National Green Tribunal
Ram Dass vs State Of Rajasthan Through Chief ... on 20 February, 2024
Item No. 01
BEFORE THE NATIONAL GREEN TRIBUNAL
CENTRAL ZONE BENCH, BHOPAL
(Through Video Conferencing)
Original Application No. 67/2022(CZ)
Ram Dass Applicant(s)
Versus
State of Rajasthan & Ors. Respondent(s)
Date of completion of hearing and reserving of order : 24.01.2024
Date of uploading of order on website : 20.02.2024
CORAM: HON'BLE MR. JUSTICE SHEO KUMAR SINGH, JUDICIAL MEMBER
HON'BLE DR. A. SENTHIL VEL, EXPERT MEMBER
For Applicant (s): Mr. Harendar Neel, Adv.
For Respondent(s) : Mr. Rohit Sharma, Adv.
Mr. Dharamvir Sharma, Adv.
Mr. Yadvendra Yadav, Adv.
Ms. Pallavi Singh, Adv.
Mr. Shoeb Hasan Khan, Adv.
Mr. Kamlesh Sharma, Adv.
ORDER
1. The main question involved in this application is extending applicability of Graded Response Action Plan (GRAP), applicable to Fixed Chimney Bull Trench Kilns (FCBTK) to other coal fired brick kilns, including those using zig-zag technology in the State of Rajasthan to maintain the air quality with regard to carrying capacity for improving effectiveness of safeguards and the regulatory measures to minimize the impact of air pollution by operation of brick kilns and to enforce the prescribed norms in absence of carrying capacity of the environment to sustain such activity.
2. In India, air quality standards are measured in terms of the Air Quality Index (hereinafter "AQI"). The AQI was launched in India on 17-10- 2014 by the Ministry of Environment and Forests. According to the press release of 1 the Press information Bureau of the same date, it 2 consists of a comprehensive set of parameters to monitor and asses the air quality. The AQI considers eight pollutants (PM10, PM2.5, NO2, SO2, CO, O3, NH3, and Pb), and based on the levels of these pollutants six categories of AQI ranging from "Good" to "Severe" have been prescribed. The index also suggests the health effects of the pollution category wise.
3. The adverse effects of these extreme levels of air pollution spare no one the young, the old, the infirm and even the future generations. A study of the data of the Global Health Depository of the World Health Organization reveals that India has the world's highest death rate from chronic respiratory diseases and that about 1.5 million people in India die annually due to indoor and outdoor pollution. The Kolkata-based Chittaranjan National Cancer Institute (CNCI), in a study commissioned and handed over to the Central Pollution Control Board, found that key indicators of respiratory health, lung function to palpitation, vision to blood pressure, of children in Delhi, between four and 17 years of age, were worse off than their counterparts elsewhere. It also found that more than 40% of the school children suffer from lung damage (Landmark Study Lies Buried, 02.04.2015, The Indian Express). We note with apprehension that there are nascent studies suggesting that pollution can lower children's IQ, hurt their test scores and increase the risks of autism, epilepsy, diabetes and even adult-onset diseases like multiple sclerosis (Holding Your Breath in India, 29.05.2015, The New York Times).
4. When we refer to these extreme effects, we are not merely referring to the inconvenience caused to people, but to abject deprivation of a range of constitutionally embedded rights that the residents ought to have enjoyed.
Needless to state, the grim situation of air quality adversely affected the right to education, work, health and ultimately, the right to life of the citizens, and this Tribunal is constitutionally bound to address their grave 2 concerns. (M.C. Mehta v. Union of India [M.C. Mehta v. Union of India, (1998) 6 SCC 60] , [M.C. Mehta v. Union of India, (1998) 9 SCC 589] , M.C. Mehta v. Union of India [M.C. Mehta v. Union of India, (1998) 8 SCC 648] and M.C. Mehta v. Union of India [M.C. Mehta v. Union of India, (1998) 8 SCC 206])."
5. The contention of the applicant is that in severe air quality condition, coal fired brick kilns cannot be allowed to operate. There is a need of the time to switch over to the PNG. There must be inter-se distance of atleast 500 meters to maintain the air quality in the location of brick kilns, further when brick kilns start they should not be allowed to start simultaneously, but their firing should be staggered to avoid adverse impact on the environment.
6. Categories of air quality and its adverse health effect can be noticed from following tables extracted from the judgment of the Hon'ble Supreme Court in Arjun Gopal & Ors. v. UOI & Ors.2017 (1) SCC, 412.
Table 1
AQI Associated Health Impacts
Good (0-50) Minimal impact.
Satisfactory May cause minor breathing discomfort to
(51- 100) sensitive people.
Moderately May cause breathing discomfort to people with
polluted lung disease such as asthma, and discomfort to
(101-200) people with heart disease, children and older
adults.
Poor May cause breathing discomfort to people on
(201-300) prolonged exposure, and discomfort to people
with heart disease.
Very Poor May cause respiratory illness to the people on
(301-400) prolonged exposure. Effect may be more
pronounced in people with lung and heart diseases.
Severe May May cause respiratory impact even on healthy (401- 500) people, and serious health impacts on people with lung/heart disease. The health impacts may be experienced even during light physical activity.
3Table 2 AQI Category, Pollutants and Health Breakpoints AQI category PM10 PM2.5 NO2 O3 CO 8-hr SO2 24- NH3 24-hr Pb 24-hr (Range) 24hr 24-hr 24-hr 8-hr (mg/m3) hr Good (0-50) 0-50 0-30 0-40 0-50 0-1.0 0-40 0-200 0-0.5 Satisfactory 51-100 31-60 41-80 51-100 1.1-2.0 41-80 201-400 0.5-1.0 (51-100) Moderately 101-250 61-90 81-180 101-168 2.1-10 81-380 401-800 1.1-2.0 polluted (101-200) Poor 251-350 91-120 181-280 169-208 10-17 381-800 801-1200 2.1-3.0 (201-300) Very poor 351-430 121-250 281-400 209-748* 17-34 801-1600 1200-1800 3.1-3.5 (301-400) Severe 430+ 250+ 400+ 748+* 34+ 1600+ 1800+ 3.5+ (401-500)
7. While considering the matter this Tribunal found that certain assessment was required to be filed by the appropriate authorities for proper consideration and these parameters are -
i. Adoption of standard operating practices for Zig-Zag kilns operations.
ii. Preventing/reducing air pollution generation at source by change of brick kilns technology and/or shift to cleaner gaseous fuels Tunnel Kiln Technology.
iii. Use of PNG/CNG.
iv. Air Pollution Control Devices (End-of-the Pipe
Technologies).
v. Applied research/pilot testing for improvement in brick
manufacturing process.
8. The matter was taken up by this Tribunal on 17.03.2023 and this Tribunal observed as follows :-
i. We are conscious that brick kilns may be necessary. Our object is not to stop any legitimate business activity but to enforce the right to breathe fresh air which is right to life. The source apportionment studies, show that brick kilns contribute 5-7% or upto 8% PM. Air pollution Control devices to be installed by the polluting sources including the brick kilns need to comply not only the consent standards but are also the Ambient Air 4 Quality norms and available assimilative capacity of the region. If the right to fresh air is not enforced, the consequences of brick kilns beyond carrying capacity of the air quality in the area are disastrous in terms of deaths and air borne diseases. This will be contrary to the mandate of the Constitution and the environmental law, particularly the principle of „Sustainable Development‟. It is well established that deteriorated ambient air quality in terms of PM10 and PM2.5 affects respiratory system particularly, the lungs which may make individuals more vulnerable to get other related fatal diseases.
ii. Accordingly, we direct CPCB to constitute a Committee of five experts to suggest ways and means, if any, by which sustenance of brick kilns activities may be viable. It will be open to CPCB to nominate in-house or other Experts. The CPCB may also explore viability of PNG as replacement of coal and other best practices in terms of fuel used, at other places. It will be open to the brick kilns owners/associations to give any other suggestions or alternatives for consideration by CPCB in spirit of collaboration with a view to find a solution. The CPCB may constitute an expert Committee within three weeks which may give its report within six weeks thereafter. Further report may be furnished in the matter before the next date by e-mail at [email protected] preferably in the form of searchable PDF/ OCR Support PDF and not in the form of Image PDF.
iii. The Committee referred above must include in the report the month wise data of SAAQMS with respect to PM concentration for the year 2021-2022, district wise with regard to PM 2.5 and PM 10 in addition to the report on i) Impact of brick kilns operation on loss/degradation of top soil, ii) study involving Carrying Capacity Assessment of brick kilns with adequate samples in terms of number of brick kilns and days for which monitoring be conducted, iii) Evaluation of the performance of brick kilns against the background concentration and carrying capacity of the area and iv) Impact on Brick Kilns operation on ambient air in categorized different districts of State of Rajasthan.
iv. The question is not merely of an individual brick kiln not emitting pollution or the extent of contribution of the brick kilns taken separately, but of the capacity of the area being already air 5 polluted and unable to take the load of pollution. When there is no carrying capacity in the area for further air pollution, we find it difficult to permit operation of the closed brick kilns to uphold the „Sustainable Development‟ principle. When even without operation of the brick kilns the air quality is not within the norms, the impact of operation of the brick kilns cannot be ignored. Thus, we find it difficult to accept the submission that the individual brick kilns maintaining the prescribed standards for discharge of emissions are entitled to operate or that they be allowed to operate on the ground that pollution caused by the brick kilns is less than other pollution from other sources irrespective of carrying capacity of the area. The fact remains that brick kilns add to the air pollution and thereby affect right of citizens to breathe fresh air.
v. The main reason for air pollution by brick kilns is use of coal etc. as fuel. The pollution can be minimized if the fuel which is currently used is considered to be replaced by cleaner fuels like PNG by appropriate modification in design not adding to the PM load."
9. Notice were also sent to the respondents including the CPCB and the CPCB in its reply has submitted that the MoEF&CC has already notified the regulations for operation of brick kilns, the relevant portions are quoted below :-
"In the Environment (Protection) Rules, 1986, in the Schedule-1, for entry at Sl. No. 74, the following entry shall be substituted, namely: -
"74 Brick Particulate matter in stack emission 250 mg/Nm3 Kilns Minimum stack height (Vertical Shaft 14 m (at least 7.5m Brick Kilns) from loading platform) Kiln capacity less than 30,000 16 m (at least 8.5m bricks per day from loading platform) Kiln capacity equal or more than 30,000 bricks per day Minimum stack height (Other than 24m Vertical Shaft Brick Kilns) 27m Kiln capacity less than 30,000 bricks per day Kiln capacity equal or more than 30,000 bricks per day 6 Notes:
1. All new brick kilns shall be allowed only with zig-zag technology or vertical shaft or use of Piped Natural Gas as fuel in brick making and shall comply to these standards as stipulated in this notification.
2. The existing brick kilns which are not following zig-zag technology or vertical shaft or use Piped Natural Gas as fuel in brick making shall be converted to zig-zag technology or vertical shaft or use Piped Natural Gas as fuel in brick making within a period of (a) one year in case of kilns located within ten kilometre radius of non- attainment cities as defined by Central Pollution Control Board (b) two years for other areas. Further, in cases where Central Pollution Control Board/State Pollution Control Boards/Pollution Control Committees has separately laid down timelines for conversion, such orders shall prevail.
3. All brick kilns shall use only approved fuel such as Piped Natural Gas, coal, fire wood and-/or agricultural residues. Use of pet coke, tyres, plastic, hazardous waste shall not be allowed in brick kilns.
4. Brick kilns shall construct permanent facility (port hole and platform) as per the norms or design laid down by the Central Pollution Control Board for monitoring of emissions.
5. Particulate Matter (PM) results shall be normalizcd at 40% CO2 as below:
PM (normalized) : (PM (measured) x 4%,)/ (o/" of CO2 measured in stack), no normalization in case CO2 measured 24%. Stack height (in metre) shall also be calculated by formula H=l4Q0r (where Q is SO2 emission rate in kg/hr), and the maximum of two shall apply.
6. Brick kilns should be established at a minimum distance of 0.8 kilometre from habitation and fruit orchards. State Pollution Control Boards/Pollution Control Committees may make sitting criteria stringent considering proximity to habitation, population density, water bodies, sensitive receptors, etc.
7. Brick kilns should be established at a minimum distance of one kilometre from an existing brick kiln to avoid clustering of kilns in an area.7
8. Brick kilns shall follow process emission/fugitive dust emission control guidelines as prescribed by concerned State Pollution Control Boards/Pollution Control Committees.
9. The ash generated in the brick kilns shall be fully utilized in-house in brick making.
10. All necessary approvals from the concerned authorities including mining department of the concerned State or Union Territory shall be obtained for extracting the soil to be used for brick making in the brick kiln.
11. The brick kiln owners shall ensure that the road utilized for transporting raw materials or bricks are paved roads.
12. Vehicles shall be covered during transportation of raw material/bricks".
10. It is further contented by the CPCB that the use of clean fuel for industrial operations has already been deliberated by the commission for Air Quality Management in National Capital Region and adjoining areas and vide letter No. (F. No. A-110018/01/2021-CAQM/8218-40) dated 23.06.2022 it is published as follows :-
"F. No. A-110018/01/2021-CAQM/8218-40 dated 23.06.2022 Subject: Standard list of approved fuels for various applications across NCR.
WHEREAS, emissions due to use of polluting fuels for various industrial, vehicular, domestic and miscellaneous purposes contribute significantly to the degradation of air quality in the NCR and adjoining areas and accordingly a consistent need has been felt to switch over to lesser polluting and cleaner fuel in the NCR;
2. WHEREAS, the Central Govt., State Govts. in the NCR and the Govt. of the NCT of Delhi have been continually making efforts to move towards use of cleaner fuels across various sectors contributing to the overall air quality in the region,
3. WHEREAS, the Govt. of NCT of Delhi and the State Govts. of Haryana and Rajasthan have an approved fuel list for various 8 applications in their respective states, Including the districts in the NCR, the State of Uttar Pradesh presently does not have an approved fuel list of its own;
4. WHEREAS, a perusal of such approved fuel lists as above indicates that there are still some heavily polluting fuels featuring in the approved fuel lists like coal, HSD, Naptha, LDO etc., the lists are not comprehensive, non-uniform and vary significantly from state to state,
5. WHEREAS, the matter related to use of clean fuels for industrial applications has already been deliberated extensively in the Commission from time to time and shifting of industries to PNG / cleaner fuels has been a priority area for the Commission and to this effect, statutory directions for permissible fuels for industrial applications in the NCR have already been issued in terms of Direction Nos. 53, 62, 63 and 64 dated 04.02.2022, 17.03.2022, 18.05.2022 and 02.06.2022 respectively;
6. WHEREAS, the concerns of air pollution are uniform across NCR and particularly from the standpoint of a common airshed approach for the entire NCR and adjoining areas, it is desirable to have a unified list of approved fuels for various applications across all sectors in the entire territorial jurisdiction of the NCR towards aiming for uniform and better emission standards and an overall improved air quality in the region;
7. WHEREAS, in pursuance of the Order of Hon'ble Supreme Court of India dated 16.12.2021 (Civil) No 1135 in the matter of Aditya Dubey (minor) and Ant v/s UOI & Ors, directed the Commission to with a view to "find permanent solution to the air pollution menace occurring every year in Delhi and NCR, suggestions may be invited from the general public as well as the experts in the field, an Expert Group was constituted by the Commission to examine and deliberate upon all such suggestions and proposals;
8. WHEREAS, the Expert Group in their report in the subject matter have also strongly recommended phasing out usage of heavily polluting fossil fuels like coal, diesel oil light diesel oil (LDO), Pyrolysis oil, Naptha etc. across NCR and to this end, have recommended a "Common" approved fuel list for NCR, incorporating cleaner fuels, to the extent possible;9
9. WHEREAS, the proposed standard/common fuel list for NCR was also deliberated upon as an agenda item in the recently held meeting of the full Commission on 25.03.2022 and considering the need to optimally balance the imperatives of sustainability of operations as also the emissions from use of various types/categories of fuels that have a direct bearing on the air quality, the Commission approved the standard fuel list for uniform adoption of clean fuels across the entire NCR, barring some exceptions;
10. NOW, THEREFORE, in exercise of its powers under Section 12 of the Act, the Commission hereby directs for adoption of a standard list of fuels in NCR as annexed;
11. The aforesaid standard list of approved fucks shall come in force w.e.f. 01.10.2022 (for areas where PNG infrastructure and supply is already available) and 01.01 2023 (for other areas where the PNG supply is still not available). In effect, the approved fael list shall be completely in force in the entire NCR w.e.f. 01.01.2023.
12. Strict compliance of the above noted directions of the Commission be ensured by all concerned."
11. Learned counsel for the State PCB, Rajasthan has argued that the MoEF&CC, New Delhi has issued notification for sitting criteria, location, distance and clustering and pollution control measures required for the brick kilns. In furtherance of the compliance of the above directions the State PCB and the State Government had also issued a notifications and directions for establishment and operation of brick kilns vide office order dated 01.04.2022 which is quoted below :-
"Guidelines for Abatement and Control of Pollution in Brick Kiln Industry In compliance of NGT order passed on dated 10/11/2021 in the matter of O.A.No.262/2020. Hakam Singh & Anr. Vs. State of Rajasthan & Others, the Rajasthan State Pollution Control Board, hereby issues guidelines for establishment of new brick kiln units 10 and mandatory pollution control measures with new as well as exiting brick kiln units.
1-General i. Brick kiln units may be established on a piece of land duly converted, for the purpose of establishment of brick kiln units, under relevant provisions of Rajasthan Land Revenue (Conversion of agricultural land for non-agricultural purposes in rural areas) Rules, 2007 and subsequent amendment rules, 2016 or on piece of land allotted by competent authority of State Government for establishment of brick kiln units.
ii. Brick Kiln units may also be established on Khatedari land for which conversion is not required under Rule 6 of the Rajasthan Land Revenue (Conversion of agricultural land for non-agricultural purposes in rural areas) Rules, 2007 and subsequent amendment.
iii. In cases where capacity of existing brick kiln is proposed to be enhanced by installing additional plant and machinery or otherwise (except replacement), it will be treated as the case for establishment of new units.
iv. The brick kiln units shall be required to comply with provisions laid down in all other related laws in force. The Consent to Establish/Consent to operate issued under the Air Act and/or Water Act is limited to control of pollution and statutory provisions contained in these Acts and does not absolve project proponent from other statutory obligations prescribed under any other law or instrument.
v. If competent authority for land conversion, on the basis of distance or any other issue, cancels land conversion and intimates to the Board about cancellation of land conversion. then consent to establish or operate, as the case may be, shall be revoked and/or refused by the State Board and the competent authority for land conversion shall be solely responsible to take necessary action for removal of the brick kiln unit from the site.11
vi. Similarly, in case of cancellation of Short Term Permit issued to the Brice Kiln units Consent to Establish or Consent to Operate, as the case may be, issued under provisions of Air Act, 1981 and/or Water Act, 1974 for adequacy of pollution control measures shell be revoked/refused by the State Board after receipt of information from Mining Department.
2. Standards To Be Achieved Back height to be provided with different type of brick kilns and emission standards have been ratified by Ministry of Environment and Forest (MoEF), Govt. of India as per Environment (Protection) Rules, 1986 (as amended time to time) vide G.S.R. 543 (E) 22/1/2009 (Annexure II). There are other activities in brick manufacturing process like mining/quarrying of clay, handling & transportation of raw material/bricks which contribute to ambient air pollution.
MoEF has also Notified National Ambient Air Quality Standards dated 16th November 2009 (Annexure III). These standards are mandatory to be achieved by the Brick Kilns units.
