| File Note: |
Discussed and the report/ recommendations sent by RO has been examined and it was noted as under: # It is noted that the last application submitted by the unit was returned at the scrutiny stage on the specific ground that the industry had not applied for renewal of Consent to Operate (CTO) under the provisions of the Water (Prevention & Control of Pollution) Act, 1974, for operation of its effluent outlet, and had only applied for renewal of CTO under the Air (Prevention & Control of Pollution) Act, 1981. In response, the industry has submitted that it had applied twice for renewal of CTO under the Water Act, 1974, however, the same was withheld by the Investment Bureau, Punjab due to non-availability of sewerage connection, and has undertaken to apply for renewal immediately upon receipt of sewerage connection from GMADA. The RO has not commented or verified regarding the veracity of the submissions of the unit. # It is further observed that no online record is available regarding the CTOs granted or refused to the project proponent under the Water (Prevention & Control of Pollution) Act, 1974. Further, the RO has not mentioned the status and validity of any previous CTO under the Water Act, 1974, nor commented upon the compliance status of conditions imposed thereunder. # The RO has reported in its inspection/visit report that the Sewage Treatment Plant (STP) was found operational at the time of visit. However, the RO has not clarified whether effluent samples from the STP outlet were collected during the visit for monitoring purposes. In case no samples were collected, the reasons for the same have not been recorded. Further, details regarding the date of last effluent sampling, parameters analysed, and results thereof from the Board’s laboratory have also not been mentioned. # The mode of disposal of treated effluent being presently adopted by the project proponent, in the absence of an operational sewerage connection (as per the unit’s own submission), has not been clearly brought out or verified by the RO. # It is observed that the project proponent has installed DG Sets of capacities 250 kVA and 500 kVA, which would result in generation of hazardous waste falling under Categories 5.1 and 5.2 of the Hazardous and Other Wastes (Management & Transboundary Movement) Rules, 2016. The unit, in its reply, has merely stated that it shall obtain authorization under the HWM Rules, 2016 “if applicable”. It is pertinent to mention that a specific condition was imposed in the last CTO granted under the Air Act, 1981, requiring the unit to obtain authorization under the HWM Rules, 2016 within a period of 15 days. Despite the apparent non-compliance of this additional condition, the RO has recommended grant of CTO, without recording any justification or compliance verification. In view of the above shortcomings, if approved, the application may be returned to the RO with directions to obtain the requisite clarifications/documents from the project proponent and to resubmit the case along with fresh, reasoned recommendations. |