National Green Tribunal
Nukatati Raja Sekhar vs Union Of India on 29 April, 2026
Item No.3:-
BEFORE THE NATIONAL GREEN TRIBUNAL
SOUTHERN ZONE, CHENNAI
Wednesday, the 29th day of April, 2026.
[Through Physical Hearing (Hybrid Option)]
Original Application No.33 of 2023 (SZ)
IN THE MATTER OF
1) Nukatati Raja Sekhar
S/o. Chinna Stayanarayana,
D.No.13-12-14/1,
Kotingalapeta, Rajamahendravaram,
East Godavari District,
Andhra Pradesh.
2) Marri Pushparaj
S/o. Rambabu,
D.No.13-7-13, 2nd Street,
Kotilingalapeta, Rajamahedravaram,
East Godavari District, Andhra Pradesh.
...Applicant(s)
Versus
1) Union of India
Through its Secretary,
Ministry of Environment, Forest & CC
Indira Paryavaran Bhavan,
Jorbagh, New Delhi -110 003.
2) State of Andhra Pradesh
Rep. by its Chief Secretary,
Secretariat, Velagapudi Guntur District,
Andhra Pradesh - 522 503.
3) Central Pollution Control Board
Rep. by its Member Secretary
Parivesh Bhawan, CBD - Cum Office Complex
East Arjun Nagar,
Delhi - 110 032.
4) Andhra Pradesh Pollution Control Board
Rep. by its Member Secretary
D.No. 33-26-14/D2,
Pushpa Hotel Center
Chalamvari Street,
Kasturibaipet, Vijayawada,
Andhra Pradesh - 520 010.
Page 1 of 20
5) Environmental Engineer
Andhra Pradesh Pollution Control Board,
Regional Office, Kakinada,
Andhra Pradesh.
6) District Collector & Magistrate
East Godavari Collector Office,
NAC, Near Horlicks Factory,
Dawaleswaram,
Rajahendravarm - 530 002.
7) Andhra Paper Mill Limited
Rep. by its Plant Manager
Sri Ram Nagar, Rajahmundry,
East Godavari District,
Andhra Pradesh - 533 105.
...Respondent(s)
For Applicant (s): M/s. K. Sravan Kumar, Medha Singh,
P. Santhosh Kumar and Mohit K Jakhar.
For Respondent(s): Dr. C.K. Syed Shaffi for R1.
Mr. K. Ravindranath for R2, R4 to R6.
Mr. R. Thirunavukarasu for R3.
M/s. S. Siva Sankar, N. Jayakumar,
N.M. Keerthana & S. Deepa for R7.
Judgment Reserved on: 10th April, 2026.
CORAM:
HON'BLE Smt. JUSTICE PUSHPA SATHYANARAYANA, JUDICIAL MEMBER
HON'BLE Dr. PRASHANT GARGAVA, EXPERT MEMBER
JUDGMENT
Delivered by Smt. Justice Pushpa Sathyanarayana, Judicial Member
1. M/s. Andhra Paper Limited (for short 'M/s. APL'), which is situated in Rajahmundry in East Godavari District, is causing concern regarding the pollution from the industry. Therefore, the applicants have filed the above Original Application seeking directions to the official respondents to close down the industry for non-compliance with the conditions of the Environmental Clearance, Consent to Operate and thereafter, implement the remediation plan in the pollution-affected areas Page 2 of 20 such as Turupuland in the river Godavari, Kotilingalapeta, Seetampeta, Sriramnagar, Lalithnagar, Lutarigiri, Malaypeta, Aryapuram, Paata Vutlanka areas of Rajahmundry Town, as per the recommendations of the expert committee.
2. It is alleged by the applicants that the 7th Respondent's pulp and paper manufacturing industry, which is 'Red' Category one, coming under Category 5 (i) of the schedule in EIA Notification, 2006, is situated 700 meters from the Godavari River. The industry, which has 123.86 Acres of land, has developed only 27.90 Acres as greenbelt.
3. The Environmental Clearance granted on 06.03.2014 mentions the production capacity of the industry as follows:
(i) Pulp production capacity - 650 TPD;
(ii) Paper production capacity - 593 TPD; and
(iii) Captive Power production - 46 MW.
4. It is stated that the Environmental Clearance was initially granted by the Ministry of Environment, Forests & Climate Change (MoEF&CC) on 31.01.2005 but approval for expansion of paper production from 330 TPD to 593 TPD and the captive power production from 34 MW to 46 MW was obtained from the SEIAA - Andhra Pradesh. Later, for the expansion of production of pulp from 550 TPD to 650 TPD, approval was obtained from the MoEF&CC.
