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It is intimated that the subject cited industry has been granted NOC from the Board for establishment of pyrolysis plant for processing of 20 TPD of waste tyres for production of 8.0 TPD of pyro oil, 7.596 TPD of carbon black, 2.0 TPD of steel wires and 1.8 TPD of non condensable gases in the revenue estate of village Sadarwala, Tehsil and District Sri Muktsar Sahib on 31.07.2023 for a period upto 31.03.2024 with 02 reactor of capacity 10 TPD each.
A complaint has been received in the Board from Gram Panchayat, Kabarwala (Sadarwala) regarding the nuisance being created by the operation of the industry.
The industry has applied for obtaining fresh 'consents to operate' under the provisions of the Water Act, 1974 & Air Act, 1981.
Accordingly, the site of the industry was visited by the undersigned on 01.04.2024 and it was observed that:-
1) The industry has yet not installed the flare mechanism and has also provided a bye-pass system with reactor for flaring of gas, in case of emergency.
2) The industry has provided a mechanism to remove the carbon from the reactor through cloth type material and the same is feeded to plastic bags for storage.
3) The industry has provided single row of plantation/saplings along the boundary wall.
4) The industry has yet not submitted any certificate from the concerned authorities regarding the adoption of safety measures incompliance to the notification dated 15.10.2014.
5) The industry is not complying with the 'Standard Operating Procedures' (SOPs) issued by CPCB on 16.01.2024 prescribed for re-cycling of waste tyre scrap for the recovery of tyre pyrolysis oil, pyro gas and char.
6) The industry is not complying with all the conditions imposed by the Site Appraisal Committee in the site clearance granted to it dated 17.05.2023.
Show cause notice before refusal of 'consents to operate 'under the provisions of the Water Act, 1974 & Air Act,1981 was issued to the industry alongwith an opportunity of personal hearing before the Senior Environmental Engineer on 29.04.2024. During hearing, Sh. Hardev Singh, Prop. of the industry submitted written reply w.r.t. notice issued to it, which has taken on record. He further stated that:-
1. Flare mechanism provided with the reactor at the farthest point.
2. Proper mechanism provided for removing of the carbon from the reactor and for filling in HDPE bags.
3. Triple row of plantation/saplings provided along the boundary wall.
4. Application applied for obtaining certificate from the concerned authorities regarding the adoption of safety measures in compliance to the notification dated 15.10.2014.
5. As per the conditions imposed in the certificate issued by the Site Appraisal Committee dated 17.05.2023, strip/chip cutting machines/shredder has not been provided by the industry as the uncut tyre is sent to the reactor for production of pyrolysis oil, gas & Char.
During hearing, it was deliberated that the Standard Operating Procedures issued by CPCB on 16.01.2024 for recycling of waste tyre scrap for recovery of pyrolysis oil, gas & Char is still under consideration with the Board and the industry will be directed to comply with said SOPs after receipt of any formal communication from the Higher Authorities.
After hearing, the Prop. of the industry as well as the officer of the Board, it has been decided that by the Senior Environmental Engineer of the Board that the Environmental Engineer, Regional Office, Bathinda shall visit the site of industry to verify the submission made by the prop. of industry and process the consent applications applied by it under Water Act, 1974 & Air Act, 1981, on merits.
In compliance to the decisions of the personal hearing, the industry was visited by the officer of the Board on 13.05.2024 and observed that the industry has neither provided pneumatic/screw conveyor systems for removal of carbon powder from the reactor nor provided any bagging plant and has also failed to submit the certificate from the concerned authorities regarding the adoption of safety measures in compliance to the notification dated 15.10.2014 issued by the Department of Science Technology & Environment, Punjab. Moreover, the industry has not complied with the decisions of the
personal hearing dated 29.04.2024.
And whereas, the matter has been considered by the Competent Authority and accordingly, consent to operate applied by the industry under the Water (Prevention & Control of Pollution) Act, 1974 and Air (Prevention & Control of Pollution) Act, 1981 was refused vide dated 27.05.2024.
