National Green Tribunal
Venkatapati Raja Yenumula vs Ministry Of Environment Forest And ... on 24 March, 2022
Author: K Ramakrishnan
Bench: K Ramakrishnan
Inspection Report in the matter of OA 175/2020 (SZ)
JOINT INSPECTION REPORT OF COMMITTEE CONSTITUTED BY HON'BLE
NATIONAL GREEN TRIBUNAL, SOUTHERN BENCH, CHENNAI IN
COMPLIANCE TO HON'BLE NGT ORDER DATED 19.01.2022 IN THE MATTER
OF OA NO. 175 OF 2020 (VENKATAPATHI RAJA YENUMALA VS UNION OF
INDIA & ORS)
SUBMITTED TO
HON'BLE NATIONAL GREEN TRIBUNAL
SOUTHERN BENCH, CHENNAI
March, 2022
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Inspection Report in the matter of OA 175/2020 (SZ)
I Preamble
An application was filed in Hon'ble NGT Southern bench alleging that air, sound, soil and water
pollution is caused on account of the activities of the M/s GAIL India Ltd (formerly Gas
Authority of India Ltd) and M/s ONGC (Oil & Natural Gas Corporation Ltd) units in the State of
Andhra Pradesh along the Krishna-Godavari Basin located in East Godavari and West Godavari
District of Andhra Pradesh. According to the applicant oil leakage is being caused in the pipe
lines established by these units causing damage to the agricultural land and also affecting the
water bodies. It is also alleged that the units are not following the pollution control mechanism
and there is no proper maintenance of pipelines. In order to ascertain the impact of the activities
of M/s GAIL and M/s ONGC in Krishna Godavari River bed in East Godavari and West
Godavari District, Hon'ble NGT has appointed a Joint Committee. Committee submitted the
report to Hon'ble NGT during April, 2021.
ONGC submitted detailed status report and compliance report to Hon'ble NGT and in response
to this Hon'ble NGT vide order dated 19.01.2022 again directed the joint committee to inspect
the unit and consider the compliance report submitted by ONGC. Hon'ble NGT has directed the
Joint Committee to ascertain as to whether ONGC is spending its CSR amount to meet the
environmental sustainable development activities as directed to be done under Environmental
Clearance and incorporate the same in the report to be filed.
II Orders of the Hon'ble Tribunal
Hon'ble NGT, Southern Bench, Chennai in Original Application No. 175/2020(SZ) in the matter
of Venkatapathi Raja Yenumala Vs Union of India & Ors vide order dated 19-01-2022 has
directed as follows:
"So, we direct the Joint Committee to inspect the unit again and consider the compliance report
submitted by the ONGC regarding the recommendations made and the Pollution Control Board
is also directed to inspect independently and submit their report regarding satisfaction of the
compliance and further steps, if any, to be taken to avoid such incidents in future from their side
as a regulator. They have also not filed any action taken report as undertaken by them. So, the
Joint Committee as well as Pollution Control Board are directed to file their further report and
action taken report, if any, required on or before 25.02.2022.
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Inspection Report in the matter of OA 175/2020 (SZ)
The Joint Committee is also directed to ascertain as to whether ONGC is spending its CSR
amount to meet the environmental sustainable development activities as directed to be done
under Environmental Clearance and incorporate the same in the report to be filed ". Copy of
Hon'ble NGT order is placed as Annexure-I.
IIa. Composition of the Committee
In compliance to Hon'ble NGT order, committee comprising of following members was
composed:
Name & designation of the Department with address
official
Sh. C Vishnu Charan, IAS Sub Collector and Sub Divisional Magistrate
Narsapuram West Godavari
Sh. Vasatha Rayudu, RDO, Amalapuram, East Godavari
Dr. Suresh B Pasupuleti Ministry of Environment Forest and Climate Change,
Scientist-D Regional Office, Vijayawada
Prof. M. Deepa Dept. of Chemical Engineering,
A.U College of Engineering (A)
Andhra University, Visakhapatnam
Sh. P. Ravindranath Andhra Pradesh Pollution Control Board, Zonal
Senior Environmental Engineer Office, Visakhapatnam
Smt. Mahima T Central Pollution Control Board
Scientist-D Regional Directorate, Chennai
The committee visited the site from 8th to 11th March, 2022 and carried out ambient air quality
monitoring, collection of water &wastewater samples and soil samples. Committee interacted
with villagers, village heads, school authorities and interacted with the applicant over phone.
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Inspection Report in the matter of OA 175/2020 (SZ)
III Compliance Verification of the units
In compliance to Hon'ble NGT orders, post committee inspection M/s ONGC has taken
corrective actions. M/s ONGC has submitted in the Compliance Report that following actions
are implemented in all installations in Kakinada and Rajahmundry asset:
a. Units have taken measures for periodical cleaning and desilting of drains.
b. Measures are taken for disposal of sludge. Tenders are invited for bio-remediation
ofsludge.
c. Closed loop system for VAP sampling(Tatipaka)
d. Initiated for construction of sludge pit of 1000 m3 capacity (Tatipaka)
e. Construction of Two sheds, One for Hazardous waste and the other for hazardous
chemicals
f. Units have initiated measures to install flowmeters at inlet of ED (effluent disposal well)
g. LDAR (leak detection and repair) is carried out internally by the units and necessary
corrective actions are taken to arrest leakages.
Compliance status of specific installation is described in below sections.
IV. Compliance Verification of Tatipaka GCS
Sl. Non-compliances Compliance status Current status of Remarks
N observed by submitted by the unit and compliance as verified
O committee during Upgradations/ by the committee
first visit Modifications made by the
unit
1 The storm water Oil catchers are provided in Unit has desilted and Partially
from the two storm water drains cleaned the drains and complying
installation is located near process area the oily sludge settled in
discharged into and any oil carried over the drains are removed.
main drains laid from the process area is but however mode of
outside the unit recovered in the oil catcher. disposal of silt & oily
premises. During Unit has taken measures to sludge was not available.
inspection the desilt and clean the storm Near the effluent
committee water drains twice a year to collection tank and near
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Inspection Report in the matter of OA 175/2020 (SZ)
observed that due prevent logging. Unit has effluent tanker unloading
to heavy rains and submitted that all the drains tank, effluents were
water logging, were cleaned and unit has present in the drain.
effluent was taken measures to recover There are cracks in tank
getting mixed with oil from the storm water used for collecting
storm water and drains. effluent from tankers and
from the main Unit claims as complying effluent was seeping into
drain it may adjacent ground.
ultimately join Storm water is
sea. discharged outside the
unit. Unit has not made
any arrangements to lift
the first flush of rain
water (for 30minutes)
and to treat the same in
ETP.
