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[Cites 9, Cited by 0]

National Green Tribunal

M.Jayachandran vs Ministry Of Environment Forest And ... on 29 July, 2022

Bench: K Ramakrishnan, K. Satyagopal

litem No.2:

BEFORE THE NATIONAL GREEN TRIBUNAL
SOUTHERN ZONE, CHENNAI

Original Application No. 131 of 2020 (SZ)

(Through Video Conference}

IN THE MATTER OF

M. Jayachandran,

.. .Applicant(s)

The Ministry of Environment Forest a 'hange and Ors.

. Respondent(s)

Yuy aa Py. SS rege ye
Judgment I ronowaced Ni:

<
CORAM:
HONE SPICE K. RAMA
HON? ATYAGOPAL KORLAPATI, EXPERT MEMB R &

Sy;

For Applicantt = Md: jay Prashanth

For Respon

"Mir MLR. G@kul Mrs.
Se ee avall; MD Xsan BS
Shangugay ally gek Shag b

. s
'anushrée,
Yess .

aran Sr.

~
BSS

Ce
Judgment pronounced through Video Conference. Application is disposed of
with directions vide separate Judgment. All pending interlocutory application(s), if

any, also stands disposed of, in view of the disposal of the Application.

ceaseesytersnyerendes benenasn cess JM.
{Justice K. Ramakrishnan}

(Dr. Satyagopal Korlapati}
O.A. No. }31 of 2020
29th July, 2022. AM.



BEFORE THE NATIONAL GREEN TRIBUNAL
SOUTHERN ZONE, CHENNAI

Original Application No. 131 of 2020 {SZ}

(Through Video Canference)

IN THE MATTER OF

1. M. Jayachandran,
Son of Murugesan Naidu,
GangaiammankKovil Street,
Puliyankannu, Naviock Village, _
Ranipet District~ 632401.

2. B. Gopi Sathiyarajan,
Son of S. Balan,

No. 4/36B, Bajanai Koil Street
Thandalam- RanipeieS32401 -

SR
BSNS
A

S

The State of

Tami
: r oe ge:

Secretariat, &
Chennai- 600%

3. The District Colle
District Collectorate
District Institution of E
Kellys Road, Navalpur,
Ranipet- 632401

4. The Sub- Collector cum Revenue Divisional Officer,
Office of the Revenue Divisional Officer,
Ranipet- 632401

5. The Member Secretary,
Tamil Nadu Pollution Control Board
No. 76, Mount Salai, Guindy, Chennai- 600 032

6. The District Environmental Engineer,
Tamil Nadu Pollution Control Board,



Ranipet, Tamil Nadu

7. The Chief Engineer,
Public Works Department, WRO
State Ground and Surface Water Resource data centre,
Tharamani, Chennai- 600 1138

8. M/s Thirumalai Chemicals Limited,
Rep by its Chairman and Managing Director,
95-A, SIPCOT Industrial Complex,
Ranipet, Tamil Nadu- 632 403

... Respondent(s)

For Applicant(s}: Mr. S.V.N

For Respondent(s): Mr. represented Mrs. Me.

et D, Sha jmuganathan for Re, RS, R4 & RY
(Mr. MLR. -Gokuls Krishnan yepresented Mrs.

.Shanmugavall

CRS
AN

K. RAMAKRIS

ONer ~ Yes/No

AER: .
a Ce
UDGMENT co

Delivered by Justice K. Ramakrishnan, Judicial Member.

1. The grievance in this application was regarding the pollution
caused to the water bodies due to the activities of 8th
respondent- unit. It was alleged in the application that
applicants are agriculturalists and social activists and are also

having lands in Puliyankannu Village ef Nawleck Panchayat



ba

which is next to Karai Village where 8° respondent industry is

located.

_Barlier the Ranipet Town in Vellore District was having very

fertile land consisting of hectares of agricultural lands and
there were two rivers, namely, Palaar and Ponnaiyaar which
runs through the Ranipet Town in Vellore District which was
the major source for livelihood of the people in the locality and

Epurpose as well. In 1972 the

that is being used for agricultu

lst industrial area in the St nil Nadu, namely, The State

Industries Promotion Corpora ion. of Tamil Nada Limited

products.

. They were drawing 2.2 lakh litres of ground water anc

discharging the untreated effluents directly into the water
bodies, namely, Puliyankannu Eri and Kaarai Eri through rain
water channels. The said water bodies are having extent of
nearly 100 acres and it leads to Paalaar River through the
Palaar annaicut which in turn feeds the Kaveripaakam Eri On

account of the indiscriminate discharge of untreated effluent,


the water quality in the water body has been affected which
indirectly affected the agricultural activities in that area, The
entire water source has been affected on account of the
activities of the industries there including the 8 respondent
which resulted in degradation of soil and agricultural lass to
the people in the locality. The water quality has also been

affected resulting in health hazards to the people.

affected by cancer and
y the industries including

: brought to the notice of the
%

OO, it was

action was taken. In 2

water bodyand ons

<

peeks,

1 affected res

the 8 respon OD
Hon'ble High Court of Madras as W.P, No. 10631 of 2000 and in
that it was revealed that on 34.09,1999, the officials of the
Tamil Nadu Pollution Control Board inspected the factory by
surprise and found that untreated effluent from primary
clarifier was being discharged into storm water drain by-
passing other ETP units such as Anaerobic filter, submerged

aerated fixed film reactor, lamella separator, secondary clarifier



with the help of a hose of 3 inchers diameter. The consent was
issued by the Pollution Control Board with a condition that
diversion or by-passing of any discharge of untreated trace
effluent from ETP is prohibited. Though issued a show-cause
notice by their proceedings no. ICEA(V LR\/P/110013/99 dated
27.09.1999 and they replied the same stating that due to severe
blockage of anaerobic freed line, the primary clarifier of ETP
started overflowing and notice such over flow, the operator in

temporary hose to drain the

order to arrest the same had-put'e

SS

the nearb which has"

Was

& .
ARS se

d outside the factory.

against them bul the

The PWD/ WRO officials had inspecte

fon

the area on 22.07.2019

and found that the 8 respondent had in fact discretely let out
untreated effluents and caused pollution. Based on the same,
the Sub-Divisional Magistrate, Ranipet Division made a
surprise inspection with Tamil Nadu Pollution Control Board
and Police officials in the 8 respondent industry on

93.99.2019 and noticed that untreated brownish trade effluent



6.

was let out from the secondary clarifier tank through 2.0 inch
hose pipe into common rain water d rain and caused pollution.
After an elaborate enquiry regarding the issue, they initiated
proceedings against the 8* respondent under Section 133 of
Code of Criminal Procedure and passed an order on 08.11.2019

and this has proved the illegal activity of the 8b respondent.

The 88 respondent had given certain explanation stating that

due to unexpected rainfall or 3 09.2019 between 15:30 to

ie emergency m aintenance

17:30 Hrs, they had to restor

measure to treat the rain water harvest water, seepages and

revitable things.

SS

happened and
= Ss :

discharging
through the
effluent treatment plant provided, by providing a pipe which
ultimately discharges into storm water drain which reaches the

water bodies mentioned above as alleged in the application.

. Panchayat also passed a resolution against the operation of the

8% respondent unit. There was an interim order passed in the
proceedings initiated under Section 133 of Code of Criminal

Procedure directing the 8 respondent to stop letting out



untreated effluent into the water body. Subsequently, on
account of the undertaking given by them that they will adapt
7LD narms and also considering the necessity for permitting
the Pharma industry to function, Hon'ble High Court permitted
them to re-start the unit on condition that they will have to
follow ZLD. They are causing pollution and they are not

maintaining the standard required. The Sub-Divisional

Magistrate passed the final orders in the proceedings initiated

under Section 133 of Code. inal Procedure noting the
fad

1 suggester

monitor the implementation of the directions issued. Even now,

thy

the illegal activity of the 85 respondent continuous. So they
fled this application seeking following reliels:

" «@) To declare the operations of the 8th respondent unit as
legal, umauthorized and in violation of the Environment
Protection Act, 1986.

fi} To grant permanent injunction and resiram the Sth
respondent unit from carrying on further activities.

Gi} To direct the respondent authorities to order for permanent
elosure of the operations of the 8th respondent industry for
violations of environmental law,

Gv} To direct the 8th respondent to pay environmental
comperisation as may be determined by this Hon'ble Tribunal.



{vy} To direct the reapondent (1) ta {7} fo initiate criminal
presecution against the 8th respondent for violations of the
provisions of the environ mental legislations.
(vi) Pass such further or other orders as this Hon'ble Tribunal
may deem fit and necessary in the interest of justice."
8. The 1st respondent filed counter contending that they are only
policy makers regarding control of pollution which is likely to be
saused on account of the operations of the units and units

which are coming under the purview of EIA Notification, 2006

have to obtain Environmental Clearance and the standards

provided under the Environm: ection Act and Rules have

to be monitored by the State Pollution Centrol Boards and

ication ar
pli ation Tee A

and running the unit since long time adhering to the conditions
imposed. The activities of the 8h respondent were continuously
monitored by the Tamil Nadu Pollution Control Beard and
whenever they were issuing any directions to improve the
system, they were investing huge amounts in establishing the
systems directed by the Pollution Control Board.

10. They are one of the largest producers of Phthalic Anhyrdride
and providing 25 to 30 per cent of their products for domestic

wo

&



market and the remaining things they were making exports.
They were continuously fighting for the imposition of anti-
dumping duty (ADD) for their product and that was challenged
and final findings dated 1 399.3018 in the earlier round of
litigation, ADD Le. Anti-Dumping Duty imposed was
recommended to be withdrawn. Recently they filed another
application with designated authority to commence

ADD in respect of phthalic

investigation for imposition x

anhydride originating from 'China PR, Indonesia, Korea RP and

Thailand. Pursuant to the complaint, the designated authority

issued an 3
investigatio
the abo

11. Acco

which are manufacturer of these products and on account of

the same, the other countries have got irritated and they are
initiating proceedings against 8% respondent to stall their
activities. Their products were certified by the authorities and
they were adopting ZLD system and they have not discharged
any untreated or tre ated effluent outside, since 2006, 10 years

hefore ZLD system was made mandatory in the State of Tamul



Nadu. This was appreciated by the District Administration.
They were also taking all reasonable care to avoid pollution
being caused on account of their activities. They have obtained
necessary Environmental Clearance and also other consent and
they are strictly adhering to the conditions imposed.

12. Pursuant to the inspection conducted by the officials of 5
respondent, the renewal of consent was granted on 03.07.2019

which was valid up to 31.03.2020. Though they applied for

extension and due to the

pandemic it was extended up to

to TCCL (Tamil Nadu Chromates and Chemicals Limited) and

for remediation measures, several studies have been conducted
by the Central Pollution Control Board and TIT and action is
being taken on that aspect. As against the proceedings initiated
under Section 133 of Code of Criminal Procedure, they have

fled W.P. No. 344473/2019 and the Hon'ble High Court

10



Madras vide order dated 12.12.2019 stayed the operation of the
order dated 08.11.2019 issued by the 34 respondent.

13. Rarlier an interim order was passed and on the basis of the
action plan submitted the same was revoked. The 3"
respondent also issued a closure order under Section 33 of the
Water (Prevention and Control of Pollution) Act, 1974 directing

the 8® respondent to conduct hydro-geological study to

segregate different trade.¢ at source and revamp the

existing ETP to the latest state of art treatment, to revamp the

storm water drainage system-and 'also imposed Environmental

Compensatit Rs 18,60,0

a

theyhave refi

are strictly complying with the conditions and also carrying out
the directions issued by the 5° respondent from time to time.
They are also conducting studies by various agencies as
directed by the Board. They are only using the water as
permitted under the consent. The joint report also go to show

that the high level TDS found was not due to any of the activity



of the 8 respondent. They wanted certain time for comply with

the recommendations made by the Joint Committee as follows:

S.No. | Direction 'Time Required

(1) 'Construction and commencement of [2 months from lifting of
new and upgraded ¢LD sy stem/ETP : leckdown _. |

{ii} The answering respondent will treat | 4 months irom
and dispose fo the 2.4 million litres of commencement of the |
waste water which has been stored In i Lew, uperaded  ZLD

raw water tanks, during the tr ials of ; systert
'the ZLD since the waste water has
'been stored by the unit specifically for
; the said _purpase. ;
{it} Certification of the upgraded A Lb s | 2 months from ifting of
| : : lockdown restrictions.

Preparation 'of DER for ne

(iv) 3-6 months from lifing:
_-- Jand within the industry of lockdown restrichions. |
(v} Construction of sub-surk 9? months from lifting of
retainer wall to ensure lockdown restrictions.
gis water
the unit'
15. The
they
respo atised on

District Collector, Ramipet or a Senior Officer not below the
rank of Assistant Collector or Sub Divisional Magistrate of that
area designated by the District Collector 2) a Senior Scientist of
Pollution Contrel Board designated by the Chairman, 3)
Superintending Engineer of Public Works Department and
Water Resources Organization, 4) Senior officer from the
Ministry of Environment, Forest & Climate Change (MoEF &
CC}, Regional Office, Chennai and 5) a Senior Scientist from

12



Central Pollution Control Board, Regional Office, Chennai to
inspect the unit in question and also the Puliyanganu Eri
Palaar and Ponniyar which according to the applicant had
polluted on account of the alleged activities of the 8*
respondent and submit a factual as well as action taken report,

if any violation is found.

17. The Committee was directed to consider the question as to

whether there was any illegal discharge of trade effluents into

the water bodies or public drain il egally by the 8th respondent

caused to the water bodies on

\

and the nature of contamination:

damage

=>

'and ascertain

lying..with all the

ndition imposed in the conseng;
< , &

Rane.
yeas

re also direct ®

BS

Ros
S

' "S
compensation, €

comrnittee. The Committee was directed to take water samples
from the water bodies as well as from the drain where the
industries is situated aid after conducting the analysis, if there
is any contamination found, the remedial measures to rectify
the same may aiso be recommended. MoEF&CC, Regional

Office, Chennai was designated as the nodal agency.



18. The matter was taken up on 15.03.2021. On that date this

Tribunal considered the reports submitted by the Jouit

Committee dated 11.02.2021, e-filed on 12.02.2021 extracted

in Para 3 of the order which reads as follows:

REPORT OF THE JOINT COMMITTEE REGARDING HON'BLE NGL (82) ORDER
DATED 30-07-2020 IN THE MATTER OF ORIGINAL APPLICATION NO. 131 OF 2020
(SZ) TITLED AS JFYACHANDRAN V8 THE MIN, OF ENV. FOREST & CLIMATE
CHANGE AND ORS.