3. A Pollution Control Measures Required Following measures must be provided by brick kiln owners for abetment of pollution:-
i. Scientifically designed gravitational settling chamber for proper retention/ collection of Particulate matter/unburnt fuel part.
ii. Approach road within the premises of brick kiln area should be pucca / stabilized with brick bats etc. iii. Bricks should be laid in a staggered manner for baking to entrap maximum particulate matter at the source itself.
iv. Safe and adequate infrastructure facility for stack monitoring as per CPCB guideline(Annexure) v. Active haul roads inside the premises should be adequately wetted with water.12
vi. Wheel cleaning facilities should be provided, for delivery trucks leaving the works for the removal of mud.
4. Plantation and Other Issues The piece of land shall be utilized for establishment of brick kiln unit in such a manner that plantation up to norms of 33% of total area of land can be carried out leaving sufficient spaces for utilities, office building and keeping peripheral plantation to the extent possible. The plantation must be carried out as per guidelines issued by the Board vide circular dated 15.7.04.
Similar practice shall be adopted for plantation in case of brick kiln units established or proposed to be established on STP's, after demarcation of areas within STP's. However if area/land is not suitable for plantation purposes, the project proponent may carry out plantation on an adjacent areas or any other suitable areas after duly informing he concerned Regional Officer.
Ground water shall not be abstracted without prior N.O.C. from Central Ground Water Authority.
A Sign Board showing the name, address and capacity of the brick kiln unit should be displayed at the entrance of the site.
The brick kiln area (converted/allotted/demarked at STP) shall be clearly demarcated by providing boundary walls/fencing at all sides.
5. Restrictions vide Taj Trapezium and various matters from Hon'ble NGT (A) Taj Trapezium Notification As per Hon'ble Supreme Court directions issued on 10/05/1996 in the case of M.C. Mehta vs. Union of India & ors, no brick kiln shall be allowed to be established or operated within 20 km radial distance of the Taj Mahal and other significant monuments in the Taj Trapezium Zone and Bharatpur Bird Sanctuary.
13(B) Brick kiln units located in the NCR Region of the State shall comply with the order passed by Hon'ble NGT in the following matters-
i. O.A.No.1016/2019, Utkasrsh Panwar V/s CPCB & Others regarding conversion of brick kiln to zigzag structure.
ii. O.A.No.21/2014, Vardhman Kaushik V/s Union of India regarding use of cleaner fuel such as natural gas (PNG/CNG), LPG, Bio Gas etc in compliance of CPCB letter dated 27/11/2020.
(C) All Brick kiln units shall comply with the orders passed by Hon'ble NGT in the various matters from time to time.
6. PROCEDURE TO SUBMIT APPLICATION FOR CONSENT TO ESTABLISH AND CONSENT TO OPERATE i. Applications for consent in establish and consent to operate shall be submitted on line through RPCBMIS Portal along with prescribed documents and consent fees as per foe notification 2016.
ii. All the applications shall be examined first by pre screening cell in terms of documents submitted and deficiencies, if any, shall be communicated online. In case of complete application the Project Proponent shall be asked to deposit the same fee as per foe notification, 2016.
iii. As per categorization of Board, Brick kiln units are categorized in Orange Category and the power to dispose off such applications is delegated to Regional Offices of the State Board.
iv. Checklist of documents for the applications of Consent to Establish & Consent to Operate is attached.
All concerned are directed to ensure strict compliance of the Guidelines while dealing with the issues related with brick kiln industry."
12. It is further submitted that the State of Rajasthan has issued office order dated 02.06.2020 mentioning that the brick kilns units fall under category 14 orange and Department of Environment, Govt. of Rajasthan has framed rules named Rajasthan (Prevention and Control of Pollution) (Amendment Rules, 2016) whereby the fee and the period of consent has been prescribed for different categories of industries.
13. It is further submitted that State PCB is having Continuous Ambient Air Quality Monitoring Stations (CAAQMS) operational at various locations in the Jaipur, Alwar, Bhiwadi, Ajmer, Udaipur, Kota, Pali, Jodhpur (Total 10 Nos). The statement of annual average of parameters being monitored at the CAAQMS from January, 2022 to December, 2022 is annexed herewith and marked as Annexure-R/2 (Collectively).
14. The AQI as reported are as follows :-
Yearly Average: Jan. 2022 to Dec. 2022 NO2 NH3 SO2 CO O3 PM10 PM2.5 Station Name AQI µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Police Comm. 60.55 64.98 14.68 1.47 31,52 142.7 70.27 151 Jpr Psy. Center 40.87 37.40 12.0 0.84 44,29 4 107.45 52.28 111 _ Jpr Sci. Park 47.04 4 5 . 9 2
15.66 0 . 8 7 48.97 131.69 55.96 -
Jpr 6Alwar 21.81 23.23 13.0 0.74 20,26 92.19 41.54 123 92 Bhiwadi 64.40 81.62 19.80 1.02 20.28 203.75 94.74 216 .
Ajmer 25.96 61.65 17.73 0.74 29.18 116.43 56.58 111 Udaipur 32.99 29.26 8.47 0.68 34,40 119.09 54.65 115 Kota _ 22.38 19.68 10.22 0.73 33.59 115.26 57.98 123 Pali 20.78 16.14 9.25 0.75 34.52 104.91 58.11 105 Jodhpur 37.68 27.20 8.76 0.79 31.67 155.48 71.56 153 Standards 40.00 100.00 50.00 2 100 60.00 40.00 (8 hrs) (8 hrs) AQI Colour Codes Related Heath Concerns Minimal Impact Good (0.50) Satisfactory Minor breathing discomfort to sensitive people (51-100) Breathing discomfort to the people with lung, Moderate heart disease, children and older adults (101-200) Breathing discomfort to people on prolonged Poor exposure (201-300) 15 Very poor Respiratory illness to the people on prolonged (301-400) exposure Severe (>400) Respiratory effects even on healthy people Monitoring Location : CAAQMS AJMER, RAJASTHAN Monthly Average Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5 Parameters AQI µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Jan-22 21.96 102.46 11.42 0.91 32.14 102.71 56.92 102 Feb-22 22.72 134.18 13.64 0.72 28.00 109.03 58.80 106 Mar-22 25.66 96.52 15.32 0,77 31.77 114.59 54.61 110 Apr-22 29.34 39.97 19.56 0.83 3 5. 4 0 194,30 75.88 124 May-22 18.94 26.91 16.46 0.63 40.07 155.97 77.33 160 Jun-22 20.58 29.28 22,24 0.66 37.52 111.48 63.90 121 Jul-22 31.74 51.90 28.63 0.70 26.40 89.27 39.52 87 Aug-22 34.06 46.66 15.65 0.71 20.64 93.69 40.08 94 Sep-22 15.95 20.16 24,09 0.67 29.88 80,65 40.80 83 Oct-22 25.21 36.26 14.07 0.68 26.07 109.81 51.19 110 Nov-22 33.62 60.78 12.74 0.82 23.38 115.44 57.89_ 117 Dec-22 31.77 94.67 18.88 0.84 18.90 120.24 62.07 113 Standards 40.00 100.00 50.00 2 100 (8Hrs) 40.00 (8Hrs) 60.00 Monitoring Location : CAAQMS ALWAR, RAJASTHAN Monthly Average NO2 NH3 SO2 CO O3 PM10 PM2.5 AQI Month/ µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Parameters Jan-22 29.19 34.86 12.63 0.91 13.55 92.85 48.18 93 Feb-22 31.31 37.54 13.32 . 0.79 17.72 89.48 38.22 89 Mar-22 36.51 34.30 11.94 _ 0.73 19.06 98.58 37.90 99 Apr-22 29.18 32.02 15.06 0.67 22.74 106.13 3835 103 May-22 18.91 21.26 13.50 0.62 25.99 121.38 52.04 115 Jun-22 14.78 15.27 15.16 0.65 24.50 98.23 41.54 95 Jul-22 7.96 11.20 14.03 0.66 14.50 63.97 30.07 64 Aug-22 4.84 7.61 14.46 0.51 17.66 62.29 29.20 63 Sep-22 6.40 11.80 11.47 0.63 19.97 81.67 31.23 81 Oct-22 14.32 16.88 13.31 0.81 22.17 83.56 38.22 87 Nov-22 31.31 27.05 11.38 0.89 24.49 107.13 56.16 116 _ _ Dec-22 37.02 29.03 13.32 1.01 20.78 101.04 57.19 101 Standards 40.00 100.00 50.00 2 100 60.00 40.00 (8Hrs) (8Hrs) 16 Monitoring Location : CAAQMS BHIWADI, RAJASTHAN Monthly Average Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5 AQI Parameters µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Jan-22 54.69 82.02' 18.99 1.01 9.44 205.29 112.1 274 Feb-22 54.38 84.21 24.43 0.87 13.31 198.73 3 103.9 246 Mar-22 55.00 90.68 34.48 0.96 23.19 251.74 1 119.0 297 Apr-22 81.10 128.25 45.21 0.87 29.98 294.38 1 154.1 323 May-22 58.06 63.40 23.49 0.87 30.28 250.20 6 124.1 274 Jun-22 63.72 73.34 19.26 0.81 27.36 205.47 2 101.5 218 Jul-22 25.52 19.53 10.62 0.83 15.70 85.95 0 41.95 84 Aug-22 43.97 42.39 13.64 0.79 14.88 86.99 36.97 85 Sep-22 123.61 88.51 10.43 1.08 15.36 130.24 60.66 131 Oct-22 87.84 107.86 11.19 1.48 192.89 83.14 191 Nov-22 54.47 90.21 12.14 1.38 19,33 23.50 290.89 ' 261 Dec-22 70.47 109.08 13.71 1.24 16.03 252.19 111.8 87.55 202 2 100 1 Standards 40.00 100.00 50.00 60.00 40.00 (8Hrs) (8Hrs) Monitoring Location : POLICE COMMISSIONERATE OFFICE JAIPUR, RAJASTHAN Monthly Average Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5 AQI Parameters µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Jan-22 62.60 54.42 17.46 1.52 29.94 166.81 87.70 192 Feb-22 62.23 59.47 12.17 1.65 33.44 152.89 68.76 135 Mar-22 73,23 65.73 17.64 1.52 38.63 155.95 73.76 146 Apr-22 84.82 68.15 16.35 1.95 33.15 192.96 100.23 225 May-22 55.47 72.58_ 11.43 1.32 42.26 192.22 94.11 209 ._ Jun-22 50.05 _ 82.35 14.32 1.02 29.77 134.94 70.01 149 Jul-22 33.78 94.99 13.80 1.02 28.03 58.04 25.36 58 Aug-22 33.40 56.12 12.96 0.86 18.90 82.06 37.12 80 Sep-22 35.00 48.79 13.21 2.33 22.55 94.75 45.47 91 Oct-22 85.29 50.99 15.30 1.17 31.65 153.79 71.28 147 Nov-22 78.30 84.77 12.48 1.74 34.87 174.02 81.22 187 Dec-22 72.39 41.44 19.06 1.50 35.02 154.40 88.19 194 100 Standards 40.00 100.00 50.00 2 (8Hrs) 60.00 40.00 (8Hrs) Monitoring Location: SCIENCE PARK, JAIPUR, RAJASTHAN Monthly Average Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5 AQI Parameters µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Jan-22 24.83 32.67 15.81 1.00 42.72 166.96 67.74 145 Feb-22 31.44 43.46 15.62 0.84 54.71 155.84 63.14 137 Mar-22 52.73 68.19 17.01 0.87 53.77 138.91 62.87 126 Apr-22 90.69 96.40 16.88 0.92 56.70 165.30 71.12 151 May-22 69.95 97.24 14.41 0.64 59.60 225.13 85.98 205 17 Jun-22 61.49 15.60 15.01 0.82 57.87 155.38 55.99 138 Jul-22 35.25 27.81 15.65 0.82 37.97 57.77 29.85 64 Aug-22 24.02 23.69 15.33 0.75 38.70 67.28 32.93 62 Sep-22 27.21 26.46 14.89 0.76 45.58 60.67 34.52 67 Oct-22 35.65 28.74 15.08 0.95 57.22 68.54 46.83 89 Nov-22 61.82 53.04 17.56 1.15 52.98 167.41 66.05 159 I Dec-22 49.36 38.22 14.67 0.96 29.81 151.05 54.54 134 100 Standards 40.00 100.00 50.00 2 (8Hrs) 60.00 40.00 (8Hrs) Monitoring Location : PSYCHIATRIC CENTRE, JAIPUR, RAJASTHAN Monthly Average Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5 AQI Parameters µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Jan-22 41.27 38.44 11.46 0.95 40.25 105.94 64.24 114 Feb-22 36.75 39.08 11.70 0.67 47.99 112.98 50.97 109 Mar-22 43.55 37.82 13.15 0.85 51.45 126.73 61.25 118t Apr-22 49,65 42,10 14.14 0.94 41.07 ı4g.3s 62.85 138 May-22 32.66 26.93 11.09 0.74 52.66 179.27 83.20 199 Jun-22 25.48 19.09 11.25 0.77 54.82 122.19 47.08 113 Jul-22 26.26 31.80 9.67 0.74 38.34 39.90 19.72 52 Aug-22 24.41 29.20 8.90 0.66 31.50 51.99 22.29 59 Sep-22 32.43 32.68 12.64 0.79 36.92 68.04 34.46 71 Oct-22 48.09 40.53 14.64 0.88 50.71 103.51 57.13 118 Nov-22 67.22 59.72 10.55 1.14 45.15 115.86 67.23 131 Dec-22 62.67 51.39 15.04 0.97 40.59 114.63 56.96 110 100 40.00 Standards 40.00 100.00 50.00 2 (8Hrs) 60.00 (8Hrs) Monitoring Location: CAAQMS JODHPUR, RAJASTHAN Monthly Average Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5 AQI Parameters µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Jan-22 45.86 34.69 9.80 0.99 30.73 172.86 80.52 168 Feb-22 42.32 25.85 9.43 D.91 31.90 175.78 8S.22 184 Mar-22 32.05 19.39 9.40 0.88 33.96 172.90 83.90 180 Apr-22 31.77 18.97 8.00 0.78 33.49 191.6B 86.2 189 May-22 34.3S 24.19 7.58 0.83 34.51 226.46 102.60 239 Jun-22 34.32 23.36 7.09 0.84 37.00 168.44 74.13 161 Jul-22 29.28 20.29 7.12 0.68 22.93 71.11 33.78 71 Aug-22 26.51 21.53 7.21 0.49 22.22 94.57 38.74 91 Sep-22 30.98 21.96 8.07 0.54 24.43 95.50 44.Z9 91 Oct-22 41.09 80.78 9.79 0.81 32.53 159.01 75.83 146 Nov-22 55.00 46.55 13.22 0.99 38.96 182.03 80.12 172 Dec-22 48.65 38.93 8.41 0.77 37.37 155.44 72.62 142 100 56.96 Standards 40.00 100.00 50.00 2 (8Hrs) 60.00 (8Hrs) 18 Monitoring Location: CAAQMS KOTA, RAJASTHAN Monthly Average Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5 AQI Parameters µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Jan-22 26.86 32.54 9.74 0.74 32.28 113.26 79.41 165 Feb-22 38.32 23.00 10.06 0.65 46.56 137.86 69.34 131 Mar-22 36.03 24.50 10.88 0.63 44.06 133.74 65.88 122 Apr-22 17.69 12.93 7.78 0.13 18.03 71.17 37.58 135 May-22 22.45 ZS.82 9.66 0.50 50.71 189.06 84.37 186 Jun-22 21.97 20.25 10.18 0.67 44.61 105.69 53.91 106 Jul-22 14.45 17.30 9.57 0.66 23.05 55.93 28.87 57 Aug-22 19.41 22.23 9.72 0.69 19.10 59.26 30.79 60 Sep-22 12.93 9.39 11.30 0.75 17.28 59.61 35.43 70 Oct-22 18.14 18.75 11.46 0.93 31.13 118.97 57.99 115 Nov-22 16.42 13.82 11.85 1.21 37.45 162.69 81.38 189 Dec-22 23.88 15.61 10.43 1.19 38.82 165.93 70.80 144 100 56.96 Standards 40.00 100.00 50.00 2 (8Hrs) 60.00 (8Hrs) Monitoring Location Monitoring Conducted By:
CAAQMS PALI, RAJASTHAN ENVIRONNEMENT S.A INOIA PVT. LTD.
Monthly Average
Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5
AQI
Parameters
µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3
Jan-22 33.62 26.33 9.50 0.75 27.17 104.49 59.48 168
Feb-22 25.97 21.97 13.34 0.65 33.81 113.88 62.05 184
Mar-22 15.01 16.45 10.64 0.68 30.92 118.36 64.32 180
Apr-22 17.60 15.41 13.91 1.11 47.75 133.61 69.80 189
May-22 18.46 20.22 13.49 0.79 41.33 169.53 76.22 239
Jun-22 18.50 18.40 6.35 0.56 34.63 116.47 66.43 161
Jul-22 17.89 20.32 6.65 0.50 16.11 58,68 33.84 71
Aug-22 18.32 12.69 6.07 0.S7 22.68 67.14 39.46 91
Sep-22 18.49 11.45 5.68 0.54 21.35 78.95 30.79 91
Oct-22 20.62 11.03 6.79 0.71 38.66 85.21 45.56 146
Nov-22 22.41 8.50 8.93 1.04 48.72 107.25 62.26 172
Dec-22 22.47 10.97 9:60 L05 51.16 105.35 59.73 142
100 56.96
Standards 40.00 100.00 50.00 2 (8Hrs) 60.00
(8Hrs)
Monitoring Location : CAAQMS UDAIPUR, RAJASTHAN Monthly Average Month/ NO2 NH3 SO2 CO O3 PM10 PM2.5 AQI Parameters µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 µg/m3 Jan-22 23.12 30.54 10.48 0.97 36.11 149.86 74.66 149 Feb-22 35.50 36.35 10.45 0.86 42.92 140.54 58.09 127 Mar-22 42.85 35.87 11.26 0.86 47.44 137.64 63.70 125 Apr-22 51.22 28.27 8.05 0.77 54.75 139.00 59.44 126 May-22 43.38 32.32 6.03 0.62 46.94 164.97 67.33 148 Jun-22 28.25 46.60 6.53 0.57 S7.85 85.00 40.52 81 19 Jul-22 16.55 27.03 8.96 0.41 16.29 51.06 23.53 51 Aug-22 14.42 27.40 5.86 0.36 14.43 65.98 29.68 64 64 Sep-22 25.52 30.90 7.46 0.43 18.81 76.26 35.14 71 Oct-22 39.03 25.25 7.18 0.80 24.51 111.10 48.27 105 Nov-22 38.21 9.14 9.03 0.74 32.54 145.75 73.07 150 Dec-22 37.78 21.49 10.30 0.77 40.21 161.91 82.41 175 100 56.96 Standards 40.00 100.00 50.00 2 (8Hrs) 60.00 (8Hrs)
15. The Rajasthan State Pollution Control Board has entered into an memorandum of understanding (MoU) with Malviya National Institute of Technology (MNIT) Jaipur for estimating carrying capacity of ambient air in Alwar and Bharatpur districts of Rajasthan on the following terms:-
"1. Introduction:-
Brick Kiln, manufacturing is, a smap : scale and unorganized : sector in India. The emissions produced from the Brick ,Kiln are primarily Particulate Matter (PM10), Carbon Monoxide (CO) and Sulphur, Dioxide (SO2) during brick firing operation. CO is mainly emitted due to incomplete combustion of fuel whereas the SO2) emissions are dependent on the amount of sulphur present in the fuel. All these three pollutants are criteria pollutants included in the National Ambient Airy Quality Standards (NAAQS) and pose significant harm to human health and the environment.
