 lakh in the EC compliance report submitted by it as well as endorsed by the RO, LDH-IV.
6. Also, the RO has reported in the EC compliance report that the plantation need to be enhanced by the unit to achieve 33% of the total project area. The unit is required to clarify regarding the same.
7. Also, the RO has reported in the EC compliance report that the industry has not submitted compliance of the following conditions of EC pertaining to ‘Air Quality Monitoring and Preservation’:
i. The project proponent shall install 24x7 continuous emission monitoring system at process stacks to monitor stack emission with respect to standards prescribed in Environment (Protection) Rules 1986 and connected to SPCB and CPCB online servers and calibrate these systems from time to time according to equipment supplier specification through labs recognized under Environment (Protection) Act, 1986 or NABL accredited laboratories.
ii. The project proponent shall monitor fugitive emissions in the plant premises at least once in every quarter through labs recognized under Environment (Protection) Act, 1986.
iii. Ambient air & noise levels should conform to prescribed standards both during day and night. Incremental pollution loads on the ambient air quality, noise especially during worst noise generating activities, water quality and soil should be periodically monitored during construction phase as well as operation & entire life phase as per the MoEF & CC guidelines and all the mitigation measures should be taken to bring down the levels within the prescribed standards.
iv. The project proponent shall install system to carryout Ambient Air Quality monitoring for common/criterion parameters relevant to the main pollutants released (e.g., PM10and PM25 in reference to PM emission, and S02 and NOx in reference to S02 and NOx emissions) within and outside the plant area at least at four locations (one within and three outside the plant area at an angle of 120 each), covering upwind and downwind directions
The industry is required to submit compliance of the aforesaid conditions.
You are requested to clarify to the aforementioned queries within 2 days, so that your application can be processed further. |
2022-08-11 14:20:14.269 |