5. The applicants have alleged many violations committed by the 7th Respondent's industry of the Environmental Clearance dated 06.03.2014.
(1) The industrial wastewater shall be properly collected, treated and utilized for plantation purposes, whereas the treated effluent is partially used for washing and greenbelt within the premises and the remaining is discharged into the Turupulanka Sand Shoals of the Godavari River.Page 3 of 20
(2) The project shall install multi-cyclones, wet scrubbers to achieve the particulate emission below 50 mg/Nm3.
The emission from the chemical recovery section shall be controlled through primary and secondary venture scrubbers, whereas the 7th Respondent is controlling the gaseous emission from both process and flue gas stacks of recovery boiler, coal fire boiler, etc. through ESPs.
(3) In case of treatment process disturbances/ failure of pollution control equipment adopted by the industry, the industry should be shut down till the control measures are rectified. However, it is found that all the processes, including the pollution control systems have either interlocking arrangements or manual controls. The effluents are diverted and stored in a buffer storage lagoon till they are rectified. The lagoon storage capacity is approximately 9,000 M3.
(4) The industry should have developed 33% of the greenbelt of the total land as per the CPCB guidelines, whereas according to the industry, 65 Acres of greenbelt and woodyard are in 86.34 Acres while the total extent itself is only 123.86 Acres.
(5) All the commitments made by the Project Proponent
during the public hearing should have been
implemented by the industry. So far as this is
concerned, it is stated that the industry is implementing the commitments. There is a CSR Wing with a separate budget as per the Companies Act. However, the smell nuisance and water pollution which were agreed to be reduced have yet to be complied with.
6. It is stated that on 10.07.2015, the Andhra Pradesh Pollution Control Board (APPCB) had issued a closure order for causing pollution and committing violations by the respondent industry. However, the same was revoked on 27.07.2015 by imposing certain conditions and giving directions.
Page 4 of 207. The applicants state that as per the revocation order direction, (a) the industry shall undertake the study of alternate discharge option into the sea; (b) based on the study report, the comprehensive action plan shall be submitted within four months; and (c) the study report shall incorporate (i) the issues like the feasibility of drains closer to the mill which are already discharging into the sea; (ii) Joining the scheme if APIIC lays out a dedicated effluent conveyance to the sea; (iii) Work with other industries or Municipal Corporation for a pipeline up to the dedicated drain/discharge post drinking water intake point of RMC; and (iv) Work with NEERI in upgrading the Turupulanka Sand Shoals or lagoons for further polishing. Besides, to control the odour problem, the foul condensate collection and treatment shall be commenced by August 2015.
8. Even after the issuance of the closure order, an inspection was caused by the APPCB and issued an order for non- compliance. Even after the issuance of the said directions on 30.01.2017, the industry is said to be non-compliant with the Board's directions. The above aspect is also relevant from the inspection report dated 30.03.2017 based on the randomized risk- based inspection.
9. The applicants also complain that the APPCB has failed to take action on the highly polluting 7th Respondent industry, despite having found several irregularities, non-compliances, violations, harmful pollution and odour nuisance at the industry.
10. Therefore, the applicants have come up with the above application to
(a) Direct the official respondents, including the MoEF&CC, CPCB, and APPCB;
(b) Close down the respondent industry for their continuous violation; and
(c) Direct them to implement the remediation plan and initiate prosecution against them.
Page 5 of 2011. The Central Pollution Control Board (CPCB) filed an interim report dated 19.05.2023, wherein it is stated that in compliance with the order of this Tribunal, an inspection team was constituted for inspection of the APML. The CPCB has stated that originally the Environmental Clearance was issued by the MoEF&CC on 06.03.2014, which has extended the validity up to 05.03.2025. The Consent for Operate (CFO) issued is also valid up to 30.06.2023. At the time of inspection, it was found that approximately 22561 KLD of water from the river Godavari is utilized in the process section and 18543 KLD of effluent is generated. The effluent generated is treated in the ETP of capacity 45,000 KLD consisting of primary clarifiers, aeration tanks, secondary clarifiers, and tertiary clarifiers. 12,000 KLD effluent from paper machine effluent after clarification and evaporated condensate are reused in the industry in pulp mill dilution, paper machine showers, floor washing, chemical dilution, ETP Sludge belt showers, through a dedicated network of pipelines. During the inspection, the wastewater samples were collected in each component of the ETP, the inlet and outlet of the ETP. The team also visited the Turupulanka island in the river Godavari and sample of wastewater discharge into lagoons were also collected and handed over to the CPCB, Regional Directorate, Bangalore for analysis. The industry has installed the Online Continuous Effluent Monitoring System (OCEMS) and Effluent Monitoring System (EMS) at the outlet of the ETP for treated effluents and at four stacks for emissions.
