| File Note: |
It is submitted thatthe industry was granted consent to operate under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/PTA/2021/15307478 dated 15/04/2021 and under the Air (Prevention & Control of Pollution) Act, 1981 vide no CTOA/Renewal/PTA/2021/15327787 dated 15/04/2021 for manufacture of Malt @ 62 Metric Tonne/Day alongwith Malt Clums @ 1.85 Metric Tonne/Day (by-product) by using Wheat @ 4 Metric Tonne/Day and Barley@ 67.2 Metric Tonne/Day under red category. These consents are valid upto 31/03/2026 with conditions mentioned therein.
As per the record file, the industry was issued Show cause notice for revocation of the consent granted under the Water (Prevention & Control of Pollution) Act, 1974 and for cancellation of consent granted under the Air (Prevention & Control of Pollution) Act, 1981 issued to the industry vide Board’s letter no. 385 dated 19/01/2023 alongwith opportunity of personal hearing before the Chief Environmental Engineer (P) of the Board on 31.01.2023. After hearing, it was decided that:
1. The Environmental Engineer, Regional Office, Patiala shall immediately visit the industry to collect effluent samples and get it analyzed from PBTI Lab, Mohali.
2. The industry shall submit a bank guarantee amounting to Rs. 2 Lakh as an assurance to achieve standards prescribed by the Board for the treated effluent being discharged onto land for plantation within 7 days.
3. The industry shall submit registered agreement made with the contractor and the farmers for disposal of the boiler ash in an environmentally sound manner within 7 days.
4. The industry shall maintain its plantation area and shall make arrangements for proper distribution of treated effluent into the plantation area within 7 days.
5. Environmental Engineer, Regional Office, Patiala shall visit the industry immediately after 7 days and shall submit his report / recommendations regarding compliance of the above said decisions and shall also verify the contentions of the representative of the industry regarding rain water harvesting pits immediately thereafter.
6. Further action in the matter shall be taken after the receipt of report / recommendations from Environmental Engineer, Regional Office, Patiala.
The proceedings of the hearing were conveyed to the industry vide Board's letter no. 1867 dated 21/03/2023.
The industry was visited by Officers of the Board on 31.01.2023 and samples were collected which were sent by to PBTI, Mohali. The result shows that various parameters were within permissible limits as fixed by Board. The results show that various parameters are within permissible as prescribed for such discharge onto land for plantation. But the concentration of MLSS and MLVSS is on the lower side.
The industry was again visited by the undersigned on 05.08.2023 and 7/8/2023 and contacted Sh. Jaspal Anand GM and Sh. Radhakrishnan at site. It was observed that the industry has failed to comply with the decisions of the personal hearing given to it on 31.01.2023 and also again found violating the provisions of the Water (Prevention & Control of Pollution) Act, 1974.
Accordingly, the consent to operate under the Water Act, 1974 was revoked vide Board’s letter no. 8610-11 dated 07/11/2023 and notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as amended in 1988 issued to the industry vide Board's letter no. 8612-13 dated 07/11/2023 alongwith opportunity of personal hearing before the Chief Environmental Engineer (P) on 17/11/2023 postponed on 07.12.2023 vide Board’s letter no. 9095 dated 29.11.2023. After hearing, it was decided that:
1. The industry shall upgrade its ETP and install its new clarifier by January, 2024 and ensure to meet with the discharge standards of BOD less than 30 mg/ltr in future.
2. The industry shall plug its 01 no. rain water harvesting pit installed for surface run of within 07 days and submit the report to the Regional Office. Regional Office shall verify the submission of the industry regarding usage of another 03 rain water harvesting pits for recharging of roof top storm water only.
3. The request of the industry to waive off the bank guarantee amounting to Rs. 2.0 lacs imposed in the last hearing on 31/01/2023 is hereby denied and the industry shall immediately submit the bank guarantee amounting to Rs. 2.0 lacs as an assurance to upgrade its ETP and to achieve BOD in its treated wastewater to the tune of less than 30 mg/Nm3 at all the time.
4. The industry shall explore the possibility to reuse its treated wastewater in cooling tower.
5. The industry shall apply to obtain consents to operate under the Water (Prevention & Control of Pollution) Act, 1974 & the Air (Prevention & Control of Pollution) Act, 1981, within 07 days.
