| File Note: |
Earlier industry has granted consent to operate under Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOW/Renewal/LDH1/2021/16446253 Date of issue: 25/08/2021 Date of expiry: 30/06/2025 and CTOA/Renewal/LDH1/2021/16446028 Date of issue: 25/08/2021 Date of expiry: 30/06/2025 for Washing/Dyeing of garments @ 3000 No./day.
Thereafter, the industry was given personal hearing before the Chairman of the Board on 25.04.2024 w.r.t. notice to issue directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 as well as show cause notice for revocation of consent to operate under the Water Act, 1974 and revocation of authorization under the Hazardous and other Waste Rules, 2016 along with notice for imposition of Environmental Compensation (EC), during hearing it was decided as under:-
1. The consent to operate granted to the industry under the Water (Prevention & Control of Pollution) Act, 1974 and authorization granted under the Hazardous and other Waste (Management & Trans-boundary Movement) Rules, 2016 be revoked.
2. The directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 be confirmed for closure of the industry and disconnection of electric connection.
3. All the D.G. sets existing in the premises of the industry be sealed.
4. A reminder be issued to MCL in continuation to letter no. 163 dated 11.01.2021 and to Assistant Excise and Taxation Commissioner, Excise and Taxation Department, Ludhiana in continuation to letter no. 165 dated 11.01.2021 to intimate the date & year from which the industry is doing dyeing/washing process.
5. The amount of Environmental Compensation be calculated after receipt of reply from MCL and Excise and Taxation Department, Ludhiana.
6. The Environmental Engineer, Regional Office-1, Ludhiana shall verify the year wise installation / addition of machinery by the industry and pursue the matter with MCL and Excise and Taxation Department for early response
The point wise compliance for the decisions of the personal hearing is as under:-
1. The letter was issued to MCL in continuation to letter no. 163 dated 11.01.2021 and to Assistant Excise and Taxation Commissioner, Excise and Taxation Department, Ludhiana in continuation to letter no. 165 dated 11.01.2021 to intimate the date & year from which the industry is doing dyeing/washing process. The report from State Sale Tax Officer has been received and is attached. As per the report the unit is in the business of buying dyeing related raw materials since 2005.
2. The amount of Environmental Compensation is calculated which is mentioned as under:-.
As per the report received from State Sale Tax Department, the unit is in the business of dyeing of fabric Since, 2005. So for the time period 01.04.2005 to 25.04.2019, this office has calculated the Environmental Compensation amounting to Rs. 6,42,25,000/- as per calculations below:
EC= PI*N*R*S*Lf
PI= 80 (since project proponent is violating Water Act, 1974 & Air Act, 1981 and is Red category industry)
R= 250 (since project proponent is small scale Red category industry, hence, R factor has been taken as 250)
N= 5138 days calculated w.e.f 01.04.2005 till 25.04.2019 (due date of compliance of decisions of hearing)
S= 0.5 since scale is small
Lf= 1.25 since the project proponent is located in city with population less than 1 million
EC= 80*5138*250*0.5*1.25
EC= Rs 6,42,25,000/-
Now, in this case
EC = PI x N x R x S x LF
where, EC is Environmental Compensation in ₹
PI = Pollution Index of industrial sector
80 (since the industry is violating Water Act, 1974 and Air Act, 1981 and is red category industry, hence, PI = 40% of 80=32 for both Acts)
N = Number of days of violation took place
5138 days (01.04.2005 till 25.04.2019)
R = A factor in Rupees ( ₹ ) for EC
250 (since industry is small red category industry)
S = Factor for scale of operation
0.5 (since scale is small)
LF = Location factor
1.25 (population more than 1 million)
EC = 80*5138*250*0.5*1.25
Environmental Compensation= Rs. Rs 6,42,25,000/-
Minimum Environmental Compensation per day is Rs. 5000/-.
Therefore, 5138 X 5000 = Rs. 2,56,90,000/-.
