National Green Tribunal
K Gemini vs Union Of India Rep. By The Secretary To ... on 1 June, 2020
Author: K. Ramakrishnan
Bench: K. Ramakrishnan
Item No.7:
BEFORE THE NATIONAL GREEN TRIBUNAL
SOUTHERN ZONE, CHENNAI
Original Application No.16/2019 (SZ)
IN THE MATTER OF
K. Gemini ...Applicant(s)
With
Union of India and Others. ....Respondent(s)
Date of hearing: 01.06.2020.
CORAM:
HON'BLE MR. JUSTICE K. RAMAKRISHNAN, JUDICIAL MEMBER
HON'BLE MR. SAIBAL DASGUPTA, EXPERT MEMBER
For Applicant(s) : Sri. B. Lakshmi Narasimhan represented the
applicant.
For Respondent(s): Sri. G.M. Syed Nurullah sheriff forR1.
Sri. M. Mani Gopi forR2.
Sri. Kasi Rajan through
M/s. Deepika represented for R3.
Sri.N.L. Raja,Senior Counsel along with Sri. T.
Ravichandran represented the project
proponent/R4.
1
ORDER
1. In the above matter as directed by this Tribunal, as per order dated 27.02.2020, the committee had submitted the report by e-
mail dated, 29.05.2020. The fourth respondent had filed their written objection as well to the earlier report with documents through e-file which has received on 29.05.2020.
2. As per order dated, 27.02.2020, the case was posted to 15.05.2020 for filing the report. On 15.05.2020 it was adjourned by notification to today to be taken up through Video Conference.
3. When the matter was taken up through Video Conference today, Sri. B. Lakshmi Narasimhan represented the applicant. Sri. G.M. Syed Nurullah Sheriff represented first Respondent, Sri. M. Mani Gopi represented 2nd Respondent, Sri. Kasi Rajan through M/s. Deepika represented3rd Respondent, Sri.N.L. Raja Senior Counsel along with Sri. T. Ravichandran represented the project proponent, namely 4th Respondent.
4. Learned counsel for the applicant submitted that through there was a direction given by this Tribunal to Ministry of Environment, Forests and Climate Change (MoEF & CC) to submit their response as to whether this project requires prior 2 Environmental Clearance (EC), they have not submitted their response so far. Even as per the committee report, further investigations have to be done and further report will have to be filed in this regard.
5. The learned senior counsel appearing for the 4th respondent submitted that they wanted to file a detailed objection of the committee report and that also can be considered before passing the orders.
6. The joint committee has filed the report after discussing the back ground and decisions taken in meeting of the committee made the following observations and recommendations :
"3.0 Field observations of Joint Committee:
(i) Status of action taken by M/s Chemplast Sanmar Ltd w.r.t Recommendations of last visit of Committee ;
Table 1: Status of action taken against the last visit of committee Sl. Recommendations of last visit of Present Status No. committee
1. To remove the un-used pipeline from The unit has removed the surplus course of the River some portion of the Cauvery and to ensure that no trade unused pipe lines - effluent or any other liquid discharge Complied into river or any drain 2 To stop sending domestic effluent The unit has already into either Soak Pit or Septic tank, provided STP for entire domestic effluent shall be domestic effluent taken to STPs exist( if adequate) or to arising from Plant II & 3 be provided additional STP to treat III. Now the Unit has entire sewage and utilised for installed one new STP gardening and other purposes in w.r.t Plant IV & V and place of fresh water. it is in operation. The Unit has not provided STP for domestic effluent w.r.t. Plant I & its colony and still sending domestic effluent into soak pit/septic tank..