The Hon'ble NGT has recently issued a blanket order to shut down all the brick kilns within the administrative limits of Alwar and Bharatpur districts of Rajasthan to control/avoid the pollution load emitted by the brick kilns after accounting, for the Assimilative supporting capacity of the area to comply with the NAAQS based on PM10 parameter.
The report submitted by CPCB in compliance to directions of NGT has calculated pollution load, assimilative capacity and environment supportive capacity based on PM10 parameter. Subsequently, it was concluded that there is not enough carrying capacity in the air environment of Bharatpur & Alwar Districts to operate any brick kiln.20
2. Need of Study :
The blanket ban on operation of brick kiln industries has affected livelihood construction activities in the region due to shortage of quality bricks and rise in the prices of bricks. A need is there to revisit the district wise carrying capacity, as calculated by the CPCB on following accounts:-
The arid conditions of Rajasthan are responsible for high background PM10 concentrations in the region due to re- suspension of natural dust. A large proportion of the PM10 concentration in the air may be of crustal origin. Evaluating the carrying capacity of the environment based solely on concentration may lead to erroneous conclusions.
Absolutely same monthly average values of PM10 have been used for calculating the carrying capacity of ambient air of Alwar and Bharatpur districts of Rajasthan.
The carrying capacity of Alwar and Bharatpur districts was assessed by CPCB considering satellite based data in the absence of ground based monitoring stations.
If multiple point observations are available then pollution contour may be developed and weighted area between two contours may be used to get a better indication of carrying capacity.
Hence, it is recommended that the pollutions from the brick kiln needs to be reexamined. This may be carried out by using both PM2.5 as well as PM10 as parameters and their compliance with NAAQS. Using PM2.5 in addition to PM10 will indicate that the pollution load considered is only from anthropogenic activities and 'not natural.
3. Project Objective:
The proposed key objective for the study is to examine the additional load (based on PM10 PM2.5 parameter) on the ambient air environment from the brick kilns in and, around Alwar and Bharatpur cities through atmospheric dispersion modeling.21
4. Applicable Standards:
The Environmental Protection Rules, 1986 and its amendments specify the limits on an emissions from brick kiln stack: Apart from this, the brick kiln emission shall be such that the average pollution load is within the limits prescribed under the NAAQS.
5. Methodology:
1. An emissions inventory of the existing brick kilns will be populated (the data shall be provided by the Rajasthan State Pollution Control Board, RSPCB). Any data available with Central Pollution Control Board(CPCB) may also be used. The inventory will comprise stack geo-location, diameter, height, exit temperature, flue gas exit velocity, flue gas composition, and type and amount of fuel consumption. In the absence of emission inventory, USEPA AP42 emission factors and/or emission factors generated by Grreentech in their report "A Roadmap for cleaner Brick Production in India, 2012" shall be used.
2. The 5-year surface and upper air meteorological data will be obtained from the nearby Airports/CAAQMS stations/IMD/any other reliable source. The mixing height is a critical parameter in the dispersion of pollutants, which is normally accessed from "Atlas of hourly mixing height and associative capacity of atmosphere in India published in 2008 by India Meteorological Department, New Delhi. If point meteorological data is not available then the corresponding gridded data (accessible online) shall be used.
3. AERMOD, an USEPA regulatory model will be used to study the cumulative dispersion of pollutants (PM10/PM2.5) from the brick kilns in and around both Alwar and Bharatpur cities.
4. The atmospheric dispersion modeling,-will provide additional load on the ambient air environment from 22 the cumulative operation of the brick kilns. Pollution maps (isopleths) will be generated for PM10/ PM2.5, Parameters individually for Alwar and Bharatpur, cities.
5. Based on isopleths the pollution hotspots in I each study area will be identified where the ground level' concentration (GLC) is exceeding (more than the background levels) by fixed percentage/concentration. The contribution from clusters of brick kilns will be simulated at each hotspot for various meteorological conditions. Subsequently, iterations will be performed to geographically reposition or complete shutdown of these clusters to maintain regional air quality in compliance with NAAQS."
16. Since, there are many Brick Kiln owners who put their appearance in this proceedings, thus, the applicant was directed to move an application to implead all those persons who are being affected by this order and in compliance thereof, the applicant move an application I.A. No.49/2023, which was disposed vide order dated 22.09.2023 in following manner :-
1. "Original application was filed to regulate the brick klins industries and to implement the order dated 17.02.2021 passed by Principal Bench of this Tribunal in Original Application No. 1016/2019, wherein it was held that as per terms of GRAP, FCBTK brick kilns stand prohibited under „severe‟ condition of air quality by the order of the Environment Pollution (Prevention and Control) Authority (EPCA) dated 01.11.2019. The applicant herein seeks extending such prohibition to brick kilns operated by zig-
zag technology, which also involve coal as fuel and cause pollution load which in „severe‟ air quality conditions becomes hazardous to health. According to the Applicant, even brick kilns run by zigzag technology add to PM2.5 and also contribute to the air pollution in the NCR and should not be allowed till GRAP is applicable i.e. when air quality is severe and above.
2. By moving the I.A. No. 49/2023, the applicant wants to say that though this application has not been moved against any brick klins owner and intended to improve the air quality of the cities, 23 where the Ambient Air quality is not as per parameter laid down by the CPCB and pollution load is severe and becoming hazardous to health, thus, it is necessary to implead the respondents as mentioned in para 4 so that they should be given an opportunity of hearing and to find certain remedial and suggestive measures.
3. The application deserves to be allowed. Accordingly, the application is allowed. The respondent as mentioned in para 4 from Sr. No. 1 to 10 be impleaded as a respondent nos. 06 to 15. Applicant is directed to take necessary action and send the copy of the application and relevant documents to the all newly added respondents. Respondents are directed to submit their suggestive measures to maintain the air quality in the area. Since, it is not a personal case and it is intended to maintain the air quality thus the respondents newly added are required to submit their own view with regard to the maintenance to the air quality parameter before the next date of listing. I.A. No.49/2023 stands disposed of accordingly."
17. In light of the above facts the CPCB was directed to submit the report after giving due opportunity of hearing to the brick kilns owners association. In compliance thereof, the CPCB constituted a committee and submitted the report which is as follows :
"In compliance of the order, Central Pollution Control Board has constituted a committee of 05 members vide order dated 18.4.2023 & 24.4.2023 (revised office order). Following were the 05 committee members with 01 special invitee from CPCB, Delhi:
1. Dr K V George, Chief Scientist & Head, APC Division, NEERI, Nagpur
2. Prof Sudhir Kumar, HAG, Environmental Engg, MNIT, Jaipur
3. Dr. Neeraj Jain, Principal Scientist, CBRI, Roorkee
4. Sh Sunil Kumar Meena, Sc-D, CPCB, Regional Directorate, Bhopal
5. Sh Vikram Singh Parihar, Chief Scientific Officer, RSPCB, Jaipur Sh Vinay Prabhakar, Sc-C, IPC-IV, CPCB, New Delhi - Special invite.
The committee held its 02 meetings on 26.4.2023 & 17.5.2023 and had detailed discussion on various points related to brick 24 kilns viable operation, carrying capacity, impact on air quality and soil fertility & others plan to execute the work.
In compliance of the order following work has been executed so far:
1. Suggestions from brick kiln associations on the viable operation of brick kilns CPCB vide its letter dated 9th June 2023 seek the suggestions from the representatives of different brick kiln associations of Sikar, Alwar, Bikaner, Sriganganagar, Bharatpur, Jaipur of Rajasthan state. Suggestions were sought on the use of PNG or any alternative fuel, difficulties in conversion of kilns from FCBTK to Zig-zag technology, use of ash in brick manufacturing and operation of kilns for fixed durations. The representation received from 5 associations representatives of Bharatpur, Jaipur, Sriganganagar districts.
S. Issues on which Brief on the representations of brick No. suggestions were kiln associations sought
1. Use of PNG in brick Following are the few major issues manufacturing raised due to which use of PNG is not viable in the Rajasthan state:
Non-availability of PNG in Bikaner division Costly equipments in range of 3 to 15 Cr Establishment of brick kilns in far-far places of the villages/districts PNG based brick manufacturing plants operation is different then the conventional FCBTK where fire is moved whereas in PNG brick moves and fire stays at one point.25
2. Alternative fuel of coal & Currently the brick kilns run on the its feasibility agro fuel viz. residue of Mustard, (environmental & cotton, mehndi, Gwar crops. And financial) the fuel is easily available in nearby areas. This gives financial support to farmers too. If the kilns start operating on coal or other fuel then this near-by available agro residue will be burnt in fields and will cause air pollution.
3. Difficulties in conversion The difficulties arising in conversion of kilns from FCBTK to of kilns to zig-zag:
Zig-Zag The cost of conversion will be high from 30-55 lakhs.
No or less number of skilled
labors available for zig-zag
type operation
No bank loan & govt.
subsidy provided on the
conversion
No training provided on zig-
zag operation
Imposition of GST on brick
from 1% to 6% and
Imposition of GST on the
royalty since 2017-18.
Suggested solutions:
Provide training on the zig-
zag operation
Bank financial support &
35% subsidy on the
conversion
Increase timeline of
conversion by up to 7 years.
4. Use of ash in brick 6% to 16% crop residue can
manufacturing be used with soil as internal
fuel that will save the soil
quantity as well as improve
26
the quality.
As submitted, in Bikaner
division, it is practices that
40% Balu sand is mixed for
making bricks. That‟s why
no further requirement of
mixing ash is required.
5. Viability of business if The business may be made
operation of bricks made viable by fixing the
for fixed period operational period of brick
production
during January to June or
February to June; this will
improve the air quality
during winter season,
conserve the soil, by this
availability of bricks can be
ensured for whole year &
others.
The recommendations for effective & viable operations of brick kilns stated by the expert committee constituted in NGT matter OA 31 of 2021 (CZ) vide order dated 3.6.2021 in the matter of Vijay Singh Vs State of Rajasthan & Ors related to Rajakhera area of Dholpur districts of Rajasthan are as below:
"General Recommendations The particulate matter emissions from brick kiln stacks are primarily due to incomplete combustion of coal or biomass fuels, leading to formation of black colored soot particles, which form majority of the particulate matter in the stack emissions. Coal contains about 15-35% volatile matter, which is lower chain of hydrocarbons. This volatile matter gets released within seconds of firing the coal in the kiln. For combustion of this volatile matter, both primary air (from below the coal) and secondary air (above the coal) are required in appropriate proportion and quantity. If the air is not provided for combustion, part of this released volatile matter does not get burned 27 or gets only partially burnt, which gives release to unburnt hydrocarbons (HC) and Carbon monoxide (CO). The unburnt hydrocarbons, once cooled to about below 600oC, get condensed and form soot particles. This is an irreversible reaction and soot once formed, cannot be combusted. If the soot formation could be prevented or substantially reduced, the particulate matter emissions from brick kilns can be substantially reduced. Reduction in soot formation also means reduction in coal consumption.
The conversion from FCBTK to zig-zag technology helps in improving the combustion by providing better mixing of fuel and air and longer high temperature zone to burn off the volatile matter resulting in the reduction of particulate matter emissions. The results from various previous monitoring studies show significant reduction in particulate matter emissions in stack gases in zig-zag kilns as compared to FCBTK.
In this regard, specific opinion/suggestion with a road map regarding sustenance operation of brick kilns to make viable in Rajakhera block are as under:
(A) IMMEDIATE MEASURES (0-1 years for
implementation)
1. As an immediate measure to reduce emission of particulate matter from stack, path length of flue gases may be increased so that most of SPM may settle due to action of gravity. As it will also bring down the temperature of the flue gases, an induced fan will need to be installed before stack. Path length may be increased by zig-zag setting of the bricks in FCBTK or by diverting the flue gases to a long nala (channel/path) before entering into the stack. This nala will be connected to stack at the other end.
2. It is observed that pollution level during rainy season is almost negligible and keeping this in mind, brick kilns may be allowed to operate during rainy season (July to September) also if they have proper shed arrangements and 28 willing to do so. Shed will also be helpful in reducing the fugitive dust emissions and fuel requirement. Shed will also reduce heat losses which will increase the thermal efficiency of the kiln.
3. Rajasthan State Pollution Control Board must fix the length and width of the kiln. It will restrict the enormously high production of bricks (more than 50,000 bricks per day) as in practice by most of the Brick kiln operators. This will results in lower emission load and improvement in carrying capacity.
4. Brick kilns manufacturers association may be asked to conduct innovative studies to meet the emission norms for the present FCBTK type brick kilns by adopting fueling firing mechanism, modifying the path length of flue gas flow, installing appropriate pollution control system (like wet scrubber system) before the flue gas exit the chimney. This may be tried for different types of fuels being used in the kilns.
(B) SHORT TERM MEASURES (within 3 years) The above immediate measures can effectively control the SPM level up to 20%, however, these are not the adequate/permanent methods to control the emission of finer particulate matter (PM10 and PM2.5) which are escaped from stack due to high temperature of flue gas. Therefore, following short term measures are recommended and must be implemented (within 3 years) for further reduction in the stack emissions.
1. Conversion of FCBTK kilns to zig-zag kilns.
2. Installation of a proper air pollution control device like wet scrubber for control of PM10, PM2.5 and greenhouse gases emission due to burning of coal is suggested. Wet scrubber is the most trusted, proven, efficient and sustainable technology for control of particulate matter and scrubbing of greenhouse gases. This device can be helpful to reduce SPM below 50 mg/Nm3.
29Suitability of Wet Scrubber Technology During firing of green bricks in zig-zag fired induced draft brick kilns a significant concentration of moisture is carried away by the flue gas. Since the temperature of flue gases in the stack of kilns is generally between 50-100oC, which result in condensation of moisture in flue gases and at times it is required to be drained from the bottom of the ID fan which otherwise affects performance of the fan efficiency besides corrosion of fan. The flue gas also contains SO2 due to sulphur in coal. In view of this, the wet scrubber would be the suitable option as air pollution control device which can simultaneously remove particulate matter and gaseous pollutant like SO2.
It is also brought out that the chimney in induced draft brick kiln is either installed in the central island or along the outer trench wall of the kiln i.e. outside the kiln. Whereas the installation of air pollution control device would be easy with the chimney outside the kiln, installation of APCD in the central island is expected to pose several problems and would require an innovative design solution. The water used for scrubbing of gases would be required to be neutralized using alkaline material, which can further be re- circulated or can be used in preparing clay mix for brick moulding. However, before its adoption at wider scale, the basic design parameters are required to be confirmed/checked and suitability of the system be assessed by demonstrating at two or three locations.
(C) MID-TERM MEASURES (3-10 years) Following mid-term measures are recommended for further improvement in the brick industry using high draught technology for implementation in next 3-10 years depending on the need, infrastructure availability and expenditure involved:
1. The use of internal fuel is recommended which is a well proven technology to control particulate matter and gaseous emissions from brick kiln. It can reduce or exempt the use of external fuel demand for firing of bricks. Materials like agricultural residues, fly ash, rice husk, mustard husk, cow dung, reject coal, coconut fiber or any other non-hazardous material can be used as internal fuel. Use of Agro-residue as internal fuel can also 30 reduce clay consumption by 30-40% and reduce gaseous emission. Agriculture residue as an internal fuel can be recommended after a proper scientific and technical study.
Although use of coal as an internal fuel is a well-established technology in other countries. However, in India, it is in a very primitive stage and requires detailed study. Use of internal fuel in zig-zag kilns especially when APCDs are in place, should be promoted. Further, use of internal fuel is not possible in all regions because the characteristics of brick earth is different in all over the country and having mixing problems due to low bonding capacity of the brick earth. The other main constraints in implementation of this technology are mechanized and electricity powered extruders, pug mills, power connection, huge investment etc.
2. Agriculture residue can be used in zig-zag brick kilns as external fuel only after converting to briquettes for the reduction in particulate matter and gaseous emissions from flue gas. Although its use depends on the availability of materials and briquettes making plant nearby.
3. Manufacturing of Resource Efficient Bricks (REBs) products such as perforated bricks, hollow bricks and blocks. These products save fuel up to 30 % resulting reduction in pollutants emission up to 30 %. REBs also reduce clay up to 50 % for their manufacturing apart from saving of other resources during use as walling unit in buildings. Although this is possible only after mechanization of brick kiln. Bureau of Energy Efficiency (BEE) is supporting REBs technology and launching a special "E3" mark to promote the manufacturing and marketing of the REBs.
4. Use of auto coal/fuel feeding system to standardize the firing practice at optimum level.
5. The introduction of mechanization process for the molding of clay bricks is suggested. This proves largely beneficial especially in the case of mixing internal fuel with clay as the manual mixing of internal fuel is hazardous for the health of the workers who are involved in the process.
6. Use of fly as (minimum 25%) in clay brick should be made mandatory to save soil and fuel.
31(D) LONG TERM MEASURES (After 10 years) After 10 years, based on need to shift/upgrade on to the new technology like tunnel kin, Hoffman kiln or any other new technology based on cheaper fuel like solar power or natural gas (PNG/CNG), long term measures can be implemented to reduce emission of particulate matter to negligible level. Although there are many environmental advantages of shifting to new technology like gas based kiln/tunnel kiln, but the implementation of these measures depends on the availability of infrastructure and willing of brick kilns for huge investment for change of technology which is not possible in today‟s scenario. After 10 years, there may be possibility of availability of cheaper fuel and infrastructures required for adopting gas based technology. The major constraints in use of natural gas in existing zig-zag kiln are as under:
1. All the kilns will have to modify either to Hoffman Kiln or a Tunnel kiln. Both these technologies are comparatively less efficient than the existing kilns.
2. Viability of PNG:
The combustible mixture of natural gas and air does not ignite if the mixture is leaner than 5% and richer than 15% of the fuel-air ratio required for ignition. This narrow inflammability range makes PNG one of the safest fuel. (Source: GAIL India, Ltd). However, bricks kilns require it in very large volume. Expert man power is required to handle it and work has to be carried out according to strict schedules and parameters. To keep such high level of disciple, looks very difficult in bricks kilns.
The pricing of PNG is another issue. To make a comparison, the coal, having GCV of about 6000 Kcal/kg, is available at a price of about 11000 per MT whereas, currently the PNG (GCV 11500kcal/kg) cost at Agra for industrial use is Rs. 45/SCM (rate effective from 7.4.2021), it will mean an increased cost of burning.
Brick kiln operator need to make modifications in plant & arrange for internal pipeline from downstream of meter till the gas consumption points which requires addition expenditure. This shall increase the cost of manufacturing.32
The technology to use PNG in brick kilns is not available indigenously and has to be imported. Even the equipment with the required safety devices has to be imported.
(E) MEASURES TO CONTROL FUGITIVE DUST EMISSION Fugitive dust is generated from various processes during brick manufacturing and having bigger particle size which cannot travel beyond a distance of more than 100 meters. The major fugitive dust emission takes place from following steps during brick manufacturing:
i. Clay Excavation, Transportation, and Stacking at the Kiln site ii. Preparation of Clay by adding internal fuel and water iii. Manual Moulding of Green bricks iv. Loading in the Brick Kiln v. Covering Bricks with Ash in Kiln Rooftop vi. Fuel Handling (Coal/Agriculture Waste) vii. Firing of Bricks in High Draught Kiln viii. Removal of Ash from Kiln Rooftop ix. Unloading of Fired Bricks x. Stacking and Delivery of bricks Following measures are recommended to control the fugitive dust emission from a brick kiln:
1. Coal should preferably be stored under shed with proper ventilation on a pucca platform. Crushing of coal should be done in enclosed equipment/ area to avoid process emissions. The coal size should be between powders to ¾ inch i.e. properly graded coal. This would help in uniform brick quality as the powdered coal ignites immediately on feeding thereby releasing heat to the top layer of brick setting.
