| File Note: |
Sub: Opportunity of the personal hearing given before the Chairman of the Board on 25.04.2024 w.r.t. show cause notice for refusal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 to M/s Punjab Dyers Association (Focal Point Module), 8.65 Acre Land, Tajpur Road, Jamalpur Awana, Ludhiana.
The following were present:
On behalf of Punjab Pollution Control Board
Er. G. S. Majithia, Member Secretary, Punjab Pollution Control Board
Er. Pardeep Gupta, Chief Environmental Engineer, Ludhiana
Er. Pardeep Balu, Add. Senior Environmental Engineer, Zonal Office-1, Ludhiana
On behalf of the industry
No one attended the hearing.
The Add. Senior Environmental Engineer, Zonal Office-1, Ludhiana brought out that the Punjab Dyers Association (PDA) was earlier granted consent under the Water Act, 1974 vide no. CTOW/Renewal/LDH4/2023/22538966 dated 24/06/2023 valid upto 23/09/2023 for discharge of trade effluent into Budha Nallah after treatment through CETP of 40 MLD (Focal Point Module) and domestic effluent onto land for plantation through septic tank.
The SPV had submitted Bank Guarantee of Rs 1 crore valid upto 30.06.2025 as an assurance that the SPV will assure to upgrade the CETP and achieve the prescribed standards and the industry shall comply with the provisions of the Water Act, 1974, Air Act, 1981, Environment (Protection) Act, 1986 and/or another environmental law applicable to the industry and Rules, Circulars & Directions issued by the Board from time to time.
The PDA has now applied for obtaining renewal of ‘consent to operate’ under the Water (Prevention & Control of Pollution) Act, 1974.
The PDA has installed a CETP (40 MLD) for the treatment of effluent generated from the textile units situated in Focal Point area of the Ludhiana. Presently, 73 numbers of industries are members of the CETP and 65 no. of industries are discharging their effluent to CETP.
The CETP was visited by officers of the Board on 13.09.2023 and it was observed as under:
1. The CETP was in operation during visit and the treatment involves following steps:
Gravity Fed Effluent - Receiving Chamber - Coarse Screen - Raw effluent collection sump - Stilling chamber - Fine Screen à Equalization tank - pH Correction-I (Lime & FeSo4 Dosing) - Reactor Clarifier (Poly Dosing)* - pH Correction-II - SBR Basin (04 in numbers)** - Chlorine Contact Tank - Treated Effluent Disposal.
However, out of two grit removal screens, the mechanical screen was not in operation.
2. The various stages as shown by PLC was not in consonance with the operation carried out at the CETP, as there was some fault in the PLC system. The PDA has not recorded any comments/maintained record in this regard.
3. During visit, PDA was guided to provide temperature gauges at the equalization tank and SBR tanks and same may be connected with PLC in order to improve the efficiency of treatment and to avoid high temperature shock loading in SBR tanks.
4. PDA was also guided to provide log book at the CETP and designate a person from PDA, so that, whenever, any director of PDA visits the CETP, record of visit will be maintained.
5. The operator is not maintaining any record regarding sludge recirculation.
6. During visit, effluent samples were collected from the inlet as well as outlet of CETP and has been sent to Zonal Lab, Ludhiana for analysis.
7. As per analysis results of samples collected, all the parameters are within prescribed standards of MoEF/CC except TDS and Bio-assay.
8. It has installed 1 no. boiler of capacity 2 TPH with cyclone as APCD and a drier for drying of sludge and the same was yet under installation. However, it has not obtained any NOC regarding the same.
9. The industry is lifting the sludge into the vehicle of TSDF without providing any HDPE sheets and without filling in bags. No numbering and tagging was there. The sludge was got lifted in a crude manner.
10. The CETP is not maintaining record of generation of sludge in form-3 as required under Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016
11. The sludge was stored inside the room in shape of heaps. Though the unit is in the process of proving evaporator for drying the sludge.
The monthly effluent samples collected by the Board of the CETP are continuously not meeting with the committed standards as per the DPR submitted at the time of appraisal of the CETP scheme submitted to MoEF & CC for financial incentive.
The industry was issued show cause notice for refusal of consent to operate under the Water Act, 1974 and Air Act, 1981 & show cause notice for refusal of authorization under the Hazardous and other Waste (Management & Transboundary Movement) Rules, 2016 with hearing before Chairman of the Board on 09.10.2023, wherein it was decided as under:-
1. The PDA shall operate its CETP of 40 MLD capacity regularly and efficiently so as to achieve the prescribed standards.
2. The PDA shall apply with the above said observations within 15 days, failing which action as per law shall be taken without further notice in the matter.