1. BACKGROUND

The Hon'ble NOT, wide ds order dated 30-07-2020 (Anmexare-1) y has constituted a joint

commiitec econ of 1) the District Collector, Fanpe or a Senior Officer not below the rank

Collector of Sub Divisional Magisizate of that area designated by him 2) ¢ Sent iar

Scientist of P0! ation Control Board designa ted bv the Charman: of Tami Nadu Pollution Contre!

Board, 3) Supetintending Engineer of Public Works oe and Water Resources

a

Organization, 4) Senior officer from dhe Ministry of Ensitonment, Forest & Climate Chang
(MoEF & CC), Reguoual Ofhice, Chennai and 5} a ir si sientist fom Central Pollution Coslt aI
Board, Reaioual Olfice, Cheanai with the sollewing directions tt

(u)

(i)

Inspect thie waif in question and also the Palyangans Eri, Palaar and Ponneyar which
were polluted on account of this ant submit a factual as well gs action faken repost 19
this Tribunal, if any violation fs found.

Go into the question as lo whelber there was any illegal discharge of uade eifhieuts
into the water bodies or public drain illegally by the aghth respondent and the gature
of contannnation eansed fo the water bodies on account of the llegal activity, asse

the daniage caused fo the envuonment Land suvironment compensation and ascertaan as
'o whelher the eighth respondent ts strictly complying with: all the pollution caatrol
norms including the condition impesed by the vahoiies

seertaitvas to whetlier there is any unauthorized extraction of ground water and while
asgessung the envireumel sal compensation, this aspect also may be considered by the
commer

Take wa ier saruples trom the water hodies as well as fom! the dram where the undusties
siinaled and afler conducting {he aualysis, iW there 1s aay eon amination found, the

venedil ineasaes fo veclily the sante may aise be recommended.

14



2, JOINT COMMITTEE

The MeEF&CC, Regional Offic Hee hennai, ax {he nodal agency, requested all concerned
authorities for the nomination of the atic icials for the joint cosmitiee and site inspection. As per
the nominations received, the joint commutice constats of fhe following member:

i) Tim &. Elenbehavath, LAS

Sab-Collecter, Ranipet

Shn . Ravi chandran

itonmental Eugmeer (DEE), TNPCB, Vellore,

ey) ciinaa
| Superutending Engmeer, Pune Works Deparnscat (AWD), Water Resourve |
Orzamsation ( WRO), Penny: ay "Tasin Circe, Tins vannamnalai, p ' {As intonated, |
Shr No Sar: os, SE (FWD) who was nominated 4s member eat] her, bas been

" ranalerred)
& | De &. Sridhar
 Seentst D',
| Regione! Office, MeEF&CC, Cucena
SDR Rayforat
iS ne "Y
anal Pally tution Contial Boat (CPCB), Recioual Direclorate, Chenan

&

3, JOINT COMMITTEE'S INSPECTION AND ACTION TAKEN REPORT:

Fee

The commiliee aegsubery jonily Inspected the industrial uml M/s Thiranehd Chengeas
wun Photos :

Ue Ly Lad, SPC Ors Etats al ae lex, Ranipel oe Nadu} on 07-10 8

cuality analysis Hi REN sty Wa eto as wel cella foi thie de n was carlied out Dy te con
with help of exfensrve sa ae a and avalysis by MalrC iCPCH seeagnized and NABL

Bott ae Hee aporeaclied fhe National Envin eumentel Engineenag
seswar ile we CREERD sal fon Chennai for the sampling and aualysis and stace NEERI

wanted mere om six muonths-time, te agalysis was dane by the NABL accredited laberafary.
water and soil sangles m ueatby water bodies and drains were collected by 'he

Bi Pet tte
Accordingly,
% esis +

sounmeice on 16-12-2020 and gat analyzes

4, INDUSTRY PROFILE AND LOCATION DETAILS

TCL is a producer of petrocheancals and food ac: idalants, The 47- acre manulnetune
ites located 125 kn west of Chennai on the NEL40. TCL started manu facta from 1976, 7 Me
CUInpany procuces the came produel, Phthalic ashydsde (Dicarboxyiie ankydnde) from
beginning, The later additions of dicardoxyiic acids, Fumarie acid and malic seid are recovered
trom the waste gases vom Pita anhydride manufaches, TCL gat consent to operate trons 1986

15



ang gotrenewed cantinuonsly. In 1996, tt obtaimed EC from MorF for expansiog of its production
; : p
i

capacities. The renewal ef consents regularly contipacd,

Fig, 1 Map showing the location details of TCL with other industry cluster & water bodies

phe +
i oe Reve s
t 3 i
a x 3
. 3
Ke, NM

16



5, IMPACT OF INDUSTRIAL EFFLUENT ON WATER BODIES
5.4. Indarmation on products manufactured by TCL:

TCL Raniioet  amuufactx ing Plihatic aulsydiide (Disa busylic auhydk les! 34 tas ay,
Fumaric Acid of LG Tous/day and Malic Acid (Dicarboxylic Acids) of L2Toas/day for which
indastty is using raw material as O-Avlene (322.4 Tonsttay and Malete Anbydide {O88
Toas'day.

Phthalic anhydride: Phthalic subdue ts manuhx ctured using O-Xylene vapours nixed
vrith aig react in the presence of catalyst af bigh temperature. In this process, only the possibility
of contaminants is geitiag info ETP is O-xylene and Pithalic anliydide. By the dehydration,
phthalic acid ean be eeuverted into phthalic anlyditde and hoth are water sohible and the

possibilities of presence in Raw effluent

Malte Acid: Malic Acid is bemg manufactured in two different me sthods im which fast
method is fom Meleic anhydride hydrolysis process to produce Maleic Acid and then Maleic actd
is hydrolysed to form Makic Acid. The secoud method is fom Fumane Acid hydrolysis process fo
produce Malic Acid, On completion of F the reaction the reactents are separated from the products
by cooling and centrfugme and then seoytallizne by ceninfiging and dryng. The collected
guother liquer is sent ty ETP whieb may sontain traces of Malic Acid, Ln this, maleic anbydes ide is
a colourless crystalline Hake aul in water it reacts to Gaur Maleic avid. Maleie acid fons

culouriess prismatic urysials dissolved in weler, maleic acid is a very slong ergame nea.

Fumaric Acid: Famaric Acid is manufactured from serubber solution. of Pithalic
anhiveride plant by isomerization. The | famuaric acid solution while cooling will precipitate and then
vel centrifage and separate Fumaric acid orystais sand mother Hcuor, The collected mother Lyuor

s sent to ETP which aray contain traces of Funaric Acid.

'The overall production of all three products toget shee 19 382 Toos'day in which Plibahe
antivdnide production is 03% (384 tonsday), 4% (16 Tons' day) is Fumaric Acid and 2 { (12
Tonsiday} is Make Acid tet 'hthelic endydride production Ue passidle effluent contammeation 18
Phthalic acid and O-xylone and rest 7% production may generate cfflucni contaniination is Melee
acid and Make Acid

Water consumption aud effluent generation: The tolal water vonsanypton per day Is
arouud 2278 KL day in witie around 1903 AL! day is the cooling tower avaporation loss ip wiseh
Piihalio division cooling tower is L962 KL day anc Chemical division coaling tower is 13 KL/day.

fy averall water consametion aronad 86% 18 showihig as T evaporation fuss. The process water

1?


oe in the wet serabber Is showing around 64 KL/day and process steant leaks is around 13

KLiday whiclt is around 3.4% of total water consumption. The overall effluent generated in TCL
-- all processes is around 220K L day in which proves ef filuent is 4k Liday, Cooling
tower blow down is 42KL/day and DM plant reject water is around S3RL/day,

The capacity of the storage fanks which is already stored effluent is GHO8KL and Cooling
ower civenfation sump tanks capacity of SO0KL (4 tanks and each have 200KL). Based on the
effinent generation (145K L/day) in the process and the storage tanks capecity, the current eltluents
are stored is around 46 days process effhrent. Also, DM plant reject water gen peration is around
33K Lday and the stored quantity inthe CT circulation sump is around 8OOKL which 1s almost 25

days DM repel.

Analysis of raw effluents The ray effhient of PCL bas been analysed and found Phthalic
Acid (431 Jing'L), Fumarie Acid (94.2) and Maleie Acid (141. 7mgiL) based on the raw material
ased end produets manafactaed. Also, is raw effluent, presence eof TES (7280nig/L) and COD
(3432ing'L.) clearly indicates the effluent contains good arnounts ts of organics. Apart fom TDS and
COD, the Cilortde ncn and Sodiner (L730me/L) contents are high in the raw eiflue yl ibat
may be due to DM plant reject water discharge.

The effluents stored in the storage fanks has alse been characterized asd found Patislic

acid aud Maleic acid presence in all staage tauks samples col Heoled within the industry ani il
clearly indicates that the water stored in fhe sfornge tauks are industry effluent only, Only the
cooling tower cireulation samp water got detected oxalic acid nif as per the consent order no oxalic
acid either as caw material of product is being used in this mdustry. The samples collected with
the industry {bend high COD values due fo organic acids preseut whereas the outside callected
saeaples gol devected very less COD which indicates t he outside samples may be mipacied either
by tannery efflnent discharges or any other i inorganic based industries discharges. The TDS and
COD ratio in within Axdustry collected samples are around 1: 3.7 whereas te water samples
collected outside the industry is around 1:21 witch clearly mdicates the samples ¢ collected outide

the industry feud ligh TDS and COD valves indicates the samples ave il inorganic innatare and
this may be dae to other suumces also incheding tannery y offlnent.

in

ar
in

Water sample collectlun and analysis:

The sanmptes are collected boi downstream aud upsiream moxitorng wells wiitin the
industry and characterized. The average Oxalic Acid concentration oa the upstream monioniag
wells is 1] Finsg'L aud Diowustream is AWasg'L. whieh clearly indicates the oxalic avid presence may

ba frons the ontside sources. The average TDS concentration on the upstreani monitoring wells ts

8



3370me/L and Downstream is 14 13me/L which also indicates the high TDS presence may be fom
the outside sources. In the mouiloring well samples (both up & downstream) Phthalic anlivdride,
Funuarie Acid, Maleic acid aud Malic acid is not get detected. Total Chromaun got detected high
concentration (18me/L) at the upstream meutoring well No out of all monitoring wells winch 1s
NW comer of the plant and also it is very nearby defunct uit of M/s Tamil Nadu Chromates and

Chentical Compaay Ltd (CCL) and this is the only source for Chromium contamiation.

The water samples were collected outside the industry on different tdentdied locations
(including Puliyankana Evi, Karai Eni, Thendalam Eni and Palar) and analyzed and found thet that
oxalic acid is present in almost ail the locations at the concentration range beween 20.6 to
46528merL which clearly mdicates the oxalic acid may be from other sources like fannertes apart
fio the industry, The maximum concentration of 46528meL got detected outside Drain near
road side - opp to continental leather as weil as oulside of Thirumalai chemicals-NW Coret of the
plant- Both Thirumalai chemicals & Tamil Nadu Chromates and Chemical Company Lid (CCL)
Discharge mixing point discharged / Letting out into common drain (Public) got detected the oxalic

acid concentration of i 3édrne/L.

19



+

oar nunubers of sod samples were collected within the industry nearby the Xvlene storage
tanks area and found oxalic acid present et high concentration (1145.6mg/L) neatby fsoptine Tank
No. {Sand 153.6mg'L ss prosent at night comer of the open.arca. Phthalic auliydride, Frmarts Acid,
Malsie acid avd Malic acid is not get detected in the soil samples. Total Chrono get defected
in the soflseniples in the ranges between 6.8 to TTme"L which may be due te cantaninalios fon

chromium aveste dianpsite.

The sediment samples are collected outside the industry and got detecied oxalic acid
aiost of the locations Out of all samples, the Karat Ei sediment sample gol detected oxalic acid
at high concastration of 44 1Gng'L.

The industry may have generated mere eflteeat than presently approved process effluent
quantity that may be reason the raw effluents are stored in the storage tanks. Also, DM plant reject
eonlains high amount of sadhun and chloride whiell carpet be able fo treat in normal RO
mombtane and if requires see water mentbrane for effective remov al of chloride, Oversll, the
indusly bas to increase their effluent treatment plant w ith seawater membrane ILO system and in
fetare they should not fo store ary efflueat in the storage tanks,

'he resulls detailed in Tables 1-7 are given in at Annexure-3 and Maps showing the
sampling location are given af Annexure.

5.3 Findings of the analysts:

1} The unit is designed for 720 KLD of ireatment capacity (Consent to operate granted
fur 360 KLD), whereas afler diection fara TNPCR the wnlis sexe evaling tle organic
& iuorgautie waste stream and upgrading the treatment capacity O00 ALD winch ts
vader trail an.

3} 'The stagnated samples collected on 1 1.11.20 shows the discharge of uutreated eluent
an ihe own land jaside the industry prentises. The same ts confirmed by comparing
with the infet effinent characteristics of ETP.

§} Oosiug water few the disclarge anc wes s collected at three different luvwivns wad
Philalic acid presence is identified al one location.

4) Even though phthalic acid, dumarie acid & Malic ack were present in the sanples

collected inside prentisas, Ilieir impact due to over How during the rauyy seasou outside
the prenuses and orher water horlies not identified sites these &
Sivhly bio-degradable im natwe, Morcover, these pollutants' 'no-degradabilily may
also inctease after mixing with wutvealed sewage.

asic pollutants are



ay
ee"

9)

6 OBSERVATION BY TIRE MEMBER

During the study, Ovalic acid presence is identified in most of the lncation around the
SIPCOT industrial area and its downstream and im all water bodies. To identify the
smurees, of oxalic. acid, nilet effluent samples of Conimon Efftiuent Treatment Plant
(CRTP) were collected and same is found, which shows the oxalic acid pollution is
due to TannericwCLEIPs.

Presence of Cliraminn Visvere also identified in the water borlies, which is che ta the
coninuos seepage waler Towmeg from openly stored sludges present tn fhe closed
anit of M/s Tamilnadu Chromate and Chemical Lid, (TCCL).

Untreated sewage How from nearby residential areas is also pollutmg the water bodies.