2 The tilted plate ETP Upgradation work is Tilted plate interceptor is Not-
interceptor and yet to be undertaken. not upgraded but only complying
slop oil tank are Support structure of Tilted supporting civil structure
not working Plate interceptor is (wall) is strengthened.
properly. The strengthened and is in The capacity and
capacity and operation as per the design retention time of plate
retention time of capacity of 21 cum per hour interceptor is not
plate interceptor is which is adequate as per the adequate to treat the
not adequate to design criteria of ETP. effluent. Oil separators
treat the effluent. Unit claims as works under are not properly
Hence the oil progress. working.
removed from
effluent is
stagnated and
overflowing.
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Inspection Report in the matter of OA 175/2020 (SZ)
3 The units have not ETP upgradation works is Unit is yet to obtain Complying
amended the yet to be undertaken. amendment of the w.r.t
consent for the Post committee inspection, consent order for effluent
revised quantity of Tatipaka GCS is taking increased quantity of discharge
effluent generated. effluent from other effluent generated. limits.
Thereby presently installations only on very As per the records,
the effluent rare occasions and effluent average effluent
generated from the generated from Tatipaka generated from the Not
installation is GCS is only treated in the installation is 350m3/day complying
more than the ETP. but the capacity of w.r.t CFO
quantity specified effluent collection tank conditions
in the CFO issued Unit claims as work under is 40 KL. Unit is not
by APPCB and progress having capacity to store
moreover the the effluent for even a
existing ETP is day.
not adequate in ETP comprises of
terms of capacity collection tank slop oil
to treat the present tankclarifierMMF
effluent generated. ED wells. Committee
As per the CFO collected effluent sample
issued to Tatipaka from inlet and outlet of
GCS on ETP and the analysis
27.02.2015 the results are given in table
quantity of 1 and treated effluent is
effluent is 225 meeting with ED well
KLD but presently disposal limits.
effluent generated
is more than 500 Old ETP which is not in
KLD. In addition, use is filled with
15 KLD of effluent. Oily effluent is
effluent generated still present in clarifier.
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Inspection Report in the matter of OA 175/2020 (SZ)
from Tatipaka Unit shall submit time
mini refinery, bound action plan to the
Endamuru GCS treat the effluent present
and Mandapeta in old ETP and to
GCS has to be dismantle old ETP.
treated. Hence the
existing ETP of
capacity 500KL is
not adequate to
treat the present
quantity of
effluent generated.
Table 1: Wastewater analysis results of Tatipaka GCS
Location TSS mg/L Oil & grease mg/L
ETP inlet - Tatipaka 1670 66.7 mg/L
ETP Outlet- Tatipaka 15 BDL(DL:4.0)
APPCB standards 100 10
Guard pond Water- Tatipaka 12 BDL(DL:4.0)
From the results it is clear that the treated effluent is meeting the APPCB standards for ED well
disposal. From the guard pond effluent is discharged to ED well. Detailed wastewater analysis
results are enclosed as Annexure-II.
4 Sludge drying Unit has invited tenders for Oily sludge generated Not-
beds are not in disposal of sludge. from the inception of the complying
operation Oily sludge is collected in unit is stored in open in
Sludge storage tank. sludge tanks upto brim
Tendering work is in of the tank. It was
progress for Oil recovery reported by the unit that
from Sludge (E-tender No. the spillages were
K16JC21015) removed and transferred
followed by Bioremediation to the tank itself. During
of residual for which NOA rainy season, runoff
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Inspection Report in the matter of OA 175/2020 (SZ)
exist with TERI. water from sludge tank
Unit claims as work under is likely to carry sludge
progress. particles with it to the
surrounding area.
Committee collected sediment samples near effluent collection tank and tanker unloading tank
and analysis results for core parameters are as follows (detailed sediment analysis results is
submitted as Annexure-III:
Table 2: Sediment samples analysis results of Tatipaka
Location Total
Iron Mercury Lead Benzene Benzo(a)py Phenols
TPH
(mg/kg) (mg/kg) (mg/kg) (mg/kg) rene (µg/kg (mg/kg)
mg/Kg
Sediment sample
adjacent to 40 BLQ BLQ BLQ BLQ BLQ BLQ
411.84
KL effluent (LOQ:11.0) (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1)
collection tank
Sediment sample
adjacent to BLQ BLQ BLQ BLQ BLQ
752.67 729.61
effluent tanker (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1)
unloading tank
Sediment sample BLQ(LOQ: BLQ(LO BLQ(LOQ: BLQ(LOQ:
98.13 3148.15 3.88
near sludge tank 2.0) Q:20) 20) 0.1)
sediment analysis results indicates that effluent may be seeping into the soil from effluent
collection tank and tankers unloading tank.
5 TVOC levels Online Hydrocarbon TVOC levels was Complying
measured using detectors are installed to measured using
handheld PID monitor fugitive emissions. handheld PID analyzer
analyser in the in the ETP area and
ETP area is Guard pond and storm water TVOC levels was
varying from drains cleaning has been varying between 0ppm
2.2ppm to 4.0ppm carried out and TVOC levels to 2ppm.
are within the limits
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Inspection Report in the matter of OA 175/2020 (SZ)
Unit claims as complying
6 There is no Hazardous waste and Unit has constructed one Complying
dedicated chemical sheds are shed for storage of
hazardous waste constructed. hazardous waste- lube
storage shed. ETP Storage of hazardous waste oil but however lube oil
sludge, empty & chemicals are being stored was not stored in the
barrels, slop oil in the designated sheds. shed. Reported that lube
are stored Unit claims as complying oil was disposed during
haphazardly February, 2022.
within the unit
premises
7 In old GCS plant Drain channels are cleaned. It was observed that no Complying
drain effluent is The pH levels are observed effluent was joining the
joining storm to be within the limits. drain in old GCS plant
water drains and Unit claims as complying and drains were in dry
pH of drain condition. There were no
effluent was 14 rains in the area during
committee inspection.