2. To control dust emissions due to airborne ash from the top of brick settings, the top ash layer in the preheating zone should be kept covered with sheet.
3. The clay should be prepared at a Centralized location with the use of Backhoe-Loader (JCB) and Mechanized Clay mixing machine which can help in the reduction of dust emissions at 33 clay mixing places.
4. An iron shed should be installed over the kiln which will reduce the fugitive emission from the kiln and also reduce the coal consumption. This will further helpful in reducing the pollution due to burning of coal and protection of the kiln during rains.
Provision of shed over kiln would save at least 20-30 tons of coal every first cycle. Providing shed over the kiln would also improve the ambience of the area and provide shed to the workers working in the kiln.
5. Pavement of approach road within the premises of brick kilns. Water should be sprinkled frequently over roads around brick kiln and over the ash layer before its removal and transfer.
6. A wall of at least 3.0 meters height to be constructed on the sides where land is not available for green belt development to prevent fugitive emissions. Multi-layer green belt to be developed along the periphery of brick kiln.
As per the MoEFCC notification 22.2.2022 following is to be compliant by the brick kilns:
1. All new brick kilns shall be allowed only with zig-zag technology or vertical shaft or use of Piped Natural Gas as fuel in brick making and shall comply to these standards as stipulated in this notification.
2. The existing brick kilns which are not following zig-zag technology or vertical shaft or use Piped Natural Gas as fuel in brick making shall be converted to zig-zag technology or vertical shaft or use Piped Natural Gas as fuel in brick making within a period of -
(a) one year in case of kilns located within ten kilometre radius of non- attainment cities as defined by Central Pollution Control Board
(b) two years for other areas. Further, in cases where Central Pollution Control Board/State Pollution Control Boards/Pollution Control Committees has separately laid down timelines for conversion, such orders shall prevail.34
3. All brick kilns shall use only approved fuel such as Piped Natural Gas, coal, fire wood and/or agricultural residues. Use of pet coke, tyres, plastic, hazardous waste shall not be allowed in brick kilns.
4. Brick kilns shall construct permanent facility (port hole and platform) as per the norms or design laid down by the Central Pollution Control Board for monitoring of emissions.
In Rajasthan, CPCB has defined 05 cities i.e. Jaipur, Jodhpur, Kota, Udaipur, Alwar as non-attainment cities. The brick kilns situated within ten kilometre radius of non- attainment cities shall be converted to zig-zag technology or vertical shaft or use Piped Natural Gas as fuel in brick making within a period of ONE year.
Brick kilns in Rajasthan As per the brick kiln survey reports received on 6.6.2023 from RSPCB there are total 2037 brick kilns established in 24 districts of the Rajasthan. Out of these 263 are of Zig-Zag type & rest 1730 are operating on FCBTK. Status of remaining 3 & 41 brick kilns of Alwar & Bharatpur were reported as closed in survey and their type of operation is not provided. There are 07 districts viz. Sriganganagar, Bhilwara, Hanumangarh, Bharatpur, Alwar, Dholpur & Jhunjhunu having more than 100 brick kilns. The NCR region‟s kilns of Alwar & Bharatpur districts operated during March to June for 4 months; whereas in other districts the operation period is of 5 to 8months i.e. October to June. Majorly mustard residue, biomass is the fuel used by the BKs. In 1000 bricks 300Kgs fuel is used and on an average daily 12-13 thousands bricks are produced that requires 3 Tons of fuel. The details are as tabulated below:
S. District Total Zig FCBTK
No. Brick kiln Zag
1 Alwar 149 146 0
2 Balotra 2 0 2
3 Banswara 7 2 5
4 Dungarpur 5 0 5
5 Bhilwara 280 0 280
6 Bundi 4 2 2
7 Chittorgarh 12 0 12
8 Jhalawar 1 0 1
9 Ajmer 24 0 24
10 Tonk 13 1 12
11 Churu 36 0 36
35
12 Rajsamand 11 0 11
13 Sikar 91 0 91
14 Sawai Madhopur 23 0 23
15 Udaipur 5 0 5
16 Bhiwadi 4 4 0
17 Dholpur 135 1 134
18 Sriganganagar 420 5 415
19 Hanumangarh 274 7 267
20 Jaisalmer 8 1 7
21 Jhunjhunu 110 0 110
22 Jaipur North 183 2 181
23 Bharatpur 153 88 24
24 Bikaner 87 4 83
The outcome of the survey reveals that a large number of brick kilns are operational with FCBTK system in Rajasthan.
ii) Impact of brick kilns operation on loss/degradation of top soil To study the impact of brick kilns operation on loss/degradation of top soil, the methodology adopted in NGT O.A. 1088 of 2018 Dinesh Chahal & UOI was used in this study. To assess the loss of top soil due to brick kiln activity, soil samples (from upper 15 cm layer) were collected by the CPCB team from the land where top soils had been removed for brick manufacturing. For assessing loss of soil fertility due to brick manufacturing, samples of top soil (from upper 15 cm layer) were collected from the same land where soils were not yet removed from brick manufacturing. In places of brick kiln activity where such un-dugged soils could not be clearly identified visually, surface soils were collected from nearest agricultural lands for comparison.
Total 16 soil samples were collected during in 9th June to 10th June 2023 from 03 districts viz. Sriganganagar, Churu & Ajmer from agricultural land & mined out area to assess the soil quality for total 10 parameters viz. pH, EC, Organic Carbon, N, P, K, Fe, Mn, Zn & Cu. The samples were sent to ICAR- Indian Institute of Soil Science, Bhopal institute for required analysis. The analysis will complete by the end of July 2023. Copy of the details are enclosed. The analysis report is pending.
iii) Study involving Carrying Capacity Assessment of brick kilns with adequate samples in terms of number of brick kilns and days for which monitoring be conducted & Evaluation of the performance of brick kilns against the 36 background concentration and carrying capacity of the area Study No. 1. Rajakhera, Dholpur district (Year 2019 & 2020) The field survey revealed that out of 103 brick kilns established within 11kms radial distance from Rajakhera block, only one brick kiln is utilizing Zig-Zag technology and rest all are of Fixed Chimney Bull's Trench Kiln (FCBTK) technology. The major fuel used is Husk (Agro-residue). A huge number of brick kilns i.e. 57 out of 103 are running without Consent to Operate.
Estimation of daily pollution load from single brick kiln Source emission monitoring was not performed as the brick kilns of Rajakhera block were non-operational due to ongoing rainy season; Considering this, the source emission monitoring data of FCBTK based kilns operating on coal & husk at Aligarh (Uttar Pradesh) was considered. This monitoring was carried out by CPCB in June 2021. Based on this data, daily pollution load from single brick kiln was estimated. The calculated PM emission load with 17% O2 correction for single brick kiln is 0.705 Tons/day.
The detailed information is given as below:
Sr. Parameter Value No. 1. Type of Fuel Used Coal + Husk 2. Monitored at Port Hole Height , m 3.0 3. Internal diameter of Stack, m 3.0 4. Flue Gas Velocity, m/s 3.0 5. Ambient Temp., K 311 6. Flue Gas Temp., K 350 7. Actual PM Concentration, mg/Nm3 273 8. Corrected PM Concentration at 17% 420 O2, mg/Nm3 9. Normalized Flow Volume at 25 C, (Nm3/day) 16,77,818 10. Actual PM Emission Load, kg/day 458 11. Corrected PM Emission Load at 17% O2, kg/day 705
Estimation of Existing Pollution Load w.r.t PM2.5 For the estimation of the pollution load w.r.t. PM2.5; total area in which brick kilns are operational, mixing height of the area and PM2.5 concentration for the particular months were considered. For PM2.5 data, Aerosol Optical Density (AOD) data was 37 considered.
Total area (a) : 380 km2 (All the 103 brick kilns operational in the radial distance of 11 kms from the centre of Rajakhera village) Average atmospheric mixing height during a : As there is meteorological station nearby particular month in km (b) wise meteorological information available district online for 2015 at https://urbanemissions.info / blog-pieces /india-meterology-bydistrict/ was considered for monthly mixing height. The mixing height was considered same for 2019 & 2020 due to unavailability of the yearly meteorological data. The meteorological data is as tabulated below:
Month % Frequency of Mixing height in different ranges Weighted mixing <100 100-500 500-1000 1000-2000 >2000 height in Considered 50 300 750 1500 2000 KMs Average height, m Jan 66.12 15.45 13.17 5.24 0 0.257 Feb 63.69 13.095 9.52 12.5 1.19 0.354 Mar 58.198 11.69 8.1989 17.6075 4.3 0.476 Apr 55 10.13 4.166 9.72 20.97 0.654 May 51.47 11.55 3.22 4.3 29.43 0.738 Jun 36.94 17.638 5.13 10 30.27 0.865 Jul 20.43 31.45 12.5 25.67 9.94 0.782 Aug 32.25 30.24 12.7 24.59 0.134 0.574 Sep 55.55 12.777 4.86 17.91 8.88 0.549 Oct 63.3 9.94 3.897 17.069 5.779 0.462 Nov 68.75 11.66 8.33 9.86 1.38 0.307 Dec 68.41 15.32 13.84 2.419 0 0.220 Source: https://urbanemissions.info/blog-pieces/india-meterology- bydistrict/ Total volume of Air in the area of concern during a particular month in KM3 (C) : a xb Average PM2.5 concentration for a particular month in kg/km3 (d):
For understanding the ratio of AOD data to CAAQMS data, PM2.5 values of 06 cities for the year 2019 were analyzed for the ratio of CAAQMS to AOD. The ratio is tabulated below:
S.NO. City CAAQMS/AOD
ratio of 2019
1. Jhind 1.08
2. Bhiwani 1.12
3. Agra 0.96
4. Muzaffarnagar 1.07
5. Sonipat 0.994
38
6. Bulandsahar 0.998
As the average ratio is nearly 1 and in the case of unavailability of the ambient air quality data of the Rajakhera village; AOD data was considered for the calculation.
The AOD derived PM2.5 values for the year 2019 & 2020 are as tabulated below:
Month PM2.5 Values (µg/m3)
2019 2020
January 154 152
February 95 122
March 60 54
April 61 51
May 64 62
June 53 44
July 43 33
August 39 27
September 39 59
October 80 114
November 126 165
December 150 214
Therefore, Total estimated pollution load of PM2.5 (X) = c x d Month PM2.5 Pollution load (MT/Month) 2019 2020 January 15 15 February 13 16 March 11 10 April 15 13 May 18 18 June 17 14 July 13 10 August 8 6 September 8 12 October 14 20 November 15 19 December 13 18 Estimation of total assimilative capacity w.r.t. PM10 Total volume of Air in the district during a particular month in km3 (c) Particulate Matter (PM10) concentration in ambient air as per NAAQ standard, 2009: 100μg/m3 i.e. 100 Kg/Km3 (Ref. Air Quality Index/NAAQ Standards) Therefore, total assimilative capacity w.r.t. PM10 in ambient air of the area during a particular month (y): C x 100 = y Kgs 39 2019 & 2020 Month Total Assimilative Capacity in MT January 10 February 13 March 18 April 25 May 28 June 33 July 30 August 22 September 21 October 18 November 12 December 8 Estimation of total supportive capacity based on PM10 Total Supportive Capacity (z) = Total Assimilative Capacity (y) (-) Total Estimated Load (PM10) (x) As for the estimation of the pollution load, Aerosol Optical Density (AOD) data of PM2.5 was considered. The PM2.5 values have been extrapolated to PM10. The month-wise ratio of PM10 to PM2.5 for the year 2019 & 2020 was calculated based on the nearest manual Ambient Air Quality Monitoring station i.e. Agra city (35 kms from Rajakhera village). The monitoring data for April & May 2020 were not available due to non-operation of manual station during COVID restriction. For these 02 months, average annual ratio was considered which is 1.57.
The estimated total supportive capacity for the year 2019 is 2019 Month Pollution Monthly Pollution Total Total load in factor of load in Assimilativ Supportive MT PM10/PM MT w.r.t. e capacity in capacity in PM2.5 2.5 PM10 (x) MT w.r.t. MT w.r.t.
PM10 (y) PM10
(z)
January 15 1.4 21 10 -11
February 13 1.34 17.42 13 -4.42
March 11 1.93 21.23 18 -3.23
April 15 2.63 39.45 25 -14.45
May 18 2.63 47.34 28 -19.34
June 17 2.86 48.62 33 -15.62
July 13 1.68 21.84 30 8.16
August 8 1.28 10.24 22 11.76
September 8 1.32 10.56 21 10.44
October 14 1.37 19.18 18 -1.18
November 15 1.18 17.7 12 -5.7
December 13 1.2 15.6 8 -7.6
40
The estimated total supportive capacity for the year 2020 is 2020 Month Pollution Monthly Pollution Total Total load in factor of load in MT Assimilative Supportive MT PM10/PM2. w.r.t. capacity in capacity in PM2.5 5 PM10 MT w.r.t. MT w.r.t.
(x) PM10 PM10
(y) (z)
January 15 1.23 18.45 10 -8.45
February 16 1.46 23.36 13 -10.36
March 10 1.62 16.2 18 1.8
April 13 1.57 20.41 25 4.59
May 18 1.57 28.26 28 -0.26
June 14 2.56 35.84 33 -2.84
July 10 1.81 18.1 30 11.9
August 6 1.24 7.44 22 14.56
September 12 1.59 19.08 21 1.92
October 20 1.65 33 18 -15
November 19 1.3 24.7 12 -12.7
December 18 1.26 22.68 8 -14.68
The above analysis indicates that some supportive capacity may be available during the monsoon months, i.e. July, August & September.
Assessment of restriction of brick kiln operation w.r.t. total Supportive capacity available Based on the above estimation of pollution load, total assimilative & supportive capacity of the Rajakhera block, decision on restriction of brick kiln operation may be planned to sustain the supportive capacity available. For this the factor of pollution load i.e. 0.705 Tons/day/brick kiln (Corrected PM emission load at 17% O2) has been considered.
The year-wise assessment for restriction of brick kiln operation w.r.t. supportive carrying capacity is as tabulated below:
2019 Particulates No. of brick kilns
Month Supportive contribution operation needs to
capacity of single be restricted w.r.t.
available brick kiln in the supportive
in MT w.r.t. Tons/day capacity available
PM10
January -11 -16
February -4.42 -6
41
March -3.23 0.705 -5
April -14.45 - 20
May -19.34 - 27
June -15.62 - 22
July 8.16 +12
August 11.76 +17
September 10.44 +15
October -1.18 -2
November -5.7 -8
December -7.6 - 11
2020 Particulates No. of brick kilns
contribution operation needs to
Month Supportive of single be restricted w.r.t.
capacity brick kiln in the supportive
available Tons/day capacity available
in MT w.r.t.
PM10
January -8.45 -12
February -10.36 -15
March 1.8 +3
April 4.59 +7
May -0.26 0.705 0
June -2.84 -4
July 11.9 +17
August 14.56 +21
September 1.92 +3
October -15 -21
November -12.7 -18
December -14.68 -21
NOTE:
i. The numerical value with (-) symbol indicates the number of
brick kilns whose operation needs to be restricted. ii. The numerical value with (+) symbol indicates the number of brick kilns that can be allowed other then the operational ones.
Study no. 2 Sriganga nagar district, Rajasthan (Year 2021-22) In compliance of the Hon‟ble NGT order dated 10.11.2021 in NGT O.A. 262/2020 (PB) in the matter of Hakam Singh Vs State of Rajasthan & Ors; detailed study of ambient air quality, source emission monitoring and carrying capacity assessment was carried out. The details are as below:
Site visit and monitoring To ascertain the contribution of the brick kiln operation and other activities viz. mining, transportation etc in ambient pollutants viz.42
PM10, PM2.5; the committee opined to carryout Ambient Air Quality (AAQ) monitoring in the upwind and downwind direction of brick kilns during their operational and non-operational period.
Ambient Air Quality monitoring:
The Ambient Air Quality monitoring was carried out by Rajasthan State Pollution Control Board, Bikaner during 15th to 19th Dec 2021 (operational period) & during 26th January to 2nd February 2022 (non-operational period) in brick kiln area of Suratgarh & Anupgarh tehsils of Sriganganagar district.
Monitoring locations during operational period (15th to 19th Dec 2021)
1. Brick Kiln Units, near Gurudwara 7 Chak, Suratgarh (Upwind)
2. Brick Kiln Units, near 6 Chak, Suratgarh (Downwind)
3. Brick Kiln Units. Near 87 GB A, Anupgarh (Upwind)
4. Brick Kiln Units, Near 87 CB B, Anupgarh (Downwind) S. Location Date of 24 hourly Remarks No. monitoring concentration of the pollutants in µg/m3 PM10 PM2.5
1. Brick Kiln Units, near 15.12.2021 206 169 About 70% Gurudwara 7 Chak, brick kilns Suratgarh (Upwind) were operational.
2. Point no. 1 of the 15.12.2021 217 170 (About 200 Brick Kiln Units, near brick kilns 6 Chak, Suratgarh out of (Downwind) consented
286)
3. Brick Kiln Units. Near 18.12.2021 173 137 87 GB A, Anupgarh (Upwind)
4. Brick Kiln Units, Near 18.12.2021 194 138 87 GB B, Anupgarh (Downwind) It is quite evident that PM2.5 is equal in both downwind as well as upwind. There is negligible increment in PM2.5 concentration i.e. 1 µg/m3 in downwind. This contribution of major PM2.5 may be due to other sources like vehicles movements etc. To assess contribution of crop residue based FCBTK brick kilns in 43 particulate matters viz. PM10 & PM2.5, it was opined to carry out particle size analysis of the particulate matter in flue gas. CSIR-
Advanced Materials & Processes Research Institute (AMPRI) was asked to analyze few samples for the particle size analysis. The samples were submitted on 10.3.2022 for the analysis. The analysis work is in progress. On receipt of the report; results with interpretation shall be incorporated.
AAQ Monitoring during non-operational period (23rd January to 2nd February 2022) The brick kilns stopped their operations from the mid of January, 2022 due to the rainfall during 4th to 8th January 2022 and 19th to 22nd January that resulted in re-preparation of green bricks as all prepared bricks ready for firing were wet and became muddy. The heavy rainfall was observed on 5th January 2022 i.e. 24.8 mm/day. The meteorological data from 1.1.2022 to 26.1.2022 available on India Meteorological Department (IMD) website are as tabulated below:
S.NO. Date Ambient Rainfall Wind Wind
Temp (mm/day) Direction Speed
(oC) (Degree) (m/s)
1. 1.1.2022 12 0.0 162 0.14
2. 2.1.2022 13 0.0 228 0.33
3. 3.1.2022 15 0.0 188 0.37
4. 4.1.2022 14 0.1 92 0.57
5. 5.1.2022 13 24.8 179 0.67
6. 6.1.2022 13 5.4 190 0.33
7. 7.1.2022 13 9.1 216 0.42
8. 8.1.2022 11 2.6 231 0.31
9. 9.1.2022 11 0.0 244 0.30
10. 10.1.2022 10 0.0 175 0.41
11. 11.1.2022 10 0.0 201 0.40
12. 12.1.2022 11 0.0 183 0.28
13. 13.1.2022 09 0.0 80 0.43
14. 14.1.2022 10 0.0 164 0.32
15. 15.1.2022 9 0.0 136 0.37
16. 16.1.2022 9 0.0 110 0.45
17. 17.1.2022 10 0.0 82 0.36
18. 18.1.2022 12 0.0 214 0.31
19. 19.1.2022 13 0.9 85 0.55
20. 20.1.2022 11 0.3 118 0.56
21. 21.1.2022 12 0.7 64 0.83
22. 22.1.2022 12 0.6 161 0.41
23. 23.1.2022 12 0.0 120 2.63
24. 24.1.2022 12 0.0 125 0.60
25. 25.1.2022 13 0.0 180 0.84
26. 26.1.2022 11 0.0 224 0.25
44
The rainfall was not observed after 23rd January 2022 and as per the committee opinion, this was the right time to assess the ambient air quality during the non-operational period of brick kilns. The monitoring locations and observed pollutants concentration during 27th Jan to 2nd Feb 2022 at Srivijaynagar are as tabulated below:
S. Location Date of 24 hourly Remarks (field No monitoring concentration of observation) . the pollutants in µg/m3 PM10 PM2.5
1. Near Chugh 27.01.2022 134 76 Kilns were non-
bricks, vill. 36GB, 29.01.2022 127 80 operative in whole Anupgarh road, 31.01.2022 136 84 district.
