| File Note: |
It is intimated that the industry was granted consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/SAS/2023/23777031 dated 01/12/2023 and under Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/SAS/2023/23772629 dated 01/12/2023, both having validity upto 31/01/2024 for production of Menthol Crystals @16.6T/day, Menthol Flakes @ 6.6T/day, Menthol liquid/powder @16.6T/day, Cefixime Trihydrate @1.786T/day, Cefuroxime Axetil (Amorphous) @1.65 T/day, Cefpodoxime Proxetil (Coated) @0.007 T/day, Cefpodoxime Proxetil @0.01T/day, Cefditoren Pivoxil @0.0035T/day, Cefdinir @0.05T/day, Ceftriaxone Sodium @0.84T/day, Cefotaxime Sodium @0.4T/day, Cefepime Injection @0.0577T/day, Cefuroxime sodium @0.02723T/day, Cephalothin Sodium @0.05T/day, Cefazolin Sodium @0.00321T/day, Cefprozil @0.0005T/day, Cefoxitin Sodium @0.001T/day, Ceftiofur @0.00003T/da,y Ceftaroline @0.00002T/day, Metformin HCL @0.07T/day, Cefcapine Pivoxil @0.00002T/day, Sodium Carbonate @0.002T/day, L-Arginine @0.002T/day, Ceftazime Pentahydrate @0.015T/day, Ceftibutene Hydrate @0.02T/day and Cefotium HCL @0.015T/day with certain conditions mention therein.
Details of compliance status of previous hearings/directions:
A. Compliance of decisions of hearing held on 01.09.2023:
Earlier, the industry was issued notice for 33-A of the under the Water (Prevention & Control of Pollution) Act, 1974 and 31-A of the Air (Prevention & Control of Pollution) Act, 1981, along with an opportunity of personal hearing before the Hon’ble Chairman of the Board on 01.09.2023 in the said hearing, it was decided as under:
1. Environmental Engineer, Punjab Pollution Control Board, Regional Office, SAS Nagar shall immediately encash bank guarantee amounting to Rs. 10.0 lakhs which is already deposited with the Board by the industry as an assurance and send the report thereafter.
2. The industry shall submit a new bank guarantee amounting to Rs. 10.0 lakhs as an assurance to comply environmental laws all the times.
3. The industry shall get the re-verification of premises from Director of Factories, Punjab and shall submit certificate to the effect that measures provided by the industry are adequate and all safety measure are in place to avoid such incident in future within one month.
4. The industry shall get safety audit of its premises from institute of repute and shall submit the report within one month.
5. The industry shall provide additional precautionary measures such as handheld gas analyzers and highly sensitive gas sensors on overall boundary wall of the unit with siren system.
6. Environmental Engineer, Punjab Pollution Control Board, Regional Office, SAS Nagar shall visit the industry in the last week of September, 2023 to verify the contention of the industry w.r.t various compliance made by it and carry out complete monitoring of ETP , APCDs & groundwater and thereafter to send the consolidates report alongwith concrete recommendations so as to enable the competent authority to proceed further in the matter.
As per decision no. 01 of the hearing held on 01.09.2023, this office had encashed Bank Guarantee amounting to Rs. 10 lakhs of the industry vide Receipt No. 10/5502 dated 28.09.2023.
Further, as per decision no. 02 from the hearing held on 01.09.2023, the industry had submitted a Bank Guarantee amounting to Rs. 10 lakhs vide bearing no. 42070ILG001623 dated 09.10.2023, having validity upto 08.10.2025.
The point wise compliance of the decision of the hearing 01.09.2023 is attached in the agenda note.
From above, it is clear that the industry has not yet fully complied with the decisions of the hearing held on 01.09.2023 under the stipulated time period given by the Competent authority.
B. Compliance of decisions of the hearing held on 17.11.2023:
Sr. no. Decisions Compliance status
1. The renewal of ‘consent to operate’ applied by the industry under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 be granted to the industry for a short period i.e. upto 31.01.2024.
