| File Note: |
It is submitted that the HCF was granted consent to operate under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/PTA/2020/13191736 dated 22/08/2020 and under the Air (Prevention & Control of Pollution) Act 1981 vide no. CTOA/Varied/PTA/2019/9554528 dated 29/04/2019, both valid up to 31/03/2024, for 100 Bedded Hospital subject to conditions mentioned therein.
As per the record file, show cause notice for revocation / cancellation of authorization granted under the Bio Medical Waste Management Rules, 2016 vide Board's letter no. 3148 dated 11.06.2021 alongwith opportunity of personal hearing before the SEE, ZO-1 on 29.06.2021. After hearing, it was decided that:
1. A copy of the reply submitted by the hospital during the hearing may be sent to Environmental Engineer, Regional Office, Patiala for his information.
2. The Environmental Engineer, Punjab Pollution Control Board, Regional Office, Patiala shall visit the hospital, verify the contentions made by it during the hearing and send the report / recommendations, thereafter, within 15 days.
3. It was made clear to the representative of hospital that if it was found violating under the provisions of Environmental Rules / Laws in future, then, action under the said Rules / Laws will be taken against the hospital, without giving any further notice / opportunity.
4. Further action in the matter will be taken after receipt of report from Environmental Engineer, Punjab Pollution Control Board, Regional Office, Patiala.
The proceedings were conveyed to the hospital vide ZO-1, Patiala letter no. 3554-55 dated 30.06.2021.
To verify the compliance of the decisions of personal hearing. The hospital was visited by the EE & AEE of this office on 12.05.2023 and Sh. Lucky Dhiman /Manager was present at the time of visit. During visit, it was observed as under:
1. The HCF was in operation.
2. The bio-medical waste bags were found in torn condition in the storage room.
3. The bio-medical waste was also found littered in the storage room.
4. No bar code was there on the bio-medical waste bags and glucose bottles were also found without cutting into torn red bags.
5. The hospital is not cutting plastic/glucose bottles stored in storage room.
6. The inlet tank of OT/Lab/IVF was found mixed with Bio Medical Waste.
7. The ETP/STP sludge was stored in an open area needs to be scientifically disposed off.
8. Plantation area where discharge of outlet of ETP/STP was very near to rain water harvesting drain. There are chances when rain comes, it might discharge into rain water drain, which ultimately leads to rainwater harvesting.
9. The STP clarifier was found stagnated needs to be cleaned.
10. The HCF is maintaining record of Bio Medical Waste Management Rules, 2016. However, as per the Bio Medical Waste Management Rules, 2016 authorization they are generating higher bio medical waste.
11. There is no water meter installed at the inlet & the outlet of the ETP and no water meter at the inlet of STP. The HCF also needs to install energy meter at the ETP cum STP and submit the record in this office.
12. The sample collected at the inlet of STP & outlet of STP and outlet of ETP is as under:
Sr. No. Parameters Inlet of STP Outlet of STP Outlet of ETP Prescribed Standards
1 pH 6.9 7.4 7.2 6.5-9.0
2 TSS mg/l 117 23 121 100
3 COD mg/l 282 78 220 250
4 BOD mg/l 125 17 85 30
5 O&G mg/l 7.0 BDL BDL 10
6 Bio-Assay Zero% survival of fish in 100% of effluent after 96 hours 90 % survival of fish in 100% of effluent after 96 hours
Furthermore, the hospital was issued show cause notice for revocation of consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and cancellation of the authorization granted under the Bio-Medical Waste Management Rules, 2016 as well as Notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 vide Board's letter no. 4313 dated 21.06.2021 alongwith opportunity of personal hearing before the CEE(P) of the Board on 28.06.2023. After hearing, it was decided that:
1. The hospital shall submit Bank Guarantee amounting to Rs. 2.0 Lacs in favour of Environmental Engineer, Punjab Pollution Control Board, Patiala as an assurance to comply with the provisions of Water (Prevention & Control of Pollution) Act, 1974 and Bio-Medical waste Management Rules, 2016 within 7 days.
2. Environmental Engineer, Regional Office, Patiala shall revisit the hospital to verify the compliance of the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and Bio-Medical waste Management Rules, 2016, in case the hospital was again found violating the provisions of the said Acts, the bank guarantee submitted by the hospital shall be en-cashed without any further opportunity of personal hearing.
The proceedings were conveyed to the hospital vide Board's letter no. 4864-65 dated 13.07.2023.
In compliance to the decision No.1 of the above said was hearing, the HCF had deposited a bank guarantee of Rs. 2.0 lacs, bearing no. 08531ILG000623 dated 29/07/2023, which is valid upto 28/10/2024.
Thereafter, a complaint was received from the office of Executive Engineer, Drainage cum Mining & Geology Division, Patiala vide its letter no. 7263-65 dated 06/11/2023 regarding illegal discharge of polluted water in SYL River by M/s Neelam Hospital.