6. Regional Office, Patiala shall convene a meeting with BDPO and Xen, Panchayati Raj alongiwth the industry for construction of Pond for the wastewater of the village stagnated near the plantation area of the industry. The industry shall contribute for construction of the said pond under its CER activities.
7. Regional Office, Patiala shall visit the industry in 1st week of January, 2024, verify the status of upgradation of ETP as well as another decision of the personal hearing and submit its report.
8. Further action shall be taken after the report from the Regional Office, Patiala.
The industry had applied for obtaining renewal of consent to operate under the Water Act, 1974, but the application was returned and the industry was asked to apply for fresh consent to operate under the said Act as the previous consent has been revoked.
Now, the industry has applied for obtaining fresh consent to operate under Water (Prevention & Control of Pollution) Act, 1974 for manufacturing of Malt @ 62 MTD by using Barley @ 72.5 MTD & Wheat @ 4 MTD& Malt clum @ 1.85 MTD and to discharge trade effluent @ 240 KLD and domestic effluent @ 15 KLD onto land for plantation along with requisite documents.
As per the record file, the industry had deposited Rs. 1,08,000/- vide UTR no. AXSK210570000818 dated 26.02.2021 as consent fee under the Water (Prevention and Control of Pollution) Act, 1974, which is adequate upto 31.03.2026. The industry has now deposited Rs. 21600/- vide UTR no. SBIN124041316850 dated 10.02.2024 as consent fee under the Water (Prevention and Control of Pollution) Act, 1974, which is adequate upto 31.12.2026 (after deducting of 25% consent fee for one year) against the gross value of fixed assets Rs. 823 lacs as on C.A certificate dated 30.09.2023 as per certificate dated 18.12.2023.
The industry was asked to clarify the following:
1. As per the previous CA certificate submitted by the industry the total cost of fixed assets was 8.33 cr in 2020 which has now reduced to 8.23 cr as 30.9.2023 after the addition in the cost of plant and machinery by Rs 22. 37 lakhs. The industry is required to clarify the above observation, submit CA certificate regarding un-depreciated value of the fixed assets alongwith production and pollution load undertaking.
2. Effluent analysis report is not submitted alongwith the application.
The industry has submitted that the Value of Gross Block (Un-depreciated) for the period 1.1.2021 to 30.9.2023 is explained as below:
a) Our Value of Opening Gross Block (un-depreciated) was Rs 833.27 Lakhs. During the above period there was Addition/Replacement in the fixed assets to the extent of Rs 133.78 Lakhs, whereas, during the same period the fixed assets have been discarded/Sold to the extent of Rs 143.95 Lakhs. Hence the value of Gross block as on 30.09.2023 is Rs 823.09 Lakhs in this connection the CA certificate is attached.
b) The addition of Rs 22.37 lakhs shown in the CA certificate is actual replacement of assets (Worn out Worm Conveyor changed), which does not effect on the production capacity & Pollution load. An undertaking that this does not in any way effect the production and pollution load.
c) The industry has got its effluent tested from SAI Lab, Patiala on 21.02.2024 and the results are reproduced as under:
Sr. No. Parameters Inlet of ETP Outlet of ETP Prescribed Standards
1. TDS mg/I 968 1168 2100
2. TSS mg/I 208 18 100
3. COD mg/I 617 111 250
4. BOD mg/I 341 27 30
The above said analysis results reveals that the concentration of various is within permissible limits as prescribed by the Board.
The industry vide its letter dated 19.02.2024 has submitted compliance to the decisions of the hearing on 07.12.2023, which is as under:
1. The process of upgradation of ETP is almost complete. A new secondary clarifier along with a roughing filter has been added to improve the performance of ETP. The treated effluent is supposed to be discharged onto land for watering of plantation area, for which applicable discharge limit regarding BOD is 100 mg/l. Through, our ETP is designed to achieve BOD less than 30 mg/l, but, occasionally due to seasonal variation affecting micro-bilogical activity and loading variation, at times, the BOD levels may exceed 30 mg/l. Therefore, we humbly request you not to impose the BOD limit of 30 mg/l and allow us to comply by the applicable standards as prescribed by the CPCB.
2. The rainwater harvesting pit meant for surface run of has been plugged and disconnected.
3. The industry has submitted a bank guarantee bearing no. 0163724BG0000002 dated 16.02.2024, valid upto 15.02.2025 amounting to Rs. 2.0 lakhs.
