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Discussed, please.
The industry is a large scale dyeing unit, which was earlier granted consent to operate under the Water Act, 1974 expired on 08/02/2022 with usual conditions and special conditions that :- 1. The industry shall achieve the stringent standards as being implemented for the CETPs under all circumstances within one month.
Thereafter, the industry had applied for consent to operate under Water Act, 1974, the sample of the industry was collected on 21.01.2022 and as per the analysis report various parameters are found beyond the prescribed standards and as such the consent application of the industry was refused.
Thereafter, the industry has got the treated effluent samples from outlet of ETP (before RO) analyzed from PBTI Lab, Mohali dated 12.07.2022 and as per the analysis report, the industry is achieving the stringent standards.
The industry had also submitted a written representation before Hon’ble Chairman of the Board for reconsideration of its application for consent to operate under Water Act, 1974 mentioning that the industry had earlier installed MVR system for the treatment and evaporation of RO reject however, it has failed to meet the designed parameters. Thereafter, the industry had installed MEE for treatment of RO Reject. The industry had also informed that they have engaged M/s Enviros India Pvt. Ltd., (EIPL) for achievement of complete ZLD system which shall be covered into two phases.
A. Phase A- Upgrade to further improve the quality of water downstream (primary & secondary) adding tertiary filtration to cater to ZLD compliance I. Up-gradation of ETP Plant (introducing a new technology, named 'Electro Catalytic Oxidation Treatment. II. Installation of RO III. Installation of DIA Filtration for Salt recovery (Brine) IV. Installation of RO for Brine concentration
B. Phase B 1. Installation of Multi Effect Evaporator (MEE) Plant 2. Additionally, an Agitated Thin Film Dryer (ATFD)
The industry has undertaken to complete all the activities by 31.03.2023 and achieve complete ZLD system. The representation was considered by the competent authority of the Board and consent to operate under Water Act, 1974 has granted dated 17/10/2022 valid upto 31/03/2023 with following special conditions :- a) The industry shall achieve stringent standards prescribed by the Board in compliance to the directions issued by the Department of Science, Technology & Environment, Govt. of Punjab vide orders dated 10.10.2019. b) The industry shall take adequate steps to segregate & stop the effluent discharge into domestic sewer by 31.03.2023 in compliance to directions issued by the Department of Science, Technology & Environment, Govt. of Punjab vide orders dated 10.10.2019. c) The industry shall achieve Zero Liquid Discharge (ZLD) by upgrading its existing ETP by 31.12.2022. d) The industry shall continue to operate its ETP regularly and efficiently so as to achieve prescribed standards. e) The industry shall install water meters on all the relevant locations i.e. UF feed, UF Outlet, RO Inlet, RO permeate reuse line, RO reject line, MEE condensate line etc after the installation of complete ZLD system, maintain record of the same and submit to the Board on monthly basis.
Thereafter, the industry was given personal hearing before Hon'ble Chairman of the board on 27.02.2023 wherein it was decided that :- 1. The industry shall continue to operate its ETP regularly and efficiently so as to achieve ZLD status at all times. 2. The industry shall submit complete water balance statement, within 15 days. 3. Direction u/s 33-A of the Water (Prevention & Control of Pollution) Act, 1974 be issued to the industry that the industry shall not discharge its industrial effluent into municipal sewer after 31.03.2023. 4. The Environmental Engineer, Regional Office-2, Ludhiana shall visit the industry immediately and send comments w.r.t ZLD status of the industry and request made by the industry to waive off Environmental Compensation of Rs. 21,37,500/-.
Thereafter, the industry had applied for extension in consent to operate under Water Act, 1974. The industry has submitted a written request stating that it has completed the installation of ZLD system. The industry has deposited the bank guarantee of Rs. 20.00 Lacs, however has not submitted the EC of Rs. 21,37,500/- and has requested for re-consideration of the decision regarding imposition of EC as it has invested a huge amount on the completion of ZLD system. The industry had submitted in writing that it has completed the installation of equipment's for ZLD system as per phase –A & B detailed above. The industry has also submitted an adequacy assessment certificate / study report of ETP based on ZLD system from Guru Nanak Dev Engg. Collage dated 28.02.2023 as per which the study regarding the treatment process and adequacy of the ETP based on ZLD system was got conducted by testing and consultancy Cell of GNE collage, Ludhiana from 27.12.2022 to 28.12.2022 as per which the ETP has been found to be sufficiently designed and the industry is currently operating an ZLD which is sufficiently designed to handled discharge at ETP outflows. The request of the industry was considered by the Competent Authority of the Board and it was decided to reduce the compensation to Rs 8.5 Lacs which has been deposited by the industry. The industry had deposited the environmental compensation of Rs. 8.5 Lacs and CTO under Water Act, 1974 was granted to the industry with changed mode of disposal and with adoption of ZLD process valid upto 31.03.2024.
Meanwhile, a complaint has been received conveying the CCTV footages regarding emitting of black smoke from the stack of the industry.
