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National Green Tribunal

National Green Tribunal Southern Zone vs The Chief Secretary To Govt. Of Tamil ... on 25 May, 2021

Bench: K. Ramakrishnan, K. Satyagopal

Item No.3:

              BEFORE THE NATIONAL GREEN TRIBUNAL
                    SOUTHERN ZONE, CHENNAI


                    Original Application No. 257 of 2020 (SZ)
                           (Through Video Conference)
IN THE MATTER OF


      Tribunal on its own motion
      Suo Motu based on the news item in
      The New Indian Express Newspaper dated 27.11.2020,
      "A Cooum in the making in Karur?"
                                                                  ...Applicant(s)

                                     Versus
      The Chief Secretary to Govt. of Tamil Nadu,
      Govt. Secretariat, Fort St. George,
      Chennai and Ors.
                                                                ....Respondent(s)

Date of hearing: 25.05.2021.


CORAM:

      HON'BLE MR. JUSTICE K. RAMAKRISHNAN, JUDICIAL MEMBER
      HON'BLE MR. Dr. K. SATYAGOPAL, EXPERT MEMBER


For Applicant(s):               Suo Motu by Court.


For Respondent(s):              Mr. C. Kasirajan through
                                Ms. D. Ashwini for R6.
                                Mrs. P. Jayalakshmi for CPCB.




                                   Page 1 of 46
                                 ORDER

1. The above case has been Suo Motu registered by this Tribunal on the basis of the newspaper report published in The New Indian Express, dated 27.11.2020 under the caption "A Cooum in the making in Karur?"

It is alleged in the newspaper report that the dyeing units and industries in Karur are polluting the Amaravathi River to such an extent that it could soon become a second Cooum in the State. So, this Tribunal admitted the matter and appointed a Joint Committee to go into the question and directed them to submit a report and this case was originally posted to 22.02.2021 for that purpose. Thereafter, the matter has been adjourned from time to time at the request of the committee members.

2. Thereafter, on 12.04.2021, this Tribunal had considered the statement submitted by the Commissioner, Karur Municipality in the form of report wherein, they have admitted that there is lack of facilities available for treating the sewage that is being generated in Ward No.33 to 48 of that municipality and though requests have been made to the Public Works Department (PWD) for allotting certain areas for establishment of Sewage Treatment Plant (STP), no reply has been received from them.

3. This Tribunal also considered the gist of the report regarding the implementation of the Solid Waste Management Rules, 2016 wherein, they have stated that they commenced the bio-mining process on Page 2 of 46 22.02.2020 and they have almost completed 80% of the disposal of the accumulated waste and they are also having a Sewage Treatment Plant with capacity of 15 MLD but they are getting sewage for treatment to the extent of 6.5 MLD which is being used for collecting and treating the sewage generated from the Ward No.1 to 32 in that municipality. But they have not mentioned anything about the arrangements made by them in respect of Ward No.33 to 48 which were earlier part of two independent local bodies but later merged with the Karur Municipality as early as on 2011. They have not mentioned as to whether any steps had taken by them to have the Under Ground Sewage Facility in these wards to connect the sewage water to the existing Sewage Treatment Plant, so that it can be used at its optimum level which will to some extent resolve the issue and the committee as well as the concerned departments were also directed to submit independent reports regarding the steps taken from their side to protect the Amaravathi River from pollution and posted the case to today for that purpose.

4. When the matter came up for hearing today through Video Conference, Mr. C. Kasirajan through Ms. D. Ashwini represented 6th respondent and Mrs. P. Jayalakshmi represented the Central Pollution Control Board (CPCB) who is one of the member of the joint committee.

Page 3 of 46

5. The 6th respondent/ Tamil Nadu Pollution Control Board had submitted a report signed on 22.04.2021 e-filed on 26.04.2021 and received on 28.04.2021 which reads as follows:-

"Report on behalf of the 6th Respondent/ Tamil Nadu Pollution Control Board I, S. Ragupathi, Son of Thiru. R. Sangam, Hindu, aged about 54 years, having office at No.76, Mount Salai, Guindy, Chennai - 600 032, do hereby solemnly affirm and sincerely state as follows:-
1. I am the Joint Chief Environmental Engineer, Tamil Nadu Pollution Control Board, Chennai - 32 and I am filing this reply affidavit on behalf of the 6th respondent board and as such I am well acquainted with the facts of the case from the records.
2. It is respectfully submitted the Hon'ble NGT has passed order dated 15.12.2020 and directed as follows:-
"Para 8 .... to appoint a joint committee comprising of 1) the District Collector, Karur District, or a Senior Officer not below the rank of Assistant Collector or Sub Divisional Magistrate deputed by the District Collector, 2) a Senior Scientist from Central Pollution Control Board (CPCB), Regional Office, Chennai, (3) a Senior Officer from the Tamil Nadu State Pollution Control Board as designated by its Chairman, 4) a Senior Officer not below the rank of Superintending Engineer of Public Works Department and Water Resources Organisation (WRO) of that area, (5) the Municipal Commissioner, Karur Municipality to inspect the area in question and submit a factual as well as action taken report, if there is any violation found, including assessment of environmental compensation for damage caused on account of any alleged illegal activity resulting in pollution to the water in the river Amaravathy.
Para 11 The committee is also directed to ascertain the existence and 7 functioning of any Effluent Treatment Plant (ETP), Sewage Treatment Plant (STP) and requirement of a Common Effluent Treatment Plant (CETPs) in that area and its operation level as to whether it meets all the norms by testing the inlets and Page 4 of 46 outlets of the effluents being treated by these units and if there is any violation found, what is the action proposed to be taken against such units.
The Central Pollution Control Board (CPCB), Regional Office, Chennai will be the nodal agency for co-ordination and for providing all necessary logistics for this purpose."

Status of Dyeing units in Karur

3. It is respectfully submitted that in the year 2011, there were 487 textile processing units functioning in and around Karur Town. Out of these, 391 units were members of 8 Nos. of Common Effluent Treatment Plants and balance units (96) were running with Individual Effluent Treatment Plants. The treated effluents from these units were discharged either directly or indirectly into irrigation canals of River Amaravathi. However, the dyeing industries with the available treatment technology at that time could not achieve the standards prescribed by the TNPC Board.

4. It is respectfully submitted that, an Writ Petition No.24650 of 2003 filed by an agriculture association, the Hon'ble High Court of Madras directed the TNPC Board to issue closure direction to of all the dyeing units which have not provided zero liquid discharge plants vide its order dt. 16.09.2009. Accordingly all the 487 units and 8 CETPs operating in the year 2012 as the units have not provided ZLD plants.

Then, the units have started to provide ZLD plants and at present 68 dyeing and bleaching units have provided zero liquid discharge system comprising of Effluent Treatment Plant, R.O. plant and Reject management system and started operating with valid consents of the Board.

Out of the 68 units, 46 are textile dyeing units and 22 are textile bleaching units. Out of the 68 units two units are large scale, two units are medium scale and 64 units are small scale units. Out of the 68 units only 28 units are machine process and the rest of 40 units are small scale had dyeing and bleaching process. Out of 68 units only 22 units are generating 100 KLD and above trade effluent quantity and the rest of 46 units are generating less than 100 KLD trade effluent.

Page 5 of 46

Regarding the location details of the units from River Amaravathy three units are located within 100 m, 29 units from 100 m to 1 Km, 32 units from 1 Km to 5 Km and 3 units 5 Km away from the river. Out of the 68 units only 55 units are in operation and seven units are not in operation for the past one year and six units are given direction of closure by TNPCB.

Status of Sewage from Karur Municipality:

5. It is respectfully submitted that, the Karur Municipality have provided a Sewage Treatment Plant (STP) of 15 MLD capacity and part of the Municipal area (32 out of 48 wards) is connected with the STP through underground drainage system (UGDs). The treated sewage from the STP is discharged into nearby irrigation channel. The sewage from the balance area (16 wads) and the adjacent Andankoil Village Panchayat area in not connected with the system and the sewage is gaining access to the River Amaravathi through rain water odai.

The TNPC has directed the Karur Municipality to provide STP with UGDS covering the entire municipal area and to prevent the sewage gaining access into River Amaravathy.

