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It is intimated that the industry is a large scale red category unit. The industry has earlier granted consent under Water Act, 1974 vide no. CTOW/Renewal/LDH2/2023/21327344 dated 19/06/2023 valid upto 31/03/2024 & under Air Act, 1981 vide no. CTOA/Renewal/LDH2/2020/12296939 dated 17/07/2020 valid upto 31/03/2025.
Thereafter, the industry was given hearing before the Chairman of the Board on 15.03.2024 w.r.t. show cause notice for revocation of consent to operate granted under the Water Act, 1974 and after hearing it was decided that :-
1. The industry shall comply with all the violations stated as above, immediately.
2. The industry shall continue to operate its pollution control devices regularly and efficiently so as to achieve the prescribed standards.
3. The industry shall immediately finalize the order for installation of Zero Liquid Discharge (ZLD) plant.
4. The industry shall submit Progress Evaluation and Review Technique (PERT) chart for installation of 2LD plant, within 15 days.
5. The industry shall install and commission ZLD plant by 31.05.2024 and shall complete its stabilization by 30.06.2024.
6. The industry shall submit Bank Guarantee of Rs. 50 lacs, within 15 days, as already imposed during hearing dated 23.11.2023 as assurance that the upgraded ETP based on ZLD technology will be installed and commissioned by 30.06.2024.
7. The Environmental Engineer, Regional Office-2, Ludhiana shall monitor progress and submit compliance report of hearing decisions alongwith recommendations in the matter, accordingly.
The industry has submitted written reply to the above referred letter which is detailed as below :-
This is reference to your letter No. 1915 Dated 04/04/24 regarding proceeding of the personal hearing before the Honorable Chairman of the Board on 15.03.2024 w.rt. Show cause notice for revocation of consent to operate granted under the Water Act. 1974 along with notice to issue directions u/s 33-A of the Water Act 1974. In this notice it is stated that the industry shall submit Progress Evaluation and Review Technique (PERT) chart for installation of ZLD Plant within 15 days. The Industry shall install & commission ZLD plant by 31.05.2024 and shall complete its stabilization by 30.06.2024. The Industry shall submit Bank Guarantee of Rs. 50 Lacs, within 15 days.
The Submission the observation pointed out in notice is given below:-
1. The Govt. has constituted the committee of the experts to examine the alternative available to reuse the Treated Trade Effluent as well as review of the Policy of the State Government whether Treated effluent can be allowed to discharge into MC Sewer, so as not to affect Parameters of STP's at Terminal Point. We are waiting for the final decision of the Committee.
2. In view of the your direction and advise, We are in process to negotiating with the different suppliers to provide us complete economical viable ZLD with latest technology and called M/S lon Exchange President to have discussion on their latest technology and submitted the number of samples of effluent to their Gurugram Lab, & second in Mumbai Lab. Their proposal is awaited, we also received the proposal from M/s Hyper Filtration, Hydro-Tech Paryaveran, Zero Discharge Technologies Pvt. Ltd. commercial review of offers is under progress.
3. We request Punjab Pollution Control Board to implement this direction in the whole Punjab. The Implementation of ZLD only on large scale units in Ludhiana will make us incompetent in market considering installation and running cost of ZLD & we will be non-competitive. We will be left with no other option then to close unit & more than 3000 employees will be unemployed in our Garment Division. As such Textile Industry is going thru difficult times. We request your good self to look into it sympathetically.
Sir, in view of above submission, we are able to address all the observations mentioned in the letter 1915 dated 04.04.2024.Hope you understand our problem of non- submission of Rs.50 Lacs Bank Guarantee in such a tough time when the textile industry in whole world is moving towards recession.
Now, the industry has applied for renewal of consent to operate under the Water Act, 1974 alongwith requisite documents and same production capacity. The industry has already deposited Rs. 14,10,000/- vide UTR No. 208583665 dated 16.03.2020 on account of water consent fees, which is adequate for the period upto 31.03.2025.
The industry was visited by the EE & AEE of this office on 01.02.2024 and it was observed as under :-
1. The industry is engaged in process of spinning of yarn and dyeing of polyester, acrylic and same was in operation during visit.
2. The industry has installed 42 No. Cabnet dyeing machine and 25 No. Top dyeing machines of different capacities.
3. The industry has installed an ETP of capacity 4 MLD comprising of collection cum equalization tank, chemical dozing, primary clarifier, aeration tank, secondary clarifier, carbon filters & sand filters and decanter for dewatering of ETP sludge. The ETP was found in operation during the visit. The treated waste water was being discharged into M.C. sewer.
