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Subject: Proceedings of the personal hearing given by the Chief Environmental Engineer (B) of the for refusal of renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 and show cause notice for violations under the provisions of the Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016 to M/s Ambey Industries, G.T. Road, Sirhind Side, Backside Modern Steel Ltd., Mandi Gobindgarh on 09/05/2024.
The following were present:
From the Board:
Er. Lavneet Dubey, SEE, ZO-II, Patiala
Er. Amit Kumar, EE, ZO-II, Patiala
From the industry:
Sh. Mukesh Kumar, Partner
Environmental Engineer, Zonal Office-II, Patiala brought that the industry is a large scale induction furnace unit under orange category. Earlier, the industry was granted 'consent to operate' under Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Fresh/FGS/2023/20165696 dated 04/01/2023 and under the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Fresh/FGS/2023/20165507 dated 04/01/2023, which is valid upto 31/03/2024 for manufacturing of Steel Ingots, Billets, HR Flats, Strips (With CCM Plant & rolling mill) @ 375.0 MTD, with certain conditions mentioned therein.
The industry was granted authorization under the Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016 vide no. Auth/Fresh/PBIP/FGS/2023/210234796 dated 01/06/2023 valid upto 31/03/2024 with certain condition mentioned therein.
During visit to the area by the officer of the Board during night hours on 30/10/2023 and it was observed as under:
1. The industry was in operation during the time of visit and engaged in the business of manufacturing of Girder, Channel, Flat bar by using iron scrap as raw material.
2. The industry has installed pusher type furnace of Capacity 100 MTD and the same were found in operation.
3. The industry has installed side suction hood system followed by Bag Filter house as APCD to contain the concentration of Particulate matter within the prescribed Standards and the same was found in operation.
4. During the visit, thick black smoke was observed escaping out from the shed of the industry and it was also observed that the side hood was not working properly because of that 70-75% of thick black smoke was escaping through the shed.
5. The representative of industry could not show record regarding compliance of SOPs framed by PSCST, Chandigarh for the operation of the industry.
6. During the visit it was also observed that there was no door at the hazardous waste room.
Show cause notice for cancellation of Consent to operate granted under the Air (Prevention & Control of Pollution) Act, 1981 and cancellation of authorization under Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016 was issued to the industry with an opportunity of personal hearing before the Chief Environmental Engineer(B) on 17/11/2023.
Sh. Puneet Kumar, Partner of the industry attended the personal hearing and stated that there was a problem of bags of the APCD and the same has got rectified. Now, the APCD is working properly. He further requested to drop the notice.
After hearing the officer of the Board and representative of the industry, Chief Environmental Engineer (B) Patiala decided that :
1. To improve the efficiency of bag house of the existing APCD, the industry shall up-grade its bag filters in the bag house in the existing APCD as per the specifications given below within one month and shall get it verified/ certified from PSCST, Chandigarh.
Filter medium/Scrim Three polyester batt layer needle felt (Profiled microfibres + microfibers) 2 layers of high strength woven scrim from filament textured yarns with an inter-batt layer Premium Fibre Blend/Scrim: PTFE Treatment : full bah PTFE finish
Thickness Range from 2mm to 2.5mm Range from 2mm to 2.5mm
Basis weight 650 grams/square meter 650 grams/square meter
Finish Oil & water repellant Oil & water repellant
Temperature resistance 80-100 oC/ peak 150 oC 80-100 oC/ peak 150 oC
2. The industry shall submit the proposal regarding control of Secondary Emissions generated from the process within one month after consultation with the PSCST, Chandigarh.
3. The industry shall submit a bank gurantee amounting to Rs. 2.0 lakh within 7 days as an assurance to comply with the Environmental Laws and Environmental Engineer, Regional Office, Fatehgarh Sahib shall encash 50% of the above said bank guarantee.
4. The industry shall use good quality raw material free from dust and oil.
5. The industry shall develop the adequate green area all around the boundary wall and shall stabilize all of its movement area within the premises of the industry as well as approach around the industry, so as to minimize the dust emissions within one month.
6. A team of the officers shall be constituted by CEE(B) to surprisingly visit the industry to verify the conditions imposed in Environmental Clearance, other compliance of Environmental Laws immediately after one month and shall submit report/ recommendations, thereafter.
The industry had deposited 02 no. bank guarantees vide no. 0327IFBG2403001 & 0327IFBG2403003, respectively dated 15.03.2024 of Rs. 1.0 lakhs each in the Board. The bank guarantee amounting to Rs. 1.0 lacs vide no. 0327IFBG2403001 has been encashed by Regional Office vide no. 104 dated 15.04.2024.