The Hon'ble Madurai Bench of Madras High Court has also given direction in this regard to Karur Municipality in its order dt. 28.09.2016 in W.P. (MD) No.15295 of 2012.

6. It is respectfully submitted that the TNPCB is monitoring the ZLD plants, all units have installed flow meters at inlet and outlet of three stages of ZLD plants.

In large and medium size units the flow meters are connected with computer recording system and the same is connected with water quality watch centre at TNPCB head office, Chennai and 24 x 7 monitoring is ensured.

In small scale machine dyeing units computer recording system is ensured. To ascertain the performance of ZLD Plants samples are collected and analysed at each stage of ZLD Plant and the performance is studied.

The sludge of Effluent Treatment Plant and mixed salt of SEP/ATFD are disposed of cement industries and common disposal Page 6 of 46 facilities respectively. Manifest system for storage, transport and disposal is followed by these units.

The dyeing units in Karur are monitored by District Environmental Engineer, TNPCB, Karur and Environmental Engineer, Flying Squad, TNPCB, Erode.

Action against any operation of illegal units brought to the notice of the Board is taken through District Co-ordination Committee headed by District Collector. For the past two years power supply to nine units was disconnected and dyed material also seized.

Closure and disconnection of power supply order issued to consented six units based on the shortfall in operation and performance of ZLD plants.

Monthly samples are collected and analysed at the following locations:

Karur Muncipality STP outlet which joins with Panchamadevi PWD irrigation channel.
Ground water sample at both banks of River Amaravathi. River water samples at Thirumukkadalur 8 KM downstream side of Karur Town and the confluence point of River Amaravathi with River Cauvery.

7. It is further submitted that the Hon'ble Madurai Bench of Madras High Court has filed as Suo Motu W.P. (MD) No.17508 of 2020 based on the same news item published in the Indian Express newspaper on 27.11.2020 regarding pollution of river Amaravathy and it is stated in the news item, sewage and solid waste from Karur Municipal area is disposed into the River and illegal discharge from textile dyeing and bleaching units are also gaining access to the river and thereby polluting the river.

8. It is respectfully submitted that the Hon'ble Court in its order dated 09.12.2020 directed the TNPCB to collect water samples in Rettaivaikkal (abandoned PWD Channel) running within the Karur Town at five locations. The Hon'ble High Court also directed to collect and send counter samples to King Institute, Chennai.

9. It is respectfully submitted that, the District Environmental Engineer, Karur collected samples from the Page 7 of 46 following locations on 10.12.2020 between 11.20 A.M. and 03.20 P.M.:

(i) Rettaivaikkal at Chinnandankoil water tank road (Near Veema Engineering Works)
(ii) Rettaivaikkal at Pasupathi Layout (Near BSNL headquarters)
(iii) Rettaivaikkal at Walkers Club under light house bridge
(iv) Rettaivaikkal at small bridge adjacent to Kamaraj market
(v) Rettaivaikkal at Rathinam Salai nearby Neelimettu Street
(vi) Pancahmadevi Vaaikkaal adjacent to Murugan saw mill.
(vii) Mettuvaaikkal at Rayanur Road in front of Sri Lakshmi Agency Godown One set of samples sent for Analysis to Tamil Nadu Pollution Control Board, Advanced Environmental Laboratory, Salem on 10.12.2020 at 07.00 PM. One set of Counter samples sent for analysis at Salim Ali Center for ornithology and natural history, Coimbatore on 10.12.2020 at 09.15 PM, since King Institute, Chennai is not accepting effluent samples for analysis.

The comparative statement of report of TNPCB and Salim Ali Centre is submitted herewith as Annexure.

Under the above circumstances, it is humbly prayed that this Hon'ble National Green Tribunal (Southern Zone) may be pleased to pass such further or other orders as this Hon'ble Tribunal may deem fit and proper in the facts and circumstances of this case and thus render justice."

6. The Joint Committee also filed a report dated 20.05.2021 e-filed on 22.05.2021 and received on 24.05.2021 which reads as follows:

"1.0 Preamble:
A case has been registered by Hon'ble National Green Tribunal, Southern Zone, Chennai on its own motion-SUO MOTU based on the newspaper report published in the Indian Express Page 8 of 46 dated 27th November, 2020 under the caption "A Cooum in the making in Karur?" and an Order was passed on 15th December, 2020stating that;
"... 8. In order to ascertain the genuineness of the allegations made in the paper report and action taken by the local body to resolve the issues, we feel it appropriate to appoint a joint committee comprising of 1) the District Collector, Karur District, or a Senior Officer not below the rank of Assistant Collector or Sub Divisional Magistrate deputed by the District Collector, 2) a Senior Scientist from Central Pollution Control Board (CPCB), Regional Office, Chennai, (3) a Senior Officer from the Tamil Nadu State Pollution Control Board as designated by its Chairman, 4) a Senior Officer not below the rank of Superintending Engineer of Public Works Department and Water Resources Organisation (WRO) of that area, (5) the Municipal Commissioner, Karur Municipality to inspect the area in question and submit a factual as well as action taken report, if there is any violation found, including assessment of environmental compensation for damage caused on account of any alleged illegal activity resulting in pollution to the water in the river Amaravathy.
9. The committee is directed to inspect the industries in that area and ascertain as to whether they are having proper effluent treatment discharge system and is there any illegal or unauthorised untreated discharge being made by any of the industries in that district to the Amaravathy river so as to cause the pollution of the river water
10. The committee is also directed as to ascertain as to whether there is any illegal discharge of untreated sewage from the municipal area to the river
11. The committee is also directed to ascertain the existence and functioning of any Effluent Treatment Plant (ETP), Sewage Treatment Plant (STP) and requirement of a Common Effluent Treatment Plant (CETPs) in that area and its operation level as to whether it meets all the norms by testing the inlets and outlets of the effluents being treated by these units and if there is any violation found, what is theaction proposed to be taken against such units.
Page 9 of 46
12. The committee is also directed to ascertain as to whether Karur Municipality is complying with the provisions of the Solid Waste Management Rules, 2016 in its letter and spirit in disposing the waste generated including the sewage and whether there is any illegal discharge of such things into the river which causes pollution and whether the direction issued by the Principal Bench of National Green Tribunal in O.A. No. 606 of 2018 have been complied with.
13. The committee is also directed to test the water quality of the river in respect of all criteria's including the presence of heavy metals, Total Coliform (TCL) and Faecal Coliform (FCL) apart from ascertaining the quality of water in the river and if there is any contamination found, ascertain the source and suggest the necessary steps to be taken for removing the contamination and make the water to the potable level.
14. The committee is also directed to suggest the proposed actions to be taken against the erring units and on that basis; the regulating authorities are directed to take steps against such units so as to prevent such illegal activities being continuedin that area.
15. Central Pollution Control Board (CPCB), Regional Office, Chennai will be the nodal agency for co-ordination and for providing all necessary logistics for this purpose.
16. The committee is directed to submit the report to this Tribunal on or before 22.02.2021 by e-filing..."

A copy of the said Order is placed at Annexure - 1 Joint committee submitted to the Hon'ble tribunal stating that the inspection was carried out and water samples have been taken and requested six weeks time for submission of the final report.

Hon'ble tribunal has considered the request of the joint committee and further directed the committee to file the report on or before 12.04.2021. The copy of the said Order is placed at Annexure

- 2. Joint Committee could not complete the report for want of additional information and requested for further four weeks time. Hon'ble tribunal directed the committee, District Administration and Karur Municipality to file the report on or before 25.05.2021. The copy of the said Order is placed at Annexure - 3.

Page 10 of 46

2.0 Constitution of Joint Committee In compliance with the above said Order and with the approval of Member Secretary, Central Pollution Control Board, Delhi; Regional Director, Chennai has constituted the Joint Committee (Copy of Constitution Order is enclosed as Annexure -

4) with the following members based on the nominations receivedfrom the respective Departments:

S. Name of Member & his Contact details Organization No designation Mob no & email ID District Revenue Officer, 9445000918
1. District Collector, Karur & Karur dro.tnkar@nic .in Shri.P. Muthusamy, Superintending Engineer, Chief Engineer, WRD, 9865227961 &
2.

