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It is submitted that the industry was earlier granted ‘consent to operate’ under red category under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/SAS/2020/12899237 dated 30.07.2020 and under the Air (Prevention & Control of Pollution) Act, 1981, vide no. CTOA/Renewal/SAS/2020/12899200 dated 30.07.2020 both valid upto 30.06.2025 for manufacturing of Ethyl Acetate @ 36 Metric Tonnes/Day & Butyl Acetate @ 4 Metric Tonnes/Day by using raw material as Ethyl Alcohol @ 19 Metric Tonnes/Day, Butyl Alcohol 2.5 Metric Tonnes/Day & Acetic Acid 26.5 Metric Tonnes/Day subject to certain terms and conditions mentioned therein.
Now, the industry has applied for varied consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 for manufacturing of Ethyl Acetate @ 36 Metric Tonnes/Day & Butyl Acetate @ 4 Metric Tonnes/Day by using raw material as Ethyl Alcohol @ 19 Metric Tonnes/Day, Butyl Alcohol 2.5 Metric Tonnes/Day & Acetic Acid 26.5 Metric Tonnes/Day alongwith requisite documents.
The industry has submitted a covering letter in which it has been mentioned that:
“5. The reason for submission of application for grant of varied consent to operate is due to increase in fuel quantity being used in boiler as now the customers require the material of high purity and to achieve this we required to re-distill the finished goods to meet the customers requirement. As per the prevailing conditions of Pet coke Supplier they require to mention the quantity of pet code being used in consent letter. We are required to store the Pet Coke at our end for uninterrupted running of plant. Also the supplier companies are supplying the material in big consignments”
The details of fuel for which earlier ‘consent to operate’ was issued by the Board and present ‘consent to operate’ application is as under:
Fuel details Quantity for which previous ‘consent to operate’ issued
Quantity for which varied ‘consent to operate’ applied
Pet coke 3 TPD 11 TPD
The industry had earlier deposited Rs. 54500/- (Rs. 54000/- under Water (Prevention & Control of Pollution) Act, 1974) and Rs. 500/- as application form fees vide UTR no. N174201165574619 dated 22/06/2020 and Rs. 54000/- vide UTR no. N174201165574140 dated 22/06/2020 under the Air (Prevention & Control of Pollution) Act, 1981. The industry had submitted CA certificate showing fixed assets of the industry as Rs. 196.06 lakh as on 31.03.2020. Therefore, the consent fees were valid upto 30.06.2025 under both the Acts. Now, the industry has deposited Rs. 63100/- vide R. No. 507707004 dated 16.03.2024 under Water (Prevention & Control of Pollution) Act, 1974 including Rs. 1400/- as NOC regularization & Rs. 500/- as form downloading fees and Rs. 61200/- vide R. No. 734396496 dated 16.03.2024 under Air (Prevention & Control of Pollution) Act, 1981. The total fee deposited by the industry is adequate upto 31.05.2029 against the total cost of the industry Rs. 202.66 lakhs as per latest CA certificate submitted by the industry as on 19.10.2023.
The industry has submitted compliance report of the conditions of the previous granted consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention &Control of Pollution) Act, 1981.
Visit:
The site of the industry was visited by AEE of this office alongwith ASO of the Board on 28.03.2024. During the visit, it was observed as under:
1. The industry is involved in manufacturing of Ethyl Acetate & & Butyl Acetate using Acetic Acid, Butyl & Ethyl Alcohol and was in operation during the visit.
2. The process involves esterfication of industrial ethyl alcohol and butyl alcohol with acetic acid. In the reaction there is generation of water, which is separated through layer separation from the final product. The manufacturing process is under:
Ethyl Alcohol Butyl Alcohol Addition of Acetic Acid in reactor Esterification Reaction Layer Separation of Water Ethyl Acetate/Butyl Acetate.
3. The industry is using PSIEC supply as source of fresh water and flow meter has been provided with the same.
4. The industry has installed an ETP to treat the effluent generated during reaction of raw material and ETP consist of SAFF rector, tube settler, Pre filtration tank & Dual media Filter and Activate Carbon Filter. The treated effluent is feed into cooling tower. The industry has provided flow meter at the pipeline carrying effluent to cooling tower and is maintaining record of readings of the same.
5. During last visit to the site of the industry on 19.10.2023, effluent sampling of ETP was carried out and the analysis results are under:
Sr. no. Parameters Outlet of ETP Prescribed Standards
1. pH 8.1 6.5-9.0
2. TSS mg/l BDL 200
3. TDS mg/l 480 2100
4. BOD mg/l BDL 100
5. COD mg/l 29 -
From above, it is clear that the industry is now complying with the prescribed standards.
