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[Cites 5, Cited by 0]

National Green Tribunal

Rajasekar Shambu vs The Chairman Karnataka State Pollution ... on 9 May, 2022

Bench: K Ramakrishnan, K. Satyagopal

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                                                                                              3


                JOINT INSPECTION REPORT



Name of the Industry Inspected:    M/S Syntho Chirals Private Limited, Kolhar Industrial
Area, Bidar.

Name of the Inspecting Officers:

1.   Shri S Madhusudhan Senior Environmental Officer, Zonal Office Kalburgi
2.   Shri Gopalkrishna B Sanatangi Environmental Officer KSPCB Bidar.

     Reference: The Board direction issued vide memo dated: 05.04.2022

     Date of Inspection                   12.04.2022, and monitoring      carried on
                                          11.04.2022

     Consent status                       Water Act 1974          Air Act 1981

                                          AW-313104                AW-313104
                                          30.06.2023               30.06.2023

     Products manufactured                As per CFO               Actual Manufactured

                                           Sr | Product Name           Sr | Product Name
                                           1 | Acylovir                1 | Acylovir
                                           2 Alendronate               2 Alendronate
                                                Sodium                      Sodium
                                                betamethasone               betamethasone
                                           3      :     ;              3      :     :
                                                Di-propinate                Di-propinate
                                                 Betamethasone              Betamethasone
                                           4 | Sodium                  4 | Sodium
                                                 Phosphate                  Phosphate
                                           5     Betamethasone       6      Betamethasone
                                                 Valerate           .       Valerate
                                           6     clerrythomycin       6     clerrythomycin
                                                 tests only                 tests only
                                               Clobetasol                  Clobetasol
                                           7 | Nate-17-                7 | Nate-17-
                                               Propinate                   Propinate
                                               Dexamethasone               Dexamethasone
                                           8 | Sodium                  8 | Sodium
                                                 Phosphate                  Phosphate
                                           9 |   Irate Canozole        9 | Irate Canozole
                                            10 | Ketacenazole          10 | Ketacenazole
                                            11 | P-Panthenol           11 | P-Panthenol
                                            12 | phenylene             12 | phenylene




                                  Page 56 of 110
                                                                                                                  4


                                                                       propane amino            propane amino
                                                                       hypo chloride-           hypo chloride-
                                                                       salts only               salts only
                                                                 13    Pyrazine            B    Pyrazine
                                                                      Amide                     Amide
                                                                      Triazole                  Triazole
                                                                 ue Mesylate               4 Mesylate
                                                                      triazole                  triazole
er




                                                               | 15 | piperzine-test       15 | piperzine-test
OC




                                                                      scale only                scale only
ET OORT et




                       HWM Status                              Valid upto 30/06/2023
e
eee ee




             WATER POLLUTION CONTROL                  STATUS

                    Source of water:       Open Well
              SS




                    Quantity of water consumption as per Consent: 7 KLD
                    Actual water consumed for different purposes: 7 KLD
              ee




                    Quantity of effluent generation from different sources as per CFO;

                    Sources of generation        Quantity                    Mode of treatment and disposal
                    Domestic                     3

                   Process                       Z                          Feed tank to MEE system and
                                                                            MEE system followed by
                                                                            agitator thin film drier (ATFD)
                   Washings                                                 Feed tank to MEE system and
                                                                            MEE system followed by
                                                                            agitator thin film drier (ATFD)
                   Boiler blow down                                         MEE
                   RO Rejects                                               MEE




                                                     Page 57 of 110
           Tt NSPE ED

                                                                                                                                                 5
        RS EBT




                                              5.       Details of effluent treatment plant
       EEE




                                                           STP units
                                                   f
                                                       b. MEE          20 KLD
                                                       c. Condensate treatment plant
                                                       d . Closed loop system for solvents and raw material handling.
        Ostet     EE Se tae ae ee Eee eS Ty




                                                   AIR POLLUTION CONTROL                       STATUS

                                                       Slno_       | Air Pollution source      Air pollution   Chimney          _   Monitoring
                                                                                               control         height above' | facility
GH EAL Ringe RetANC




                                                                                               equipment       ground level
                                                                                               provided
                                                       1             Process emissions         Scrubbers       15 feet above        provided
                                                                     from GLR, No of                           roof level
                                                                     GLRs
                                                   2                 MEE
                                                   S                 ATFD                      Condenser       NA                   NA
                                                   4                 Boiler with capacity      1.5 Ton         90 feet              Provided
                                                   :                 D G sets with capacity | 250              15 feet



                                                   SOLID WASTE MANAGEMENT                                                     At
                                                   1. HAZARDOUS WASTE

                                                               SL.NO | SOURCE OF                    QUANTITY     MODE OF             PRESENT
                                                                       GENERATION                   OF           STORAGE             STOCK IN
                                                                                                    GENERATION | AND                 THE
                                                                                                    PER DAY      DISPOSAL            STORAGE
                                                                                                                                     YARD
                                                               1        Process residue             30 KG        Packed in           1000 Kgs
                                                                                                                 double lined
                                                                                                                 Poly bags &
                                                                                                                 Stored at
                                                                                                                 Designated
                                                                                                                 area and
                                                                                                                 disposed to
                                                                                                                 Authorised
                                                                                                                 TSDF
                                                           2            Activated carbon         2Kg             Packed in
                                                                        sludge                                   double lined




                                                                                            Page 58 of 110
                                                                                                                                                             6
                                                                                                                                     Mt'

                                                                                                                    Poly bags &
                                                                                                                    Stored at
                                        beta rg © CORREA TE SEN




                                                                                                                    Designated
                                                                                                                    area
                                                                       3     MEE   salts          200 KG            Packed in                    2000 Kgs
 Ee ENT tote Sakeinente aoe Sopatie scutes




                                                                                                                    double lined
                                                                                                                    Poly bags &
                                                                                                                    Stored at
                                                                                                                    Designated
                                                                                                                    area and
                                                                                                                    disposed to
                                                                                                                    Authorised
                                                                                                                    TSDF
ae eee eae ent Te re Te BN ES ee eed ee EOE SN LTE Oe TCE




                                                                       4     DISCARDED            10 numbers per    Handed over
                                                                             CONTAINERS           month             to authorized
                                                                                                                    recycler

                                                                  . OTHER WASTE

                                                                       SL.NO | SOURCE OF          QUANTITY         MODE OF                 PRESENT
                                                                               GENERATION             OF           STORAGE                 STOCK IN
                                                                                                 GENERATION        AND                     THE
                                                                                                   PER DAY         DISPOSAL                STORAGE
                                                                                                                                           YARD
                                                                       1      DOMESTIC
Oe earte ce Cs ee ae eee ae Pee
                            eee