The drains/ chamels comiecting toflie water bodies belongs fo SIPCOT indusinal eres
as well as the other local bodies found grown with bushes/plants. which results
iodustrics taking chanecs for Hlegal discharge.

The surface water bodies nainefy Puliyankanms lake, Karai lake, Sitheri lake and their
drains were nof properly maintaised. Due to improper maintenance of drams, the
water flow is affected, which leads to formation of wetland.

AND

SUB-COLLECTOR, RANIPET

ADDRESSING ILLEGAL DISCHARGE OF TRADE EFFLUENTS
(Detailed report received from the Sub-Colector, Ranspet with images/photos ate given al
Annextre-5).

The Coxnittee Menyber (Sub-Collector Ranipet} has brought out the following observations
and conclusions during his inspection along with DEE, TNPCB conducted on 11.11.2026 which
was conducted based or a compliant received from local resident at that time:

art

harpe of Effluent inside the Coarmapaoy premises

ORO ACE BOIS CONCELUSIO Nw

poh une quantity of effhrent

| water sSiagnated O21 ope

. ground iy the yard area in

: the norih corner of the plant.
: Barthen enabsanlaneuts have

been created ta seep down

'ante the grou.

The compairy claim that the stagnated water ar the
open growid in the yard area is external seepages COWES
into their plant fromrihe West, N.West, because of the

extensive slopes of land, the external underground
esepages flow from West to East and flona Nortinvest 10

South East from outside of TCE and thiough TCL.

Phe test report revealed thatthe wastewater stored
in oper pround by earthen erubaniiments dm the yard area
ecoutiivs Huemaric aca to the comoentalion of 200.47
mgel S&L 58.40 niget aud Puthalic Anhydride '4.70 sagel
& 3. 40;n@. Punsaric acid and Phuialic Anhydride sre the
naain products of the plant. Pummaric acid, Maleic acid and
Phanatic Avbydride are tuamifactured. only by the
respondent's company, mo other company in the
sarroumding area manufactures the above said chezuicals.

Zhe report of anakysis revealed that signature

pollutants of the company i¢.. Pumaric nmecid ana

Phthalic Anhydride were present in the water. lence
it is proved that the water singnated on the open
ground by earthen embankment is nothing but the
trade effluent generated at the niannLacturing precess
im the plant. The stagnated water contains TOS 24324
ipl sid 24132 wy). These harnifal trade effluent were
stagnated. i open grand to seep dows dute the soil,
whieh will result tye contamination of groundwater.

be.

: A thee quantity ofatater

© trom OM plant reject/
'untreated or partially treated
effhyent stored in 5 Raw

'qqer tans. d bernporary

<

rw pipelines were found.
: Same pipelines conuected

du 2 punipsasperauing in

"the DM plant reject

There were ¢ight satuples collected at Storage
Tank - MA Raw water Pink, Storage Tank - PA-H Raw
wrrtar left side, Storage Tank - PA-H Raw water Right
side, Raw .weater Collection tank IT Phok, Raw water
Coltection tank Ii Pink, Raw water Collection tank IT I
Hiack sud DM Piant discharge pipe Ine neariaw water
stotage tank.

21



collection tank. A demo was
done by the plant officials
that how the water pumped
through these lemparary
PVC pipes to raw water
tanks

The company claimed that Untreated' partly
treated, high TDS feed for the varions sections of the new

ETP plant is needed for testing They further claimed |

that about $200 KE. stored in the tanks for treatment
fox commissioning activities, and tuning the new ZLD
plants. The raw effluent generated during the ongaling
manufacturing precess itself enough fer lesting the

new ETP Plant There is no need of siering such huge
_ quantity of effluent in raw water tank. The company

om TNPCB ior
eforing such high TDS untreated'parhally tre:

did not obtain any prior pernussion §
ated eff Trent ;
in raw water tanks. The raw water fanks filed 9
temporary inflow PVC pipes. A demonstration was done
(ny the plant authorities how the partially treated effluent,
OM Plant regeneration water pumped into new water
tanks,

They were asked to puna back the water as
elaimed by the company to ETP and RO plant for Ruther

'treatnient. Ne one is alde te pump back the water In

reverse direction Info ETP/RO Plant as claimed by the
company. There is no such plpeline for pumping back
water fo ETP/RO Mant.

Ag per fie TNPCB noms the pipelines showd
have indicated wilh clear colour cadings. The
authorities did not follow any such colon coding fer rew
effluent, DM plant regeaeration water and raw water

paking distinct fom other pipelmes.

pant |

ed

tower storage

ESuent/biowdown
swastewater Was pumped up
ago unised MA coolmg
; of
such tanks filled up half and
drained on Oped Brot ond

SHES.

The te est report revealed that ile wastewater slated
in MA Cooling Tower Storage task end compartireut
contains Fumeric acid to the concentration of Q/ 76
MA Coalmg Tower iank Middle
coupartinent contains Fumaric aeid to the concentahios
of 348.80 mg? axl Phthalic Anhydride 19.19 nig.

ae Sioage

Fumanic acid and Philiahe Anhydride are te main)

oroducts Eumaric ack], Maleie acul aad

Phthalic
respondents campary, Ro othe company 1 the

af the plant.

Anhydride are manuiactured only by

 sitrounding area manufactures the above said chemicals.

The company claimed that the "MA Cooling Tower

| storage tank is used to store residual cooling system |

Heev j
Lat

11

22


fie xylene storage tank's | 3
parapet walls. A heap of salt
sediments, sindge were Key

| packed and stored inside the

parapet walls.

"Wastewater stagnated inside |

waters and muds Hushed and drained from the
systems", This report proves thet the wastewater stored
in the MA Cooling Tower storage tank contains Ine

signature pollutants of the plant Le, Fumaric acid and

Phthalic Anhydride The claim of the vomyauy is

'}

disproved by the fhet revealed in the test repo t. Henee,

dhe wastewater is nothing but the effluent generated by

pees

the mneumtfacturing process.

The company also claimed that the MA Coohag

Tower ground Concrete tank is in excellent condition

and is wed ta the residual cnoling 'esystens water and mad

fashed and drained fiorn the systems.

a VS
The MA Couing Morage Tanks were found fo de
foaking and discharging offhsont from the Conercte tanks
fo open ground and ram waler crains, Hence, ihe
copapany "s claim is net iene.

Xylene Tank Fam was analysed,

There was no water stagnation found in the
Xylene Tank Farm area inside the parapet wall from
the year 2016 to 2019. In Samuary of 2020, wales

stagnation was fousd in the Xylene Tank Fann area

inside fhe parapel wall. {t is periinent to note thal ihe
water stagnation in the Tank Farm area is 3 recent
phenomenon,

The company also claimed that the external
scepages were found in the dyke wall area af the Q-
Xylene storage tanks. The company passed the burden to

extemal seepages. However, the report of ANALYSIS
revealed thet the seepages stored near the i ope ec

storage tank area, Q-Xylene Storage tanks [3 & )4-area
vonuius Fienaric acid lo the canceuiation al 246.93
nigel & 99.50 ngs end Phthalic Anhydride [1.46 wg.

Fumaric acid, Maleic acid and Phthalic Anhydride
are manufactured only by the respondent's company, |
no other company in the surrounding area

manufactures (he above said chemicals. Hence, it is

proved that the seepages found in the dyke wall area |

Google Earth Satellite Historical kne veayot

42



Potassium are foaad effluent water stored in the 8

depth water stagnation has heppened. If could not aave

on sy

of O-Xylene and Isoprene storage tanks contains raw
elfluents of the plant

The Chemical analysis of the secbnented salt asc
the effluent water sored in the raw water tank are
matched with each other. Sedium, Chlorides,

ay
water tanks, mud the sediment sludges found mice tae |
parapet wall of the Xylene Tauk ares.
[i was found that the water stagnation mark 'vas

found for 1 moter depth inside the parapet wall, a clear |
stain and water marking foed m fhe walls. Parapet |
wall was builf np with random mbble masonry far 3
speter height. The parapet walls have been constructed for
the safety purpose to hold the gn, if any accidental
sills fiom the xylene tanks if is evident thal | eer:

happened without any artificial punspiug into the parepet
wall crea.

Hence, it is corroborated that a large column |
of effluent water has been Kept stagnated into the |
parapel wall wea until It seeps inte groundwater, lt
resutled in ihe sali dissolved te dhe effluent deposited
at the hotter of the parapet wall area, Itwas scraped
by the Company authorities and kept stored in
Polyihene bags. .

The DM plant rejeets ate

manned formigh 2 wrley
=

prions in collection BUIKS.

The compeny claimed 'that Untreated' partly vested, bigh TDS feed for the varions sections af the new ETP plant is needed for testing, They further clainied that about $200 KL stercd in the tanks for treatment for commissioning activities, and tuning the new 71.0 plants, The raw effluent generated during the ong sola manufacturing process itself enough for testing the new ETP Plant, There is no need of storing such huge | quantity of effluent in nay water lank, The compasey did not oblaln any prior permesion fom TAPCO ka soning such high TDS untreated /pariinby teated efiluent mm caw weter tanks, The raw water tanks fitted sot rexnporary inflow PVC pipes. A demonstration was doe oy the plant al Lenities how the partially treated ¢ effluent, 43 suthorries did not follow any seh colour cading for ray een TM Plant regeneration water pumped inle raw wae | tanks. :

They were asked fo pap back "he weler as clainied by the company fo ETP and RO plant for duther treatment, Ne ane is able to pump back the water b1 reverse direction inla ETP/RO Plant as claimed by Qie | company. There is no such pipeline for pumping hack water (¢ RT PURO Plank.
As pet the TNPCB norms the pipelines should | have indicated with clea colour codings. The plint efiluen:, JM plant regeneration water and raw waler nakiug distinct front oles pipeliaes.
1), Underground cement pipeline oppusite to the company:
The Joint Comnuttee inspected the company and the water hadies Jn the vie!y on 07 10.2020. Itwas found that an uncergeonnd cement pipeline along with she road m SIPCOT Inad oppostle to the alleged company ended bin ewthen dram nearby cremation ground. A tom inspection conducted dy the Sup Collector, Ranieet and the Project Offer, SIPCOT on 13.10.2020. The Project Officer, SIPCOT subrattted a report on OL 12.2 201 | NELNag | Details asked Reply by Project OHicer following queues:
What isthe pirpose of the pipelme?
1 | To fumish ihe Pipeline Layout Pipeline favout wap from the origination fo imap [row Uke orignialgin 10 aut pont s enclosed end pout 2 To furaish the Length, Breadth | The details of ievet th, Breadth plang Depth aad Dimension of the dimension of the pipe Ime tke own in the pipeline layout enclosed.

s To fumish the answers far the | There is a gosstbke of cay ing the po "oposal for dis} sos i *offluent from this oxidation pond fom M Ms. th aaa Chemicals Lis and effivent aay alse he let oid ror this pipeline.

Wie dic request the 8 SPS 'Of io constcuct {hat pipelue?

Details are not available ia tus office.

When was it consimected?

'Phere is ne records availadle in this office How much amount spent fer ihe sonstmetion?

Nat aseertamed id dat railed below:

Who did spend the money? No: ascertamed Who did execute the Work? No ascertained Who did graut permission to | We have not given any permission to lay lay pipeline in SIPCOT laad, -- | pipeline Panchayat land?
A To fiunish the map ot the Lavout map enclosed SIPCOT, Ranipel, Phase-], industrial Estate Tess learnt from the rogort submited by the Prosect Officer, SIPCOT that the underground cement pipeline from Thirumalai Chemicals Ltd to the water drain canal of Karai Lake was laid without any permission. The Project Officer, SIPCOT submitted a layout map of the noderground cement pipeline. The pipeline has 504m length, 300mm diameter and L6manhates, The pipeline caries water fain the used wadetion pond near the Tluratualat Chemmeals Lid to ihe water draia to Karai lake. A local eaquiry made with the residents of the localities. The frets ascertained from the report submitted by the Project Officer, SIPCOT and the local enquiry are detailed below: -
L. The Thirunalai Chemicals Lid bas constructed the underground cement pipeliae without any permission fom SLPCOT aad Local body.

2. The company has Jaid an underground gipeline clandestinely fo let out the effluent mte the water body.

3. The pipeline was connected with lire oxidation poad nearby Tirumalai chemucals lid. 'The oxidetion poud is sifvated very next fo the effluent treatment plant (ETP! of the company. FF is possible to discharge effluent to the oxidation pond from waere the effiuent is earied/taken througli the pipeline. The local resident complained to Sub Collector Ranipet ia Jane 2019 about illegal discharge of effluent throug) the unused oxidation pond. Heace, it was closed by the directions of DEE, TNPCB Vellore.

7, ENVIRONMENTAL COMPENSATION PAID FOR THE DAMAGE CAUSED TO THE ENYTRONMENT:

Earlier, on 25.00.2019, for a public cemplaint af egal discharge of the trade effuents outside the industry premises by TCL, action was taken by the Sub- Divisional Magistrate under section 133 of Code of Criminal Procedure and directed the industry not to open the tut without resorting to making the ZLD system effective. Thereatter, an juterim infunction order which was issued by the Sub-Collector was revoked ou 05.10.2019 upon heatug the explanation aud sukmussion ef action plans by TCL. if ywas submitted by the TCL that incident of discharge of 26 waste effluent happened was due to forces attributable to nature resulting m aidden increase 10 hydraxtic {oad to Fflnent Treatment Plant as were taking ram water into our RTP. ln this regard for "he above complaint, the Tamil | Nadu Polhition Contral Board -vide order dated 13-11-2019 (Annexure-6), had issued fhe industry certain directions ander Section 32.8 of the Water (Prevention and Control of Polluen) Act, 1974 as amended, and anye ased a penalty of RS.18.5 Lakes for the feflowing violation but have not issued any ditections fo close the unit. ) The unit bas failed to operate the ETP cont imuonsty and efficienlly so as to eclieve Zero Liquid Discharge (ZLD) system.
(i) The display of dow merers provided at inlet of ETP (Fqualization Tank) and ouilet (Sand filter bed) was found fo rusted and display not cleat Gi} The online conneclivily of ETP, R.O ang RAB were ¢ found fe not display readings from 22-9-2019 vi The aur hes discharged effieent/waste water outside the premises by not maintaining ZLD into chamel confluencing with drain water of defunct unit Mis Tamil Nada Chromates end Chemicals Lid. This directly veaches lakes of KaraiPulyankanne which is used by public aad villages and violation of consent order conditions issued fo the amt.