Partially Complied
3. To install adequate number of flow The unit has installed meters and web camera to ensure the adequate number of ZLD system and to submit the flow meter and web detailed water auditing report on camera for monitoring account of ZLD and recycling of but no water auditing treated effluent in different process. report made available to committee to verify the adequacy Partially Complied
4. To stop disposing their hazardous The hazardous waste waste in captive SLFs and to direct to generated from Plant- sent to Common TSDF or Co- I, II & III is being processing depending on the quality disposed in captive of Hazardous waste. SLF itself. Only the hazardous waste from Plant V is being sent to TSDF. Partially Complied 4
5. To take immediate steps to provide proper The unit has not taken any storm water management system to collect step to segregate and roof top water separately, surface runoff collect storm water from (contaminated with product or raw plant area as well as from material) from plant area separately and vacant land of plant - Not Surface run off from vacant land Complied. separately in all plants and to construct separate storage system so that these water shall be utilised for industrial purpose with suitable treatment if required. No Storm water shall be let it out in public drains/Odai.
6 The industry shall explore the possibility The unit has not taken any of diversion of storm water drains which steps either diversion of are passing inside the premises in storm water drains which consultation with local administration. In are passing inside the extreme circumstances of non diversion of premises or installation of existing storm water drains (Odai), the online monitoring system to unit required to install online monitoring these drains - Not system for pH, TDS, BOD and COD to Complied. ensure the natural quality of storm water/ surface water runoff.
7. To take steps to find out root causes for The unit has not oozing of water from outside boundary submitted any inventory wall of Plant - II (South west side) and report regarding this to sources of stagnant water in the area. Committee --- Not Complied
8. To take action to reuse the storm water No Steps taken ----- Not collected from seepage of the unit during Complied rainy time. The unit shall take necessary step to close the rain water inlet line to avoid the rain water entry into the unit IV.
9. To provide Continuous Ambient Air Only VOC is monitored in Quality monitoring stations (CAAQM) in Plant IV, CAAQM yet to four directions around the Plant-II, III, IV, install for continuous V and Power Plant. The unit shall monitor monitoring of AAQ around PM10, SOx, NOx, Chlorine and VOC the units --- Not Complied 5
(ii) Status of Secured Land Fill w.r.t CPCB criteria for Hazardous Waste Land fills:
The Joint Committee inspected the SLFs of M/s Chemplast Sanmar Ltd., Plant I, II, III & V, the detailed reports of individual plants are enclosed at Annexure -4. Number of SLFs in each plant and piezometers/bore wells installed are as below:
Table 2: Details of SLFs, Hazardous waste disposed and number of Peizometers installed SLF No of Type & Quantity No of location SLFs Category of exist Hazardous of Piezomete and its waste status disposed Hazardou rs/Bore s waste well disposed Plant I 1no.(Ac Chemical 59.42 MT 1 tive) Sludge from Waste water Treatment (35.3) Plant II 15 No. 1.Process 5265.37M 4 (14 are Residues(22.2) capped 2.Chemical T and Sludge from one is Waste water active) Treatment (35.3) Plant III 14 No. 1. Distillation 50702.888 11 (13 are residues (20.3) MT Peizometer capped 2.Brine (2002.95 and 2 bore and Sludge(16.3) MT of HW well one is 3.Chemical from SLF active) Sludge from sent to Waste water TSDF) Treatment (35.3) 6
4. Process acidic residue, filter cake, dust (received from Cabot Sanmar Ltd (17.1) Plant V 4 No. Residue, Filter 175 T 7 (3are cake (17.1) Peizometer capped and one is active) The Summary of Compliance w.r.t CPCB criteria for Hazardous Waste Landfills (Published in February 2001) is tabulated below;
Table 3: Compliance w.r.t CPCB Criteria Sl CPCB Compliance status of SLFs of each plants No Criteria Plant I Plant II Plant III Plant IV 1 Location Complied Complied Complied Complied Criteria: No No No No Lake or pond within 200 m River No No No No within 100 m Flood plan No No No No Higway within 500 m Public Park within No No No No 7 500 m Critical No No No No Habitat area Wetlan No No No No d if any Air port No No No No if any Water supply well within No No No No 500 m No No No No Coastal Regulat No No No No ion Zone 4.2 - 12 m 4.2 - 12 m 4.2 - 12 m 4.2 - 12 m Ground No No No water investigatio investigatio investigatio table No n carried n carried n carried Type of investigatio out out out Soil n carried Permeab out ility of soil Any other criteria 2 Liner criteria Single Single Single Single adopted; 1.5mm 1.5mm 1.5mm 1.5mm Single or Double liner system liner system liner system liner system Thickness was not was not was not was not of geo provided as provided as provided as provided as membran per CPCB per CPCB per CPCB per CPCB e criteria criteria criteria criteria Details of 8 liner system 3 Leachate Trench net Trench net Trench net Trench net trench net work not work not work not work not work and provided provided, no provided, no provided, no collection Not leachate leachate leachate system complied collection collection collection system exist system exist system exist in any in any in any closed SLF. closed SLF. closed SLF.