8 LDAR of refinery Unit is periodically Unit is yet to carry out Partially
is not carried out. monitoring TVOC levels Leak detection and Complying
TVOC levels near internally. Unit has carried repair (LDAR) study
the valves of out LDAR internally. through certified
distillation column Unit claims as complying agencies.
is around 5ppm
and near sampling
point is 70ppm
9 In the gas The Boiling point of TEG is There was no odor Complying
dehydration unit more than 240oC whereas, nuisance. VOC levels
in the re-boiler the re-boiler temperature is was measured using
system, during maintained at 190oC. So the handheld VOC analyzer
knocking out chances of glycol and it was 0ppm.
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Inspection Report in the matter of OA 175/2020 (SZ)
some glycol vaporisation is nil.
vapors is carried Unit claims as complying
along with
moisture. There
was odor nuisance
in the area.
10 Odour nuisance Due to cleaning of drains, There was no odour Complying
removal of oily sludge and nuissance. Ambient air
controlled knock out quality monitoring was
emissions TVOC levels are conducted inside the unit
within the limits and hence and in malletivara
there is no odour nuisance. merakinagalam village,
Unit claims as complying Peerlacheruvu nagar
village and pedapatinam
nagarm village
surrounding the
installation and found
that it is meeting
ambient air quality.
Ambient air quality
results are enclosed as
Annexure-IV
11 CFO validity Tatipaka GCS has Complying
obtained Consent under
the Water Act, 1974, the
Air Act, 1981 and
Hazardous Waste
authorization valid till
31.07.2023. Copy of
Tatipaka CFO is
enclosed as Annexure-V
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Inspection Report in the matter of OA 175/2020 (SZ)
Photo 1: drains in Tatipaka after cleaning Photo 2: tilted plate interceptor
Photo 3: Hazardous waste Photo 4:waste oil drums Photo 5: Clarifier filled with
storage shed stored in open effluent in old ETP
Photo 6: Effluent treatment plant Photo 7:Treated effluent storage
tank
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Inspection Report in the matter of OA 175/2020 (SZ)
Photo 8: Sludge tank Photo 9: area surrounding the sludge tank
IVa. Environmental compensation from Tatipaka GCS
EC for
EC=PI x N x R x S x LF
violation of
Where,
CFO
EC = Environmental Compensation in INR
conditions
PI = Pollution Index of industrial sector (red-80)
N = Number of days of violation took place (from the date
of violation to date of compliance- 25.02.2021 to
11.03.2022= 379 days
committee had calculated compensation till 25.02.2021 and committee re-
inspected during 08-03-2022 to 11-03-2022 and observed following non-
compliances:
1.Tilted plate interceptor is not properly working
2. Effluent is seeping into soil from effluent collection tank and tanker unloading tank
3. Oily sludge (hazardous waste) is laying in open in sludge tank for more than 5 years.
4. Effluent and oily sludge is present in Old ETP which is not in use for more than 3 years.
R = A factor in Rupees for EC (Rs. 250/-) S = Factor for scale of operation (large-1.5) LF = Location factor=1 Page 12 of 39 13 Inspection Report in the matter of OA 175/2020 (SZ) =80*379 days*250*1.5*1 = 1,13,70,000/-
Rupees One crore thirteen lacs seventy thousand only Considering that unit has made improvements and is mainly complying with effluent disposal standards, committee has not imposed repeated violation factor.
V. Compliance Verification of Kesanapalli-W: GGS
Sl. Non-compliances Compliance status Current status of compliance Remarks
No observed by submitted by the as verified by the committee
committee during unit and
first visit Upgradations/
Modifications
made by the unit
1 Effluent is getting Drains were Unit has cleaned storm water Partially
mixed with storm cleaned. drains but however Oil catchers complying
water and storm are not installed in the drains and
water is discharged measures to prevent entry of
into main drain effluent into storm water drains
outside the unit is not taken up. Measures to lift
premises. pH of the or pump first flush of rain water
storm water was 12. into ETP is not taken.
In addition the Records on the quantity of oily
leaves and garden sludge removed from the drains
waste is in the drain and mode of disposal of this
and getting putrefied sludge was not made available to
in the drain itself committee.
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Inspection Report in the matter of OA 175/2020 (SZ) 2 The effluent stored Red colored Reported that red colored Complying in treated effluent effluent is taken to effluent from treated effluent sump was red in ETP for treatment. storage tank was again taken color and pH was Unit informed that back to ETP for re-treatment. more than 12 awareness was During committee insoection no created among the red colored effluent wss present workers as not to inside the unit premises. Treated add any chemicals effluent samples were taken and into treated water or analysis results are given table 3. fresh water sumps.
Unit claims as
complying
3 There is no Dedicated storage Unit has constructed two Partially
dedicated hazardous sheds for hazardous separate sheds for chemical complying
waste storage sheds waste and storage and hazardous waste (shed is
chemicals have storage. Unit is generating two constructed)
been built. categories of hazardous waste:
Unit claims as ETP sludge/ oily sludge and
complying waste lube oil. Currently unit
continues to store ETP sludge/
oily sludge openly in sludge tank
and unit has proposed to store
only waste lube oil in the shed.
But however on the day of
inspection, the shed was empty
and waste lube oil was not
present.
