| File Note: |
Sir, the pointwise reply is as under: -
Sr. No. Recommendations Reply
1. The actual hazardous waste generation submitted by the industry is significantly higher than the calculations highlighted above based on consented production, total solid analysis, flow rates etc. Therefore, the industry is required to submit clarification in this regard. The industry is lifting spent bromine from many industries and as it is lifting spent process waste, the same may have significant amount of impurities leading to higher sludge generation.
However, the industry is complying with HWM Rules, 2016 and is lifting the entire process sludge to TSDF Nimbua.
2. Lot of fugitive emissions could be sensed near the ETP collection tank, creating irritation of skin/eyes. Therefore, the industry is required to make arrangements to tap fugitive emissions effectively and also get the testing done regularly for ambient air for the parameters mentioned in the SOP for utilization of spent alkali bromide framed by CPCB in 2019. The industry has provided 7 no. scrubbers on process and collection tanks to control fugitive emissions and is complying with the SOPs prescribed for such units.
However, a special condition has been imposed w.r.t Monitoring of the specified parameters for source emission shall be carried out quarterly for the first year followed by at least annually in the subsequent year of utilization. Fugitive emission for specified parameters shall be carried out quarterly. The monitoring shall be carried out by NABL accredited or ISO17025/EPA approved laboratories and the results shall be submitted to the concerned SPCB/PCC on a quarterly basis.
3. Analysis results reveals that the condensate of single effect evaporator is having concentration of TDS, COD & BOD, which is not suitable for reuse in cooling towers. High concentration of TDS and presence of TSS reveals that the evaporators are not functioning efficiently enough to produce condensate which is devoid of solids. Such high concentration of solid and BOD/COD carrying effluent is not suitable for usage in cooling tower. Therefore, there is every possibility that such effluent/condensate may be discharged outside to an undisclosed location through unauthorized means.
The industry has now provided RO filtration after the evaporators to achieve ZLD as suggested by the Board.
4. The existing treatment system based on physico chemical followed by evaporators is inadequate to treat such kind of effluent having high BOD & COD.
5. Keeping in view of the high values of EC, TDS, Chloride, Sulphate etc. within industry and less in the outside area, hydrological study regarding ground water in nearby area (1-2 km) needs to be carried from an institute of Repute/charted Engineer Institute. That 4 nos. samples were collected by the visiting team from within the premises and from surrounding areas and as per analysis results the concentration of various parameters except TDS in the ground water is within acceptable limits. However, for TDS it was beyond the acceptable limit but within permissible limits as per ISO10500:2012
6. The industry is required to provide plantation all along the boundary wall to mitigate the odour issue outside the premises. The industry has provided fresh plantation along the boundary of the project as recommended by the team.
7. The industry is required to remove the stagnation adjoining to the boundary wall of the unit immediately and plug the outlet of the domestic effluent of its office complex outside the unit. The stagnation along the boundary has been removed and the outlet has been plugged.
8. The industry is not managing the hazardous waste stored in the hazardous waste room in environmentally sound manner and is required to do the same as per the Hazardous Waste Management Rules, 2016. The industry has improved overall housekeeping in the hazardous waste room.
In the view of above, it is recommended that the 'consent to operate' under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 may be granted upto 30.06.2025, subject to suitable conditions and additional conditions that:
1. The industry shall maintain proper daily record of abstraction of groundwater and generation, treatment & disposal of trade effluent, at all times.
2. The industry shall monitor the specified parameters i.e. HCl, HBr, NH3, TOC, Chlorine for source emission quarterly for the first year followed by at least once annually in the subsequent year. Fugitive emission for specified parameters i.e. HCl, Cl2, Br2, shall be carried out quarterly. The monitoring shall be carried out by NABL accredited or ISO17025/EPA approved laboratories and the results shall be submitted to the concerned SPCB/PCC on a quarterly basis
3. The industry shall complete the work regarding installation of additional evaporator within 15 days.
4. The industry shall comply with the guidelines issued by PWRDA and shall obtain permission from PWRDA for abstraction of ground water.
5. The adequacy/ efficacy of the pollution control arrangements shall be the sole responsibility of the industry and the industry shall be bound to implement/ upgrade its pollution control arrangements as per the discretion of the Board to achieve the prescribed emission/ effluent standards, as amended from time to time.
6. The industry shall regularly operate and maintain its ETP and ensure that the treated sewage conforms to the effluent standards prescribed by the Board / Ministry of Environment and Forests & Climate Change for such discharges.
7. The industry shall comply with the provisions of Solid Waste Management Rules, 2016.
8. The project proponent shall not discharge any effluent at any unauthorized place by any unauthorized means i.e. shall not discharge any wastewater in any drain / inland surface waters / drain/choe/nallah/ onto land for stagnation or outside its premises, at any time, under any circumstances.
9. The industry shall ensure that the activity of unit does not create any nuisance in the surrounding areas and no public complaints are received.
10. The Consent is being issued to the industry based upon the documents/ information submitted by it along with the online application form. The Board would be at liberty to take penal action against the industry and its responsible/ concerned person(s) in case information/document is detected as incorrect/false/misleading at any point of time.
11. In case the industry 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 industry.
12. 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.
(Competency Senior Environmental Engineer)
Date of Deemed Approval : 01.04.2024 |