As dirceted by the TNPCB, an amount of Rs, 18,60,000 (Rupees Eightoon lakhs sixty thousand only) was paid by TCL as environmental conmpensation op 13-12-2019, Ewrther, for repeated complaints and violations, the TNPCB, on 0-12-28 $20 (Annexare-7}, issued stringent directions, under the Water Prevention a and Control of pollution) Ast, 1974 as atuended, to the TCL to: (i) Restrict the production of £0 % of its consen ted quantity so ag fo achieve zero liquid discharge consistently till the commencement & effective fuctionng of newly constnected ZLD components (ii) Furnish the bank Guarantee for Rs. 10 lakhs (Rupees Ten Lakhs} to the Board for the compliance of the following conditions.

(i The mit shal! constrict and commence fhe new 7LD components for effective functioning so as wachieve Zero Lquid discharge

(a) The unit shal operate the ETP coniinuonsly and efficiently so as to aclieve Zero Liquid Discharge (ZLD) system at all tines.

(ii} The opeiation of the uit shall uot slitact any public compianits, (iv} The wnitshall comply with recommendations of ie Hydro-geolagical study report,

(v) The unit shall provide garland drains around the wait premises to enswe that thete 18 no seepage of water frou outside preniises tuto the nail and vice-Versa.

ad (vii Thetmut shall provide suitable no. of Ferzometric wells af the unstrean and downstieam side of the unit premises, go as te assess the ground Water qua ity.

ivi} The wat shall provrle proper cain water harvesting eystemn in the nail prenuses to tepthe rita wale, Weal end reuse [or benelivial purpose, so as lo avoid dle rain waler samoll anlede the preaises of the nail.

fei) The unit shall revamp the storia water dau within hie unit premises aller detsiied study on the carryina capacity with regpect to surface mnolt.

lace the existing anaerobic contact fer with suitable advanced isyatenn so as fe noprowe the quality ef ailuesl inte aeralne trealinen! Gx} The nant has te te:

agaerobic treaties Systein.
(x) The unit shall comply with conditions ment joned in the reuewal of consent order vide prov. dated OF. 07 2018.

(x The anit shall stict'y comply with conditions mention ved in the renewal of consent cader vide prov, dated (2.132019, fy this regard, for pei-complance of consent order conditions, Gscharges noheed ai violador of consent candians, exces vianceot ma aly presetibed standards 'consent Lints, inter al disthaige to the euvirounsent land, water ac ¢ aw cesulling inte acute agary or dauage ty the enviroument aud injection of veated : ane treated 'unttvated effluents to the gronuc water ant based cx repeated violations caused by the unit, as directed by the TNPCB, vide order dated 8- 1-203), an amount of Rs. 17.48,000 ftupces Seventeen lakhs forty thousand only} was paid by TCL as cnviranmenial compensation on 22-1-2021 (Amnexure-$}, g COMPLIANCE WITH ALL THE POLLITION CONTROL NO IRMS INCLUDING CHE CONDITION EMPOSED BY THE AUTHORITIES.

The nail has obtained the following consents'authonization:

iy Couseal Under Air Aet whith is valid wate 30.09.2029 3} Consent Uneclor Water Act 'nol: is valid upto 36.09.2920
3) Authoszation Under HW rules which 3 vali upte (Q.02 2025 The Committee seviawed the status of compliances of various daeetions issued by the TNPCS (roe. No. TSFTNECBEGSQ2VLKv REAM OLY deted (3-11-2019) arsmg ont of the public complaint on 229-2019 alleging discharge of waste water trom the wit casing surface'ground water polation aad subsequent interim injwaction order issued by the Court of Sub-

Divisienal Mayisuiate (Runape! Division) ox -{1-2019. Corapliance stalus af the cond ittons isssedl by the TNPCE on 00-12-2020 1s piven at ANNEXUTE-d.

i?

28

9, p> anaes

6) CONCLUSIONS AND RECOMMENDATIONS:

The overall grievance in this case is regarding the pollution caused fo the water bodies namely Karai Eri, Puliyanganu Eni, Palaar and Pouniyar eu account of the illegal activ Hes conducted by the industrial unit M's Thinmmalai Chemieals Ltd (TCL). From the sample analysis, itwas observed that the industry's land inside their own prenuses was polluted due te discharge of uatreated effluent. The same was confistaed by compara will the inlet effluent characteristics of Effluent Treatment Plant. Oosing water from the discharge land was collected at three different locations and Phthane acid presence is ~ idenhfied at one location. Even though phthalic acid, fumaric acid & Malic acid were present in the samples cellected inside premises, their impact, due to over flow during the ramy season outside the premises aud other water bodies, was not fraceable"observed, since these organie pollutants are highly bio-degradable in nature. Moreover, these pollutants' biodegradability may also increase after mixing with witreated sewage. Hence, the impact could not be traced in the samples collected at water bodies, Oxalic acid pollution: The study found that presence of Oxalic acid in most of the location around the SIPCOT industrial area aud its downstream areas and in all waler bodies. To identify the sources of oxalic acid, CETP inlet cfflaent samples were collected and same 18 found, which shows the oxalic acid polltion is due to Tanneries/CETPs, Compliance status of pollution norms for Tanneries/CETPS in SIPCOT wal be covered as part of another NGT foint Committee in the matter of OA No.186/2020 (52). Chromium contamination: Presence of Chromir was also identried in the water bodies, which is due to the contiguous seepage waler flowing from openly stored shidges present in the definct unit of M/s Tamil Nada Chromaie & C hemical Ltd. (TCCL). Detail study was already carried out wider the National Clean Enetgy Fund (NCEF) project by CPCB for remediation of chromium contaminated site. The report was submited to TNPCB and TN State government with request {0 fake up remediation. work. The status report was already filed nuthe matter of OA No. 1886/2020 (SZ). Untreated sewage flow from nearby residential areas is-also polluting the water bodies. The drains! channels connecting to the water bodies belougs to SIPCOT industrial area as well ag the other local badies fonnd grown with bushes'plants, which results industries taking chances for legal discharge.
7) 8}
8) 10}
12) Fer improper effluent managemen! and violations nidiced in cousent conditions, the uri paid environmental ccsupensation fwice to the TNPCR. Agia nount of Ra. Rs. £7 AG,E)0 (Rarpess Seventeen Inkhs forty thonsand only} was paid by TCE as anviromnents) suippensation on 22-L-2021. The wnt, for fhe sinalar vindaticaw, had paid air agonal oP Ra.

18.6G,000 (Ropees Eighteen lakhs saxty fheus muh onty) te tie TINPCE as endrompental yompensation on 13-12-2019, Recommendations tea FOL: As Ge uel was al SEV Ee for PENE-COLES olabe af cotisent order conditions, discharges notiond in Vielaticnof consent sanchtions, inicrnal discharge fy the environment -land, water and air resulling iufo acute injury of damage to the environment and injection of treated 'partially treated snatreated effluents ta the grongd water and hased en repeated violations, dhe unit wae directed by T MPCB to restriet ibe production of 0 af is consented quantify se ag te oehieve zere lignid discharge covisistently oH ve compiencoment & effective fnctionhig of newly constineted ZLD components. As the mut is in the process of establishing ALD system aut started trial mins for validation of the equipment to achieve. "ere liqtid discharge with respect te treahog a effluents, the aint shall he allawed fo operaic im Al load ouly afler ensuriug the coniplete'filll Hedge :d Gperatian of aparaded ETP by TNFCB. The fulltiedsed opeiation of ZLD system shoud be commenced witlde fhur mothefiae by the TCL, Further, the conditions igsned by FNPCB are kr be ouplied within fhreesnosths times.

Adler cunmissiouing of upgraded P, adequacy test weeds to be canicd out by amp uslepe ndent govt acadeanic/research institution hke HT Madias and to certify that the unit eved 100% ZLD capacity.

CT. shall, in consultation with reputed sashituie such as TY, Madras. ee area DPR wathin free menthe-time, for the remediation of the Jand whece Ihe un eated effhieut was Bischasged within the industry site ai exeoule the task af reredintion : eneainiete Bile, jer the supervision of TNPCH. The entire cost forthe study aud remediavion shall be bx ty the industry as pex polliifer pays poniniple.

oa Recommendations te SPICOT & SIDCO: 7 he drains belong to the SEPQIIT & STOO ghali be yasdatemes! _ properly apd eusire dese draizs sal nol caay apy untested wWsewape other flan the staerm water.

Recomniendations to Lacal bodies & PWD: For managenient af sewage inflow sldel is causing enfrophicatian af lake or post by having adequate infbasttuenne for treatment at sewage trough adequate capacity of sewage lrealoient mans (STFs) or comsbination ofoaiber low-cost treatment teclinologies for ensuring discharge nouns notified under Enviroment (Protection) Act, [986 and same should be ensured by the concerned local or wban beaks.

ad 9] PUES shall carry ont pentedic dredging /de-weeding activines in poncs aud lakes for preper restoratian asic pearesss Recommendations fo FNPCB: TNPCR shall be dixected fo carry out the detailed sticky farsi mapPlog of oxalic acid in the entire area STPCOT, STDCO area, Ranipet & nearby igen villages and alse toidentily any other sourees other than taumeries. A. Detailed Project Ieepart shall be prepare od pad accordingly remediathar skal' be su; strect dx cared oat by wperpem. Fou this, ic cutire shelby "aud rergediaticn: cost shall be bore by te lanneries/CUTPs and other such ide nite sources of industrics that are using oxalic Beil.

Kee ommendations €o Csovt. af Tamil Nada: Remediation: of Chraniay CCUa NARA re-slall be cartied cart ley Gort. of TS as per the status report filed in theunatter of OA So. 1 TEG2020 (37).

By considerhrg the above facts and observation of the doint Cammittee, the Hon' ile Trilranal RAY pass appropriate Or dive GV Thirection (sy as deen au.

19. 8th respondent filed their objections to the Joint Committee reports more or less in tune with the objections filed by them to the original application wherein they have reiterated various steps taken by them and also the subsequent renewal issued by the Pollution Control Board. They have further contended that apart from the compliance of the directions issued by the Committee and the Board, they have also taken following steps voluntarily to ensure augmentation. of eco-friendly practice which reads as follows:

a. Site infrastructure upgradation to-ensure improved handling of rainwater, ime voving the storm: water drain née gr ks, removal "structures ands: building compottn wall on all b.
-: anting saplings in the area outside the raw tate to .expand the green- -belt in the area and imp Tamil Nadu Pollutio ontrol Board 'after they issued notice under Section of the 31(A) Air (Prevention and Control of Pollution} Act, 1981 and the 33({A) Water (Prevention and Control of Pollution) Act, 1974. Thereafter for some time the case was clubbed along with O.A. No. 186 of 2020 which was related to a larger issue of chromium contamination site in Ranipet.
31 °21.When the matter was taken up on 16.08.2021, this Tribunal considered the Joint Committee report regarding the compliance of the recommendations in this case dated 16.04.2021 e-filed on the same date extracted in Para 5 of the order which reads as follows:
Compliance status of Recommendations ora de by the Jot Committee and present status of courpliance of directions already iasued by the Tamil Nadu Pollution Cantrol Board (ENPCB) under Section 334 Water (Prevention and Caontrel of Pollution) Act, [974 and under Section 314 of Air (Prevention and Control of pollutien) Act, 1984
1. Background The Hor'ble NGT, vide its order dated 30-07-2020 constifited a Joint Canmuttee to inspect the unit in question M/s Thiremaial Chemicais Ltd (PCL), SIPCOT Industrial Complex, Ranipet} and also the Puliyanganu Evi, Palaar and Ponniyar which were polluted on account of industrial pollutien, and submit a factual as well as action taken report to this 'Tribunal.

The Joint Commiitee submitted its report dated 11.02.2021 to the NGT. Upon hearing the Joint Committee report, the NGT vide order dated 15-3-2021 observed that "4 fi is seen from. the repert that there is ano ther case pending sefore this Tribunal in OLA. No. 186 of 2020 which is dealing with die faryer issue of Chromitan deposil in its ured crud the remedial sreasures to be taken for that purpose and some af te comumilien members are members in the other case also end fhey have submitted that some report has been fled in that cause'.

"s Under such eireumstanees, we feel that it is better that bath these cases can go together, so that confucting orders can be muniderd. Inthe meauntine the purties are also directed to complete their pleadings and objections to the joint committee report, so that aii these issues can. be taken together"

5S te the meantime the cwanmilter is aise directed fo ascertain as ie present status of comphance including the directions issued by natice under Section 334 Water (Prevention and. Cantrol af Pollution) Aet, 1974 and ander Section 31A of Air {Prevention and Control of pollution) Act, [9ST and s nbnut independent reparts to this Tri bunal regarding the same".

°s Parties are directed to subrrut fhe respective pleadings canted objections and tu: reportas directed on or before 19.04.2021".

32

2. Joint Committee's inspection to review the compliance of the Committee's recommendations and TNPCB's directions by 8"

Respondent company.
in order to review the compliance status of the Commuttees's recommendations and TNPCDs directions by 6 Respondent company ('CL), the Committee conducted a meeting in the Listrict Collector Office at Ranipet and visited the industry unit on {2-4-2021. Based on the site inspection and information provided by the industry init, the compliance status of the industry is given in Table-1 & 2 below: 3
Table 1, Recommendations of the Joint Committee pertaining to tt Respondent company and their compliance status SN Recommendations of the Joint : Committee pertaining to 8"

Respondent company Compliance Status triternal 'injection of treated untreated effluents to the canumenceme4nt Bs : £OTO As the unil was observed for non- compliance of corisent conditions, discharges uoliced in wolation of consent conditions, discharge to the environment -land, water and air resulting inte acute injury or damage fo the environment and treated -- fpartially and based on gesund water repeated violations, the unit was directed by TNPCR to restrict the production of 50% of its consented quaritity so as to achieve zero liquid discharge consistently ull effective funetioning of newly constructed Liquid Discharge CORIPONENTS, Ag the unit is in the process of and.

istarted trial rans for validation of the equipment to achieve Zcro liquid 2 discharge wilh respect to trealing | installed ETP components establishing ZLD system effluents, the wnit shall be allowed to operate in full load ony after ensuring the complete /fili-fledged Being complied order | The components comprising of "Disc Type RO, Waste Heat : Evaporator equivalent ta corventiona:

MER), ATFD are already installed & tral runs in presence of vendors is being done, teething issues are under care being made to run at fall capacity by 30% June 2021, the The industry informed that they have ordered a (ZLD) which will be a standby to new ETP with (WHE & correction, Efforts of we 150 KLD cenventional MEE WHE.

