| File Note: |
It is submitted that there are 04 no. units running in the name & style of M/s Vijay Plastic as Unit-I, Unit-II, Unit-III and Unit-IV and all are small-scale plastic recycling units. All the units have valid consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 & the Air (Prevention & Control of Pollution) Act, 1981 and the detail of the same are as under:
M/s Vijay Plastic (Unit-I):
The unit has obtained consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Fresh/LDHKH/2023/21751911 dated 15/05/2023 and the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Fresh/LDHKH/2023/21751894 dated 19/05/2023, both were valid upto 30/09/2023 for manufacturing of Plastic Granules @ 1.5 MTD. Thereafter, the unit has availed the auto renewal facility and obtained renewal of consent to operate under the Water Act, 1974 vide no. CTO/Renewal/LDHKH/2023/23982549 dated 21/10/2023 and the Air Act, 1981 vide no. CTO/Renewal/LDHKH/2023/23920923 dated 21/10/2023, both are valid upto 21/10/2025 subject to the suitable terms & conditions mentioned therein.
M/s Vijay Plastic (Unit-II):
The unit has obtained consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDHKH/2021/14145605 dated 14/01/2021 and the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/LDHKH/2021/14145558 dated 14/01/2021, both were valid upto 30/09/2025 for manufacturing of Plastic Granules @ 1.5 MTD subject to the suitable terms & conditions mentioned therein.
M/s Vijay Plastic (Unit-III):
The unit has obtained consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDHKH/2021/14180083 dated 06/02/2021 and the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/LDHKH/2020/14145657 dated 16/12/2020, both were valid upto 30/09/2024 for washing of plastic scrap @ 1.95 MTD subject to the suitable terms & conditions mentioned therein.
M/s Vijay Plastic (Unit-IV):
The unit has obtained consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDHKH/2021/14461440 dated 02/01/2021 and the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/LDHKH/2021/14146529 dated 14/01/2021, both were valid upto 30/09/2025 for manufacturing of Plastic Granules @ 1.5 MTD subject to the suitable terms & conditions mentioned therein.
Thereafter, the industry was issued show cause notice for violations of the provisions of the Plastic Waste Management Rules, 2016 alongwith an opportunity of personal hearing before the Chief Environmental Engineer of the Board on 09/01/2024, wherein, it was decided as under:
1. The industry shall obtain a single varied Consent to Operate under Water Act, 1974 and Air Act, 1981 for all its 04 units and its new industrial packaging unit, by 31/01/2024.
2. Senior Environmental Engineer, Zonal Office-ll, Patiala shall revoke the Consent to Operate granted under Water Act, 1974 and Air Act, 1981 since single industry exists at the ground level.
3. The industry shall submit the fresh application for obtaining registration on the centralized EPR portal developed by the CPCB as a Plastic Waste Processor for Cat-lll @ 250 TPA, along with reply to the observations, by 31/01/2024.
4. The industry shall submit the fresh application for obtaining registration on the centralized EPR portal developed by the CPCB as a Producer for its industrial packaging unit, by 31/01/2024.
5. The industry shall provide the record regarding the quantity and source of plastic waste collection within 15 days.
6. The industry shall not sell recycled granule for the manufacturing of plastic carry bags in the State of Punjab.
7. The industry shall dispose its ETP sludge through TSDF Nimbua by 31/01/2024 and make sure that ETP sludge should not be stored beyond 180 days in compliance with the Hazardous and Other Waste (Management and Trans-boundary) Rules, 2016.
8. The industry shall submit drawing of Effluent Treatment Plant (ETP) installed treatment for the of trade effluent by 31/01/2024 to the Head Office (HQ-3), Patiala.
9. The industry shall submit Bank Guarantee of amount Rs. 2.0 lacs (2no. of 1 lacs each), in the favour of EE, RO, FGS as an assurance to comply with the hearing decisions out of which Bank Guarantee of amount Rs. 1.0 lacs shall be in cash by the EE, RO, FGS.
10. The industry shall be visited by the team consists of Er. Parveen Saluja, Environmental Engineer, Er. Shivani Gupta, AEE (OS) and Er. Pawan Sharma, AEE (OS) in the first week of February and thereafter submit the report, within 15 days.
In compliance to the hearing decision no. 1, the industry has now applied for obtaining varied Consent to Operate under the provisions of the Water Act, 1974 and the Air Act, 1981 for all its 04 units for manufacturing of Plastic Granules @ 6.45 MTD alongwith requisite documents and consent fee.