The industry was granted ‘consent to operate’ under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 upto 31.01.2024 and has now applied for obtaining renewal of the same
2. The industry shall submit bank guarantee amounting to Rs. 25 lakhs within 7 days as assurance to comply with the pollution control laws to the o/o Environmental Engineer, Punjab Pollution Control Board, Regional Office, SAS Nagar.
The industry had deposited bank guarantee amounting to Rs. 25 lakhs bearing no. 42070ILG002023 dated 11.12.2023, which is valid upto 11.12.2024.
3. Environmental Engineer, Punjab Pollution Control Board, Regional Office, SAS Nagar shall encash the bank guarantee amounting to Rs. 15 lakhs earlier deposited by the industry immediately and thereafter send the report to the Competent Authority.
As per decision no. 03 of the hearing held on 17.11.2023, PPCB has encashed Bank Guarantees amounting to Rs. 15 lakhs of the industry vide Receipt No. 30/5503 & 31/5503 dated 12.12.2023
4. A committee headed by Sh. Paramjit Singh, SEE, Zonal Office-1, Ludhiana, Mrs. Anuradha Sharma, Environmental Engineer, Regional Office, Roopnagar, Sh. Mohit Singla, AEE, Regional office, Patiala alongwith Dr. Anoop Verma, Professor, Thappar Institute of Engineering and Technology (TIET), Patiala, as Technical Expert shall visit the industry and submit technical report w.r.t. water auditing, groundwater study in and around the industry, adequacy of ETP/MEE, complete material balance including generating of sludge and study as to whether unit is based on ZLD Technology or not, within 20 days with concrete recommendations. The committee has submitted its report to the Board, which is attached herewith as Annexure-A. Further, the industry has engaged TIET and TIET, Patiala is yet to submit its final report to the Board.
5. A separate letter shall be written to Dr. Anoop Verma, Professor, School of Energy and Environment, TIET, Patiala to carry out water auditing, groundwater study in and around the industry, adequacy of ETP/MEE, complete material balance including generation of sludge and study as to whether unit is based on ZLD Technology or not of the industry on its request.
Same as point no. 04 above.
6. The expanses which will incurred to conduct the study by TIET, Patiala shall be bear by the industry. Also, the industry shall approach the TIET, Patiala immediately to get the study conducted.
Same as above.
C. Compliance of directions issued u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 to the industry vide letter no. 9954 dated 04.01.2024:
PPCB vide letter no. 9954 dated 04.01.2024 has issued following directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 to the industry.
A. The industry shall reduce the production capacity of the unit by 25%, till the time final environment audit report is received from TIET, Patiala.
B. The industry shall not discharge any quantity of treated/ untreated trade effluent outside its premises or plantation purpose, under any circumstance.
C. The industry shall obtain revised Consent to Operate under the Water Act, 1974 and Air Act, 1981, for reduced production capacity.
In this regard, the industry has now applied for obtaining ‘consent to operate’ under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 for 75% of the following production capacity, along with requisite documents:
Sr. no. Name of the Product produced/to be produced Quantity of Products produced/to be produced.
Installed Production
Capacity Average Actual production for which the consent is now sought (i.e. 75%)
1. Menthol Crystals T/day 16.6 12.45
2. Menthol
Flakes T/day 6.6 4.95
3. Menthol liquid/powder T/day 16.6 12.45
4. Cefixime Trihydrate T/day 1.786 1.3395
5. Cefuroxime Axetil (Amorphous) T/day 1.65 1.2375
6. Cefpodoxime Proxetil (Coated) T/day 0.007 0.00525
7. Cefpodoxime Proxetil T/day 0.01 0.0075
8. Cefditoren Pivoxil T/day 0.0035 0.002625
9. Cefdinir T/day 0.05 0.0375
10. Ceftriaxone Sodium T/day 0.84 0.63
11. Cefotaxime Sodium T/day 0.4 0.3
12. Cefuroxime sodium T/day 0.02723 0.0204225
13. Cephalothin Sodium T/day 0.05 0.0375
14. Cefazolin Sodium T/day 0.00321 0.0024075
15. Cefprozil T/day 0.0005 0.000375
16. Cefoxitin Sodium T/day 0.001 0.00075
17. Ceftiofur T/day 0.00003 0.0000225
18. Ceftaroline T/day 0.00002 0.000015
19. Metformin HCL T/day 0.07 0.0525
20. Cefcapine Pivoxil T/day 0.00002 0.000015
21. Sodium Carbonate T/day 0.002 0.0015
22. L-Arginine T/day 0.002 0.0015
23. Ceftazime Pentahydrate T/day 0.015 0.01125
24. Ceftibutene Hydrate T/day 0.02 0.015
25. Cefotium HCL T/day 0.015 0.01125
26. Cefepime Injection T/day 0.0577 0.043275
Fee details:
As per the record file of this office, the fee already deposited by the industry previous application is already adequate upto 31.12.2024. The industry has not submitted any additional fee with the present online application.