4. The industry has installed online continuous effluent monitoring systems (OCEMS) at the final outlet of the ETP leading to the M.C. sewer for analyzing of pH, COD, BOD & TSS of the treated waste water. The industry has installed electromagnetic flow meter at the final outlet of the ETP. The industry is getting the OCEMS calibrated regularly and has maintaining record of the same. The OCEMS are connected with the server of the Punjab Pollution Control Board as well as Central Pollution Control Board which are being verified by the RO from time to time.
5. The industry has installed 03 No. Submersible pumps for abstraction of ground water. Out of these three, 2 submersible pumps were in operation.
6. The industry is maintaining the record of ground water abstraction, treated wastewater and reuse of treated wastewater. The industry has submitted record regarding water abstraction and water reused in the process. As per the record maintained by the industry, the industry is discharging on an average of 2200 -2500 KLD of effluent at ETP outlet.
7. The industry has installed storage tank of capacity 16 Lacs Ltr for reusing of treated wastewater into the processing area. As per the record, the industry is reusing treated trade effluent @ 300-350 KLD on daily basis rest of the effluent is discharged into sewer.
8. The air emission smaple of the industry was collected on 01.02.2024 and as per the analysis report received, the SPM parameters has been found to be 112 mg/NM3, which is within the prescribed limits of the Board.
9. The industry has installed CCTV Cameras for online surveillance of various components of the ETP and stack of the boiler with IP address, ID & password 202.164.39.148, Admin and oswal12345, respectively. The industry has installed CCTV cameras at the following location :-
a) Overview of ETP components
b) Outlet of the ETP
c) Inlet of the ETP
d) At the stack of the boiler
10. The sampling of waste water was carried out on 01.02.2024 and as per the analysis report, the industry is conforming to the prescribed standards, which are given in the annotated form as under :-
SNo Parameter Outlet of ETP
1 Total Chromium (mg/l) BDL
2 SAR 3.5
3 Ammonical Nitrogen (as N) BDL
4 Phenolic Compounds (mg/l) BDL
5 Sulphide (mg/l) BDL
6 Oil & Grease (mg/l) BDL
7 Biochemical Oxygen demand (mg/l) 8
8 Chemical Oxygen demand (mg/l) 52
9 Total dissolved Solids(mg/l) 1019
10 Total Suspended Solids (mg/l) BDL
11 pH 7.4
It is further intimated that the industry was imposed additional conditions with the consent granted under the Water Act, 1974 are given as under :-
a. The industry shall ensure more than 50% treated trade effluent is utilized in the dyeing, cooling, boiler feed and any other process within 6 months and the industry shall explore the possibility for reduction in the quantum of abstraction of ground water.
Through, the industry is utilizing 300-350 KLD of treated effluent back in the process out of 2000-2500 KLD of treated effluent generated at the outlet of the ETP, however, the industry has failed to ensure that more than 50% treated trade effluent is reused in the process, as per the condition of earlier granted consent.
It is further informed that a meeting was taken by Sh. Gurmeet Singh Meet Hayer, Hon’ble Minister Department of Science, Technology & Environment, Govt. of Punjab on 19.10.2022 with the delegation of the Large scale dyeing units of Ludhiana for segregation of industrial effluents discharged into municipal sewer of Ludhiana in-compliance of directions u/s 5 of EPA, 1986 issued by the Department of Science, Technology & Environment, Govt. of Punjab vide order dated 10.10.2019 wherein it was decided that :-
‘All the Large Scale Dyeing units discharging their effluent into municipal sewer, Ludhiana shall take adequate steps to stop discharging their industries effluent into Municipal sewer, Ludhiana by 31.03.2024’
Further, PPCB vide its order dated 111 dated 12.03.2024 has constituted a committee headed by CEE, Ludhiana to consider the representation made by large scale dyeing unit to DC, Ludhiana to examine the possibilities and review of the policy of the State as to whether any type of industry could be allowed discharge into sewer so as not to effect performance of STP at terminal points. The Board vide above office order has also granted time to the large scale units upto 30.06.2024 to continue their operations till the committee submits its report
The representative of the industry has submitted that the industry is deliberating the installation of ZLD system with various vendors and has also submitted the technical offers and quotation from the different vendors for installation of ZLD process, however, the industry is lagging behind the timelines and considering the progress made by the industry till date. It is evident that the industry shall not be able to achieve the complete ZLD system by 30.06.2024 as not even the purchase order has been made by the industry yet. Further, the industry has not submitted bank guarantee of Rs. 50.00 Lacs till date.
In view of above explained facts, it is recommended that show cause notice for refusal of consent to operate may be issued to the industry alongwith personal hearing before the Competent Authority of the Board, please.
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