The industry has also submitted the point wise compliance of the hearing decisions dated 09/01/2024, which are as under:
Sr. No. Hearing Decisions Compliance made by the industry
1 The industry shall submit the fresh application for obtaining registration on the centralized EPR portal developed by the CPCB as a Plastic Waste Processor for Cat-lll @ 250 TPA, along with reply to the observations, by 31/01/2024. The industry shall submit the fresh application for obtaining registration on the centralized EPR portal developed by the CPCB as a Plastic Waste Processor for Cat-lll @ 250 TPA after obtaining varied consent to operate under the Water Act, 1974 and the Air Act, 1981.
2 The industry shall submit the fresh application for obtaining registration on the centralized EPR portal developed by the CPCB as a Producer for its industrial packaging unit. The industry has closed its packaging unit, which was verified during visit by the AEE.
3 The industry shall provide the record regarding the quantity and source of plastic waste collection within 15 days. Source Scrap Material Qty./Month
Sapna Enterprises, Ludhiana PVC & MLP 40MT & 80 MT
Preeti Bottle Store, Khanna MLP 60 MT
Sai Plastics, Khanna LDPE 50 MT
Garvit Enterprises, Ludhiana LDPE 40 MT
Akbar Khan, Khanna PVC & MLP 50 MT & 50 MT
Tarun Malhotra, Ludhiana PVC & MLP 50 MT & 50 MT
4 The industry shall not sell recycled granule for the manufacturing of plastic carry bags in the State of Punjab. The industry has agreed to not sell the recycled granule for the manufacturing of plastic carry bags in the State of Punjab.
5 The industry shall dispose its ETP sludge through TSDF Nimbua by 31/01/2024 and make sure that ETP sludge should not be stored beyond 180 days in compliance with the Hazardous and Other Waste (Management and Trans-boundary) Rules, 2016. The industry has disposed its ETP sludge through TSDF Nimbua vide Invoice No. DC/2023-24/2045 dated 12/02/2024.
6 The industry shall submit drawing of Effluent Treatment Plant (ETP) installed treatment for the of trade effluent by 31/01/2024 to the Head Office (HQ-3), Patiala. The industry has submitted the drawings of ETP installed in the Feasibility Report attached with the application.
7 The industry shall submit Bank Guarantee of amount Rs. 2.0 lacs (2no. of 1 lacs each), in the favour of EE, RO, FGS as an assurance to comply with the hearing decisions out of which Bank Guarantee of amount Rs. 1.0 lacs shall be in cash by the EE, RO, FGS. The industry has deposited 02 no. bank guarantees amounting to Rs. 1.0 lakhs each vide no. 0578NDDG00015024 & 0578NDDG00014924 dated 12/02/2024, out of which Bank Guarantee amounting to Rs. 1.0 lacs have been encashed by the RO, Fatehgarh Sahib vide letter no. 3085 dated 07.03.2024.
In compliance to the hearing decision no. 10, the industry is yet to be visited by the team consists of Er. Parveen Saluja, Environmental Engineer, Er. Shivani Gupta, AEE (OS) and Er. Pawan Sharma, AEE (OS).
The industry has submitted the CA certificate dated 20/01/2024, wherein, the total value of fixed assets of all the units as on 31/12/2023 is Rs. 56.12 lacs with value of plant & machinery is Rs. 29.80 lacs. Accordingly, the industry has deposited consent fee amounting to Rs. 7200/- vide online R. No. 760700421 dated 29/01/2024 under the Water Act, 1974 and Rs. 7200/- vide online R. No. 685889819 dated 29/01/2024 under the Air Act, 1981. As such, the fee deposited by the industry under the both Acts is adequate upto 31/03/2026 as per office order dated 29/10/2018.
To verify the contents of the application, the industry was visited by the AEE (OS) on 19/04/2024 and Sh. Vijay Kumar, Proprietor was contacted. During visit, it was observed as under:
1. The industry was in operation and engaged in the business of manufacturing Plastic Granules.
2. The industry has merged all its 04 units in compliance to the hearing decision.
3. The manufacturing process of the industry is as under:
Waste Plastics -> Sorting -> Grinding -> Washing (Only in case of LDPE scrap) -> Extrusion -> Recycled Granules.
4. The industry has installed an ETP based on physico chemical for treatment of wastewater generated from the washing process and the same was found in operation during visit.