                                                                   2          OFFICE               10 Kgs Per      Disposed to
                                                                              STATIONARIES           Month         Waste paper
                                                                                                                   Vendor
                                                                                                                                     xT
                                                                   3          E WASTE                                            ~"t
  BE oe




                                                                   4          BOILER ASH         30 -- 40 Kgs per   Stored in               1 Ton
                                                                                                       Day         Ash Shed
                                                                                                                   and
                                                                                                                   disposed to
                                                                                                                   Brick
                                                                                                                   Manufacture
                                                                   5          SCRAPS IRON                                                  Nil
                                                                              AND STEEL




                                                                                                                                "A




                                                                                            Page 59 of 110
                                                                                       7




COMPLIANCE TO THE OBSERVATIONS OF THE JOINT COMMITTEE
VISIT DATED 27.11.2019

SIN | Observations | Compliance
Oo
 }     The Unit has | They are having valid consent and Hazardous Waste
       displayed the | Authorization and also displayed at the entrance of the main
       Consent and     gate.
       Hazardous        »
      waste                                                          'Prt Ltd,
       authorization                                ee
                                                     i cin
       conditions at
       the entrance of
       the Unit, as
       per the
       direction of
       the Hon'ble
       Supreme
       Court Order in
       W.P No (C)
       657/1995.
       The unit has      Authorization No: 322967
       valid consent     Valid up to 30/06/2023
       and Hazardous
       waste
       authorization.

       The source of     They have provided the water flow meter at open Well
       water supply
       is Own open       Obtained NOC From the Karnataka Ground Water Authority.
       well and not      Attached
       installed flow
       meter and
       water
       consumption
       record is not
       available. The
       unit has not
       obtained NOC
       from the
       Karnataka
       Ground Water
       Authority
       (KGWA) for




                               Page 60 of 110
                                                                                    8




usage of
Ground water
for industry
use.




                  inccuracy. 5 1m
                  "Time: 12-04-2022 15:18
                  = 3          Chirels open

The raw           As Civil repair and maintenance work was going in warehouse
materials are     They have stored the goods in shed with proper precaution as
stored in shed.   per the norms of PCB.
The closed        They don't have closed system for Solvent Handling
loop system
for solvent
handling is
under
commissionin
g..

During            During the inspection it was noticed that, the plant was under
inspection        operation.
there was no
production and
informed that
the plant was
under
maintenance
shut down.

The unit has      They have installed Flow meter and cameras to MEE and also
installed flow    installed the OCEMS and same Connected to CPCB/KSPCB on
meter and         11.12.2019
camera to
MEE, but
OCEMS is not
yet connected
to
CPCB/KSPCB




                                 Page 61 of 110
                                                            9




The unit has     They are maintaining the records of the
20 KLD ETP,      MEE.
the low TDS
and High TDS
effluent are
combined
treated with
neutralization
followed by
Multiple
Effect
Evaporator
(MEE) and
Agitated thin
Film Drier
(ATED). The
salt generated
is disposed to
common
TSDF. The
MEE
Condensate is
used as Boiler
feed. The Unit
informed that
MEE is not
operated
continuously
and only four
times ina
month. There
is need to
maintain flow
records. Since
the plant is
under
maintenance
shutdown, the
committee
could not
carryout
sampling to
assess the




                        Page 62 of 110
                                                                                          10




     performance
     of MEE.


     The unit           They have replaced the Loose pipe lines with permanent Lines
     transfers the                                                  ue cp wf

     effluent from
     collection tank
     to the MEE by
     the loose pipe
     lines, need to
     be replaced
     with
     permanent
     line.

     The Unit has       Reactors are not in operation as Production Block is under
     erected the        construction the Reactors are kept under Safe condition as per
     process reactor
     adjacent to the
     MEE, the
     same need to
     be removed
     and shifted to
     other place.



                        Elevat           , ae

                        fe             aS                      mi
                          CCU!         om



10   The unit has       They are disposing the residues to TSDF.
     stored off         They have Constructed Separate Block for the storage of H.W
     specification      with spillage collection Pits
     products/proce
     ss residues etc.
     in large
     quantity, the
     unit shall
     dispose the
     same as per
     the HWM
     Authorization
     immediately.
     The unit needs
     to develop            esis   rag Sicatsiaieaicitiotits,




                                         Page 63 of 110
                                                                                                  11




            adequate
            storage area of
            HW with
            spillage
            collection pits.

    11      The unit is not    They have taken over    the sick unit and improvements is under
            having storm       progress.
            water
            management
            system,
            collection and
            treatment of
            the same.

    12       There is an       The sample of well water is collected for analysis. Report is
             existing open     awaited.
            well in the
            plant
            premises, open
            well sample
            was collected
             for analysis
             (GW6), the
             analysis
             results are
             discussed at
             section 5 iii.
             The well water
             was not
             conforming
             w.r.t COD,
             Total
             Hardness and
             Ammonia.




MONITORING

    The   sample of condensate of MEE is collected for analysis..
    The   sample of open well/tube well collected for analysis.
i




    The   sample of ambient air quality is conducted.
    The   emissions from scrubber outlet are collected for testing acid mist concentration.




                                      Page 64 of 110
                                                                                                                12


The above    samples are submitted to KSPCB          Laboratory   for analysis purpose.     The report is
awaited.

Apart from the above, the following important observations were made:

a.   There is no discharge/bypass of effluent to outside the premises.
b.   The said unit has adopted Zero Liquid discharge facility.
c.   The Non compliances observed during the Joint committee visit on 26/11/2019 has been
     complied with except that_the Industry has not adopted treatment for condensate before
     using for cooling tower, not provided storm water management               and closed loop system
     for solvent handling.


The Industry authorities have sought time of 3 months             (three months) to adopt treatment
for condensate,     to provide   storm   water   management   measures    and   closed   loop   system   for
solvent handling.