02.02.2022 143 94
Srivijaynagar Weather was clear
(Upwind) except on 1st Feb,
2. Near house of Sh 27.01.2022 115 77 2022 (Fog in
Sukha Singh, Vill. 29.01.2022 114 79 morning was
36 GB, Anupgarh 31.01.2022 163 121 observed)
rd, Srivijaynagar 02.02.2022 121 103
(Downwind)
The PM10 & PM2.5 during the non-operational period of the brick kilns reveals that the average concentration of PM10 & PM2.5 ranges from 128µg/m3 to 135µg/m3 and 83.5 µg/m3 to 95µg/m3 respectively in upwind and downwind. The higher concentration of pollutant may be due to lifting of fine particles of crustal sand (being non-cohesive), vehicle movement, agricultural activities and other domestic activities.
Source emission monitoring Central Pollution Control Board (CPCB), Regional Directorate, Bhopal vide its letter dated 17.12.2021 constituted the monitoring team for conducting source emission monitoring of 286 brick kilns units having valid consent to operate from Rajasthan State Pollution Control Board. RSPCB also constituted 05 teams to inspect and monitor brick kilns with CPCB. The emission monitoring was scheduled from 3rd January 2022 to 23rd January 2022.
It is pertinent to mention that the monitoring of 286 brick kilns was suspended in between from 8th January 2022 due to the spread of „Omicron‟ COVID variant in the monitoring team and the field conditions were also not feasible due to continuous rainfall as there was no electric earthing provision available on the kiln stack and the brick kilns were planning to shut their operation due to rainfall.
45Further the source emission monitoring shall be scheduled on normalization of the COVID situation and full load operation of the kilns; probably from last week of March 2022.
However, 19 kilns were monitored on 6th to 7th January 2022 during this adverse situation.
The list of brick kilns monitored is as tabulated below with monitored Particulate Matters (PM) concentration in mg/NM3.
S.NO. Name of the brick Kiln Monitored
conc. of PM
in mg/NM3
1. M/s Jai Bharat Brick Industries, Suratgarh 665
2. M/s Bagri Brick Products, Suratgarh 231
3. M/s Bagri Bricks, Suratgarh 190
4. M/s Maheshwari Brick Kiln Company, Suratgarh 279
5. M/s Bagri Brick Kiln Company, Suratgarh 203
6. M/s Bagri Bricks Kiln Industries, Suratgarh 410
7. M/s Deepika Bricks Suppliers, Suratgarh 239
8. M/s Bagri Kilns, Suratgarh 593
9. M/s Bagri Int Udhyog, Suratgarh 661
10. M/s Kothari Bricks Suppliers, Suratgarh 206
11. M/s Bajrang Kiln Company, Suratgarh 421
12. M/s Gumber Int Udhyog, Suratgarh 295
13. M/s Bahlim Kiln Co, Suratgarh 621
14. M/s Sharma Kiln Industries, Suratgarh 209
15. M/s Sharma Int Udhyog, Suratgarh 460
16. M/s Santosh Bricks Manufacturer, Suratgarh 210
17. M/s Ram Shree Int Udhyog, Suratgarh 170
18. M/s Tiger Int Udhyog, Suratgarh 655
19. M/s Vinayak Brick Industries, Suratgarh 191
All the monitored 19 brick kilns were meeting the consented
emission standard of 750mg/NM3.
NOTE: Emission monitoring of the 19 brick kilns, where
concentration varied from 170mg/Nm3 to 665 mg/Nm3 in the crop-residue based FCBTK kilns reveals that the variation may be due to the monitoring at non-isokinetic velocity or due to improper feeding of fuel during the monitoring period. Source emission monitoring at constant velocity in such non-continuous process of firing & non-firing where flue gas velocity varies significantly, is not advisable to get the appropriate emission concentration. It was opined 46 that to verify the compliance, proper methodology needs to be developed by CPCB along with SPCBs.
During discussion with brick kiln representatives, following was brought into the knowledge:
The brick kilns established in 10 Tehsils of Sriganganagar district are mostly based on Fixed Chimney Bull‟s Trench Kiln (FCBTK) technology and uses mustard husk as fuel due to its sufficient availability in this area. The average fuel consumption is 300 kgs/1000 bricks. The fuel cost varied from Rs. 300- 400/quintal based on the availability. On a 21- ghodi brick kiln i.e. arranging 21 bricks of 9 inches each in one row. Each row has 2100-2200 bricks. One row gets completed in about 3-4 hrs heating, i.e. 6 rows in a day operation. By this the average production is 12000-13000 bricks daily. These bricks cool down in about 8 days and removed after 8th day. One firing to non-firing period has average 30 mins gap. On an average 60 kgs fuel is used during each firing period i.e. 2kgs/min; about 3000kgs/day.
Estimation of the carrying capacity of the area To estimate the carrying capacity of the Sriganganagar district w.r.t. brick kilns operation, methodology earlier adopted in Hon‟ble NGT (PB) Original Application No. 1016/2019 in the matter of Utkarsh Panwar Vs CPCB & Ors was considered here too.
Estimation of Existing Pollution Load w.r.t PM2.5 In Sriganganagar district all the 10 tehsils i.e. Srivijaynagar, Anupgarh, Gharsana, Sriganganagar, Suratgarh, Sadulsahar, Rawla, Srikaranpur, Padampur & Raisinghnagar have brick kiln manufacturing units.
Total area (a) : 10930 km2 (Total area of the district as per the Rajasthan Govt. district website https://sriganganagar.rajasthan.gov.in/) 47 Average atmospheric : "Atlas of Hourly Mixing Height and mixing height during Assimilative Capacity of Atmosphere in a particular month in India", published in 2008 by India km (b) : The Meteorological Department, New Delhi. The Mixing height of Hourly mixing height is as tabulated below:
Rajasthan is as per the Mixing height of Rajasthan as per the "Atlas of Hourly Mixing Height and Assimilative Capacity of Atmosphere in India", published in 2008 by India Meteorological Department, New Delhi Day Month & Month & Month & Month & time Season March Season Season Season (hour of Dec-Feb April-June July-Sept Oct-Nov the day) winter Intermediate Summer Monsoon Post Mansoon month of winter & summer Min Max Min Max Min Max Min Max Min Max
1. 20 40 60 75 100 110 70 85 40 60
2. 30 60 85 105 140 150 110 145 80 140
3. 80 110 165 205 250 300 275 340 300 380
4. 180 220 365 410 550 600 525 590 500 580
5. 370 420 635 735 900 1050 850 975 800 900
6. 580 680 1015 1140 1450 1600 1265 1420 1080 1240
7. 720 900 1210 1460 1700 2020 1540 1800 1380 1580
8. 900 1020 1450 1660 2000 2300 1775 2040 1550 1780
9. 950 1100 1525 1775 2100 2450 1850 2205 1600 1960
10. 950 1120 1500 1760 2050 2400 1800 2150 1550 1900
11. 900 940 1400 1660 1900 2380 1600 2015 1300 1650
12. 600 700 1150 1450 1700 2200 1270 1610 840 1020
13. 370 440 785 920 1200 1400 825 990 450 580 Average Mixing 512 596 873 1027 1234 1458 1058 1259 882 1059 height
(m) The monthly available maximum mixing height in KMs is as tabulated below:
Month wise maximum mixing height in KMs Month Mixing Height in KMs January 0.596 February 0.596 March 1.027 April 1.458 May 1.458 June 1.458 July 1.259 August 1.259 September 1.259 48 October 1.059 November 1.059 December 0.596 Total volume of Air in the district boundary in KM3(C) : a x b Average PM2.5 concentration for a particular month in kg/km3 (d):
M/s Suratgarh Thermal Power Plant,
Suratgarh (Sriganganagar)
GPS location 29.163621,74.024601
CAAQMS (Switch Yard) data of Year
2021
Ratio of
Month PM10 PM2.5
PM10/PM2.5
Jan 2021 146 124 1.2
Feb 2021 124 100 1.4
Mar 2021 133 75 1.8
Apr 2021 140 80 1.9
May 2021 124 67 1.9
June 2021 197 101 1.9
July 2021 120 82 1.6
Aug 2021 96 50 1.9
Sep 2021 36 32 1.3
Oct 2021 85 48 1.8
Nov 2021 202 147 1.5
Dec 2021 160 121 1.4
Therefore, total estimated pollution load (in MT) of PM2.5(x) = c x d Total volume of 24 hourly Air in the District PM2.5 pollution Concentration of Month during a load in MT/day PM2.5 in µg/m3 particular month during 2021 (kg/km3) (D) in KM3 (C) (XPM2.5) = C x D January 6514 124 805 February 6514 100 653 March 11225 75 845 April 15936 80 1275 May 15936 67 1075 June 15936 101 1609 July 13761 82 1131 August 13761 50 686 September 13761 32 437 October 11575 48 553 November 11575 147 1701 December 6514 121 790 Estimation of physical assimilative capacity w.r.t. PM10 Total volume of Air in the district Sriganganagar in a particular month in KM3(c) Particulate Matter (PM10) concentration in ambient air as per NAAQ 49 standard:
100μg/m3 i.e. 100 Kg/Km3 (Ref. Air Quality Index/NAAQ Standards, 2009) Therefore, daily Assimilative capacity w.r.t. PM10 in ambient air of the area during a particular month (y): c x 100 = y Kgs Month Total volume of 24 hourly Average Daily Air in the Concentration of Permissible Sriganganagar PM10 in µg/m3 PM10 pollution District during a (kg/km3) as per load in MT/day particular month NAAQS,2009 during 2021 in KM3 (C) (D) (YPM10) = C x D January 6514 100 651 February 6514 100 651 March 11225 100 1123 April 15936 100 1594 May 15936 100 1594 June 15936 100 1594 July 13761 100 1376 August 13761 100 1376 September 13761 100 1376 October 11575 100 1157 November 11575 100 1157 December 6514 100 651 Estimation of physical supportive capacity based on PM10 The formula for assessing the supportive capacity is based on the physical boundaries (Box-model) that works on assumptions of steady-state conditions; i.e. it is supposed that the emissions, wind speed and characteristics of air available for dilution will not vary over time and that pollutants emitted to the atmosphere are uniformly mixed in a volume. Considering this, it is better to call it physical supportive capacity.
Physical Supportive Capacity (z) = Assimilative Capacity (y) - Total Estimated Load (PM10) (XPM10) Month Existing Ratio of Existing PM10 Available PM2.5 PM10/ PM10 Emission PM10 Pollution PM 2.5 Pollution Load(MT/day) Emission Load load Load [Permissible (MT/day) (MT/day) (MT/day) capacity] [Available during 2021 during (YPM10) Physical (XPM2.5) 2021 capacity] 50 (XPM10) (Z)=(YPM10-
XPM10)
January 805 1.2 954 651 (-)302
February 653 1.4 892 651 (-)241
March 845 1.8 1562 1123 (-)439
April 1275 1.9 2362 1594 (-)768
May 1075 1.9 2022 1594 (-)428
June 1609 1.9 3089 1594 (-)1496
July 1131 1.6 1760 1376 (-)384
August 686 1.9 1306 1376 (+)70
September 437 1.3 563 1376 (+)813
October 553 1.8 1008 1157 (+)150
November 1701 1.5 2527 1157 (-)1369
December 790 1.4 1109 651 (-)458
NOTE:
1. The numerical value with (-) symbol indicates that area has no available physical supportive capacity.
2. The numerical value with (+) symbol indicates that area has available physical supportive capacity.
{The methodology earlier adopted in Hon‟ble NGT (PB) Original Application No. 1016/2019 in the matter of Utkarsh Panwar Vs CPCB & Ors was considered for estimating the carrying capacity} It is pertinent to mention here that in the months (March to June) when dispersion is found significantly well, in those months also the physical supportive capacity is not available; this may be due to lifting of fine particles of crustal sand (being non-cohesive), vehicle movement, agricultural activities and other domestic activities. For rationalizing the supportive carrying capacity this factor needs to be incorporated to bring a holistic view on the available carrying capacity.
Cumulative & individual impact of brick kilns on Ambient Air quality:
An expert committee report was submitted in NGT O.A. 31 of 2021 (CZ) in order dated 3.6.2021 (Vijay Singh Vs State of Rajasthan & Ors) regarding the brick kilns operation in Rajakhera village of Dholpur (Rajasthan). There were 103 brick kilns established within 11kms radial distance from 51 Rajakhera block, only one brick kiln is based on Zig-Zag technology and rest all are of Fixed Chimney Bull's Trench Kiln (FCBTK) technology. The major fuel used is Husk (Agro-residue). The committee carried out the sensitivity analysis with available data. The dominant wind speed taken was 0.50-2.10 m/s. 24 hourly predicted PM concentrations levels in Rajakhera Village under 2 emission and 4 meteorological scenarios (as observed in isopleths). Further, for better understanding predicted PM levels (minimum, maximum and average values) at discrete receptor points of Rajakhera village are included. Depending upon the predominant wind direction, the brick kilns in the upwind direction of the village will have more impact on the air quality of the village. Maximum impact is predicted under the worst meteorological condition (wind from N-W direction) to be 24 μg/m3 for actual emission scenario and 36 μg/m3 for combustion corrected emission scenario. Further, impact of a single brick kiln is predicted under the similar situation/scenario. It is predicted that 24 hourly PM concentration from single brick would be about 2.32 μg/m3 and 3.62 μg/m3 for actual and corrected PM emissions scenario at a distance of 500 m from the brick kiln. Similar kind of analysis for Sriganganagar district may help in understanding the cumulative and individual impact of brick kilns and accordingly mitigation measure may be taken.
iv) Impact on Brick Kilns operation on ambient air in categorized different districts of State of Rajasthan The brick kiln distribution in Rajasthan as per the survey report of RSPCB is as shown below in 20 grids of 200x200KM2 area. The major spread is in North- East and South-East.
SENSITIVITY ANALYSIS CPCB has carried out sensitivity analysis for the prediction of Cumulative Impact of all the Existing Brick Kilns with the committee constituted in NGT matter OA 31 of 2021 (CZ) vide order dated 3.6.2021 in the matter of Vijay Singh Vs State of Rajasthan & Ors related to Rajakhera area of Dholpur districts 52 of Rajasthan. The details outcome are as below:
The committee made an effort to predict the cumulative impact of all the 103 brick Kilns in Rajakhera Block on the Air Quality of Rajakhera Village 1.0 Introduction Cumulative impact of all the 103 brick kilns presently operating in the Rajakhera Block has been predicted using widely accepted air quality model (AERMOD) under certain critical meteorological conditions (represented by uni-directional flow with low wind) and with assumption that all the brick kilns are of same capacity and similar amount of emissions are released from all the stacks. The air quality model requires inputs with respect to stack details with flue gas characteristic, and meteorological data (like wind speed, wind direction, relative humidity, ambient temperature etc.) which predicts the resultant air quality in the region/places (receptor) of interest.
The details of model input data with respect to emission sources, meteorological data and predicted resultant air quality in the Rajakhera village is given in the following sections.
2.0 Details of Brick Kilns and Meteorology 2.1 Distribution of Brick Kilns in the Rajakhera Block At present, there are total 103 brick kilns in the Rajakhera Block. Distribution of all the brick kilns is depicted in Fig. 1. These kilns are further divided in three clusters as C1, C2 & C3 based on their location in different directions with respect to Rajakhera village. Cluster C1 (North-West Sector) has most number of brick kilns 62, whereas Cluster C2 (West-South West Sector) has 21 and Cluster C3 has 20 brick kilns. These kilns are located within about 11 km radius from the center of Rajakhera village.
2.2 Stack and Likely Emission details of Brick Kilns At present all the brick kilns are non-operational. In the absence of actual field data of the brick kilns in the Rajakhera Block, stack emission data of similar type of brick kilns (FCBTK) located in Aligarh district has been considered. Aligarh is aerially about 110 km from Rajakhera village. Stack monitoring in the brick 53 kilns was done during June 2021 by the team of CPCB. Stack monitoring data of 8 brick kilns is considered and average values are used for the present analysis. Stack monitoring was done at an average height of about 3 meters from the ground, where portholes are provided in the brick kiln stack. The flue gas exit velocity observed at that level has been calculated at the top of the stack by following the standard procedure. Details of stack and flue gas characteristics considered in the air quality modeling are given in Table 1. Two emission scenarios are considered taking actual PM concentration and PM level corrected to 17% O2 levels.
Table 1: Details of Stack and Flue Gas Characteristics used as Model Input Parameters (based on Actual Data Monitored for 8 Brick Kilns at Aligarh) Sr. Parameter Value No. Type of Fuel Used Coal + Husk A. Monitored at Port Hole Height (3.0 m)
1. Diameter of Stack, m 3.0
2. Flue Gas Velocity, m/s 3.0 3. Flue Gas Temp., K 350 4. Actual PM Concentration, mg/Nm3 273 5. Corrected PM Concentration at 17% 420 O2, mg/Nm3
6. Normalized Flow Volume at 25 C, (Nm3/day) 16,77,818 B. Calculated/Expected at the Stack Top (30.0 m) and used in Modeling Exercise
1. Top Diameter (m) 1.0
2. Exit Flue Gas Velocity (m/s) (corresponding to 27.0 top diameter) 3. Exit Flue Gas Temperature (K) 350 4. Stack Height, (m) 30 5. Actual PM Emission Load, kg/day 458 6. Corrected PM Emission Load at 17% O2, 705 kg/day
7. Actual PM Emission Rate, g/s 5.30
8. Corrected PM Emission Rate at 17% O2, g/s 8.16
9. Daily Operational Schedule 24 hrs Continuous 54
10. Total Number of Brick Kilns in Rajakhera block 103 2.3 Meteorological Data Region specific meteorological data was not available for Rajakhera Block/ Dholpur district, therefore, hourly surface meteorological data collected from the continuous ambient air quality monitoring station (CAAQMS) located at Sanjay Palace, Agra has been used. Agra is about 35 km from Rajakhera village. As most of brick kiln are expected to operate from November-December onwards, typical meteorological data for the month of December is considered. The meteorological pre- processor, AERMET has been setup and run for one day. The meteorological parameters used in the AERMET are wind speed, wind direction, relative humidity, ambient temperature, solar radiation, atmospheric pressure and precipitation. In addition to that, upper air estimator, an in-built feature of AERMOD, is used to estimate the upper air profile of meteorological parameters.
To present the worst case scenario (uni-direction wind flow with low wind speed), the collected meteorological data has been assumed into three uni- directional directions and one with the wind direction spread equally in all the 8 directions. Wind rose for 4 meteorological scenarios are shown in Fig. 2. The uni- directions are selected with a view to consider brick kilns in the upwind direction of Rajakhera village.