The industry claimed that. al current running capacity, the newly with the old ETP capable of achieving Zere are 2LD | 33 be! Ope TTP Madrasa and to certify thet tie waent Bas achieved TOoOe&s 2LId ] reer consultation QWEthy reput ad imstitute such as UT, | Macix ion of Upgrade a} RTP by TNPC UW. 'Phe full-fledged operation of 2LD system. should be 7 commenced within four months-

time by the TCL.

wit bh CD PRE EE Legiiicl discharge Pespece cpuustities.

tay The industry has assured that full-fledged Z2LD will be commissioned by 30t June 2021.

ALE cominissioning of iapgracded The tock yo has assured EYP, adexuacy test meets te be | that once the upgraded ETP teoarried aust ly ar inidepiceiclerit Bove.

TLration "Hike ~acinania ys research ine is CXUIULELIS STOLE, certification will be done by WY Madras bey 305 dune SOL 7 prepare @ DPin w iii three Mioe, for thas cenaed tation af pyar AeE the land where the wanireated Deffhaent was discharged within, the tnichastry site and execute the task of remediation. of ecortsiirated site, ander the supervision of "PNPCR. The entire cost for the study and rentediatinn shall be berne by thre Industry as per polhiter pays principle.

Not ceryolert The irihastry las informed that they Rave discussed avithy LY Madras arc) DPR is warner preparation for remocdiation afr the contearminested banc within ithe industry premises The imehistey das ass sured that DPR wilf be prepared by ond of May 2021 anal remediation work will he carbheed wound ciereber the supervision af PNPCIS. | Table 2. Directions of the TNPCB pertaining to 8 Respondent company amd their compliance status era bepaich cli:

SOharge not the operation of 24 following noted.
ye ecco snneneeneenenesennnenneeopbengeeeeneeett asenceneertee SN Directions 'issued by Compliance status i Fhe car ; xi ¢ COnSstru vand | "Being e omnplic el. Tcenmmence phe thew ZL COMP OTLELThS for effective | During the Joint CMM ree "ss fanetioning so as ta aciveve inspec tion held a La-d-2ar2t it wars observed that the inhustry hac commenced the fiull-Tecged LI system. However, Pra Sress as Organic cffluemt:
Frosr fren.
ILD.
£Q Ro treatment EPP, $igihy Clarifier UARSC hard:
ESS |' argardic three tirait. ress rejects will Ratect Solicts to-1y fer game slice.
miaketp.
Inorganic effluent: Phe GOW FL will pe ba Harcbyuiess VEL. bs prepusecl tor tatilbere thie existing RO,1,2,3 fr Pennie OY TOM effluent & ont Ceacoling ~ TR, in which HRSCC-2 for ane silica, awe (Cl ILD. BRO Perrieate: fren. the RC- L236 & RO-o are proposed ta wiliee for DM. Plant /coo lire ge tower miake up.
been efthuertt provieiedt Reverse Osrmiosis -t of cupacity 400 fi which IS - wo aay bect removal of frou wiiiedi it is feed ta the RO-S of capacity LOO ILI. RO Perrecate from: above said Be BOOS is proposed to mtilige for IDM Piank Talow RO refect Prernievel of from whirich it is teed. to the RO-6 of capacity 200 ' The arganic reject from ROQ-S and inorganic reject from RO-o are proposed to treat in the HRSCC-3 from which it will be sent to Waste Heat Evaporator of capacity 150 KLD and feed te the Agitated Thin Film Dryer (42 KLD) for recovery of salt and will be dispased to | Authorized recycler approved by TNPCR.
The unit has constructed new ETP and has started trial runs for validation of the equipment to finally achieve Zero liquid 'discharge with respect to treating thelr own effluents. The unit has installed HRSCC 3 Nos (65 KLD each} The industry has assured the full- fledged operation of ZLD system by June 2021, The unit shall operate the ETP continuously -- and efficiently so as to achieve Zero Liquid Discharge (2LD) system at all times. Being complied.
All the components of ETP, RO, MEE and ATFD are under from the treatment system noticed. During inspection the industry has recovered and stored salts of 2.9 'Tomes within the unit premises. As per the TNPCE direction issued on 09-12-2026, the industry has to restrict the production capacity to 50%. In response to this, the industry has restricted the effluent quantity to below SO % by scaling down high effluent generation plants and production adjustments in other plants. TRIS is misinterpretation of the orders of the TNPCB. The company operations. No bye-pass of effuent | produces almost -- 100% of consented quantity of Pthalic Anhydride chemical. The: company's appeal to TBPCB regarding amendment in the orders as 50% reduction in effuent generation has not been accepted by TNPRCR.
2.4 Million Litres of waste water which contains RO reject water, Regeneration water from DM plant, | and untreated/partially treated effluent had been stored in Raw water tanks.

lt was suggested by the Joint Coruniittee that around 2.4 Mulion Litres of waste water that has been atored for long time in the storage tank inside the industry premises should be treated and disposed off immediately.

The industry's existing ETP capacity is 560 KLD. Data for the rionth of March 2021 from Water Quality Watch Center (WQWC) shows 179.47 KLD on 26,03.2021, Now the unit has restricted the effiuent generation to 50% of consented quantity.

3 The operation of the unit shall not attract any public complanits.

Agreed to comply.

General complaint petitions were received often fdurmg the year 9919 and 2020} from nearby Public through District

-Adtninistration against --s the discharge of trade effluent from ESTP into nearby water sources.

The industry has been advised {fo comply with all environmental norms _ stipulated under.

36
"al Environment Protection Act/ Atr Act/ Water Act.
'The unit shail comply with - recannmendations of the Hydro-peological study report.
Coraplied.
Complied with recommendations of the report of Dr Ganapathy of VIT. As suggested, a sub-surlace storm water drain was construed in the western side of M/s. TCL anc was in operation. Photographs are shown in Annexure.
The unit shall provide garland drains around the unit prerrises to ensure that there is tie stepage of water from outside premises into the unit and vice-Versa.
Being C omplied The industry has cons structed the sub-surface storm water drain outside the industry premises on western side in between M/s.Tamil Nada Chromates Chemicals Ltd dump side and M/s.Thiramalal Chemieclas Ltd. In northern side, the industry has assured fo construct 4 retainer wall to ensure that there is tio seepage of water from autside premises into the unit and vice-Versa. The length of retainer wall is 500 metres and with a depth ranging from 1.5 metres to 5.0 metres. The with of the retainer wall is 250 oun. The Joint Committee, while Inspecting | the retainer wall construction, Suggested to increase the wall height to 2-3 feet to prevent excess water fo flow inside the industry. Photographs of retainer wall consituction are shown in Annexure 6 The unit shall provide suitable no. ef Peizemetric wells at ihe upstream and Soruplied, Eight nos. of Peizometnc wells have been provided. 4 nos at the downstream side of the unit 3?
i oe a premises, so as to assess the | _ ground water quality.
upstream and 4 nos., al the downstream, The unit shail provide proper rain water harvesting system | in the unit premises to tap the rain water, treal reuse for beneficial purgose, so as to aveid the rain water sunoff outside the premises ef the unit.
and | Compled.
'The unit has made arrangement to collect the rain water from 1.85 lakh sq. ft. of roof area in the Six zones of the unlit premises and saitis was reused as raw water for process.
Photes of roof collection water opt Wwe The unit shall revamp the storm water drain within the unit premises after detailed study on the carrying rapamity wilh respect {0 surface runoff.
Comphed.
The unit bas revamped the existing storm water drains and provided | subsurface callection tank of holding capacity 300,000 Liters at western: side and there is 4 rainwater outlet point in the eastern side near Fonnai Road. Pumps were installed to take back the collected rain water.
Photos of revamped storm water drains are shown in Annexure. final ranoff point at the South | "The anit has to replace the existing enaerobie contact filter with suitable advanced anaerobic treatment system so as to improve the quality influent! into aerobic treatment system.
Being Complied.
'The industry claimed thet through some study conducted anaerobic system improvement, it was found that effluent is highly biodegradable and the biodegradability is 85%. Further, it was reported that Anaerobic Filter Conmpartnent was replenished and revived by the addition of Bio cultures supplemented with suitable doses of nutrients and jaggery (feod for culture during inoculation).
for The industry claimed that the:
continuous addition of cultures 38 and improvements like recycling of sludge back ta the system, the present efficiency of the Anaerobic Filter Compartment has been increased to 69-70% which is the normal COD removal capacity of any Anaerobic Filter or Anacrotic digesters. In addition to above, additions of cultures and nutrients were done tn the aeration systems like SAFP {Submerged Aerated Fixed Film Reactor) a Secondary Aeration System followed by RAs (Return of the Activaicd Sludge} which has also efficiency of the aeration system. } iThe woit shall comply with conditions mentioned in the renewal of consent order vide proc.dated 03.07.2019 Compliance status on Water Act, HWA and Air Act are given below: ingreased the | WATER ACT:
1. The unit shall operate and maintain the Sewage Treatment Plant elficiently and continuously and the treated sewage shall be discharged on Industry's own land for gardening, green belt | development after satisiying the standards prescribed by the Board.

Commplied.

All the components of sewage treatinent plant were under operation. The treated sewage samples collected from the STP by the TNPCB. The ROA of the treated sewape reveals that the parameters mostly satisfy the standards prescribed by the Board. Treated sewage is utilized fer gardening, green belt development analyse the treated sewage through Board's lab and farnish ROA of the same.

Complied, The treated sewage collected from the STP by the TNPC Boarl The ROA of the treated sewage reveals that the parameters mostly satisfy the standards oreseribed by the Board, SANIPES | 3-The unit shall operate and maintain the ETP along with RO plant and MEE efficiently and continuously and ensure | Partially Complied.

As per the TNPCB direction issued on Q9- 12-2020, the industry has to 1 0 that the RO permeate and Maltiple Effect Evaporator (MER) condensate shall be recycling for process after satislying the standards prescribed by the Board,

4. 'Fhe unit shall etisuce that RO reject shall be sent to Mine for further treatment.

ii the which contains RO reject waler, restrict the production capacity to 50%, In response to this, the industry has restricted the eflueat quantity to below SO % by scaling down high effluent generation plants and production adjustments in other plants. This is misinterpretation of the orders of TNPCB, The company produces almost 100% -- af consented quantity of Ptralic Anhyrtride cheniical. The company's appeal to TBPCB regarding amendment in the orders as 50% reduction in effluent generation has not been accepted | by TNPCB, 9.4 Million Litres of waste water Regeneration water from DM plant, and untreated/purually treated | effluert had been stored in Raw water tanks.

It was suggested by the Joint Committee that around 2.4 Million Litres of waste water that has been stored far long time in the storage tank inside the industry premises should be treated and disposed off immediately All the components of ITP, RO, MEE and ATFD are under operations, Partially Complied RO reject is sent fo MINE followed by ATFD to recover salt. No bye- sass of effuent from the treatment system noticed. During inspection the industry has recovered and stored salts of 2.9 Tonnes withm the unit premises.

49

| immediately.

restrict the production capacity to 50%. In response to this, the industry has restricted the effluent down high effluent generation plants and production adjustments in other plants. This is misinterpretation of the orders af the TNPCB. The company produces almost 100% -- at consented quantity of Pihalic Anhydride chemical. The company's appeal to TBPCS regarding amendnient in the orders as 50% reduction in effuent generation has not been accepted iby TNECH.

2.4 Million Litres of waste water which contains RO reject water, Regeneration water from DM plant, and untreated/partially treated effluent had been stored in Raw water tanks.

Committee that around 2.4 Milton stored for iong time im the storage tank inside the industry premises should be treated and disposed off Cit discharge at all times and shall not discharge any treated/untreated -- cilluent outside the premises of the unit 'The unit shall achieve zero Partially Compled As per the TNPCR direction issued on 09-12-2020, the industry has to restrict the production capacity to 50%. In response to this, the industry has restricted the effiuent quantity to below 50 % by scaling down high effluent generation planis and production adjustments in other plants. This ft As per the TNPCB direction issued | on 09-12-2020, the industry has to quantity to below S50 % by scaling:

It was suggested by the Joint a8 ;
Litres of waste water that has been | | is misinterpretation of the orders of | At the TNPCB.
produces consented COR TDAnY 106% of ai of Pthabe The almost quantity | Anhydride chemical, The company's appeal to TBPCS regarding amendment in the orders as 50% reduction in efiuent gerieration has not been accepted | by TNPCB.
4 NMilfon Litees of waste water | which contains RO reject water, Regeneration water from DM pant, and untreated/partially treated effluent had beer stored in Raw water tanks.

It was suggested by the Joint Committee that around 2.4 Millon Litres of waste water that has been stored for long time in the storage tank inside the industry premises should be treated and disposed of) immediately.

All the components of "TP RO,MEE and ATFD are under operations. No bye-pass of effluent from the treatment system noticed, |

6.The unit shall reguiarly analyse the treated trade effluent through Board's lab ard furnish Rod of the same.

Complied.

Samples collected and analyzed through the TNPC Board.

7. The unit shall ensure the connectivity of EMEM provided at the inlet and out fet of ETP, MIEE inlet, MEE distillate, MEE concentrate, MEE centrifuged mother liquor and MEE steam miet with Care Ar Centre TNPCB / CPCB portals and provide proper data at all (times.

of Coniplied, EMEMs connected to TNPCR & CPCB portals.

13

a2 . Sone.

oe e unit shall operate and inaintain the separate EMS M 2 vovided at the line for the collection and pumping of seepage Wwatcr to the Equalization tank and maintain the log book for the The Complied.

uit has maintained the EMFM provided and also maintained the log book for the same, ) The unit she maintain the EMFMs provided at all the sources connected to Effluent water anid maintain the log book for the same.

Ll operate and -

Complied.

The unit has operated and maintained the EMPM provided at | all the sources comected to Effluent and alse maintained the log hook lor the samc.

| 10. The unit shall operate and "rcainiain the ATPD tor concentrating the liquor generated from the erystallizer efficiently and cant: TRUGLISEY, mother Complied.

ATED is under operation ground around the _comiposting unit and analyse the ground w furnish report to Board.