        ENVIRON
        KSPCB, BIDAR


                  Oan--
        SENIOR ENVIRONMENTAL OFFICER
        KSPCB, ZONAL OFFICE, KALABURGI




                                          Page 65 of 110
                                                                                                                                13


                                                                  JOINT INSPECTION REPORT
VERE TIS Or Td ap TITTY




                                       Name of the Industry Inspected: M/S Suryakala Laboratories Pvt Ltd, Kolhar Industrial
                                       Area Bidar                                                               a
FEIT TS




                                       Name of the Inspecting Officers:
TEE




                                        1.   Shri S Madhusudhan Senior Environmental Officer, Zonal Office Kalburgi
ee Re




                                       2.    Shri Gopalkrishna B Sanatangi Environmental Officer KSPCB Bidar.
Tr 8 et aaa aie a ee ee ee




                                             Reference: The Board direction issued vide memo dated: 05.04.2022

                                             Date of Inspection                   07.04.2022, 13.04.2022
                                                                                  monitoring on 12.04.2022
                                             Consent status                      Water Act 1974 | Air Act 1981

                                                                                 AW-104346           AW-104346
                   :                                                             30/06/2022          30/06/2022
                   .                         Products manufactured               As per CFO          Actual Manufactured
                                                                                 CFO copy              We are manufacturing
                                                                                 enclosed in            products as per CFO.
                                                                                 Annexure-1
                                             HWM    Status                '      30/06/2021. Applied for Renewal / process.


                             WATER POLLUTION CONTROL                   STATUS

                                1.    Source of water:
                               2.     Quantity of water consumption as per Consent:
                               3.     Actual water consumed for different purposes:
                               4.     Quantity of effluent generation from different sources as per CFO;

                                      Sources of generation          Quantity                       Mode of treatment and
                                                                                                    disposal
                                      Domestic                        4KLD                          SEPTIC TANK
                                      Process                         29 KLD                       MEE
                                     Washings                         1 KLD                        MEE
                                     Boiler blow down                 1 KLD                        MEE




                                                                                                           ae



                                                                      Page 66 of 110
                                                                                                                                                            14


                                                       RO Rejects                         1 KLD                              MEE

                                                       If any others                      1KLD                               MEE


                                              5.       Details of effluent treatment plant
                                                       a.   STP units                        :     4 KLD
             hy




                                                       b.   MEE                              : 30KLD
            RNS IN eer




                                                       c.   Condensate treatment plan         : Not provided. The condensate is directly used for
                                                            cooling tower                                                            Mt
                       Rptans RISE fo, Fa
           SR as tere REE




                                            AIR POLLUTION CONTROL                     STATUS


                                  é                Sl.no       | Air Pollution source            Air pollution      Chimney                 Monitoring
                                  i
                                e                                                                control            height above            facility
                                i
                                                                                                 equipment          ground level
                                                                                                 provided
                                                       1          Process emissions           11 NO's GIRs          3- stage                Circulation
                                                                  from GLR, No of            available              scrubbing               of lye water
                                                                  GLRs                                              system                  and
                                                                                                                    provided with         | monitoring
                    ta See




                                                                                                                    blower height: | the PH of
     PUREE a wane eee




                                                                                                                    60 ft.           the
                                                                                                                                -    scrubber
                                                                                                                                            solution
                                                   2              MEE                            Scrubber          NA                       NA
                                                   3              ATFD                           24 kid capacity | Chimney                  Proposed
                       hes ns eke ee




                                                                                                 ATFD is           height is 40 ft. | port hole
Stat AG UdeS whee ere fee




                                                                                             provided.   with condenser
                                                   -              Boiler with capacity       4Ton&2Ton | Chimney             Port hole
                                                                                             Boilers are height is 103 ft. | provided
                                                                                           available.
                                                   5              D G sets with capacity | 250 kva&500           | Chimney                  NA
                                                                                           kva                     height is 6 ft.

                                                   SOLID WASTE MANAGEMENT
                                                   1, HAZARDOUS WASTE                                                            Ae

                                                            SL.NO | SOURCE OF                      QUANTITY     MODE OF                      PRESENT
                                                                    GENERATION                     OF           STORAGE                      STOCK IN
                                                                                                   GENERATION | AND                          THE
                                                                                                   PER DAY      DISPOSAL                     STORAGE




                                                                                         Page 67 of 110
                                                                                                                                                                                     15
                                                                                                                                                              M
                                                                                                                                                            "7




                                                                                                                                                                       YARD
                                                                                             1   Process residue          600 kgs              Cement                  Nil
     aT ene te ee GEOR © Pe TRA Rete ao ep ctrr SRT tt tnectaes reise py




                                                                                                                                               recliners
                                                                                             2   Activated carbon         50 kgs               TSDF                    100 kgs
                                                                                                 sludge
                                                                                             3   MEE salts                1500 kgs             TSDF                    400 kgs
                                                                                             4   DISCARDED                50 kgs           Authorized                  10
                                                                                                 CONTAINERS                                    recycliers
                                                                                    2            IF ANY OTHER

                                                                                   2. OTHER WASTE
PR Ne Sekt a mE RT Po ty A




                                                                                         SL.NO | SOURCE OF                 QUANTITY | MODEOF' | PRESENT
                                                                                                 GENERATION                   OF      STORAGE | STOCK IN
                                                                                                                          GENERATION | AND                        THE
                                                                                                                           PER DAY         DISPOSAL | STORAGE
                                                                                                                                                                  YARD
                                                                                         1       DOMESTIC                              -   -                      -
                                                                                     2           OFFICE                                2   =                      3
                                                                                                 STATIONARIES
                                                                                     3           E WASTE                      5 kgs        Exchange                   Nil
                                                                                     4           BOILER ASH                   1 Ton         Send to red | 2 tons
                                                                                                                                            brick
                                                                                                                                           industries
                                                                                                                                           and farmers
                                                                                     5           SCRAPS IRON                       -       -          oe
                                                                                                 AND STEEL


                                                                           COMPLIANCE TO THE OBSERVATIONS                  OF THE JOINT COMMITTEE                           VISIT
                                                                           DATED 27.11.2019


                                                                               SLN_ | Observations           Compliance
                                                                               0




                                                                                                                                                       "a




                                                                                                                   Page 68 of 110
                                                                                   16




The Unit has       YES, the unit has displayed the Consent and Hazardous waste
displayed the      authorization conditions at the entrance of the unit.
Consent and
Hazardous
waste
authorization
conditions at
the entrance of
the Unit, as per
the direction of
the Hon' ble
Supreme Court
Order in W.P
No(C)
657/1995.




The unit has       Validity expired, Applied under process.
valid consent
and Hazardous
waste
authorization.

The source of      The source of water is from outside tankers. Flow meters are
water supply is    installed at the input and various
open well          Discharge points in the unit and regularly recording the
located within     consumption of the same.
the premises
and tankers,
not installed
flow meter for
water
consumption
and record is
not available.
The Unit has
not obtained
NOC from the
Karnataka
Ground Water
Authority
(KGWA) for




                         Page 69 of 110
                                                                                   17




usage of
Ground water
for industry
use.

The unit is not   Not provided, However the industry has provided pipe for old
having closed     solvent tank having scrubber. They are proposing to shift all
loop system       solvent tanks at one place.
for solvent
handling to
minimize the
solvent loss.




