| File Note: |
Sir, pointwise reply to the observations raised by Competent Authority is as under: Observation No. 1: The date of ETP monitoring and its results. The ETP of the industry has been monitored by the Board on 22.05.2019, as per analysis result, the concentration of various parameter was found pH = 7.4, TSS = 112 mg/l, TDS = 1752 mg/l, COD = 380 mg/l, BOD = 129 mg/l, Oil & Grease = BDL, which was beyond the prescribed limit for such discharge onto land for plantation. Thereafter, the SCN under the provisions of the Water Act, 1974 was issued to the industry vide Board's letter no. 3491 dated 26.06.2019 due to the violations observed during visit dated 22.05.2019 (copy attached) with an opportunity of personal hearing before SEE, ZO, Bathinda on 05.07.2019/. After hearing it was decided as under: 1. The industry shall stabilized ETP atleat 15-20 days in advance before the operation of parboiling plant in the coming season and provide all the necessary equipments such as flow meter and energy meter. 2. The Regional Office shall visit the industry in coming paddy season, verify the contentions of the industry and submit report. Thereafter, the industry was visited by the officers of the Board during the ongoing paddy season on 30.12.2020 and it was observed that the industry was in operation for production of steamed rice by operating its parboiling section. During visit, emission samples were collected from port hole of stack attached with boiler of capacity 12 TPH and stack of APCD attached with paddy cleaner of parboiling section. As per analysis result of Board's lab, the concentration of SPM was found to be 311 mg/Nm3 and 458 mg/Nm3, respectively, i.e. is within the limits by the Board / State Govt. Thereafter, the industry has applied for varied of consents to operate granted under the Water Act, 1974 & the Air Act, 1981 for production of saila rice / steamed rice @ 6 TPH and raw rice / steamed rice @ 6 TPH along with sorted rice of capacity 12 TPH through OCMMS on 15.02.2021 along with analysis report of effluent sample got analyzed from Board's approved lab of M/s Eco Laboratories & Consultants Pvt. Ltd., Mohali, as per report the representative of the lab has collected the effluent sample from outlet of the ETP installed by the industry on 11.12.2020, as per result the concentration of pH = 7.58, BOD = 36mg/l, COD = 156mg/l, TDS = 707 mg/l and TSS = 67mg/l, which is within the prescribed limit for such discharge onto land for plantation. Thereafter the industry was visited by officer of the Board to check compliance on 17.02.2021 and found complying with the provisions of the Water Act, 1974 & the Air Act, 1981. Accordingly, the industry was granted Consent to operate under the Water Act, 1974 & the Air Act, 1981 with validity 31.03.2025 along with special conditions as under: 1. The industry will comply with the code of practice prescribed by the department of Science Technology and Environment vide office order no. 10/48/2004-STE(4)/2535 dated 15.10.2013. 2. This consent is granted to the industry for its premises in land area of 49 kanals 0 Marla only. The industry shall not increase its premises without prior permission of the Board. 3. The industry will get its air emission samples collected/analysed from the Boards’ Lab/approved Lab of the Board, within validity period of consent. The industry was visited by officer of the Board on 17.11.2021 and it was observed that the industry was in operation for production of steamed rice by operating parboiling plant. The ETP of the industry was in operation for stabilization only and no flow was observed at outlet of ETP. As such, effluent sample could not collected. The boiler section was in operation, one no. emission sample was collected from port hole of stack attached with boiler and as per analysis report, Particulate Matter was found 225 mg/Nm3, which is within the prescribed limit for such discharge. Also, one no. sample from stack of paddy pre cleaner attached with parboiling section was collected and as per analysis report, Particulate Matter was found 296 mg/Nm3, which is within the prescribed limit for such discharge. Thereafter, the industry was visited by officer of the Board on 19.11.2022 and it was observed that as under: 1. The industry was in operation for production of steamed rice & fortified rice. 2. No discharge was found at the outlet of parboiling section. 3. The industry has not installed water flow meters at the source of water supply and the outlet of ETP. 4. The industry is required to provide wall of adequate height around rice husk storage area. Observation No. 2: Total plantation area available for discharge of its treated effluent with documentary evidence of available land and its adequacy. The matter was discussed with representative of the industry and the industry has submitted record of land measuring 22 kanals 14 marlas under plantation area i.e. registry, aks chajra, site map showing location of the industry, ETP plantation etc and further submitted that the industry and its sister concerned unit M/s Shankar Agro Foods had developed plantation are in 6 acre. But, after partition, the land under ownership of the industry is 22 kanals 14 marlas under plantation. Same is adequate to handle effluent @ 150 KLD. Observation No. 3: How the new boiler of 6 TPH and dryer has been commissioned