| File Note: |
<p style="text-align: justify;">Submitted for perusal and consideration as above. </p>
<p style="text-align: justify;"><!-- [if !supportLists]-->1. Since my joining as SEE, ZO-2, Ludhiana, i have received number of cases, where the directions have been confirmed for the closure of unit/ disconnection of electricity due to use of HCl acid in place of H2SO4 (for which consents were earlier issued and agreements made with the re-processing facilities). Main reason for the strict action taken against the unit was that the spent HCl acid cannot be reprocessed in the H2SO4 based reprocessing facility as FeSO4 (Ferrous Sulphate) is to be produced from the spent H2SO4. Moreover, the presence of HCl in H2SO4 facility will result in build-up of chloride / TDS in mother liquor and will hamper the functioning of H2SO4 based reprocessing.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->2. <!--[endif]-->After the closure of units, number of industrial units and association approached me. Some of the industrialists claimed that they are not using HCl at all, whereas other submitted that the suppliers are intentionally mixing the HCl in H2SO4 being cheaper in rate and the industries thus were unaware of the fact were using HCl un-intentionally. Some have doubted that presence of both HCl and H2SO4 in same sample cannot be analysed.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->3. <!--[endif]-->To ascertain the ground reality, I had taken up the matter with the laboratory and observed that:-</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->a) <!--[endif]-->Both HCl and H2SO4 are transparent. After mixing of both, there is no change in physical appearance. Hence, it is physically difficult for the officer of the Board, industry or anyone else to recognize whether it is H2SO4 or HCl.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->b) <!--[endif]-->However, there are simple titration method with which it is easy to check the presence of HCl, if mixed with H2SO4. This test can be performed by industrialist in their premises by adding some chemicals in the acid and will take hardly two to three minute. Even, AEEs of the Board can check prima-facia in the field.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->c) <!--[endif]-->Laboratory persons can even perform this test in presence of industrialist in their industries.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->d) <!--[endif]-->The adulation of HCl with H2SO4 or even substitution of H2SO4 with HCl may be done by the industrialist at their own or by the dealers / distributers or suppliers.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->4. <!--[endif]-->Mostly, tiny / small scale units are found involved in such ill-practices due to cost factor involved or due to unawareness or in absence of technical knowhow.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->5. <!--[endif]-->In view of the position explained above and considering the involvement of tiny / small scale units, it is recommended that in such cases:</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->a) <!--[endif]-->Short term consents along with temporary restoration of electric connections (not to disconnect electric connection where connection not disconnected) for six months may be allowed with following conditions:</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->i. <!--[endif]-->Submission of Bank Guarantee of suitable amount as an assurance not to use HCl or pickling or other activities without the permission of the Board. It is proposed that Bank Guarantee for a period of one year from such units may be taken as per following slabs:</p>
<table border="1" width="461" cellspacing="0" cellpadding="0">
<tbody>
<tr>
<td valign="top" width="240">
<p><strong>Plant & machinery</strong></p>
</td>
<td valign="top" width="221">
<p><strong>Bank Guarantee Amount</strong></p>
</td>
</tr>
<tr>
<td valign="top" width="240">
<p><!-- [if !supportLists]-->A) <!--[endif]-->Upto Rs. 25 Lacs</p>
</td>
<td valign="top" width="221">
<p>Rs. 25,000 /-</p>
</td>
</tr>
<tr>
<td valign="top" width="240">
<p><!-- [if !supportLists]-->B) <!--[endif]-->Upto Rs. 1 Cr.</p>
</td>
<td valign="top" width="221">
<p>Rs. 50,000/-</p>
</td>
</tr>
<tr>
<td valign="top" width="240">
<p><!-- [if !supportLists]-->C) <!--[endif]-->More than Rs. 1 Cr.</p>
</td>
<td valign="top" width="221">
<p>Rs. 1,00,000 /-</p>
</td>
</tr>
</tbody>
</table>
<p style="text-align: justify;"><!-- [if !supportLists]-->ii. <!--[endif]-->Obtain training from the Zonal Lab, Ludhiana for in-house checking of adulteration of the HCl in H2SO4 solution or supply of HCl purely by the dealer in the guise of H2SO4. Zonal Lab, Ludhiana shall issue a certificate regarding given a training and literature for facilitating them to check in-house adulteration or presence of HCl in their raw material / spent acid.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->iii. <!--[endif]-->The industry will setup in-house testing arrangement to check the presence / adulteration of HCl in their raw material / spent acid, within one week and inform the Regional Office with photographs through e-mail about the compliance.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->b) <!--[endif]-->Regional Office with Laboratory staff shall surprise check on the spot at least two times. In case, still HCl is being used, place the matter before the Competent Authority for encashment of Bank Guarantee otherwise in case of compliance, matter may be placed for return of Bank Guarantee.</p>
<p style="text-align: justify;"><!-- [if !supportLists]-->c) <!--[endif]-->Regional Office-4 shall organize a training program for such units in association with Zonal Lab, Ludhiana and CICU to assist the concerned industries and aware them about the ill-effects or technical hitches for not allowing spent HCl to be disposed off through H2SO4 reprocessing facility. Literature is also to be circulated to guide the industrialists. Other ROs to extend support the conduct of such training program. As this training will be of 15-20 minute only it could be extended in small groups of 40-50 persons or RO wise on same date.</p>
<p style="text-align: justify;">Submitted for approval, please.</p> |