Not Not Not
complied complied complied
4 Type of No phase No phase No phase No phase
operation operation - operation - operation - operation -
of SLF Not Not Not Not
(phase complied complied complied complied
operation
or non
phase
operation)
5 Record Not Not Not Not
Keeping complied complied complied complied
and
Waste
inspection
(as per
the
Section
8.2)
6 Number 1 4 11 7
of The The The The
Monitorin monitoring monitoring monitoring monitoring
g wells wells not wells not wells not wells not
installed , meeting the meeting the meeting the meeting the
whether criteria of criteria of criteria of criteria of
monitorin CPCB CPCB CPCB CPCB
g wells
meeting
9
the
criteria of
CPCB
7 Environm Complied Complied Complied Complied
ental
monitorin
g
systems
as per
section
9.4
8 Closure Not Not Not Not
plan : applicable complied complied complied
Whether since it is
meeting active
with
CPCB
criteria
9 Monitorin Not Not Not Not
g has applicable complied complied complied
been since it is
carried active
out as per
the Post
closure
criteria of
CPCB
Following are the general observations on Closed and active SLF of four plants of M/s Chemplast Sanmar:
Out of 34 SLFs, 30 SLFs were found closed and capped with cement concrete, only four SLFs were found in active state.
14 SLFs were found built before implementation of CPCB criteria for Hazardous Waste Land Fills, 10 remaining 20 SLFs were built after implementation of CPCB criteria All SLFs were partially meeting with location criteria, however no investigation carried out regarding type of soil and permeability of soil in the identified area for constructing SLFs As per the CPCB guidelines, if the ground water table lies between 2- 6 m, the liner system shall be Double composite liner, However the unit has provided single liner, this lining system also not as per the CPCB guidelines.
In all 30 closed SLFs, no leachate collection & management system exists, which confirms the SLFs were constructed without following the CPCB criteria. Leachate collection trench network in active SLFs (4 no.) also found not meeting with CPCB criteria. All SLFs found not operated in phased manner as per CPCB criteria.
No Record Keeping and Waste inspection maintained as per the CPCB criteria.
As per the CPCB guidelines minimum of 4 Piezometers / ground monitoring wells (one in up gradient and three in down gradient)should be provided. No SLFs meeting this criterion and most of them found filled with silt and soil.
No closure plan was observed in all 30 closed SLFs. No gas collection system provided to extract gas if any from SLF, no monitoring carried out as per the post closure criteria.11
iii. Status of operation of the Plant - IV The unit of M/s Chemplast Sanmar Ltd Plant-IV, Veerakkalpudur village, Mettur Taluk, Salem District has obtained consent (altered) under Water Act and Air Act vide Board Proc. No R1/TNPCB/SLM/F.146/RL/W&A/97 dt 31.03.1997 for production of Metallurgical Silicon, Anhydrous HCL, Hydrogen and Caustic Soda. Necessary amendment under the Air Act for the changes in emission sources was issued by the Board vide Proc. dt 8.3.2011.Subsequently, the consent was renewed up to 31.03.2020. Due to non-profit of products, manufacturing activity was stopped from 27.03.2010.