3. The Environmental Engineer, Regional Office shall visit the CETP after 15 days and shall submit the detailed report with recommendations on merits.
4. The consent application under the Water (Prevention & Control of Pollution) Act, 1974 shall be decided on merits after compliance as above.
In compliance to hearing decisions, the CETP was visited by officer of the Board on 03.11.2023 and it was reported as under:
1. The CETP was in operation during visit.
2. Effluent samples were collected from the inlet as well as outlet of CETP and detail Comparison w.r.t. design standards as well as MoEF/CC standards of last 2 no. analysis report of samples collected is as under:-
Date 04.10.2023 03.11.2023 Standards Design Standards
Parameter Outlet Outlet MoEF/CC
pH 8.2 8.4 6.0 - 9.0 5.5-9.0
TSS 46 25 100 50
TDS 4621 4920 2100 Inlet TDS +/- 10 % variation
COD 212 128 250 100
BOD 27 16 30 10
O & G 7.2 4.6 10 10
Phenolic Compound 2.2 BDL 1 -
Sulphides 5.6 0.8 2 -
Amm. Nitrogen 14.3 1.9 50 2
SAR 29.4 24.2 - -
Total Chromium BDL BDL - -
RSC 8.8 7.9 - -
Bio-assay 20% survival of fish in 100% effluent in 96 Hrs. 70% survival of fish in 100% effluent in 96 Hrs 90% survival of fish in 100% effluent in 96 Hrs. 90% survival of fish in 100% effluent in 96 Hrs.
As per analysis result of sample collected, the parameters TDS and Bio-assay are beyond prescribed limits of the Board. comparison of analysis report of effluent samples collected on 03.11.2023 w.r.t. design standards as well as MoEF/CC standards, as per which, the conc. of parameters TDS= 4920 mg/l against prescribed limit of MoEF/CC standards 2100 mg/l, COD=128 mg/l against prescribed limit of design Standards = 100 mg/l, BOD=16 mg/l against prescribed limit of design Standards= 10 mg/l and Bio-assay = 70% survival of fish against design Standards of 90% survival of fish in 100% effluent in 96 Hrs.
Hence, as per analysis result of sample collected, the conc. of various parameters i.e. TDS, COD, BOD and Bio-assay are beyond the prescribed design standards of the Board.
The SPV has not submitted the time bound proposal for up-gradation and augmentation of the CETP along with PERT Chart so as to achieve the prescribed standards as well as the standards as mentioned in the DPR appraised at the time of approval of financial aid received from the Government for this CETP.
The association was issued show cause notice for refusal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 with hearing before Chairman of the Board on 12.01.2024, wherein it was decided as under :-
1. The PDA shall operate its CETP of 40 MLD capacity regularly and efficiently so as to achieve the prescribed standards.
2. 25% of Bank Guarantee of Rs 1.00 Cr. i.e. Rs. 25 lac submitted by the PDA be encashed.
3. The PDA shall comply with the above said observations within 15 days, failing which action as per law shall be taken without further notice in the matter.
4. The PDA shall submit the time bound proposal for up-gradation and augmentation of the CETP along with PERT Chart so as to achieve the prescribed standards as well as the standards as mentioned in the DPR appraised at the time of approval of financial aid received from the Government for this CETP, within 15 days.
5. The PDA shall submit the proposal for discharge of treated effluent onto land for plantation / irrigation to Board in time bound manner.
6. The Environmental Engineer, Regional Office shall visit the CETP after 15 days and shall submit the detailed report with recommendations on merits.
7. The consent application under the Water (Prevention & Control of Pollution) Act, 1974 shall be decided on merits after compliance as above.
8. For the non-achievement of effluent discharge standards, personal hearing be given to all the three CETPs of 50 MLD, 40 MLD and 15 MLD capacities.
9. The Senior Environmental Engineer, Zonal Office-I, Ludhiana shall inquire the matter regarding getting analysis report by the PDA.
As per analysis report received from Zonal Lab, Ludhiana for sample collected during surprise visit on 25.02.2024, parameter TDS is beyond the prescribed standards.
The Association is not complying with decisions of personal hearing held before Chairman of the Board on 12.01.2024.
In view of above, the Association was issued show cause notice for refusal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 with hearing before Chairman of the Board on 25.04.2024.
No one from the PDA attended the hearing. However, vide e-mail dated 24.04.2024 PDA has requested to give another date of hearing.
After considering material facts on record, the Chairman of the Board decided that another opportunity of personal hearing be given to the industry.
Submitted for confirmation and for conveying to the PDA and Regional Office, please. |