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Inspection Report in the matter of OA 175/2020 (SZ) 4 The unit was ONGC having CFE Unit is having two ETP's. Not disposing the and auto renewal of Capacity of old ETP is 750 m3/ complying effluent by means of CFO for the day and capacity of new ETP is marine disposal but operation of 1500 m3/day. Old ETP however the unit has Kesnapalli-w ETP comprises of not obtained which is available tilted plate interceptor flash necessary upto 31.07.2023. mixer flocculation tank permissions from CRZ clearance was dissolved air floatation dual APPCB for marine also obtained for media filter guard pond ED disposal. Further, laying disposal line. well. part of the pipeline New contract/tender On the day of inspection, raw used for deep sea was awarded for effluent was directly taken to disposal (1000m laying New Marine DAF and pre-treatment units stretch of pipeline disposal line in were not in operation. taking deep sea) is place of broken line New ETP comprises of broken and washed (which is expected Corrugated plate interceptor away. Presently the to be completed by induced gas floatation Nutche unit is disposing the March-2022, in the filter sequential batch effluent in the coast. favourable climate reactor media filters treated The unit had window) effluent storage tank sea obtained CRZ Meanwhile, disposal.
clearance for laying temporary Unit has obtained CRZ clearance of pipelines arrangement was for laying of pipeline for marine made with 8"casing disposal. Copy of CRZ clearance pipe and GRE is placed as Annexure-VI.
flexible connection Unit has obtained CFE from in place of the APPCB for laying of pipeline for washed out portion marine disposal. Copy of CFE is (till the permanent placed as Annexure-VII. line will be made APPCB has not granted CFO to available). the unit for marine disposal but Page 15 of 39 16 Inspection Report in the matter of OA 175/2020 (SZ) Also additional however unit claims that consent arrangement was fees is paid by the unit for done to take a marine disposal line. However substantial portion committee has clarified that unit of N.ETP treated has to obtain prior consent from effluent to ED wells APPCB for marine disposal.
ETP(old) for disposal for deep Marine disposal pipelines of well injection, and 1000m was broken and washed subsequently to away during 2018 and currently reduce marine only 60m marine disposal disposal quantity pipeline is present against the from New ETP. requirement of 1000m of deep Additional high sea disposal. Unit continues to pressure water dispose around 1200KLD of injection pump was effluent through marine disposal.
installed for this
purpose. Unit has completed laying of
Also additional 1500 m HDPE line with diffuser
Effluent disposal in the sea during February, 2022
wells were and trenching work (post-burial
commissioned after work) by dredger pontoon
WOR for effluent Marine is in progress. The new
disposal (deep well pipeline will be commissioned injection) for during March, 2022. The new capacity expansion. pipeline is at a distance of 150m from the old pipeline. The unit is Unit claims as work laying a new pipeline by under progress deviating the alignment of old pipeline in the CRZ area, Hence it is mandatory that unit has to Page 16 of 39 17 Inspection Report in the matter of OA 175/2020 (SZ) obtain CRZ clearance and CFE from APPCB for laying new pipeline but however unit has not obtained any clearances for laying new pipeline.
Currently, around 1200 KLD of
effluent from new ETP is
disposed through marine
disposal.
During inspection, villagers approached the committee and informed that effluent is discharged outside Kesanapalli GGS into empty land. Committee visited the area and observed that outside the boundary wall of the unit, water stagnation (lagoon/ pond) was present at two locations and villagers informed that it is effluent discharged from the installation. At one location just beside the boundary wall of the unit large quantity of slightly reddish colored water was present. The boundary walls of the unit are weak, cracks & small openings are developed on the wall towards old ETP. Committee collected inlet & outlet samples of old & new ETP, samples from two water stagnation points and beach water (near to disposal line) and analysis results for core parameters are as follows:
Table 3: Old ETP Kesanaplli analysis results Location TSS mg/L O & G mg/L Old ETP inlet Raw Effluent-Kesanapalli 171 BDL(DL:4.0) Old ETP outlet Effluent-Kesanapalli 13 BDL(DL:4.0) APPCB standards for ED well disposal 100 10 Table 4: New ETP Kesanapalli analysis results Sl.No Parameter New ETP inlet New ETP outlet CPCB marine outfall standards 1 pH 7.98 7.08 5.5 -9.0 2 TSS mg/L 53 17 100 Page 17 of 39 18 Inspection Report in the matter of OA 175/2020 (SZ) 3 Zinc mg/L 0.10 BLQ (LOQ:0.005) 2 4 BOD mg/L 3708 44 30 5 COD 15862 172 100 6 Chlorides 8697 9197 600 7 Sulphates 69 43 1000 8 TDS 15675 8411 2100 9 Oil & grease BDL (DL:4.0) BDL (DL:4.0) 10 10 cyanides BDL (DL:0.1) BDL (DL:0.1) 0.2 11 flourides 0.21 0.11 1.5 12 Sulphides BDL (DL:1.0) BDL (DL:1.0) 2.0 13 T. Cr 0.06 BLQ (LOQ:0.005) 1.0 14 Copper 0.07 BLQ (LOQ:0.005) 0.2 15 Lead BLQ (LOQ:0.005) BLQ (LOQ:0.005) 0.1 16 Mercury 0.04 0.01 0.01 17 Nickel BLQ (LOQ:0.005) BLQ (LOQ:0.005) 37 Table 5: Analysis results of wastewater at Kesanapalli Location pH TPH mg/L BOD mg/L COD mg/L TOC mg/L Beach sea water 8.02 3.23 274 427 171 Water stagnation (small) around 8.77 55.6 33 121 45 250m away from industry boundary Kesanapalli Large water stagnation besides 9.01 971.17 89 345 129 the boundary wall of industry towards old ETP - Kesanapalli From the analysis results in Table 5, it is observed that traces of TPH is present in beach sea water and at water stagnation point 250m from industry boundary. TPH of 971.17 mg/L is present in water adjacent to industry boundary which indicates that effluent may be leaking or may be discharged into adjacent land.Page 18 of 39 19
Inspection Report in the matter of OA 175/2020 (SZ) 5 Water logging Area is cleared of Unit has levelled the area to Complying observed at the water logging. prevent water logging.
entrance of the unit Levelling and
cleaning was done.
Now the premise is
properly
maintained.
6 In the ETP area, the After excavation of The committee excavated soil in Complying
unit had covered the area, where ever the ETP area and as well at other
with fresh soil. The oily soil was locations to check for oil
committee excavated observed and which spillages or dumping of sludge the portion of the was removed and on ground. Sediment samples soil and found that transferred to were collected and observed that black oily soil was sludge bed for only traces of TPH is present present below upto bioremediation. which implies that unit has depth of 1m cleaned the area. Results are given in table 6.
