| File Note: |
<p class="MsoNormal" style="text-align: justify;"><span lang="EN-US" style="font-family: 'Tahoma',sans-serif; mso-fareast-font-family: 'Times New Roman'; color: black; mso-themecolor: text1; mso-ansi-language: EN-US;">It is submitted that the undersigned is having additional charge as AEE, HQ-2 and is looking at the work assigned under said charge. Further, it is added that the application was marked to me on 12.01.2023 and at that time, Er. Navtesh Singla, EE, RO, Patiala was on EL and Er. Parveen Saluja, EE took the charge for break period and directed the undersigned to discuss for reply of observations. However, in meantime, Er. Rohit Singla, EE, joined as EE, RO, Patiala on 20.01.2023 and the observations were discussed with him immediately and accordingly, reply was sent on 23.01.2023 and due to which it took 10 days to reply the observations. </span></p>
<p class="MsoNormal" style="text-align: justify;"><span lang="EN-US" style="font-family: 'Tahoma',sans-serif; mso-fareast-font-family: 'Times New Roman'; color: black; mso-themecolor: text1; mso-ansi-language: EN-US;">The industry vide letter dated nil has submitted its reply to the show cause notice issued for refusal of Consent to Operate under Air Act, 1981, which is reproduced as under:</span></p>
<p class="MsoNormal" style="margin-left: .25in; text-align: justify; text-indent: -13.5pt;"><span style="font-family: 'Tahoma',sans-serif; color: black; mso-themecolor: text1;">1. Vide the board policy GPC/Guidelines/RS/SP/F-/2018/290 dated 15/06/2018 which advises the induction furnaces to get their APCD assessed and designed by PSCST is not applicable on us due to the following reasons:-</span></p>
<p class="Style" style="text-align: justify; text-indent: -.25in; mso-list: l1 level1 lfo2; margin: 0in .7pt .0001pt .5in;"><!-- [if !supportLists]--><span lang="EN-US" style="font-size: 11.0pt; font-family: 'Tahoma',sans-serif; mso-fareast-font-family: Tahoma; color: black; mso-themecolor: text1;"><span style="mso-list: Ignore;">(a)<span style="font: 7.0pt 'Times New Roman';"> </span></span></span><!--[endif]--><span lang="EN-US" style="font-size: 11.0pt; font-family: 'Tahoma',sans-serif; color: black; mso-themecolor: text1;">We do not have any induction furnace; we have Zinc Die Casting machines as clearly mentioned in our CTE. Photograph of data plate of the die casting machine installed at our site is attached in the reply submitted.</span></p>
<p class="Style" style="text-align: justify; text-indent: -.25in; mso-list: l1 level1 lfo2; margin: 0in .7pt .0001pt .5in;"><!-- [if !supportLists]--><span lang="EN-US" style="font-size: 11.0pt; font-family: 'Tahoma',sans-serif; mso-fareast-font-family: Tahoma; color: black; mso-themecolor: text1;"><span style="mso-list: Ignore;">(b)<span style="font: 7.0pt 'Times New Roman';"> </span></span></span><!--[endif]--><span lang="EN-US" style="font-size: 11.0pt; font-family: 'Tahoma',sans-serif; color: black; mso-themecolor: text1;">The above mentioned Board’s letter is in spirit of handling MS scrap metal melting industry where the temp ranges between 1500-2000 deg Celsius and capacities of furnace are high. In our industry we only use pure zinc bars as raw material due to strict concerns and maximum temperature reaches 400-450 deg Celsius. </span></p>
<p class="Style" style="text-align: justify; margin: 0in .7pt .0001pt .5in;"><span lang="EN-US" style="font-size: 6.0pt; font-family: 'Tahoma',sans-serif; color: black; mso-themecolor: text1;"> </span></p>
<p class="MsoListParagraph" style="margin-left: 22.5pt; mso-add-space: auto; text-align: justify; text-indent: -.25in; mso-list: l0 level1 lfo1;"><!-- [if !supportLists]--><span lang="EN-US" style="font-family: 'Tahoma',sans-serif; mso-fareast-font-family: Tahoma; color: black; mso-themecolor: text1;"><span style="mso-list: Ignore;">1.<span style="font: 7.0pt 'Times New Roman';"> </span></span></span><!--[endif]--><span lang="EN-US" style="font-family: 'Tahoma',sans-serif; color: black; mso-themecolor: text1;">In spite of the above reasons our industry obtained feasibility report from PSCST in compliance to the conditions laid by PPCB in the CTE. But the feasibility report issued by PSCST is unnecessarily overdesigned and it seems that the APCD factors/parameters generally proposed for MS scrap metal melting industry has been proposed for us in the feasibility provided. This is evident from the fact that a pneumatic pulsejet jet bag cleaning system has been proposed for our bag filter when the flue gas conditions and other related parameter does not require this system. The APCD that was provided to us along with the zinc smelting furnace by our supplier has been provided with mechanical shakers for bag cleaning which is standard practice for our sector of industry. Due to this reason we opted to get our adequacy assessment from M/s Evapo Tech Technical service and consultants who are competent and renowned consultants in the region. Moreover, PPCB officials have themselves physically inspected the APCD during the field visit and have found no inadequacy in it. The industry has requested to withdraw the notice and grant Consent to Operate. </span></p>
<p class="Style" style="margin-right: .7pt; text-align: justify;"><span lang="EN-US" style="font-size: 11.0pt; font-family: 'Tahoma',sans-serif; color: black; mso-themecolor: text1;"> </span><span style="font-family: Tahoma, sans-serif; font-size: 11pt;">From the perusal of reply submitted by the industry, its seems that the industry is not considering itself as induction furnace, which is factually incorrect, as the furnace is electrically operated and thus falls under the definition of induction furnace. The point of industry that it does not use scrap as raw material and charges only raw zinc as raw material and thus not taking the adequacy assessment report from PSCST, Chandigarh can be considered, in light of the office order issued by Board vide no. GPC/guidelines/RS/SP/F/2018/2090 dated 15.06.2018 for getting the design of induction furnace from PSCST, Chandigarh, which has been issued considering scrap as major raw material in induction furnaces. In this case, the industry is not using scrap and has installed bag filter as APCD, which is not pulse jet filter type.</span></p>
<p class="Style" style="margin-right: .7pt; text-align: justify;"><span lang="EN-US" style="font-size: 11.0pt; font-family: 'Tahoma',sans-serif; color: black; mso-themecolor: text1;">In light of above mentioned facts, it maybe decided as policy matter whether the induction furnace using raw metal (non-scrap) as raw material, requires adequacy assessment/completion certificate of its APCD from PSCST, Chandigarh or not. <span style="mso-spacerun: yes;"> </span><span style="mso-spacerun: yes;"> </span><span style="mso-spacerun: yes;"> </span></span></p> |