PWD, WRD, Coimbatore Region sewropalani@gm Palani ail.com The Commissioner, Shri. I. Nakkiran 8489916703 &

3. Karur Municipal Municipal Engineer commr.karur@tn.

Council, Karur gov.in Shri. K. Ravichandran, Chairman, Tamilnadu 8056042243 &

4.. District Environmental Pollution Control tnpcbkarur@gmai Engineer, Karur District Board, l.com Chennai Central Pollution 9243424389 & Shri. S. Karthikeyan, Control Board,

4. skarthikeyan.cpcb Scientist C Regional @nic.in Directorate, Chennai 3.0 Meetings of the Joint Committee:

In compliance to Hon'ble NGT Order dated 15.12.2020, CPCB as a Nodal Agency Organized a meeting on 3rd February, 2021 through video conference to discuss the Order issued by Page 11 of 46 Hon'ble NGT, deliberated the issues, and made a strategical plan to address the issues. All the members of the Joint Committee attended the meeting through video conference. The Committee has decided unanimously to carry out the area inspection of Karur town and joint monitoring of River Amaravathy, Discharges, ETP, CETP, STP, MSW treatment facilities and priority industries on river bed on 11th and 12th February, 2021 tentatively.
As decided by the joint committee in its meeting held on 3rd February, 2021, a joint committee meeting was convened by the District Revenue Officer, Karur on 11th February, 2021 at 10.30 AM at his Office. All the members of the Joint Committee attended the meeting in person and discussed the terms of reference of the Hon'ble NGT Order, finalized the river stretches to be surveyed to identify all the drains/discharges in the stretch, STP, ETPs, CETPs and industries to be inspected based on the pollution potential. Accordingly, two days program was prepared and finalized. Further discussed the Monitoring protocol, sampling methodology, parameters to be analysed and concluded the same. Exhibits are placed at Annexure - 10.

4.0 Inspection of the Area by Joint Committee:

As decided in the joint committee meeting, the committee carried out the inspection of the following area on February 11, 2021:
4.01 Inspection of industries in Karur: DEE, TNPCB, Karur appraised the joint committee stating that Prior to the year 2012, there were 487 Textile processing units in and around Karur town. Out of 487 units, 391 units were members of one of the eight CETPs and balance 96 units were having their own individual ETP. The treated effluent from these units was discharged either directly or indirectly into irrigation canals of River Amaravathy.

During the year 2011 - 2012, all 487 units and 8 CETPs in Karur were totally closed down and power supply to the units were disconnected since the units failed to establish the ZLD system based on the direction issued by Hon'ble High Court of Madras in WP no.: 24560/2003 filed by the agriculture association.

At present, 68 units have established Zero Liquid Discharge Page 12 of 46 (ZLD) system comprises of Effluent Treatment System, RO Plant and Reject Management System and operating the units with valid consent of TNPCB. Out of 68 units, only 61 units are in operation and remaining seven units are not in operation for the last one year. TNPCB has issued closure Order on 16.12.2020 to five units due to violations observed in ZLD system. Thus, the units are treating their effluent, recycling their entire treated water in the process and not allowed to discharge any effluent.

The Joint Committee inspected two ZLD systems established at M/s. Atlas Processing Mills, Village Andankoil, Karur and M/s. Navarang Dye works, Sanapiratty Village, which are located within 500 m from the river bed and assessed its adequacy.

4.02 Common Effluent Treatment Plant (CETP): It is reported that in Karur area, eight CETPs were in Operation. In accordance with the direction issued by Hon'ble High Court of Madras in WP no.: 24560/2003 filed by the agriculture association, all the eight CETPs has been closed down, since they failed to adopt the ZLD system. The joint Committee inspected two CETPs located within 500 m from the river bed namely

1) M/s Karur Andankoil Pollution Control Ltd., S.F No. 1812, Andankoil West Village, Karur Taluk

2) M/s Amaravathy Pollutech Ltd., Andankoil East Village, Karur Taluk.

Verified that both the CETPs found closed and witnessed that removal of recovered sludge was under progress.

4.03 Effluent Treatment Plant (ETP): Consent has been granted to those units only, which have ZLD system. Thus, there is no standalone operational ETP in Karur area.

4.04 Sewage Treatment Plant (STP): Inspected the STP and verified the facilities available. In order to evaluate the performance of STP, it is decided to collect the samples of Inlet, Aeration tank and Outlet.

4.05 Discharge points into River Amaravathy: Survey for eleven km stretch of River Amaravathy has been carried out by the joint committee in order to identify the discharge points into the River Amaravathy. During the survey, the joint committee has identified six discharge points into the river. All the six discharges Page 13 of 46 of the Karur into River Amaravathy namely Periandankoil, AVS- AVR Colony, Chinnandankoil, Light House (Under Old bridge), Sungagate, Kolantagoundanur and T. Sellandipalayam were surveyed, observed its nature & basic characteristics of discharges and decided to collect the samples to assess its pollution potential.

4.06 River Amaravathy:

Eleven km stretch starting from Check Dam at Andankoil village i.e, upstream of Karur town to Downstream of Karur town at Sanapiratti was surveyed to assess the quantity and quality of river water and to find out any discharges into the river. On the day of inspection, scanty flow was noticed in the River and it is reported that the flow was 10 Cusecs.
4.07 Solid Waste Management/Treatment Facilities:
Inspected the Bio- methanation Plant, Micro Compost Centre (MCC), and material recovery facility in Integrated Solid Waste Management Facility at Arasu Colony, Vangal Road, Bio-Mining site/Legacy waste processing centre, Village Panchamadevi and MCC at Arugampalayam in order to ascertain the facilities available and assess itsperformance.

5.0 Joint Monitoring :

Based on the outcome of area inspection, the joint committee carried out the monitoring of the following places on February 12, 2021.
Based on the area inspection and observation of the joint Committee, samples were collected to assess the quality of River Amaravathy & the pollution potential of discharges and evaluate the performance of STP. The details of samples collected are as follows:
No. of samples S.No Matrix . collected 1.0 River Amaravathy 4 Page 14 of 46 2.0 Discharges into River Amaravathy 6 3.0 Sewage Treatment Plant, Karur 3 4.0 CETPs, 8 nos All were Closed down fully 5.0 ETPs No standalone ETP Total 13 List of sampling point and the parameters analysed, is presented below:
List of samples collected and parameters to be analysed Samples from River Amaravathy S.No Sampling point Geo-coordinates Parameters analysed .
       Check Dam at                                    pH, TDS, DO,
                                  N 10o 57' 5.7636"
       Andankoil,                                      BOD,COD, Cl,
1.     Upstreamof Karur                                SO4, PO4,
                                  E 78o 2' 26.1276"
       town, left bank                                 TKN, Total
                                                       Nitrogen,Ammonical
                                                       Nitrogen,
                                                       NO3-N, NO2-N,
       Madurai Bye-              N 10o 56' 33.1008"
                                                       Fluoride, Total
       pass bridge
2.                                E 78o 3' 25.8156"    Alkalinity, P-
       (NH44), left
       bank                                            Alkalinity,
                                                       Total
                                                       Hardness, Ca, Mg,


       Thirumanilayur             N 10o 57' 5.7636"    Na, K, SAR, RSC,
3.     Padikattuthurai,                                Boron, Total
       Rightbank                  E 78 2' 26.1276"
                                       o
                                                       Coliform, FC


                            Page 15 of 46
                                                              &




                                                             Heavy metals ( Cu,
              Sanapiratti                                    Cd, Cr (Total &
                                         N 10o 57' 5.7636"
              village near Old                               Hexa), Iron, Mn,
        4.    Dindugal Water                                 Ni,Pb & Zn)
                                         E 78o 2' 26.1276"
              Supply Scheme,
              Right bank


             Sample of discharges:


                                                                               Comes
                                                     Side
                                                                               under
S.No.         Name of                    Geo-         of         Area of
                                                                               UGDS
                the                  coordinates    River         source       area or
                discharg                             bank
                                                                                 not
                e
        Periyar        Nagar,                                Chinnandan
                                     N 10o 57' 6"
        Opp. Periandankoil                                       Koil East       Not
                                                     Left
1.      Over Head Tank                                            village    covered
                                     E 78o 2' 34"
                                                              Panchayat