7 Opposite to new The said area was Opposite to new ETP boundary Complying ETP boundary wall, allowed to dried up wall, sediment samples were waste oil & sludge is water, where ever collected and TPH in the dumped on land to oily soil was sediment samples is 3.55 mg/kg an extent of two to observed and was which implies that unit has three acres removed and cleaned the area while traces of transferred to oily sludge is present. Unit has sludge bed for initiated plantation in the area.
bioremediation
.After cleaning
properly, initiative
was taken to bring
this area under
green belt (by
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Inspection Report in the matter of OA 175/2020 (SZ) growing greenery) 8 In around 5acres of The area allowed to It was reported by the unit that Complying land opposite to DG dry water and wherever oily sludge was room the effluent & where ever present, it was cleaned by the sludge is contaminated soil unit. Mercury in the soil sample accumulated. From was observed and is below limit of quantification the sediment that portion was sampling it is learnt cleared from the that mercury is area to sludge pit.
present in the range Now greenery is
of 201 mg/Kg visible in the area.
The soil analysis by
HECS, shows
mercury levels
below the
quantifiable limit.
Table 6: Kesanapalli sediment samples and analysis results are as follows:
TPH Iron Mercury Lead Benzene Benzo(a) Phenols Location (mg/Kg) (mg/Kg) (mg/kg) (mg/kg) (mg/kg) pyrene (µg/kg (mg/kg) Kesanapalli large water BLQ BLQ BLQ BLQ BLQ stagnation 6.52 966.23 (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1) outside unit Premises kesanapalli BLQ BLQ BLQ BLQ BLQ beach sludge-5.89 2494.66 (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1) kesanapalli Page 20 of 39 21 Inspection Report in the matter of OA 175/2020 (SZ) (sludge) behind transfer pump- BLQ BLQ BLQ BLQ BLQ 93.53 2519.68 kesanapalli (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1) (sludge) behind ows -
BLQ BLQ BLQ BLQ BLQ
kesanapalli 55.60 1223.52
(LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1)
(sludgel)
sediment sample
behind old ETP
BLQ BLQ BLQ BLQ BLQ
dmf feed sump-319.19 1894.93
(LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1)
kesanapalli
(sludge)
sediment sample
in front of new
etp control BLQ BLQ BLQ BLQ BLQ
3.55 1329.06
building - (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1)
kesanapalli
(sludge)
Analysis results indicates that small quantity of spills/ leaks is present behind old ETP feed sump.
9 CFO validity Kesanapalli GGS has obtained Complying Consent under the Water Act, 1974, the Air Act, 1981 and Hazardous Waste authorization valid till 31.07.2023. Copy of CFO is placed as Annexure-VIII Page 21 of 39 22 Inspection Report in the matter of OA 175/2020 (SZ) Photo 10: water stagnation outside the unit Photo 11: water stagnation outside the premises (small pond) industry slightly reddish in color (large pond) Photo 12: New ETP at Kesanapalli Photo13: new ETP treated effluent storage tank Photo14 : Effluent disposal on the shore through Photo15: laying of new pipeline existing pipeline of 60m Page 22 of 39 23 Inspection Report in the matter of OA 175/2020 (SZ) Photo 16: old ETP area Photo 17: Sludge tanks V.b Environmental compensation to be levied from Kesanapalli GGS EC for EC=PI x N x R x S x LF violation of Where, CFO EC = Environmental Compensation in INR conditions, sea PI = Pollution Index of industrial sector (red-80) disposal N = Number of days of violation took place (from the date without of violation observed to date of compliance- 379 days obtaining committee had calculated compensation till 25.02.2021 and committee permission re- inspected during 08-03-2022 to 11-03-2022 and observed following from APPCB non- compliances Page 23 of 39 Old ETP was not properly operated Unit is generating more than consented quantity of effluent 24 Inspection Report in the matter of OA 175/2020 (SZ) Oily sludge is stored in open in sludge tank for more than five years Unit is disposing effluent through marine outfall against the consented mode of ED well disposal Marine outfall pipeline is broken and effluent is disposed with pipeline of 60m.
R = A factor in Rupees for EC (Rs. 250/-) S = Factor for scale of operation (large-1.5) LF = Location factor 1 =80*379*250*1.5*1* repeated violation factor of 2 =Rs. 2,27,40,000/-
Rupees Two crore twenty-seven lacs forty thousand only Considering serious nature of violation, committee has assessed EC for repeated violation VI. Compliance Verification of Odalarevu GCS Sl. Non-compliances Compliance status Current status of compliance Remarks No observed by submitted by the as verified by the committee committee during unit and first visit Upgradations/ Modifications made by the unit 1 The ETP is not Unit has improved ETP was in operation. ETP is Not functioning housekeeping and designed to treat 160 m3/day of Complying properly. Oil is maintenance (26 m3 /day of producer water w.r.t ED well removed from slop activities. with inlet TSS of 500 ppm and disposal limit oil tank and then Unit has replaced oil & grease of 500 ppm and 134 for oil & effluent is stored in corroded valves, m3/ day of storm water). grease holding ponds. serviced pumps & Committee collected samples of Multimedia filters pipelines, producer water (inlet of ETP) Page 24 of 39 25 Inspection Report in the matter of OA 175/2020 (SZ) were not in installation of new and treated effluent (outlet of operation on the day diaphragm pump, ETP) and from storm water of the visit. Effluent replacement of drain. It is found that treated is disposed on the media of multi- effluent is not meeting with ED ground without media filters. well discharge standards w.r.t oil treatment. ETP is & grease. Flow meters are not properly Unit is producing installed at inlet and outlet of working since 2017 18-30 m3/day of ETP. TPH is present in drain and the unit is yet to effluent which is sample in traces which implies replace worn out processed in 3-5 that effluent is not discharged pumps hours and injected into drain. Results are given as into effluent disposal follows:
wells.
The ETP is
operational and
functioning properly
and operated in
batches depending
upon load to ETP.
