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Subject: Proceedings of the personal hearing given by the Chief Environmental Engineer (B) of the Board for refusal of renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 to M/s Pagro Frozen Foods Pvt. Limited (Unit-II), Jalberi Gehlan, G.T. Road, Near Sadhugarh, Distt. Fatehgarh Sahib on 02/05/2024.
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. Rajesh Mittal, Manager Accounts
Sh. Sukhraj Singh, Plant Head
Environmental Engineer, Zonal Office-II, Patiala brought that the industry was granted 'consent to operate' under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Varied/FGS/2023/20740395 dated 01/03/2023 valid upto 30/09/2023 for manufacturing of Frozen vegetables Patty & Tikki/ Frozen Vegetables @25,000 MTA, with certain conditions mentioned therein.
The industry has applied for obtaining renewal of consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974.
While passing through the area, an officer of the Board had informed that wastewater from M/s Pagro Industries is being discharged onto the adjacent forest land. To verify the source of wastewater, the industry was visited by the officers of the Regional Office, Fatehgarh Sahib on 15/01/2024 and observed that the wastewater was being released through an outlet onto the forest land abutting to the industrial premises. It was also observed that water used by laborers for washing purposes was also being discharged into the storm water drain, which ultimately leads to the forest land. Samples from the wastewater stagnated in the forest land and the ETP outlet were collected and as per the analysis results, TSS, BOD and Oil & Grease were found beyond the permissible limits for such type of discharges.
The plantation area developed by the industry for utilization of the treated wastewater from ETP is just adjacent to the storm water land and it was observed that there was stagnation of treated wastewater in the plantation area and some wastewater was being discharged from the plantation area into the storm water land.
Show cause notice for refusal of renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 was issued to the industry with an opportunity of personal hearing before the Chief Environmental Engineer on 13/02/2024, which was held on 22/02/2024, due to administrative reasons.
The representative of the industry attended the personal hearing and stated that the tap used for washing of hands etc. was kept open inadvertently by the labour. Now, the industry has removed the tap and has put the blockade at the outlet of the drain, so as to rule out the possibilities of repeat of such incident in the future. He further 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 construct an embankment around the plantation area within 15 days, so that no water from the plantation area crosses over to the forest land.
2. A team of the officers comprising of Er. Amit Kumar, EE(ZP-II), Er. Gurkaran Singh AEE, Regional Office, Patiala shall visit the industry to verify the contentions of the representative of the industry & other compliances of Environmental Laws and shall submit report/ recommendations, within 7 days.
3. The application submitted by the industry for obtaining consent to operate under Water (Prevention & Control of Pollution) Act, 1974 shall be considered after the receipt of the report from the above said team.
In compliance to hearing decisions, the industry was visited by the officers of the Board on 04/04/2024 and observed as under:
1. The industry is engaged in the business of frozen food, food processing/ fried tikki & patty and was in operation. Raw Material processing is about 80000 T /day and production is in the range of 25000 T/day.
2. The industry has installed ammonia based chilling plant and cold store of capacity 6000 MT.
3. The industry has made agreement with M/s Vista Processed Foods for manufacturing of Allo Tikki and Patties, being made within the plant.
4. The industry has installed two no. of submersible pumps as source of fresh water and has common header as well as flow meter. The reading of the flow meter was noted as 166426 m3 and is maintaining record of the same.
5. The source of wastewater generation is washing of raw material, washing of processing line, CIP, floor washing, boiler blow down, softener regeneration, Ammonia condenser overflow (CT blow down), domestic effluent etc.
6. The representative of the industry has submitted that fresh water abstraction takes place out of major water is being used in the process for washing, CIP etc. (including M/s Vista Processed Foods Manufacturer of Allo Tiki and Patties), in boiler, in 4 no. cooling towers and the trade effluent generated from the process, boiler blow down, cooling tower overflow and the domestic effluent goes to ETP for treatment.
7. The industry has installed ETP consisting of Collection Tank, Filter vessel, Clarifier, Lagoon with aeration, Anaerobic Digester, Clarifier, Aeration tanks (3 no.), Secondary clarifier, Outlet. The ETP was in operation. Samples were collected from the outlet of ETP and as per the analysis results, the industry has failed to achieve prescribed effluent standards for TSS, BOD and O&G at the outlet of ETP and TSS, BOD at discharge point leading to plantation.