In compliance of above said hearing decisions, the industry was visited by the team of the officers on 12.02.2024 and it was observed as under:
1. During visit, the industry was in operation.
2. On the arrival of the team, it was observed that although the side hood was kept on the crucible, but lot of emissions were found escaping the hood and polluting the environment.
3. It was observed in the working shed that un-shredded raw material was being fed in the furnace and the furnace was found over flowing from the top of the crucible and void spaces could be seen which is resulting in incomplete combustion and thick grey smoke
4. The representative informed that the melting furnace is of capacity 25 ton/heat (megatherm make). The representative of the industry informed that it is taking 13-14 heats per day.
5. The part emissions being tapped through the side hood were being conveyed to the twine cyclone (2 no. in parallel) followed by 7 module pulse jet bag house filters, which is further connected to the stack.
6. During visit, it was observed that duct attaching the ID fan to the stack has an opening from where emissions were found escaping. The representative of the industry informed that the opening is kept to clean the duct for any deposition but the cover of opening sent for repair. Due to said opening in the duct, emissions were found escaping in the shed rather than going through the stack.
7. The ID fan attached with the APCD was found operational and the samples were collected from the stack for monitoring purpose. As per the report received from the Head Office Lab, Patiala, the concentration of particulate matter was found 66 mg/Nm3 against the permissible limits of 150 mg/Nm3. Further, the industry has installed Online Continues Emissions Monitoring System (OCEMS) on the stack and it was showing reading ranging from 30 to 60 mg/Nm3.
8. The representative of the industry informed that motor of capacity 425 HP have been provided on furnace of capacity 25 Ton. As per the record, the average power consumption of the units on operation of ID fan attached to 25 Ton furnace is 3340-4020 per day (for 24-hour operation of the unit). Whereas, 425 HP or 317 KW capacity motor working at 80 % efficiency should consume about 6000 units/day. Thus, the industry is not operating its APCD regularly and as observed is by-passing the process / fugitive emissions generated from the furnaces.
9. The industry is maintaining record as per SoP teamed by PSCST and submitted copy of the same to the team. The industry has submitted copy of completion certificate issued PSCST Chandigarh according to which the industry has installed APCD on their induction furnace of capacity 30 T/heat.
10. The industry has provided u-tube manometers (5 no.) out of which 3 manometers were in operation and 2 no. are not having manometers fluid in it.
11. The industry has installed one no. shredding machine, which was not in operation during visit. The representative informed that the same is not being operated as under maintenance. The industry has installed one bundling machine for compaction of raw material / scrap.
12. The industry has also installed one no. continuous concast mechanism (CCM) to manufacture billets, which was also found in operation.
13. The industry has also installed rolling mill, which was not in operation at the time of visit.
14. The industry has stabilized its movement area wherever vehicle movement has to take place for suppression of dust.
15. The industry is having 2 no. silent D.G. sets but not provided with adequate stack height.
16. The industry is not generating any trade effluent and has provided septic tank for treatment of domestic effluent generated from about 90 persons. There are no residential quarters inside unit.
17. The industry has provided two no. collection tanks at the back side of the unit for collection of the RO reject & cooling tower blow through storm water drain. The rep. of the industry informed that the said water is used in the rolling mill for cooling of rolls. One borewell was observed near these collection tank and the overflow of these tanks may lead to this borewell, however no discharge was observed in the borewell during the visit.
18. The industry has provided 2 no. hazardous waste rooms for storage of APCD dust i.e. hazardous waste of category no. 35.1 of schedule-1 of Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016. During visit, these rooms were found completely filled with the bags of Hazardous waste, which could not be counted as the same were stacked without numbering and in an haphazard manner. As per the record maintenance by the industry, 11,735 kg APCD dust is lying the premises. Further, lastly the industry has disposed of 7.740 MT to M/s Madhav KRG for disposal vide manifest no. 1042 dated 06.02.2024. The industry is maintaining record of generation, storage and lifting of hazardous waste. As per the record being maintained the industry, it is generating APCD ash in the range 500-800 kg/day for the last three months.
19. The industry is storing the bag house filters (damaged one) in the separate hazardous waste room however, the industry is not maintaining any record of the same and not having any disposal arrangements of this waste.