Now, the industry has again applied through OCMMS for obtaining CTO from pollution angle for operation of plant for the production of 8.0 TPD of pyro oil, 7.596 TPD of carbon black, 2.0 TPD of steel wires and 1.8 TPD of non condensable gases by using scrap / waste tyre @ 20 T/batch and wood (fuel) @ 700 kg/day as raw material.
The industry has submitted request letter (copy attached) regarding consideration of pyrolysis plant for processing of 10 TPD of waste tyres for production of 4.0 TPD of pyro oil, 3.798 TPD of carbon black, 1.0 TPD of steel wires and 0.9 TPD of non condensable gases.
The industry has deposited consent fee of Rs 5400 under each Act on 01.02.2024 against fixed assets of Rs 71.17 lacs under red category. The fee deposited by industry is adequate for a period upto 31.12.2024 after deducting balance CTE fee of Rs 1800 (as the industry has proposed project cost of Rs. 49 lacs at the time of NOC).
Accordingly, the site of the industry was visited by the undersigned on 26.06.2024 and it was observed that the industry was not in operation, the industry has installed 1 reactor and the industry is yet to start its operation
The point’s wise compliance of CPCB conditions in SAC granted to industry is as under;
1. The PP shall install Packed Bed Scrubber for control of gases emission and reduction of odour.
Compliance: The industry has installed one reactor and has informed that plant has been commissioned on trial basis for 2 days. Thereafter the industry has not been operated due to non issuance of electric connection. The industry has installed alkali scrubber for gases emissions from reactor and a stack of 30 meters has been provided with it. The industry has informed that during initial fired wood will be used after that pyro gas will be used for firing. The adequacy of APCD will be only checked after the commissioning of the unit. The industry has provided safety valve in the processing shed.
2. De-beading machine without manual intervention or with safety guards wherever manual intervention is involved, to ensure safety of workers.
Compliance: The industry has informed that uncut waste tyres be directly feeded to reactor. After the pyrolysis process, char is removed and steel wire is pulled and removed with the help of motor operated system. No cutter / chip making /grinder/cracker / shredder has been provided by the industry.
3. Strip cutter and chip making machines should have safety guards to ensure safety of workers.
Compliance: As per Sr.no. 2.
4. The Cracker/Shredder should have adequate arrangements for capturing fiber and fugitive particulates leading to cyclone separator/bag filter. The cracker/shredder should also have magnetic separators to remove any iron particles. For controlling the noise from these machines they should have acoustic enclosure.
Compliance: As per Sr.no. 2.
5. The grinder/pulveriser which further reduces the crumb size should necessarily have adequate arrangements to extract fibers and fine particles through suction and bag filters.
Compliance: As per Sr.no. 2.
6. All the conveyors, vibrating screens and transfer points including packing should be covered and fitted with suction system connected to bag filters.
Compliance: The industry has now provided screw conveyor systems for removal of the carbon powder from the reactor. The conveyor leads to carbon powder storage container, where the bags of carbon powder will be filled from the bottom and arrangement has been provided at the top for traping the emission generated during baging with the alkali scrubber of Reactor. The industry has stored about 100 bags of about 15 kg of carbon underneath the processing shed.
7. The whole process area should have proper ventilation system.
Compliance: The industry has provided pyrolysis plant underneath the shed and has ventilation as the same is open from two sides.
8. Adequate fire fighting arrangements in terms of fire hydrants have to be installed in the premise of the unit in such a way that it should cover all the areas of the plot
Compliance: The industry has provided fire stopping arrangement in the processing shed.
9. All workers should have personal protective equipment/gadgets such as safety apron, masks, shoes, gloves, goggles, helmet and earplugs.
Compliance: The industry has informed that plant will be operated only with PPE.
