| File Note: |
It is intimated that the project is a large-scale red category unit. Earlier, the industry was granted consent to operate under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/SAS/2023/22914420 dated 02.09.2023 having validity upto 01.03.2024 for manufacturing of r-Hepatitis B Vaccine @ 49315.7 Numbers/Day, Diphtheria Vaccine @ 136986.3 Numbers/Day, Pertussis Vaccine @ 136986.3 Numbers/Day, Tetanus Vaccine @ 273972.6 Numbers/Day, Cell Culture Vaccine @ 202739.7 Numbers/Day, Haemophilus Influenza Type B Vaccine @ 136986.3 Numbers/Day, Operation of R & D, Euphorbia Prostrate Herbal extraction @ 540 Kg/Year, subject to suitable conditions and special conditions that: -
1. The industry shall install single stage RO system within 2 months and utilize the RO permeate and RO reject as per proposal submitted to the Board.
2. Further, decision regarding installation of MEE by the industry shall be taken after adjudging the adequacy and efficiency of the single stage RO to be installed by the industry.
Earlier, the industry was given personal hearing given on 10/3/2023 by the Hon’ble Chairman of the Board. After hearing, it was decided as under:
1. The consent to operate granted under the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981 be revoked.
2. The industry shall deposit a bank guarantee of Rs. 50.0 Lacs (valid for one year) in the O/o Environmental Engineer, Regional Office, SAS Nagar within 7-days as an assurance to properly operate ETP and achieve the prescribed effluent standards and compliance with the environmental laws.
3. 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 / onto land for stagnation or into the ground at any time under any circumstances and will discharge only treated effluent onto land for plantation / irrigation conforming to the effluent standards prescribed by the Board / Ministry of Environment and Forests & Climate Change.
4. The industry shall regularly operate & maintain its effluent treatment plant and treated effluent shall be discharged onto land for plantation conforming to the effluent standards prescribed under the Environment (Protection) Rules, 1986 or by the Punjab Pollution Control Board, whichever are stringent.
5. The industry shall provide the R.O followed by MEE so as to achieve the zero liquid discharge (ZLD) and shall submit the time schedule mention in the PERT chart given by it for installation and commissioning and R.O followed by MEE.
In compliance to the decisions of hearing dated 10.03.2023, the industry has submitted bank guarantee of Rs. 50 lakh bearing no. 007NDDG00019624 dated 18/05/2023 valid upto 17/06/2024.
Now, the industry has applied for renewal of consent to operate under Water (Prevention & control of Pollution) Act, 1974 for same production capacity along with requisite documents.
The industry has submitted CA certificate mentioning the cost of the fixed assets of Rs. 22821.83 lakh. The industry has earlier deposited Rs. 11,29,000/- vide UTR No. AXTB231187296088 dated 28/04/2023 (Rs. 5,64,500/- each under Water Act, 1974 and Air Act, 1981). The consent fee deposited by the industry is adequate upto 31/03/2026.
The industry was visited by AEE of this office on 05.04.2024 and it was observed as under:
1. The industry was in operation and engaged in the business of manufacturing and formulation of Hepatitis B vaccine and various other products of vaccine.
2. The industry has constructed 04 blocks (VB 1-4) for the production of vaccine and 01 block constructed for herbal products. The industry has constructed 01 block of R& D purpose.
3. The industry has installed an effluent treatment plant consisting of collection tank, oil & grease trap, 02 no. equalization tanks, flash mixer, primary clarifier, SAFF-1, clarifier-1, SAFF-2, clarifier2, PSF and ACF, filter press (02 no.), sludge drying beds, which was in operation.
