| File Note: |
It is submitted that the industry has applied for obtaining Consent to Establish (NOC) under the Water (Prevention & control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 for manufacturing of Thinners @ 5 KLD, Recovery Solvent after Distillation of spent solvents by using Solvents @ 5 KLD, Spent Solvents @ 20 KLD with requisite documents and fee.
NOC fee
The industry has deposited Rs. 11,300/- vide R. No. 823736761 dated 23.02.2024 including application form fee. The NOC fee deposited by the industry is adequate for one year, against the proposed cost of the project of Rs. 260.00 lacs.
Manufacturing process
Raw materialDistillationProduct
Land document
The industry has submitted the lease deed made on dated 08.02.2024 between Smt. Suman Kaur (First Party) and M/s Rasaynic Labs Pvt. Ltd. for area of land 3.0 Bigha 15 Biswa which is valid till 04.02.2039.
Suitability of site
The industry has submitted land classification certificate issued by DTP vide no. 165 dated 15.02.2024, as per which the site falls in industrial zone as per Master Plan Lalru.
Further, during site visit it was observed that there is no residential area, village phirni/lallakir within the 100 mtr boundary wall of the project.
It is pertinent to mention here that the CPCB has issued Standard Operating Procedure for units engaged in recovery of spent solvent in August, 2019 and the Para 8.0 of the said SOP relating to the siting criteria for such industries is reproduced as under:
“Facilities for utilization of Spent Solvent shall be located in a notified industrial area or industrial park/ estate/ cluster and in accordance with Consent to Establish issued by the concerned SPCB/ PCC.”
As such, the site of the industry is suitable for establishment of the unit.
Applicability of EIA notification dated 14/9/2006/ Press Note 17 (1984 series)
The spent solvents are highly flammable liquids as such, the industry might be covered under the First Schedule of Factories Act, 1948 and required to obtain site clearance under the said Act. It is mentioned here that Govt. of Punjab, Deptt. of labour vide letter no 7319-45 dated 27.08.2013 has exempted the industries from obtaining the site clearance which are to be established in the designated/ approved area. Since the industry is to be established in the industry zone, as such, the industry is not required to obtain said clearance under the Factories Act, 1948. Further, the Press Note 17 (1984 series) has been discarded by the Ministry of Commerce & Industry, Govt. of India through Press Note 3 (2019 series) dated 11/09/2019. As such, the industry is not required to obtain permission under the Press Note 17 (1984 series).
Regarding applicability of the EIA Notification dated 14/09/2006, it is added here that as per EIA Notification dated 14/09/2006, the synthetic organic chemicals manufacturing units are covered under category 5 (f) of the said notification. Since, this industry is to carry out only distillation of spent solvent and to manufacture thinners by way of mixing of recovered solvents as such no chemical synthesis process is involved in the manufacturing activity of the industry, therefore, the industry does not attract the provision of the EIA Notification dated 14/09/2006.
Water Pollution
The industry will generate trade effluent @ 3.0 KLD i.e. waste water to be generated from washing of reactors, floor cleaning etc., which will be evaporated in the electric evaporator. The condensate will be reused in the cooling tower and the concentrate sludge will be disposed off to TSDF Nimbua.
The Domestic effluent generation @ 0.8 KLD will be treated in onto land for plantation after passing through septic tank.
Air Pollution
The industry has proposed to install one boiler of capacity 2.0 TPH in which wood will be used as fuel and water scrubber will be provided as APCD alongwith stack of adequate height.
The industry has proposed to install one no. D.G set of capacity 66 KVA, which will be equipped with canopy and adequate stack height.
Visit
The site of the industry was visited by AEE of this office on 02.03.2024 and during visit, it was observed that:
1. The site is located in Village Jhawansa, Derabassi, SAS Nagar.
2. The industry has started the civil construction work of boundary wall.
3. The industry has not installed any plant and machinery, which is proposed to be installed.
Recommendations
Keeping in view of the above, it is recommended that Consent to Establish (NOC) under the Water (Prevention & control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 may be granted for one year subject to suitable conditions and additional conditions that:
1. The NOC/CTE has been granted on the basis of undertaking submitted by the industry i.e. falls in industrial zone and it is the entire responsibility of the industry to submit the site suitability at the time of the consent to operate. The industry will be responsible for any financial loss if the above undertaking is found to be wrong at any later stage.
2. The industry shall not operate its unit till it obtains valid “consent to operate‟ under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 and authorization under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
3. The industry shall not procure its raw material i.e. spent solvents, till it obtains 'Actual User Certificate' issued under Rule 9 of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
4. The industry shall comply with the SOP (standard operating procedure) for recovery of spent solvent issued by the CPCB in Aug-2019, in true letter & spirit.
5. The industry shall submit the approved building plan under the Factories Rule, 1952 from the competent authority or the authorized person of the Department of Labours.
6. The industry shall install the cyclone separator with the wood fired boiler of capacity 2 TPH as per the proposal submitted by it and the adequacy & efficacy of the wet scrubber shall be the entire responsibility of the industry.
7. The industry shall maintain the record of fresh water consumption.
8. The industry shall re-circulate the entire water of the cooling tower.
9. The industry shall discharge only domestic effluent onto land for plantation within premises after passing through the septic tank as proposed by it.
10. The industry shall not discharge any effluent at any time or any other unauthorized place by any unauthorized means.
11. The industry shall not consume any fuel for burning purpose except wood for boiler of capacity 2 TPH, without the prior written permission of the Board.
12. The industry shall comply with the guidelines issued by the PWRDA from time to time.
13. The industry has been approved by the Board from pollution angle and the industry shall obtain the statutory clearances / permissions from all other concerned departments.
14. The industry shall ensure the compliance of provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981, Environment (Protection) Act, 1986 and/or any other environmental law applicable to him and Rules, Circulars & Directions issued by the Board from time to time.
15. In case the project proponent fails to comply with the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981, Environment (Protection) Act, 1986 and/or any other environmental law applicable to the project and Rules, Circulars & Directions issued by the Board from time to time, action as deemed fit shall be taken against the project proponent.
Competency: Senior Environmental Engineer
Date of Receipt : 23.02.2024
Date of Scrutiny : 03.03.2024
Date of Deemed Approval: 19.03.2024 |