The point wise compliance of Condition as per Board office order no. PPCB/SEE(HQ-2)/2020/92 dated 03.02.2020 is as under;
10. To ensure the safeguard of the health of workers involved in the tyre pyrolysis industries, a condition may be imposed while issuing the Consent to Establish / Operate to the industrial units to the effect that regular health checkups at an interval not more than 3 months shall be got carried out by the project proponent for his workers / staff. A certificate to the effect that no adverse effect has been observed to the health of workers / staff shall be obtained and submitted by the industry / project proponent to the Board at the time of consent / renewal of consent from the concerned Medical Officer/Senior Medical Officer of the area.
Compliance: The industry is required to make compliance in this regard.
The point wise compliance of code of practice and pollution abatement measures for all units in order dated 15.10.2014 is as under;
11. All units, including existing ones, shall be allowed to process the waste tyres generated from Within the State of Punjab only. Procurement / Import "of scrap tyres/waste rubber products from foreign off-shores or even from other states within the country shall not be allowed.
Compliance: The industry has informed that waste tyre will be procured from Punjab only. The industry is required to submit record of procurement in this regard to Board on regular basis.
12. For the initial heating of the reactor, all authorized fuels are allowed, The emissions emitted from the fuel burning should be passed through an alkali scrubber before discharging these into the atmosphere through a stack of minimum 30 mts. Height for proper dispersion of the gases.
Compliance: As per Sr. no. 1.
13. The furnace for heating the reactor should be optimally designed and operated so that proper burning of the fuel can take place and generation of Carbon monoxide (CO) emissions is minimized.
Compliance: The industry has provided CO sensor in processing shed.
14. The uncondensed gases should be flared through a properly designed flare mechanism at a minimum height of 10 mts from the ground level or 3 mts above the height of the nearest building, whichever is more.
Compliance: The industry has provided flare mechanism in the one corner of the industry. The industry has provided bypass system with reactor for flaring pyro gras in case of emergency alongwith the stack of scrubber.
15. The carbon powder produced should be removed from the reactor in completely closed and controlled conditions through a pneumatic/ screw conveyor system in such a manner that the contents of the reactor are not open to the atmosphere at any point of time. The end of the conveyor system shall be attached to a bagging plant where all the carbon black be bagged in the HDPE bags and the bags shall be properly sealed. Only one exhaust after the bagging plant stall be allowed and the same should be attached to a stack of minimum 30 mts. height after passing through a suitable APCD such as Alkali Scrubber to prevent dust/odour emissions.
Compliance: The industry has now provided screw conveyor systems for removal of the carbon powder from the reactor. The conveyor leads to carbon powder storage container, where the bags of carbon powder will be filled from the bottom and arrangement has been provided at the top for traping the emission generated during baging with the alkali scrubber of Reactor.
16. The unit should carry out stack and ambient air quality monitoring for SO2, RSPM, CO and HCs at least once in three monthsfrom a recognized laboratory. The unit will maintain a log book for recording the plant operation, monitoring of the stack emissions and ambient air quality, generation & utilization of wastewater & sale of various products and byproducts.
Compliance: The industry is required to make compliance in this regard and record is to be maintained in this regard.
17. Wastewater generated from the oil-water separator should not be discharged anywhere and should be mixed with the carbon powder, which may be sold to the cement manufacturing plants or other such industries.
Compliance: The industry has provided oil water separator and the industry provided arrangement for mixing of wastewater with carbon powder and record for sale of carbon is to be maintained in this regard.
18. The generation, transportation and disposal of carbon black powder to the cement manufacturing plants or any other such industry will be recorded through proper manifest system and no third party should be involved in its disposal.
Compliance: The industry is required to make compliance in this regard. The industry is required to submit record in this regard to Board on regular basis.
19. A green belt of minimum 4 mts. width all along the boundary of the plant should be developed with minimum three rows of broad-leaved trees. Open space to be left after the green belt for the movement of the fire tenders should be 6.0 mts. all around the plant or as per the requirement of National Building Code of India (NBG) — 2005, whichever is more. And any amendments from time to time will be applicable at that time. No material is allowed to be stored in this open space.