20. The representative of the industry submitted copy of Environmental Clearance granted to it by SEIA, Punjab according to which the industry shall undertake manufacturing of steel ingots / billets, HR Flats, Strips @ 131250 TPA (375 TPD) by using MS scrap and ferrous alloys @ 143250 TPA in an area 5.4203 acres, with suitable conditions. The industry has also submitted six monthly compliance report of EC conditions.
21. As per EC conditions out of total 5.4 acres land it has to provide green area in about 7184 sq. meter land. The representative could not submit any detail / map of the area under plantation submitted at the time of obtaining Environmental Clearance to the Board. The industry has provided green area in three pockets and some along the boundary wall. As observed, the plantation is not done in 33 % of the total land area of the unit as per the EC condition.
22. The industry rep. informed that CSR activity undertaken is pond developed in Chatarpur village, school rooms/toilets constricted in Govt. school, Chatarpur, medical equipment in Prabhat Puri charitable hospital (Total amount spent – 20,57,676/-). The industry has submitted copy of letter issued by Sarpanch Gram panchayat of Chattarpura w.r.t rain water rejuvenation pond, construction of bathroom in Govt. primary school Chattarpura and copy of machinery provided in Prabhat Puri Charitable Hospital, Mandi Gobindgarh. The CER activities done is as per the Environmental Clearance condition.
23. In compliance to the EC condition, the industry has installed 4 no. ambient air automatic monitoring station, out of which 3 were found in operation. 5. In compliance to the EC condition, the industry has not provided secondary furnace extraction system on the induction furnace / CCM, so far. The representative of the industry submitted that it has sent a letter dated 25.12.2023 to PSCST, Chandigarh in which it has requested the following: -
a. To improve the efficiency of bag house of the existing APCD and industry shall up-grade its bag filter house in the existing APCD.
b. The proposal regarding control of secondary emissions after consultation with the PSCST, Chandigarh.
24. In compliance to the EC condition the workers were not using Personal Protective Equipment (PPE) which were working near the melting furnace.
Now, the industry has applied for renewal of consents to operate under Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981. Accordingly, the industry was visited by the AEE of Regional Office, Fatehgarh Sahib on 23/04/2024. As per the visit report, the industry has installed online continuous emission monitoring system on stack of APCD installed, but, the same was not connected with the PPCB server. The industry has given assurance that it will get the OCEMS connected with the server of PPCB within one week. The industry has developed only 18% green area within its premises in 4 pockets and is in process of purchasing additional land for remaining plantation area. In compliance to the hearing decision no. 1 of hearing given to the industry before Chief Environmental Engineer (B) on 17/11/2023, the industry has up-graded its bag filters in the bag house in the existing APCD as per the specifications given in the decisions of the hearing and got verified/certified from PSCST, Chandigarh.
The industry is found violating the provisions of the Water (Prevention & Control of Pollution) Act, 1974 & the Air (Prevention & Control of Pollution) Act, 1981 and Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016 and is also not complying with the conditions of Environmental Clearance granted to it as reported by visiting team. Thus, violating the provisions of the said Acts/ Rules and causing pollution intentionally & deliberately in the area.
Accordingly, show cause notice for refusal of renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 and show cause notice for violations under the provisions of the Hazardous & Other Wastes (Management & Transboundary Movement) Rules, 2016 was issued to the industry with an opportunity of personal hearing before the Chief Environmental Engineer of the Board on 09/05/2024.
The representative of the industry attended the personal hearing and submitted the written reply, which was taken on record. He futher stated that the industry has aleady rectified the osbervations made by the visiting officer. The industry has got its duct repaired, now the suction at the side hood is proper and no smoke escapes from the side hood. The industry is in a process to incsease the green area. The industry has installed two shredder machines for shredding of the scrap and requested to drop the notice.
After hearing the officers of the Board and representative of the industry, Chief Environmental Engineer (B) Patiala decided that :
1. The industry shall submit a feasibility report for the proposed pollution control measures to control the secondary emissions within one month from reputed agency/ chartered institute along with pert chart with respect to the installation of the pollution control measures.
2. In case no proposal is submitted, action under the provisions of Air Act, 1981 including imposition of EC will be initiated by the Board.
3. Environmental Engineer, Regional Office, Fatehgarh Sahib will submit detailed report on the compliance of decision no. 2, immediately after completion of one month.
4. The renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 upto adequacy of the fee deposited by the industry.
5. The industry shall increase its plantation area in compliance of the condition imposed in Environmental Clearance within two months.
If approved, the proceedings may be conveyed to the industry as well as Regional Office for ensuring compliance, please.
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