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The report/ recommendations of RO in the application has been perused and it was noted that the project proponent has applied for obtaining fresh consent to establish (NOC) from pollution angle under the provisions of the Water (Prevention and Control of Pollution) Act, 1974 and the Air (Prevention and Control of Pollution) Act, 1981 for development of Commercial Plots @ 6 nos.
The project proponent has proposed that there is total fresh water requirment is 2.16 KLD and total wastewater generation @ 1.72 KLD and the same will be treated in STP of capaciy 5 KLD. After tratment in STP, the entire treated wastewater will be utilized for sprinkling along road sides for dust suppression till they get sewer connection.
The RO has commented on the proposal that in absence of alternate disposal arrangement, the project proponent has proposed to dispose 1.75 KLD for sprinkling of dust suppression till it gets sewer connection, which seems adequate in principle.
However, in a similar application for CTE applied for the project 'Yuwenia Walk' App ID 30509393, the RO had reported that the project has not provided adequate disposal for the excess treated wastewater and proposing the entire excess treated wastewater (@ 2 KLD) for sprinkling along road side, which is not sufficient during rainy and winter season. The same application had been recommended for refusal of CTE.
In this regard, it is brought out that the project proponent has proposed disposal of the surplus treated effluent (approx. 1.72 KLD) through sprinkling for dust suppression, by citing the directions of the Hon’ble National Green Tribunal dated 03.12.2020 in O.A. No. 283/2020. It is clarified that the said NGT order is specifically applicable to Municipal Corporations/Urban Local Bodies for mitigation of ambient air pollution through systematic sprinkling of treated STP water on public road networks and pavements prior to mechanized sweeping, being an institutional measure contemplated under GRAP/NCAP frameworks. The Tribunal has expressly directed that “all Municipal Corporations/Local Bodies… ensure sprinkling of water before sweeping of roads, using treated water from STPs” and submit quarterly reports through the State AQMC mechanism. Thus, the operative directions are addressed to road-owning public agencies and not to individual industrial or commercial establishments. Further, sprinkling for dust suppression is inherently seasonal and intermittent, and cannot be treated as a reliable and continuous effluent disposal route, particularly during monsoon/rainy periods when dust suppression is neither required nor operationally feasible. Accordingly, disposal of treated effluent through such ad-hoc sprinkling cannot be considered a tenable, permanent or compliant mode of effluent management under the Water (Prevention & Control of Pollution) Act, 1974.
Also, it is brought out that the project proponent has not proposed any reuse of treated effluent for flushing by provision of dual plumbing arrangement, which is mandated as per Board's order no. 315 dated 05.07.2018.
In consideration of the above ; if approved, the competent authority be recommended that the application of the project proponent for Consent to Establish (NOC) under the Water Act, 1974 & the Air Act, 1981, be refused as the effluent disposal proposal is not adequate/ appropriate.
Comp.: SEE, ZP-1
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