Details of Bank Guarantees
As per the record file of this office, the industry has following bank guarantees in the custody of this office:
1. The industry has submitted a bank guarantee amounting to Rs. 25 lakhs bearing no. 42070ILG002023 dated 11.12.2023, which is valid upto 11.12.2024.
Details of NGT matter in O.A. no. 173/2023 titled as Shalbhjit Singh v/s State of Punjab:
It is submitted that the subject cited matter- O.A no. 173/2023 titled as Shalbhjit Singh v/s State of Punjab is pending in the Honble National Green tribunal. The said matter is related to the industry M/s Nectar Lifesciences Unit-II, Saidpura, Derabassi.
The said matter was lastly listed on 05.01.2024 on the said date, PPCB had submitted written reply, a copy of which is attached herewith as Annexure-A.
In the hearing held on 05.01.2024, Hon’ble NGT has passed following orders:
“Learned Counsel appearing for the PPCB has submitted that sample analysis report of the samples taken from the unit is awaited. Therefore, a fresh report after obtaining sample analysis report will be filed. The PPCB is also directed to carryout water audit and submit the water audit report as also the water flow chart of the unit is question and also point out the sample analysis report of discharge of water from the unit by whatever source. The report will also disclose the manner of disposal of sludge by the report by filed within a period of six weeks by e-mail of judicial-ngt@gov.in preferably in the form of searchable PDF/OCR Support PDF and not in the form of Image PDF.”
The matter is now listed of hearing on 05.03.2024.
Details of previous visit and violation:
It is worth to mention here that earlier a telephonically complaint was received against the industry regarding problem related to fly ash being faced by residents of village Haripur Hinduan, Derabassi. Accordingly, the site of the industry was visited and report was sent to Zonal Office-1, Patiala vide e-noting no. 24668885. Thereafter, the industry was issued advisory notice vide letter no. 10397 dated 22.01.2024.
Visit:
The site of the industry was visited by AEE of this office alongwith ASO Patiala of the Board on 02.02.2024 and it was observed as under:
1. The industry Nectar Lifesciences, Unit-II which is a bulk drugs manufacturing unit was in operation. The industry is also having its sister concern company involved in manufacturing of bulk drugs located in Village Haripur Hinduan namely Nectar Lifesciences, Unit-I and the effluent generated from this company is also treated along with its own effluent. The effluent of unit no.1 is being carried through underground pipeline to unit no. II for treatment.
2. The industry has installed 02 no. boiler of capacity 40 TPH each, both of which are provided with separate ESPs as APCD. during visit, it was observed that only one of the boiler of capacity 40 TPH was in operation and the second boiler of capacity 40 TPH was under maintenance. The industry is using rice husk and chopped wood as fuel in the boiler. The representative informed that on an average 50-60 tonnes of ash is produced per day. The industry has installed one no. ash storage silo of capacity 50 tonnes with 02 no. boiler of capacity 40 TPH each. During visit, stack emission sampling was carried out on 02.02.2024 and the analysis results as obtained from Head office Lab, Patiala is tabulated as under
Point of Sample Collection Parameters Results
Prescribed Standards
From port hole on stack after APCD (Boiler Furnace 40 TPH/Boiler-2) Particulate Matter (mg/Nm3 at 12% CO2) 142 150
3.