        AVS-AVR Colony,          N 10o 57' 13"                Ward No           Partly
2.      Chinnandankoil                               Left           19       covered
                                     E 78o 4' 17"

        Light House (Under       N 10o 57' 19"                Ward No           Partly
3.      Old bridge),                                 Left           27       covered
                                     E 78o 4' 56"

                                     N 10o 57' 6"             Ward No            Non
4.      Sungagate discharge                         Right           30       covered
                                     E 78o 5' 12"

        Near Animal                  N 10o 57' 3"             Ward No            Non
5.      Husbandary office,                          Right
                                                                    37       covered
        Kolantagoundanur             E 78o 5' 35"




                                 Page 16 of 46
                                     N 10o 56' 40"                 Ward No         Non
6.        T. Sellandipalayam                          Right          41         covered
                                     E 78o 4' 22"

Parameters analysed; pH, TSS, TDS, BOD, COD, Ammonical Nitrogen, Oil &Grease & Heavy metals ( Cu, Cd, Cr (Total & Hexa), Mn, Ni, Pb & Zn) Samples from STP:
              Name of the                Geo-
     S.                                                       Parameters
               discharge          coordinates
     No.                                                       analysed

                                  N 10o 57' 6"      pH,    TSS,     TDS,
     1.     Inlet to STP                                   BOD,     COD,
                                  E 78 2' 34"
                                            o
                                                    Ammonical        Nitrogen      &      TotalNitrogen

                                                    pH, TSS,       TDS,     BOD,
                                 N 10 57' 13"
                                        o
                                                    COD,
            Outlet to STP
     2.                                             Ammonical Nitrogen, Total
                                  E 78o 4' 17"
                                                    Nitrogen, SAR, RSC, Oil &
                                                    Grease and TC & FC
                                 N 10o 57' 19"
     3.     Aeration Tank                                     DO & MLSS
                                  E 78o 4' 56"



In Toto, four samples of river, six samples from discharge points into the river and three samples from STP and thus a total of thirteen samples were collected, sealed and sent to Advance Environmental Laboratories, TNPCB, Salem for further analysis. Based on the test report, the analytical test data has been interpreted as follows 5.1 River Water Quality:
Characteristics of samples collected from six Discharge Points;
During the survey, the joint committee has noticed untreated sewage is discharged into River Amaravathy at six points, Page 17 of 46 collected the samples from each discharge points and analysed for the Environmental pollutant parameters. Analytical Test Report of discharges is placed at Annexure 5. The Analytical Test Data of those discharges are presented below;

                                    Analytical Test Data of discharges
                                                                          Near
                         Periyar
                                        AVS-      Light                  Animal         T.
                         Nagar,                              Sunga-
S.     Parameter                        AVR       House                  Husban-      Sellandi
                         Perianda                              gate
No.                                    Colony     corner                  dary        palayam
                          n-koil
                                                                          Office

1.    pH at 25 oC          6.72         6.77       6.48       6.68         6.9         6.68

2.    TDS           at
                           796          1584        884       1584        1592         2132
      180oC

3.    TSS                  80            44           52       128         48           64

4.    Fixed
      Dissolved            760          1524        828       1496        1512         2040
      solids

5.    BOD                  30            30           33       84          74           78

6.    COD                  192          208         200        416         376          384

7.    Oil           &
                           <4            <4        <4           4           4            4
      Grease

8.    Ammonical
      Nitrogen      as     6.16         10.1       6.72       12.9        11.2         14.6
      NH3-N

9.    Copper              BDL           BDL        BDL        BDL         BDL          BDL

10.   Zinc                BDL           BDL        BDL        BDL         BDL          BDL

11.   Lead                BDL           BDL        BDL        BDL         BDL          BDL

12.   Nickel              BDL           BDL        BDL        BDL         BDL          BDL

13.   Cadmium             BDL           BDL        BDL        BDL         BDL          BDL



                                      Page 18 of 46
 14.   Manganese         BDL          BDL        BDL        BDL          BDL            BDL

15.   Total
                        BDL          BDL        BDL        BDL          BDL            BDL
      Chromium

16.   Hexavalent
                        BDL          BDL        BDL        BDL          BDL            BDL
      Chromium

17.   Flow               Sca      Moderate      Low      Moderate     Moderate         Low
                         nty
Note.: All values are in mg/Lexcept pH. BDL - Below Detection Limit.
The pH of the drain is varying from 6.48 to 6.9, which are in line with normal characteristics of sewage.
TSS of the discharges varies from 44 to 128, which are in line with normal characteristics of sewage. Normally it will be around 100.
TDS of the discharges normally depends on the TDS of raw water used. It varies from 796 to 2132 mg/L, which is slightly more than the normal value. The reason may be due to higher TDS in raw water being consumed.
BOD of the discharges varies from 30 to 84. Normally BOD of a typical sewage will be around 300 mg/l. Here it is on lower side, may be due to dilution. On further enquiry, it is informed by the Officials of Karur Municipality based on the repeated analysis of STP inlet samples that the BOD of sewage from Karur area will be normally around 100 mg/L only.
Oil & Grease of the discharges are lies in between near and below detection level.All elements of heavy metals are below detection level.
From the test report, it is inferred that the discharges are nothing but the untreated sewage from nearby households. Where the average BOD comes to 54.8 mg/Lagainst the Standard of 30 mg/l. Therefore, the discharge of untreated sewage should be stopped immediately. Therefore, it should be channelized to STP Page 19 of 46 for treatment. If the same is not technically feasible, onsite decentralised wastewater treatment should be installed. The operation of such system should be self-sustained, once it is stabilized after its establishment.
• Water quality of River Amaravathy:
Water quality with respect to physicochemical parameters and heavy metals were assessed. During the site inspection, the joint committee observed the scanty flow and a flow of 10 cusecs was reported. The flow was on one side of the bank and following a small stream. The Analytical Test Report of river samples is placed at Annexure - 6.
Water quality with respect to physicochemical parameters:
*BIS Upstream ofKarur town Sanapiratti at rightbank AndanKoil CheckDam, Thirumanilayur atright Drinking water quality NH44 Madurai bypass bridge S. Parameters Standards bank No. Acceptable/ Permissible, mg/l
1. pH 6.5 to 8.5 7.27 7.05 7.2 7.3
2. 5.0 mg/Lfor DO 6.0 6.7 6.8 6.8 bathing 3. TDS at 180oC 500/2000 512 556 576 612 4. FDS -- 492 532 556 596 5. COD -- 16 16 16 16