12. In the second report dated 10.08.2023, it is stated by the CPCB that the manufacturing process in the 7th Respondent industry is explained. Regarding the water consumption and effluent generation, it is stated that the river Godavari is the source of water for process and domestic consumption. The flowmeter is provided at the raw water intake. 27 Nos. of flowmeters are installed at various process sections. The daily records of flowmeter reading, water consumption and wastewater generation are maintained. As per the flowmeter reading, 32,405 KLD of water from the river Godavari is utilized in the process section and 27,532 KLD of effluent is generated.
Page 6 of 2013. According to the CPCB, the average water consumed per tonne of paper produced is 55 Kilo Liters (KL) and it is complying with the Environmental Clearance condition of 75 KL per tonne of paper produced. The industry has installed an ETP of capacity 45,000 KLD, which is adequate for treating the effluent. Effluents generated from paper machines 2, 3, 5 and 6 are treated in Stream-1 and the treated effluent is recycled. The effluent is collected in 200 M3 collection tank and fed to the clariflocculator capacity of 2000 M3 per hour. Clarification is a process of separation of suspended solids from the wastewater using gravity. Supernatant from the clarifier is collected in the reclamation back water tank of capacity 200 M3. The excess effluent from Stream- 1 and effluents generated from the white thickener are mixed with the inlet effluent at Stream-2. Sludge generated in the clariflocculator is de-watered in the white thickener and the bottom white thickener is processed during the dewatering press of capacity 36 TPD. The white fibre sludge from the dewatering press is sold to egg trays manufacturer as per permitted in the Consent to Operate.
14. The effluent from paper machines 1 and 4, pulp mill, surplus reclaimed effluent from ETP Stream-1, etc. are treated in the ETP of Stream-2. From the collection tank, effluent is pumped to the primary clarifier of capacity of 7,500 M3/Hour for the separation of suspended and colloidal matter. The effluents from the aeration tank are clarified in two secondary clarifiers of capacity 6,000 M3 x 2 and then a tertiary clarifier of capacity 7,500 M3. 395 KLD of treated effluent is utilized within the industry's premises for gardening and greenbelt development. The remaining treated effluent is discharged into lagoons at Turupulanka island in the river Godavari through a pipeline as per the disposal method permitted in the CTO. The sludge generated from the primary clarifiers, secondary clarifiers and the tertiary clarifiers is dewatered in the sludge dewatering machines and dryers in the Stream-3 sludge handling system.
15. The results of the water sample analysed show that pH, BOD, COD, TSS and AoX and oil greases are within the limit of effluent discharge standards. As stated earlier, the electromagnetic flowmeter and the OCEMS at the outlet of the ETP Page 7 of 20 are connected to the CPCB portal. The inspection team analysed 15 minutes average data and found that the industry is complying with effluent discharge standards.
16. The CPCB report also mentioned about the disposal of the treated wastewater at Turupulanka island, water quality monitoring of the river Godavari, regarding the air pollution control devices installed, the status of the OCEMS installed for monitoring emissions. The report found that the OCEMS is not calibrated and operated properly and are not recording the actual values, based on the comparison of concentration of particulate matter emissions recorded during manual monitoring and corresponding OCEMS data. The CPCB has also filed its report on the measures taken for fugitive emission control, Ambient Air Quality (AAQ) Monitoring Station, odour control system, and status of hazardous waste disposal.
17. Finally, the CPCB has stated that the industry is complying with the conditions of the Environmental Clearance and Consent, except for the following:
"1. The lease agreement of discharge of treated effluent to lagoons at Turuplanka island was expired in 1999 and yet to be renewed.
2. The industry is exceeding the source emission standards for Particulate matter at recovery boiler and coal fired boiler.
3. The industry is exceeding the source emission standards for Hydrogen Sulphide at Rotary Lime Kiln- 1 and Rotary Lime Kiln -2.
4. OCEMS installed for monitoring emissions are not calibrated and operated properly as particulate matter emissions data recorded in OCEMS are 2 to 4.5 times less than the actual concentration of Particulate matter emissions.
5. As per the consent conditions, temperature of the effluent shall be below 35°C prior to the inlet of the ETP. To reduce the temperature of the effluent from 45-48°C, the effluent is circulated through cooling tower prior to microbial treatment. As per the records, the temperature at the outlet of the cooling tower is 40- 45°C. During the inspection it was observed that the industry is in the process of renovating the cooling tower to increase the surface area to reduce the effluent temperature to less than 35°C.