The Unit has
installed
OCEMs and
connected to
CPCB/KSPCB
. The OCEMS
is found
working.




                   Time: 12-04-2022 15:35   '
                  Note: Suryakala Li




                              Page 70 of 110
                                                                                        18




The unit has       The MEE & ATFD is in working condition.MEE tubes are
30 KLD ETP,        changed to increase the performance and also new ATFD with
the low TDS        capacity of 1 kl/hr is installed. To ascertain the claim of the
and High TDS       industry in respect of the tolerance limit of condensate the
effluent are       sample of the same is collected for analysis purpose. Report is
combined           awaited.
treated with       The applicant is of the opinion that treatment for the condensate
neutralization     is not required since the tolerance limit is within norms,
followed with      however this can be only known after the receipt of analysis
stripper,          report.
Multiple Effect
Evaporator
(MEE) and
Agitated thin
Film Drier
(ATFD). The
salt generated
is disposed to
common
TSDF. The
MEE
Condensate is
used as Boiler
feed. The
analysis results
of effluent
samples reveal
that, the MEE
condensate is
reported with
high
concentration
of COD and
alkaline PH,
which
indicates that
poor.
Performance
of MEE
condenser and
condensate
generated is
not suitable for
recycling as
cooling tower,
make up water.




                             Page 71 of 110
                                                                                                                  19




The unit has      MEE salts are disposed at regular intervals. The spillage
storage of        collection pit is also provided at the Hazardous waste storage
large quantity    area.
of process
residue and
MEE salts
about 20 Tons,
the same is
stored in
unscientific
haphazardly in
HWM    storage
area. Due to
huge storage,
there is
generation of
leachate,
which is
coming out of
storage area.
The unit shall
immediately
dispose the
same to the
authorized
agency as per
HW
authorization
                  | Accuracy: 27.6
and shall not      'Time: 12-04-2022 15:37
                  Note: Suryakala Laboratories pvt itd Hazardous waste storage spillage collection pit photo S
accumulate
large quantity
of solid waste
and dispose the
same at regular
frequency.
There is no
spillage
collection pit
existing in
HWM storage
area.




                              Page 72 of 110
                                                                                                   20




      7                         Coal ash is stored in separate room and the same is disposed to
              Coal is used as | brick industries at regular intervals.
              fuel in Boiler,
              the ash
              generated from
              the Boilers,
              ash lumps and
              fine ash shall
              be stored
              separately in
              bags to avoid
              fugitive
              emissions.




              The unit is not
              having storm
              water
              management
              system,
              collection and
              treatment of
              the same.




MONITORING

      The sample of condensate from is collected for analysis..
  =

The sample of ambient air quality is conducted. wn The emission from scrubber outlet is collected for testing acid mist concentration. The above samples are submitted to KSPCB Laboratory for analysis purpose. The report is awaited.

Page 73 of 110 21

The above samples are submitted to KSPCB Laboratory for analysis purpose. The report is awaited.

Apart from the above, the following important observations were made:

a. There is no discharge/bypass of effluent to outside the premises. b. The said unit has adopted Zero Liquid discharge facility. c. The Non compliances observed during the Joint committee visit on 26/11/2019 has been complied with except that_the Industry has not adopted treatment for condensate before using for cooling tower, not provided storm water management and closed loop system for solvent handling.
The Industry authorities have sought time of3 months (three months) to adopt treatment for condensate, to provide storm water management measures and closed loop system for solvent handling.
YTAL OFFICER KSPCB, BIDAR oe SENIOR ENVIRONMENTAL OFFICER KSPCB, ZONAL OFFICE, KALABURGI Page 74 of 110 22 JOINT INSPECTION REPORT Name of the Industry Inspected: M/S Sri Lakshmi Chemicals, Kolhar Industrial Area Bidar Name of the Inspecting Officers:
W ON TMATE
1. Shri S Madhusudhan Senior Environmental Officer, Zonal Office Kalburgi
2. Shri Gopalkrishna B Sanatangi Environmental Officer KSPCB Bidar.

HET E EE ONIN Reference: The Board direction. issued vide memo dated: 05.04.2022 ees TN TUTE Date of Inspection 07.04.2022 ,13.04.2022, oe a ea Monitoring carried on 11.04.2022 Gees eT Consent status Water Act 1974 Air Act 1981 ee to Ae eT Nae Nee Valid upto Valid upto Se 30.06.2022 30.06.2022 Products manufactured As per CFO Actual Manufactured TOTS ON IPCA(Iso Propyl | IPCA(Iso Propyl Ree Chloro Acetate) Chloro Acetate) PRN HWM Status Valid upto 25.09.2025 WATER POLLUTION CONTROL STATUS Source of water: Third Party Water supplier by Water Tankers Daily Quantity of water consumption as per Consent:5.0KLD See Actual water consumed for different purposes:3.5KLD Quantity of effluent generation from different sources as per CFO;0.500MT Sources of generation Quantity Mode of treatment and disposal Domestic 1.500 Treated in Septic tank and Soak pit Process 2.000 The trade effluent 0.30KLD is being pre treated and then further treated in Multiple Effect Evaporator followed by Agitated Thin s oy Page 75 of 110 23 oes Trent becca e Film Drier. The MEE/ATFD condensate is used for cooling tower #.

%:

x makeup to achieve zero + pe liquid discharge. The salts IES eee ene tog OR eT EAT ET Eee SSR Sond pe Bee tt"
generated at MEE/ATFD is disposed as hazardous waste in authorized TSDF.
                                                         Washings                         0.30                      MEE"
                                                             Boiler blow down            0.30                       Neutralized and used for
                                                                                                                    Gardening.
                                                             RO Rejects                  Nil                        NA
  NN TT wn OL




                                                         If any others                  Nil                         NA
  eee
 ee




. Details of effluent treatment plant a. STP units : Nil b . MEE: 30 KLD c. Condensate treatment plant: Nil d. Closed loop system for solvents and raw material handling: Work under progress. At present using vaccum suction from the 200 liters drums.
                                                                                                                             "ML