In the year 2019, the unit has established the Hydrogen Peroxide (H2O2) (50%) manufacturing unit to manufacture 53,000 MT/Year in the same premises by utilising the surplus Hydrogen gas produced in the M/s. Chemplast Sanmar Ltd- Plant III (Caustic Chlor Plant) located adjacent to this plant and obtained consent to operate of the Board. In the Hydrogen Peroxide manufacturing process, Hydrogen will be obtained from the plant III and Oxygen is obtained from the Air. Both are reacted in the Ethyl Anthraquinone working solution (Solvent) in the presence of a catalyst (Palladium) and forms Hydrogen Peroxide.
The Joint Committee inspected the Plant IV on 20.01.2020, the team of officials from Directorate of Industrial Safety and Health verified in detail w.r.t safety measures provided in raw material storage, process equipment's, transmission equipment and in the product storage area. The brief description on process of Hydrogen peroxide and 12 suggestion on improvement of safety measures is enclosed at Annexure - 5. The committee also witnessed the VOC monitoring carried out by third party laboratory to verify the adequacy of source pollution control devices installed to control VOCs.
iv. Visit to Surrounding areas by team of officials from NGRI to understand the field conditions for preparing the proposal for taking up detailed study of Ground water to ascertain the causes for ground water pollution in the area:
The NGRI team visited to the surrounding villages located around the M/s. Chemplast Sanmar Group of companies on 27.01.2020 and collected samples from the open wells and bore wells for assessing the ground water contamination in and around the M/s. Chemplast Sanmar Group of companies, prepared proposal for taking detailed study. The proposal is under process and the unit has been requested by the TNPCB to remit the project cost to the NGRI (Annexure - 6) 4.0 Monitoring Results & Discussions and other Specific observations:
i. Source Emission Monitoring of Plant IV During field visit, the committee witnessed the source emission monitoring of the Plant IV to ascertain the adequacy of air pollution control devices installed. During monitoring, out of two reactors of H2O2 Production unit only one reactor was in operation and operating at 36% (52 MT/day) of the consented capacity. The unit has two separate chiller followed by activated carbon adsorbent beds to recover solvent from process air (from oxidiser) to reduce the Volatile Organic 13 Carbon (VOC) before venting out to atmosphere. Since one reactor was in operation the process air from one reactor being treated by using both chiller followed by activated carbon adsorbent beds, hence the samples from inlet and out let of both Activated carbon adsorbent beds were monitored and results are tabulated as below;
Table 4: Analysis report TVOCs monitored from inlet and Outlet adsorbent bed (In case of both adsorbent beds used to control VOC before venting into atmosphere) Sl. Parameters Activated carbon Activated carbon No. adsorbent-1 adsorbent-2 In let Out let In let Outlet 1 Temperature in 307 306 306 315 Kelvin (33.85o C) (32.85o C) (32.85o C) (41.85o C) 2 Oxygen O2 in % 10.7 10.4 9.8 9.4 3 Carbon dioxide 5.8 6.0 6.3 6.6 CO2 in % 4 TVOC in PPM 750 25 270 0.3 (2421.84mg (80.728mg (871.863mg (0.969 mg /m3) /m3) /m3) /m3) 5 Ethyl Benzene in 1.22 BDL 4.18 BDL PPM 6 P-Xylenein PPM 2.33 0.53 8.07 BDL 7 Propylbenzenein 24.15 4.19 44.31 BDL PPM 8 1,2,4 - 1616.12 251.09 1808.76 3.59 Trimethylbenzene in PPM 9 1,3,5 - 73.72 17.52 294.30 BDL Trimethylbenzene in PPM 10 Naphthalene in 385.77 0.90 18.41 0.34 PPM 11 Sec-Butylbenzene 44.75 13.44 129.34 BDL 14 Sl. Parameters Activated carbon Activated carbon No. adsorbent-1 adsorbent-2 In let Out let In let Outlet in PPM From the above, it is observed that the inlet concentration of VOC (750 & 270 PPM) in two Adsorbent were found to be different concentrations, which indicates the poor operation of chiller (i.e. poor operation of chiller results into difference in inlet concentrations).