From above, it is clear that the industry is now complying with the prescribed standards.
4. The industry has also installed another boiler of capacity 25 TPH, which was found to be in operation during the visit. The industry has installed bag filter house as APCD with the said boiler. However, the industry has not provided adequate stack height with the said boiler. Further, any sampling platform was also not found to be provided with the said stack. As such, stack emission sampling could not be carried out by the visiting team. It is also worth to mention here that the industry has not installed online SPM meter with stack of the said boiler.
5. The industry has installed incinerator for incineration of hazardous waste being generated from the unit. However, the said incinerator was not in operation during the visit.
6. The industry has installed 03 no. SRPs in its premises. The industry has installed only VOC meter with the SRP and no TOC meter have been installed, yet.
7. The industry has installed 03 no. DG set of capacity 1250 KVA x 2 no. and 750 KVA x 1 no. with canopy and adequate stack height.
8. During visit, it was observed that Dr. Anoop Verma, Professor, TIET, Patiala was also present at the site alongwith his team and was carrying out ETP sampling, groundwater monitoring, piezometer monitoring etc.
9. There are 02 no. of old separate holding tanks for storage of HTDS and LTDS being transported from unit. During visit, it was observed that the industry has now stopped taking effluent into these tanks and is directly transporting effluent into ETP and MEE. Further, the amount of effluent earlier stored in these tanks was also found to be significantly reduced.
10. The industry has installed 02 no. tubewells for abstraction of ground water in its premises. As per the record maintained by the industry, the detail of abstraction of ground water is as under:-
Tubewell Average values of groundwater extraction in KLD
December 2023 January 2024
Tubewell 1 & 2 979KLD 994.4 KLD
11. For treatment of HTDS of unit 1 & 2, the industry has installed 02 MEEs of capacity 350 KLD & 90 KLD.
12. The industry has installed ATFD for thickening of MEE concentrate and MEE condensate is being sent to ETP for treatment along with LTDS of unit 1 & 2.
13. The industry has installed ETP based on physic-chemical treatment followed by biological treatment for treatment of LTDS being generated from unit 1, unit 2 & MEE condensate. As per record maintained by the industry, the details of quantity of LTDS being treated in the ETP is as under:-
Effluent Detail Average values of effluent in KLD
December 2023 January 2024
LTDS at ETP inlet 1090 KLD 1130 KLD
14. The industry is reusing treated effluent for cooling tower makeup as well as plantation purpose within its premises. As per record maintained by the industry, the details of quantity of RO permeate being used for cooling tower makeup & for plantation within the premises is as under:-
RO Detail Average values of effluent in KLD
December 2023 January 2024
RO Permeate (cooling tower) 665 KLD 667 KLD
RO permeate (plantation) 29.8 KLD 28.3 KLD
15. The industry has developed plantation area as per Karnal Technology near Admin Building in an area of around 4 acres. Besides the plantation area developed as per Karnal Technology, the industry has also developed green area as lawns inside the premises of the industry. The industry is using treated wastewater for plantation purpose in the said area.
16. There is a drain passing adjoining to the backside of the industry. During visit, storm water outlet of the industrial unit was found plugged and no effluent was being discharged into the said drain by the industry.
17. No illegal discharge of effluent by the industry into any agricultural fields was observed during the visit.
18. The industry has installed CCTV camera near the main garland storm water drain near MEE area. During last visit, the industry was asked to install CCTV at 02 more location, immediately:-
a) Near final outfall of storm water drain of the industry into natural choe.
b) Near subsidiary storm water drain of the industry near the plantation area.
However, the industry has not installed the same yet.
From above, it is clear that the industry is not completely complying with the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981. Further, the industry has also not completely complied with the decisions of hearing held on 01.09.2023.
Recommendations:
In view of above, if approved, the industry may be issued show cause notice for refusal of ‘consent to operate’ under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981, along with an opportunity of personal hearing before the Competent Authority.
Competency- Hon’ble Chairman (Large, Red)
Date of receipt of case- 14.02.2024
Target date of deemed approval- 28.03.2024 (i.e. 30 working days)
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