6. BOD 3.0 mg/L for outdoor <2 <2 <2 <2 bathing

7. Total 200/600 208 208 220 208 Alkalinit y Page 20 of 46

8. Phenolpthalein

-- 20 8 4 8 Alkalinity

9. Chloride 250 /1000 84 100 124 138

10. Fluoride 1.0 /1.5 0.051 0.063 0.075 0.046

11. TKN -- 1.68 2.24 2.24 2.24

12. Ammonical Nitrogen, 0.5/0.5 0.56 1.12 1.12 1.12 NH3-N

13. Nitrate 45 0.064 0.042 0.085 0.057 Nitrogen, NO3

14. Nitrite

-- 0.031 0.045 0.392 0.527 Nitrogen, NO2

15. Total Nitrogen -- 1.77 2.33 2.72 2.82

16. Dissolved Phosphate, asPO4 -- 0.019 0.023 0.056 0.134

17. Total Phosphate, asPO4 -- 0.05 0.06 0.125 0.412

18. Sulphate 200/400 69 78 59 57

19. Hardness asCaCO3 200/600 228 240 248 244

20. Calcium as Ca 75 48 49 52 53

21. Magnesium 30/100 26 28 28 27

22. Sodium, Na -- 67.8 74.2 81.9 87.9

23. Potassium, K -- 5.6 5.9 6.3 9.5

24. Boron 0.5 BDL BDL BDL BDL Page 21 of 46

25. Cu 0.05/1.5 BDL BDL BDL BDL

26. Cd 0.003 BDL BDL BDL BDL

27. T.Cr 0.05 BDL BDL BDL BDL

28. H Cr -- BDL BDL BDL BDL

29. Iron 0.3 0.288 0.39 0.158 0.037

30. Mn 0.1/0.3 BDL BDL BDL BDL

31. Ni 0.02 BDL BDL BDL BDL

32. Pb 0.01 BDL BDL BDL BDL

33. Zn 5/15 BDL BDL BDL BDL

34. % Sodium -- 39 40 41 43

35. SAR -- 2.0 2.1 2.3 2.5

36. Total 500 MPN Coliform, for outdoor 4.5 11 12 5.5 MPN/100 ML bathing

37. Faecal Coliform, -- <1.8 4.5 4.5 1.8 MPN/100 ML All values are in mg/L except pH, SAR, TC, FC & %Na.

In India, CPCB has identified water quality requirements in terms of a few characteristics, known as primary water quality criteria. Further, Bureau of Indian Standards has also recommended water quality parameter for different uses in the standard IS 2296:1992. Each water use demands specific quality need. Therefore, to set the standard for the desire quality of a water body, it is essential to identify the uses of water in that water body. In India, the Central Pollution Control Board (CPCB) has developed a concept of designated best uses of Water. According to this, out of the several uses of water of a particular body, the use which Page 22 of 46 demands highestquality is termed its designated best use. In light of above, the water quality criteria A and its designated best use is Drinking Water Source without conventional treatment but after disinfection, which demands highest quality of water has been considered in the present case.

Compliance status with respect to Designated Best uses of water - A Class Dam, Thirumanilayurat NH44 Madurai Sanapiratti at bypass bridge Upstream of Karur town right bank AndanKoil S.No Criteria for A ClassDBU right bank Check .




1.0       Total Coliform MPN/100ml                Complied                                 Complied                          Complied                          Complied
          shall be                                       with                                with                               with                             with
          50 or less
2.0       pH between 6.5 and8.5                   Complied                                 Complied                          Complied                          Complied
                                                         with                                with                               with                             with

3.0       Dissolved             Oxygen            Complied                                 Complied                          Complied                          Complied
          6mg/L or more                                  with                                with                               with                             with

4.0       Biochemical             Oxygen
                                                  Complied                                 Complied                          Complied                          Complied
          Demand 5 days 20 oC, 2mg/L
                                                         with                                with                               with                             with
          or less


But in the NGT Order dt.:15th December, 2021 says "Steps to be taken to make the water to the potable level", therefore the drinking water Standards notified by BIS has also been considered for data interpretation of river Amaravathy water quality.

From the Analytical Test Data presented above, it is inferred that pH: The pH of the river water along Karur stretch fluctuates from 7.05 to 7.3. Thus the acidity and alkalinity balance of the river water along the Karur stretch is not disturbed and complying with the standard of potable water.

Page 23 of 46

DO: The dissolved Oxygen of the river water along Karur stretch fluctuates from 6.0 to 6.8 mg/L. DO is more than 5.0 mg/L at all locations. It shows that the health of the river is maintained.

Total Dissolved Solids (TDS): The TDS of the river water along Karur stretch fluctuates from 512 to 612 mg/L. TDS follows the increasing trend towards downstream and not in acceptable value of 500 mg/L but is within permissible value of 2000 mg/L. This may be due to the natural phenomena of geological terrain of the river bed.

Fixed Dissolved Solids (FDS): The FDS of the river water along Karur stretch ranges from 492 to 596 mg/L. FDS follows the increasing trend towards downstream.

Bio-Chemical Oxygen Demand (BOD): BOD of the river water along Karur stretch is below the detection level. BOD is less than 3.0 mg/L at all four location. It indicates that the organic load in the river is not significant.

Nitrate Nitrogen - NO3-N: The Nitrate level ranges from 0.042 to 0.085. Nitrate along the stretch is not in significant level and is within the acceptable range.

Chloride: The chloride level ranges from 84 to 138 and is within the acceptable range. Even though the level is not significant but follows the increasing trend towards the downstream.

Fluoride: The Fluoride level ranges from 0.046 to 0.075 and is within the acceptable range.

Hardness: The hardness of river water varies from 228 to 248 mg/L. Slightly more than the acceptance level of 200 mg/L but well within the permissible value of 600 mg/L. The value indicates that the river water is moderately Hard water.

Heavy metals: All heavy metals except Iron are below detection level. Iron level in the river stretch is complied with the Standards and marginally exceeds in one location.

Page 24 of 46

Faecal Coliform: is a specific indicator of faecal contamination originating from human or animal wastes and is an important indicator of water quality - especially in waters where sewage or slurry is discharged. Presence of Faecal Coliform in the river water shows the contamination of sewage.

The quality of river water at all four locations is meeting with the BIS drinking water Standards except for the parameters TDS, FDS & Hardness. These two parameters TDS & Hardness are not within the acceptable range but are in permissible range. An increase of 100 & 16 mg/L and 19.5% & 7% is observed in case of TDS & Hardness respectively. The marginal increase may be due to the characteristics of local terrain.

The quality of river water is meeting the requisite standards in spite of six discharges of raw sewage may be due to the following reasons;

 In the river, scanty flow was observed and follows a small stream.

 The quantity of sewage discharge is less and percolates locally  Because of that the discharge of sewage is not getting mix up with the riverwater  But during flood or full flow, the sewage may get mix up, contaminates the river water and will have impact on the quality of river water.

The quantity of sewage discharge is not sufficient enough either to flow through the river or to get mix up with river water as stated above. Because of this reason, the river water is meeting the requisite Standards in spite of discharge of untreated sewage.

• Inspection of the industries:

The joint committee inspected two industries located within 500 m from the river bed namely Page 25 of 46
1. M/s. Atlas Processing Mills,1. M/s. Atlas Processing Mills, Sivasakthi Nagar, Periyandankoil Post, Karur
2. M/s. Navarang Dye Works, Village Sanapiratti, Village Narikkattiyur, S . Vellalapatty post, Karur - 639 004 The joint committee examined the Zero Liquid Discharge (ZLD) system for its adequacy.

The ZLD system at M/s. Atlas Processing Mills consists of Effluent Treatment Plant, RO system, MEE, ATFD, Filter press and Decanter. ETP consists of Receiving tank, Flocculation tank, Primary Clarifier, Aeration tank, Secondary Clarifier, Colour removing treatment, Dual Media filter, Filter Press, Decanter and Sludge Drying Beds. The reject management system consists of 4 stages RO system, Multi Effect Evaporators (4 effects), Agitated Thin Film Dryer (ATFD) and Solar Evaporation Pond (SEP). From the operational parameters DO & MLSS of Aeration tank, the Joint Committee assessed the performance of Activated Sludge Process. From the Flow, TDS value and colour of reject of each stage of RO System and MEE and salt collection at ATFD, the joint committee assessed the performance of ZLD system. The treated effluent (RO permeate and MEE condensate) is recycled. The recovered salt to the tune of 1.5 TPD is packed in Poly bag and disposed off in M/s. Tamilnadu Waste Management Ltd., Viruthunagar for safe disposal. Thus, the unit is complying with ZLD system. Since there is no discharge of treated effluent, sample of final treated effluent could not be collected. vital parameters of ZLD system are placed below;

   System                                  Flow ( L/Hr)        TDS      (mg/L)

                  Feed                       36,000                  5500
RO stage 1        Permeate                   24,000                  230

                  Reject                     12,000                10500

                  Feed                        8,000                10500
RO stage 2        Permeate                    4,000                  400




                           Page 26 of 46
                    Reject                     4,000               19000

                   Feed                       4,000               19000
RO stage 3         Permeate                   2,250                500

                   Reject                     1,750               38000

                   Feed                        6000               38000
RO stage 4         Permeate                    2400                600
(or) nano
                   Reject                      3600               58000
filtersystem
                   Feed                        2000               58000
MEE                Condensate                  3800                250

                   Reject                      200               315000

                   Feed                        500               315000
ATFD               Salt generation          80 Kg /hour             -