The high concentration of VOC in inlet of first adsorbent bed results into outlet concentration as high as 25 PPM which indicates that saturation of adsorbent bed due to high inlet concentration.
Other organic compounds viz. Benzene group and Naphthalene were found in inlet as well as at out let of adsorbent- 1.
The sources CO2 in inlet and outlet of adsorbent bed are questionable and require identification of source. The performance data of adsorbent beds (both 1 and 2) at varying concentrations of VOC is not available with industry.
Table 4a: Analysis report TVOCs monitored from inlet and Outlet adsorbent bed (In case of one adsorbent bed used to control VOC before venting into atmosphere) 15 Sl. Parameters Activated carbon No. adsorbent-2 In Out let let 1 Temperature in Kelvin 299s 317 (25.8 (43.85o 5o C) C) 2 Oxygen O2 in % 10.4 10.5 3 Carbon dioxide CO2 in % 6.0 6.0 4 TVOC in PPM 320 0.2 (103 (0.646 3.31 mg 9mg /m3) /m3) 5 Ethyl Benzene in PPM 3.79 BDL 6 P - Xylene in PPM 6.99 BDL 7 Propylbenzene in PPM 51.5 BDL 6 8 1,2,4 - 1876 2.38 Trimethylbenxene in .83 PPM 9 1,3,5 - 267. BDL Trimethylbenzene in 52 PPM 10 Naphthalene in PPM 7.64 0.14 11 Sec-Butylbenzene in 111. BDL PPM 85 From the above, it is observed that the lower concentration of VOC (320 PPM) at inlet of Adsorbent bed 16 results into lower concentration at out let, it indicates that better efficiency of chiller reduces the load on adsorbent bed.
The efficiency of removal of other organic compounds viz Benzene group and Naphthalene were found good, which confirms that lower concentration of VOC at inlet increases the efficiency of adsorbent. But, no data is available with industry regarding the performance of adsorbent bed at varying inlet concentrations of VOC. The CO2 concentration is found almost same as first case and requires identification of source ii. Monitoring of Piezometer / Bore wells installed in SLF The committee also monitored the piezometers / Bore wells installed in SLFs, during inspection out of 25 piezometer / Bore wells. Among the piezometers, one piezometer well was found dry and no water was available. The committee taken 24 samples from piezometers / borewells and analysis reports of each wells are tabulated in respective reports of individual plant SLFs (Annexure - 4). The summary of water quality report of individual plant SLFs are tabulated below:
Table 5: The summary of water quality report of individual plant SLFs Sl Paramete The maximum and minimum concentration observed N rs Plant- Plant-II Plant-III Plant-V o. I Minim Maxim Minim Maxim Minim Maxim um um um um um um 17
1. Conducti 1638 339 1643 395 1553 438 1240 vity at 25°C (µmhos / cm)
2. pH at 7.24 6.78 7.48 7.13 7.77 6.94 7.53 25°C
3. TDS at 1196 228 1104 288 1112 344 884 180°C (mg/l)
4. Chloride 170 30 355 52 320 40 235 as Cl (mg/l)
5. Sulphate 162 8.7 46.2 <5 34 <5 14.4 s as SO4 (mg/l)
6. BOD (at 3 <2 3.0 <2 19.8 <2 165 27°C for 3 days) (mg/l)
7. COD 24 16 24 16 120 16 528 (mg/l)
