| File Note: |
Subject: - Proceedings of the personal hearing given before the Senior Environmental Engineer (ZP-1) on 27.03.2024 w.r.t show cause notice for refusal of the consent to operate applied by the industry under the Water (Prevention & Control of Pollution) Act, 1974 & the Air (Prevention & Control of Pollution) Act, 1981.
The Following were present:
On behalf of Punjab Pollution Control Board
Er. Navtesh Singla, Environmental Engineer (ZP-1)
On behalf of the Industry
1. Sh. Pawan Sharma, GM Admin
2. Sh. Neeraj Chhibba, Plant Manager
At the outset, Environmental Engineer, ZP-1 brought out that: -
The industry was granted to 'Consent to Operate' under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Fresh/RPN/2023/21923108 dated 15/07/2023, valid upto 30/09/2027 and Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Fresh/RPN/2023/22648536 dated 15/07/2023, valid upto 30/09/2027 for Sale & Service of Earth Movers Machines Vehicles @ 10 Nos./Day and Registered Vehicle Scrappage Facility (RVSF) @ 100 Nos./Day, subject to the conditions mentioned therein.
The industry has applied for fresh 'consent to operate' under the said Acts in the new name and style of M/s Dada Trading Company with certain documents. However, the documents submitted by the industry are incomplete and are not in the name and style of new company. Further, the consent fee deposited by it is also not adequate.
The industry was visited by officer of Regional Office, Rupnagar on 13.03.2024 and contacted Sh Neeraj Chhiba, Operation Head of the unit. The detail of the unit and observations made during visit are as under:
General Information:
1. The industry is engaged in scrapping / dismantling of end of life vehicles and service of excavators. The industry is in operation.
2. It is procuring about 3 vehicles/day and dismantling about 4 vehicles / shift in a day.
3. The scrapping / dismantling operation mainly involves:
a. End of life vehicle – Depolluting – Dismantling – Storage of dismantled parts.
b. Accidental excavator – repair / replacement of parts – repaired vehicle.
4. Previously it was working in the name and style of M/s Dada Motors Pvt Limited. Now, it has changed to M/s Dada Trading Company.
5. Now a day the unit is dismantling vehicles @ 4 nos./shift and repairing excavators @ 1 nos./month only.
Water Pollution & its Control:
1. It has installed a submersible pump as source of fresh water and no water meter is provided with the same.
2. The dismantling operation is observed to be dry and hence no trade effluent is generated.
3. About 1.8 KLD of fresh water is consumed in domestic use as per manpower available. There is septic tank provided for treatment of domestic effluent which is got emptied through moveable tanker to dispose of at unknown place.
4. No plantation area is developed for utilization of treated wastewater.
5. Rainwater Harvesting Well is installed with provisions of receive the surface run off.
Air Pollution & its Control:
1. It is having DG set of capacity 160 KVA which is equipped with canopy and stack of height about 6 ft above it.
2. The parking area is unlined and can generate dust emissions during vehicle movement / handling operation. No dust suppression system is provided in this area.
Hazardous Wastes Management:
1. It is generating hazardous wastes as per CPCB guidelines as under:
a. Liquid Hazardous Wastes:
i. Waste oil
ii. Transmission oil
iii. Brake fluids and cleaners
iv. Fuel and fuel filters
v. Coolant (Antifreeze)
b. Solid Hazardous Wastes:
i. Lead acid batteries
ii. Air filter
iii. Oil filter
iv. Hot tank solution
v. Mercury switch
vi. Break shoe clutch plates / discs
vii. Rubber parts
viii. Glass parts (containing PVC sheet)
ix. Electronic parts
x. Refrigerant gases
xi. Air bags
xii. Catalyst
2. It has not provided proper storage facility for Hazardous Wastes. Only one small room is provided for scrap batteries.
3. No agreement with the authorized recyclers / TSDF is produced.
4. No record of hazardous wastes is maintained.
5. The Environmental Data board is not provided at the main gate.
6. The hazardous waste is kept in open on the interlocked tiled floor.
7. It has not obtained authorization of the Board.
8. The scrap batteries also found kept in the parking area which is having unlined surface.
From the above, it is clear that the unit is not complying with the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981, Environment (Protection) Act, 1986, Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016 and the guidelines of CPCB for such units, intentionally and deliberately.
The industry is not complying with the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981 and Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016 as well as the guidelines of CPCB for such units intentionally and deliberately.
It has been proposed to refuse the consent to operate applied by the industry under the provisions of the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 after affording an opportunity of show cause cum personal hearing.
Therefore, show cause notice for refusal of the consent to operate applied by the industry under the Water (Prevention & Control of Pollution) Act, 1974 & the Air (Prevention & Control of Pollution) Act, 1981 issued to the industry vide Board's letter no. 12899 dated 22/03/2024 with an opportunity to appear in person before the Senior Environmental Engineer of the Board in his office Punjab Pollution Control Board, Vatavarn Bhawan, Nabha Road, Patiala on 28.03.2024 at 11.00 AM (Preponed on 27.03.2024).
The representative of the industry has attended the hearing submitted as under:-
• The industry has provided water meter at submersible pump. Photo of water meter attached herewith.
• Entire domestic effluent of the industry is collected in the septic tank which is not yet filled, hence the question of lifting the domestic effluent does not arise. Industry assures that moveable tanker will never be used for disposal of domestic effluent.
• The industry has started developing plantation area for treated water utilization.
• The industry has provided canopy for D.G Set along with adequate stack height 3 meter above silencer.
• The industry has provided separate storage area for each category of Hazardous Waste.
• The industry has made agreement in the earlier name of DADA MOTORS (P) LTD. for different categories of Hazardous waste. We request the Board to apply for hazardous Waste Authorization after getting the name changed in the agreement of all categories. For which we need at least 10-15 days time.
• The industry has maintaining record of Hazardous waste & Other Waste.
• The industry has provided Environmental Data Board at main gate of premises.
• The industry has provided proper storage for Hazardous Waste of each category.
• The industry has provided a separate room to store scrap batteries.
After hearing the officer of the Board, representative of the industry and material facts on the record, the Senior Environmental Engineer (ZP-1) decided as under: -
1. The industry shall submit the Bank Guarantee amounting to Rs. 1 lac as an assurance to comply with the Environmental Laws, within 7 days.
2. The industry shall remove all the observations of the visiting officer as well as guidelines of the CPCB for such units, within 10 days and submit compliance to the office of Environmental Engineer, Regional Office, Patiala.
3. The industry shall provide proper plantation area within its premises for disposal of treated wastewater, within 10 days.
4. The industry shall utilize the rain water harvesting pit for recharging of roof top of water only.
5. Environmental Engineer, Regional Office, Patiala shall visit the industry, verify the compliances / contentions of the industry and send the concrete recommendations for deciding the application.
6. Further action shall be taken after the report from the Regional Office, Patiala.
If approved, proceedings may be conveyed to the industry as well as Environmental Engineer, Regional Office, Rupnagar for compliance. |