3.0 Prediction of Impact due to 103 Brick Kiln Emissions on Rajakhera Village 3.1 Modelling Domain keeping Rajakhera Village as Receptor Air quality modelling has been carried out to predict the likely impact of all the 103 brick kilns operation on the ambient air quality of Rajakhera village. The receptor grid is defined for an area of 11 km x 11 km with Rajakhera village as Centre and grid cell size of 0.5 km x 0.5 km, as shown. Total 2025 receptor points are defined to capture the impact of emission from brick kiln stacks.
Further, 17 discrete receptor points are chosen within 2 km x 2 km region and in all the directions of the Rajakhera village area to predict the PM pollutant concentrations emitted from the brick kiln stacks. The discrete receptor locations are shown.
553.2 Air Quality Modeling Air quality model, AERMOD is used to predict the pollutant concentration emitted from multiple stacks as described in previous sections. The model is setup and run using input data of sources, emissions and meteorology. The model is setup keeping Rajakhera village as centre of modeling domain (11 km x 11 km) using actual UTM coordinate system which is converted to local coordinates for better understanding. Individual stacks are defined in the model and grouped altogether to predict the cumulative impact at Receptor Points under different meteorological and emission scenarios. The cumulative impact of all the 103 brick kilns has been predicted under 4 meteorological scenarios (3 uni-directions and multiple directions) for 2 emission scenarios (actual and corrected PM emissions). The air quality modeling results are presented in the following sub-sections.
3.2.1 Cumulative Impact of 103 Brick Kilns for Actual PM Emission Scenario (458 kg/day) 24-hourly predicted PM Concentration Isopleths for actual PM emission scenario (458 kg/d or 5.30 g/s) considering different wind flow conditions is presented, respectively for N-W sector, W-SW sector, N-E sector and multiple directions. 3.2.2 Cumulative Impact of 103 Brick Kilns for Corrected PM Emission Scenario (705 kg/d) Similarly, 24-hourly predicted PM concentration isopleths for corrected PM emission scenario (705 kg/d or 8.16 g/s) considering different wind flow conditions is presented respectively for N-W sector, W- SW sector, N-E sector and multiple directions. 3.3 Predicted PM Concentration Levels at Rajakhera Village 3.3.1 Cumulative Impact of 103 Brick Kilns 24 hourly predicted PM concentrations levels in Rajakhera Village under 2 emission and 4 meteorological scenarios (as observed in isopleths) are summarized in Table 2. Further, for better understanding predicted PM levels (minimum, maximum and average values) at discrete receptor points of Rajakhera village are included.
56Depending upon the predominant wind direction, the brick kilns in the upwind direction of the village will have more impact on the air quality of the village. Maximum impact is predicted under the worst meteorological condition (wind from N-W direction) to be 24 µg/m3 for actual emission scenario and 36 µg/m3 for combustion corrected emission scenario.
Table 2: Predicted 24 hourly PM Concentrations Levels in Rajakhera Village for Different Emission and Met Scenario Sr. PM Emissions / No. of PM Conc. PM Conc. (µg/m3) No. Meteorological Brick Range based Min. Max. Avg.
Scenario Kilns on Isopleths
likely to (µg/m3)
impact
1. Actual Emission Scenario (458 kg/d or 5.30 g/s) a. North-West (N-W) 62 20-30 23 24 24 Sector b. West-South West 21 10-20 9 18 13 (W-SW) Sector c. North-East (N-E) 20 1-10 9 10 9 Sector d. All Directions 103 1-10 3 5 4
2. Corrected Emission Scenario (705 kg/d or 8.16 g/s) a. North-West (N-W) 62 30-45 35 37 36 Sector b. West-South West 21 15-30 13 28 20 (W-SW) Sector c. North-East (N-E) 20 1-15 14 16 15 Sector d. All Directions 103 1-15 5 8 6 3.3.2 Impact of Single Brick Kiln Further, impact of a single brick kiln is predicted under the similar situation/scenario. It is predicted that 24 hourly PM concentration from single brick would be about 2.32 µg/m3 and 3.62 µg/m3 for actual and corrected PM emissions scenario at a distance of 500 m from the brick kiln. The predicted PM levels at different distances are summarized in Table 3.
57Table 3: Predicted 24 hourly PM Concentration from Single Brick Kiln at different Downwind Distances Distance in PM Concentrations (µg/m3) Downwind Actual Emission Corrected Emission Direction Scenario (458 kg/d or Scenario (705 kg/d or 5.30 g/s) 8.16 g/s) N-W All N-W All Sector Directions Sector Directions Wind Flow Wind Flow Wind Flow Wind Flow 500 m 2.32 0.01 3.62 0.02 1 km 1.28 001 3.18 002 1.5 km 0.99 0.01 2.10 0.02 2 km 0.84 0.01 1.37 0.01 2.5 km 0.59 0.01 1.13 0.01 3 km 0.47 0.01 1.06 0.01 5 km 0.40 0.00 0.66 0.01 10 km 0.36 0.00 0.56 0.00 Limitation: In the absence of actual stack emission data for the brick kilns and meteorological data of the Rajakhera Block, similar/corresponding data for the nearby brick kilns in Aligarh region and met data of Agra has been used in the air quality modelling. Therefore, the air quality prediction results should be treated as indicative values. It is recommended that this exercise need to be updated for the brick kilns of Rajakhera block adopting "Guidelines on Methodologies for Source Emission Monitoring" published by CPCB and actual meteorological data for the Rajakhera region.
Based on the supportive capacity estimation and the sensitivity analysis outcomes; regulatory authority may take decision on the month-wise restriction on the operation of the brick kilns situated on the upwind direction i.e. North, North-West considering the distance from the Rajakhera village.
58V) SAAQMS data with respect to PM concentration for year 2021-22 The Ambient air quality data for FY 2021-22 of 10 CAAQMS stations reveals that in the particular months when Air quality is not as per NAAQS, 2009, due to no supportive carrying capacity the brick kiln operation needs to be restricted. The details are as tabulated below:
Cities No. of Months (FY 21- Name of the months
22) in which average AAQ was exceeding PM10 standard of 100µ/m3 Alwar 3 Nov 21 to Jan 2022 Ajmer 6 April 2021, Nov 21 to March 2022 Bhiwadi 11 April 21 to Aug 21, Oct 21 to March 2022 Udaipur 6 April 2021, Nov 21 to March 2022 Jaipur 9 April 21 to June 21, Oct 21 to March 2022 Kota 6 April 2021, Nov 21 to March 2022 Jodhpur 11 April 21 to Aug 21, Oct 21 to March 2022 Pali 7 April-May 21 & Nov 21 to March 22 Monthly Ambient Air Quality monitored at 10 CAAQMS stations established in Rajasthan 59 Parameters Monthly City Concentration Apr-21 May-21 Jun-21 Jul-21 Aug-21 Sep-21 Oct-21 Nov-21 Dec-21 Jan-22 Feb-22 Mar-22 (microgram/m
3) Minimum 54 31 38 44 46 46 48 81 73 52 59 61 PM10 Maximum 117 240 132 176 115 88 99 191 154 176 124 132 Average 84 66 71 82 76 62 75 124 107 108 89 99 Alwar Minimum 23 15 18 20 23 22 24 37 39 27 25 24 PM2.5 Maximum 54 98 46 144 49 33 62 107 91 81 59 53 Average 43 32 31 35 30 27 38 69 58 57 38 38 Minimum 65 39 50 41 31 46 38 54 45 35 60 72 PM10 Maximum 281 161 218 109 145 101 145 257 177 203 225 186 Average 113 84 79 71 79 63 98 115 109 103 109 115 Ajmer Minimum 24 22 23 24 23 22 26 27 28 25 34 29 PM2.5 Maximum 165 70 71 46 54 50 75 144 114 89 110 103 Average 53 41 35 36 38 31 53 58 56 57 59 55 Minimum 143 65 74 69 47 54 83 222 158 69 86 146 PM10 Maximum 440 503 495 244 259 180 369 814 443 326 350 331 Average 310 178 195 127 136 86 225 381 282 205 199 252 Bhiwadi Minimum 71 38 39 30 25 26 33 106 63 39 37 70 PM2.5 Maximum 211 242 205 98 127 96 195 440 218 203 186 165 Average 149 89 94 56 59 43 103 194 137 111 104 119 Minimum 73 42 44 26 61 33 38 61 83 61 95 79 PM10 Maximum 159 228 143 155 134 110 140 276 204 232 206 182 Udaipur Average 107 99 76 81 95 67 99 158 148 150 141 138 PM2.5 Minimum 36 18 23 18 32 17 23 40 44 23 43 38 Maximum 62 78 59 58 60 43 68 186 121 113 86 84 Average 49 41 36 36 42 32 48 87 79 75 58 64 60 Minimum 53 16 62 30 25 22 29 91 86 47 63 71 PM10 Maximum 203 149 264 113 114 74 182 258 190 192 260 181 Jaipu r-1 Average 127 87 106 74 73 40 103 168 128 106 113 127 (Psy. Minimum 33 8 36 16 15 8 17 50 56 22 28 30 Center) PM2.5 Maximum 103 71 75 57 52 47 123 190 117 141 92 116 Average 61 39 47 37 34 22 51 111 85 64 51 61 Minimum 61 29 64 31 51 34 44 93 122 71 59 78 PM10 Maximum 236 181 267 117 141 76 164 300 262 281 382 210 Jaipur-
2 Average 132 103 117 72 86 51 107 173 183 167 156 139 Scienc Minimum 27 13 31 17 23 13 17 53 45 29 27 34 e Park PM2.5 Maximum 86 72 100 52 59 34 78 184 98 113 132 93 Average 52 42 46 32 35 23 49 94 70 68 63 63 Minimum 58 23 69 42 39 32 61 145 105 71 72 88 PM10 Maximum 278 435 289 131 140 119 261 355 233 329 309 223 Jaipur-
3 Police Average 139 112 114 79 83 68 153 218 161 167 153 156
Commi Minimum 34 12 35 18 19 19 33 64 49 34 33 34
ssioner PM2.5
ate Maximum 124 195 80 53 55 54 123 236 129 183 106 116
Average 76 54 49 37 38 32 77 100 85 88 69 74
Minimum 92 39 56 36 40 36 41 93 70 55 87 64
PM10
Maximum 466 158 116 124 104 74 147 345 213 172 208 176
Kota Average 145 89 74 63 62 50 89 170 138 114 138 134
Minimum 48 15 23 14 21 19 24 54 48 35 43 38
PM2.5
61
Maximum 138 82 71 50 48 47 86 257 131 136 96 84
Average 67 47 39 28 35 27 50 121 99 80 69 66
Minimum 107 45 90 66 88 56 75 100 117 65 111 109
Jodhpur PM10
Maximum 677 344 320 193 161 99 259 322 352 306 281 241 Average 228 152 130 114 118 76 144 222 180 172 176 173 Minimum 52 20 44 30 40 27 38 58 58 31 60 60 PM2.5 Maximum 205 132 100 86 78 51 129 210 192 164 127 112 Average 91 63 60 53 58 40 71 108 89 81 85 84 Minimum 128 38 60 51 42 51 51 64 52 66 72 73 PM10 Maximum 120 178 178 141 117 96 124 192 141 174 165 175 Pali 3 Average 212 123 97 81 76 68 92 117 102 104 114 118 Minimum 58 18 34 25 25 24 29 32 37 31 43 40 PM2.5 Maximum 31 76 100 59 53 47 66 119 101 89 95 88 1 Average 82 51 55 40 37 35 45 69 62 59 62 64 62 The studies pending as per the Hon'ble NGT order:
1. Analysis report of the soil quality
2. Impact of brick kilns on the air quality grid-wise/district-wise.
Performance evaluation of brick kilns w.rit the background concentration and carrying capacity of the area.
Recommendations:
1. A large number of brick kilns are still operating on FCBTK.
Conversion of brick kiln as per the notification dated 22.2.2022 is to be implemented by the brick kilns owners to reduce the air pollution.
2. Based on the earlier carrying capacity study of Rajakhera block, Dholpur & Sriganganagar district, the regulation on the brick kiln operation may be imposed for the month in which negative supportive carrying capacity prevails. The Air Quality data of 10 CAAQMS stations for year 2021-22 reveals that the negative supportive capacity prevails from 3 months to 11 months in cities like Alwar, Ajmer, Bhiwadi, Udaipur, Jodhpur, Jaipur, Kota, Pali.
3. RSPCB shall initiate action against the violators operating the kiln near by the non-attainment cities without converting to zig- zag."
18. Respondent nos. 06 to 14 were also given an opportunity of hearing and the reply has been filed on behalf of different ईंट भट्टा एसोससएशन (Brick Kiln Association) with the facts that brick kiln industries are not accountable for the air pollution or any health hazards due to air pollution. It is further submitted that the studies and reports source that the factors contributing 63 to air pollution are vehicular movements, dust storms, agriculture activities and domestic activities.
19. The similar matter was considered in O.A. No. 1016/2019 titled Utkarsh Panwar vs. CPCB & Ors. vide order dated 11.02.2021 uploaded on 17.02.2021 and it was observed as follows :-
A. Order dated 23.03.2020:
1. "We have considered the above data which shows that in the corresponding months when brick kilns were operating, standard of air quality was not as per prescribed norms. Thus, the air quality of the area is unable to take further pollution load. In this regard, it may be noted that while considering the issue of operation of brick kilns in non-NCR area, where GRAP was not applicable as such, in O.A. No. 1088/2018, Dinesh Chahal & Ors. vs. Union of India & Ors., the Tribunal vide order dated 30.04.2019 observed that standards of ambient air quality are required to be maintained under Section 17(g) of the Air Act, 1981:
"3. ... The matter was again considered on 21.02.2019 with reference to the contention that the impugned order was only for Non-NCR to which order of CPCB or EPCA did not apply. The Tribunal held that even in Non-NCR, Standards of Ambient Air Quality laid down under Section 17
(g) of the Air Act are required to be followed.
If the impugned order has been passed without undertaking any study on status of ambient air quality without any carrying capacity assessment to take the additional load at concerned areas 64 and without any safeguards on „Precautionary‟ principle, the same may not be justifiable having regard to the acknowledged adverse impact of operation of the brick kilns on the ambient air quality. Reference was made to the Judgements of the Hon‟ble Supreme Court in M.C. Mehta v. Union of India, (1998) 9 SCC 149, M.C. Mehta v. Union of India (2000) 7 SCC 422, M.C. Mehta v. Union of India, (2002) 4 SCC 378, K. Guruprasad Rao v. State of Karnataka, (2012) 12 SCC 736 wherein the Hon‟ble Supreme Court directed closure or shifting of brick kiln industries and M.C. Mehta v. Union of India, (2001) 9 SCC 235 laying down that brick kilns may be allowed to operate after studying the impact on human population and vegetation."
2. Learned Counsel for the brick kiln operators, however, submit that prohibition on operation of brick kilns be lifted as some individual brick kilns meet the air quality emission standards laid down under the Environment (Protection) Rules, 1986 and the brick kilns are not the only source of pollution. Contribution of all the brick kilns taken together, to the air pollution, was about 3%. It was also mentioned that as at present air quality norms are within limit in seven districts out of 15 districts of NCR.
3. As observed earlier, the question is not merely of an individual brick kiln not emitting pollution or the extent of contribution of the brick kilns taken separately, but of the capacity of the area being already air polluted and unable to take the load of pollution. When there is no carrying capacity in the area for further air pollution, we find it difficult to permit operation of the closed brick kilns to 65 uphold the „Sustainable Development‟ principle. When even without operation of the brick kilns the air quality is not within the norms, the impact of operation of the brick kilns cannot be ignored. Thus, we find it difficult to accept the submission that the individual brick kilns maintaining the prescribed standards for discharge of emissions are entitled to operate or that they be allowed to operate on the ground that pollution caused by the brick kilns is less than other pollution from other sources irrespective of carrying capacity of the area. The fact remains that brick kilns add to the air pollution and thereby affect right of citizens to breathe fresh air.
4. We may now consider another aspect of the matter i.e. impact of the brick kilns on the top soil. As noted in order dated 05.03.2020, CPCB has undertaken to look into this aspect and has not yet completed its study. As per available study, there is huge environmental cost in using top soil for making brick making 1. Reference may also be made to a study on "The Impact of Brick Kiln operation to the degradation of topsoil quality of Agricultural Land 2". There is further issue of unutilized fly ash adversely affecting the environment which may require barring red clay brick kilns. This is proposed in a draft notification of the MoEF&CC 25.02.2019 within 300 kms of coal or lignite based thermal power plants. No doubt the said notification is only a draft but the same is evidence of such step being necessary for sustainable development.
1www.journals.sagepub.com/doi/abs/10.1177/0974929214521892# (Environmental Cost of using top-soil for brick making - a case study form India (MoEF, GoI project) (Published in Review of Market Integration, 2013) Vinish Kathuria, Professor, IIT Bombay - March 11, 2015.
2www.researchgate.net/publication/282431176_The_impact_of_brick_kiln_operation_to_the_ degradation_of_to psoil_quality_of _agricultural_land.
665. Main reason for air pollution by brick kilns is use of coal etc. as fuel. The pollution can be minimized if the fuel which is currently used is considered to be replaced by cleaner fuels like PNG by appropriate modification in design not adding to the PM load. Dealing with the air pollution caused in Morby Industrial Area in Gujarat on account of coal gasifiers in tile manufacturing, the Tribunal directed closing of coal gasifier industries without prejudice to such industries switching over to non-coal gasifiers, PNG or other such technology. It was directed 3:
"25. Accordingly, we allow the applications and direct the GPCB to close all coal gasifiers industries and units operating with the help of coal gasifiers without prejudice to such units switching over to non-coal gasifiers or PNG or technology consistent with the above report. The GPCB must initiate immediate steps for prosecution of the industries which have operated in violation of law and recover compensation for causing damage to the environment and public health."
6. Issue of allowing operation of brick kilns may give rise to following questions:
i. The use of cleaner fuels or any other alternative measures to be used to prevent air pollution.
ii. Siting and carrying capacity.3
Order dated 06.03.2019 in O.A. No. 20/2017 (WZ), Babubhai Ramubhai Saini vs. Gujarat Pollution Control Board& Ors.67
7. In view of the fact that there is no carrying capacity of the air quality in NCR region to permit any further addition to PM load by permitting unconditional operation of brick kilns using fuel which adds to PM load and since it may be necessary to consider the issue of utilizing fly ash, we require an expert opinion on following issues:
a) how brick kilns can be allowed in NCR without damage to the air quality;
b) conditions subject to which it may be done;
c) number of brick kilns to be allowed and criteria for fixing such numbers."
20. It is further argued by the brick kiln owners that :- the FCBTK technology based kiln on natural draft runs majorly on crop residue (mustard) that is available in plenty in this area. The average stack height is 30 mtrs. On an average 6T daily crop residue is consumed by individual kiln of 20,000- 30,000 bricks/day capacity. Other than the source, emission, vehicle transportation, fuel handling, leakages, kaccha road, and nearby agricultural activities, along with the natural condition, (sandy soil and sand dunes) are also contributing in increased level of particulate matters in Ambient Air even when none of the kiln was operational. The ambient air quality monitored during operational days of bricks revealed that the change in PM2.5 is negligible in downwind. The particle size distribution of few source emission sample shown a wide variation in fraction of PM2.5 & PM10 and their ratio doesn't provide much insight on the contribution of 68 kilns in PM2.5 / PM10to conclude on emission factor w.r.t. PM2.5 or PM10 and on the basis of that, it is submitted that the brick kilns operated by the answering respondents use agree residue as a fuel which does not emit any sulfur oxide and thus, no harmful or toxic elements are released in the air.