8. Total 1.68 1.12 1.68 1.12 5.6 1.12 35 Kjeldahl Nitrogen
9. Nitrate 2.444 0.021 0.207 0.014 0.078 0.035 0.160 Nitrogen as NO3 (mg/l)
10. Nitrite 0.003 0.005 0.011 0.001 0043 0.010 0.671 18 Nitrogen as NO2 (mg/l)
11. Total 4.127 1.226 1.712 1.15 5.623 1.202 35.112 Nitrogen (mg/l)
12. Total 620 112 340 68 280 148 280 Hardnes s as CaCO3 (mg/l)
13. Calcium 136 24 88 11 64 27.2 160 as Ca (mg/l)
14. Magnesiu 68 13.6 29 5.3 21.8 7.7 31.5 m as Mg (mg/l)
15. Potassiu <1 <1 <1 <1 3.9 <1 3.5 m as K (mg/l)
16. Fluoride 0.294 0.063 0.213 0.040 03.300 0.011 0.196 as F (mg/l)
17. Dissolved 0.333 0.014 1.509 0.009 0.278 0.009 1.74 Phosphat e as PO4 (mg/l)
18. Phenolic BDL BDL BDL BDL BDL BDL BDL Compoun ds (mg/l) 19
19. Sodium 459 122 176 93 288 190 288 Bicorbon ate* (mg/l)
20. % 29 15 55 31 79 41 104 Sodium
21. Iron 0.55 0.54 1.35 0.35 1.24 0.45 1.30 (mg/l)
22. Cadmium <0.00 <0.00 <0.000 <0.00 <0.000 <0.00 <0.000 (mg/l) 08 08 8 08 8 08 8
23. Mercury <0.00 <0.00 <0.001 <0.00 <0.001 <0.00 <0.001 (mg/l) 1 1 1 1
24. Lead <0.01 <0.01 <0.015 <0.01 <0.015 <0.01 <0.015 (mg/l) 5 5 5 5
25. Copper <0.00 <0.00 <0.001 <0.00 <0.001 <0.00 <0.001 (mg/l) 15 15 5 15 5 15 5
26. Zinc 0.27 0.20 0.32 0.23 0.43 0.27 0.49 (mg/l)
27. Arsenic <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 (mg/l)
28. Nickel <0.00 <0.00 <0.006 <0.00 <0.006 <0.00 <0.006 (mg/l) 6 6 6 6
29. Total <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 Chromiu m (mg/l) Summary of findings based on analysis results of samples collected during committee visit are depicted below 20 Sl Name of the No. of Parameters Remarks no. unit having Piezomet found exceeding SLFs er/monito the BIS Drinking ring water standards wells exist 1 Plant I - 1 1 Piezom Except the The active SLF eter concentration of concentration BOD and COD, of BOD and other parameters COD in were found monitoring meeting with BIS well indicates standards of the need of drinking water. close monitoring.
2 Plant II - 1 4 In 2 piezometers, The
active and 14 Piezomete all parameters concentration
Closed SLFs rs found meeting of BOD and
with standards COD in PBW 3
but in other two & 4 indicates
Piezometers the need of
namely PBW 1 & close
4 except BOD and monitoring.
COD, other
parameters were
found meeting
with standards.
3 Plant III - 1 11 In 9 piezometers, The
active and 13 Piezomete all parameters concentration
Closed SLFs rs & Bore found meeting of BOD and
well with standards COD in PBW 5
but in other two & 8 indicates
Piezometers the need of
namely PBW 5 & close
11 except BOD monitoring
and COD, other since these
parameters were two wells are
found meeting located in
21
with standards. down
gradient.
4 Plant V - 1 7 In 5 piezometers, The high
active and 3 Piezomete all parameters concentration
Closed SLFs rs (one found meeting of BOD and
well is with standards COD in PZ- 5
closed) but in one indicates the
Piezometer probable
namely PZ 5 contamination
except BOD and of ground
COD, other water which
parameters were requires close
found meeting monitoring.
with standards.