The ZLD system at M/s. Navarang Dye Works, Sanapiratti village consists of Effluent Treatment Plant, RO system, MEE, ATFD, Filter press and Decanter. ETP consists of Collection tank, Primary Clarifier, Aeration Tank, Secondary Clarifier, Tertiary Clarifier, Treated Water storage tank, Filter press and Sludge drying beds. From where, after Ultra filtration, the treated water fed into RO system of 3 stages, MEE, ATFD and SEP. The RO permeate and MEE condensate is recycled. Whereas the recovered salt is packed in poly bags and disposed off in M/s. Tamilnadu Waste Management Ltd., Viruthunagar for safe disposal. From the operational parameters DO & MLSS of Aeration tank, the Joint Committee assessed the performance of Activated Sludge Process. From the Flow, TDS value and colour of reject of each stage of RO System and MEE and salt collection at ATFD, the joint committee assessed the performance of ZLD system. Since there is no discharge of treated effluent, sample of final treated effluent could not be collected. vital parameters of ZLD system are placed below;

Page 27 of 46
      System                              Flow ( L/Hr)   TDS        (mg/L)

                           Feed             15000             9120


RO stage 1               Permeate           10000             940

                          Reject            5000          19700

                           Feed             6000          19700


RO stage 2               Permeate           3000              690

                          Reject            3000          34700

                           Feed             3500          34700


RO stage 3               Permeate           1500              1060

                          Reject            2000          46900

                           Feed             3000          46900

                       Condensate           2000              400
MEE

                          Reject             600          170000

                           Feed              200          170000


ATFD               Salt generation       60 Kg/Hour            -

Both the units are having valid consent from TNPCB. Full technical details of the treatment system are placed at Annexure - 7 & 8 respectively.

• Common Effluent Treatment Plant (CETPs):

The joint Committee inspected two CETPs located within 500 m from the river bednamely
2. M/s Karur Andankoil Pollution Control Ltd., S.F No. 1812, AndankoilWest Village, Karur Taluk,
3. M/s Amaravathy Pollutech Ltd., Andankoil East Village, Karur Dt KarurDistrict.
Page 28 of 46

Both CETPs found closed. Sludge is packed in poly sacks and kept in open yard within the CETP premises. Leachate collection facilities are provided. Witnessed the removal of recovered sludge for co-processing in cement kilns was under

progress. It is reported that all the eight CETPs in the area are closed and not in operation at present. Disposal of recovered sludge is under progress in phased manner depends on the co- processing capacity. The CETP federation has reported that the disposal of entire recovered sludge will be safely disposed off for co- processing within six months time. The status of CETP is placed below;
CETP Sludge Accumulated/Disposal details as on 12/02/2021 Numberof Quantity Sl. Name of the CETP member ofsludge Status of No. andaddress units stored in storage Tonnes
1. M/s Karur Vanchi DyeingEnviro Tech Ltd., 23 Nil -

S.F No.15/2, Balambalpuram,Karur

2. M/s Karur Andankoil Disposal of Pollution Control Ltd., sludge for Co S.FNo. 1812, Andankoil Processing is in 19 2497 WestVillage, Karur progress. So far Taluk 1500 T disposed

3. M/s Karur Karuppampalayam Stored in open EnviroTech Ltd., 48 4507 land in PVC Karuppampalayam, bags Karur.

Page 29 of 46

4. M/s Karur Thiruvai Dyeing Stored in open Enviro Ltd., 55 9434 land in PVC Thirumanilayur,Karur bags

5. M/s Karur Sukkaliyur Stored in open CETPCompany Ltd., 64 8461 land in PVC Sukkaliyur, Karur bags

6. M/s Karur Taluk Dyeing Stored in open &Bleaching ETP Co., 20 4433 land in PVC Ltd., Arugampalayam, bags Karur

7. M/s Karur Stored in open SellandipalayamPollution land in PVC 118 5664 Control Ltd., bags T.Sellandipalayam, Karur

8. M/s Amaravathy Disposal of sludge PollutechLtd., for Co Processing Andankoil East is inprogress. So 44 4400 Village,Karur far4000 T disposed Accumulated Quantity of CETP sludge as on 12/02/2021 Total 39396 T accumulat ed Quantity Quantity of Sludge sent to M/s. Chettinad Cement 5500 T Corporation Pvt Ltd for co-processing Balance Quantity as on 12/02/2021 33896 T Sewage Treatment Plant:

Out of 48 wards in Karur Municipal area, 1 to 32 wards are having Under Ground Drainage systems (UGDs) except the Page 30 of 46 newly developed areas. The sewage (Black water) from the households in these wards are pumped to STP (15 MLD) for treatment. Vital parameters of Karur are summarised as below:
S.N            Parameter                         Number
o.

 1. Population                                   2,41,458


 2. Total Households                                  67436


 3. Water supply                                    119 LPCD


 4. Total water supply                              28.84 MLD


 5. Sewage generation                               23.07 MLD


 6. Black water generation                           7.5 MLD


 7. Grey water generation                           15.57 MLD


 8. Sewage reaching STP                              7.5 MLD




From the above table, the committee has observed that Black water only reaches the STP. 35.5% of Sewage reaches the STP and remaining 64.5% ie., 15.57 MLD of sewage finds its own way and partly discharged into River Amaravathy.

The 15 MLD Sewage Treatment Plant in Karur, works based on extended aeration technology. STP consists of collection-cum- equalisation tank, aeration tank, clarifier, maturation pond and Sludge Drying Beds. In order to assess the Environmental performance of STP, a sample of Inlet, Outlet and aeration tank have been collected and analysed the relevant parameters. Around 5.5 to Page 31 of 46 7.5 MLD of sewage is treated in the STP. Analytical Test Report of STP is placed at Annexure - 9.

The analytical test data is presented below;


         Analytical Test Data of STP


                                                        Standards
 S.                                                      for the    Compliance
               Parameters        Inlet         Outlet   discharge      status
No.


1.                                                                   Complied
      pH at 25 oC
                                 6.68           7.02     6.5-9.0
                                                                        with

2.                                                                      Not
      TSS at 105oC               132            168       100
                                                                     Complied

3.    Fixed Dissolved            1284          1248        NN           NA
      Solids
4.                                                                      Not
      BOD                         15             38        30
                                                                     Complied

5.    COD                        144            232        NN           NA

6.    Ammonical Nitrogen,
                                 9.52           8.4        NN           NA
      as NH3-N

7.    Sodium Absorption
                                  3.4           2.4        NN           NA
      Ratio (SAR)

8.    Residual Sodium
                                 1.06          0.805       NN           NA
      Carbonate

9.    Total Coliform             7000          4900        NN           NA


                             Page 32 of 46
 10.                                                                         Not
      Faecal Coliform           3100            2200          <1000
                                                                         Complied

      Aeration Tank - Dissolved Oxygen - Nil                     Mixed Liquor
      Suspended


      Solids (MLSS) - 0.1

All Values are in mg/L except pH. NN - Not notified.

From the above Test Report, it is observed that the TSS, BOD and Faecal Coliform of treated sewage from STP are not meeting the required standards for the discharge.

pH: The acidity and alkalinity balance is not disturbed during the treatment process and further complied with the Standards for the discharge of sewage.

Total suspended solids (TSS): TSS has increased from 132 to 168 mg/L instead decreasing, not complying with the Standards for the discharge of sewage and also not meeting its own designed value of 50 mg/L. Sedimentation in equalisation tank and clarification of aerated water is not taking place in the clarifier. The increase in TSS may be due to the contribution from natural organic substances like Algae growth; this shows that the sewage finds its own way instead of undergoing the treatment.

Bio-Chemical Oxygen Demand (BOD): The Committee observed the low strength sewage in inlet ie., BOD of the inlet was 15 mg/L. But reported that the BOD of the sewage normally varies from 80 to 120 mg/L. The reason for the low value of BOD may be due to the secondary washings, since the sample was collected during the lean period ie., in the noon. The BOD has increased from 15 to 38 mg/L instead of decreasing and thus not only complying with the Standards for the discharge of sewage but also its own designed value of 20 mg/L. The increase in BOD may be due to the natural organic substances like Algae growth, this shows that the treatment is not taking place.

Page 33 of 46

Faecal Coliform (FC): Faecal Coliform in the final treated sewage of STP was 2200 against the standards of 1000 MPN/100ml. Only 30% reduction is observed. The treatment system supposed to remove the harmful bacteria i.e, FC completely. Whereas the treatment system removed only 30%. Thus, it confirms that the partial/natural treatment is taking place in the STP.

