| File Note: |
Subject: Proceeding of the personal hearing given on 23.04.2024 before the Chairman of the Board 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 -M/s The Simplex Metal Processors (I) Pvt. Ltd., Morinda Rupnagar Road, Village- Pathreri Jattan,Chamkaur Sahib, Rupnagar.
The following were present:
From the Board side:
1. Er. G.S. Majithia, Member Secretary
2. Er. Pardeep Gupta, Chief Environmental Engineer (P)
3. Er. Lavneet Kumar, Senior Environmental Engineer (ZP-1)
4. Er. Navtesh Singla, Environmental Engineer (ZP-I)
From the industry side:
1. Sh. Sham Sunder Mehta, Executive Director
2. Sh. Vikas Moudgil, Plant Head
The Environmental Engineer, Zonal Office-1, Patiala brought out that: -
The industry was granted to 'Consent to Operate' under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/RPN/2022/18274455 dated 09/06/2022, valid upto 31/03/2023 and under Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/RPN/2022/15903237 dated 23/05/2022, valid upto 31/03/2023 for manufacturing of Chassis Frame @ 120 Nos./Day and CED Painting of Component @ 1000 Nos./Day by using Paint @ 120 KL/day, PT Chemicals @ 50 KL/day, Cross Member @ 720 Nos./Day, Chassis Long Member @ 240 Nos./Day and Matting Part @ 1000 Nos./Day, subject to conditions as mentioned therein.
The industry was given personal hearing before the Chairman of the Board on 02.06.2023 and wherein it was decided as under:
1. The industry shall deposit the EC amounting to Rs. 10 lakh on the polluter pay principal basis and also submit a bank guarantee of Rs. 10 lakh as an assurance to comply with the Environmental norms, within 15 days.
2. The industry shall apply for 'consent to operate' under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981, within 15 days.
The industry has now applied for obtaining renewal of consents to operate under Water (Prevention & Control of Pollution) Act, 1974 & the Air (Prevention & Control of Pollution) Act, 1981 alongwith requisite documents.
The industry was visited by the officer of the Regional Office, Patiala on 27.12.2023. During visit, Sh. Vikas Mudgal, GM Operations of the industry was contacted and the observations made during visit are as under: -
1. The record of production and raw material consumption is not produced by the industry.
2. One submersible pump is installed as source of fresh water and water meter is provided with the same and its reading noted as 1.51 m3. As per record maintained, it is abstracting ground water about 3.58 m3/day only.
3. The fresh water is used in the process in various streams. The water is installed at the raw water line to the process and reading is noted as 8133.74 m3. One water meter is installed at the RO reject line and its reading is noted as 2636 m3. As per record, it is producing 3.83 m3 of permeate and 2.75 m3 reject per day from the RO system.
4. ETP is installed for treatment of trade effluent and found out of order. The Representative of the industry informed that there is electric circuit problem. The ETP was got operated during visit and the components of the ETP are as under:
Oil and Grease Trap ‣ Collection Tank ‣ Equalization Tank ‣ Primary Settling ‣ Aeration ‣ Secondary Settling ‣ Pre-filter Tank ‣ Sand Filter ‣ ACF ‣ Sludge Drying Beds.
5. STP is installed for treatment of domestic effluent and its components are as under:
Collection tank ‣ Throttle Tank ‣ Pre-Filter Tank ‣ Filter ‣ Outlet.
6. The wastewater samples from the outlets of the ETP and the STP were collected. The ETP and STP outlet wastewater were found Turbid.
7. The ETP outlet is provided with the water meter and its reading is noted as 231.26 m3. Separate energy meter is also installed with the ETP and reading is noted as 14997.3 KWh. As per record, it is treating wastewater about 3.66 m3/day and consuming electricity about 12 KWh/day.
8. The STP outlet is provided with the water meter and its reading is noted as 2859.28 m3. Separate energy meter is also installed with the STP and reading is noted as 424.1 KWh. As per record, about 1.92 m3/day of wastewater is treated in the STP. However, as per manpower working in the industry i.e about 170 employees, the water consumption comes out to be about 7.5 KLD and the wastewater generation @ 6 KLD.