5. The entire treated effluent from the outlet of the ETP is being re-used for washing of plastic scrap. The industry has submitted the sampling report of treated wastewater from the outlet of ETP carried out by M/s Evapo Tech Technical Service and Consultants on 17/01/2024 and the analysis results are tabulated as under:
Sr. No. Parameters Result Prescribed Standard
1 pH 7.4 5.5-8.5
2 Total Dissolved Solids mg/l 1498 2100
3 Total Suspended Solids mg/l 39 100
4 Chemical Oxygen Demand mg/l 80 250
5 Bio-chemical Oxygen Demand mg/l 24 30
6 Oil & Grease mg/l 1.5 10
From above, it is clear that the concentration of parameters are within the permissible limit as prescribed by the Board and the ETP installed by the industry is running in effective manner.
6. Domestic effluent of industry is being discharged onto land for plantation after passing through septic tank.
7. The industry has installed 04 no. extruders machines for manufacturing of plastic granules.
8. The industry has provided separate APCD i.e. wet scrubber on all extruder machines to control process emissions. The industry has provided adequate sampling facility to facilitate the stack emission sampling. The industry has submitted the stack emission analysis report carried out by M/s Evapo Tech Technical Service & Consultants on 17/01/2024 and the analysis results are tabulated as under:
Sr. No. Source Parameter Result (mg/nm3) Prescribed Standards (mg/nm3)
1 Extruder No. 1
Particulate Matter (PM) 80 150
2 Extruder No. 2 83 150
3 Extruder No. 3 77 150
4 Extruder No. 4 78 150
From above, it is corroborated that the concentration of Particulate Matter is within the standards prescribed by the Board/ MoEFF.
9. During visit, it was observed that no ETP sludge is being stored and lastly, the industry has disposed its ETP sludge through TSDF Nimbua vide Invoice No. DC/2023-24/2045 dated 12/02/2024.
Site Suitablitiy:
As per record file of this office, the industry has submitted the land use classification issued by the DTP, Ludhiana vide letter no. 3423-DTP(L)M2-A dated 29/11/2013 and according to which, the site of the industry falls in the Residential Zone as per Master plan of Khanna and within the MC limits of Khanna. The contents of the letter are reproduced as under:
"ਉਪਰੋਕਤ ਵਿਸ਼ੇ ਤੇ ਹਵਾਲੇ ਤਹਿਤ ਪੱਤਰ ਦੇ ਸਬੰਧ ਵਿੱਚ ਸੂਚਿਤ ਕੀਤਾ ਜਾਂਦਾ ਹੈ ਕਿ ਆਪ ਦੀ ਵਿਸ਼ੇ ਅਧੀਨ ਸਾਈਟ ਵਿੱਚ ਇਕਾਈ ਜੁਲਾਈ 2007 ਤੋਂ ਪਹਿਲਾਂ ਦੀ ਚੱਲ ਰਹੀ ਹੈ। ਸਾਈਟ ਪ੍ਰਵਾਨਤ ਮਾਸਟਰ ਪਲੈਨ, ਖੰਨਾ (2010—2031) ਦੀਆਂ ਤਜਵੀਜ਼ਾਂ ਅਨੁਸਾਰ ਰਿਹਾਇਸ਼ੀ ਜ਼ੋਨ (ਆਰ.ਡੀ—1) ਵਿੱਚ ਪੈਂਦੀ ਹੈ। ਇਸ ਜ਼ੋਨ ਵਿੱਚ ਉਦਯੋਗਿਕ ਇਕਾਈਆਂ ਆਗਿਆ ਯੋਗ ਨਹੀਂ ਹਨ। ਆਪ ਦੀ ਇਕਾਈ ਮਾਸਟਰ ਪਲੈਨ ਦੀ ਨੋਟੀਫਿਕੇਸ਼ਨ ਤੋਂ ਪਹਿਲਾਂ ਦੀ ਚੱਲਦੀ ਹੋਣ ਕਾਰਨ, ਪੰਜਾਬ ਰਿਜ਼ਨਲ ਐਂਡ ਟਾਊਨ ਪਲੈਨਿੰਗ ਐਂਡ ਡਿਵੈਲਪਮੈਂਟ ਐਕਟ 1995 (ਸੋਧ 2006) ਦੀ ਧਾਰਾ 79 ਅਧੀਨ ਸਮਰੱਥ ਅਧਿਕਾਰੀ ਦੀ ਪ੍ਰਵਾਨਗੀ ਨਾਲ ਮਾਸਟਰ ਪਲੈਨ, ਖੰਨਾ ਦੀ ਨੋਟੀਫਿਕੇਸ਼ਨ ਦੀ ਮਿਤੀ ਤੋਂ 10 ਸਾਲ ਤੱਕ ਇਸ ਯੂਨਿਟ ਨੂੰ ਚਾਲੂ ਰੱਖ ਸਕਦੇ ਹੋ। ਇਸ ਪੱਤਰ ਨੂੰ ਸਾਈਨ ਵਿੱਚ ਕਿਸੇ ਬਿਲਡਿੰਗ ਜਾਂ ਭਵਿੱਖ ਵਿੱਚ ਬਣਨ ਵਾਲੀ ਕਿਸੇ ਬਿਲਡਿੰਗ ਦੀ ਪ੍ਰਵਾਨਗੀ ਨਾ ਸਮਝਿਆ ਜਾਵੇ।"
It is pertinent to point out that as per Board’s Office Order no. 21 dated 08/06/2018 (especially for District Ludhiana), wherein, it has been mentioned as under:
“The matter has been considered and it has been decided that the existing industrial units/ establishments, which were established before the notification of the Master Plan of the respective cities shall be allowed consents/ extensions under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 and authorization under the provisions of HWM Rules, 2016 for a period of 15-year from the date of notification of Master Plan after taking concrete documents proof regarding the date of commissioning of such units. No separate approval from local bodies/ other authorities is required to be obtained.”