6. Compared to 33% of the required area to be develop as greenbelt as per the consent conditions, 32.8% of the total land area of the industry is developed as greenbelt.
7. The industry has to install four Continuous Ambient Air Quality Monitoring Stations as per consent conditions. The industry has installed only two CAAQM Stations and out of two stations, one station is in operation."Page 8 of 20
18. Finally, the CPCB has given its recommendation, which is usefully extracted below:
"i. To renew the lease agreement for discharge of treated effluent to lagoons at Turupulanka.
ii. To augment air pollution control devices at recovery boiler and coal fired boiler to control particulate matter emissions.
iii. To implement measures to control Hydrogen Sulphide emissions at Rotary Lime Kilns -1 and Rotary Lime Kilns -2 and comply with the source emission standards.
iv. To calibrate and operate the OCEMS installed for monitoring particulate matter emissions, properly and record the actual concentrations.
v. To reduce the temperature of the effluent to less than 35°C prior to microbial treatment.
vi. To develop greenbelt in 33% of the total land area of the industry to mitigate effects of fugitive emissions.
vii. To install two Continuous Ambient Air Quality Monitoring Stations in addition to the existing two CAAQM Stations and ensure operation of all the four CAAQM Stations."
19. The APPCB, in its report dated 28.08.2024, has furnished the status of the non-compliance as on 29.11.2021 of the Environmental Clearance dated 06.03.2014. The APPCB has been collecting the treated effluents being disposed of into the sand shoals of Turupulanka by the 7th Respondent on a monthly basis. The APPCB has been issuing notices to the industry whenever the treated effluent is not meeting the APPCB's discharge standards for rectifying the same. The industry has not renewed the lease permission of Sand Shoals from the Government of Andhra Pradesh and the same is under process. It is submitted by the Project Proponent also that the Commissioner of Industries, Government of Andhra Pradesh recommended the lease proposal to the Principal Secretary of Industries and Commerce, vide letter dated 29.11.2014, subject to 10% of the present market value as lease amount, with the provision for enhancement of lease amount in a block period of 5 years.
20. Regarding the monitoring of the river Godavari by APPCB, it is stated that the analysis reports of the samples collected, pH, BOD, COD and Total Coliform, are confirming to the Class-B of the CPCB use-based classification of surface water in India i.e. outdoor bathing. Earlier, the river Godavari from Page 9 of 20 Rayanapetta to Rajamahendravaram was notified as a polluted river stretch by the CPCB under Priority-V and the same was now removed from the polluted river stretch list as per the minutes of the 15th Meeting of the Central Monitoring Committee.
21. The APPCB's report dated 10.12.2024 gives the details of the non-compliances, clarification given by the industry and the latest compliance status of the industry.
22. It is reported that the lease agreement for the discharge of treated effluents to lagoons at Turupulanka Island expired in 1999 and it was not renewed. However, the industry had informed that the renewal procedure is in progress with the District Administration and is being pursued consistently. The District Collector has also sought for the report from the APPCB on the renewal of the lease agreement for the discharge of treated effluents to lagoons. The APPCB also said to have submitted the report to the District Collector, East Godavari District. The industry was also directed to expedite the plan of action for alternate disposal mode of treated wastewater along with treated sullage of Rajamahendravaram and the progress shall be reported every month to the District Administration and to the APPCB. The industry has also complied with the implementation measures to control the Hydrogen Sulphide (H2S) emissions at Rotary Lime Kilns 1 and 2 to achieve a compliance of Hydrogen Sulphide (H2S) concentration less than 10 mg within a month and other prescribed standards from the stack emissions of the Rotary Lime Kilns.
23. The APPCB also report about the compliance of the industry of the recommendations mentioned in the CPCB's report dated 10.08.2023. The industry has also complied with the recommendations of the CPCB regarding the source emissions from the stacks by controlling with Electrostatic Precipitators (ESP). It is also reported that all stack online sensors were undertaken for comprehensive maintenance and quality control checks in the month of April 2024, when the mill was shut, by M/s. Swan Environmental Private Limited, Hyderabad. The industry is having an annual calibration schedule once a quarter. The recent calibration of OCEMS was done in August 2024 and the calibration Page 10 of 20 certification was issued. The industry has also renovated the existing ETP cooling tower to bring down the temperature of effluent to less than 350C and the details of renovations are also furnished in the report.