9. As per record of the industry, it is abstracting only 3.58 m3/day of fresh water and consuming 6.58 m3/day in RO system and 7.5 m3/day (as per manpower) for domestic consumption, which doesn’t balance the material. It clearly indicates that there is another source of fresh water. Also, the wastewater treated in the ETP as well as STP is very less as compare to the consumption in the respective fields. Further, in the application it has claimed 20 KLD of fresh water abstraction, 5 KLD domestic consumption, 15 KLD process consumption, 5 KLD domestic effluent and 13.1 KLD trade effluent. The quantities mentioned in the application are not inconsonance with quantities as per record maintained by the industry.
10. Further, the industry has provided mechanical water meters with various lines which are going out of order frequently and are being replaced accordingly. The industry requires to install EMF at its submersible pump and wastewater treatment facilities.
11. The treated wastewater is discharged onto land of area about 0.8 acres for wide distanced plantation / grass lawn inside the industry. It has maintained the plantation area but is not developed as per Karnal Technology. The industry requires to provide proper ridges and furrows in the plantation area for proper utilization of treated wastewater.
12. The industry has installed Phosphating process generating acid / alkaline fumes. A wet scrubber is installed as APCD with the phosphating tank alongwith stack above the roof level. Separate energy meter is provided with the same and the reading is noted as 3530.5 KWh. No sampling arrangement is provided with it.
13. The industry has not installed emission control system with other surface treatment process.
14. Lot of fumes found generating from the multiple welding operations for which there is no emission control system is provided.
15. One Baking oven is installed of capacity about 12 pc/hr using LPG @ 50 kg/hr as fuel. No stack / emission control system is installed.
16. One Top coat of capacity about 12 pc/hr is installed. Two water tanks are provided wherein the ducts from top coat section are submerged to wash the emissions. This emission control system is not adequate as black particles are deposited on the building wall adjoining to these tanks. There is no stack after the water tanks.
17. Hot water generator is installed using LPG @ 0.2 Kg/hr as fuel. A stack of about 5 ft above the roof level is provided with the same.
18. DG set of capacities 160 KVA and 62 KVA are installed which are provided with the canopies and stack of height about 4 ft and 5 ft, respectively above DG sets.
19. The industry is generating hazardous wastes of categories 5.1, 5.2, 12.1, 12.5, 21.1, 33.1, 33.2, 35.1, 35.3, 35.4.
20. The record of the hazardous wastes is maintained. As per record, the hazardous wastes lifting date, lifting quantity and stored on date at site is as under;
a. 5.1 – 05.06.2023 – 220 lt – 100 lt
b. 12.5 – 20.07.2023 – 1970 kg – 1553 Kg
c. 21.1 – 20.07.2023 – 5325 kg – 608 Kg
d. 21.1 – 05.06.2023 – 108 no. – 23 no.
e. 21.1 – 05.06.2023 – 02 no. – 02 no.
f. 35.3 – 20.07.2023 – 975 Kg – 1022 Kg
1. The record of category 5.2, 12.1, 33.1, 33.2, 35.1 and 35.4 is not produced.
2. The agreement with the authorized recyclers / TSDF is executed for hazardous wastes.
3. A storage room of size about 16’x10’x8.5’ is provided which is having lock and key facility and danger sign is displayed outside it. The capacity of the room is not adequate for the specified time period.
4. It also has made provision for storage of hazardous waste in form of a shed. The shed is having cemented floor and walls on three sides and the fourth side is of wire mesh gate. The roof of shed is not fixed properly and is having perforations and cracks in it. Further, some part of roof is covered with tarpaulin sheet. Lock and key provision is given with the said facility. The storage of hazardous waste in this shed is require to be maintained properly.
5. The environmental data board of appropriate size and information is not displayed at main gate.
6. The solid water is not segregated.
7. No vermicomposting / composting is provided.
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 intentionally and deliberately. Further, it has not complied with the decisions of the personal hearing dated 02.06.2023.
Show cause notice for refusal of 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 was issued vide Board's letter no. 10277 dated 16.01.2024 alongwith the opportunity to reply within 10 days.
The industry has submitted reply of the show cause notice dated 25.01.2024 issued to it for non-compliance.
