| File Note: |
It is submitted that the industry is a small-scale red category unit. The industry has applied for obtaining “Consent to Establish” (NOC) under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 for manufacturing of Recovered Solvent @ 20 KLD by using Spent Solvents @ 24 KLD as raw material alongwith requisite documents and fee.
NOC fee
The industry has submitted brief project report and as per which the total project cost is Rs. 7.00 crores. The industry has deposited Rs. 22,100/- vide R. No. 491427098 dated 03.07.2024 including application form fee. The NOC fee deposited by the industry is adequate for one year.
Suitability of site
The industry has submitted the copy of land classification certificate issued by DTP SAS Nagar vide no. 906 dated 24.06.2024, as per which the site falls under Industry Zone and existing/proposed (150 ft) road as per Master Plan, Lalru bearing Khasra No. 2515/306 (5-0), 2513/295 (2-0) and 294 (4-0) total land 11 Bigha 0 Biswa (approx. 2.29 acres).
Further, during site visit it was observed that there is no residential area, village phirni/lallakir within the 100 mtr boundary wall of the project.
It is pertinent to mention here that the CPCB has issued Standard Operating Procedure for units engaged in recovery of spent solvent in August, 2019 and the Para 8.0 of the said SOP relating to the siting criteria for such industries is reproduced as under:
“Facilities for utilization of Spent Solvent shall be located in a notified industrial area or industrial park/ estate/ cluster and in accordance with Consent to Establish issued by the concerned SPCB/ PCC.”
As such, the site of the industry is suitable for establishment of the unit.
Land Documents
The industry has submitted the lease deed issued on dated 08.05.2024 between Sh. Dhruv Mangla (First Party) and M/s GMK Ingrevia Pvt. Ltd., of area of land 11.0 Bigha 0 Biswa at village Samgoli, Tehsil Derabassi, Distt. SAS Nagar, which is valid upto 07.05.2039.
Manufacturing Process
Crude Solvent Storage TankSS reactor/GLR SS reactor/GLRDistilled Solvent Collection Tank.
Water Pollution
As per the application form, the industry will generate trade effluent @ 1.0 KLD i.e. waste water to be generated from washing of reactors, floor cleaning etc., which will be treated in ETP and will be discharged onto land for plantation. The condensate will be reused in the cooling tower and the concentrate sludge will be disposed off to TSDF Nimbua.
The domestic effluent generation @ 0.8 KLD, which will be discharged onto land for plantation after treatment in septic tank.
Air Pollution
The industry has proposed to install 2 nos. Thermopack of capacities 200000 Kcal/Hour and 300000 Kcal/Hour with Water Scrubber as APCD in which wood will be used as fuel.
The industry has proposed to install one no. DG set of capacity 65 KVA, which will be equipped with canopy and adequate stack height.
Applicability of EIA notification dated 14/9/2006/ Press Note 17 (1984 series)
The spent solvents are highly flammable liquids as such, the industry might be covered under the First Schedule of Factories Act, 1948 and required to obtain site clearance under the said Act. It is mentioned here that Govt. of Punjab, Deptt. of labour vide letter no 7319-45 dated 27.08.2013 has exempted the industries from obtaining the site clearance which are to be established in the designated/ approved area. Since the industry is to be established in the industry zone, as such, the industry is not required to obtain said clearance under the Factories Act, 1948. Further, the Press Note 17 (1984 series) has been discarded by the Ministry of Commerce & Industry, Govt. of India through Press Note 3 (2019 series) dated 11/09/2019. As such, the industry is not required to obtain permission under the Press Note 17 (1984 series).
Regarding applicability of the EIA Notification dated 14/09/2006, it is added here that as per EIA Notification dated 14/09/2006, the synthetic organic chemicals manufacturing units are covered under category 5 (f) of the said notification. Since, this industry is to carry out only distillation of spent solvent and to manufacture thinners by way of mixing of recovered solvents as such no chemical synthesis process is involved in the manufacturing activity of the industry, therefore, the industry does not attract the provision of the EIA Notification dated 14/09/2006.
Visit
The site of the industry was visited by AEE of this office on 04.07.2024 and during visit, it was observed that: -
1. The site is located in Village Samgauli, Tehsil Derabassi, SAS Nagar.
2. The industry has provided boundary wall at the site.
3. The industry has not installed any plant and machinery.
Recommendations
Keeping in view of the above, it is recommended that “Consent to Establish” (NOC) under the Water (Prevention & control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 may be granted for one year subject to suitable conditions and additional conditions that: -
1. The NOC is only valid for establishment of unit at Khasra No. 294/295/306, Village Samgauli, Tehsil Derabassi, District. SAS Nagar for manufacturing of Recovered Solvent @ 20 KLD by using Spent Solvents @ 24 KLD as raw material.
2. The project proponent shall get it site plan approved from the Competent Authority before starting any development work. The NOC/consent to establish has been granted based on the proposed site plan of the project proponent and if in case, site plan not approved by the competent authority, the NOC shall be revoked automatically.
3. The industry shall not operate its unit till it obtains valid “consent to operate‟ under the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 and authorization under the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
4. The industry shall not procure its raw material i.e. spent solvents, till it obtains 'Actual User Certificate' issued under Rule 9 of the Hazardous and Other Wastes (Management and Transboundary Movement) Rules, 2016.
5. The industry shall obtain permission from Petroleum and Explosives Safety Organization (PESO) for storage transportation and handling of solvents etc.
6. The industry shall provide VOC monitors at primary and secondary vent condensers and shall connect the same with the server of the Board.
7. The industry shall install suitable fire fighting system and obtain fire NOC from the concerned department and shall submit the same at the time of consent to operate.
8. The industry shall comply with the SOP (standard operating procedure) for recovery of spent solvent issued by the CPCB in Aug-2019, in true letter & spirit.
9. The project proponent shall obtain the permission from PWRDA for abstraction of ground water.
10. The industry shall obtain permissions from other concern departments, if need be.
11. The industry shall maintain the record of fresh water consumption.
12. The industry shall re-circulate the entire water of the cooling tower.
13. The industry shall discharge only domestic effluent onto land for plantation within premises after passing through the septic tank as proposed by it.
14. The industry shall not discharge the effluent into any drain/choe/nallah, in any case.
15. The industry shall not discharge any effluent at any unauthorized place by any unauthorized means i.e. shall not discharge any wastewater in any drain / inland surface waters / drain/choe/nallah/ onto land for stagnation or outside its premises, at any time, under any circumstances.
16. The industry shall ensure that the activity of unit does not create any nuisance in the surrounding areas and no public complaints are received.
17. The NOC is being issued to the project proponent based upon the documents/ information submitted by it alongwith the online application form. The Board would be at liberty to take penal action against the industry/project proponent and its responsible/ concerned person(s) in case information/document is detected as incorrect/false/misleading at any point of time, without any opportunity of Personal Hearing.
18. In case the project proponent fails to comply with the provisions of the Water (Prevention & Control of Pollution) Act, 1974, Air (Prevention & Control of Pollution) Act, 1981, Environment (Protection) Act, 1986 and/or any other environmental law applicable to the project and Rules, Circulars & Directions issued by the Board from time to time, action as deemed fit shall be taken against the project proponent.
Competency: Senior Environmental Engineer
Date of Receipt : 03.07.2024
Date of Scrutiny : 04.07.2024
Date of Deemed Approval : 26.07.2024 |