DO & MLSS from Aeration tank: In order to ensure the effectiveness of operation of STP, sample from aeration tank for the parameter Dissolved Oxygen (DO) & Mixed Liquor Suspended Solids (MLSS) was collected. The analytical Test Report reveals that DO was nil against not less than 2.0 mg/L and MLSS was 0.1 against the value in between 3500 and 4000 mg/L. In absence of DO and MLSS, it is not possible to stabilize the Organic substances biologically.

Sludge Drying Beds: The joint committee did not find any accumulation of sludge in sludge drying beds during the inspection of STP.

In light of above, the joint committee has concluded that the sewage is just passing through the STP and partial treatment is taking place in its natural way. Operation of STP was not carried out professionally. The BOD of raw sewage will be around 300 mg/Lin an average, whereas here it is around 100 mg/L only. One third of the reference value. The Analytical Test Report of repeated analysis of raw sewage confirms the same. The Joint Committee had a lengthy discussion on the same.

Irrigation water quality Classification: As per plan, the treated sewage from STP is supposed to be used for land application/irrigation and reported that the treated sewage is used for irrigation. In view of this, the following parameters are analysed to ensure its safe use for irrigation and confirm that any discharge from any of the Textile processing units is getting mix up with the sewage.



S.No      Parameter and its        Classification         Suitability



                        Page 34 of 46
 .            value

1.     pH - 7.02                         Excellent
                                                           Suitable for
2.     SAR - 2.4                           Fair             irrigation
3.     RSC - 0.805                       Excellent

The partially treated sewage from the STP is discharged into nearby irrigation Channel. From there, the partially treated sewage is used for irrigation.

Gaps observed in STP:

 Oil and Grease trap and its allied facilities namely collection, storage and safe disposal mechanism for scum are not in place.
 Bar Screen Chamber and its allied facilities namely collection, storage and safe disposal mechanism for grit and floatables are not in place.
 Chlorination or UV radiation or any other disinfectant mechanism is not in place for safe disposal of treated sewage so that Faecal Coliform in the final treated waste water is absent.
 Failed to maintain the desired level of Dissolved Oxygen and Mixed Liquor Suspended Solids (MLSS) in the Aeration tank.
Action proposed to be taken against STP:
The operator of STP may be directed to operate the STP professionally based on the operational parameters as referred above so as to achieve the standards for the discharge of treated sewage.
The raw sewage from the balance area (16 wards), newly developed areas and the adjacent Andankoil village Panchayat area which are not covered under the UGD system is discharged into the River Amaravathy (Left bank) and Storm water drain (Right bank of the River). The TNPCB has directed the Karur Municipality to provide STP with UGDS covering the balance municipal area and Page 35 of 46 stop discharging the untreated sewage. The Hon'ble Madurai Bench of Madras High Court has also given direction in this regard to Karur Municipality vide order dt. 28/09/2016 in WP(MD)No 15295 of 2012. But still untreated sewage from part of Karur area is discharged directly into the River Amaravathy (Left bank) and Storm water drain (Right bank) for want of land to establish STP.
Solid Waste Management:
Karur Municipality consists of 48 wards spread over 53.26 Sq. Km. The population of Karur Municipality is around 2.5 lacs. The scenario of Solid Waste generation in Karur Municipality is presented below;
                                      Wet Waste,         Dry Waste,
   Category            Numbers                                            Total,
                                          TPD                TPD
                                                                           TPD
Households               67426                   4            11            53
                                                 1
Commercial
                         13766               4                7             11
establishments

Industrial
                           215               -                3                 3
units

Bulk
                           77                    1            2.5          12.5
generators
                                                 0
Total                    81484                   5           23.5          78.5
                                                 5
Inert & C & D
                       As above              -                3                 3
waste

                       Grand Total                                         81.5



Micro Compost Centre MCCs: Wet (Bio-gradable) waste from households are collected at door steps in a segregated at source manner on daily basis. The same is transported to the nearby Micro Compost Centre (MCC) for treatment. There are twelve MCCs in Page 36 of 46 Karur Municipality area. The capacity of each centre varies from 3 to 5 TPD. Each centre will have 14 to 16 pits. Thus 41 TPD wet waste is treated in twelve MCCs.
On receipt of wet waste at MCC, non-bio degradable items are removed manually. The screened materials are shredded in mechanical shredder. While shredding the wet waste, Effective Microorganisms (EM) ball will be introduced. The shredded wet waste is fed into the compost pit layer by layer per pit per day. Seven pits will be chosen in first cycle and will be fed for 3 rounds. Thus 21 days will take to complete the first cycle. Remaining 21 days the pit will be left for composting. Periodic turning of waste during compost process is being carried out manually by heaping from one end to another end. In the second cycle, the feeding will be carried out in the remaining seven pits for twenty-one days in three rounds. On completion of 42 days, the compost will be ready and sold at the centre itself to the farmers on first come first basis. Now, first set of seven pits will be ready for feeding. Thus the cycle repeats and goes on.
Gaps observed:
Failed to
1. mix the bulk agent namely garden waste, Farm yard Waste, Coconut fibre (Peat), wood chips, wooden pieces, Straw, shredded coconut shells, plant cuttings, Mulch, husk, bran and saw dust, of suitable proportion, along with the shredded wet waste before feeding into the compost pit in order to maintain the particle size and Oxygen level.
2. Establish suitable rotary screen to screen the compost and non-composted materials.
3. The bio degradable materials which is not fully composted may be recycled as a bulking agent
4. Provide hard surface pad (Concrete floor) to dry the compost
5. Provide shed of adequate capacity to store the compost Page 37 of 46
6. Maintain the stock register for the management of Compost stock Bio-Methanation Plant, 5 TPD: Food, Vegetable and Fruit waste are transported to Bio-

methanation plant. The waste is checked for any other non bio degradable waste manually and handpicked. The bio degradable waste is grinded into slurry form and fed into the digester. The bio-gas so generated is used to operate the machineries and lighting established in Integrated Solid Waste Management facility.

Gaps observed: Bio gas was stored in the Bladder instead of the gas holder.A puncture was noticed in the bladder holding the biogas.

Bulk Waste: The Bulk waste generated from 64 Kalyana Mandapams, 10 Hotels and 3 Educational Institutions are treated in 18 Onsite Compost Centre (OCC) on their own. 34 bulk waste generators use a common facility.

Dry Waste: The dry waste is collected at door step twice in a week. Dry waste so generated from Karur Municipal area is transported to the Integrated Solid Waste Management facility in the village Arasu Colony. There, the dry waste is screened for recyclable and non recyclable waste manually. The waste namely coconut shells, Paper, Glass, Plastic, iron items are hand-picked and sold off to scrap dealer. The non recyclable waste items namely polythene bags, rubber, tyres and cloths are shredded, baled and forwarded to cement industries for co- processing. The non usable items, inert are stored along with C & D waste in Arikkapalayam yard at Salem bye pass road and used for land filling.

Legacy waste: The legacy waste accumulated over the period of 30 years spread over 13.68 acres in the Village Panchamadevi. The accumulated waste is estimated Page 38 of 46 to be around 1,41,731 m3 and the legacy waste processed so far is 1,27,558 m3 on the day of inspection. Around 86% of legacy waste has been processed so far. Reclamation of dumping yard and Bio-mining of legacy waste is under progress.

Bio remediation of the legacy waste is carried out by adopting coning compost. The stabilised waste is screened mechanically by adopting 3 stages & SCADA controlled Trommels. The recyclable material so recovered is sold off to scrap dealer and RDF is forwarded for co-processing. Bio-earth is sold off to farmer as manure. Inert is forwarded to C&D waste yard at Arikkampalayam, Salem Bye pass road for safe storage and land- filling as per the request.