The E-file has been sent to the committee for verifying the calculated Environmental Compensation, which is under process. Thereafter the industry made request for release of single phase electric connection for office use, which was granted by the competent authority of the Board.
Now the industry has applied for obtaining consent to operate under Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 along with restoration of electric connection.
The clarification was raised to the industry in light of the report of the expert committee dated 02.02.2024, as the report highlighted that the real time/actual capacity of the evaporator installed by the industry was checked during the visit by making the evaporator operational and it was only made possible after diverting entire steam from boiler to the evaporator. Further practically the evaporator was able to evaporate 300 ltr of RO reject in 1 hr 30 min. However, in the feasibility report the capacity of evaporator was mentioned 1000 ltr/hr. The industry was requested to provide calculations justifying the installed capacity of the evaporator as 1000 ltr/hr along with steam requirement calculations (along with operating pressure). In reply to the clarification the industry inform that their RO reject is about 6000 ltr/day and the working hours of the industry are about 12-15 hrs/day and evaporation required has been mentioned as 500 ltr/hr. Further, the industry has submitted that the steam required for evaporating 500 ltr/hrs Ro reject is 125 kg/hrs.
In this regard calculations have been made to find out steam required to evaporate 500 ltr/hr RO reject under ideal conditions (considering 100% efficiency of evaporator and zero steam loss).
Considering 100% efficiency of evaporator just for cross checking the quantity of steam requirement mentioned by the industry. Practically the efficiency of single effect evaporator is in the range of 65-70%.
Working hours of industry as stated by the representative in its clarification is 12-16 hrs.
For calculation we consider working hours to be 12.
So the quantity of RO reject to be fed to evaporator comes out to be 6000/12 = 500 ltr/hr.
Considering the TDS in RO reject to be 3000 mg/L & considering no water in the concentrate. The material balance is as under.
Mass balance (kg/hr)
Solids Liquid Total
Feed 1.5 498.5 500
TDS (Salt) 1.5 0 1.5
Evaporation - - 498.5
Energy balance:
Heat available per kg of steam = latent heat + Sensible heat in cooling to 90oC
For calculation considering steam temperature to 134oC (as per operating conditions of existing boiler)
= 2.164x106 + 4.186x103 (134-90)
= 2.164x106 + 4.186x103 (134-90)
= 2.34x106 J/kg
Now energy required to heat the RO reject
= latent hear+ sensible heat in heating the RO reject from 30 to 90oC
Considering RO reject temp to be ambient i.e. 30oC
=2281x103 x 498.5 + 500x4.186x103x(90-30)
=1137078.5 x 10 + 2093 x103 x 60
= 12.626 x 108 J
Principally heat from steam= Heat required by RO reject for complete evaporation therefore quantity of heat required per hour = 12.626x108/2.34 x106
= 539.57 kg/hr
Steam required per kg of RO reject for complete evaporation = 539.57/498.5
= (1.1) kg steam/kg of water
Taking efficiency of evaporator as 70% and considering other loss, the actual steam required to a evaporate 1 kg of water will be on the higher side i.e. 874.8 kg/hr Moreover the committee also practically checked the capacity of evaporator and around 300 ltr water was evaporated in 1 hr 30 min after closing all the steam consumption in the dyeing section.
The industry was visited by the undersigned on 07.06.2024 and observed as under:-
1. The industry was not in operation and only single phase connection was available during the visit.
2. The industry has installed 6 nos. garment washing-cum-dyeing machines.
3. The industry has installed boiler of 800 kg capacity.
4. The industry has provided evaporator comprising of 2 heat exchangers in parallel, making the configuration of evaporator as single stage.
5. The present application of the industry is for dyeing/washing of garments @ 3000 numbers/day with generation of effluent @ 75.0 KLD and the bifurcation of effluent to achieve ZLD is as under:-
75.0KLD fed to ETP followed by UF RO and reject @ 6000 ltr/day is fed to evaporator to achieve ZLD.