21. On the point of the use of PNG it is submitted that the use of PNG is not applicable in so far as the State of Rajasthan because State does not have the infrastructure to provide large quantities of PNG and to ensure that the same is available in all districts. The report of the State PCB enumerate that :-
i. "Brick kilns require large volume of PNG. Expert man power is required to handle it and work has to be carried out according to strict schedules and parameters, which looks very difficult in brick kilns.
ii. The pricing of PNG taken from Agra for industrial use showed the market rate to be Rs.45ISCM. The Brick Kilns would further require to make modification in their plants and arrange for internal pipeline from. downstream of meter .till the gas consumption points which requires additional expenditure. Therefore, the switch to PNG would increase the cost of the manufacturing multifold.
iii. The technology to use PNG in brick kilns is not available indigenously and has to be imported. Even the equipment with the required safety devices has to be imported. The 69 aforementioned reasons provided in the report. Amply clarifies, that the switch to PNG is not viable.
iv. There are total 573 brick kilns spread in all the 10 Tehsils of Sriganganagar district. The district has sandy soil and presence of sand dunes. The FCBTK technology based kiln on natural draft runs majorly on crop residue (mustard) that is available in plenty in this area. The average stack height is 30 mtrs, On an average 6T daily crop residue is consumed by individual kiln of 20,00030,000 bricks/day capacity.
Other than the source, emission, vehicle transportation, fuel handling, leakages, kaccha road, and nearby agricultural activities, along with the natural condition, (sandy soil and sand dunes) are also contributing in increased level of particulate matters in Ambient Air even when none of the kiln was operational. The ambient air quality monitored during operational days of bricks revealed that the change in PM2.5 is negligible in downwind. The particle size distribution of few source emission sample shown a wide variation in fraction of PM2.5 and PM10 and their ratio doesnot provide much insight on the contribution of kilns in PM2.5 or PM10.to conclude on emission factor w.r.t. PM2.5 or PM10.
70v. The FCBTK technology based kiln on natural draft runs majorly on crop residue (mustard) that is available in plenty in this area. The average stack height is 30 mtrs. On an average 6T daily crop residue is consumed by individual kiln of 20,000 - 30,000 bricks/day capacity."
22. It is further submitted that the report submitted by the committee is silent on any impact of the operation of the brick kilns to the death rate in the area. In .the absence of any data, report or any other reliable scientific data, no liability can be fastened 'upon the brick industry. Interestingly; the Report attributes the level of air pollution to "traffic". It submits that re-routing and provision .of alternative routes, limit the movement of heavy vehicles on the agreed-upon ways, the organization of periodic maintenance of vehicles and the promotion of the public transport instead of private cars is worthy of attention for control of pollution caused by transport. In addition, it was also submitted, that a project be undertaken to educate the public about the need to protect the environment and to promote green areas, roads and industrial companies. Therefore, it is most respectfully submitted, that the conclusion sought to be drawn by the Applicant in the answering paragraph is not only incorrect but entirely baseless and uncorroborated.
23. It is further submitted that the brick kiln industry in district Sriganganagar is complying with the pollution control standard set up by the State PCB and the same has been duly noted in the case of Hakam Singh. The compliance with 71 regard to viability at the PNG is presently unfeasible for the following reasons :-
i. "Brick kilns require large volume of PNG. Expert man power is required to handle it and work has to be carried out according to strict schedules and parameters, which looks very difficult in brick kilns.
ii. The pricing of PNG taken from Agra for industrial use showed the market rate to be Rs.45/SCM. The Brick Kilns would further _ require to make modification in their plants and arrange for internal pipeline from downstream of meter till the gas consumption points which requires additional expenditure. Therefore, the switch to PNG would increase the cost of the manufacturing multifold.
iii. The technology to use PNG in brick kilns is not available indigenously and has to be imported. Even the equipment with the required safety devices has to be imported. Additionally, the training and expertise required to handle the usage of PNG would further lead to unemployment in the area which would impact numerous families. It is for these reasons, that the Hon‟ble Supreme Court has culled out the principle of "Sustainable Development".
24. The contention of the brick kiln owners are that they have adopted all the precautionary conditions and criteria provided by the state PCB from time to time and have further represented to the state PCB to restrict the operation of the brick kilns industry from January to June (extended to next 15 days).
7225. On the basis of above contention of the brick kiln owners the committee/CPCB was directed to consider the following points:-
i. Analysis report of the soil quality ii. Impact of brick kilns on the air quality grid-wise/district-
wise. Performance evaluation of brick kilns w.r.t. the background concentration and carrying capacity of the area.
And the committee revisited the above matters and submitted the report with the following facts :-
1. "ANALYSIS REPORT OF THE SOIL QUALITY (impact of brick kilns operation on loss/degradation of top soil) To study the impact of brick kilns operation on loss/degradation of top soil, the methodology adopted in NGT O.A. 1088 of 2018 Dinesh Chahal & UOI was used in this study. To assess the loss of top soil due to brick kiln activity, soil samples (from upper 15 cm layer) were collected by the CPCB team from the land where top soils had been removed for brick manufacturing. For assessing loss of soil fertility due to brick manufacturing, samples of top soil (from upper 15 cm layer) were collected from the same land where soils were not yet removed from brick manufacturing. In places of brick kiln activity where such un-dugged soils could not be clearly identified visually, surface soils were collected from nearest agricultural lands for comparison.73
Total 16 soil samples were collected during in 9th June to 10th June 2023 from 03 districts viz. Sriganganagar, Churu & Ajmer from agricultural land & mined out area to assess the soil quality for total 10 parameters viz. pH, EC, Organic Carbon, N, P, K, Fe, Mn, Zn & Cu. The samples were analysed by ICAR-Indian Institute of Soil Science, Bhopal institute for required analysis.
Outcome of the analysis results:
The soil samples were air dried, processed and sieved through 2 mm sieve. The processed soil samples were analyzed for various soil fertility parameters. The pH and electrical conductivity (EC) of soil samples were measured in soil: water solution of 1:2 ratio, whereas soil organic carbon was estimated by following a wet oxidation method (Walkley and Black, 1934). Plant available micronutrient was extracted by the DTPA extractant (Lindsay and Norvell 1978) and analyzed in ICP-OES instrument. Available nitrogen, phosphorus and potassium content in soil was estimated following standard protocol (Av- N (Kjeldahl method; Subbaiah and Asija, 1956), Av-P (Olsen et al., 1954), Av- K (ammonium acetate extraction; Hanway and Heidel, 1952). The result indicates that variation in soil fertility parameters exist among the sampling sites. For comparison of soil parameters, mean values obtained from all agricultural field sample (site 1,3,5,7,9,11,13,15) were compared with mean value obtained from all brick kiln sample (site 2,4,6,8, 10,12,14,16) were used. It is evident from the result that the soil parameters indicating the soil fertility status like organic carbon (OC), available, N, P, K, Fe, Mn, Zn and Cu are significantly lower in the brick kiln soil as compared to agricultural surface soil sample indicating reduction in soil fertility due to brick kiln and may result in decline in crop productivity.
The results are as tabulated below:
74Table 1 Soil Fertility parameters of soil sample collected from various locations Availabl Availabl Availabl S. Location Name Location Geo location OC pH EC Fe Mn Zn Cu typeof eN eP eK No. soil (%) (ds/m) Kg/ha PPM sample Sh Dinesh Bishnoi, Agriculture 29.316572, 1 0.3 8.6 0.834 156.8 33.53 451.68 1.1 8.35 0.5 0.73 Village-Jetsar, The- soil 73.618991 Vijaynagar Soil of 29.316423, 2 Bisnoi Int Bhatta, 0.1 9.4 0.658 125.44 12.76 225.6 0.94 5.55 0.17 0.54 Jatsar minedout 73.618423 area Navneet Balana, Agriculture 29.239222, 3 0.2 8.4 0.517 112.9 22.15 371.04 1.55 5.66 0.13 0.31 33GB,Srivijaynagar soil 73.497494 A-1 Brick Kiln, 33GB, Soil of 29.239682, 4 0.2 9 2.425 100.35 20.49 304.96 1.51 5.45 0.28 0.56 Srivijanagar minedout 73.498334 area Shri Baghla, Chak- Agriculture 29.373775, 5 0.3 8.9 0.279 200.7 29.15 385.12 2.13 8.65 0.38 0.47 1SGM,Suratgarh soil 73.860924 Badhla Int Udhyog, Soil of 29.373564, 6 0.2 8.6 1.717 100.35 15.4 260.16 1 4.53 0.14 0.35 Chalk-1SGM, minedout 73.860216 Suratgarh area Shyam ji ka Khet, Agricult 29.505807, 7 0.2 9 0.363 160.35 22.11 327.36 0.92 4.3 0.5 0.33 15SGM,Suratgarh ure soil 73.874694 Jai Sri Shyam Int Soil of 29.505581, 8 0.2 8.9 0.182 134.43 22.31 315.2 0.97 5.81 0.39 0.35 Udhyog,15SGM, minedout 73.874883 Suratgarh area S M Brick agri field, Agricult 29.835994, 9 0.3 9.3 0.487 150.53 18.13 367.84 1.63 8.59 0.35 0.74 Netwadavillage, ure soil 73.876863 Sriganganagar 75 S M Brick Supplier, Soil of 29.835348, 10 0.3 8.8 0.339 112.9 15.63 259.44 1.62 8.64 0.45 0.75 Netwada, minedout 73.874785 Sriganaganagar area Sh Punia ji Agri field, Agricult 29.740304, 11 0.3 8.8 0.26 206.98 10.2 302.88 1.22 7 0.56 0.36 Ganesggarh, ure soil 73.874262 Sriganagnagar Punia Int Udhyog, Soil of 29.739474, 12 0.2 8.7 0.255 194.43 2.53 145.6 1.05 2.61 0.58 0.2 Ganeshgarh,Srigangan minedout 73.873868 agar area Sh ShyamSundar Agricult 28.136243, 13 0.1 9 1.568 112.9 10.41 211.68 1.31 5.07 0.72 0.32 agri field, Ladsar, ure soil 74.617746 Ratangarh, Churu BBC Int Udhyog, Soil of 28.136411, 14 0.1 10 0.129 106.62 1.85 125.84 1.37 4.29 0.53 0.11 Ladsar, mined out 74.617459 Ratangarh, area Churu Andul Rahim agri Agricult 26.53029, 15 0.2 8.8 1.03 194.43 28.98 289.12 1.74 5.09 0.37 0.53 field, Gegal, Ajmer ure soil 74.758342 Maa Vaishnodevi Int Soil of 26.534605, 16 0.2 9.9 0.763 94.08 1.27 102.88 1.3 3.97 0.12 0.19 Udhyog, Kishangarh, mined out 74.764204 Ajmer area Table 2: Mean value of sampling sites for different soil fertility parameters Sampling Locations OC pH EC Available Available Available Fe Mn Zn Cu Nitrogen Phosphorus Potassium (%) (ds/m) Kg/ha PPM Agriculture soil 0.24 8.82 0.667 161.9 21.8 338.3 1.45 6.59 0.438 0.473 0.17 9.15 0.808 121.1 11.5 217.5 1.22 5.11 0.333 0.380 Soil of mined out area 76
2. Impact of brick kilns on the air quality grid- wise/district-wise.
Performance evaluation of brick kilns w.r.t the background concentration and carrying capacity of the area.
2.1 Estimation Of The Carrying Capacity Of The 07 Districts To estimate the carrying capacity of the 07 district i.e. Alwar, Ajmer, Udaipur, Jaipur, Kota, Jodhpur & Pali based on the available CAAQMS data for FY 2021-22; the methodology earlier adopted in Hon‟ble NGT (PB) Original Application No. 1016/2019 in the matter of Utkarsh Panwar Vs CPCB & Ors was considered here too.
Estimation of Existing Pollution Load w.r.t PM10 Total area (a) :
Total area of the 07 district as per the Rajasthan Govt. district website (https://forest.rajasthan.gov.in/content/raj/forest/en/resources/forest
-statistics/general-introduction1/district-wise---forest-area-w-r-t-- geographical-area.html) is as tabulated below:
S. Geographical Area
No. Cities (SQKM)
1. Alwar* 8380
2. Ajmer 8481
3. Udaipur 11724
4. Jaipur 11143
5. Kota 5217
6. Jodhpur 22850
7. Pali 12387
*- Alwar includes Bhiwadi too
Average atmospheric : The Mixing height of Rajasthan is as per
mixing height during the "Atlas of Hourly Mixing Height and
a particular month in Assimilative Capacity of Atmosphere in
km (b) the India", published in 2008 by India
Meteorological Department, New Delhi. The Hourly mixing height is as tabulated below:77
Mixing height of Rajasthan as per the "Atlas of Hourly Mixing Height and Assimilative Capacity of Atmosphere in India", published in 2008 by India Meteorological Department, New Delhi Month & Month & Month & Month & Season March Season Season Season Day Dec-Feb April- July-Sept Oct-Nov time June (hour of Intermedia the winter te month of Summer Monsoon Post day) winter & Monsoon summer Min Max Min Max Min Max Min Max Min Max 7 20 40 60 75 100 110 70 85 40 60 8 30 60 85 105 140 150 110 145 80 140 9 80 110 165 205 250 300 275 340 300 380 10 180 220 365 410 550 600 525 590 500 580 11 370 420 635 735 900 1050 850 975 800 900 12 580 680 1015 1140 1450 1600 1265 1420 1080 1240 13 720 900 1210 1460 1700 2020 1540 1800 1380 1580 14 900 1020 1450 1660 2000 2300 1775 2040 1550 1780 15 950 1100 1525 1775 2100 2450 1850 2205 1600 1960 16 950 1120 1500 1760 2050 2400 1800 2150 1550 1900 17 900 940 1400 1660 1900 2380 1600 2015 1300 1650 18 600 700 1150 1450 1700 2200 1270 1610 840 1020 19 370 440 785 920 1200 1400 825 990 450 580 Average Mixing 512 596 873 1027 1234 1458 1058 1259 882 1059 height (m) The monthly available maximum mixing height in KMs is as tabulated below:
Month wise maximum mixing height in KMs Month Mixing Height in KMs January 0.596 February 0.596 March 1.027 April 1.458 May 1.458 June 1.458 July 1.259 August 1.259 September 1.259 October 1.059 November 1.059 December 0.596 78 Total volume of Air in the district boundary in KM3(C) : a x b Total volume of Air in the district boundary in KM3 Month Alwar Ajmer Udaipur Jaipur Kota Jodhpur Pali Apr-21 12218 12365 17094 16246 7606 33315 18060 May-21 12218 12365 17094 16246 7606 33315 18060 Jun-21 12218 12365 17094 16246 7606 33315 18060 Jul-21 10550 10678 14761 14029 6568 28768 15595 Aug-21 10550 10678 14761 14029 6568 28768 15595 Sep-21 10550 10678 14761 14029 6568 28768 15595 Oct-21 8874 8981 12416 11800 5525 24198 13118 Nov-21 8874 8981 12416 11800 5525 24198 13118 Dec-21 4994 5055 6988 6641 3109 13619 7383 Jan-22 4994 5055 6988 6641 3109 13619 7383 Feb-22 4994 5055 6988 6641 3109 13619 7383 Mar-22 8606 8710 12041 11444 5358 23467 12721 Average PM10 concentration for a particular month in kg/km3 (d):
Average month-wise PM10 concentration in Kg/KM3 Month Alwar# Ajmer Udaipur Jaipur* Kota Jodhpur Pali Apr-21 197 113 107 133 145 228 212 May-21 122 84 99 101 89 152 123 Jun-21 133 79 76 112 74 130 97 Jul-21 105 71 81 75 63 114 81 Aug-21 106 79 95 81 62 118 76 Sep-21 74 63 67 53 50 76 68 Oct-21 150 98 99 121 89 144 92 Nov-21 253 115 158 186 170 222 117 Dec-21 195 109 148 157 138 180 102 Jan-22 157 103 150 147 114 172 104 Feb-22 144 109 141 141 138 176 114 Mar-22 176 115 138 141 134 173 118 79 # - The average PM10 concentration of Alwar & Bhiwadi CAAQMS data *- The average PM10 concentration of 03 CAAQMS stations established in Jaipur Therefore, total estimated pollution load (in MT) of PM10(x) = c x d Month Total estimated pollution load (in MT) of PM10 Alwar# Ajmer Udaipur Jaipur* Kota Jodhpur Pali Apr-21 2407 1397 1829 2161 1103 7596 3829 May-21 1491 1039 1692 1641 677 5064 2221 Jun-21 1625 977 1299 1820 563 4331 1752 Jul-21 1102 758 1196 1052 414 3280 1263 Aug-21 1118 844 1402 1136 407 3395 1185 Sep-21 781 673 989 744 328 2186 1060 Oct-21 1331 880 1229 1428 492 3485 1207 Nov-21 2241 1033 1962 2195 939 5372 1535 Dec-21 971 551 1034 1043 429 2451 753 Jan-22 782 521 1048 976 354 2342 768 Feb-22 719 551 985 936 429 2397 842 Mar-22 1510 1002 1662 1614 718 4060 1501 # - The average PM10 concentration of Alwar & Bhiwadi CAAQMS data *- The average PM10 concentration of 03 CAAQMS stations established in Jaipur Estimation of physical assimilative capacity w.r.t. PM10 Total volume of Air in the 07 districts of Rajasthan in a particular month in KM3(c) Particulate Matter (PM10) concentration in ambient air as per NAAQ standard: 100μg/m3 i.e. 100 Kg/Km3 (Ref. Air Quality Index/NAAQ Standards, 2009) Therefore, daily Assimilative capacity w.r.t. PM10 in ambient air of the area during a particular month (y): c x 100 = y Kgs 80 Month Estimation of physical assimilative capacity w.r.t. PM10 Alwar# Ajmer Udaipur Jaipur* Kota Jodhpur Pali Apr-21 1222 1237 1709 1625 761 3332 1806 May-21 1222 1237 1709 1625 761 3332 1806 Jun-21 1222 1237 1709 1625 761 3332 1806 Jul-21 1055 1068 1476 1403 657 2877 1560 Aug-21 1055 1068 1476 1403 657 2877 1560 Sep-21 1055 1068 1476 1403 657 2877 1560 Oct-21 887 898 1242 1180 553 2420 1312 Nov-21 887 898 1242 1180 553 2420 1312 Dec-21 499 506 699 664 311 1362 738 Jan-22 499 506 699 664 311 1362 738 Feb-22 499 506 699 664 311 1362 738 Mar-22 861 871 1204 1144 536 2347 1272 # - The average PM10 concentration of Alwar & Bhiwadi CAAQMS data *- The average PM10 concentration of 03 CAAQMS stations established in Jaipur Estimation of physical supportive capacity based on PM10 The formula for assessing the supportive capacity is based on the physical boundaries (Box-model) that works on assumptions of steady-state conditions; i.e. it is supposed that the emissions, wind speed and characteristics of air available for dilution will not vary over time and that pollutants emitted to the atmosphere are uniformly mixed in a volume. Considering this, it is better to call it physical supportive capacity.
