| File Note: |
Online agenda note generated.
It is submitted that the industry has earlier obtained renewal of consent to operate vide no. CTOA/Renewal/SAS/2021/16513601 dated 13/09/2021 having validity upto 31/03/2022 under the provisions of the Air (Prevention & Control of Pollution) Act, 1981 for Decorative paints @ 40000.0 KL/Year, Performance coating (REFINISH PAINT) @20000.0 KL/Year using raw materials ALUMINIUM PIGMENTS @ 6758.0 Kg/Year, chemicals @ 53346 Kg/Year, DRIERS @ 163220 Kg/Year, EXTENDERS @ 1315493 Kg/Year, NITROCELLULOSE @ 249891 Kg/Year, RESINS @ 4668657 Kg/Year, SOLVENTS 6216634 Kg/Year, WATER @ 545599 Kg/Year, ADDITIVES @ 809100.6 Kg/Year, WATER BASED LATEX 10000 Kg/Year, PIGMENTS @ 1069464 Kg/Year along with certain special conditions mentioned therein.
Thereafter, the industry has obtained renewal of consent to operate vide no. CTOA/Renewal/SAS/2022/17830749 dated 21.03.2022 under the provisions of Air Act, 1981, having validity upto 30.09.2025 for Decorative paints @ 40000.0 KL/Year, Performance coating (REFINISH PAINT) @20000.0 KL/Year using raw materials ALUMINIUM PIGMENTS @ 2026 Kg/Year, chemicals @ 141577 Kg/Year, DRIERS @ 181087 Kg/Year, EXTENDERS @ 3293906 Kg/Year, NITROCELLULOSE @ 237013 Kg/Year, RESINS @ 4956593 Kg/Year, SOLVENTS 5868299 Kg/Year, WATER @ 2847729 Kg/Year, ADDITIVES @ 373630 Kg/Year, WATER BASED LATEX 444853 Kg/Year, PIGMENTS @ 1118054 Kg/Year along with certain special conditions mentioned therein.
Also, the industry has obtained renewal of consent to operate under the Water (Prevention & Control of Pollution) Act, 1974 vide no. CTOW/Renewal/SAS/2025/28165905 dated 25.04.2025 having validity upto 30.09.2029 under the provisions of the for Decorative paints @ 40000.0 KL/Year, Performance coating (REFINISH PAINT) @20000.0 KL/Year along with certain suitable conditions.
The industry was granted renewal of CTO under the provisions of the Air (Prevention & Control of Pollution) Act, 1981 vide no. CTOA/Renewal/SAS/2025/30080478 dated 17.12.2025 valid upto 31.03.2026, subject to certain terms and conditions mentioned therein.
Present status
Now, the industry has applied for obtaining renewal of consent to operate under red category (117.1 Manufacturing of solvent based paints/varnish) under the provisions of Air (Prevention & Control of Pollution) Act, 1981 for Decorative Paints @ 40000 KL/Year and Performance Coatings (Refinish Paints) @ 20000 KL/Year using raw materials Additive @ 454935 Kg/Year, Aluminium pigments @ 2291 Kg/Year, CHEMICALS @ 130685 Kg/Year, DRIERS @ 218255 Kg/Year, EXTENDERS @ 3381208 Kg/Year, Nitrocellulose @ 227000 Kg/Year, PIGMENT @ 1569987 Kg/Year, RESIN @ 5505579 Kg/Year, Water @ 3857482 Kg/Year, SOLVENT @ 5994260 Kg/Year, Water base Latex @ 609557 Kg/Year along with requisite documents.
Fee status
The industry had deposited Rs. 440000 vide R.no. 621869187 dated 28.04.2025 under the provisions of Air (Prevention & Control of Pollution) Act, 1981. The fee deposited by the industry is adequate upto 21.06.2028 after adjusting late fee/ penalty as well as NOC regularization fee against the total cost of the industry Rs. 11267.87 lacs as per latest CA certificate submitted by the industry as on 31.03.2026.
While scrutinizing the application, following observations were observed and the project proponent was requested through clarification to submit the reply and the project proponent has submitted the reply and the same is reproduced below:
Sr. No. Clarification Reply by project proponent
1. The detail filled in the application form is not in consonance with earlier granted consent to operate under the provisions of the Air (Prevention & Control of Pollution) Act, 1981. The present application has been filed after the change in category, as guided by the department. Therefore, certain details reflect the current categorization. We respectfully submit that there is no change in manufacturing process, production capacity, pollution control systems, or emission parameters as compared to the earlier consent. The differences observed are only procedural in nature.