Compliance: The industry has provided 3 row of sapling along the boundary. The industry has left space around processing shed for movement of fire tenders.
20. The raw material, product, (oil) and carbon powder (by-product) shall be stored in areas separate/distinct from the processing area (shed where the reactors are installed), open space provided for green belt and open.
Compliance: The raw material is stored in open, carbon powder is stored underneath the processing shed and oil is stored in tanker outside the processing shed.
21. The flare room should be located at the farthest place from the processing shed in an area other than the green belt and open space.
Compliance: The industry has provided flare mechanism in the one corner of the industry.
22. At least three digital pressure and temperature gauges outside the reactor should be provided which should be easily readable to a person on the floor for accurate measurement of the reactor pressure and temperature.
Compliance: The industry has provided total 4 pressure and temperature gauge (3 manual, 1 digital) outside the reactor.
23. There will be one emergency exit route for the pyrolytic gases in the reactor operated through a spring loaded valve which should automatically open in case of any emergency e.g. uncontrolled rise in reactor pressure, The exit should be connected with the existing APCD / Stack provided with the reactor for the discharge of emissions from the fuel burning.
Compliance: The industry has provided bypass system with reactor for flaring pyro gases in case of emergency alongwith the stack of scrubber.
24. Arrangements for water sprinkling on the reactor will be provided which will get automatically activated along with the activation of pressure release valve.
Compliance: The industry has provided water sprinkling line on the roof of processing shed.
25. A sensor for CO gas will be installed in the main working area to ensure that concentration of CO in the working area does not exceed the prescribed limits for occupational safety and health. It will also be coupled with a warning/alarm system so that the plant operator can take adequate steps to rectify the situation.
Compliance: The industry has provided CO sensor in processing shed.
26. Appropriate Onsite emergency plan, as per requirements under the Factories Act, 1948, will be made and implemented to handle any accident, fire leakage or any other emergency situation. All such measures shall include raw material storage, product storage and handling thereof.
Compliance: The authorized person of Director of Factories has prepared onsite emergency plan and the industry has submitted of the same in this office. The industry has provided fire stopping arrangement in the processing shed.
27. The plant will be operated under the continuous supervision of a qualified person with a minimum of two years experience in a similar process.
Compliance: The industry has informed that only qualified person will operate this plant.
28. All the persons/workers in the premises should wear an-air filter mask to avoid inhaling of the fine carbon black particles.
Compliance: As per Sr. no. 9.
29. Plants will confirm to all safety measures as provided in Factories Act, 1948 and fire safety norms.
Compliance: The authorized person of Director of Factories has prepared onsite emergency plan and the industry has submitted of the same in this office. The industry has provided fire stopping arrangement in the processing shed.
30. The plants will maintain good house-keeping and will ensure that no raw material, products and by-products get spilled inside or outside the plant.
Compliance: The industry is required to maintain this compliance on continuous basis during its operation. Presently there is no spillage inside or outside the plant. From above, it is clear the industry has neither provided pneumatic/screw conveyor systems for removal of carbon powder from the reactor nor conveyor system for bagging of carbon powder & with the installation of alkali scrubber alongwith 30 meter stack height with bagging plant.
Now, the industry is complying with the 'Standard Operating Procedures' (SOPs) issued by CPCB on 16.01.2024 prescribed for re-cycling of waste tyre scrap for the recovery of tyre pyrolysis oil, pyro gas and char and also complying with all the conditions imposed by the Site Appraisal Committee in the site clearance granted to it dated 17.05.2023.
In view of above, it is, recommended that the case may be forwarded to Zonal office, Bathinda with recommendations to grant consent to operate under Water Act,1974 & Air Act. 1981 for a period upto 31.12.2024 for half of the capacity for which NOC has been issued (as the industry has only installed one reactor) with the condition to make compliance as mentioned in table attached.
(Competency – SEE) (Small Scale)
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