24. The APPCB submitted its Action Taken Report dated 05.03.2026, confirming compliance with the Task Force's direction dated 15.03.2024. Among the directives issued, one required the industry to expedite a plan for the alternative disposal of treated wastewater, along with treated sullage from Rajamahendravaram. In response, the industry engaged M/s. CII- Triveni Water Institute, which prepared a report titled "Feasibility Study for Exploring Alternative Options for Effluent Discharge"
dated 20.01.2017. The report proposed the following alternatives for disposal:
I. Laying of a treated effluent pipeline up to Ava Drain at Kadiyam, for combined discharge along with Rajamahendravaram municipal sewage, and thereafter routing through natural drainage channels to ultimately join the Bay of Bengal at Coringa.
II. Laying of a treated effluent pipeline up to Ava Drain at Kadiyam, for combined discharge with municipal sewage, with final discharge through natural drains leading to the Bay of Bengal at Yanam, considering the ecological sensitivity of the Coringa region.
The industry shall expedite the plan for alternative disposal or shall implement Zero Liquid Discharge (ZLD) systems for effluent disposal.
25. Respondent No.6, who is the District Collector - East Godavari District, has reported that initially, Turupulanka lands were allotted in favour of M/s. Andhra Paper Limited vide G.O. Ms. No.1244, Revenue (O) Department dated 29.12.1969, an extent of 488.53 Acres on a lease basis for ten years. Further, vide G.O. Ms. No.410 Revenue (B) Department dated 28.02.1983, renewal of lease was issued while granting of additional lands of an extent of 124.18 Acres in Turupulanka land and sand shoals in favour of the industry for a further period of ten years. Once Page 11 of 20 again, in the year 1992, the renewal was done vide G.O. Ms.810, Revenue (Assignment I) Department dated 04.08.1992 of an extent of 612.71 Acres for a period of ten years with effect from 01.07.1989. Thereafter, no renewal order was issued in this matter. After the bifurcation of the East Godavari District, a representation was given by the industry for renewal and the report regarding the same was called from the Revenue Divisional Officer (RDO), Rajamahendravaram, who had submitted the same. The detailed factual report was also submitted to the Government through the Chief Commissioner of Land Administration, Andhra Pradesh, vide report dated 29.11.2024 and the same is awaited. An extent of 229.52 Acres is already under utilization of M/s. Andhra Paper Limited without renewal of lease. However, the Government may take a decision in the matter, based on the merits of the case, as it is a Turupulanka lands.
26. Respondent No.7, which is the Project Proponent, namely M/s. Andhra Paper Limited (APL), is one of the largest paper and pulp manufacturers in India, producing writing, printing and copier papers for foreign and domestic markets. It has a total production capacity of 2,40,000 Tonnes/Annum with work force of around 5,300 persons. It claims to have the state-of-art technologies in achieving a sustainable production process as well as a sustainable environment. The industry claims to have the following:
(i) Bellmer Dewatering Sludge Press for ETP Sludge;
(ii) ETP Sludge Drier;
(iii) Odour Control Management i.e. Low Volume High Concentration (LVHC) & High Volume Low Concentration (HVLC) system;
(iv) Foul Condensate Collection and treatment with H2O2;
(v) Excellent Spill Control Management; and
(vi) 100% cooking effluents segregated and reused under Chemical Recovery Process.Page 12 of 20
27. The 7th Respondent claims to have implemented several advanced technologies. The said advanced technologies and facilities ensure sustainable growth through a smart investment portfolio, leading to environment-friendly growth and adherence to the compliance standards set by the concerned authorities, such as MoEF&CC, APPCB, and SEIAA - Andhra Pradesh. The process involved in the production of pulp, paper and treatment of effluents by the 7th Respondent is at various stages like:
(I) Raw material preparation;
(II) Cooking;
(III) Pulp washing;
(IV) Oxygen delignification and pulp bleaching; (V) Stock preparation and paper making; and (VI) Effluent treatment.
28. The industry also denies the allegations made in the application regarding the air, odour and water pollution. It is stated that air pollution control is achieved by managing emissions from stacks using Electrostatic Precipitators (ESPs). The main source of air pollution, if any, is from the stacks of the recovery boiler, coal-fired boiler, rotary lime kilns - 1 and 2. These stacks are provided with ESPs for the control of air pollution. Air pollution control equipment is also maintained and overhauled from time to time for sustainable performance. All four stacks are fitted with online continuous emission monitoring analysers and the data therefrom are immediately transmitted to the CPCB and APPCB servers.