4. The industry has installed ETP of capacity 80 KLD. However, the actual discharge is about 70 KLD.
5. The effluent samples were collected during earlier visit on dated 19.05.2023, 29.11.2023 & 19.02.2024 from outlet of ETP and results are as under: -
Sr. No. Parameters Outlet of ETP( 19.05.2023) Outlet of ETP( 29.11.2023) Outlet of ETP( 19.02.2024) Prescribed Standards
1. pH 7.6 8.2 7.8 6.0-8.5
2. Total Suspended Solids mg/l 22 BDL 53 100
3. Total Dissolved Solid mg/l 753 1610 1451 -
4. Bio-chemical Oxygen Demand mg/l 16 13 9 30
5. Chemical Oxygen Demand mg/l 67 90 36 250
6. Phosphate mg/l 0.4 2.8 - 5.0
Sulphate mg/l - 172 - -
7. SAR 1.55 - 3.2 -
8. Ammonical Nitrogen mg/l 1.8 2.6 5.2 -
9. Phenolic Compund mg/l BDL - - 1.0
10. Cyanide mg/l BDL - - 0.10
11. Sulphide mg/l BDL - - 2.0
12. Oil & Grease mg/l BDL BDL BDL 10
13. Total Chrome mg/l BDL BDL - 2.0
14. Hexa Chrome mg/l BDL - - 0.10
15. Zinc mg/l 0.11 BDL 0.21 -
16. Copper mg/l BDL BDL BDL -
17. Arsenic mg/l BDL BDL BDL 0.20
18. Lead mg/l BDL BDL BDL 0.10
19. Mercury mg/l BDL BDL BDL 0.01
20. Bio Assay 90 % survival of Fish in 100 % effluent after 96 hours 90 % survival of Fish in 100 % effluent after 96 hours 90 % survival of Fish in 100 % effluent after 96 hours 90 % survival of Fish in 100 % effluent after 96 hours
As per analysis report all the parameters are within the prescribed limits of the Board.
6. The industry has also installed STP of capacity 20 KLD for treatment of domestic effluent consisting of collection tank, primary clarifier, aeration tank, secondary clarifier, pressure sand filter and activated carbon filter and the same was in operation during the visit.
7. The industry is maintaining the record of wastewater treated by the ETP and electricity consumed in the operation of the ETP.
8. The industry has installed RO for requirements of its manufacturing unit VB1 and VB3. The Ro-reject generated from the process unit is about 15 KLD is now being passed through tertiary RO system and treated permeate is being used in boiler &cooling tower and RO reject is again fed to the inlet collection tank. Due to the installation of tertiary RO their will be fresh water saving of 17-23 KLD.
9. The industry has developed plantation in an area of about 5 acres in four stretches as per Karnal Technology for the utilization of treated wastewater.
10. The industry has installed online continues effluent monitoring systems at the final outlet of the ETP and the reading was noted to be Ph =9, TSS= 40.6 mg/l, BOD= 16.97 mg/l, COD= 77.33 mg/l.
The industry has now submitted a request letter in this office stating that the proposal earlier submitted by the industry for installation of RO after the ETP is not feasible. As the RO reject generated after ETP is not meeting the requirement for boiler feed as well as cooling towers and the same has to be discharged onto land for plantation only.
Now, the industry has installed Tertiary RO treatment plant for reduction in TDS of reject RO water after VB1 and VB3 production sections. This RO system will reduce the TDS to less than 50 mg/L and then the water can directly be used as feed to boiler & it’s all parameters were also meeting our requirement for boiler feed. This will reduce the consumption by 17 - 23 KL per dayof extracting ground water from the bore well.
Further, the industry had earlier requested that as the TDS of the effluent is very low, installation of MEE will not be economically viable.
Recommendations w.r.t installation of RO
Sir, it is submitted that the industry is not an API unit and is a vaccine manufacturing biotech unit. The manufacturing process of the industry do not require reactors and salts as required in other pharmaceutical industries and the vaccine is prepared through inactivated protein and cell culture based production.
The industry doesn’t generate any waste ML or High TDS effluent and the effluent is only generated through CIP/equipment washing and is low TDS in nature. Further as per last 3 sampling results, the TDS of treated effluent is i.e 753 mg/l, 1610 mg/l & 1451 mg/l. The industry has adequate land for disposal of treated effluent.
With the installation of Tertiary RO, the industry has achieved water saving of about 20 KLD.
The installation of MEE may result in water saving but lead to increase in additional boiler load vis-s-vis energy consumption. Also, the industry will need additional freshwater to maintain the green belt and plantation already provided by it. So, the net environmental benefits achieved by installation of MEE in such type of industries seems to be minimal in presence of alternate disposal arrangements (plantation area) already provided by the industry.
In view of above, it is recommended that;
1. The request of the industry and the recommendations of this office may be placed before the competent authority for exemption from installation of MEE and RO after ETP by the industry.
2. The bank guarantee of Rs. 50 lacs submitted by the industry may be returned as the industry has been found complying during last three visits.
3. Consequent to decision at pt. 1, the ‘Consent to Operate’ under the Water (Prevention & Control of Pollution) Act, 1974 may be granted to the industry upto 31.03.2026, subject to suitable conditions and following additional conditions:
I. The industry shall operate its ETP and STP regularly and efficiently and treated effluent shall be discharged onto land for plantation conforming to the effluent standards prescribed by the Board.
II. The industry shall ensure that no effluent (treated/untreated) is discharged into any sewer/nallah/Choe etc.
III. 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.
IV. 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.
V. In case the industry 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 – Hon’ble Chairman of the Board
Date of Deemed Approval : 15.05.2024 |
