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Id:

20890188

Approve:

false

Approve Note:

Clarification:

false

Clarification Note:

Date Created:

2023-01-16 11:11:21.175

File Note:

It is submitted that earlier, the industry was granted consent to operate under the Water Act, 1974 & the Air Act, 1981 vide nos. CTOW/Renewal/FZR/2020/14105885 and CTOA/Renewal/FZR/2020/14105831 dated 24.11.2020 for operation of card board mill for production of Card Board @ 2 TPD by using Waste paper, Waste Jute Bags, Waste Cloth & Rice Straw as raw material, valid upto 30.09.2025 each, subject to the suitable conditions mentioned therein and following special conditions:- 1.    The industry will maintain its re-circulation system so as to ensure that no trade effluent be discharged any time without obtaining the prior permission of the Board. 2.    The industry will not use sludge of pulp and paper mill [i.e. category 32.3 of Schedule-I appended with the Hazardous & Other Wastes (Management & Transboundary Movement) Rules 2016] without obtaining prior permission of the Board.                                     A complaint was received in this office regarding usage of paper sludge by the industry without the permission of the Board. To verify the contents of the complaint, the industry was visited by AEE on 30.03.2022 and it was observed as under:- 1.    The industry was not in operation, however the industry has stored paddy stubble, jute bag alongwith paper industry sludge as raw materials in open. 2.    The re-circulation system installed by the industry was not in working condition as huge quantity of trade effluent was found stagnated. 3.    The industry has not made adequate plantation along its boundary. 4.    The industry discharges its domestic waste water into collection tank and no provision has been made to utilize the same onto land for plantation / irrigation. 5.    The industry is not complying with SOP framed by CPCB for such type of industries.                                     In view of above, the industry has been issued show cause notice before revocation of consent granted under the Water Act, 1974 as well as notice u/s 33-A of the Water Act, 1974 with an opportunity of personal hearing on 28.4.2022.                                     During hearing, Sh. Sukhdev Singh, representative of the industry stated that they are not aware about the fact that paper mill sludge cannot be used without obtaining authorization as well as registration certificate-cum-passbook under the Hazardous & Other Wastes (Management & Transboundary Movement) Rules 2016. He further stated that they are taking paper mill sludge from M/s Khanna Paper Mills, Amritsar and requested to grant some time to comply with the observations of the Board.                                     After considering the material facts on record, the Chief Environmental Engineer (B) of the Board has decided that: a)    The consent granted to the industry under the Water Act, 1974 be revoked. b)   The industry shall not use paper mill sludge without obtaining authorization as well as registration certificate-cum-passbook under the Hazardous & Other Wastes (Management & Transboundary Movement) Rules 2016. c)    The industry shall remove the incompletions pointed out by the Board as well as comply with SOP prescribed by CPCB for such units, within 15 days. d)   Regional Office, Faridkot shall visit the industry immediately after 15 days to verify the compliances made by the industry and thereafter, submit his report / recommendations in the matter, within 7 days. e)    The CEE, Jalandhar be written to initiate action against M/s Khanna Paper Mills, Amritsar as it has sold its paper mill sludge to the industry, which is not authorized to use the same as raw material. f)     During hearing, the representative of the industry was made clear that in case of any violation(s), further action (which may include closure of the industry) shall be taken without giving any further notice / opportunity.                                     The copy of proceedings of the hearing dated 28.4.2022 were conveying to the industry for compliance vide letter no. 2159 dated 06.05.2022. Also, Consent to operate under the Water Act, 1974 revoked vide no. 2286 dated 12.05.2022. A letter issued vide no. 2293 dated 12.05.2022 to CEE (J) requesting to initiate action against M/s Khanna Paper Mills, Amritsar as it has sold its paper mill sludge to the industry, which is not authorized to use the same as raw material.                                    Thereafter, the industry vide its email dated 12.05.2022 has submitted that it is building structure for receiving the raw material and has attached photographs with the letter. Further, the industry has sought one month time for completing the construction of said structure.                                     Now the industry has applied for varied consent to operate under the Water Act, 1974 and the Air Act, 1981 for operation of card board mill for production of Card Board @ 2 TPD by using Waste Paper/ Jute Bags / Clothes / Ride Straws etc. @ 1 TPD and Paper to Paper mill waste Sludge @ 1 TPD, with requisite documents and adequate consent fees. The detail of the case is as under: ·         The industry has submitted a letter in which, it has been informed that we have utilized paper mill ETP sludge as one of the raw materials without complying with the SOP framed by CPCB for such types of industries as well as without obtaining Authorization and registration certificate cum passbook under hazardous and other wastage (Management and Transboundary Movement) rules. 