5.0 Conclusion of the Joint Committee based on the field observations and monitoring
a) Measures taken against the recommendations of last committee visit
1. The unit has removed certain portion of the unused pipes from the surplus courses.
2. No steps taken to install STP in place of Soak pit or Septic tank in Plant I & its colony
3. No water auditing report made available to committee to verify the adequacy
4. The hazardous waste generated from Plant-I, II & III is being disposed in captive SLF itself. Only the hazardous waste from Plant V is being sent to TSDF.
5. The unit has not taken any step to segregate and collect storm water plant area as well as from vacant land of plant 22
6. The unit has not taken any steps either diversion of storm water drains which are passing inside the premises or installation of online monitoring system to these drains
7. The unit has not submitted any inventory report regarding root cause for oozing of water from outside boundary wall of Plant - II
8. No steps to close the rain water inlet to avoid the rain water entry from outside into the plant IV.
9. Only VOC is monitored in Plant IV, CAAQM yet to install for continuous monitoring of AAQ around the units
b) Compliance status of SLFs w.r.t CPCB criteria and water quality around the SLFs of Plant I, II, III & IV Out of 34 SLFs, 30 SLFs were found closed and capped with cement concrete on top, only four SLFs were found in active state.
14 SLFs were found built before implementation of CPCB criteria for Hazardous Waste Land Fills, remaining 20 SLFs were built after implementation of CPCB criteria All SLFs were partially meeting with location criteria, however no investigation was carried out regarding type of soil and permeability of soil in the identified area for constructing SLFs As per the CPCB guideline, if the ground water table lies between 2- 6 m, the liner system shall be double composite liner. However, the unit has provided single liner, this lining system also not as per the CPCB guidelines. In all 30 closed SLFs, no leachate collection & management system exist, which confirms the SLFs were 23 constructed without following the CPCB criteria. Leachate collection trench network in active SLFs (4 no.) also found not meeting with CPCB criteria.
All SLFs found not operated in phased manner as per CPCB criteria.
No Record Keeping and waste inspection maintained as per the CPCB criteria.
As per the CPCB guide line, a minimum of 4 Piezometers / ground monitoring wells (one in up gradient and three in down gradient) should be provided. No SLFs meeting this criterion and most of them found filled with silt and soil. Out of 22 peizometer wells monitored, in 5 Peizometer wells the concentration of BOD & COD found slightly high (high BOD & COD reported in one well), which indicates the sign of contamination.
No closure plan was observed in all 30 closed SLFs. No gas collection system provided to extract gas if any from SLF, no monitoring carried out as per the post closure criteria.
The NGRI member suggested that further study is required for assessing the ground water contamination in and around the M/s. Chemplast Sanmar Group of companies in Mettur area.
c) Pollution control measures and safety measures taken in plant IV Pollution Control measures:
As per the VOC monitoring carried out by the third party laboratory in Plant IV, the efficiency of one activated carbon adsorbent found very poor in spite of 24 H2O2 production at 36% of consented capacity (one reactor) and process air being treated by using both chiller and adsorbent beds.
In second time monitoring, it was observed that the lower concentration of VOC (320 PPM) at inlet of Adsorbent bed results into lower concentration at out let, it indicates that better efficiency of chiller reduces the load on adsorbent bed. The efficiency of removal of other organic compounds viz. Benzene group and Naphthalene were found good, it confirms that lower concentration of VOC at inlet increases the efficiency of adsorbent.
High concentration CO2 was found at inlet and outlet of adsorbent in both cases of monitoring, hence it needs identification of sources. There is a possibility of saturation of the adsorbent bed. The regeneration was not taking place based on saturation (Break through point) of the absorber, which need further investigation.
The parameters such as circulation rate of the working solution and air flow rate will affect the performance of the adsorbent beds.