                                                         AIR POLLUTION            CONTROL      STATUS

                                                         Sl. | Air Pollution source   Air pollution       Chimney                  Monitoring facility
                                                         no                           control equipment | height above
                                                                                      provided            ground level
1 | Process emissions from | GLR's 8, having 4 | 20m Port hole provided GLR, No of GLRs scrubbers 2 | MEE 30KLD NA NA 3 | ATFD 20m NA NA 4 | Boiler with capacity 125TF8 30m Port hole provided 5 | D Gsets with capacity | 62.5KVA 3m NA SOLID WASTE MANAGEMENT :
1. HAZARDOUS WASTE SL.NO SOURCE OF QUANTITY MODE OF PRESENT STOCK IN GENERATION OF STORAGE THE STORAGE Page 76 of 110 24 s sh ENO GENERATION | AND YARD FERS PS Se PER DAY DISPOSAL 1 Process residue 15 kgs Authorised Nil EERE TSDF 2 Activated carbon NIL Nil Nil IE sludge ES SC 3 MEE salts 15kgs Authorised Nil e cit ul Se he te ey eee EEE TSDF 4 DISCARDED 20 nos Drum 20 numbers CONTAINERS purchaser 5 IF ANY OTHER Nil Nil Nil
2. OTHER WASTE « pe hrur POE SL. | SOURCE OF QUANTITY OF | MODE OF PRESENT STOCK IN NO | GENERATION GENERATION | STORAGE THE STORAGE YARD PER DAY AND DISPOSAL 1 DOMESTIC Nil Nil Nil 2 OFFICE Nil Nil Nil STATIONARIES 3 E WASTE Nil Nil Nil 4 BOILER ASH 50kg Sold to Brick Nil Industry 3 SCRAPS IRON AND Skg Sold to Iron Nil STEEL Scrap Purchaser ML al j COMPLIANCE TO THE OBSERVATIONS OF THE JOINT COMMITTEE VISIT DATED 27.11.2019 Si. Observations Compliance No s mt Page 77 of 110 25 The Unit has | Updating Weekly once displayed the Consent and Hazardous waste authorization conditions at the entrance of the Unit, as per the direction of the Hon'ble Supreme Court Order in W.P No (C) 657/1995.
The unit is not Consent Valid up to 30.06.2022 having valid Hazardous Waste Authorization Valid up to 25.09.2025. Copies consent and | enclosed. Hazardous waste authorization.
The unit is not in operation, applied for renewal of consent.
The source of | Third party water suppliers by Tankers Daily. water supply is | Procurement, Storage and consumption details maintained in by tankers not | separate register. Copies enclosed. having own source. There is no water consumption record available.
The unit is not Closed loop system for solvents work is under process. having closed Meanwhile we are using dedicated pipes and drums for handling loop handling of solvents. system for solvent. There two solvent storage tanks exists.
Page 78 of 110 26
The unit has | Arranged the spillage collection pit for Hazardous Waste storage provided room. Segregated and dedicated area allotted for solvent drums.
ex hazardous waste | = ------
storage area found with process residue storages and storage area is not spillage collection pit.
The used solvent drums are stored in open place.
The unit is use Coal ash stored in separate shed and disposed to Brick industry coal as fuel for purchaser. boiler and ashes generated are not properly handled.
The source of Third party water suppliers by Tankers Daily. water supply is Procurement, Storage and consumption details maintained in own open well separate register. Copies enclosed. and not installed flow meter and water consumption record is not available. The unit has not obtained NOC from the Karnataka Ground Water Page 79 of 110 27 Authority (KGWA) for usage of Ground | water for industry use.
     The raw                                                          Yes
     materials are
     storedin shed.      |
     The closed loop     |
     system for
     solvent handling |
      is under
      commissioning.
     During                  |                                  Yes
     inspection there
     was no                  |
     production and
     informed that
     the plant was
     under
     maintenance
     shut down.

10    The unit has                   OCEMS is connected and data push up to KSPCB and CPCB
      installed flow
      meter and
      camera to MEE,
      but OCEMS is
      not yet
      connected to
      CPCB/KSPCB




11    The unit isnot             | Storm Water Collection point arranged and treated through
                                 |
      having storm       af
                                     MEE.




                                            Page 80 of 110
                                                                                                                 28


                   water
                   management
                   system,
                   collection and
                   treatment of the
                   same.




      MONITORING

The sample of condensate from MEE will be collected for analysis..

The sample of open well/tube well will be collected for analysis. eet The sample of ambient air quality will be conducted. The emission from scrubber outlet will be collected for testing acid mist concentration.

The above samples are submitted to KSPCB Laboratory for analysis purpose. The report is awaited.

Apart from the above, the following important observations were made:

a. There is no discharge/bypass of effluent to outside the premises. b. The said unit has adopted Zero Liquid discharge facility. c. The Non compliances observed during the Joint committee visit on------ has been complied with except that the Industry has not adopted treatment for condensate before using for cooling tower _and closed loop system for solvent handling.
The Industry authorities have requested 1 month (one month) time period to adopt treatment for condensate and closed loop system for solvent handling.
The said bulk drug unit has complied with the conditions stipulated in the consent for operation issued by the Board.
            ENVIRON                 AL OFFICER
            KSPCB, BIDAR



            SENIOR ENVIRONMENTAL                  OFFICER
            KSPCB, ZONAL            OFFICE, KALABURGI




                                               Page 81 of 110
                                                                                                                                             29


                                        "3                         JOINT INSPECTION REPORT
iin ait inate di Lat ek Sa ak ee Name of the Industry Inspected: M/S Chandra Life Sciences Pvt Ltd Kolhar Industrial Area Bidar : Name of the Inspecting Officers:
1. Shri S Madhusudhan Senior Environmental Officer, Zonal Office Kalburgi E 2. Shri Gopalkrishna B Sanatangi Environmental Officer KSPCB Bidar.