The industry was visited by the officer or Regional Office, Rupnagar on 09.02.2024 to check the compliance of observations raised in the show cause notice. It was observed that:
1. The industry was in operation and involved in the process of manufacturing of chassis frames and CED painting of components.
2. The industry has installed EMF at the main source of water supply i.e. borewell and started maintaining record of it. The average water consumption is ranging from 4 KL to 13.5 KLD, however, it was observed that the water usage was 20.3 KL on 28.01.2024 (the day when phosphating rinsing tank was refilled). The industry has maintained printed logbook of water consumption w.e.f 01.02.2024.
3. The industry is also maintained energy meter readings for scrubber provided with phosphating section and top coat paint booth.
4. The industry has installed an ETP of capacity of 30 KLD which was operational during visit. It was observed that the outflow of water meter provided at ETP ranges from 2 KL to 6 KL, as per the register maintained by the industry.
5. The plantation area has been developed as per Karnal technology and work for maintaining ridges furrows was under progress at the time of visit.
6. The analysis results of ETP and STP effluent samples are within the permissible limits.
7. The industry has provided port-hole alongwith sampling platform (phosphating platform overhead) at the stack attached with APCD of phosphating process.
8. The industry has informed that new wet scrubber has been got designed and purchase order has been given to M/s Kalyan Projects Construction Company, SAS Nagar on 05.02.2024. The same shall be installed by the industry latest by 01.04.2024.
9. Stack height of hot water generator was found 5 feet and the same will be increased by 10 feet by local fabricator within this month.
10. One LPG operated baking oven has been provided by the industry, but the stack of same is yet not provided.
11. Further, the industry has revised agreement with M/s RAMKY / Nimbua for disposal of haz. Waste of cat. 5.2, 12.1, 12.5, 21.1, 35.1, 35.3 and 35. It is further informed that the industry has not deposited the EC of Rs. 10 Lacs and the Bank Guarantee of Rs. 10 Lacs in compliance to the decisions of the personal hearing held on dated 02.06.2023, however, the industry has intimated that it has submitted the written request letter to Competent Authority for waiving of Environment Compensation and Bank guarantee being it has now complying with the Environmental norms.
The industry is yet to make complete compliance of the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981 and has not yet deposited the Environment Compensation amounting to Rs 10.0 lacs and bank guarantee of Rs. 10.0 lacs in compliance to the decision of the hearing giving to it on 02.06.2023.
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.
As such, 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 has been issued vide Board's letter no. 42 dated 02.04.2024 with an opportunity to appear in person before the Chairman of the Board on 23.04.2024.
The representative of the industry attended the hearing and submitted that it has complied with the observations of the visiting officer of the Board. He further informed that he has already installed wet scrubber on its top coat painting section, provided stack on adequate height with its LPG baking oven and also developed plantation area as per the Karnal Technology. He further requested to grant the consents and also exempt the company for deposition of bank guarantee and Environmental Compensation imposed on it during the last hearing.
After hearing the officers of the Board and the representative of the industry, the Chairman of the Board decided as under: -
1. The industry shall deposit Environmental Compensation amounting to Rs. 10.0 lakh in five monthly installments of two lakh each. The industry shall deposit its first installment of Rs. 2.0 lakh within 3 days to the office of Environmental Engineer, Regional Office, Rupnagar alongwith postdated cheques for remaining four installments to be deposited.
2. A team of officers consisting of Er. Navtesh Singla, Environmental Engineer, Zonal Office-I, Patiala and Er. Gurkaran Singh, Assistant Environmental Engineer, Regional Office, Patiala shall visit the industry, verify the compliance of the violations reported by Regional Office, within 7 days and submit its report. In case, the industry found complying with the observations/ non-compliances as contended by it in the hearing, the bank guarantee amounting to Rs. 10.0 lakh earlier imposed on it shall be waived off otherwise the industry shall submit the bank guarantee amounting to Rs. 10.0 lakh immediately to the Board.
3. The application for obtaining consent to operate under the Water Act, 1974 and the Air Act, 1981 shall be decided after the receipt of the report of the team constituted at Sr. No. 2.
If approved, the proceedings may be conveyed to the industry as well as Regional Office for compliance, please. |
