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It is submitted that the industry is an existing Common Bio-Medical Waste Treatment Facility (CBMWTF), categorized as a Small Scale Red Category unit, and was granted Consent to Operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 vide No. CTOW/Renewal/MKS/2023/20851358 dated 06.04.2023 and under the Air (Prevention & Control of Pollution) Act, 1981 vide No. CTOA/Renewal/MKS/2023/20851312 dated 21.04.2023, both valid up to 31.03.2028, for processing Bio-Medical Waste @ 10 TPD (3000 TPA) through an incinerator of capacity 250 kg/hr, an autoclave of capacity 250 Ltr./batch (45-minute cycle), a shredder of capacity 300 Kg/hr for shredding Bio-Medical Waste, and three encapsulated sharp pits (each of size 2 m × 2 m × 2 m), subject to suitable conditions mentioned therein.
Further, the industry was granted expansion Consent to Establish (NOC) under the provisions of the Water Act, 1974 and the Air Act, 1981 vide No. CTE/Exp/MKS/2022/17269164 dated 13.07.2022, valid up to 12.07.2023 for installation of an additional incinerator of capacity 200 kg/hr (standby) for processing 10 TPD (3000 TPA) of bio-medical waste.
The industry was also granted Environmental Clearance under EIA notification dated 14.09.2006 for installation of CBWTF vide no. SEIAA/2018/878 dated 16.07.2018 for equipment’s, i.e. for 2 nos. incinerator of capacity @ 250 Kg/hr, 2 nos. autoclave of capacity @ 250 litres., 1 no. Shredder of capacity @ 300 Kg/hr and 1 no. effluent treatment plant of capacity 4.5 KLD.
To assess the compliance status of the facility, inspections were carried out by the officers of the Board on 14.07.2025 and 14.10.2025, and an e-Noting vide No. 29175562 was generated highlighting the shortcomings observed during the visits, which was forwarded to the competent authority for further necessary action.
Meanwhile, the industry has applied through the OCMMS portal dated 24.10.2025 for obtaining varied Consent to Operate under the Water Act, 1974 and the Air Act, 1981 for operation of the additional 200 kg/hr incinerator (standby), without any increase in treatment capacity or land area.
The non-compliances observed during the inspection dated 14.10.2025 were processed in the applied case and forwarded to the competent authority and recommended that the consent granted under the provisions of the Water Act, 1974 and the Air Act, 1981 may be revoked and further action be initiated against the industry, for the violations observed. Subsequently, the competent authority issued a show-cause notice vide No. 3666 dated 05.12.2025, proposing refusal of varied Consents to Operate and revocation/cancellation of the earlier granted Consents to Operate under the Water Act, 1974 and Air Act, 1981, while granting an opportunity to submit a written explanation within 10 days.
The industry has submitted point-wise clarification to the show-cause notice dated 13.12.2025 (copy attached).
The industry has submitted a CA Certificate dated 13.10.2025, reflecting a Fixed Capital Investment (FCI) of ₹260.01 lakhs, including plant & machinery worth ₹172.57 lakhs during FY 2025–26.
Further, the unit has submitted the Pre-commissioning Check-up Report (Sr. No. 375118 dated 18.08.2025) and Commissioning & Handing-Over Certificate dated 22.08.2025 for the additional 200 kg/hr incinerator from M/s Thermax Limited. Compliance to the conditions imposed in the NOC has also been submitted in the annotated form.
The industry has deposited consent fees of ₹72,000/- each under the Water Act, 1974 (Receipt No. HDFCN52025101639862485 dated 16.10.2025) and under the Air Act, 1981 (Receipt No. HDFCN52025101639855036 dated 16.10.2025).
The industry had not obtained extension of NOC for installation of the additional 200 kg/hr incinerator (standby). As per Board’s Office Order No. 524 dated 29.10.2018, failure to obtain/renew consent within the stipulated time attracts a penalty equivalent to the year-gap consent fee. After accounting of previous balance fees, NOC regularization charges, and applicable penalty, the consent fee under both Acts has been found adequate up to 30.09.2030.
To re-access the compliance status of the CBMWTF, the unit was inspected by the Er. Ravi Pal, Environmental Engineer and Er. Sahil Goyal, Asst. Environmental Engineer on 30.12.2025, and the following observations were made:
1. The facility was found operational at the time of inspection.
2. The facility has installed an incinerator of capacity 250 Kg/hr (in-operational) equipped with a venturi scrubber as an Air Pollution Control Device (APCD). The system comprises a water tank with drop separator, packed bed, activated carbon filter, mist eliminator, and ID fan, all housed within a shed. Industry has rectified the leakages in the scrubber observed during the last visit.
