| File Note: |
It is intimated that the project proponent has submitted a reply of the SCN issued and same is attached herewith which be persued. Content of the reply submitted by the project proponent are reproduced as under:-
"We are running a duly approved mega project (Mall cum Multiplex) under the Punjab Government Mega Project Policy 2003. The mall adheres to all statutory compliances and had received consent from the Board to operate under Section 25 of the Water (Prevention & Control of Pollution) Act 1974 and Section 21 of the Air (Prevention & Control of Pollution) Act 1981 well before operations of the Mall.
We have installed proper and adequate pollution control devices in the Mall, which formed the basis for obtaining consents in 2012. These consents have been duly renewed on annual basis up to 2023 following inspections by the Board's representatives. Our pollution control devices consistently meet the emission standards prescribed by the Board and the Ministry of Environment and Forests, New Delhi, under the Environment (Protection) Act 1986. We ensure compliance on day to day basis and maintain data accordingly through tests, samples, and reports.
It is a matter of record that due to the company's name change from Alena Ventures Limited to VR Majha Limited, we applied for renewal of the existing consents under the new name. The Board instructed us to apply under the varied category through the Invest Punjab Portal, a procedure we have duly adopted and followed. Documentary proof of the company's name change from Alena Ventures Limited to VR Majha Limited has already been submitted to Regional office Amritsar. Copy of the same is also being attached herewith as Annexure - A for your kind consideration.
It is a matter of record that the unit was visited by an officer of the Board on 22/01/2024. According to their analysis report, the concentration of various parameters exceeded the permissible limits. However, as previously stated, we adhere to daily SOPs and maintain data and analysis reports of the same on quarterly basis. We are submitted analysis reports dated 23/12/2023, 26/03/2024 & 05/06/2024 for your kind consideration. These reports demonstrate that the results are within the prescribed limits. Copy of analysis reports dated 23/12/2023, 26/03/2024 & 05/06/2024 attached as Annexure - B for your kind perusal.
There is a six-month gap since the visit by the concerned officer of the Board. Therefore, we kindly request that the unit be visited once again, and that fresh analysis reports be requested and conducted.
1. Our Mall is operations since 2012 and all pollution control devices are in proper working condition along with STP.
2. Agreed.
3. Agreed as a matter of record that we are recording and maintaining the data at the outlet. We have provided water meter at the line leading to gardening and flushing tank storage but we were never directed to keep records of the same hence it is requested to kindly consider our request to maintain this data now onwards. Water meter installed at the line leading to flushing area was not working in place of gardening and the same will be replaced shortly. We assure to maintain data of each outlet now onwards as per satisfaction of the Board.
4. The Mall is utilizing wastewater for gardening and flushing purposes, water meters are placed in each outlet but due to lack of knowledge we were not maintaining the data of the same. We were never directed by the representative of the Board for this now as per the directive of the representative of Board, we ensure to keep these records updated on day to day basis.
5. This is matter record that we have separate line for flushing and cleaning through waste water. We are not using fresh water for washroom and in kitchen. We assure to maintain record of the same now onwards."
It is further intimated that During visit dated 06.06.2024 it was observed that the shopping mall has 02 no. submersibles for abstraction of fresh ground water. As per details submitted the shopping mall has applied for obtaining permission from PWRDA 7560 m3/month (252 KLD).
Now, the mall has claimed that they are recirculating treated effluent into flushing purpose, for gardening and makeup into colling towers. It has also claimed in its submission (point no. 5) that they are not using fresh water for washroom and in kitchen. The shopping mall has submitted water balance for recycling of treated effluent but overall consumption of the freshwater is missing for which the mall has installed 02 no. submersible pumps and has obtained permission from PWRDA @ 7560 m3/month.
The reply of the project proponent has not contained actual facts. It is therefore recommended that show cause notice for refusal of the consent to operate under Water (Prevention & Control of Pollution) Act, 1974 may be issued to the industry with an opportunity of personal hearing before Competent Authority of the Board.
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