2016. In relation to this, we want to convey that in our cardboard mill, we utilize approximately 60% Paddy Straw waste, 35% ETP sludge (paper to Paper mill) and 5% jute waste in manufacturing our cardboards, and no chemicals are used in the manufacturing process. It is also dried in the sunlight afterward. Our industry falls in Green Category 3009 (Cardboard or corrugated box and paper products (excluding paper or pulp manufacturing and without using boilers). The ETP sludge (paper to paper mill) is bought from Khanna Paper Mills, Amritsar. We would like to mention that M/s Khanna Paper Mills, Amritsar makes paper from the waste paper. As per the CTO under Air act (CTOA/Renewal/ ASR/2022/17883451) and CTO under Water Act (CTOW/Renewal/ASR/2022/17905312) granted to them dated 23.05.2022 valid up to 31.03.2026, their ETP sludge has been considered as the by-product material which doesn’t come under hazardous waste material. They have received Hazardous waste management authorization (HWM/renew/ASR/2021/15816047) on 23.07.2021 valid up to 22.07.2026 for Schedule I 5.1-Used or spent oil @ 10 KL/Annum only, not for the ETP sludge. Even they have received the consent allowing them to dispose off the treated trade effluent into the Hudiara Drain. We would like to inform you that these consents has been renewed (23.05.2022) after the revocation of our consents (dated 12.05.2022). We are unable to understand that, ETP sludge coming out of M/s Khanna Paper Mill, Amritsar (Generator) is being considered as the by-product in their consent and then how come it can be considered as the hazardous waste for our industry (consumer). In reference to this, it is certified toM/s Gujrat Paper Mills Association that paper to paper mill ETP sludge is a non-hazardous waste by Ministry of Environment, Forest, and Climate change (HSM Division), Government of India, New Delhi via letter no. F. No.23/38/2017-HSM Dated 8th August 2017 (copy attached). We would like to mention that certification was given after detailed analysis done by the committee being set up by the government providing the generalized information regarding The AOX in the sludge meet the limit for discharge from paper mills and sludge can therefore be considered as Non Hazardous. After this information, on our behalf from Sophisticated Analytical Instrument Laboratories Society, Thapar Technology Campus, Patiala we got a sampling report dated 25.06.2022, of our paper waste and that report also stated that this paper mill sludge is Non-Hazardous waste (copy attached). For these reasons, this rule does not apply to our industry as this sludge is under non-hazardous waste Moreover, every cardboard industry utilizes 400–500-acre paddy stubble waste and reuses paper mill ETP sludge waste that is very beneficial to the environment rather than harming it. This industry is very eco-friendly and helps in keeping the environment clean by solving Punjab’s Paddy stubble waste problem. So, we humbly request you, that to reconsider this rule and dismiss the Revocation of consent to operate granted under the provision of the water act. Letter No.1286 dated 12/05/2022. We have applied for the varied CTO and request you to please grant us the consents. We shall be really thankful to you. ·         The industry has submitted CA certificate dated 21.12.2022 regarding value of gross fixed assets of the industry of Rs. 23.38 lakhs as on 30.11.2022. The industry has already deposited Rs. 12000/- {Rs. 11000/- each vide UTR No.AXSK202740014682 & AXSK202740015869 dated 30.09.2020 and Rs. 1000/- each vide R.No. 95/5109 & 96/5109 dated 30.10.2020} as consent to operate fee under the Water Act, 1974 and Air Act, 1981. The adequacy of the consent to operate fee was upto 30.09.2025 under Orange category. Now, the industry has also deposited Rs. 6250/- vide Receipt No. 177761698 dated 06.01.2023 as consent to operate fee under the Water Act, 1974 and Air Act, 1981, which is adequate for a period upto 31.12.2027 under the Water Act, 1974 and Air Act, 1981, under green category, respectively, including the penalty of 50% of one year fee under the Water Act, 1974. ·         The industry was visited by the AEE of this office on 11.01.2023 and it was observed that: 1.    The industry was not in operation at time of visit as per its requirement. However, raw material i.e paddy straw, waste jute bags were found stored at site.  The industry has stored sludge (paper industry) at site. The representative of the industry showed the builties of sludge from Khanna Paper Mill. The industry has provided shed with roof of size 25’ x 12’ for storage of ETP sludge. 2.    The industry has installed waste water treatment facility consisting of dust settling tank, fiber settling tank, storage tank 02 no. and sludge drying beds. The industry has made provision to re-circulate the entire treated trade effluent back into the process. The treatment facility installed by the industry was in line/operational condition. No bye-pass was observed at site. 3.    The industry has installed septic tank for treatment of its domestic effluent. The industry has made plantation to contain effluent after septic tank. 4.    The industry has planted new plants in addition to already made plantation along the boundary. 5.    The industry has complied with the provisions of the Water Act, 1974 and Air Act, 1981. 6.    As per the record of Khanna Paper Mill submitted by the industry, the sludge of the industry is non-hazardous. The industry has produced builties of Khanna Paper Mill.                                     Keeping in view of the above, it is recommended that varied consents to operate under the Water Act, 1974 & Air Act, 1981 may be granted to the industry for the production of Card Board @ 2 TPD by using Waste Paper/ Jute Bags / Clothes / Ride Straws etc. @ 1 TPD and Paper to Paper mill waste Sludge @ 1 TPD, for a period upto 31.12.2027, under green category, subject to the suitable conditions alongwith additional condition that The industry will maintain the record of paper industry sludge procured and submit the same on monthly basis to the Board, please.

Inspection:

false

Inspection Note:

Officer:

PPCB139

Reject:

false

Reject Note:

Role:

RO AEE Aushpreet Singh