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Subject: Proceedings of the personal hearing given by the Chief Environmental Engineer (B) of the Board for refusal of renewal of consent to operate under the Air (Prevention & Control of Pollution) Act, 1981 to M/s K.S. Alloys, Village Kumbh, Amloh Road, Mandi Gobindgarh on 29/07/2024.
The following were present:
From the Board:
Er. Rajeev Gupta, Sr. EE, ZO-II, Patiala
Er. Amit Kumar, EE, ZO-II, Patiala
From the Industry :
Sh. Ashok Kumar, Partner
Environmental Engineer, Zonal Office-II, Patiala brought that the industry was granted consent to operate under the provisions of the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Varied/FGS/2023/21944667 dated 19/06/2023 valid upto 31/12/2023 for manufacturing of MS Billets (with CCM) and Castings @ 84 MTD or Round, Square, Flats and Angles (Rolling mill unit) @ 84 MTD or ERW Pipes @ 80 MTD by using Melting Scrap, Sponge Iron and Ferro Alloys @ 92.0 MTD as raw material, with certain conditions mentioned therein.
During the area visit of the Mandi Gobindgarh, it was observed that black smoke was being emitted in the atmosphere from the industrial premises of the industry. To verify the source of emission, the industry was visited by the officer of the Board on 23/10/2023 and observed as under:
1. The industry was in operation and engaged in the business of manufacturing of Rounds by using iron scrap as raw material.
2. The industry has installed induction furnace of Capacity 10 TPH and the same was found in operation.
3. The industry has installed side suction hood system followed by Bag Filter house as APCD to contain the concentration of particulate matter within the prescribed Standards and the same was found in operation.
4. About 60% emission from the melting of scrap was being escaped into the shed by-passing the side hood, which indicates that either the APCD installed by the industry is inadequate or it is not being operated effectively.
Show cause notice for cancellation of Consent to operate granted under the Air (Prevention & Control of Pollution) Act, 1981 was issued to the industry with an opportunity of personal hearing before the Chief Environmental Engineer on 17/11/2023.
Sh. Ashok Kumar, Partner of the industry attended the personal hearing and submitted the written reply, which was taken on record. He further stated that at the time of visit of officer of the Board, the industry was in a process of transferring the molten metal from the crucible of the furnace. Only oxidized gases were present at that time. The industry has also extended the size of the hood to collect maximum emissions. He further requested to drop the notice.
After hearing the officer of the Board and representative of the industry, Chief Environmental Engineer (B) Patiala decided that :
1. To improve the efficiency of bag house of the existing APCD, the industry shall up-grade its bag filters in the bag house in the existing APCD as per the specifications given below within one month and shall get it verified/ certified from PSCST, Chandigarh.
Filter medium/Scrim Three polyester batt layer needle felt (Profiled microfibres + microfibers) 2 layers of high strength woven scrim from filament textured yarns with an inter-batt layer Premium Fibre Blend/Scrim: PTFE Treatment : full bah PTFE finish
Thickness Range from 2mm to 2.5mm Range from 2mm to 2.5mm
Basis weight 650 grams/square meter 650 grams/square meter
Finish Oil & water repellant Oil & water repellant
Temperature resistance 80-100 oC/ peak 150 oC 80-100 oC/ peak 150 oC
2. The industry shall submit the proposal regarding control of Secondary Emissions generated from the process within one month after consultation with the PSCST, Chandigarh.
3. The industry shall submit a bank guarantee amounting to Rs. 2.0 lakh within 7 days as an assurance to comply with the Environmental Laws and Environmental Engineer, Regional Office, Fatehgarh Sahib shall encash 50% of the above said bank guarantee.
4. The industry shall use good quality raw material free from dust and oil.
5. The industry shall develop the adequate green area all around the boundary wall and shall stabilize all of its movement area within the premises of the industry as well as approach around the industry, so as to minimize the dust emissions within one month.
6. A team of the officers shall be constituted by CEE(B) to surprisingly visit the industry to verify the conditions imposed in Environmental Clearance, other compliance of Environmental Laws immediately after one month and shall submit report/ recommendations, thereafter.
In compliance to hearing decision, the industry had submitted 02 no. of bank guarantees for Rs. 1.0 Lakh each vide. No. 0450NDDG00000624 dated 29/01/2024 and 0450NDDG00000724 dated 29/01/2024 both were valid upto 25/01/2025 and the 0450NDDG00000624 dated 29/01/2024 was enchased as per order of Competent Authority vide letter no. 3119 dated 15/03/2024.
Now, the industry has applied for renewal of consent to operate under the Air (Prevention & Control of Pollution) Act, 1981. Accordingly, the industry was visited by AEE of Regional Office, Fatehgarh Sahib on 29/03/2024 During the visit, it was observed as under:
1. The industry has installed induction furnace of capacity 7 TPH along with CCM and rolling mill and the industry has installed ERW pipe plant after rolling mill to manufacture ERW Pipe @ 80 MTD. The induction was not in operation, due to its maintenance
2. The industry has installed spark arrestor followed by bag filter as APCD along with side hood as per design PSCST and the industry has installed energy meter on its APCD and its reading was 451943.