Unit claims as
Complying
Table 7: Odalarevu raw and treated effluent analysis results Oil and Grease TPH Location pH TSS (mg/L) (mg/L) (mg/L) Storm water drain beside Security 1.48 8.01 11.6 22 Gate at Vashishta gate - Odaleruvu ETP inlet - Odaleruvu 6.47 116 52 NA ETP outlet - Odaleruvu 5.87 8 14 NA APPCB ED well disposal limits 100 10 Page 25 of 39 26 Inspection Report in the matter of OA 175/2020 (SZ)
2 Severe odour Oil in the CRWS No odour nuisance sensed by the Complying nuisance and VOC tank and other committee members. VOC was levels inside unit operational area pits measured using handheld PID premises was have been processed analyser and value was 0ppm.
varying from and being
4.0ppm to 6.0ppm maintained regularly
when measured within limits so that
using handheld PID VOC and odour
(photo ionic nuisance is not
detector) analyzer available in the
premises anymore.
3 During the visit, Unit claims that Since there was no rains, there Partially
there were rains and MEG barrels were was no water logging. Unit has complying
water logging was placed near the not taken any measures for the
observed in the area. referred lagoon cleanup of the area. Black oily
Both Effluent mixed having an area of sludge is still present in the area.
with storm water 1.25 acres (not 10 Top layer of soil is not fully
was present in the Acres) during removed and only in certain
unlined lagoon in construction areas top 10cm of soil is
more than 10acres of activities. removed however bund is not
land between M/s Unintended and constructed. Committee
GAIL and M/s inadvertent leakage collected three sediment samples
ONGC terminals. of one of the barrel at different at various points
The pH of the of MEG in the area where ONGC pipelines are
lagoon water was might have resulted passing and from sediment
around 5 into low pH value in analysis results, it implies that
the sample. The the it contains total petroleum
same has been hydrocarbons in the range of 297
rectified. mg/kg to 421 mg/Kg. No other
Top layer of soil has heavy metals is present. The been recovered and summary of the results is as Page 26 of 39 27 Inspection Report in the matter of OA 175/2020 (SZ) shall be processed follows:
for bio
remediation/Transfer
to TSDF for landfill
depending upon
sample analysis.
After removal of the
top layer of soil, the
area will be properly
protected with bund
and rain water shall
be stored in the
pond.
Unit claims as
Complying
Table 8: Odalarevu Sediment sample analysis results Location Total Benzo(a) Iron Mercury Benzene Phenols TPH Lead (mg/kg) pyrene (mg/kg) (mg/kg) (mg/kg) (mg/kg) mg/Kg (µg/kg Beside security gate BLQ BLQ BLQ BLQ BLQ at vashishta gate- 693.54 1441.86 (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1) odaleruvu (soil) Area between GAIL BLQ BLQ BLQ BLQ BLQ and ONGC-odalerevu 297.17 31.35 (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1) (soil) Lagoon Area between BLQ BLQ BLQ BLQ BLQ GAIL and ONGC- 335.57 153.73 (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1) odalerevu (soil) lagoon between GAIL and ONGC BLQ BLQ BLQ BLQ 421.74 846.43 2.28 near watch tower- (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1) odalarevu (soil) ETP beside settling BLQ BLQ BLQ BLQ BLQ 10019.79 1553.94 tank -odalarevu (soil) (LOQ:2.0) (LOQ:2.0) (LOQ:20) (LOQ:20) (LOQ:0.1) Page 27 of 39 28 Inspection Report in the matter of OA 175/2020 (SZ) Analysis results indicate the presence of TPH in the range of 297 mg/Kg to 10019 mg/Kg. Unit has to take measures to prevent oil spillages/ leakages and to clean the existing spills.
4 The storm water The storm water Storm water drains are cleaned Complying drains are drains are being and reported that the oily sludge completely clogged cleaned periodically and silt removed from drains was and was filled with in phase wise transferred to sludge tank but thick oily sludge. manner to remove however the records on how the vegetation. much quantity of sludge was removed from drains is not made available to committee. Drains were dry and no effluent was transferred through drains.
5 CFO validity Unit has applied for consent and renewal is awaited. Consent fees is paid.
VI.a Environmental compensation to be levied from Odalarevu GCS EC for EC=PI x N x R x S x LF violation Where, EC = Environmental Compensation in INR PI = Pollution Index of industrial sector (red-80) N = Number of days of violation took place (from the date of violation observed to date of compliance- 379 days committee had calculated compensation till 25.02.2021 and committee re- inspected during 08-03-2022 to 11-03-2022 and observed following non- compliances treated effluent not complying with ED well disposal limits oily sludge is laying beside settling tank in the ETP area R = A factor in Rupees for EC (Rs. 250/-) S = Factor for scale of operation (large-1.5) Page 28 of 39 29 Inspection Report in the matter of OA 175/2020 (SZ) LF = Location factor 1 =80*379*250*1.5*1 =Rs. 1,13,70,000 Rupees One Crore thirteen lacs seventy thousand only Considering unit has made improvements and unit is complying with effluent discharge standards committee has not assessed repeated violation factor VII Compliance verification of Gopavaram GGS Sl. Non-compliances Compliance status Current status of compliance Remarks No observed by submitted by the as verified by the committee committee during unit and first visit Upgradations/ Modifications made by the unit 1 Unit is generating Unit is in the process As per the CFO issued by Not 1800 KLD of of upgrading ETP APPCB, quantity of effluent is 6 Complying effluent but the and augmenting the KLD but actual effluent capacity of ETP is capacity. generation varies from 1500 600 KL Unit claims as work KLD to 1800 KLD. ETP is under progress having capacity to treat 600 KLD of effluent and both treated & untreated effluent is discharged into ED (effluent disposal) wells. Committee collected samples from inlet (producer water) and outlet of ETP, storm water drain at north-
east corner and from unlined lagoon. From the analysis results it is found that effluent is getting Page 29 of 39 30 Inspection Report in the matter of OA 175/2020 (SZ) mixed with storm water.
Untreated Effluent is discharged into ED wells. Storm water drains are filled with oily sludge.
Oil contaminated wastewater is stored in unlined lagoon in the premises. Land in the premises is observed to be contaminated at several places indicating discharge of untreated oil bearing effluents on open land.
Hazardous waste is stocked in a concrete tank without disposal since commission of the premises. Treated effluent is complying with discharge limits.