We hereby submit the updated details of air stack emissions pertaining to our Solvent Recovery Plant (SRP) for your kind information and record.
2. The industry has not submitted latest CA certificate. As such, the fee deposited by the project proponent cannot be adjudged. The latest Chartered Accountant Certificate, duly signed and stamped, is being uploaded herewith for your kind examination. The same supports the consented fee already deposited by us for a five-year period.
3. The SOP compliance submitted by the project proponent is not proper as no date has been mentioned therein. We acknowledge the observation and submit that the omission of dates was inadvertent. Accordingly, dated SOP compliance documents are now being submitted for your kind consideration.
The industry has submitted compliance report of SOP. However, no date has been mentioned therein.
Visit Report
The site of the industry was visited by the Environmental Engineer, RO, SAS Nagar alongwith the undersigned on 16.04.2026. During the visit, it was observed as under:
1) The industry was in operation. The industry is engaged in manufacturing of Decorative Paints @ 40000 KL/Year and Performance Coatings (Refinish Paints) @ 20000 KL/Year.
2) The representative informed that the waste-water is sent to ETP plant from the processing section in mobile containers known as Totes.
3) The industry has installed ETP of capacity 2.5 KLD having following components for the treatment of waste-water generated during washing of potable vessel:
Oil & Grease Trap---- Chemical Dosing of lime & PAC manually & aeration---- Addition of Poly manually in Flash Mixer ----Collection Tank-----Electronization -----Anaerobic Reactor----- Aeration ----Tube Settler----Filter Feed tank-----pressure sand filter---- activated carbon filter--- UF--- RO--- Disposal. The effluent samples were collected and sent to Head office laboratory for analysis. Results of the same are awaited.
4) Only aeration tank and collection tank was in operation during the visit. Tube settler seems to be not in operation since long and the condition of evaporator used for RO rejects reflects that the same is not in operation since long.
5) The anaerobic (water holding) tank was in direct contact with the atmosphere; therefore, anaerobic conditions were not maintained. Filters & RO were not in operation during the visit.
6) The industry has provided 14 no. rain water collection pits near the ETP area. The representative informed that the same is being used for gardening purpose and fire-fighting. However, lot of algae growth found in stagnant water of rain water harvesting pits.
7) The industry has installed 2 no. submersible pumps for the extraction of ground water. The industry is maintaining record of extraction of fresh water for process.
8) Approx. 57 totes were found within the industry premises filled with trade effluent. Additionally, the same trade effluent was observed stored in green barrels located in an open area, left uncovered.
9) Approx. 59 drums (each of 200-liter capacity) were found filled with a mixture of paint liquid, contaminated cloth rags, PPE (gloves), paper, and cardboard.
10) A significant amount of paint was observed spilled on the floor in the area where these barrels were stored.
11) The industry has provided 03 no. dust extraction system with the powder charging section of solvent-based paint plant. Stack height of dust extraction 001 & 002 was adequate. However, the stack height of dust extraction 003 was less than as filled in the application form. Hence, the stack height of dust extraction 003 was inadequate.
12) The industry has installed SRP for the recovery of solvents from the spent solvents which are used back into the process. The industry has provided 2 no. storage tanks of capacity 5000 ltrs in which fractional distillation of the spent solvent is being done followed by single stage cooling in condenser using water. The vent of the spent solvent storage tank was connected to condenser which is further connected to recovered solvent storage tank in closed loop. The vent provided over the recovered solvent tank for discharge of emissions is pumped through VOC absorption media. The height of the vent of the condenser is adequate. The industry has installed TOC Analyzer over the vent. The industry is maintaining record regarding spent solvent received in the SRP, qty. of recovered solvent and qty of recovered solvent sent to processing section. The SRP section is provided with the stack of adequate height. The stack emission samples were collected from 001, 002 & 003 and sent to Head office laboratory for analysis. Results of the same are awaited.
13) The industry has provided 1 no. DG set of 625 KVA capacity with adequate stack height and canopy.
14) The hazardous waste of category 33.1 was being found lying in open. The industry was unable to show any record regarding hazardous waste w.r.t. storage, lifting even after the lapse of 20 min.
From the above, it is clear that the industry is not complying with the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981 and is violating the conditions of the earlier granted consent to operate under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 and the Air (Prevention & Control of Pollution) Act, 1981.
Recommendations
In view of the above, it is recommended that:
A. Consent to operate under the provisions of the Air (Prevention & Control of Pollution) Act, 1981 may be refused, please.
B. The Consent to operate granted to the industry under the provisions of the Water (Prevention & Control of Pollution) Act, 1974 may be revoked, please.
*Competency ~ Worthy Chairperson of the Board |