4. The cooling water demand is prominent during summer season and the industry shall be engaging consultants to explore possible of reuse of treated effluent for cooling water makeup.
The copy of reply is attached herewith.
Accordingly, the industry was visited by the AEE of this office 28.03.2024 and contacted Sh. Jaspal Anand, GM at site. During visit, it was observed as under: -
1. The industry was in operation.
2. The industry has installed biological ETP (based on anaerobic treatment followed by aerobic treatment) which was in operation during the visit. The meter reading at outlet was 27320 KL. The industry is maintaining the record of operation of the ETP as per which the average discharge of last 3 months is ranging between 110 KLD to 160 KLD for discharge onto to land for plantation. The representative of the industry informed that due to winter season the discharge is less and increases in the summer season.
3. The effluent sample of the industry were collected and sent to Board’s lab for analysis.
4. The industry was in the process of installing new secondary clarifier and finishing work was in progress. The representative of the industry informed that the same shall be installed and commissioned in the first week of the April.
5. The industry has developed about 4.2 acre of land under plantation for disposal of treated effluent, which is adequate to handle the discharge of consented effluent.
6. The industry has plugged the rainwater harvesting pit located at the backside of the unit near the boiler ash disposal area from where surface run off was being discharged in it. The industry has also made provisions to tap roof top water and discharge the same in the rainwater harvesting pit provided near the boiler area and has disconnected the surface run off arrangements in the said pit. The representative of the industry informed that the similar arrangements to tap roof top water on the rest 2 no. rain water harvesting pits shall be made before the onset of monsoon season.
7. The representative of the industry submitted that the use of treated effluent into cooling tower might lead to bacteriological contamination and as they are dealing with food item it shall not pass the food quality parameters.
The industry has also submitted a letter addressed to CEE(P) dated 28.03.2024 in this regard, which is reproduced as under:
‘Being a food manufacturing unit, Reuse of ETP Water in Cooling Towers, which is having organic matter could lead to bacteriological contamination in our cooling tower. Contaminated cooling tower water may further lead to infect our RM/FG or Growth of bacteria in RM/FG which may lead to further health hazards as this is being used by the food industries/ brewery as raw material.
Our process quality controls are very strict and we are to comply with the prescribed SOPs. We have communicated about exploring the possibility of reuse of the treated wastewater for cooling purposes, to our headquarters. Only after due clearance from the headquarters, we shall be in a position to commit about the same.
Further we have taken Additional Steps to reuse of ETP Water:
a. For Road Cleaning, horticulture & Suppression of Dust.
b. We are Reusing Waste Water for Boiler ash quenching (approx. 10-15 KI/day)
c. We Shall Explore other possibilities of Reusing waste water after installation of secondary Clarifier in the first week of April.
The delay in commissioning of secondary clarifier/filter is because of multiple issues related to on-site erection - laying of foundations, irregular availability of labour, surface coating, sourcing of filter material, etc. The same shall be commissioned within 7-10 days’. Copy of letter enclosed.
8. The matter regarding construction of pond for the wastewater of the village Rauni was taken up with XEN, Panchayti Raj and the industry and a meeting has been fixed in the first week of April, 2024 and the industry shall contribute through CSR funds.
9. The industry has provided brick road / pucca road in front side of its unit and the industry was advised to make all the internal roads at the backside near the boiler area and boiler ash disposal area also brick paved and make arrangement to use of treated water for sprinkling / dust supersession.
The industry has made compliances to most of the decisions of the hearing and as per the industry, the new secondary clarifier shall be commissioned in the 1st week of April. Further, the submission made by the industry w.r.t reuse of treated water in the cooling tower may be considered as it has proposed to make alternate arrangements for reuse of treated effluent.
In view of the submission made by the industry, the application of the industry may be considered for grant of consent to operate for short term so that all the compliance shall be verified in this time.
In view of above, may if approved, recommendation be sent to SEE, ZO-1, Patiala for granted of fresh consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 upto 31.03.2025 with suitable conditions and following special condition that:
1. The industry has provided brick road / pucca road on all the internal roads and make arrangement to use of treated water for sprinkling / dust supersession.
2. The industry shall comply with the PWRDA guidelines for abstraction of ground water.
3. The industry shall commission its secondary clarifier in the 1st week of April, 2024 and inform the Board.
4. The industry shall make arrangement for recharging of roof top storm water in the 2 no. rain water harvesting pits before onset of monsoon. |