Copy of CFO is enclosed as Annexure-IX Table 9: Gopavaram raw and treated effluent analysis results Oil and Grease TPH Location pH TSS (mg/L) (mg/L) (mg/L) ETP Inlet - Gopavaram 7.58 29 BDL(DL:4.0) NA ETP Outlet- Gopavaram 7.66 11 BDL(DL:4.0) NA Storm water drain North east corner- 731.78 8.07 6 BDL(DL:4.0) Gopavaram Storm water collected from unlined 185.53 7.50 71 BDL(DL:4.0) lagoons in Gopavaram Page 30 of 39 31 Inspection Report in the matter of OA 175/2020 (SZ) Photo 18: Effluent treatment area Photo 19: effluent stagnation Page 31 of 39 32 Inspection Report in the matter of OA 175/2020 (SZ) Photo 20: oily sludge dumped on the ground VII.a Environmental compensation to be levied from Gopavaram GGS EC for EC=PI x N x R x S x LF violation Where, EC = Environmental Compensation in INR PI = Pollution Index of industrial sector (red-80) N = Number of days of violation took place (from the date of violation observed to date of compliance- 379 days committee had calculated compensation till 25.02.2021 and committee re- inspected during 08-03-2022 to 11-03-2022 and observed following non- compliances oily sludge is laying beside settling tank in the ETP area untreated effluent is discharged through storm water drains Sediment contains high concentration of sludge indicating dumping of oily sludge R = A factor in Rupees for EC (Rs. 250/-) S = Factor for scale of operation (large-1.5) LF = Location factor 1 =80*379*250*1.5*1 =Rs. 1,13,70,000 Rupees One Crore thirteen lacs seventy thousand only Page 32 of 39 33 Inspection Report in the matter of OA 175/2020 (SZ) VIII Utilization of CSR funds by M/s ONGC in Rajahmundry and Kakinada assets ONGC has devised framework for utilization of CSR funds. Though the installations at Kakinada asset and Rajahmundry asset are currently operating under loss but however the overall profit made by M/s ONGC nationwide is considered for CSR fund utilization. Reported that 5% of theoverall profit made by M/s ONGC is utilized for CSR activities and the total profit is dividedamong all installations. Based on the CSR proposals received by various modes such as through District Collector, NGO's, Public representatives etc are compiled and approval is obtained through their key executive/ corporate head. Kakinada asset & Rajahmundry asset prepare a CSRplan based on the proposals received and on the allocated amount to each installation. Both Rajahmundry and Kakinada asset are having a CSR co-ordinator for implementation of CSR activities.
The CSR proposals received from various domain are first examined by the CSR co-ordinator by way of field visit or verifying the DPR etc and after examining the proposals it is put up to an internal screening committee and then to virtual corporate committee. These committee further examine and recommend the activities after which approval is obtained. Based on the proposal received CSR activity is implemented and then it is monitored by either CSR co-ordinator or project monitoring team. Post implementation & monitoring, documents are obtained such as utilization certificates etc and activity is completed.
For ground trothing purposes, committee verified the CSR records for last five years (2017 onwards) and also visited areas where activities are implemented such as installation of water tanks, providing cycle stand for school children etc. Committee interacted school Principle, Tehsildar and it was reported that CSR activities are taken up the units.
Four village heads met the committee and requested the committee to direct M/s ONGC to release more amount to the villages where the wells are located rather than spending the amount in diverse manner and in other villages. Committee clarified the Village heads that committee is verifying as to whether CSR funds are properly utilised or not. M/s ONGC Rajahmundry asset has spent around Rs. 21.04 crores on CSR activities during 2018-19, Rs. 23.05 crores during Page 33 of 39 34 Inspection Report in the matter of OA 175/2020 (SZ) 2019-20 and Rs. 8.08 crores during 2020-21 respectively. Reported that during 2020-21, M/s ONGC has contributed to PM cares fund and hence hence there is a decline in amount spent on CSR activity in the region.
The committee interacted with the applicant and objections were raised on installation of two Water ATM's in Antharvedi Devasthanam and nearby village. Committee visited both the water ATM's and discussed with the M/s ONGC team. Based on the proposals received, M/s ONGC has proposed to two install water ATM's. Water ATM's are water treatment machines (basically RO system) which either draw surface or ground water treat the water and clean water is provided through tap. Each villager was given a card and on inserting the card, each villager gets around 20 liters of water per day. M/s ONGC has implemented the project on the condition that M/s ONGC will only bear the capital expenditure (only the cost of water ATM machine) and one year AMC and subsequently the village has to maintain the water ATM. The land required for installing ATM was identified by the villagers, electricity was provided by village/ temple authorities. After lapse of one year the expenditure towards O &M cost/ AMC cost of the water ATM had to borne by the village. Reported that water ATM installed at Antharvedi Devasthanam was operational for one year and afterwards no one has taken responsibility and currently it is not operational. While the water ATM in the village is not put to use. During committee visit, both the water ATM's were not in operation.
The process flow followed by M/s ONGC for CSR is given in the below image. Further two case studies are given as Annexure-X. Page 34 of 39 35 Inspection Report in the matter of OA 175/2020 (SZ) Image: Process flow followed for CSR projects at ONGC Page 35 of 39 36 Inspection Report in the matter of OA 175/2020 (SZ) Image: CSR abstract of Rajahmundry asset from 2018- 2021 IX Conclusions and Recommendations Hon'ble NGT vide order dated 19.01.2022 directed the committee to inspect the units and verify the compliance status of the units. Committee observed that as compared to previous visit, there are improvements but units are yet to achieve compliance and few serious & significant violations were observed by the committee.