The unit has provided on line VOC monitoring system. But, it has not been placed properly and not serving the purpose. Present real time VOC monitoring system captures VOC in Ambient and not the actual concentration at point source.25
Safety measures:
As per the study conducted by the Additional Director of Industrial Safety and Health, the existing safety measures are found not adequate and inadequate safety measures observed in the plant IV is enclosed in Annexure - 5.
6.0 Recommendation of Joint Committee :
1. The industry shall take steps to comply with all measures suggested by first committee which are tabulated in table No.1.
2. The NGRI shall carry out a study of all the 34 SLFs with respect to seepage since the high concentration of BOD & COD observed in the 5 Peizometer wells.
3. The industry shall take detailed study on ground water pollution in around the M/s. Chemplast Sanmar Group of industries through NGRI. The cost of the study should be borne by the M/s. Chemplast Sanmar Group of industries.
4. After the above said study, if there is any seepage, the evacuation of the stored sludge from SLF into the TSDF can be decided by the Hon'ble NGT.
5. The unit shall provide proper Piezometer around the SLFs in consultation with the joint committee with proper depth to get true representation of the value.
6. Considering the environmental factors such as adjacent Cauvery River, Mettur Dam, Water table in that area and nearby habitations, the Plant I, II, III and plant V shall be directed to stop disposal of any sludge in the captive SLFs and to direct to dispose into the TSDF.26
7. The unit shall be directed to implement all safety measures in Plant IV as suggested by Additional Director of Industrial Safety & Health (Annexure -5).
8. The production of H2O2 in Plant IV may be restricted to 30-
40% (57.6 T/day) of consented capacity (144 T/day) until implementation of following measures; The unit shall provide more effective chillier to the solvent recovery unit for better recovery of the solvent.
The unit shall provide adequate number of additional adsorbent beds for better control of VOC emission further.
In addition to adsorbent beds, the unit shall be directed to install Regenerative Thermal Oxidizer (RTO) system to achieve the VOC emissions below 5 microgram /Nm3.
The concertation of VOC at outlet of adsorbent should be interlocked with production line. The unit shall provide proper stack emission monitoring system (VOC monitoring) with suction motor. The unit shall install alarm system to give caution in case of exceedance of VOC limit in the stack The unit shall provide suitable emission monitoring system of the inlet and out let of the adsorbent. The unit shall provide Siren system coupled with ambient VOC monitoring system to give alert to public in case of exceedance of TVOC in ambient air. The unit shall carry out automation in the adsorbent section to control emission.
279. The unit shall regularly calibrate all the VOC monitors installed at the stacks attached to adsorbent beds and provide proper data to Care Air Centre of TNPCB, Guindy at all times
10. The unit shall provide Continuous Ambient Air Quality monitoring stations (CAAQM) in four directions around the Plant - II, III, IV, V and Power Plant. The unit shall monitor PM10, SOx, NOx, Chlorine and VOC."
7. The counsel appearing for Ministry of Environment, Forest and Climate Change (MoEF & CC) wanted further time to file the report.
8. The committee is directed to seek the assistance of NGRI to conduct the study as observed in the recommendations and thereafter file a further report regarding the same to this Tribunal, instead of delegating the same to the project proponent.
9. The committee is directed to submit the further report as directed within two months time through e-mail or e-filing at [email protected] after conducting the study by the agency suggested by them in the joint report.
10. The Registry is directed to communicate this order to the joint committee members immediately through e-mail, so as to enable them to comply with the direction.
2811. The Ministry of Environment, Forest and Climate Change (MoEF & CC) is directed to submit their response as to whether this project requires any prior environmental clearance (EC) before commencement under the prevailing environmental laws.
12. For consideration of report and also for filing objections and response to the Original Application by the party respondent who did not file the response so far and objections if any to the joint committee report, post on 21.08.2020.
.....................................J.M. (Justice K. Ramakrishnan) ..............................E.M. (Shri. Saibal Dasgupta) O.A.No.16/2019 (SZ) 01st June, 2020. Sr. 29