without CTE of the Board. The industry has submitted self declaration through Sh. Kewal Krishan, Director of the industry that they have 21 kanals land adjoining to the industry on the name of the ownership of the industry. They have obtained classification in the year 2021, but land added in the industrial premises during this year i.e. 2024. Therefore, the industry has applied for varied Consent to operate under the Water Act, 1974 & the Air Act, 1981 and has deposited NOC regularization fee. Observation No. 4: Whether, the effluent quantity will not increase with the increase in production and how Board will ensure that the industry will not produce parboiled rice with the increased raw material and production capacities. The industry has not provided pipeline for supply of water to handies of parboiling to rule out the production of saila rice. The industry will produce steamed rice from section -2 by installing new boiler of capacity 6 TPH and new dryer. Therefore, effluent quantity will not increase. Observation No. 5: Is the DTP certificate dated 05.08.2021 regarding land use still hold good. The industry has obtained classification report from DTP Faridkot vide memo no. 1130DTP(FDK)/MISC-25(Moga) dated 05.08.2021. Further, Master Plan of Baghapurana (2016-2031) has already been approved. Observation No. 6: When the APCD was monitored last and its results. The industry was visited by the officers of the Board during the ongoing paddy season on 30.12.2020 and it was observed that the industry was in operation for production of steamed rice by operating its parboiling section. During visit, emission samples were collected from port hole of stack attached with boiler of capacity 12 TPH and stack of APCD attached with paddy cleaner of parboiling section. As per analysis result of Board's lab, the concentration of SPM was found to be 311 mg/Nm3 and 458 mg/Nm3, respectively, i.e. is within the limits by the Board / State Govt. The industry was visited by officer of the Board on 17.11.2021 and it was observed that the industry was in operation for production of steamed rice by operating parboiling plant. The boiler section was in operation, one no. emission sample was collected from port hole of stack attached with boiler and as per analysis report, Particulate Matter was found 225 mg/Nm3, which was within the prescribed limit for such discharge. Also, one no. sample from stack of paddy pre cleaner attached with parboiling section was collected and as per analysis report, Particulate Matter was found 296 mg/Nm3, which is within the prescribed limit for such discharge. Observation No. 7: The details of fly ash disposal arrangements made by the industry not reported. The industry has provided room type enclosure of size 40'x40'x10' with arrangement to wet fuel ash for temporary storage of fuel ash, from where the nearby farmers lifted the fuel ash used in their fields as manure. The industry has also submitted regarding this In view of above if approved, CTO under the Water Act, 1974 and the Air Act, 1981 be granted to the industry for a period upto 31.03.2028/adequacy of consent fees for production of • Saila Rice / Steamed Rice @ 6 TPH alongwith rice sortex machine of capacity 6 TPH (from 1st set of machinery), • Steamed Rice / Raw Rice @ 6 TPH alongwith rice sortex machine of capacity 6 TPH (from 2nd set of machinery), respectively for premises in an area 70 kanals 07 marlas, subject to the following special conditions that:- 1) The industry will comply with the code of practice as notified by the Govt. of Punjab, Department of Science, Technology and Environment vide endst. no. 10/48/2004-STE(4)/932 dt. 15.10.2013. 2) This consent has been granted in supersession to the consent granted to the industry vide no. CTOW/Varied/MOG/2021/15165623 dated 20.04.2021, valid upto 31.03.2025. 3) The industry will maintain its ETP in line every time alongwith all mechanical fittings, filter media and flow meter at outlet of ETP during non-operation of parboiling plant and will maintain proper record regarding operation of ETP during operation of parboiling plant viz-a-viz generation of trade effluent. 4) The industry will ensure to depute technical person (s) for maintaining / stabilization / operation of ETP, failing which application for further extension / renewal of consent to operate under the Water Act, 1974 will not be considered. 5) The industry will submit prior schedule for operation of parboiling section to produce saila rice and stabilize the effluent treatment plant, well before the re-commissioning of parboiling section so as to ensure proper treatment of trade effluent from the said section for achieving the standards prescribed by the Board for such type of industries/discharges. 6) This consent is granted subject to the submission of analysis report of effluent samples by the industry from the Board’s lab within a period of two months after re-commissioning of the industry for operation of parboiling plant viz-a-viz achievement of effluent standards as prescribed by the Board for such type of industry/discharges as per said analysis report. 7) The industry shall always maintain the plantation area, so as to dispose off the treated effluent in efficient manner whenever it operates the Parboiling plant.
(reply in table form alongwith requisite documents is attached herewith) |