1} The unit shall collect the water {rey wells provided! ETP and Vermi Mezometric the same so as to asceriam ater quality and Complied.

Hight nos, of Peizometric wells have been provided. 4 nos at the upstream and 4 nos. al the downstream. The industry claimed that they furnish the report to the Board on the ground water quality from Piezometric wells.

: Authorization {2.The Haz rardous waste generated sha ll be properly disposed as per the obtained WaSis under Hazardous (MH&TM) Rules, 2008 and 'shall _ provisions of Hazardous an I comply with the Other Wastes (Management and Transboundary Movement) Rules, 2016.

Complied.

The industry has been generally complied the conditions stipmated in the HW Authorization hazardous impervious yard covered with roof shed in an earmarked place within the pr CHISES, 3 The industry has operated and.

i, The industry has stored ie wast: imo an! Area:

marked | each container holding the | hazardous wastes with marking "Hazardous Wastes"
. The storage area has fenced and a sign of danger should be placed at the storage site. . The containers holding the hazardous wastes kept in good condition.
. The industry has installed hazardous waste display board at the entrance of the factory and updated the same regularly.
6, The industry is maintaining the Form-3 and submitted | Form-TV_
13.The unit shall ensure that | Complied the non- Hazardous solid waste is dispased scientifically for Rurther beneficial purposes without any accumulation.
No Accumulation of solid waste found within the premises.
14. The unit shall comply Hazardous and other with the conditions imposed in Wastes (Management Handling & Trans Boundary Movement) Rules, 2016. Compliance of Conditions stipulated in the latest HWA issued dated 11.02.2020 {1) The unit shall dispose the Used/Spent Oil to the units having valid authorization of the Board and registration certificate as recyclers and necessary endorsement shall be made in respect of the quantity transacted in the original letter of registration lissued to the recycling unit lifting used oil, Complied.
Used/ Spent Oil to the units having and registration certificate as recyclers.
The industry is disposing the valid authorization of the Board. (2) The unit shall dispose hazardous waste category (1.2) Tarry vesidues and still bottonis from distillation to M/s. Gujarat Enviro Protection and Infrastructure Limited, Ranipet as reported. 15 44

gs (oo hazardous waste s.2 {Wastes or containing oil), {35.3} Chentical 'sludge from waste water treatment and (B2) Total Petroleum Hydrocarbons {TPH} (Co-

C 3G) equal to fer} more than 5000 me/ke to M/s. TNWML, canals ipsondi as | reported.

categories } The unit shall dispose resides | Compiled, The unit shall dispose heardous waste category (5.1) usedfspent oi to the authorized reported, recyclers aS Conmplied.

The industry is disposing the Used/ Spent Oi] to the units having valid authorization of the Board and registration certificate as recyclers, (5) The hazardous wastes shall be stored in a closed designated area, without exposure to rain, sunlight Pete.

Camplied.

The industry has stored the hazardous waste it an impervious yard covered with root shed tn a area sarmarked place within the premises.

(6) The unit shall dispose the Used /Sperit ofl to only those inchustries, which are having valid registration certificate, as ré-processors with Environmentally Sound lymanagement facilities to reprocess used / Spent oll.

Complied.

The industry is disposing the Used/ Spent Oil to pollution contro! Board authorized recycler only.

(7) The unit has to ensure that the ssed/spent ou 'disposed shall confirm the tandards suitable for reprocessing of used/spent eth et St the | Complhed.

(8} The unit shall ensure that adequate salety measures been fire have provided to avoid any fire accidents in the unit.

Complied.

The industry has provided adequate fire safety measures as 6 AS per the ors ey site ernergency planning | approved | by Inspecter of factory.

=) "The ut shall maintain (he Hazardous waste display Boards tn front of the factory clearly indicating the same regularly as mandated by the "Hen ble Supreme Court order dated 14.10.2008.

Conmplied, The industry has installed hazardous waste display board at the entrance of the factory and updated the same regularly, (1G) The Hazar dous wastes shall be stored in a compatible container on an impervious platform in elased shed which shall be orovided with requisite fire protection system, personal protective equipment and safety system.

Compled

1. Phe ho 3 umt has marked each container holding -- the hazardous wastes wi i.

marking "Hazardous Wastes , The storage area has fenced and a sign of danger shoul! be placed at the storage site. The contamers holding the hazardous wastes kepl in good condition.

' authorization '(Management (11) The person authorized shall comply with all the conditions stipulated tn the and ather conditions of the Hazardous anid Other Wastes and Transboundary Movement) Rules, 2016.

Complied.

Transboundary fig} The unit s hall maintain Ferm 3 and submit Form 4 prescribed under the Havarcious and Other Wastes (Management and Rules, 2016.

Movement] |

i) Compled.

The industry is maintaining the Rorrm-3 at the site and subniitted form-IV to TNPCE HS) The Hazardous wastes shall be disposed only with manifest that shall oe maintained io Form-10 of the Hagar dous and Other Wastes anagenient and 'Complied, The industry has followed manifest systern to transport the HOW and submitted Form 10 jeux , AG Transhoundary Movement} / Rules, 2016, (i4) The manifest shall be endorsed by the dispatcher, transporter and receiver of hazardous wastes. The eridorsed copy tnantfest shall be furnished to TNPCB as and when such disposal is made.

of the.

Coniphed.

The industry has provided the information of the hazardous nature of the wastes and measures to be taken in case of an emergency as Transport Emergency (TREM) card fe the transporter. The industry has followed manifest aystent to transport the HOW and submitted Form 10 ' Bnvironment (15) The umt shall ensure that all provisions of | Hazardous and Other Wastes (Mariagement and Transboundary Movement} Rules, 2016 as armended are complied with while handling hazardous waste.

Complied (16) The authorization is) subject to the terms and conditions as may be specified in the Rules for the » 3 time being in force under the (Protection) Act, 1986 and the conditions mentioned in the Schedule A & B. Comtpiied.

hazardous (17) The unit shall not store the Hazardous waste generated outside -- the premises of the unit.

Coniplied.

(18} The unit shall dispose the accumulated quantity of wastes immediately.

Compiled The industry has stored hazardous waste on site for a maximum period of 90 days a maxinrum quantity of 10,000kgs.

18

(19)The unit shall not store the Hazardous waste not exceeding 90 days and mtaintain a record of transier, storage and dispusal Hazardous waste.

« ai Coniplied.

The industry has stored hazardous waste on site for 8 maximum period of 90days a maximum quantity of 10,000kgs.

{20} The unit shall renew and have valid agreements with Hazardous waste C ompited.

facilitators at ail Umes. ; 21} The unit shall possess Net Complied.

valid consents of the board under Water and Air Acts at call fimes.

The industry has Renewal of Consent fo Operate (RCO} uneler Water Act & Air Act valid upto 31.03.2620 and subsequently Board has issued that the validity of RCO is extended upto 3O.08, 2020.

The industry is Rinctioning withoart valid consent ofthe Board. The industry has submitted the renewal under Water and Air Acts through TNOCK vide hewes AGES

-application No: 31860921 dated 24.03.2020 and the industry was requested to furnish certain details | and compliance for the direction issued by the Board. The industry has resubmitted the application on 11.04,2021 and under process.

15.The unit shall not use 'use and throwaway plastics' such as plastic sheets used for food wrapping, spreading en dining tabie etc., plastic plates, plastic coated tea cups, plasiic tumbler, water souches and packets, plastic straw, plastic carry bag and plastic flags irrespective thickness, within the industry premises. Instead it of Complied The industry has not used the 'use and throwaway | plastics' and the sae was display ed in the employees assemble areas, 18 4g shall encourage use of eco- friendly alternative such as banana leaf, arecanut palm plate, stainless steel, glass, porcelain plates/cups, cloth bag, Jute bag etc., i6.in case of revision of consent fee by -- the Gevernment, the unit shall remit the difference in amount within one menh Failing to remit the consent fee, this consent order will be withdrawn without any notice and further action will be initiated against the unit as per law.

from the date af notification. | CompHed.

The industry has remitted the consent fee as per the revised GO.

AIR ACT {The unit shall operate and maintain the Air Polbition Control measures / Acoustic PMeasures efficiently and continuously so as to satisly Ambient Air Quality / Emission /Antbient Noise Level Standards prescribed by the Board.

Complied.

Air pollution control measures were i operation. The AAQ/SM/ANL survey conducted by the Board lab on 39,08.2020 reveals that the parameters are well within the standards prescribed by the Beard,

2.The unit shall periodical survey tor Ambient Air Quality) Noise Level/ Stack Emission as per the submit the repert to the Board without fail, conduct.

MoEF Notification 2009 and | Coniplied.

The industry has conducted the survey for Ambient Air Quality/ Noise Level/ Stack Enussion through TNPC Board Lab yearly twice. The unit has carmed out survey through TNPCB lab, Vellore on Ambient Air Quality/ Noise) Level) Stack Emission on

3.The unit shall ensure the commec#hvity of online monitoring system for the emission parameter PM, SOs, CO and NOx attached to Thermic Fluid Heaters and Conplied.

OCEMS fer the parameters PM, SOx, NOx & CO connected to TNPCB and CPCB portals were found in operation. | 20 49 provide proper data to Care Air Centre of TNPCS, __ hennat / CPCB at all AMES, 4 The unit shall ensure the connectivity of VWOC/CO moritors provided at the process stacks such as PAI, PAQ and PAS with Care Air Centre of TNPCB, Chennai / CPCB and provide proper data at all times. | Compe.

OCEMS for the pararneters VOC && CO connected to TNPCB and CPCS portals were found In operation.

as = In ease of revision of consent fee by -- the Government, the unit shall regit the difference in amount within one month frora the date of notification. Failing to remit the consent fee, this consent order will be without any:

"notice and further action will be initiated against the unit withdrawn as per law, Comiplied The industry has remitted the consent fee ag per the revised GG. The unit has RCO valid upte 31.08.2026 and subsequently Board has issued thet the validity | of REGO is extended upto 30.09.2080. The unit is functioning without vald consent of the Board. The unit has submitted the renewal under Water and Air Acts through | TNOCMMS vide appHcation No:
8188052) dated 24.08.2020 and the unit was requested to iurnish certain details and compliance for the direction issued by the Board. The unlt has resubmitted the application on 11.04.2021 and under process.
The unit shall strictly coraply with conditions rmientioned in the renewal of consent order vide proc, dated 13.17.2019 Action taken by the unit are detailed below:
TNPCB's directions issued on 13.11.2019,
1) The unit shall conduct the Hydro-geological study through a competent agency and furnish report.

Complied.

Complied with recommendations 'of the report of Dr Ganapathy of VIT. As suggested, a sub-surface storm water_drain was construed and was in operation,

2) The unit shall provide garland drains around the rit pret mises fo ensure that there is ne seepage of water from outside premises itito ithe unit and wice-Versa.

The industry has constructed the aub-suriace storm: water drain outside the industry western side in between M/s.Tanul Nadu Chromates Chemicals Ltd dump side and M/s. Thirumalal:

Chemiclas Ltd.
In northern side, the industry hes assured to construct a retainer wall te erisure seepage of water HEM ises fron outside 500 metres and with a depth ranging fram 1.5 metres to 0.0) metres. The width of the retainer wall is 250 mm. The Joint Comnniitee, while inspecting the:
construction, the wall retainer wall suggested ta itierease height te 2 water to flow inside the industry. Photographs of retainer construction are shown if ATHICNUre _
3) The unit shall provide suitable no. of Plezometric wells af the upstream and downstream side of the unit premises, so as to asscss the eround water quailty.

ds WHrslreaim.

Conuied.

Eight nos. of Pelz momerric Wels have been provided. 4 Nos at te upstream and 4 Nos., at the

4) The unit shall provide proper rain waler harvesting system in the unit premises to tap the ram water, treat and reuse fer beneficial purpose, se as to avoid the rain water runoff outside the premises of unl.

Compled.

The unit has made arrangement to calle at ne rain water from 3. ~ lakh sq. ft. of roof area in the - 3 ZODeS ie the urtit prenises process.

Pedi in the western side ot M/s. TCL premises on that there is no into the unit and vice-! Versa, The length of retainer wall is | 3 feet to prevent excess | wall | and sae was reused as raw water for | | 8} The unit shail revainp the storm water drain within the unit premises afier detailed study on the carry ing capacity with surface runol?, respect to the collected rain i Canplied.

The wit has revariped the existing storm water drains and provided subsuriace collection holding capacity $00,000 Liters at final ranoff point at the South western 'sidie and there is 4 rainwater outlet point in the eastern "ide near Ponnai Road. Pumps were installed to take back weler, fark of &) The unit shall segregate "ey the different stream of trade ' effluent at source itself based en the characteristic of effluent generated and revamp the existing ETP with latest state of art af treatment technology se as to achieve ZL at all times.

Por Compicd Organic effluent:

further treatment of organic effluent from ETP, the unit has provided Reverse Osniosis ~} of capacity 400 KLD, in which RO - rejects will go to High Contact Clarifier (IRSCC- {} for removal of hardness and silica from which it is feed to the RO-S of KLID RO Rermeate td | er 4 & RO-5 is utiize for DM Flant capacity 100 irom above sa proposed to makeup.
Inorganic effluent:
The unit is proposed to utilize the existing RO,1,2,3 for treatment of DM eluent & Coaling Tower blaw down (CTBD), in which RO reject will go to HRSCC-2 for har dnes ss and silica, from which it 'is feed to the RO-6 cf capacity 200 KLD. RO Permeate from the RO-| & RO-6 are proposed fo) 1,2,8 utilize for DM Piant/cooling tower makeup.
The erganic reject Rated Solids | removal of) from ROQ-S and | inorganic reject from RO-6 are | 23 52 proposed to treat in the HRSCC-3 from which it will be sent to Waste Heat Evaporator ef capacity 150 KLD and feed to the Agitated Thin Film Dryer (42 KLD) for recovery of salt and will dispased to | Authorized recycler approved Dy TNPCE.
ai The unit has constructed new ETP has started trial runs for validation of the equipment te finally achieve Zero liquid discharge with respect to treating their own effluents. The unit has installed HRSCC 3Nes (65 ID cach) |
7) The unit has to replace the | existing anaerobic contact filter with suitable advanced anacrebic treatment systen so as to improve the quality of influent into serobic freatment system.

i Pilter Complied.

The industry claimed that through some study conducted -- for anaerobic system improvement, it was found that effluent is highly biodegradable and the biodegradability is 85%, Further, if was reported that Anaerobic Filter Compartment was replenished and revived by the adsition of Bio eultures supplemented with suitable doses of nutrients and jaggery (ood for culture du ring inoculation).