Further, the Board vide letter no. 1955-57 dated 18/01/2023 has informed that department of Water Resources (RD and GR), Central Ground Water Authority, Ministry of Jal Shakti Govt. of India, New Delhi under Section 5 of the Environment (Protection) Act, 1986 has issued directions vide order dated 6/4/2022 that “It shall be mandatory for the project proponent abstracting ground water to obtain No objection Certificate from Central Ground Water Authority or the concerned State/UT Ground Water Authority as the case may be in the compliance conditions in consent to operate and consent to establish issued by the State pollution control Board”
PWRDA vide notification dated 27.01.2023 has exempted units from obtaining any permission of the authority, which are extracting not more than 300 cubic meters of ground water per month.
In the subject cited case, the industry has mentioned ground water extraction @ 2.67 KLD. Considering 30 working days in a month during season, the ground water extraction will be 80.1 KL/month, which is less than 300 KL/month. As such, the industry does not require to obtain permission from PWRDA.
From above, it is clear that the industry is complying with the decisions of the personal hearing dated 09/01/2024 as well as with the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981.
In view of the facts mentioned above, if approved, it is recommended that the varied consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 may be granted upto 30/09/2025 for manufacturing of Plastic Granules @ 6.45 MTD subject to the suitable and special conditions as under:
1. This consent will supersede the earlier consent granted to the industry for all the units under the Water Act, 1974 and the Air Act, 1981:
M/s Vijay Plastic (Unit-I): Under the Water Act, 1974 vide no. CTO/Renewal/LDHKH/2023/23982549 dated 21/10/2023 and the Air Act, 1981 vide no. CTO/Renewal/LDHKH/2023/23920923 dated 21/10/2023, both are valid upto 21/10/2025.
M/s Vijay Plastic (Unit-II): Under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDHKH/2021/14145605 dated 14/01/2021 and the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/LDHKH/2021/14145558 dated 14/01/2021, both were valid upto 30/09/2025.
M/s Vijay Plastic (Unit-III): Under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDHKH/2021/14180083 dated 06/02/2021 and the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/LDHKH/2020/14145657 dated 16/12/2020, both were valid upto 30/09/2024.
M/s Vijay Plastic (Unit-IV): Under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/LDHKH/2021/14461440 dated 02/01/2021 and the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/LDHKH/2021/14146529 dated 14/01/2021, both were valid upto 30/09/2025.
2. The industry shall comply with the guidelines for abstraction of groundwater issued by the PWRDA from time to time.
3. The industry shall submit the fresh application for obtaining registration on the centralized EPR portal developed by the CPCB as a Plastic Waste Processor for Cat-lll @ 250 TPA, along with reply to the observations.
4. The industry shall not engage in any activities related to packaging unit without the prior approval of the Board.
5. The industry shall not sell recycled granule for the manufacturing of plastic carry bags in the State of Punjab.
6. The industry shall comply with by-Laws of Master Plan of Khanna and will shift from its present location to industrial zone/Focal Point before 31/12/2025.
7. The industry shall not increase its production capacity without prior written permission from the Board.
8. The industry shall not install any new machinery without prior written permission from the Board.
Scale- Small (Orange)
Date of Receipt of Application – 08/04/2024
Date of Scrutiny – 09/04/2024
Date of Visit – 19/04/2024
Target Date of Deemed Approval – 02/05/2024 (15 working days)
Competency – CEE, Waste Management {As the industry was afforded an opportunity of the personal hearing before the CEE (Waste Management) on 09/01/2024} |
