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It is further submitted that RO reported that Mr. S.L. Verma has submitted a complaint along with electricity bill of M/s Sumit Knit Fab for the month of May, 2024 alleging that the said firm has illegally restored three phase electric connection after getting relief from Board for single phase for domestic purpose. He further submitted that enforcement cell of the PCPCL was visited on 27.05.2024 and consumption of 13126 units was noted. To verify/authenticate the complaint, Regional office vide letter no. 964 dated 13.06.2024 requested the PSPCL authorities to intimate that whether the industry was operated from the period 09.05.2024 to 27.05.2024.
The industry i.e. M/s Sumit Knit Fab has also submitted a clarification in this regard vide letter dated 13.06.2024 claiming that they have not operated their unit during this period and the bill of the month of April, 2024 has been carry forwarded by PSPCL authorities and the bill of April, 2024 has been issued as that of May, 2024. In this regard, the PSPCL authorities is the only one, who can inform, as to whether the claim of complainant is true or clarification of applicant industry M/s Sumit knit fab is true.
It is further submitted that Regional office also requested the concerned PSPCL authorities telephonically on Mobile No. 9646111599 and even the copy of request made by Regional office was also forwarded. The PSPCL authorities vide their memo letter no. 1978 dated 06.06.2024 received in Regional office on 25.06.2024 has intimated that the single-phase electricity units were consumed by the industry and no action under UUE is required to be taken against the said unit. Copy of the report of PSPCL is attached by RO.
It is further submitted that, as already stated in note history as above, the industry is not fully complying with the observations of the special team constituted by the competent authority of the Board. The point wise compliance made by the industry w.r.t observations of the team is reproduce below:- 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. 11. 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, which shows that the boiler installed under capacity and can either run the dyeing machines or can be used to evaporate 200 ltr/hr RO reject.
On perusal of above report, it is further submitted as under:
1. RO reported that 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………………………….
As per point no. 8 of report of committee, during 01 hour and 30 minutes, 300 ltr of RO reject was evaporated. Hence the evaporator has operational capacity of about 200 ltr / hr. As per record maintained by the industry, total RO reject generated from 01.01.2023 to 01.02.2024 was 658 KL, which is equivalent to 2 KLD of RO reject. Hence, in case, this evaporator would be operated for 10 hrs, it can evaporate about 2000 Ltr of RO reject and in 24 hrs it can evaporate 4.8 KL. The committee further reported that RO permeate was expected against 75% permeate received as per records maintained. Then, rest of the 25 % should be the RO reject, which will be 18.750 KL i.e. 25 % of 75 KLD consented discharge. So, there is a gap of an average of 13.95 KLD. The reply submitted by industry is not justifying the same. The industry has not installed EMF meter at UF reject.
2. RO reported that the industry has been advised to maintain separate record for consumption of fresh water for domestic purpose and for industrial use……………………………….
The industry was visited by officers of the Board on 28.10.2020 and it was observed that the industry has installed 6 no. washing milling machines of capacity 1000 Kg (02 nos.) and 1500 Kg (04 nos. each). The industry has installed 05 nos. electric operated dryer, 02 no. tub dyeing machines, 02 no. knitting machines and 03 no. tuning machines. Regional Office has not reported the detail of present installed machines and effluent generated, in compliance of decision no. 6 of the personal hearing held before the Chairman of the Board on 25.04.2024.
3. RO reported that the industry has not changed membrane from the last five years…………………………….
As per point no. 6 (B) of report of committee, the TDS of fresh water + RO permeate which is stated to be re-used for washing/ dyeing process is 1267 ppm. As per the flow chart displayed at site, the ZLD plant is design for RO permeate 50 ppm TDS. It seems that the efficiency of RO is near to 5 % of consented discharge of 75 KLD.
4. RO reported that the claim of the industry regarding re-using of effluent of TDS upto 2000 mg/L is not acceptable……….
As per point no. 6 of report of committee, the effluent sampling was carried out and pH was found to be 8.2 - 8.3 and TDS was found to be 1267 mg/l. This effluent was never re-used in the dyeing process. The water having pH less than 7 and TDS between 100-200 mg/l is suitable for dyeing process. Hence, the industry's claim about reuse of waste water is not true and if this type of effluent will be re-used, the dyeing process will be patchy with dull shade.
5. RO reported that the possibility of discharge of effluent through flexible pipe from ETP or RO plant, as per report of the committee cannot be ruled out……………………...
If the industry is having sewer connection, there is possibility of discharge of effluent in odd hours.
6. RO reported that the industry has not installed EMF meter at UF reject ……………..
As per point no. 5 (A) of report of committee, total effluent received after the conventional treatment of RO plant was 10656 KL. Whereas, the effluent processed through RO plant was 8630 KL. There is no account of 2026 KL effluent. This effluent may either be directly disposed off after the ETP plant to MC sewer without evaporation to save cost of energy involved in evaporation. there is a gap of an average of 13.95 KLD and details is mentioned at observation no. 1.
7. RO reported that the industry has now provided hazardous waste under category 33.1 in the Hazardous Waste Facility………………….
However, the drums containing chemical basin in the process area.
8. RO reported that 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…………………
The industry was in operation without providing proper display board outside the premises from date of commissioning to 02.02.2024 in violation of directions issued by the Hon'ble Supreme Court.
9. RO reported that the industry has not submitted any bills regarding maintenance of the RO plant……………….
The industry is not maintaining the record regarding maintenance of the RO plant.
10. RO reported that the industry has not provided automatic dosing arrangement………………….
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.
Regional office further reported that the industry has not complied with the observation of the committee and has not proposed any upgradation in the RO and Regional office recommended that the request submitted by the industry for grant of consent to operate under the Water Act, 1974 may be refused and restoration of the electric connection may not be granted.
In view of the above, it is recommended that the consent to operate under the Water Act, 1974 may be refused and restoration of the electric connection may not be granted, please.
(Category - Red, small) (Competency lies with SEE for deciding consent case and for notice/ directions u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 and u/s 31-A of the Air (Prevention & Control of Pollution) Act, 1981, competency lies with CEE Ludhiana)
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