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It is submitted that visit was carried out by the following team of officers constituted by the Competent Authority of the Board as per the decisions of the personal hearing given to the industry:
1. Er. Navtesh Singla, EE (ZP-1)
2. Er. Gurkaran Singh, AEE (RO, PTA)
During Visit, Sh. Vikas Mudgal, GM operations was contacted at site. During visit, it was observed as under:
Water Pollution and its Control:
1. The phosphating process and the painting process was not in operation however only welding operations were going on at site.
2. The industry has installed one submersible pump as source of fresh water and electronic magnetic water flow meter has now been provided with the same and its reading noted as 2.03 m3/hr (Totalizer 1655.25 m3). As per record maintained, ground water abstraction has varied from 174 KL/month (7.9 KLD) to 486 KL/month (19.48 KLD) from Jan to April 2024.
3. The water meter is installed at the raw water line which is being given to the RO feed (Double Stage RO) and reading is noted as 911.7 m3. As per record maintained, raw water abstraction has varied from 77 KL/month (6 KLD) to 335 KL/month (14 KLD) from Jan to April 2024.RO permeate is being given to Hot water generator and DM plant. The DM water and part hot water from hot water generator is being given to PT /phosphating section. As per record maintained, RO reject has varied from 36 KL/month (3.6 KLD) to 107 KL/month (4.8 KLD) from Jan to April 2024.It can be inferred that RO permeate has varied from 41 KL/month (4.1 KLD) to 228 KL/month (10.3 KLD) from Jan to April 2024.
4. The industry has installed ETP for treatment of trade effluent generated from the pretreatment including phosphating as well as cathode electronic deposition line. The components of the ETP are Oil and Grease Trap, Collection tank, Dozing cum mixing tank, Primary Settling tank, Aeration, Secondary Settling, Collection tank, Sand Filter, ACF and Sludge Drying Beds.
5. During visit no flow at the inlet and the outlet was available. The rep. of the industry informed that dozing of lime , DAP, Urea in the collection cum mixing tank is being done and Sodium Hypochloride solution dozing is done after the secondary clarifier in the collection tank. The rep. informed that dozing on approximate basis is done when the water comes in the inlet of ETP.
6. The industry has provided EMF at the outlet of ETP and the totalizer reading noted is 806.87 m3. As per the record maintained by the industry ETP outlet has varied from 70 KL/month (3.5 KLD) to 190 KL/month (8 KLD) from Jan to April 2024.
7. The rep. of the industry informed that about 50 KL /week of effluent is discharged from the PT line mainly from rinsing section. All the tanks are washed and cleared once a year as informed by the rep. of the industry.
8. STP is installed for treatment of domestic effluent and its components are as under: Collection tank Throttle Tank Pre-Filter Tank Filter Outlet. The STP outlet is provided with the mechanical water meter and its reading is noted as 107.91 m3. New flow meter has been installed on 27/3/2024. As per record maintained, treated domestic effluent has varied from 75 KL/month(3.5 KLD) to 71 KL/month (3.5 KLD) from Jan to April 2024.
9. The industry has tried to provide ridges and furrows (with Popular tree plantation in the furrows) as required to provide Karnal Technology but these are found not properly maintained i.e. uneven distribution of treated wastewater along with wild grass.
10. Flexible pipeline has been installed from the outlet of ETP to the plantation area .
11. The RWH well now has been blocked with stones.
Air Pollution and its Control:
1. It 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.Sampling arrangement has also been provided.
2. The industry has provide fume control system in one section of the welding section but is required to provide complete fume suction mechanism on the multiple welding operations.
3. One LPG fired Baking oven is installed .New stack along with hoods at the entry and exit level have been provided.
4. One Top/ spray painting section has been provided and it has provided Twin water scrubber to scrub emissions from this section. The water scrubber(APCD) is not having stack and sampling arrangement. The rep. informed Kalyan Fabricators Mohali have installed the wet scrubber and they informed that stack arrangement is not required .
5. LPG fired Hot water generator is installed and a new stack of about 3 m above the roof level has been provided with the same.
6. 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.
Hazardous waste Management:
1. The industry has provided separate impervious room for storage of its hazardous waste and is maintain record of generation of hazardous waste of categories 5.1, 5.2, 12.5, 21.1, 33.1, 35.3, 35.4. The industry has clubbed paint residue ,waste cotton (paint mixed), paint chemical sludge /filters/membranes under cat 21.1. Also industry taken waste cotton oil mixed under category 5.2.
2. The agreement with the authorized recyclers / TSDF is executed for hazardous wastes.
3. The danger sign board outside the hazardous waste room and environmental data board outside the main gate has been provided .
Conclusion:
Although the industry has make the compliances of the most of the observations earlier made by the visiting officer of Regional Office Roopnagar, However, the industry is required to make the following additional compliances:
a) The industry is required to make proper ridges and furrows in its plantation area for uniform distribution of the treated waste water.
b) The industry is required to immediately remove flexible pipeline and provide permanent pipeline to carry treated effluent from ETP outlet up to plantation area.
c) Since the industry is adding various chemicals like urea, DAP, lime and polyelectrolyte on approximate basis at various stages in the ETP therefore, it is required to make proper chemical dozing arrangements and should get the dozing of chemicals optimized by way of conducting jar test. Moreover, the polyelectrolyte dozing after the secondary clarifier shall lead to addition of solids in the treated effluent and the industry is required to reassess the treatment methodology alongwith quantity of chemicals being added in the ETP.
d) The industry is required to provide complete fume suction mechanism on the multiple welding operations inside the processing shed.
e) The industry is required to provide stack and sampling arrangement alongwith the wet scrubber attached to the to coat/paint booth.
Recommendations:
1. The industry may be granted consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 for short term i.e. upto 31/3/2025 with suitable conditions and special condition to comply with all the observations as mentioned in the above said conclusion within one month.
2. As the industry has complied with the observations earlier pointed out by Regional Office, the Competent Authority may consider the request of the industry to waive off the bank guarantee amounting to Rs. 10 lakh earlier imposed on it.
Submitted please.
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