| File Note: |
It is submitted that the industry was granted consent to operate under the Water Act, 1974 vide no. CTOW/Fresh/PTA/2020/13525135 dated 23/10/2020 and under the Air Act, 1981 vide no. CTOA/Fresh/PTA/2020/13525148 dated 23/10/2020, both are valid upto 30/06/2025 for manufacturing of Aluminium Profile other industrial products @ 10 MTD by using Aluminium Scrap/Ingots @ 10.6 MTD as raw material with the certain condition mention therein.
As per the record file, the industry was visited by officers of the Board on 06.12.2022 and it was observed as under:
1. The industry was in operation and engaged in production of aluminum products by using aluminum scarp/ingots. No machinery w.r.t. pickling and anodizing has been installed in the premises and only degreasing activity of billets is carried out presently in the industrial premises.
2. The industry has provided one no. melting furnace capacity of 5 Ton/batch based on furnace oil equipped with water scrubber as APCD and adequate stack height. The representative informed that furnace was not in operation from last 4 days, due to non-availability of raw material.
3. The industry has provided pre-heater for billets based on PNG and electric oven for aging of extruder products.
4. The ETP provided by the industry for treatment of effluent generated from degreasing of dyes and saturated water of scrubber provided with furnace, was not in operation and was found in abandon condition.
5. No dosing chemical/flocculent was found provided at location of ETP for dosing.
6. The meter provided at final outlet of ETP is not in operational condition.
7. No proper pipeline network for utilization of treated effluent for plantation purpose has been provided.
8. The sand filter and carbon filter provided as component of ETP were found in choked condition.
9. The effluent of RO system installed near main gate of the industry was found discharged through pucca channel in the drain passing nearby to the industry. It has been apprehended that the industry might be discharging its trade effluent without treatment through this pucca channel for disposal into drain.
10. The industry has not provided flow meter with the source of fresh water supply in its premises.
Accordingly, the industry was issued notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 alongwith the opportunity to personal hearing before the Chief Environmental Engineer (P) of the Board on 30.01.2023 issued vide Board's letter no. 379 dated 18/01/2023. After hearing, it was decided that:
1. The industry shall submit a Bank guarantee amounting to Rs. 2 lakh as an assurance to comply with the environment laws within 7 days.
2. The industry shall not install any pickling and anodizing machinery without prior permission of the Board.
3. The Environmental Engineer, Regional Office, Patiala shall visit the industry immediately after 15 days to verify the contentions of the representative of the industry and submit his conclusive report/recommendations immediately thereafter.
4. Further action, shall be taken after the receipt of report/recommendations from the Environmental Engineer, Regional Office, Patiala.
The proceedings of the hearing were conveyed to the industry vide Board's letter no. 1869 dated 21/03/2023.
In compliance of the decision no. 1, the industry had submitted a bank guarantee bearing no. 0506223BG0000347 dated 15.4.2023 amounting to Rs. 2 lacs, valid upto 14.4.2024.
Now, to check the compliance of the above said decisions, the site of the industry was again visited by the officers of the Board along with scientific staff on 20.10.2023. During visit, it was observed as under:
1. The industry was in operation.
2. The industry has installed 1 no. oil fired aluminium melting furnace of capacity 5 TPD, which was also found in operation.
3. The industry has provided wet scrubber as APCD with the melting furnace, which was found not in operation during the visit as the motor of the same went out of order.
4. The industry has provided preheated for billets based on PNG and electric oven for aging of extruder products.
5. The industry was not operating its wet process and only domestic effluent was being generated.
6. The industry has installed STP plant for treatment of its domestic effluent, which was also found not in operation. The representative of the industry informed that the same is being operated on batch basis and the treated wastewater is used for makeup of scrubbing water in wet scrubber or onto land for plantation.
7. The industry has not provided proper plantation area within the premises for utilization of treated domestic effluent.
8. The industry could not show the record regarding generation / disposal of its hazardous waste pertaining to category no. 5.1, 35.1 and 35.3.
9. During visit, stack emission sampling was also carried out and as per the analysis results, the level of SPM was found to be 476 mg/Nm3 against the prescribed limits of 150 mg/Nm3. Hence, the industry is not conforming to the emission standards.
10. As per the latest Fuel policy notified by the Punjab Government dated 4.10.2023, furnace oil and other liquid oil containing high sulphur content are banned to be used as fuel, however, the industry is still using furnace oil to operate its melting furnace.
As such, notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as amended in 1988 & 31-A of the Air (Prevention & Control of Pollution) Act, 1981 as well as notice before encashment of the bank guarantee has been issued to the industry with an opportunity to appear in person before the Chief Environmental Engineer(P) Punjab Pollution Control Board, Vatavaran Bhawan, Nabha Road, Patiala on 07/12/2023 vide Board's letter no. 9093-94 dated 29/11/2023. After hearing, it was decided that:
1. The industry shall completely shift its unit on PNG by 15/01/2023 till then it shall use only fuel in its melting furnace, which is authorized as per fuel policy of the Board.
2. The consent to operate granted by the Board under the Water (Prevention & Control of Pollution) Act, 1974 & the Air (Prevention & Control of Pollution) Act, 1981 shall be revoked.
3. The industry shall apply for obtaining revised consents to operate under the Water (Prevention & Control of Pollution) Act, 1974 & the Air (Prevention & Control of Pollution) Act, 1981, without any wet process, within 07 days.
4. The industry shall carry out CER activity in its area including distribution of Jute Bags in the school / social places amounting to Rs. 1.0 lac, within one month.