3. The industry has installed 2 nos. DG sets of capacities 125 and 250 KVA, which are equipped with canopy and stack of adequate height.
4. The industry has applied PTEE Treatment: full bath PTEE finish 650 bags on its APCD.
5. Sh. Ashok Sharma, representative of industry was informed he approached to PSCST, Chandigarh and they searching design for control of secondary emission generated from the industry approached to PSCST, Chandigarh and they searching design for control of secondary emission generated from the industry.
6. The industry has installed shredder for segregation and sizing before its feeding into crucible.
7. The industry has planted the plants around the boundary walls and the industry has advised to more plantation.
The industry has not complied with decisions of the personal hearing dated 17.11.2023 as the industry has not submitted the proposal regarding control of secondary emissions generated from the process and has not replaced its bag filters as per the given specifications. Thus, violating the provisions of the said Act and causing pollution intentionally & deliberately in the area.
Show cause notice for refusal of renewal of consent to operate under the Air (Prevention & Control of Pollution) Act, 1981 was issued to the industry with an opportunity of personal hearing before the Chief Environmental Engineer of the Board on 09/05/2024.
The representatives of the industry attended the personal hearing and stated that the industry has complied with the observations made by the visiting team on 20/03/2024. The industry has installed the furnace of capacity 7 TPH and accordingly obtained the consents from the Board. The industry shall submit the bills of M/s Electotherm India Ltd. in this regard. For secondary emissions, the industry is looking for a reliable vendor and he further requested to give some time to install the APCD.
After hearing the officers of the Board and representatives of the industry, Chief Environmental Engineer (B) Patiala decided that :
1. The industry shall submit bills for purchase of induction furnace unit from M/s Electrotherm India Ltd. within 7 days to Regional Office, Fatehgarh.
2. The industry shall submit a feasibility report for the proposed pollution control measures to control the secondary emissions within one month from reputed agency/ chartered institute along with pert chart with respect to the installation of the pollution control measures.
3. The industry will be re-heard after one month.
4. In case no proposal is submitted, action under the provisions of Air Act, 1981 including imposition of EC will be initiated by the Board.
5. The industry shall properly store its hazardous waste i.e. APCD dust in its hazardous waste room and make proper numbering on each bag of hazardous waste being stored in the room, as per the HWM Rules, 2016
6. Environmental Engineer, Regional Office, Fatehgarh Sahib will submit detailed report on the compliance of decision no. 1 and 2, immediately after completion of one month.
7. The renewal of consent to operate under the Air Act, 1981 applied by the industry be granted upto the validity of consent fee deposited by the industry.
A complaint has been received in the Board from the Sh. Rajwinder Singh, Vill. Kumbra regarding pollution caused by the industry. To verify the contents of the complaint, the industry was visited by the officer of the Regional Office, Fatehgarh Sahib on 25/06/2024 and made some observation.
Regular telephonic compalints have been received in the Board, therefore the industry was again visited by the officer of the Regional Office, Fatehgarh Sahib on 10/07/2024 and the energy consumption was calculated for the 120 hp motor running for 140 hours with 90% efficiency is approximately 13,925.38 kWh. However, the recorded electricity consumption for the APCD operation from 01/07/2024 to 10/07/2024 is only 10,814 kWh. This discrepancy suggests that the industry is not operating its APCD efficiently. There is a significant difference between the expected and actual energy consumption, indicating potential inefficiencies or operational issues with the APCD.
The industry has not complied with decisions of the personal hearing given to it from time to time. Thus, violating the provisions of the Air (Prevention & Control of Pollution) Act, 1981 and causing pollution intentionally & deliberately in the area.
Accordingly, show cause notice for refusal of renewal of consent to operate under the Air (Prevention & Control of Pollution) Act, 1981 was issued to the industry with an opportunity of personal hearing before the Chief Environmental Engineer on 29/07/2024.
The representative of the industry attended the personal hearing and submitted that the complainant is making baseless complaints, due to his personal interests. The industry has already installed APCD as per the design of PSCST, Chandigarh same is being operated regularly. SOPs prescribed by the PSCST are being followed in true letter & spirit. He further requested to grant consent under the Air (Prevention & Control of Pollution) Act, 1981 and drop the notice. He assured that no violation will be made by the industry in future.
After hearing the officer of the Board and representative of the industry, Chief Environmental Engineer (B) Patiala decided that
1. The consent to operate under the Air (Prevention & Control of Pollution) Act, 1981 be granted to the industry upto the adequacy of fee deposited by it.
2. The industry shall submit a feasibility report for the proposed pollution control measures to control the secondary emissions within one month from institute of repute / chartered institute along with Pert Chart with respect to the installation of the pollution control measures.
3. The industry shall ensure that no black smoke shall be emitted by the industry at any point of time, in future.
4. Environmental Engineer, Regional Office, Fatehgarh Sahib shall keep the strict watch on the operations of the unit, so that emitting of black smoke can be ruled out during the odd hours.
If approved, the proceedings may be conveyed to the industry as well as Regional Office for ensuring compliance, please.
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