The industry claimed that the continuous addition of cultures and improvements like recycling of sludge back to the system, the present elliciency of the Anaerobic Compartment has heen increased to 65-70% which is the normal COD removal capacity of any Anaerobic Filter or Anacrohic digesters. In addition to above, additions of cultures and mutrients were done in the aeration systems like SAFF_ (Submerged Aerated | 53 t t Rived Film Reactor} a Secondary Aeration System followed by RAs Return of the Activated Sludge! which has also increased the efficiency of the aeration system.

8} The unit shall operate the Being complied. ETP cortinuously and efficiently so as to achieve All the components of ETP, RO, Zero Liquid Discharge LD) (MEE and ATFD are ou nder system at all times. operations. No bye-pass of efffuent from the treatment system: noticed, During inspection the industry has recovered and stored salts of 2.9 Torines within the unit premises.

As per the TNPCB direction issued an 09-12-2020, the industry has to restrict the production. capacity to 50%. In tesporse to this, the industry has restricted the effluent quantity to below S50 % by scaling down high efflient generation plants and production adjustments in other plants. This is misinierpretation of the orders of the TNPCB. The company produces alinost = 100% af consented quantity of Puhadlic Anhydride chemical. The company's appeal to TRPCB regarding amercdiment in the orders as 50% reduction in effluent gerieration has not been accepted by TNPCR.

3.4 Million Litres of waste water which contains RO reject water, Regeneration water Ford DM plant, and untreated/ partially treated effluent had been stored in Raw water tanks.

It was suggested by the Joint Committee that around 2.4 Million Litres of waste water that has been 25 'tank inside the industry preutises should be treated and disposed off uamediately.

The industry's cxisting ETP capacity is S60 ALD. Data for the month of March 2021 from Water Qualiiy Wateh Center (WOW) shows 179.47 KLD on 26,030,202 1.

Now the writ teas restricted the Oo) The operation of the anit Agreed to comply. shall not attract any public cornplaints. General complaint petitions were received often {dunng the year Public through District | Adimimsiration apainat the discharge of trade efflient from ETP inte nearby water sourees.

The industry has been advised fo comply with all environmental Oris stipulated under Environment Protection Act/ Aw ety Water Actl Somphed.

10) The unit fas to pa) environmental corupensation viclations caused by the wnit | Environmental Cori pensation Dwithiin ane moth. Pamount of Ks.i8.6 lakhs vicle C.R.No.82750 dated 13. 12.2019 Se Be Conclusion As per the TNPCE dircetian issued an OG-12-2020, the industry has to restrict the production capacity to GO%, In resporee to this, the industry bas restricted the effiaent quantity to below SO % ly snaling down high effhaent generaben. plants arcl production adpistments in other pharits. This is misinterpretation of the orders of the "FNPCS. The company produces aimost TQOQ' of consented quantity of Puiake Aniydride chemical. The company's appeal ta TBPOD rega relirig amendment in the omlers ag SO% reduction in effluent generation has not been accepted by NPR.

> 4 Million Litres of waste water which moritains EO reject water, generation water from DM plant, and untreated fpartially treated effluent tad been stored In Raw sweater tarks. It was suggested by the Joint Clommittee that around 2.4 Milhon Litres of waste water that lias heen stered fer long time in the storage rank inside the industry premises should be treated and disposed off imunecdiately.

he industey has assured that full-fledged @LE wihl be cormmuissioned by 30% June 2021 a nd alex once the upgraded ETP is 2 commissioned, certification ofits adequacy will be carried by TIP Madras by 80% dune 2021 under the supervision of TNPCK.

By considering the above facts and observation of the Joint Committee, the Hen'ble Tribunal may pass appropriate Order is} {Direction (5) as deemed fit.

coerced effluent generation ta 50% af:

2019 and 2020) fram nearby; of Rs. 18.6 lashs for the The industry Bas paid the:
:
22. It was also mentioned in the report that the full-fledged ZLD will be commissioned by 30.06.2021 and once the upgraded ETP is commissioned, certificate of its adequacy will have to be carried out by Madras by 30.06.2021 under the supervision of the Tamul Nadu Pollution Control Board.
23. It was again taken up on 08.11.2021, this Tribunal considered the report submitted by 7: adu Pollution Control Board 'NaduRoliution Corirol Board and submit a } & sont - ;

q the preseril, "after remedic a. i NGT order « ad Lt TUTE Lid., (PCL) us inspe a by Joint Chi idivironmental Engineer iMonitoring), TNPCB, Vellore (on 22.09.2021. During the inspection, Effluent Treatment Plant provided by the urtit followed by RO systems, and MEE followed by ATFD to achieve Z2LD were found in operation. The following compliances were observed for the Board's Direction dt. 13.11.2019, 09.12.2020 and compliance of Hon'ble NGT order dt. 15.03.2021.

a tad oard 'a Directions issued by TNPC 5 TNPCB/ F.0892/ VLR/RL/ W/ 2019 Dated: 13.11.2019.

~ 'Directions issued by TNPC Board Compliance by the unit mel The unit shall conduct the Hydro-

geological study through a competent agency and furnish report.

Compfied With., The unit has conducted the Kydre- | geological study by Dr. Ganapathy 7 WIT University, Vellore and the un has the suggested Dy him.

Mitigation and Management implemented reconnnendations No The unit shall provide garland drains around the unif orernises to ensure that there is no seepage of water from vautside premises into the unit and yice-Versa,.

The / completed the Retainer wall along the | unt has constructed and northern portion of their unit ( the length of retaining wall is 238 metre in north side and & metre towards north west as fotal in the north west corner of the unit as this stretch is reported to be contribuled more seepage by the hydro geological study conducted by Dr.S Sankaran (Retired Chief Scientist al NGRI} from: 7.5 metres ta 4.0 metres and and with depth ranging | width is 250 mm} as recommended by an Expert Hydro-Geologist Dr S| Sankaran (Retired Chief Scientist of NGERI who worked along with VIF, Vetlore's Environmert Department ta study of the SIPCOT water shed. The iwidih of ihe retainer wall is 250 mrn.

The remaining portion is already provided with compound wail te prevent the seepage.

The atest Photographs on the | completion of the retainer wall is | attached ag Annexure 2 Dung 22.08 2027, #8 observed that the unif has compisted the 490 % retainer wall (238 Mt + &. Mt length Was:

inspection an of the construction of on North west corner of the unit). The retainer wall provided in ROG covering HOPE sheet at foundation :
level cuiside portion of the wall with l earthen drain at GL so as fo prevent from the seepage from outside. The | unit has already provided the surface | drain on western side of the unit te. pass on the seepage fram TCCL. C).

nall provide suitable No. of Peizometric wells at the upstream and ' downsiream side of the unit premises, sa as fo assess the ground water quality, The unt has provided the & | Plez rometric wells (4 - upstream & 4 downsteam).

Camplied with, Be.

The unit shail provide proper rain water harvesting system in the unit oremises to tap the rain water, treat and reuse for beneficial purpose, SO AS to avoid the sain water runoff outside the sremises of the unit Complied with, The unit has 'eporeg rat 1.85 square feet of roof area covered into five zones for collection of rain water for reuse.

The unit shail revamp the storm water drain within the unit premises after detailed study on the carrying capacity with respect to surface runot, : sump at South West Complied with.

The unit h drains in the plant area te receive the | as modified ine storm y notes ae :

excess rain water from their premises | and the collected sionm water _ ach the final run-off paint (collection f corner).
et The unit shall segregate the diferent stream of trade effluent af source itself based on the characteristic of eMuent generated and revamp the existing ETP with latest state of arf of teaiment at sechnology so as to achieve ZLD at all a i mes.
The unit has segregated the ade effluent ag Organic and Inorganic for set eHiuent.
The | unit is augmented with mocern Disc | separate teatment of
-d Tube Reverse Osmosis system. | t Evaporation and Agitated Thin Fi Drier (ATED). The unit is tr organic and inorganic stream in the | eating ihe existing ETP and the inorganic stream ; is treated in the augmented Disc anc Tube Reverse Osmesis sysiem, It was :
also found during inspection tat in (WHE) 19 Nos. of modules out of 38 and old | the Waste Heat Evaporator ut fao7 MEE were not under operation and | they are reported to be kept as.

standby. :

The new ETP with ZLO Components :
comprising of Disc Type RO with New 150 KLD conventional MEE followed by & ATFD were installed and commissioned and found under operation. The unit has reporied that the system Le new conventional MEE 150 KLD capacity is sufficient even for full consented capacity of trade effluent.
"sh The unit has to replace the existing anasrabic contact filter with suifable advanced anaerobic trealment sysiem sO as to Improve the quality of induent ints aerobic treafment system. Comptied with, Cerlain modifications have been implemented in the existing anaerobic contact fiter so as to improve the quality of influent in io aerotic ireatment system by the unit. Co The unit sha operate the continuousiy and efficiently so as to achieve Zero Liquid Discharge (LD) Comphes with, During inspection if was observed that they have generated the trade effluent from their process at this situation, 'less than 286 KLD which is 50% of the consented quantity and this quantity is treated so as fo achieve ZLD by the 'unit( copy of flow meters readings enclosed vide Annaxure.3} £O The operation of the unit shall not altract any public complaints. The unit has assured fo comply the. candition.
ace 3 "Fy ey $ he unit has fo pay Environmental Compensation of Rs. 18.6 Lakhs for the violations caused by the unit within one month.
Comotied with, Directions issued by TNPC Board vide Pros. No.:
TSITNPCBIF.O892/VLRIRLIWSA/2020 Dated: 09.42.2020 cry Directions issued by TNPC Board Compliance by the unit 'The unit shall restrict the production to 50% of is consented quantity so as to consistently th the commencement & effective functioning of newly constructed Z2LD | ' camponents.
Yet fo be complisd .
During inspection, it was found that one of the product Dicarboxylic Anhydrides- achieve zero liquid discharge | (Phthalic Anhydride) quantity was found to | be exceeded the restricted quantity Le., 50 | 6 of its consented quantity as per the direction issued by Board vide Board's Proc No. TSTNPCBIF.0802/VLRIRLIVEAIZ 920 Dt. 09.12.2020 and other products are within 50 % of iis consented quantity. The copy of the letter submitted oy the unit at 29 99,2021 for the production capacity from | 94.08.2024 fo 31.08.2021 is enclosed fer:
referenoe. ( Annexure. 1) The production for the month of August 2024 (1.8.2024 to 31.08.2021) as follows:
_ Product a Dicar | ee boxyl | a. pay _ Bicarbox io eo ylic | Anhy ¥ Acid i dride Acids Salts S wt : Consen | | fed | 10,82 | | 0 Quantit | 0 1,925 | 18 oy Actual Producti al onin sore 733 0 August | ee The unit has reported that to comply with | Board's direction, their production has thus | been adjusted by them such that the complex generates below 50% of the effluents by reducing the production of high es effluent generation plants with the following points.
4. Dicarboxylic Acids contribute to maximum effluent -reduced to less than 50% of consented quantity
2. Dicarboxylic Anhydrides do nat contribute to liquid effluent Le) the continuous process ~cannot be tuned down, has catalyst /yield safety implications.

At present the unit has installed and ' |} commissioned the new ETP with ZLD { new ETP along with MEE followed by. AYFD- (150 KLD capacity of conventional | MEE } so as to achieve the ZLD for ful capacity of consented quantity.

However, they have generated the trade affiuent from their process at this situation, | less than 280 KLD which is 50% of the.

consenied quantity so as to achieve the | ZLD{ copy of enclosed vide Annexure.3) flow meters readings Dicarboxylic Anhydrides are made in i The unit shall furnish the bank guarantee for Rs. 10 lakhs (Rupees Ten lakhs } immediately valid for a periad | one year to the Board in the format enclosed for the compliance of the following conditions .

Compiled with, The unit has furnished the bank guarantee for Rs. 10 lakhs (Rupees Ten lakhs } fo the | Board.

| not | complaints.

* (¥he unit shall construct and | The unit has segregated the trade effluent | commence the newly ZLD as Organic and Inorganic for separate components for effective | treatment of effuent. The unit is. functioning so as fo achieve | augmented with modem Disc and Tube Zero Liquid Discharge. Reverse Osmosis system, Evaporation and Agitated Thin Film Drier (ATFD). The unit is freating the organic and inorganic stream in :

the existing ETP and the inorganic stream is treated in the augmented Disc and Tube | Reverse Osmosis system. ff was also | found during inspection that in the Weste Heat Evaporator (WHE) 19 Nos. of) modules out of 38 and old MEE were riot under operation and they are reporied to be kept as standby.
The new ETP with ZLD Components comprising of Disc Type RO with New 40 | KLD conventional MEE followed by & ATED were installed and commissioned | and found under operation. The unit has | | repotted that the system le new) conventional MEE 150 KLD capacity . : sufficient even for full consented capacity oF | trade effluent. :
SES Unt Shall operate the _Complied with, : 7 existing ETP continuously , The ETP, RO, MEE followed by ATFD were | and efficiently so as to: found under operation. actieve Fero Liquid | There was no discharge of effluent found | Discharge (ZLD) system at all outside the premises during Inspection | times and ensure that there shall not be any discharge cf treated / untreated effluent in to the ouiside of the: _ premises. 2 ~3 Fhe operation of the unit shall The unl has assured to comply "the | | attract any public ) condition ; The unit shall comply with the | recommendations of Hydro- geological study report. premises as Complied with, The unit has completed the permeable sub- surface storm water drain, outside the western border of the firn to allow the chromium contaminated water to flow away from the Mis Thirumelal Chemicals Ltd., Comprehensive Hydro-geological Study report prepared by Dr. G.P Ganapathy , | Professor and Director , Centre for Disaster Mitigation and Management, VIT, Vellore. suggested in the | an The unit shall provide garland drains around the -- unit premises to ensure that there is no seepage of water from ouiside sremises into the unit and vice-Versa.
as recommended by The unit has constructed and completed | the Retainer wall along the northern portion of thelr unit ( the length of relaining wall is 238 metre in north side and 9 metre towards north west as total in the nonh yest corner of the unit as this strefch is reported to be contributed more seepage by the hydra geclogical study conducted by Or.S Sankaran (Retired Chief Scientist of NGRH and with depth ranging from 7.5 metres to 5.0 metres and width is 250 mm ) Geologist Dr S Sankaran (Retired Chief Scientist of NGRI} who worked along with | _VIT, Vellore's Environment Beparimeni to study the SIPCOT water shed. The width of the setainer wail compound wail to prevent the seepage.

