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Subject: Violations of the provisions of Water Act, 1974, Air Act, 1981 and Hazardous and Other Waste Rules, 2016- M/s Om Steel Rolling Mills, Village Alour, Bhadla Road, Khanna.
It is submitted that the industry is a small scale rolling mill and has applied for renewal of consent to operate under Water Act, 1974 and Air Act, 1981 through OCMMS. The industry has valid authorization under HWM Rules, 2008 valid upto 30.06.2020. As the industry was not submitted reply to the clarification raised by this office, the industry was visited by AEE of this office on 19.08.2019 in the presence of Sh Madhav Jindal, Partner and observed that
1. The industry was in operation during visit.
2. The industry is engaged in manufacturing of Bars Flat @ 75 MTD and ERW Pipe @50MTD.
3. The manufacturing process of the industry is as under:- Raw Material Furnace Loading Heating Melting Pouring in Moulds FlatsWeldingERW Pipe.
4. The industry has not provided sludge drying beds to dry sludge generated from the process.
5. The industry had installed cyclone followed by wet scrubber as APCD.
6. The industry has produced record of energy meter of APCD (completed upto 14.08.2019 and blank thereafter) which was as under:-
Initial reading on 14.08.2019= 4547 kwh
Reading during visit on 19.08.2019= 4602 kwh
Consumption= 4602-4547= 55 kwh
Working days (as informed by the industry)= 3 days
As per above, Average consumption of energy in operation of APCD= 55/3= 18 kwh/day
As per record, average consumption of energy in operation of APCD=
50-70kwh/day
(Copy of the above record is also attached herewith)
From above, it is clear that either the industry is manipulating record or is not operating its APCD on daily basis.
7. The industry has not installed water meter on submersible pump due to which water consumption couldn’t be adjudged.
8. There is no generation of trade effluent, cooling water is being recirculated and domestic effluent is being discharged onto land for plantation after septic tank.
9. The representative of the industry informed that there is no generation of waste water as the lean solution is recycled thoroughly as it contains required chemicals which are utilized for digestion of zinc in the solution.
10. The condition of the hazardous waste storage room was very poor as all the stored hazardous waste (i.e approx 80-100 kg) was found spilled on the floor. No danger sign and data Board was provided outside the hazardous waste room. Roof of the hazardous waste room was found leaked as hazardous waste was found wet due to entry of rain water inside hazardous waste room.
11. Approx. 150-200 kg of Hazardous waste was found spilled/ scattered in the vicinity of wet scrubber in a very bad manner, which shows that the industry is not serious about the management of Hazardous waste.
12. The industry has produced Hazardous waste record (completed upto 05.07.2019) which is as under:
Last lifting of Hazardous waste (05.07.2019)= 1365 kg
Remaining hazardous waste as per record on 05.07.2019= 545 kg
Hazardous waste found stored during visit on 19.08.2019= approx 80-100 kg
Copy of the above record is attached herewith.
In the clarification of above, the representative of the industry informed that approx. 445 kg of Hazardous waste was washed away with rain water.
13. The industry has provided Environmental Data Board on flex which was in a very bad situation.
In view of the above, it is recommended that
1. Consent to operate under Water Act, 1974 and Air Act, 1981 applied by the industry may be refused.
2. Action u/s 5 of EPA, 1986 may be initiated against the industry due to above said serious violation of Hazardous and Other Waste Rules, 2016.
3. Bank Guarantee of suitable amount may be imposed to the industry as an assurance to comply with the pollution control laws.
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