Therefore, to check the compliances of the said personal hearing and to verify the contentions of the said complaint, the site of the HCF was visited by AEE & JEE of this office on 04.12.2023. During visit, JEE of Drainage cum Mining & Geology Department and Sh. Sandeep Watts (General Manager, Operations) of the HCF were contacted at site and was observed as under:
1. The establishment is a 100 bedded super specialty hospital and was found in operation.
2. The establishment has provided 2 no. tube wells for abstraction of ground water, out of which only one is operational with water meter installed.
3. The total fresh water used from 01-11-2023 to 30-11-2023 is 3338 KL, as per record.
4. The establishment has provided a STP plant of capacity 150 KLD for treatment of wastewater generated from hospital premises, hostel & kitchen area, which was found in operation.
5. During visit, sludge was found in clarifier level of weir was not leveled, as such, the wastewater in the said clarifier was not being distributed uniformly.
6. In the dosing section, chemical was found lying at base of the tank and hence proper dosing was not being imparted. The HCF was advised to provide a stirrer in the dosing tank.
7. The establishment has provided water meter on final line of treated water, leading to plantation area, which was noted as 7445076.4 m3.
8. As per record maintained, 2410 KL of wastewater is treated in period of 01.11.2023 to 30.11.2023.
9. The establishment has not provided sludge drying beds after sludge drying press and some sludge is found stored in open area. The representative was advised to provide proper sludge drying beds and storage room. Also, its disposal is also to be recorded.
10. The establishment is discharging its treated effluent onto land for stagnation in the area near its boundary wall. The representative of the HCF informed that their plantation area was destroyed in recent floods. Hence, no proper plantation is available with the HCF as per Karnal Technology.
11. During visit, some of the water lying stagnated in the plantation area along the boundary wall of the HCF was found seeping into adjacent drain, which ultimately leads to SYL River.
12. Water/ effluent samples were collected from inlet, outlet & aeration tanks of STP & from drain along the wall of HCF.
13. Some of plastic bottles in red colored bio-medical waste collection bins were found un-cut. The HCF was advised to provide proper training of workers.
14. No BMW was found in final storage room, as same was lifted few minutes before the visit, as per manifest.
15. Needle shredder in some wards/ OT was found out of order & needles were found un-cut in storage bins.
16. The HCF has not maintained record regarding disposal of waste food and oil & grease from kitchen area.
The hospital has again issued show cause notice for revocation of the consent to operate granted under the Water (Prevention & Control of Pollution) Act, 1974, notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as amended in 1988 & notice to issue before encashment of the BG amounting to Rs 2 lac submitted by the hospital for assurance to comply with the environmental norms alongwith the opportunity to personal hearing before the Chief Environmental Engineer (P) of the Board on 22/01/2024 issued vide Board's letter no. 10156 dated 12/01/2024. After hearing, it was decided that:
1. Environmental Engineer, Regional Office, Patiala shall en-cash amount of Rs. 1.0 lac from the bank guarantee amounting to Rs. 2.0 lacs of the hospital lying with the Board, within 07 days. In lieu of this, the hospital shall submit fresh bank guarantee of Rs. 2.0 lac as an assurance to comply with the environmental laws in future.
2. The hospital shall appoint qualified Environment Engineer to operate / maintain its ETP & STP within one month.
3. The hospital shall upgrade its STP and submit the adequacy report from the Chartered Engineer to the Board, within one month.
4. The hospital shall get its monitoring of the ETP well before mixing the treated water in STP to check the efficiency of the ETP installed by the hospital and submit the report within 15 days.
5. The hospital shall develop adequate plantation area for disposal of its treated wastewater within 15 days and ensure that no wastewater is being discharged into any drain / choe / nallah at any circumstance.
6. The hospital shall construct properly designed sludge drying beds alongwith the ETP within 15 days and the dried sludge shall be stored in separate hazardous waste storage room.
7. The hospital shall ensure that the plastic bottles be properly cut before sending it to Common Bio Waste Treatment Facility (CBWTF) and needles cutter shall be operated regularly and to comply with the BMW Rules, 2016 in toto.
8. The hospital shall apply to obtain authorization under Hazardous & Other Wastes (Management & Tranboundary Movement) Rules, 2016, within 07 days.
9. It was made clear to the hospital, in case the hospital is again found discharging its wastewater through any unauthorized mode, strict action shall be taken against the hospital including imposition of Environmental Compensation.
10. Environmental Engineer, Regional Office, Patiala shall visit the hospital, verify the decisions of the personal hearing, collect samples and submit its report, within 01 month.
The proceedings were conveyed to the hospital vide Board's letter no. 12179 dated 20.02.2024.