5. Environmental Engineer, Regional Office, Patiala shall visit the industry, verify the compliances, collect the sample and process the consent applications to be applied by the industry and submit its report, within 01 month.
6. Further action shall be taken after the receipt of the report of the Regional Office.
The proceedings of the hearing were conveyed to the industry vide Board's letter no. 9993 dated 08/01/2024.
Accordingly, the consents granted under the Water Act, 1974 and Air Act, 1981 were revoked / canceled vide Board's letter no. 10280-81 dated 16.01.2024 and no. 10282-83 dated 16.01.2024, respectively.
Therefore, the industry had applied for obtaining fresh consent to operate under the provision of Water Act, 1974 and Air Act, 1981 alongwith requisite documents.
Accordingly, the industry was re-visited by the officers of the Board on 18.03.2024 and it was observed as under:
1. The industry was in operation.
2. The industry has installed 1 no. aluminium melting furnace of capacity 5 TPD, which was also found in operation.
3. The industry is now using LSHS as fuel in its melting furnace, which is having 0.5% sulphur content as per the test report submitted by it.
4. The industry has provided wet scrubber as APCD with the melting furnace, which was found in operation.
5. The industry has provided pre-heater for billets based on PNG and electric oven for aging of extruder products.
6. The industry is not operating its wet process and hence only domestic effluent was being generated.
7. The industry has installed ETP for treatment of trade effluent generated from wet process. However, the same is not being operated due to non-operation of wet process.
8. The industry has provided septic tank for treatment of its domestic effluent and the treatment effluent is discharged onto land for plantation alongwith boundary.
9. During visit, stack emission sampling could not be carried out due to non-availability of laboratory staff.
It is pertinent to mention here that as per the latest Fuel policy notified by the Punjab Government dated 4.10.2023, furnace oil and other liquid oil containing high sulphur content are banned to be used as fuel, however, the industry in its reply has mentioned as under:
"Regarding the furnace fuel change, we've proactively communicated our decision to transition from PNG to LSHS. This decision was made due to the high cost associated with PNG gas, which we found unsustainable for our operations. Our correspondence dated January 27, 2024, included a comparison sheet highlighting the economic feasibility of LSHS over PNG. This decision aligns with the fuel policy of the Punjab Government, further supporting our rationale for the transition".
Accordingly, the industry is now using Low Sulphur Heavy Stock fuel (LSHS) to operate its melting furnace, which is having sulphur content less than 1.8 %, which is not banned as per the fuel policy.
Regarding, the decision no. 4 of personal hearing, the industry has purchased Jute Bags of Rs. 1.0 lakh approximately (bill enclosed) and the same were distributed alongwith officer of the Regional office Patiala at Govt. School of Eminence, Vill. Mardanpur, Tehsil Rajpura, Distt. Patiala on 19.04.2024.
However, the industry was issued show cause notice for refusal of consent to operate under the Water Act, 1974 and the Air Act, 1981 vide Board's letter no. 01 dated 01.04.2024.
The point wise reply submitted by the industry w.r.t SCN and comments of this office is enclosed in the attachment.
Now, the industry has again applied for obtaining fresh consent to operate under the Water Act, 1974 and the Air Act, 1981.
The earlier consent fee deposited by the industry was adequate upto 07.07.2025 against the fixed assets of Rs. 646.12 lacs as per CA certificate submitted by it.
The industry has also deposited additional fee of Rs. 72000/- vide UTR no. SBIN124058403835 dated 27.02.2024 on account of water Act, 1974 and Rs. 72000/- vide UTR no. SBIN124058403851 dated 27.02.2024 on account of Air Act, 1981 against the fixed assets of Rs. 983.93 lakh as on 31.03.2023 as per CA certificate dated 29.01.2024, which is adequate upto 30.06.2029 after deducting a penalty charge of Rs. 1800/- under each Acts (10%) due to revocation of consents.
The industry also deposited Rs. 11300/- (Rs. 10800/- as NOC regularization fee and Rs. 500/- as application form fee) vide UTR No. SBIN124058402210 dated 27.02.2024 due to increase in fixed assets.
As mentioned above, the industry is now complying with the provisions of the Water Act, 1974 and the Air Act, 1981 and also with the observations mentioned in the show cause notice except shifting entirely to PNG, regarding, which the industry has submitted that shifting of the entire fuel is not economical viable at this stage and therefore, the industry is using liquid fuel having sulphur contents less than 1.8% and therefore is complying with the fuel policy notified by Govt. of Punjab dated 04.10.2023.
In view of above, if approved, recommendations be may be sent to SEE, ZO-1 Patiala that:
1. Notice to issue directions u/s 33-A of the Water Act, 1974 and u/s 31-A of the Air Act, 1981 may be dropped.
2. Fresh consent to operate under Water Act, 1974 and Air Act, 1981 be granted to the industry for manufacturing of Aluminium Profile other industrial products @ 10 MTD by using Aluminium Scrap/Ingots @ 10.6 MTD upto 31.03.2029 with the usual conditions and special conditions as under:
1. The industry shall not operate its wet process at any time.
2. The industry shall explore possibilities to completely shift its fuel to PNG.
3. This consent granted to the industry is only for the machinery/process installed by it as per the application submitted to the Board.
4. The industry shall maintain record regarding consumption viz a viz generation/disposal of the waste water.
5. The industry shall comply with the guidelines of Punjab Ground Water Regulatory Authority (PWRDA) and obtained necessary permission from the department (if any).
6. The industry shall immediately apply to obtain authorization under HWM Rules, 2016 to the Board. |