: Reference: The Board direction issued vide memo dated: 05.04.2022 Date of Inspection 07.04.2022 13.04.2022 ee Monitoring on 13.04.2022 Consent status Water Act 1974 Air Act 1981 Active - AW-323366 | Active - AW-323366 Valid up to Valid up to 30.06.2023 30.06.2023 Products manufactured AsperCFO * Average Actual Qty / Month Manufactured (+)-2-(chlorophenyl)N-[2-[2 thienyl) 6.0 ~5.0MT : ethyl] glycine methylester hydrochloride(coupled amine) : (-) p-Chloro benzhydryl piperazine 0.5 0 2-[4[(4-Chloro phenyl)pheny1 0:5 0 methyl} piperzineyll]ethoxy]aceticacid (LCZ VII) Tartaric salt of Clopidogrel (CPA II) 6.0 5 MT Clopidogrel bi sulphate 6.0 0.25 MT 2-(2-Thienyl) Ethyl-4-Methyl Benzene 6.0 00 Sulfonate (CP B mass) CP I 6.0 00 DFTA I 18.0 a 3.50 MT DFTA II 18.0 2.17 MT Donepezile intermediate 1.0 NA Fluconazole 18.0 0.80 MT Itraconazole 3.0 00 Itraconazole and its intermediates 3.0 00 Leevocetorizine Dihydrochloride 0.5 0.02 MT Quetiapine Fumarate IP/EP and its 3.0 00 intermediates Tartaric salt of Levocetrizine(LC II) 0.5 00 Page 82 of 110 30 i i i 5 Voricanazole and its intermediates 1.0 [ 00 t HWM Status f Valid up to 30.06.2023 TONS: at 2 RMT EE eg WATER POLLUTION CONTROL STATUS Source of water:Openwell ee eee Quantity of water consumption as per Consent:53 KL Ree Actual water consumed for different purposes: Avg 48KL - Pe ROLE DOE en Quantity of effluent generation from different sources as per CFO!{9KL Mode of treatment and Sources of generation Quantity (KL) disposal Se net lire fee ee FEN Domestic 6.5 Sock Pit pet Chew aes sae Process 10 MEE Washings 1 MEE Boiler blow down 2. Used For Coal Ash Quenching RO Rejects 3 MEE If any others NA NA Details of effluent treatment plant a. STP units NA b. MEE YES c. Condensate treatment plant -- MEE condensate is sent for cooling tower make up d. Closed loop system for solvents and raw material handling --- YES AIR POLLUTION CONTROL STATUS Sl. No | Air Pollution source Air pollution Chimney Monitoring facility control height above Page 83 of 110 eee Ne ee ae nets OE eT eee eee eae nee EPs 31 MM equipment | ground level provided (Meters) 1 Process emissions MSV LABS from GLR, No of SCRUBBER- 9 AGL (Monthly) GLRs 11 NO's 2 No's 2 MEE NA NA MSV LABS ee a (Monthly) ses gt Se SE EE ee Pere cee ee Ee Se a Vee ee Pe eee 3 ATFD NA NA NA 4 Boiler with capacity 2T &1T 22 METERS MSV LABS (Monthly) 5 D G sets with capacity | 330 KVA 6 AGL at MSV LABS (Monthly) SOLID WASTE MANAGEMENT LE

1. HAZARDOUS WASTE SL.NO | SOURCE OF QUANTITY OF | MODE OF PRESENT GENERATION GENERATION | STORAGE AND | STOCK IN PER DAY DISPOSAL THE STORAGE YARD 1 Process Residue 50 to 75 Kgs / Stored in secured | 5.60 MT Day manner 2 Activated Carbon 2to5Kgs/Day | Stored in Secured | 200 Kgs.

                                                                               Sludge                                         manner *'
                                                                    3          MEE Salts              300 to 500 Kgs/ | Stored in secured | 3.779 MT
                                                                                                      Day       ,       manner. Handed
                                                                                                                        over to authorized
                                                                                                                        TSDF (Mother
                                                                                                                        Earth)
                                                                    4          Discarded Containers | 5 Nos. / Day      Re-used in the      Nil
                                                                                                                        plant.
                                                                    5          IF ANY OTHER           Not Applicable | Not Applicable       Not
                                                                                                                                            Applicable


                                                         2.       OTHER WASTE

                                                                  SL.NO | SOURCE OF                        QUANTITY       |MODEOF                | PRESENT
                                                                                  GENERATION                   OF         STORAGE | STOCK IN




                                                                                                   Page 84 of 110
                                                                                             32




                                    GENERATION         AND            THE
                                       PERDAY         | DISPOSAL | STORAGE
                                                                      YARD

    1      DOMESTIC                    4 Kgs/Day      | Used in       Used in
                                                      | Boiler        Boiler

    2       OFFICE                     1Kg/Day        | Used in       Used in
            STATIONARIES                              _ Boiler        Boiler
    3       E WASTE                       Nil         "Nil            Nil
    4       BOILER ASH                100 Kgs/Day      Brick          Brick

| Manufacturer | Manufacturer 5 SCRAPS IRON 1 to3 Kgs/Day | Stored in 200 Kgs.

AND STEEL Scrap Yard COMPLIANCE TO THE OBSERVATIONS OF THE JOINT COMMITTEE VISIT DATED 27.11.2019 SLNo | Observations Compliance 1 The Unit has displayed the Consent and Yes Hazardous waste authorization conditions at the entrance of the Unit, as per the direction of the Hon'ble Supreme Court Order in W.P No (C) 657/1995.

2 The unit has valid consent and Hazardous | Yes waste authorization. Air &Water :AW-323366 Valid up to 30-06-2023 HWM No. 326667 Valid till 30-06- 2023 3 The source of water supply is own open | The Source of water is open well.

well and installed flow meter to record Flowmeter provided. the consumption of water from openwell. | KGWA NOC Obtained. The unit has not obtained NOC from the Karnataka Ground Water Authority (KGWA) for usage of Ground water for industry use. The average water consumption is 18 KLD.

Page 85 of 110 33

ig The raw materials are stored properly in They have provided receivers to shed, where as they have provided avoid Handling of solvents. receivers for handling of solvents and We have provided primary and provided primary and secondary secondary condensers on reactors condensers on reactors for maximum for maximum recovery of solvents. recovery of solvents.

The Unit has installed OCEMs and connected to CPCB/KSPCB. The OCEMS is found working.

The unit has 20 KLD ETP, the low TDS e Strict operational controls are and High TDS effluent are combined developed while handling the treated with neutralization followed by Multiple Effect Evaporator (MEE) and effluents.

Page 86 of 110 34

Agitated thin Film Drier (ATFD). Effluent is being neutralized The MEE Condensate is used as Boiler to 7.5 pH before feeding to feed. The analysis results of effluent samples reveals that, the MEE condensate MEE. is reported with high concentration of Proper care is been taken COD and acidic pH, which indicates that during process at the layer poor performance of MEE condenser and condensate generated is not suitable for separations steps to avoid recycling as cooling tower, make up high COD to effluent. water. Additionally, stripper is provided to remove the MSV Analytical Laboratories solvent traces to avoid high COD in treated effluent.

The condensate water is being analysed regularly by the NABL approved third party laboratory. We are obtaining recyclable quality.

The analysis report is attached for ready reference.

The unit has storage of large quantity of They are segregating different process residue, spent carbon and MEE categories of Hazardous salts about 7.5 Tons, the storage area is not having spillage collection pit existing Waste and storing in double HW storage area. The unit is maintaining layered bags separately on Page 87 of 110 35 inventory of HW and Inventory is found pallets in the dedicated displayed at storage area. The hazardous Hazardous Waste Storage residue drums and raw materials (Solvent drums) are stored in same shed; the same Area. shall be stored securely in designated e Hazardous waste is being hazardous waste storage area.

disposed to TSDF regularly as per Hazardous Waste handling rules.

e Leachate collection pit is provided in the hazardous waste area and photograph is enclosed.

The process area not provided with They have provided Spillage spillages collection pits.

collection pits in process area. Photographs enclosed.