8. It was observed that the return sludge from secondary clarifier is being fed to only one aeration tank.
9. Algal growth and dry leaves were observed on the surface of secondary clarifier and the weir loading was not uniform.
10. Lot of dry leaves were observed on the surface of most of the components of the ETP.
11. It was observed that sludge pits of ETP were empty. Sand filters/ACF installed at ETP are not connected/in-line.
12. The industry has installed EMF at out let of ETP. The reading at totalizer was 405463.6m3 and flow was 16.8m3.
13. The industry provided about 2.75 acre of plantation area as per Karnal technology (land on lease in two patches) and about 3 kanal of green area. Weed growth in plantation area was observed in the plantation area. Proper ridges and furrows along with plantation need to be made especially in the land falling in Kandhari Beverages. Lot of stagnation was also observed from the top of ETP in the plantation area towards Kandhari Beverages and the same was not accessable. The industry has submitted land lease deed of 2 acres, which is attached below but has not made any formal agreement of 0.75 acre of land with the adjoining Kandhari godown unit.
14. No effluent is being discharged in the forest land or into storm water drains having outlets outside the industry.
15. The industry has not provided any treated water distribution network in the plantation area.
16. The industry has installed 1 no. of boiler of capacity 850 kg/hr and using PNG @ 30 m3/hr as fuel. The boiler can be operated on HSD also but primarily PNG is being used.
17. A thermic fluid heater of capacity 4 lac Kcal is installed. The thermic fluid heater is using PNG @ 35 m3/hr. The thermopack can be operated on HSD also but primarily PNG is being used.
18. The industry has installed 2 no. of DG sets of capacities 750 KVA and 1 no of 250 KVA capacity which are equipped with canopies and stack of adequate height.
19. The waste oil drums were found stored under hazardous waste shed, but no oil was found stored in it. The rep. of the unit informed that they have got the waste oil lifted to Satkar Oil Ludhiana on 2/4/2024. The representative of the industry assured to submit the copy of manifest within 2 days.
20. The solid waste generated from the unit is being given to piggeries.
The industry is not complying with the conditions of the Consent to Operate granted to it under the Water (Prevention & Control of Pollution) Act, 1974 as well as failed to achieve the prescribed effluent standards. Thus, violating the provisions of the said Act and causing water pollution intentionally & deliberately in the vicinity.
Accordingly, show cause notice for refusal of renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 with an opportunity of personal hearing before the Chief Environmental Engineer on 02/05/2024.
The representatives of the industry attended the personal hearing and submitted the written reply, which was taken on record. They further stated that the stagnated water in the drain was rain water and was not any over flow from the plantation area. One of their soak pits had its over flow connected to the rain water drain. The over flow was immediately disconnected from the rain water drain and a separate pipeline was installed to take the over flow to the ETP. The embankment of plantation area was done a week ago. The industry is not satisfied with the analysis reports of the sample collected by the Punjab Pollution Control Board team and is contesting the same. The industry had ordered the State Water Lab, PBTI to collect samples on 30/04/2024. The industry has provided distribution network in the plantation area. The representatives of the industry also informed that M/s Vista foods is operating from the premises of M/s Pagro Foods, the wastewater generated from the process of M/s Vista Foods is being treated in the ETP installed by M/s Pagro Forzen Foods Pvt. Ltd. (Unit-2). They further requested to carryout a parralel sampling between State Water Lab and Board’s lab.
After hearing the officers of the Board and representatives of the industry, Chief Environmental Engineer (B) Patiala decided that :
1. Environmental Engineer, Regional Office, Fatehgarh Sahib shall take the opinion of SLO as to whether a single consent may be granted to two different identities working in the same premises, as in the case of M/s Pagro Forzen Foods Pvt. Ltd. (Unit-2) and M/s Vista Foods.
2. A team of officers comprising of Er. Guneet Sethi, Environmental Engineer, Regional Office, Sangrur, Er. Atul Kaushal, AEE, Regional Office-II, Ludhiana alongwith JSO from Water Lab, Patiala shall visit the industry surprisingly within 15 days for collection of parralel effluent samples to be analysed at Water Lab, Head Office, Patiala and PBTI, Mohali. The team shall also verify the compliance of Environmental Laws being carried out by the industry and send the report/ recommendations, accordingly.
3. The renewal of consent to operate under the Water Act, 1974 applied by the industry shall be decided after the receipt of the report/ recommendations from the visiting team.
If approved, the proceedings may be conveyed to the industry as well as Regional Office for ensuring compliance, please.
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