29. Regarding the odour control system, it is claimed to be one of the best and unique among the Indian paper industry. The industry is engaged in a hard piping system for the collection and treatment of foul streams with Hydrogen Peroxide and it has also commenced upgradation of the existing LVHC NCG Incineration System and HVLC NCG Incineration System. The physical sampling for Ambient Air Quality Monitoring is being done by the MoEF&CC and the NABL-accredited third-party laboratory Page 13 of 20 at four locations of the industry premises and reports are being submitted to the APPCB and the MoEF&CC.
30. As regards the water pollution control, effluents generated from the integrated pulp and paper manufacturing process are treated at ETP through extent Activated Sludge Process. The effluents are segregated into three streams, namely:
Stream - 1 : Paper Machines 2, 3, 5 and 6 Steam - 2 : Paper Machines 1 and 4 Stream - 3 : Pulp mill, chemical recovery and utilities and other.
31. The industry has also given an elaborate report on the collection, storage, treatment and disposal done by Streams 1, 2 and 3.
32. Regarding the Godavari River water quality, the 7th Respondent has denied the allegation of discharge of untreated chemical waste and effluents into the Godavari River causing pollution. The APPCB has submitted an action plan for rejuvenation of river Godavari, Rajamahendravaram, under Priority - V to CPCB, New Delhi. The CPCB has remarked as follows:
"As per the NWMP data for the years from 2014-19, it was observed that F. Coli levels are less than 500 MPN/100 ml. The BOD levels recorded are less than 3 mg/l except in the month of May, 2016. As the BOD and F. Coli levels are within the outdoor bathing standards, during the years 2017, 2018 and 2019, it is requested that Godavari River stretch may be deleted from the list of 351 Polluted River Stretches identified by the CPCB."
33. The Godavari River stretch from Rayanapeta (Upstream of M/s. APL) to Rajamahendravaram (Downstream of M/s. APL) comes under Category - V, which is Good or Fit for bathing with the total score less than 20, as per the CPCB Guidelines.
34. With regard to Zero Liquid Discharge (ZLD), the 7th Respondent/Andhra Paper Mill, in its report dated 11.12.2024, has stated that the feasibility study on ZLD in wood/agro-based pulp and paper mills was undertaken by the Central Pulp and Paper Research Institute (CPPRI) at the instance of the Indian Paper Page 14 of 20 Manufacturers Association. As per the report dated 20.07.2022 of the CPPRI, it is concluded that implementation of ZLD in integrated pulp and paper manufacturing units is not feasible.
35. The 7th Respondent has relied on the Status Report dated 01.02.2023 filed by the CPCB, pursuant to the directions of the Principal Bench of the National Green Tribunal. In the above- referred report, it is stated that ZLD is not techno-economically feasible for wood/agriculture residue-based pulp and paper mills. However, the 7th Respondent has implemented ZLD measures in respect of black liquor management, through segregation, forced multi-effect evaporation, and utilization in recovery boilers, thereby generating process steam and captive power.
36. In the above factual matrix, it is to be examined whether the 7th Respondent (M/s. Andhra Paper Limited) has complied with all the statutory requirements.
37. After the above Original Application was taken on file and notice issued, the 7th Respondent has filed an action taken - cum- compliance report before the CPCB. Pursuant to which, the CPCB had also inspected the industry and filed the report.
38. The 7th Respondent, while reporting the compliance and implementation of various advanced technologies and state- of-art technologies, also had given the proposed investments on further enhancement of pollution abatement and the continuous ongoing process to upgrade and update the system for environmental sustainability. The 7th Respondent also undertook an investment of Rs.20.566 Crores for the following:
(i) ETP improvement;
(ii) Dust Extraction System in Chipper House;
(iii) Replacement of analyser in the existing second
AAQMS for PM10, PM2.5, So2, Nox;
(iv) Water sprinklers at coal yard and lime kiln area;
(v) Recovery Boiler ESP-3;
(vi) ETP Cooling tower 100% renovation and upgradation
of achieve less than 350C effluent temperature;
Page 15 of 20(vii) Water conservation by replacement of fresh water with paper machine waste water in Pulp Mill D1;
(viii) Oxygen Injection Line into aeration tank 1;
(ix) Redesigning of storm water drainage system;
(x) Additional 2 Nos. of AAQMS as per the Environmental
Clearance condition; and
(xi) Storage shed for ETP sludge.
39. Of the above, Item Nos.(ii), (v), (vii), (viii) & (ix) are completed. For additional AAQMS i.e. Item No.(x), orders were placed with the vendors and the rest of the items are yet to be complied with.
40. Following the communication from the 7th Respondent dated 02.01.2024, the APPCB issued directions based on an inspection and recommendations from the CPCB, which are usefully extracted below:
(1) The lease agreement of discharge of treated effluent to lagoons at Turuplanka island was expired in 1999 and yet to be renewed.