Page 88 of 110 36

The unit has provided rain water They have provided impervious percolation tank for all roof top and surface runoff water collection surface run off collection, the same need to be modified with the impervious tank tank to re-utilise storm water. of adequate capacity to reutilize the same. Since the surface run off is contaminated not advisable to percolate into ground water.

10 The unit uses coal as fuel for boiler and They have covered the Coal Ash ashes generated shall be properly shed three Sides to control fugitive handled. emission from coal ash handling.

Photographs Enclosed.

1 The process scrubber liquid shall be They have provided apermanent x directly taken to ETP (MEE) by installing | pipe line to pump scrubber liquid to permanent pipeline, to avoid spillages. ETP collection tank for further treatment. Photograph enclosed.

11 There is an existing open well in the plant | Industry is presently using the water premises, open well sample was collected from Open well.However this open Page 89 of 110 Page 90 of 110 40 JOINT INSPECTION REPORT Name of the Industry Inspected: Corvine Chemicals & Pharmaceuticals Ltd.

Name of the Inspecting Officers:

1. Shri S Madhusudhan Senior Environmental Officer, Zonal Office Kalburgi.
2. Shri Gopalkrishna B Sanatangi Environmental Officer KSPCB Bidar.

Reference: The Board direction issued vide memo dated: 05.04.2022 Date of Inspection 07.04.2022, 13.04.2022 and monitoring carried on 11.04.2022 Consent status Water Act 1974 Air Act 1981 Combined CFO No. AW-325340dt: 19.06.2021 Valid upto: 30.06.2026.

Products manufactured As per CFO.-- | Actual Manufactured (Quantity) (for the year 2021-22)

1. Sodium Azide 180 TPM 558.21495 MT/ Year

2. Trityl Chloride 80 TPM 341.017 MT/ Year

3. 5-Methy] Tetrazole 15 TPM 19.791 MT/ Year HWM Status Authorization No. 327230 dt: 30.09.2021 Valid upto: 30.06.2026 Details of products Manufactured Oty Intermediates SL. No. Product TPM Intermediates Quantity : ante _ sen | | Sodium Azide 180 -- = 2 Trity! Chloride 80 -- sesh 3 Ciprofloxacin HCL 30 --- = 4 BHT 15 --- a 5 5 Methyl Tetrazole 15 wt a 3.

               6             5 Amino Tetrazole               15                       ---                                 |
                a            Dabigatran Etexilate           3.0          Stage-1 (Dabigatran                       6.6
                             Mesylate                                  |Ethyl Acetic Salt)                 os
                                                                        Stage-2 (Dabigatran                        3.0
                                                       oe              Etexilate)                              --
               8             Donepezil HCL                  3.0)        Stage- | (Dehydro                       3.75
                                                                        Denepezil)
                                                                        Stage- 2 (Donepezil)                       3.0
               9             Pirfenidone                    3.0         Stage- |                (2-                a7
                                                                        Hydroxy                 5-
                                                                      | Methyl pyriding)




                                                  Page 91 of 110
                                                                                                                           41
          10       Solifenacin                             3:0)    Stage-1 (S) -Ethy} 1-             $3
                   Succcinate                                      Phenyl-3,4-Dihydro
                                                                   isoquinoline -2(1H)-                           ?)
                                                                   carboxylate
          11       Tamsulosin                          3.0        'Stage-                            33
                   Hydrochloride                                   1(Ethoxyphenoxy)
                                                                   ethyl amino propyle
                                                                   2|-methoxy benzene
                                                                   sulfoamide)                                        |
          12       1H Tetrazole (1- HT)                   2.0                   ---                   ide
          3        5-Benzyl Thio Th                        2.0                  =                     ian
                   Tetrazole (5- BTT)
          14       4,5-Di Cyano Imidazole                 2.0                   ---                   Be:
                   (DCI)
          15       Ethyl ThioTetrazole                    2.0                   ---                   a=
                   (ETT)
          16       5-Phenyl     1 H-Tetrazole              2.0                  ---                   ae
                   (5Ph T)
                                                     By-Products                                hi              oa

        S.No.                 Product               Oty. TPM                Byes                     Oty:
                                                                                                     TPM
           ]       Sodium Azide                            180     Sodium Sulphate                   245

                                                                   HCI                               115
           2       Trityl Chloride                         80                                                     4
                                                                   AICI;                             320
                                                                   Ammonium           Acetate          15
           3       Ciprofloxacin HCl                       30
                                                                  Piperzine                           12


WATER POLLUTION CONTROL STATUS Source of water: Open well / Water supplier (tankers) during summer. a Quantity of water consumption as per Consent: 288 KLD Actual water consumed for different purposes:60-70 KLD iS Quantity of effluent generation from different sources as per CFO:

Sources of generation Quantity | Mode of treatment and disposal "Tr Domestic 10.0 KLD Sewage treatment plant. "
        Process                                 27.62 KLD                   :                                     |
       Washings                                 2.0 KLD                                                           |
        Boiler blow down                        5.0 KLD               MEE/ ATFD/ BTP& RO                          |
        RO Rejects                              2.0 KLD
       "Tf any others                   ~ |70KLD




                                        Page 92 of 110
                                                                                                                   42
DETAILS OF EFFLUENT                TREATMENT      PLANT

STP units - | No. Capacity : 20KLD (Domestic waste) MEE - | No, Capacity :30 KLD eanoge ATFD - | No. Capacity : 12 KLD Condensate treatment plant (BTP) -- | No. Capacity:40 KLD. RO Plant - | No.Capacity: 1.0 KL/hour AIR POLLUTION CONTROL STATUS SLNo. | Air Pollution source Air pollution control | Chimney | Monitoring equipment provided | height facility above ground level 1 Process emissions from Provided 4 Nos of 9 Mtr Provided GLR, Scrubbers to 16 Nos_ | 40Nos. portal No of GLRs- 16 Nos. GLR. Each Scrubber connected to 4 GLRs.
2 Boiler with capacity Mechanical 30 Mtr Provided
i) 3.0 TPH -1INo. Dust collector 2 Nos. portal
ii) 2.0 TPH -- 2Nos 3 D.G sets with capacity = --- | 6Mtr |: Provided |i) 500 KVA-2 Nos 2 Nos. portal 4 | MEE <-- = OCEMS | 3 ATFD o-- --- No Vents SOLID WASTE MANAGEMENT
1. HAZARDOUS WASTE :
SL.NO | SOURCE OF QUANTITY MODE OF | PRESENT GENERATION OF STORAGE STOCK IN GENERATION | AND THE DISPOSAL | STORAGE YARD | | Process residue --- -- sae | 2 Activated carbon 15-20 Kg/ day Stored in HW | 1.39 MT storage site, disposed to as 7 TSDF:
             3           MEE salts               - 200 -300 Kg/       Stored in HW | 11.20MT
                                                  day                 storage site,
                                                                      disposed to
                                                                      TSDF,
             4           Discarded Containers | 15-20 Nos /           Stored in HW | 13 Nos
                                                month                 storage site,