Physical Supportive Capacity (z) = Assimilative Capacity (y) - Total Estimated Load (PM10) (XPM10) Estimation of physical supportive capacity based on PM10 Alwar# Ajmer Udaipur Jaipur Kota Jodhpur Pali * Apr-21 (-)1185 (-)161 (-)120 (-)536 (-)342 (-)4264 (-)2023 May-21 (-)269 (+)198 (+)17 (-)16 (+)84 (-)1732 (-)415 Jun-21 (-)403 (+)260 (+)410 (-)195 (+)198 (-)999 (+)54 Jul-21 (-)47 (+)310 (+)280 (+)351 (+)243 (-)403 (+)296 Aug-21 (-)63 (+)224 (+)74 (+)267 (+)250 (-)518 (+)374 Sep-21 (+)274 (+)395 (+)487 (+)659 (+)328 (+)690 (+)499 81 Oct-21 (-)444 (+)18 (+)12 (-)248 (+)61 (-)1065 (+)105 Nov-21 (-)1353 (-)135 (-)720 (-)1015 (-)387 (-)2952 (-)223 Dec-21 (-)472 (-)45 (-)335 (-)379 (-)118 (-)1090 (-)15 Jan-22 (-)282 (-)15 (-)349 (-)312 (-)44 (-)981 (-)30 Feb-22 (-)220 (-)45 (-)287 (-)272 (-)118 (-)1035 (-)103 Mar-22 (-)650 (-)131 (-)458 (-)469 (-)182 (-)1713 (-)229 # - The average PM10 concentration of Alwar & Bhiwadi CAAQMS data *- The average PM10 concentration of 03 CAAQMS stations established in Jaipur NOTE:
1. The numerical value with (-) symbol indicates that area has no available physical supportive capacity.
2. The numerical value with (+) symbol indicates that area has available physical supportive capacity.
The assessment of carrying capacity based on the available CAAQMS data of 07 districts for FY 2021-22 reveals that in all the 07 districts, the supportive carrying capacity during November to April is NEGATIVE. The most of the months i.e. 11 months with negative supportive capacity were observed in Alwar & Jodhpur. As reported there is no brick kiln in operation in Jodhpur. Jaipur is the third district where 9 months observed with negative supportive capacity. In Jaipur & Dausa districts total 183 brick kilns are established.
Further, if Alwar & Bhiwadi‟s Ambient Air Quality data of FY 2021-22 considered separately than Alwar has only negative supportive capacity during 03 months (November to January) whereas Bhiwadi has 11 months with negative supportive capacity except in September month. However, Alwar has 149 brick kilns out of which 147 converted to Zig-zag, irrespective to that Bhiwadi has only 04 zig-zag technology based brick kilns in total. Bhiwadi is an industrial town in Alwar district. The month- wise AAQ w.r.t. PM10 is as tabulated below:
82Month-wise AAQ w.r.t. PM10 Month Alwa Bhiwadi Alwar & r Bhiwadi Apr-21 84 310 197 May-21 66 178 122 Jun-21 71 195 133 Jul-21 82 127 105 Aug-21 76 136 106 Sep-21 62 86 74 Oct-21 75 225 150 Nov-21 124 381 253 Dec-21 107 282 195 Jan-22 108 205 157 Feb-22 89 199 144 Mar-22 99 252 176 Assimilative Capacity Of Rajasthan (Grid-Wise Dispersion Method) Assimilative capacity of atmosphere is assessed using its ability to dilute and ventilate pollutants by advecting it away from its source of generation. Dilution of pollutant is a function of atmospheric mixing height, which is diurnally and seasonally varying parameter. Ventilation is a directly proportional to atmospheric mixing height and horizontal wind speed. In order to assess the temporal variation of dilution and ventilation of dry arid region, weather research forecast (WRF) generated hourly mixing height is determined for an area west of Kota city (Latitude: 25.15; Longitude: 75.62). The same data is used for visual presentation of hourly and monthly variation of mixing height and ventilation.
The diurnal variation of hourly mixing height using box plot. Six months data is given in each page. The X-axis is time of the day and Y- axis is the hourly mixing height. The box shows minimum, first, second and third quartile and maximum value of hourly mixing height. For example, during January, mixing height at a particular hour for each day is put together in a box and arranged in different quartile groups. The scale of Y- axis is fixed at 2500 m. This helps in comparison among different months. It can be seen that during November to January, the 83 mixing height is relatively low compared to maximum mixing height of April to June. In the same figure, mixing height during evening and night time for January and June is compared. It can be seen that during winter (January), the night time mixing height is very low, limited within 100 m, whereas during summer (June), the night time mixing height is more than 500 m. Thus, during summer months, atmospheric high atmospheric dilution is available compared to winter months.
The comparison of mixing height during different months in terms of percentage. Hourly mixing height is normalized between 0 and 100 and shown as box plots. It can be seen that during January, the maximum day time mixing height is about 40% of the maximum mixing height. Thus, the dilution available during winter months is only 40% of the June months‟ dilution.
Daily maximum mixing height of each day for a month is used for plotting the box of quartiles for that month. It can be seen that for winter months that is December and January, the mixing height is lowest and therefore air pollution emission related activity should be restricted during these months.
Vertical extent of atmosphere provides dilution; however, horizontal wind provides advection of pollutant from its source of origin. Therefore, if the wind speed is high, the accumulation of pollutant will not take place near its source of origin, however, if the wind speed is low, accumulation of pollutant takes place. A measure of ventilation is product of mixing height and wind speed. Therefore, hourly ventilation is determined and plotted in the same way as done for mixing height."
26. While submitting this report it was found that out of 2037 total brick kilns in 24 Districts of Rajasthan approximately 269 have adopted zig-zag technology and 1768 are operating on FCBTK technology.
The Cluster-Wise Analysis Of Brick Kiln Impact On Air Quality Simulation of dispersion of emission from brick kiln in cluster is carried out using Gaussian Dispersion Model named Industrial Source Complex Short Term (ISCST). The model considers emission 84 from kiln and disperse it under the influence of meteorology. The following emission is considered for simulation:
• Stack height - 30m • Emission rate - 11g/s (~1000Kg/day) • Stack top diameter - 01 m • Exit gas velocity - 01m/s • Exit gas temperature - 333 K As per the requirement of ISCST Model, the meteorological data on hourly time basis for one full day is derived from Weather Research Forecast (WRF) model. Worst Case scenario predicted using winter time meteorological data generated by Weather Research Forecast (WRF) model. Table 1 shows the WRF derived data used in the simulation exercise. Stability class for each hour is derived from the other meteorological parameters i.e. solar radiation depending on the time of the day. The one day meteorology of January month (winter period) is considered which gives the worst case scenario.
Table 1: Meteorological data used in ISC Model.
Time Wind Wind Temp Stability Mixing
Direction Speed Class height
1. 339 0.91 302.5 6 50
2. 331 1.44 303.8 6 51
3. 195 2.47 306.4 6 85
4. 135 2.2 308.8 6 52
5. 98 0.89 310.1 5 51
6. 304 1.89 311.1 5 50
7. 341 1.29 312.5 4 52
8. 357 1.71 313.4 4 227
9. 25 2.63 313.6 3 342
10. 53 3.32 314.8 2 871
11. 90 3.31 313.8 2 959
12. 88 3.1 313.2 2 1015
13. 94 4.31 311.4 1 278
14. 67 2.04 309.5 1 416
15. 10 2.97 308.9 1 366
16. 14 3.8 308.3 2 416
17. 14 4.21 307.5 2 460
18. 43 3.95 306.8 3 418
19. 63 3.81 305.9 4 266
20. 73 4.52 305.1 5 332
21. 58 2.78 304.8 6 131
22. 28 1.92 304.1 6 55
23. 5 2.2 303.4 6 57
24. 11 2.38 302.8 6 74
Figure 1 shows the location of brick kiln across Rajasthan. It can be seen that there are some dense cluster of brick kiln. Based on visual judgment, three clusters are drawn and shown. The three 85 major cluster are area of Ganganagar, Alwar & Jaipur (North)- Bhilwara and their nearby towns/ tehsil/cities. The receptor grid for Jaipur (North)-Bhilwara cluster is shown in Figure 3. On X & Y direction, there are 21 nodes each in the grid. These equidistant nodes cover all brick kilns in that cluster. Figure 4 shows the grid in Jaipur (North)-Bhilwara cluster.
The Ground Level Concentration (GLC) of particulate matter is shown in figure 5. It can be seen that area close to the brick kiln have concentration of particulate matter (PM) beyond the National Ambient Air Quality Standards, 2009 for PM10 i.e. 100μg/M3. Figure 6 shows the receptor grids in Ganganagar cluster. This receptor grid is also of 21 x 21 nodes cluster. The GLC of PM for Ganganagar cluster is shown in Figure 7. The zoom-in view of GLC is shown in figure 8 for Ganganagar cluster. Figure 9 shows the receptor grid for Alwar cluster.
All the GLC shows exceedance beyond the National Ambient Air Quality Standards, 2009 for PM10 i.e. 100μg/M3. This is the worst case scenario analysis. The GLC of PM in the vicinity of brick kiln should not be expected to be within the prescribed standard for PM10 if any solid fuel like wood, coal is used for firing."
3.0 Summary As per the brick kiln survey, there are total 2037 brick kilns established in more than 24 districts/cities of the Rajasthan. Out of these, only 269 are of Zig-Zag type & rest 1768 are on FCBTK. Out of these 1768 brick kilns, 21 FCBTK Brick kilns dismantled the kilns operation in Bharatpur. There are 08 districts viz. Sriganganagar, Bhilwara, Hanumangarh, Bharatpur, Alwar, Dholpur, Jaipur & Jhunjhunu having more than 100 brick kilns. The NCR region‟s kilns of Alwar & Bharatpur districts operated during March to June for 4 months; whereas in other districts the operation period is of 5 to 8months i.e. October to June. Majorly mustard residue, biomass is the fuel used by the Brick kilns. For the production of 1000 bricks, 300kgs fuel is used and on an average daily 12-13 thousands bricks are produced that requires 3 Tons of fuel.
86The assessment of the impact on soil quality due to brick kiln operation reveals that the soil parameters indicating the soil fertility status like organic carbon (OC), available N, P, K, Fe, Mn, Zn and Cu are significantly lower in the soil near brick kilns as compared to agricultural surface soil sample. This indicates reduction in soil fertility due to brick kiln and may result in decline in crop productivity.
The assessment of carrying capacity based on the available CAAQMS data of 07 districts (Alwar, Ajmer, Udaipur, Jaipur, Kota, Jodhpur & Pali) for FY 2021-22 reveals that in all the 07 districts, the supportive carrying capacity during November to April is NEGATIVE. The most of the months i.e. 11 months with negative supportive capacity were observed in Alwar & Jodhpur. As reported there is no brick kiln in operation in Jodhpur. Jaipur is the third district where 9 months observed with negative supportive capacity. In Jaipur & Dausa districts total 183 brick kilns are established. Further, Alwar & Bhiwadi‟s Ambient Air Quality data of FY 2021-22 considered separately than Alwar has only negative supportive capacity during 03 months (November to January) whereas Bhiwadi has 11 months with negative supportive capacity except in September month. However, Alwar has 149 brick kilns out of which 147 converted to Zig-zag, irrespective to that Bhiwadi has only 04 zig-zag technology based brick kilns in total. Bhiwadi is an industrial town in Alwar district.
The cluster-wise assessment of the impact of brick kiln on ambient air quality during worst case scenario (winter season) for the 03 major clusters i.e. Ganganagar, Jaipur (North)-Bhilwara and Alwar reveals that, all the Ground Level Concentration (GLC) shown exceedance beyond the National Ambient Air Quality Standards, 2009 for PM10 i.e. 100μg/M3. The GLC of PM in the vicinity of brick kiln should not be expected to be within the prescribed standard for PM10 if any solid fuel like wood, coal is used for firing.
Further, in the months (March to June) when dispersion found significantly well, in those months also the physical supportive capacity is not available; this may be due to lifting of fine particles of crustal sand (being non-cohesive), vehicle movement, 87 agricultural activities and other domestic activities. Further, the assessment of the carrying capacity without considering the other source of pollution and environmental condition is not rationalized and advisable. As the present carrying capacity assessment is based on the physical boundary with steady state (Box-model), it needs to be further assessed in detail by considering brick kiln operation in totality viz. fuel use, fugitive emission, local conditions, agricultural activities etc. The crop residue used in loose form, that contribute in ambient pollution and also the thermal heat is not utilized properly. Briquetting/pelleting of such residue will help in increasing the thermal heat and reduce particulate pollution too. Funnel feeding system for continuous feeding of fuel at constant rate may result in effective combustion.
4.0 Recommendations:
1. A large number of brick kilns are still operating on FCBTK technology.
Conversion of brick kiln as per the timeline stipulated under MoEFCC notification dated 22.2.2022 is to be implemented by the brick kilns owners to reduce the air pollution.
2. Based on the earlier carrying capacity study of Rajakhera block, Dholpur & Sriganganagar district and the assessment of the ambient air quality data of FY 2021-22 of 07 cities (Ajmer, Alwar, Kota, Jaipur, Jodhpur, Pali & Udaipur), the regulation on the brick kiln operation may be imposed for the month in which negative supportive carrying capacity prevails.
3. RSPCB shall initiate action against the violators operating the kiln near by the non-attainment cities without converting from FCBTK to Zig- Zag technology.
27. It is further contended that pollutants can trigger an inflammatory cascade that can impact the Brain, Kidneys, Heart and even cause diabetes. The allergy like symptoms are only the immediate and short term consequence of the poor Air Quality Index (AQI). The longer term impact is more insidious because it is invisible. All living things need good quality air to survive and when the air is polluted life itself is threatened.
8828. Now-a-days pollution is usually a mixture of highly concentrated carbon monoxide, nitrogen oxide, sulphur dioxide and hydrocarbons, emitted from vehicles, factories and fossil fuel burning. These react with sunlight to produce smog, a thick fog or haze. There is one more component to this mix that is not always visible that Particulate Matter (PM). Chemicals, soil, smoke, dust or allergens constitute different types of PM. Varying in size, shape and chemical composition, they are defined by their diameter for air quality regulatory purposes.
29. According to the CPCB survey in the country out of the 242 cities (CPCB data released on 14.11.2023). The air quality in only 40 cities was found in this satisfactory to good range. On that day the air quality was severe in three cities, very poor in 32, poor in another 64 and moderate in 106.
Bhatatpur in Rajasthan was the most polluted with its AQI of 405 beating Delhi's 377.
30. Following were found to be to have great impact on various organs (as reported in India Today 11th December, 2023).
a) Lungs Particulate matter enters our airways first and causes an immune reaction we recognize as inflammation. This ongoing inflammation is a leading risk factor for COPD and lung cancer.
b) Heart Particulate matter can prematurely age our blood vessels and lead to more build up of calcium in the arteries a risk for stroke and heart attack. It can also cause changes to the heart rhythm and structure.
c) Brain Pollutants can impact your memory recall function as well as increase risk of Parkinson's disease by 56 percent.
89d) Eyes Pollution is now a risk factor for age related macular degeneration (AMD), a leading cause of blindness.
e) Kidney Pollution can impair kidney function as well as damage it through chronic inflammation.
31. Diseases being strongly linked to the pollution for the first time -
a) Metabolic Per a study, the risk for diabetes increased by 22 per cent for every 10 micrograms per cubic meter (µg/m3) increase in annual average levels of PM2.5 in Delhi and Chennai.
b) Cancer Inflammation caused by pollutants wakes up normally inactive cells in organs that carry cancer-causing mutations. For every 10 µg/ m3 of increased exposure to PM2.5, risk of dying from any cancer rose by 22 per cent. For cancers of the upper digestive tract, the mortality risk was 42 per cent higher. For cancers of the accessory digestive organs like the liver, bile ducts, gall bladder and the pancreas, the mortality risk was 35 per cent higher. For breast cancer, the mortality risk went up by 80 per cent.
c) Reduced Brain Performances A rise in exposure to air toxins has been linked to reduced academic performance in school; for some, the effect is equivalent to missing out a whole month of elementary schooling.
32. It is contended that various other things are also contributing the air pollution and examples as narrated are :-
a) Power Sector - 34%
b) Industry including the construction sector - 28%
c) Agriculture - 17.8%
d) Transport segment - 9% 90
33. As reported by Secretary, Union Ministry of Environment, Forest & Climate Change (India Today 11.12.2023) India had 210 million two-wheelers and 70 million four-wheelers registered as on 03.08.2022. In financial year, 2023, 22 million new vehicles, including 16 million two-wheelers and 3.6 million passenger vehicles were added.
34. Learned Counsel for the CPCB has submitted that the notification dated 22.02.2022 issued by the MoEF&CC has been amended vide order dated 15.12.2023 which was communicated to all the Member Secretaries of State Pollution Control Board vide CPCB's letter dated 29.01.2024. The relevant portion of the amendment as communicated are as follows:-
"2. The existing brick kilns which are not following zig-zag technology or vertical shaft or use piped natural gas as fuel in brick making shall be converted to zig-zag technology or vertical shaft or use piped natural gas as fuel in brick making within a period of
(a) one year w.ef. 23.02.2023 in case of kilns located within ten kilometers radius of non- attainment cities, except those treated in million plus population cities NCR districts and critically & severally polluted areas as categorized by CPCB:
(b) one year w.ef. 23.02.2024 in case of other kilns.
Provided that in case where Commission for Air Quality Management/Central Pollution Control Board/ State Pollution Control Board/Pollution Control Committee has separately issued more stringent Norms/ timelines, such orders shall prevail. "
35. It is further argued that the State PCB must enforce the guidelines issued by the MoEF&CC in light of the joint committee report. On the basis of above expert report, notification issued by the MoEF&CC and the argument advanced by the learned counsel for the parties the conclusions are as below :-91
i. The State PCB, Rajasthan is directed to implement the provisions of the notification dated 22.02.2022 with the amendments dated 15.12.2023 communicated by CPCB dated 29.01.2024 with respect to emission standard, technology conversion and sitting criteria. The operation of brick kilns in major clusters viz. Suratgarh, Jaitsar, Srivijaynagar, Raisinghnagar and Anupgarh tehsils needs to be regulated by restricting consented production or duration of operation.
ii. Order passed in original application no. 1016/2019 dated 17.02.2021 titled as Utkarsh Panwar Vs CPCB & Ors and orders passed in original application no. 262/2020 dated 11.07.2022 Hakam Singh & Anr. Vs. State of Rajasthan & Others must be strictly complied with (as applicable).
iii. An in depth study on brick kiln process optimization, assessment of region specific assimilative/supportive and carrying capacity is required to suggest and prepare environmentally sustainable functioning of brick kilns in each Tehsil of Sriganganagar district.
Such kind of detailed study may be conducted by State PCB with the help and support of other technical institutes, expert bodies and on the basis of such study passed suitable orders for the operation of the brick kiln keeping in mind the carrying capacity of the area. This exercise should be done every year in the month of January or July as suitable to the department to be decided by the Secretary (Environment).
iv. Brick manufacturer's Association should ensure that the fuel is stored properly and provide pucca road in operation area to control fugitive emission. The best practices to tap the flue gas leakages need to be adopted by all the brick manufacturers.
92v. In-case of AQI being very poor or above the norms the GRAP as applicable in the NCR region vide order quoted above may be considered to be adopted by the State PCB.
vi. Minimum distance as prescribed by the MoEF&CC, process emission, utilisation of ash generated in the brick kiln, proper maintenance and protection of the paved roads utilized by the brick owner for transportation should be properly maintained.
vii. Vehicles transporting the raw materials should be covered as provided in the guidelines issued by the MoEF&CC.
36. The recommendations submitted by the joint committee in this application be suitably considered by the Secretary (Environment) and suitable orders be issued accordingly to be implemented by the brick kiln owners to control the air pollution in the area.
37. With these observations and directions Original Application No. 67/2022 stands disposed of. Copy of the order be communicated to Secretary (Environment), Rajasthan and Madhya Pradesh for necessary action.
Sheo Kumar Singh, JM Dr. A. Senthil Vel, EM 20th February, 2024 O.A No. 67/2022 (CZ) PN 93