The industry shall immediately renew the lease agreement for discharge of treated effluent to lagoons at Turupulanka sand shallows of River Godavari.
(2) The industry shall immediately stop discharging the treated or untreated wastewater into the Turpulanka sand shallows of River Godavari for a period of one month until 25th March, 2024. (3) The industry shall expedite installation of Jet aerators in aeration tank by replacing diffuser membrane system by 30.04.2024. (4) The industry shall upgrade & maintain the cooling tower of the ETP to ensure temperature of the wastewater to less than 350C at inlet of ETP.
(5) The industry shall implement latest techniques to improve water conservation and to reduce freshwater consumption to best possible extent. The progress shall be reported periodically. (6) The industry shall complete installation of VFD for aeration tank inlet pumps to maintain consistent flow by 30.07.2024. (7) The industry shall expedite plan of action for alternate disposal mode of treated wastewater along with treated sullage of Rajamahendravaram. The progress shall be reported every month to District Administration and to the Board. (8) The industry shall expeditiously complete replacement of analyzers in the 2nd AAQM station for PM10, PM2.5, So2, NoX and VOC analyzer by 30.04.2024.
(9) The industry shall regularly operate the water sprinklers at coal yard and lime kiln area for suppression / containment of fugitive emissions. The industry shall provide flow meter with totalizer to quantify the water consumed for operation of the sprinklers and the records shall be kept accessible to inspecting officials. (10) The industry shall immediately augment air pollution control devices at coal fired boiler by 31.03.2024 and Recovery boiler Page 16 of 20 by 30.04.2024 to control pollutants emissions and ensure compliance to the prescribed emissions standards. (11) The industry shall operate the dust extraction system effectively in chipper house for suppression/containment of fugitive dust emissions.
(12) The industry shall expedite installation of additional 2 No. AAQM Stations by 30.05.2024 at representative locations in consultation with RO, Kakinada.
(13) The industry shall complete reliability studies on the NCG collection and treatment system by 31.03.2024. (14) The industry shall complete installation of H2S online stack analyzers to rotary kiln - 1 & 2 and connectivity with website of APPCB & CPCB by 30.04.2024 for continuous display of the monitoring values in the online portal.
(15) The industry shall undertake periodical study by an reputed organization to identify the dispersion pattern of odours substances in the core zone and possible impacts in the surroundings of the industry; to furnish short & long term plans to implement requite containment measures to mitigate any odour nuisance in the surroundings. The study findings and implementation plan of action to alleviate odour nuisance in the surroundings shall be furnished to the Board within 3 months. (16) The industry to implement measures to control Hydrogen Sulphide emissions at Rotary Lime Kilns -1 & 2 to achieve compliance of H2 S concentration less than 10 mg/Nm3 within a month and other prescribed standards from the stack emissions of the rotary kilns.
(17) OCEMS installed for monitoring emissions are not calibrated and operated properly as particulate matter emissions data recorded in OCEMS are 2 to 4.5 times less than the actual concentration of Particulate matter emissions. The industry shall immediately rectify the above and shall furnish plan of action to prevent such reoccurrences; to calibrate and operate the OCEMS for monitoring particulate matter emissions properly and record the actual concentrations.
(18) The industry shall ensure compliance to the CPCB guidelines dated. 05.02.2014, 02.03.2015 and further notification issued for periodical calibration of online pollution monitoring systems from time to time.
(19) The industry shall complete construction of shed of adequate capacity for storage of ETP sludge with elevated platform, leachate collection and dedicated pumps to convey the collected leachate to ETP by 30.06.2024. Adequate facilities shall be provided to prevent contamination of run-off. (20) The industry shall expedite greenbelt development in the balance area to achieve 33% of total project site. (21) The industry shall furnish implementation progress of the lapses/ recommendations of the CPCB.
(22) The industry shall abide by the directions issued by the Hon'ble NGT in O.A. No. 33 of 2023 (SZ).
(23) The industry shall ensure that there shall not be any pollution problems in the surroundings.
41. From the above, it seen that the implementation progress of the above directions shall be reported to the Regional Office, Kakinada, regularly by the 7th Respondent.