Summary of Joint committee findings based on the Field observations:

I. All 68 textile processing units in Karur area have established ZLD system and no discharge of trade effluent either treated or untreated is allowed. II. The joint committee surveyed the eleven km Karur stretch of River Amaravathy starting from Check Dam, Andankoil -Upstream of Karur town to Sanapiratti village near Old Dindugal Water supply scheme - Downstream of Karur town and did not notice any illegal or unauthorised untreated discharge being made by any of the industries into the River Amaravathy.
III. From the Analytical Test Report of river water, the joint committee has inferred that the river is meeting the Designated Best Use criteria notified by CPCB. From the parameters namely Colour, TDS, FDS, BOD and heavy metals, the joint committee is ruling out the contamination of any trade effluent. The presence of Faecal Coliform in the river water reveals that there is the possibility of inception of Domestic effluent. IV. The Test Report of river water revealed that the Page 39 of 46 Amaravathy River water is fit for drinking use with conventional treatment and bathing purposes in Karur stretch.
V. The joint committee has inspected the site in question and made the enquiry. On enquiry, the joint committee came to know that the canal was made to partially divert the river water from one bank to another bank to the temple padikattuthurai (Bathing Ghat), by the nearby temple trust on occasion of Kumbhabhishekam festival performed at Vanjileeswar Temple, Bramma thertham Road, Karur during last week of Nov-2020 for the convenience of devotees. Circumstantial evidences substantiate the above claim and Committee did not find any abnormalities in that area other than the above stated facts.
VI. In light of above, the joint committee did not assess any Environmental Compensation for damage caused on account of any alleged illegal activity resulting in pollution to the water in the river Amaravathy. VII. All CETPs in Karur area were closed way back in 2011-2012. At present none of the CETP is in operation. Only removal of accumulated sludge stored in polythene bags is going on depends on the capacity of co-processing unit.
VIII. All the units having ETP alone and failed to establish the ZLD system were closed way back in 2011-2012. Therefore, no standalone ETP is in operation. IX. Out of 48 wards in Karur Municipality limit, Ward no.
1 to 32 are covered under UGD scheme except the newly developed areas. The sewage (Black water) from these areas is channelized to Sewage Treatment Plant (STP), where it is treated partially. The treated sewage is discharged into the nearby irrigation canal. From the canal, the treated sewage is utilised for irrigation by the farmers.

X. In case of balance 16 wards and newly developed Page 40 of 46 area, the sewage is directly discharged into the River Amaravathy (Left bank) and storm water drain (Right bank). It is reported that from storm water drain, it is utilized for irrigation by the nearby farmers. All storm water drain on right bank, has provision of shutters to discharge the sewage into River Amaravathy for emergency use. It is reported that during flood time only the shutter will be opened. XI. Wet waste from the households in Karur Municipality is collected at door step in a segregated at source manner on daily basis. Wet (Bio- degradable) waste is collected daily. The wet waste is shredded and composted in twelve Micro Compost Centres. Further improvement is required.

XII. Food, Vegetable and fruit waste are grinded into slurry form and fed into Bio-Methanation plant for Anaerobic digestion to produce bio-gas. The bio gas so produced is used in operating the equipment and lighting installed at Integrated Solid Waste Management facility.

XIII. Bulk waste generators are treating their waste on their own.

XIV. Dry waste is collected twice in a week. Fresh dry waste is transported to Integrated Solid Waste Management Facility for materials recovery by handpicking and gravity separation through mechanical screening. Recyclables are handpicked and sold off to scrap dealers. Non recyclables and combustibles (RDF) is forwarded for co-processing. Inert is forwarded to C&D waste storage yard for safe storage and disposal for land filling.

XV. Bio-mining of Legacy waste is under process. But failed to provide pollution control measures and devices to check the fugitive and source emission Suggestions of the Committee:

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The Joint Committee proposed following actions to be taken by Tamilnadu Pollution Control Board and Karur Municipality to prevent illegal discharges and inception of sewage & garbage into river Amaravathy:
TNPCB may be directed to  Continue the constant and continuous vigil and monitoring mechanism of all water polluting industries in Karur area and ensure the Zero Liquid Discharge.
 Continue the constant vigil on Karur river stretch for any illegal discharges into the river Amaravathy by deploying patrolling in order to prevent any occasional discharge too.  Continue the monthly monitoring of River Amaravathy and assess its qualityfor any deterioration.
Karur Municipality may be directed to  stop discharging the untreated sewage into the river Amaravathy immediately and to take necessary steps to channelize the grey water from UGD covered area and sewage from uncovered UGD area to STP so as to treat the same  Take sincere efforts to operate the Sewage Treatment Plant in a more efficient and scientific manner and should be managed professionally.
 take sincere efforts to operate the Micro Compost Pit in a more professional manner and make additional facilities to mix the bulking agent to the shredded wet (Bio-degradable) waste so as to maintain the particle size and Oxygen level, hard surface Pad to dry the compost, Sieve to screen the compost & not fully converted compost, storage yard for storing the compost and the facility to recycle the not fully converted compost.
 to provide the hard surface pad for process & utility area & all approach roads and wind breaking walls to contain the Page 42 of 46 fugitive emission at Bio-mining site.
 Create awareness among general public to keep the unsoiled polythene bags safe, storing it and hand over the same in bulk preferably in Bundle form to the sanitary workers so as to simplify the stress on its management.  Develop Miyawaki forest as planned without fail in the reclaimed land to the tune of 13.68 acres, after completion of bio-mining.
By considering all the above facts, the Hon'ble National Green Tribunal may pass appropriate Order(s)/Direction(s) as deemed fit."
7. It is seen from the reports submitted by the Joint Committee as well as the Pollution Control Board that no industrial effluent is being discharged into the Amaravathi River and water quality in the river meets the inland surface water quality and most of the pollution that is being caused on account of the untreated sewage being discharged into the river.
8. As regards the implementation of the Solid Waste Management Rules, 2016, it was revealed from the earlier report submitted by the Karur Municipality that they have started the bio-mining process for disposal of the existing legacy waste and 80% of the legacy waste was disposed of.

But they have not mentioned anything about the present status and they have also not filed any report regarding the gaps found by this Tribunal in the earlier report submitted by the Karur Municipality. Further, it appears from the report that water samples were taken from the nearby areas of Page 43 of 46 the industry alone and not from the areas that has been pointed out in the newspaper report.

9. It is also mentioned in the newspaper report that the people in the locality had stopped the earth mover which was digging the channel inside the river to channel waste water from the nearby industries and in spite of the opposition, the digging resumed. Neither the Karur Municipality nor the Public Works Department (PWD) officials had looked into the matter and submitted any report regarding the allegations made in the newspaper report in this regard.

10.The committee that has been appointed by this Tribunal also did not go into the question as to whether any internal illegal channels have been provided from any of the industries to discharge their sewage into the river without treating the same. So under such circumstances, we feel it appropriate to direct the Tamil Nadu Pollution Control Board and the committee to consider these aspects as well and submit a detailed report regarding the specific allegations made of making illegal channels from the nearby industries for discharging their sewage or other industrial effluents illegally at the place pointed out in the newspaper report.

11.They are also directed to ascertain the location of the area which is covered by the photograph mentioned in the newspaper report and ascertain as to whether allegations made by them in this regard are correct Page 44 of 46 or not and if it is correct, what is the nature of action taken by the authority to prevent such illegal activities.

12.The Public Works Department (PWD) is also directed to file an independent report regarding the mechanism provided by them to protect Amaravathi River from pollution and encroachment. The Karur Municipality is also directed to submit a detailed report regarding the steps taken by them for implementing the recommendations made by the committee to be carried out from their side to avoid discharge of untreated sewage from Ward No.33 to 48 which were subsequently included in their municipality in respect of which no sewage treatment facilities have been provided.

13.The committee as well as the concerned departments are also directed to file their independent statement and also the compliance report as directed by this Tribunal on or before 28.06.2021 by e-filing in the form of Searchable PDF/OCR Supportable PDF and not in the form of Image PDF along with necessary hardcopies to be produced as per Rules.

14.The Registry is directed to communicate this order to the members of the committee, Tamil Nadu Pollution Control Board, Public Works Department, Karur Municipality apart from informing the same to the Chief Secretary, State of Tamil Nadu, Principal Secretaries of Environment, Public Works Department & Water Resource Organization Page 45 of 46 and Irrigation by e-mail for their information and compliance with the directions.

15.For consideration of further report, post on 28.06.2021.

Sd/-

...................................J.M. (Justice K. Ramakrishnan) Sd/-

...........................E.M. (Dr. K. Satyagopal) O.A. No.257/2020, 25th May, 2021. Mn.

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