3. The facility has installed an additional incinerator of capacity 200 Kg/hr (Standby, not in operation) equipped with a venturi scrubber as an Air Pollution Control Device (APCD). The system comprises a water tank with drop separator, packed bed, activated carbon filter, mist eliminator, and ID fan, all housed within a shed. The industry has provided a common stack for both the incinerators, with adequate height.
4. The facility has installed one autoclave of capacity 250 Ltr./batch (45-minute cycle), one shredder of capacity 300 Kg/hr for shredding Bio-Medical Waste, and three encapsulated sharp pits (each of size 2 m × 2 m × 2 m) for the storage of sharps after disinfection through autoclaving. However, all these units were found non-operational at the time of inspection.
5. The industry has provided pacca floor in the processing shed with proper slope to collect the floor washing, discharge of autoclave into open drain leads to ETP.
6. Yellow category waste was being incinerated in the incinerator of capacity @250 Kg/hr and emission of whitish-grey smoke was observed from the stack.
7. The facility has installed an Effluent Treatment Plant (ETP) comprising one reaction tank (using alum for treatment of scrubbing water) for the treatment of trade effluent generated from the autoclaving section, vehicle washing area, and wastewater from the venturi scrubber. The industry has developed plantation area for discharge of treated trade effluent in about one kanal land which is adequate to handle treated effluent @ 4.5 KLD. The ETP was operational during the visit; however, there was no discharge at the outlet, therefore the water samples could not be collected.
8. The EMF has been installed at the outlet of ETP and the cumulative discharge was recorded. The representative informed that the EMF has been ordered for inlet of ETP and would be installed within one week.
9. The facility has renewed the Bank Guarantee of Rs. 5.0 lakhs vide no. 07550ILG000225 dated 11.12.2025 valid up to 10.12.2027. (copy attached)
10. The facility has updated and maintained the records of fresh water intake; effluent generated from the ETP and hazardous waste generated within the premises.
11. The industry is complying with the conditions of the quantity of the fresh water intake granted which is 5 KLD as per the Environmental Clearance granted and the effluent generated from the process is also within permissible limits which is up to 4.5 KLD. During the last visit, the fresh water intake and effluent generated was found beyond the permissible limits due to the leakages observed in scrubber which has been rectified by the industry.
12. The facility has installed a separate sub-meter for every equipment (Incinerator/Autoclave/Shredder/ETP). Daily electricity consumption is around 200-250 kW. The representative has informed that during the last visit, the electric meter was faulty, due to which it was reflecting 500 kW but now it has been rectified.
13. The facility has provided a separate storage room for Plastic waste & glass and an additional room for storage of hazardous waste generated within the premises.
14. The facility has provided septic tank for treatment of domestic effluent with the provision discharge on to land for plantation area.
15. The facility has provided CCTV cameras at entry gate of the unit, at incinerator, at autoclave, at shredder & at unloading of vehicles.
16. The facility has provided fire safety measures, safety measures for workers appointed for treatment of bio-medical waste.
In view of the above, the industry is complying with the provisions of the Water (Prevention & Control of Pollution) Act, 1974, and the Air (Prevention & Control of Pollution) Act, 1981, conditions of the Environmental Clearance granted, and the guidelines of Management of the BMW & HWM prescribed by the CPCB dated 21.12.2016.
If approved, it is recommended that the consent to operate under Water Act, 1974 and the Air Act, 1981 be granted to the industry for operation of common bio-medical waste treatment facility to treat bio-medical waste @ 10 TPD of different categories valid up to 30.06.2030 subjected to suitable conditions which are as under: -
a) The industry will operate its ETP regularly and efficiently to achieve the standards as prescribed by CPCB for such discharge onto land for plantation.
b) The industry will comply with the guidelines prescribed by CPCB for operation of Common Bio Medical Waste Treatment Facility.
c) The industry will maintain the record of operation of the ETP and chemical dosing.
d) The industry will operate its APCD to achieve the standards as prescribed by CPCB for such discharge of emissions into atmosphere.
e) The industry will connect its online monitoring as well as CCTV cameras with the ODAMS of CPCB, a newer, upgraded portal for Continuous Emission/Effluent Monitoring Systems (OCEMS).
f) The industry will provide the GPS system with the vehicles provided for collection of bio medical waste from various locations.
g) The industry will dispose off its plastic waste and glass after disinfect to authorized user/ recycler.
h) The industry will maintain the record of operation of the APCD.
Competency – Chairperson of the Board.
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