Accordingly, the site of the industry was visited by RO on 14.11.2023 and it was reported as under:- 1. The industry was in operation during visit and is engaged in the process of dyeing, knitting and garment manufacturing. 2. The industry has installed 02 boilers of capacities one of 1.5 TPH (Standby) & one of 08 TPH (Operational) with common trima cyclone as APCD and common stack of adequate height. 3. The industry was using rice husk as fuel, the black smoke was found to be emitting from the chimney of the boiler due to high moisture content in the rice husk, which was being used as fuel in the boiler furnace. 4. The wet rice husk also impacts the working of the APCD as the trima cyclone can only entrap particulate matter, however cannot act on the smoke generated due to usage of wet fuel. 5. The industry has installed 07 of D.G. sets of capacities of 380 KVA each, which are equipped with canopy/acoustic enclosure and adequate stack height.
Accordingly, a show cause notice for revocation of consent to operate granted under the Air Act, 1981 was issued to industry with hearing before the CEE, Ludhiana on 20.12.2023. Wherein, it was decided as under:- 1. The industry shall ensure that black smoke is not emitted at any time in future. 2. The industry shall submit the Bank Guarantee of amount Rs. 5 lacs as an assurance to comply at all times the provisions of Air (Prevention & Control of Pollution) Act, 1981, in future. 3. Environmental Engineer, Regional Office shall visit the industry to verify the compliance decisions of hearing and submit the report for taking further action in the matter. 4. In case the industry fails to comply with the provisions of Air (Prevention & Control of Pollution) Act, 1981 in future the consent shall be revoked without giving any further opportunity of show cause/hearing.
Present case Now, the industry has applied for renewal of consent to operate under Water Act, 1974 & Air Act, 1981. Accordingly, the industry was visited by RO on 27.02.2024 and it was reported as under:- 1. The industry was in operation during visit and is engaged in the process of dyeing, knitting and garment manufacturing. 2. The industry has installed fabric dyeing machine containing of 2 no. soft flow machines of capacity 600 kg, 1 machine @ 350 kg, 1 machine @ 250 kg, 2 machines @ 100 kg/each , 1 machine @ 50 kg , 1 machine @ 30 kg, 1 machine @ 15 kg, 1 machine @ 2 kg (sample) 3. The industry has installed yarn package machine containing of 1 no. machines of capacity 600 kg, 1 machine @ 400 kg, 1 machine @ 200 kg, 2 machines @ 100 kg/each , 3 machines @ 25 kg each , 1 machine @ 10 kg, 1 machine @ 5 kg, 1 machine @ 2 kg, 1 machine @ 1 kg. 3. The industry has provided PPPU pump for scientific condensate recovery with the all the dyeing machines. 4. The industry has installed 2 no. relax drier, 10 no. tumbler drier in the dyeing premises. 5. The industry has installed various knitting machine, cutting machine, stitching machine in the garment manufacturing unit. 6. The industry has installed ETP based on physico chemical followed by biological treatment of the trade effluent generated from dyeing process. The industry has provided UF+RO for further treatment after ETP followed by MEE. The RO permeate is utilized back in the process and RO reject is feeded to MEE system. 7. The record maintained by the industry for the month of (i.e. after the installation of ZLD system) was scrutinized and as per the record maintained by the industry and water balance was found to be correct. 8. The representative of the industry informed that the ETP is adequately designed to handled discharge of 600 KLD which has also been mentioned in the GNE report. Further, he also informed that presently the discharge is less due to the off season. 9. The industry has completed the installation of ZLD system and has cut off its treated water discharge into sewer which has been duly verified and assessed by GNE collage as per report dated 28.03.2023. Further the operation of ETP based on ZLD was also verified by officers of this office during visit on and the EMF meters and the record maintained by the industry was checked and it was found that the industry has completely cut-off the discharge into sewer line and is managing the entire effluent inside the industrial premises through ZLD process and has thus complied with the Govt. notification dated 10.10.2019. 10. As far as the compliance to the provisions of Air Act, 1981 is concern, the industry has installed 2 no. boilers, one rice husk fired of 8 TPH capacity with multi cyclone as APCD and 2nd briquette fired boiler of capacity 1.5 TPH with cyclone as APCD. During visit air emission samples of 8 TPH boiler were collected and the results are awaited. 11. The industry has not deposited bank guarantee of Rs. 5.0 Lacs as per the decision of the personal hearing held before CEE on 20.12.2023. 12. Further, a video has again been received on 11.03.2024 regarding the black smoke being continuously emitted by the stack of the industry. As per physical conditions the APCD provided by the industry is old and requires up-gradation immediately as repeated black smoke emissions are being observed from the stack of the industry. Further, the industry has not complied with decisions of the personal hearing held before CEE on 20.12.2023.
The industry has already have a Bank Guarantee of Rs. 20 lacs deposited with PPCB since November 2022 against ZLD commitment. PPCB visited and conducted their own testing on 27/02/2024. The results are way below the required norms in both PBTI & PPCB test results.
In view of above, it is recommended as under:-
1. The consent to Operate under Water (Prevention & Control of Pollution) Act, 1974 may be granted for six months with suitable conditions and special condition that the industry shall provide Online Continuous Emission Monitoring System with its stack and connect with PPCB/CPCB server, immediately.
2. A committee is required to be constituted to study the evaporation of RO reject to adjudge the adequacy of ZLD, please.
Competency :- Hon’ble Chairman of the Board.
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