                                           Page 93 of 110
                                                                                                                 43
                                                                             disposed to
                                                                             Authorized
                                                                             Recycler.
                       Used Oi]                         120-150 Lt/          Stored in HW | Nil
                                                     | year                  storage site,
                                                                             disposed to
                                                                             Authorized
                                                                             Recycler.
                       Spent Solvent                  200-250 Kg/ day        Stored in HW | 0.21 MT
                                                                             storage site,
                                                                             disposed to
                                                                            Authorized

         2. OTHERWASTE:                                                    hoo

         SL.NO     SOURCE OF                   QUANTITY
                                                      OF                 MODE OF             |PRESENT
                   GENERATION                  GENERATION               STORAGE               STOCK IN THE
                                                                        AND                   STORAGE
                                                                        DISPOSAL              YARD
                   Domestic

                  Office stationeries

                                                                        Storedin
                                                                        designated
                  E-Waste                     22 3    Nos/ year         area, disposed | Nil
                                                                        to authorized
                                                                        recycler.
                                                                        Stored in
                 | Boiler ash                 4 -6 Kg /day              designated
                                                                                              120 Kg.
                                                                        area, disposed
                                                                        to recycler.
                                                                        Stored in
                  Scraps Iron and Steel                                 designated
                                              IOMT/ Year                                     2MT
                                                                        area, disposed
                                                                        to recycler.

         COMPLIANCE TO THE OBSERVATIONS                           OF THE JOINT COMMITTEE                VISIT
         DATED 27.11.2019

SI.No.     Observations                                     Compliance
           The unit has displayed the consent and           Displayed     Consent and        Hazardous waste|
H.W Authorization conditions at the Authorization conditions at the entrance of | entrance of the unit, as per the | the factory.

direction of Supreme Court order in W.P (C) 657/1995. The unit has valid Photograph of display board is enclosed as consent and H.W. Authorization. Annexure-1.

Page 94 of 110 44

The source of water supply for Obtained NOC for the usage of industrial use is open well and has groundwater for industrial purpose from | installed flow meter for recording Karnataka Groundwater authority, water consumption. But, the unit has Bengaluru. not obtained NOC from the Karnataka Groundwater Authority (KGWA) for NOC obtained from KGWA is Enclosed as usage of groundwater for industrial Annexure-2. purpose.

Photograph of Flow meter provided for Open well enclosed as Annexure-3. The log book extract of water meter readings is | enclosed as Annexure-4. | The raw material are stored in closed The quantity of solvent used in al shed and having closed loop system manufacturing process is very less and no | | for solvent handling. But still some of manual handling of solvents is carryout | the solvent are handled in barrels and all the solvents are sucked by vacuum manually. pump. The photographs of vacuum solvent sucking system is enclosed as Annexure-5.

The process area is not provided Spillage collection pits are provided in spillage collection pit. process area. The Photographs of spillage| collection pit is enclosed as Annexure-6.

The unit has not provided designated They have constructed designated storage>|| place for the storage of by-product i.e. facility for storing Sodium Sulphate (by- | | Sodium Sulphate etc. product). The photograph is enclosed as | Annexure-7.

Acid and alkaline scrubbers are Dyke wall and collection pits ere provided as air pollution control provided in the scrubber area. The photos | equipment to all Glass Line Reactors enclosed as Annexure-8. (GLR's) to handle the process | emissions, But, the alkaline scrubbers | area is not provided with dyke or | | spillage collection pits to avoid aby soil contamination.

Used solvent drums / barrels are stored Used solvents drums are washed in a in an open area, the same need to be separate special washing area, Washing's shifted to the designated place after are collected into effluent collection tank washing for disposal to the recyclers. and then stored under closed condition in the Hazardous waste storage site. The photo graphs of discarded containers | a stored in designated area is enclosed as | Annexurre-9, Photo of Special (Equipment) washing area is enclosed as Annexure-10 Page 95 of 110 45 |Coal / briquettes are used as fuel in Boiler ash lumps & fine ash ts collected in } Boilers, the ash generated from the separate bags and stored in designated boilers, ash lumps & fine ash shall be area.

aa) stored separately in bags to avoid Photos are enclosed as Annexure-1 1. fugitive emission.

9 There are no dyke walls between the | Provided dyke wall between acid storage acid storage tanks, as per the | tanks. Photos are enclosed as Annexure- compatibility of acid. There is no |} 12. scrubber system provided to the acid storage tank (HCL) to handle the acid | Scrubber system is provided to HCl fumes during handling of acids. storage tanks. Photographs of Scrubber is | enclosed as Annexure-13. :

10 The unit has provided surface runoff | As per suggestion of technical person collection tank with outlet for] present surface runoff collection tank overflow. But the existing capacity of | (Capacity-30.00KL) is sufficient with collection tank provided is not] compared to plant area. Surface runoff adequate and same shall be increased | collection tank's outlet was closed. with a provision to reuse after | treatment. The collection tank outlet | Photographs of Surface runoff collection | shall be removed to avoid any outside | tank is enclosed as (Annexure-14), discharge. ag) 11 The unit has provided OCEMS system | They have provided MEE ~-- OCEMS | for the treated effluent, connected to | system for the treated effluent connected to | CPCB / SPCB and found operating. CPCB / SPCB and found operating.

photos of OCEMS camera enclosed ss (Annexure-15).

12 MEE condensate is reported with high i They have installed Biological treatment |! concentration of COD and alkaline plant and RO plant from which the | pH, which indicates the poor condensate of good quality, is obtained | performance of MEE _ condensate and being recycled. | generated is not suitable for recycling as cooling tower, make up water. photos of Aeration tank and RO plant| enclosed (Annexure-16).

                                                                                                             ee               =             esl:



     MONITORING:

1. The sample of condensate before BTP and after BTP is collected for analysis.

2. The sample of open well/tube well collected for analysis.

3. The sample of ambient air quality is conducted.

4. The emission from scrubber outlet is collected for testing acid mist concentration.

The above samples are submitted to KSPCB Laboratory for analysis purpose. The report is awaited.

Apart from the above, the following important observations were made:

a. There is no discharge/bypass of effluent to outside the premises. b. The said unit has adopted Zero Liquid discharge facility.
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