Since, the steam required to evaporate 500 ltr/hr RO reject comes out to be 540 kg/hr, so with present boiler of capacity 800 kg/hr it seems tough to run the dyeing as well as evaporator at the same time. The industry needs to optimize/reduce its production and effluent generation so as to equally distribute steam to dyeing section and evaporator.
Further the industry is not complying with the points/observations of committee which are as under:-
1. There is no account of 2026 KL. Whereas, the effluent may either be directly disposed-off after the ETP plant to MC sewer without evaporation to save cost of energy involved in evaporation - As per the report of the committee there is no account of 2026 effluent for the period 01.01.2023 to 01.02.2024. There is gap of an average of 5.78 KL/day of effluent. The reply submitted by the industry does not justify the same. The industry should give in calculations the amount of effluent in the liquid sludge and reject of the UF membrane. However, the industry has requested that they will install EMF meter at UF reject in future.
2. There is possibility of unmetered water source from where the water is taken for processing activities but is not accounted in records - The industry was visited by the AEE of this office on 30.05.2024 and the industry has provided water meter on domestic tank. The industry has been advised to maintain separate record for consumption of fresh water for domestic purpose and for industrial use.
3. RO is not functioning properly and efficiently and there are chances that the industry might be discharging its treated effluent without reusing in the process - The industry has submitted RO plant life Expectancy certificate from M/s Mahavir Enviro Consultant Ludhiana, wherein it has been mentioned that RO membranes are used only 15% of is life cycle and 85% life is still remaining for RO membranes. The matter needs to be further deliberated by the experts.
4. It is neither feasible not advisable to use treated effluent with such a high TDS of around 1300 ppm for boiler feed or for dyeing/washing process as it will affect the boiler infrastructure as well as affect the quality of product being manufactured by the industry - The reply of the industry needs to be further deliberated.
5. The possibility of discharge of effluent through flexible pipe from ETP or RO plant can't be ruled out - During the visit on 30.05.2024 no flexible pipes was seen inside the permissible of the industry.
6. The industry is not treating whole of the effluent through RO plant and about 2026 KL of effluent was found unaccounted. Hence, the quantities of RO reject will be much more as compare to 658 KL as recorded by the industry - Same as per remarks mentioned at observation no. 1. It is further submitted that to rule out any discharge of RO reject into sewer the industry may be imposed condition to operate it plant at 50 % capacity since it was noted by the committee that there was unaccounted effluent @ 2026 KL.
7. The hazardous waste of cat. 33.1 were found scattered here & there and no record was maintained - The industry has now provided hazardous waste under category 33.1 in the Hazardous Wastes (Management Handling & Trans-boundary Movement) Rules, 2016 however the drums containing chemical basin in the process area.
8. The industry has not provided proper display board outside the hazardous waste storage room as only a computerized paper is pasted there - The industry has now provided display board at the gate of the unit and has also provided danger sign board on the hazardous waste room.
9. The industry has failed to submit any record of bills or documents to justify the regular and periodic maintenance of RO plant. Further, no bill regarding change of membrane or RO plant was produced - The reply of the industry can be considered.
10. The industry has not complied with the condition of consent for providing automatic dosing arrangement for optimum chemical / coagulants in its ETP instead of manual system - Automated dozing not provided.
The industry has further requested that the industry shall rectify all issues which are observed by the committee and has requested to restore the electric connection for the period of 6 months during which the industry comply with all the observation/directions issued by the Board.
It is submitted that the complainant has also submitted a letter to this office through email on 30.05.2024 addressed to Hon'ble NGT, New Delhi (copy attached) wherein the industry has requested to take action against the erring officer of the Punjab Pollution Control Board and ask not to restore the electric connection of the industry as the industry has not provided adequate evaporator and not deposited above EC and is still in violation due to which electric connection was disconnected.
It is therefore recommended that the matter be placed before the Competent Authority of the Board for final decision in the matter please.
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