6. The industry has installed 4 TPH boiler provided with Twin Cyclone followed by Double stage alkaline scrubber as APCD and followed stack of 30 mtr height. The industry is using Pet coke alongwith wood as a fuel in the Boiler. Online pH meter & SO2 meter was installed and the meter reading was pH – 9.7 & SO2 – 148. The industry has provided pressure gauge and flow meter as per the instructions issued by the Board vide circular no. HQ-1/Pet coke/F-200/2010/478 dated 20/7/2010 for use of pet coke as fuel. During visit, stack emission sampling was carried out and the analysis results are awaited.
7. The industry has submitted analysis report of stack emission samples (4TPH boiler) carried out by NABL approved laboratory i.e. M/s Centre for Environment and Food Technology Pvt. Ltd. on 13.03.2024, the conc. of the parameter were found within the permissible limits of the Board as tabulated below:
S. No. Parameters Result
(mg/Nm3) Limits
(mg/Nm3 CPCB-2010)
1 Particulate Matter, mg/Nm3 (12 % CO2 Normalization) 83.9 800
2 Suphur Dioxide, (as SO2), mg/Nm3 210 400
3 Oxides of Nitrogen, (as NOX), mg/Nm3 185 -
8. The industry has installed one no. of DG of capacity 50 KVA, which is equipped with canopy and stack of adequate height.
From above, it is clear that the industry is complying with the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981.
Recommendation:
In view of above, it is recommended that the varied of ‘consent to operate’ under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 for manufacturing of Ethyl Acetate @ 36 MTD & Butyl Acetate @ 4 MTD may be granted to the industry upto 30.06.2028, subject to the suitable conditions and the following additional conditions:
1. This consent is being issued in supersession to the earlier ‘consent to operate’ granted under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/SAS/2020/12899237 dated 30.07.2020 and under the Air (Prevention & Control of Pollution) Act, 1981, vide no. CTOA/Renewal/SAS/2020/12899200 dated 30.07.2020 both valid upto 30.06.2025.
2. This consent is valid only for manufacturing of Ethyl Acetate @ 36 MTD & Butyl Acetate @ 4 MTD and the industry shall not increase its production capacity beyond these quantities, without prior permission from PPCB.
3. The industry shall regularly operate & maintain its effluent treatment plant and the entire treated effluent in cooling tower as make up water and in the process/ other activities within its premises. No untreated/ treated trade effluent shall be discharged at any time
4. The industry shall ensure that no wastewater from its industrial premises / plantation area or otherwise find its way into storm water drain(s) directly or indirectly under any circumstances.
5. The industry shall ensure that the sample collection facility attached with the stacks should be as per guidelines mentioned in EPR-3 norms prescribed by the CPCB.
6. The industry shall properly operate & maintain its air pollution control devices so as to contain all the suspended particulate matter and gaseous emissions within the permissible limits prescribed by the Board / MoEF&CC.
7. The industry shall ensure that at any time the emission do not exceed the emissions standards of PM as 100 mg/N3, in accordance with the condition of the Environmental Clearance granted to it by the MoEF&CC vide no. J11011/337/2011-1A II(I) dated 07.06.2013. Further, the industry shall ensure that no air pollution problem or public nuisance is created in the area due to the discharge of emissions from the industry.
8. The industry shall ensure the compliance of instructions issued by the Board vide circular no. HQ-1/Pet coke/F-200/2010/478 dated 20/7/2010 for use of pet coke as fuel.
9. The industry shall ensure the compliance of conditions of environmental clearance granted by MoEF&CC vide no. J11011/337/2011-1A II(I) dated 07.06.2013.
10. The industry shall ensure that the entire fuel ash generated is utilized in an environmentally sound manner.
11. The industry will stick to the production capacity mentioned in this consent and will not increase the same without prior written permission of the Board.
12. The industry shall mot consume any fuel except pet coke in boiler of capacity 4 TPH and HSD in DG set of capacity 50 KVA for burning purposes without the prior written permission of the Board.
13. The industry shall not discharge the effluent into any drain/choe/nallah, in any case.
14. The industry 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.
15. 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.
16. 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.
17. The ‘consent to operate’ is being issued to the project proponent 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/project proponent and its responsible/ concerned person(s) in case information/document is detected as incorrect/false/misleading at any point of time, without any opportunity of Personal Hearing.
18. 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, (Red, Small)
Date of received of case: 16.03.2024
Date of visit- 28.03.2024
Target date of deemed approval – 06.04.2024 (i.e. 15 working days)
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