Page 17 of 2042. The only non-compliance as on date by the 7th Respondent is the renewal of the Turupulanka lease. The Government of Andhra Pradesh had granted a lease in an extent of 488.53 Acres on 29.12.1969 vide G.O. Ms. No.1244 Revenue dated 29.12.1969. It was renewed again on 26.02.1983 vide G.O. Ms. No.410 along with additional land of 124.18 Acres, totalling 612.71 Acres. Once again, the Government of Andhra Pradesh renewed the above-said lease vide G.O. Ms. No.810 Revenue dated 04.08.1992 for 10 years with effect from 01.07.1989 or until the completion of the dedicated drain to Bay of Bengal, whichever is earlier, at a lease rental of Rs.300 per Acre per Annum. Since the dedicated drain is so far not materialized from the Government end, after interactions and meetings with APIIC, District Collector and other industries, it was requested to the District Collector to renew the lease for a further period of 10 years from 1989 to 1999. The 7th Respondent also paid a contribution fund to the Government for the survey of the dedicated drain. The Mandal Revenue Officer recommended and submitted a report to the Revenue Divisional Officer for renewal of lease for a period of 10 years at Rs.450 per Acre per Annum, on 18.11.1997.
43. Thereafter, the District Collector also recommended the lease renewal to the Secretary to Government, Revenue Department, vide letter dated 02.06.1999. A reminder was sent by the industry on 22.07.2009 and M/s. Ramky Enviro Engineers Limited has been engaged by the industry for a detailed study for a dedicated project and the same report was communicated to the APPCB on 27.10.2010. The APIIC also recommended for the renewal of the lease by delinking from the issue of the dedicated drain. The Commissioner of Industries and also the Andhra Pradesh Land Management Authority had recommended the proposal to the Government for renewal of lease from 1999 to 2009 and for a further period of 33 years i.e. up to 2042.
44. The District Collector, who has the jurisdiction to recommend the lease rental, has directed to conduct a land survey in Turupulanka to facilitate fixing of lease rentals on 18.03.2023. The said subject matter was, in fact, escalated to the Principal Secretary to Government, Department of Commerce and Industry.
Page 18 of 20In the meanwhile, on 11.09.2024, a meeting was convened by the District Collector with all the stakeholders. The City Town Planner and the Tahsildar inspected the Turupulanka for land survey and for physical verification of lands along with survey teams. On 19.10.2024, a detailed land survey was undertaken by the Tahsildar, Rajahmundry, with land surveyors. The Rajahmundry Municipal Corporation and Tahsildar, Rajahmundry Urban, have submitted the inspection report and the land survey report to the District Collector and it is under process with the District Collector.
45. According to the 7th Respondent, all efforts have been taken to get the Turupulanka lease renewed and also paid the lease rentals to the Tahsildar, who has been accepting the same and has been permitting the 7th Respondent to use the sand sholas in terms of the lease agreement till date without any disturbance. It is also stated that it is in the final stage of being approved by the District Collector.
46. With regard to the implementation of Zero Liquid Discharge (ZLD), it is noted that the 7th Respondent has implemented ZLD measures in respect of black liquor management through segregation, multi-effect evaporation, and recovery boiler systems, thereby generating process steam and captive power.
47. It is further observed that the APPCB, while affirming compliance with the Task Force's direction dated 15.03.2024, which required the industry to expedite a plan for the alternative disposal of treated wastewater along with treated sullage from Rajamahendravaram, stated that the industry had engaged M/s. CII-Triveni Water Institute. The institute prepared a report titled "Feasibility Study for Exploring Alternative Options for Effluent Discharge" dated 20.01.2017, which proposed pipeline- based disposal options via the Ava Drain at Kadiyam, ultimately leading to discharge into the Bay of Bengal through the Coringa or Yanam routes, taking into account ecological sensitivities.
48. In light of the above, it would be appropriate to direct the 7th Respondent to expedite the implementation of the approved alternative effluent disposal mechanism within a Page 19 of 20 specified timeframe, in compliance with the directions issued by the Andhra Pradesh Pollution Control Board.
49. In view of the foregoing discussion, the following directions are issued:
I. The District Collector, East Godavari District, is directed to consider the final stage of the lease agreement, as discussed above and pass appropriate orders in accordance with law.
II. The 7th Respondent is directed to expedite and
implement the approved alternative effluent
disposal mechanism within a stipulated
timeframe, in compliance with the directions of the APPCB.
III. The 7th Respondent is further directed to adhere to all environmental norms and the conditions stipulated in the consent(s), as well as the directions issued by the APPCB, and to submit compliance reports to the APPCB, which shall ensure due verification of the same.
50. With the above observations and directions, the Original Application [O.A. No.33 of 2023 (SZ)] is disposed of.
Sd/-
Smt. Justice Pushpa Sathyanarayana, JM Sd/-
Dr. Prashant Gargava, EM Internet - Yes/No All India NGT Reporter - Yes/No O.A. No.33/2023 (SZ) 29th April, 2026. Mn.
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