Page 36 of 39 37Inspection Report in the matter of OA 175/2020 (SZ) i. Currently, Tatipaka GCS is operating the ETP and unit is testing the quality of treated effluent as to whether it is meeting the discharge standards or not and after ensuring that unit complies with discharge limits, treated effluent is discharged through ED wells. Unit has maintained records on the quantity of effluent generated, characteristics of effluent at inlet & outlet of ETP and quantity of effluent disposed through ED well. However unit has not taken adequate measures in handling the oily sludge, slop oil and washings. Spillages or oil deposition near the ETP area is not fully cleaned. Effluent oily sludge stored in the old ETP shall be treated and old ETP shall be dismantled. Sludge stored in the sludge tank shall be disposed. Unit shall ensure that it will comply with Hazardous Waste Management Rules, 2016 and dispose the hazardous waste within 90 days fromthe date of generation.
ii. Kesanapalli ETP is handling around 1800 KLD of effluent against the consented quantity of 600 KLD and is having two ETP's. Old ETP was not properly operated however treated effluent is meeting the discharge limits for ED well disposal. New ETP is handling 1500 KLD of effluent and treated effluent is disposed in the sea with existing marine outfall pipeline of 60m against consent condition of ED well disposal. Outside the unit premises water stagnation was observed and TPH (Total Petroleum Hydrcarbons) is around 971.17 mg/L which indicates that effluent may be leaking/ discharged outside the unit premises or runoff from old ETP area has stagnated outside the unit premises. Sediment samples collected around old ETP contains TPH of 319mg/Kg indicating mixing of spillages on the ground. Unit shall ensure that ETP is properly operated, effluent is disposed as the per conditions stipulated in CFO and ensure that no effluent is discharged outside the unit premises. Sludge shall be properly managed and prevent the spillages. Kesanapalli GGS shall immediately stop disposal of treated effluent by marine outfall near the coast and dispose the treated effluent as per the conditions stipulated in CFO issued by APPCB iii. Laying of new pipe line in CRZ area by Kesanapalli GGS does not have prior CRZ clearance from Ministry and Consent approvals from APPCB. Kesanapalli GGS shall Page 37 of 39 immediately approach concerned authorities for obtain prior permissions for the new pipeline.
iv. Effluent generation is around 1800 KLD and ETP at Gopavaram is having capacity to handle 600 KLD of effluent. Hence untreated effluent is discharged outside the unit premises. Water present in the storm water drain and in unlined lagoon contained TPH of 731.78 mg/L and 185.53 mg/L indicating the presence crude oil/ effluent in the sample. Sediment samples collected from Gopavaram GGS contains high concentration of TPH in the range of 644.07 mg/Kg to 30,698 mg/Kg which indicates that oily sludge is dumped on the ground. Since unit is not having ETP of adequate capacity, untreated effluent is discharged through ED wells. Unit shall take measures to augment the treatment capacity and ensure that only treated effluent is discharged through ED wells. Till the ETP capacity is enhanced, unit shall restrict its production so that quantity of effluent generation is proportionate with ETP capacity.
v. Whenever any oil spills/ leakages takes place within the unit premises or whenever sludge is carried with runoff, unit is covering it with fresh soil and not taking measures to clean up. Units shall ensure that during any untoward incidences of oil spill/ leakages, unit shall take measures to remove the entire quantity of spills/ leaks and scrap the underlying soil and store it in sludge tank and dispose the same along with oily sludge.
vi. During rains, the first flush of rains is likely to carry the pollutants into adjacent area and it is essential for the industry to have facility to lift the first flush of rain water and treat the same in effluent treatment plant.
vii. During previous committee visit it was observed that thick oily sludge was present in the storm water drains. Currently all the units have cleaned the drains and they were in dry condition. Units have also devised plan for periodical cleaning of drains. However units have not maintained records on the quantity of sludge removed from drains and 38 mode of disposal of the silt/ sludge. Unit will take measures to install oil catchers in the drains located near process area & ETP. Based on the characteristics of the silt/ sludge present in the drains, units will safely dispose the same.
viii. There was no odour nuisance during this visit and ambient air quality in the installations and in the villages is meeting the National Ambient Air Quality Standards. Committee observed huge flames from flare stack at Tatipaka GCS. Units have not maintained proper records on the volume of the gas handled in the flare stack. It was reported that unit has already proposed to install new flare stack at Tatipaka and Kesanapalli. Unit may submit time bound action plan for replacement of flare stacks.
ix. The unit has obtained consent from APPCB during 2015 and subsequently the consent is renewed (online consent monitoring and management system) but however post 2015 due to ageing of wells the quantity of produce water is increasing and there by the quantity of effluent generated is also increased. The actual quantity of effluent generated is higher than the quantities stipulated in the CFO. All the stacks installed in the installations are not covered under the purview of the Consent order. For instance stack installed at TEG unit is not included in the consent order. M/s ONGC shall ensure that every installation obtains Consent For Operation from APPCB under the Water Act, 1974 and Air Act, 1981 for the actual quantity of products manufactured, actual quantity of wastewater received and include all the stacks installed in the unit.
x. Committee observed that M/s ONGC are utilizing the CSR funds for environmental & social development activities and other essential activities identified by the District Magistrate/ Corporate Head office/ Public representatives/ registered NGO's.
39xi. The units shall pay Environmental compensation to CPCB as follows:
Name of the EC amount assessed EC amount assessed Total EC amount in installation during first visit of during second visit INR to be paid to the committee CPCB Tatipaka GCS Rs. 7,28,62,500/- Rs. 1,13,70,000/- Rs. 8,42,32,500/- Kesanapalli GGS Rs. 4,11,00,000/- Rs.2,27,40,000/- Rs.6,38,40,000/- Odalarevu GCS Rs. 5,68,50,000/- Rs. 1,13,70,000/- Rs.6,82,20,000/- Gopavaram GGS - Rs. 1,13,70,000/- Rs. 1,13,70,000/- Total Environmental Compensation to be paid by M/s ONGC to CPCB 22,76,62,500/-
is Rs. Twenty Two crores Seventy Six lacs Sixty Two Thousand and Five hundred only xii. The units shall implement the corrective actions, shall submit time bound action plan for disposal of sludge. Unit shall ensure that hazardous waste are disposed within 90 days from date of generation as per the conditions stipulated in the Hazardous Waste Authorization. Unit shall submit time bound action plan for removal of oily sludge deposited in the soil at Gopavaram, Kesanapalli and at Tatipaka. APPCB shall monitor that the oily sludge is disposed as per action plan.
Scientist-D, Ministry of Environment Forest andClimate Change, Regional Office, Dr.Vijayawada Suresh B Pasupuleti 40 P. Ravindranath Senior Environmental Engineer Andhra Pradesh Pollution Control BoardZonal Office, Visakhapatnam Prof. M. Deepa Dept of Chemical Engineering, A.U College of Engineering (A) Andhra University, Visakhapatnam Mahima TScientist-D Central Pollution Control BoardRegional Directorate, Chennai 41 42 43 44 45