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Observations of PPCB (Invest Punjab) on application for varied CTOs raised today i.e. on 11.08.2022
The pointwise reply of the observations is as under:
Observation 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.
Reply : In this regard it is brought out that at the time of getting EC/CTE the water balance was prepared on the basis of prevailing practices in the industries wherein a lot of waste water was discharged during manufacturing of IBAP & AMN particularly in the quenching process. However, during implementation of the project the industry has successfully implemented recirculation of the entire waste water generated in quenching of reaction mass, as such the waste water generation is considerably reduced. Water Balance in this regard is attached for reference please.
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.
Reply : Although the quantity of wastewater is very small , however the industry has initiated the process for procurement of OCEMS and the same will be installed within 3 months.
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.
Reply : The industry has deposited adequate CTE/CTO fee as per details given below :
CTE expansion Fee : Rs. 41000/ deposited vide Reference ID: 5059970490 dated 19.07.2021 & Rs. 8200/ vide no. 4599657162098 –INB PPCB on 27.07.2022 along with balance fee under water Act 1974.
CTO fee under Water Act : Rs. 84000/ CTO fee under Water Act vide R.No. 925637066 dated 20.06.2022 and penalty fee amounting to Rs. 8400/ paid vide R. No. 4599657162098 –INB PPCB on 27.07.2022
CTO fee under Air Act : Rs. 84000/ CTO fee under Air Act vide R.No. 492932471 dated 20.06.2022 and penalty fee amounting to Rs. 8400/ paid vide R. No. 4599657162097 –INB PPCB on 27.07.2022
4. The industry has not submitted revised building plans of its unit approved under the Punjab Factory Rules, 1952 by the competent authority.
Reply : The industry has already applied for revised Building Plan to the department of Factories, Punjab separately.
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.
Reply : It is submitted that the industry is facing a lot of problems due to Covid-19 scenario and the sales of the industry has been reduced considerably in last 2 years. However, the industry is committed towards it socio-environmental responsibilities and the balance amount shall be spent in next 2 years.
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.
Reply: The industry has already developed more than 33 % area as per layout plan attached herewith. The same shall be further enhanced wherever feasible.
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.
Reply : It is submitted that the capacity of the boiler is less than 10 TPH which is covered under small boilers as per CPCB guidelines, moreover as per the latest draft amendment for emission standards for boilers published by MoEFCC on 27.06.2022 the OCEMS is required for boilers of more than 10 TPH capacity ( copy attached).
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.
Reply : There are no significant fugitive emissions in the plant. However, emission testing will be done in the next monitoring to be carried out by NABL approved lab shortly.
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.
Reply : The noise levels are being monitored at various places within the plant as well outside the plant from time to time and it has been observed that the incremental values are within the prescribed limits. Monitoring of stack emissions and waste water is carried out by NABL accredited laboratory at regular intervals.
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., PM10 and PM25 in reference to PM emission, and SO2 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.
Reply : The Ambient Air Quality Monitoring shall be got conducted from NABL approved lab within one month.
In view of the above it is requested that varied Consent to Operate may kindly be granted under water Act 1974 & Air Act, 1981.
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