In compliance of decision no. 1, the Senior Manager, PNB Bank, Chandigarh Road, Rajpura, Distt. Patiala was requested vide this office letter no. 505 dated 23.02.2024 to make a demand draft amounting to Rs. 1.0 lakh from the bank guarantee submitted by the HCF of Rs. 2.0 lakh bearing no. 08531ILG000623 dated 29.07.2023, valid upto 28.10.2024. However, the amount is yet to be encashed and the matter is being taken up with the bank.
Further, the HCF has submitted a new bank guarantee amounting to Rs. 2.0 lakh bearing no. 08531ILG000424 dated 29.02.2024, valid upto 28.05.2025 in lieu of the above said bank guarantee.
Moreover, the HCF has also submitted adequacy certificate regarding its ETP-cum-STP chartered engineer of the Board.
Now, the hospital has applied for varied of consent to operate under the Water (Prevention & Control of Pollution) Act 1974 & the Air (Prevention & Control of Pollution) Act 1981 for 150 bedded capacity and has deposited amounting to Rs. 10000/- Vide online recipe no. 994544889 dated 22.01.2024 as water consent fee and Rs. 10000/- vide online receipt no. 180599724 dated 22.01.2024 for 150 bedded capacity, which is adequate upto 31.03.2025.
The hospital was visited AEE of this office on 26.03.2024. During visit, it was observed as under:
1. The HCF was in operation and has provided 150 beds.
2. The hospital has provided colour coded bins for collection of bio-medical waste at different locations i.e. dialysis section, emergency ward, general ward, operation theatres etc. and segregating its bio medical waste as per BMW Rules, 2016.
3. The hospital has provided shredders/ cutters for shredding of used needles and same were found in working condition.
4. Bar code stickers were pasted on the BMW bags, were used before lifting them off to the CBMWTF.
5. The hospital has stored glass (broken / unbroken) in a cardboard box with blue color marking on it.
6. The hospital has provided Final storage room for storage of bio medical waste, which is safe, pucca and with lock & key arrangement systems.
7. The establishment has provided 2 no. tube wells for abstraction of ground water, out of which only one is operational with water meter installed.
8. The HCF has maintained the record of the tubewell.
9. The establishment has provided a ETP for treatment of wastewater generated from hospital premises such as IVF, Lab, OT, Laundry and dialysis section.
10. The treated effluent of ETP is fed to the STP plant of capacity 150 KLD installed for treatment of wastewater generated from hospital premises, hostel & kitchen area, washrooms etc., which was found in operation.
11. The HCF has now provided agitator in the dosing tanks for proper mixing of dosing chemical.
12. The establishment has provided water meter on the inlet of ETP, treated effluent from ETP to STP and final line of treated water, leading to plantation area and is maintaining the record of the same.
13. The HCF has now taken a new land of approx. 1.5 acres near the hospital premises on lease for utilization of entire treated wastewater. However, plantation area has not been developed as per Karnal Technology and found stagnated.
14. The establishment has provided new sludge drying beds after sludge drying press and has also entered into an agreement with Nimbua Green Field, SAS Nagar for lifting of the same.
15. During visit, it was observed that the HCF has now closed the outlets pipes along the boundary wall of the HCF with concrete cement, through which seepage was earlier observed, which was ultimately leading to SYL River. However, being a large hospital and found violating on 15.5.2021, 23.11.2021, 12.05.2023 and 04.12.2023, 26.03.2024 and therefore, concrete action is to be taken against the HCF so that they will not cause any pollution in future. Therefore, it is advisable to direct the HCF to install OCEMS at the outlet of ETP and CCTV cameras along the boundary wall, ETP as well as in the plantation area.
16. Water/ effluent samples were collected from inlet, outlet & aeration tanks of ETP-cum-STP of HCF and were sent to Head Office Lab.
17. The hospital has installed 3 no. silent D.G. sets of 2 x 500 KVA and 1 x 150 KVA, which equipped with canopy and stack of adequate height.
Further, the HCF has submitted a copy of permission given by IMA, New Delhi to increase the bed capacity upto 150 beds vide regd no. RAJ01/201807/002 dated 01.01.2024. Moreover, the HCF has submitted a revised agreement with M/s Rainbow Environment, SAS Nagar for 150 beds.
As mentioned above, the HCF is partially complying with the decisions of personal hearing as observed during the visit, moreover, the HCF is also yet to point qualified EE to operate its ETP-cum-STP.
In view of above mentioned facts, consent to operate granted under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 may be granted to the HCF for a short period of three months up to 30.06.2024 for 150 beds subject to suitable conditions as per policy of the Board and special condition that:
1. The HCF shall install OCEMS at the outlet of ETP.
2. The HCF shall install CCTV cameras along the boundary wall, ETP as well as in the plantation area.
3. The Board shall take the 2 sets of the sample from the ETP and shall send the same to Board's lab as well as PBTI, Mohali.
Competency: CEE |