The latest Photographs on the completion .

of the retainer wallis attached as Annexure ~-- 2, During inspection on 22.09.2027, K was observed that the unit has cornpleted ithe 100 % of the construction of retainer wall (238 Mi. + 9. Mt length on Narth west comer of the unit ). The retainer wall an Expert Hydro- | is 250 mm. The:

'remaining portion is already provided with 63 provided in RCC covering HDPE sheet at foundation level outside portion of the wall with earthen drain at GL so as to prevent from the seepage from outside. The unit has already provided the surface drain om | wesiem side of the unit to pass on the | seepage fram TCCL.
The unit shall provide suitable No. of Peizometric wells as per the norms at the 'upstream and downstream side of the unit premises, so) as to assess ihe ground water quality.
Complied with, The unit has provided the 8 Piezometac wells (4 - upstream & 4 downstream). The unit shall provice proper rain water harvesting system in the unit premises to tap the rain water, treat and reuse for | beneficial purposes, so as fo avoid the rain water runoff outside the premises of unil. | Comptied with, The unit has reported that 1.85 Lakhs. square feat of roof area has been cavered into five zones for colleclion of rain water for reuse.
The unit shall complete the | entire storm water collection through drains & disposal through =o scienific. = manner within the unit premises after | detailed study on the carrying with respect to.
Somotied with, The unit has recommendations of Preliminary report oy | 7 :
pee Dr. Ganapathy of VIT. As suggeste
-
sub-surface storm water drain is in aperation.
The unit has revamped the existing storm water drains and also provided a | subsurface collection fank of holding | capacity 3,00,000 Litres at finai runoff point : at the South western sidg of the unit and also provided rainwater outlet point in the _eastem side near Ponnai Road. A suitable | | Pump is installed to take back the collected | rain water.
complied with:
2, a:
64 9 |The unit shail replace the existing anaeranic anaerobic treatment system so as to improve i system.

contact | fiter with suitable advanced | xe quality of : influent into aerobic treatment.

Complied with.

Certain implemented in the existing anaerobic modifications have been contact filler so as to improve the quality of | influent in to aerobic treatment system by the unit.

10. The unit shall s with the conditions mentioned irictly comply in the renewal of consent omey issued vide proc. dated 03.07 2019.

The compliance of canditions for renewal issued previously under Water and Air Acts has heen given in Sl Noll.

14. The unit shail strictly comply with the conditions mentioned in the direction issued vide proc. dated 13.71.2078 The compliance of conditions are given in SI No. HE Previous Renewal of Consent Order Proc. No. TS TNPCBIF.O892VLRIRLIVLRIW7A/2019 DATED: 03/07/2019 with validity up to 30.03.2020 further extended by the Board up to 30.09.2020 Water Act S.No. Additional Conditions Compliance by the unit

4. (The unit shall operate and | Sewage Treatment Plant was under

maintain the Sewage Trealment and the treated sewage shall be discharged on industry's own "evetopient after satisfying the prescribed by the Board.
Plant efficiently and continuously land for Gardening, green belt: co operation during inspection. The statement of Report of Analysis (RoA) of treaied sewage collected from August (2020 to June - 202%( Total sampies lected 4 Nos} parameters TSS exceeded the siandards revealed that the the Board. The treated sewage is being utilized for gardening in their premises. and the other parameters pH, BOD are satisfied the standards as prescribed by The unit shall regularly analyse ithe treated through sewage Complied with.
OS t x ' Complied with.
~~ Board's lab and fumish ROA of. : , he same.
(3. The unit shall operate and Effluent Treatment Plant (ETP), Reverse maintain the ETP along with RO |Osmosis (RO) and Multiple Effect; plant and MEE efficiently and Evaporator (MEE) were found to be under | continuously and ensure that the operation during inspection. The statement RO permeate and Multiple Effect of RoA of RO permeate collected fom Evaporator (MEE) condensate August 9020 fo June ~- 2027 4 Teta shall be recycling for process samples collected ~ 6 Nos.) revealed that after satisfying the standards (all the parameters except pH ( 2 sampics prescribed by the Board. collected during August & October 20205 out of 6 Nos. } are satisfied the standards prescribed by the Board. The RO permeate and condensate from MEE is being reused in their process.
a The unit shall ensure that RO Complied with., reject shall be sent io MEE for | | further treaiment. ,

5 The unit shall achieve zero Complied with, ~ "discharge at all times and shall "There was no discharge of effluent found :

"pot discharge any | outside the premises during inspection | treated/untreated effluent outside | :
the premises of the unit. & TThe uni shall regularly analyse Complied wilh., : the treated trade efluent through | | Board's lab and furnish RoA of : the same.
SSRs Gait shall ensure the | Complied with., 4 connectivity of EMFM provided at ihe inlet and out let of ETP, MEE inlet «MEE distillate, MEE concentrate, MEE centrifuged mother liquor and MEE steam | 'intet with Care Air Centre of TNPCS { CPCB portals and. , provide proper data al all times. "E the | tnt shall operate. and | 7 66 maintain the separate EMFM orovided at the fine for the | collection and pumping of seepage water to the Equalization tank and maintain the log book for the same.
Complied with...
9 |The unit shall operaie and 'maintain the EMFMs provided at all the sources connected to Effluent water and maintain the:
log book for the same. 2
12. (The unit shall operaie and | Complied wilh., maintain the ATFD -- for concentrating the mother iiquer generated from the crystalliser.

| efficiently and continuously.

11 , The unit shall collect the ground : Complied with., 'water from Plezometric wells: The statement of RoA of ground water orevided around the ETP and : collected in the month of July 2020 from 8 :

'Verml composting unit and = piezometric wells 4 - upstream & 4) analyse the same so as ta | downstream) revealed that the parameters - ascertain the ground water quality such as Tolal Suspended Solids (TS3} and furnish report to Board. Total Dissolved Solids {TDS}, Biochemical Oxigen Demand (BOD) & Chemical Oxignen Demand (COD) are exceeded the standards prescribed by the Board in different above prezometric weils.
42. |The Hazardous waste generaied | The unit has obtained authorisation under shall be properly disposed as peri the Hazardous and Other wastes | the Authorization obiained under | (Management & Transboundary Movement Hazardous weste {(MH&TM){) Rules, 20716 as amended vide Board's Rules, 2008 and shall comply | Proceedings Dt. 11.2.2020 and validity up wih the provisions of Hazardous | to 70.2. 2028, and Other Wastes (Management :
anc Transboundary Movement) Rules, 2016.
13. Compiled with., The unit shall ensure that the non 67 Hazardous solid waste is disposed scientifically for further a bensficlal purposes without any accurnulation.
14.

The unit shall camply with the:

conditions imposed in Hazardous and other Wastes (Managernent | Handing & Trans Boundary | Movement) Rules, 2016.
The unit has assured to comply the conditions.
15.

The unit shall not use 'use and f{hrawaway plastics' such as plastic sheets used for food table etc., plastic plates, wranping, spreading on dining jlastic coated tea cups, plastic tumbier, water pouches and packets, nlastia straw, plastic carry bag and plastic flags irrespective of thickness, within the industry ipremises, Instead it shall encourage use of eco friendly aemative such as banana leaf, arecanut palm plate, stainless steel, glass, porcelain plates/cups, cloth bag, Jute bag_ Complied with., ee oD in case of revision of consent fee by the Government, the unit shall remit the difference in amount within one month from the date of notification, Failing to remit the consent fee, this consent order! wil be withdrawn without any 2 notice and further action will be | jnitated against the unit as per) Complied with., 68 Alr Act S.No. | Conditions Compliance by the uni A, : The unit shall cperate and maintain | Compiled with 'the Air Pollution Control measures |The unit has provided Stack with Acoustic measures. efficiently and | Scrubber & Cyclone separator as Air) continuously so as to satisiy ! Pollution Control (APC) measures and Ambient Air Quality / Emission/) were found in operation. The RoA of Ambient Noise Level Standards Ambient Air Quality (AAQ) survey orescribed by the Board. conducted on 10.8.2024 revealed that. the parameters Particulate Matter - { PMos, PMs.) Oxides of Sulphur (SQ, ye & Oxides of Nitrogen (NO, were found:

within the AAQ standards as prescri ibed by the Board.
The unit shall conduct periodical | Complied with., ro survey for Ambient Air Quality! "Noi oise Levelf Stack Emission as per "the MoEF Notification 2009 and submit the report io the Board without fail,

3 (The unit shall ensure the Compfied with., _cannectivily of online moritoring system jor the emission parameter PM, SOx, CO and NOx attached to Thermic Fluid Healers anc provide proper data to Care Air Centre of TNPCB, Chennai / CPCB at all.

times.

4 (The unit shal ensure the | Compiled with., _connectivily of VOC/CO monitors : srovided at the process stacks such as PAT, PAZ and PAS with Care Air | Oenire of TNPCB, Chennai / CPCB | and provide proper data at all imes.

5. | Incase of revision of consent fee by | Compiled with., the Government, the unit shall remit 'the difference in amount within one month from the date of notification.

Failing to remit the consent fee, this consent order will be withdrawn and further without any nofice laction will be initiated against the | unit as per law.

Compliance by the unit on the Hon'ble NGT Order dated: 15.03.2021 as per Joint Committee report . SLNo, | NGT Order dated: 15.03.2024 as per Joint Committee report Compliance by the unit 04 The full-fledged operation of ZLD system should be commenced | within. four months-lime by the PCL. Further, | issued by TNPCB are io be the conditions complied within three-month times.

-ZLD by the unit. Further fhe unit as Organic _ separate treatment of effluent. The .

"unit is augmented with modern Disc Thin Fir Drier (ATF). The unit is. | treating the organic and inorganic | Camplied with The unit has reported that they are | now generating 50% of their consenied quantity of effluent as stated in thelr earlier letters to! TNPCB., During inspection, it was observed that the unit 's generating trade effluent quantily as jess ihan 50 % of consented quantily and this quantity is treated so as to achieve has segregated the trade effluent and inorganic for and Tube Reverse Osmosis | system, Evaporation and Agitated | siream in the existing ETP and the | inorganic stream is treated jn the | augmented Disc and Tube Reverse | Osmosis system. It was also found et Lge:
during inspection that in the Waste : 78 Heat Evaporator (WHE) 19 Nos. of ald MEE were not under operation and they modules out of S38 and are reported to be kept as standby. The new ETP with 2LD: Components comprising of Disc Type RO with New 150 KLE 'corventional MEE followed by ATFD were installed and commissioned and found under : operation. The unt has reported that ihe system ie new cenventional MERE 150 KLE /capacity is sufficient even for full consented capacity of trade effiuent to achieve 42LD . ( copy af flow meters readings enclosed vide Anrexure.3} f2 Aiter commissioning of upgraded ETP, adequacy test needs to be caried out by an independent gov. academic/research institution lke HT Madras and to certily that the unit has achieved {00% ZLD capacity.
Yet to be cemplied, The unit has reported thal # is discussed with Prof. Dr. Ligy Pig of HT Madras. They have visited their factory on 10 April, and 23, 24.7.2021, HT, Madras and carried the audit of the out treatment systems to assess thelr capacity for | 100 % ALD, unit that the report is awaited from HT, Madras and the unit assured that it woulkl get certification done by HT, Madras at the earliest, lt is informed by the | 03 TCL shall, in consultation with as HT, Madras, prepare a DPR within the > rarnediation of the land where the reputed institute such 'three = months-time, for untreated effluent Was Complied with ;

The unit has submitted the DPR as HT, Further, prepared by Madras on 22.08.2021.

been addressed by this office to the unit has submit the action plan with time Wistharged "Within "the" industry and exmoule the i rerradiation of contaminated site, | ander i the supervision of TNPCE. The fantire cost for the study and rarnediation shail be borne by the polluter pays lindustry 4@& per t arinadptie.

fask of iy thre unit ra

4. it is submitted that the unit M/s Thirumalai Chemicals Limited, SF No. 287, SIPCOT Industrial Complex, Ranipet, Nawock wllage, Walajah Taluk , Ranipet District (Vellore District} has submitted the DPR for remediation of contaminated site within. the premises vide its letter dt. 20.09.2021 so as te comply the Hon'ble NGT (Sz) order di. 15.03.2021. Based on that a letter was addressed hy JCEE (Mp, TNPCB, Vellore to the unit so as to furnish time schedule and action plan for the execution the sou remediation of contaminated site within its premises vide letter No. JCEE (Mj/F. O04 RL/NGTI O.A 131/Remediation/ 2021 Dated 23.09.2021.

24. Thereafter the matter was adjourned to consider the further report to be submitted by IIT Madras in respect of the efficacy of the system provided by th spondent and this Tribunal also directed the Sth responde "eomply with the directions oard and submit a ~ report. This Tri Board@to ascertain the same and oscompliance o fhe various wast BS S S & "Stherespondeé & ascertain as to whether the continuous online effluent monitoring system has been installed by the 8th respondent and also other similar units to ascertain the efficacy af licpaid waste Management System in that area in addition to installation of online continuous emission motitoering system to ascertain the ambient air quality and the efficacy of the air 72 pollution control mechanism. The Joint Committee was directed to conduct further inspection to ascertain these aspects.

96. Thereafter the matter was taken up on 27.01.2022. On that date this Tribunal considered the report submitted by the Tamul Nadu Pollution Control Board signed by the officer on 03.01.2022, e-filed on the same date in respect of the compliance and recommendations by the 8th respondent which reads as follows:

REPORT FILED ON BEHALF OF THE RESPONDENTS TAMIL NADU POLLUTION CONTROL BOARD. i. g. dosephine Sahayarani, Daughter of Jesu Rajan, Christian, aged about 57 years, having my office at No. 76, Mount Salai, Guindy, Chennai -600032, do hereby solemnly affirm anc sincerely state. as fallows:

4. 1 am the Joint Chief Environmental Engineer, Tami Nadu Pollution Comtro! Board, Chennai and | am filing thig Repart an behalf of the Responderits Board and as such lam well acquainted with the facts ofthe case as per records 2 it is reapectfully submitted that the Hion'ble NGT 52) in its arder dated 08.17.2027 has directed the Tamilnadu Pofution Cantrol Board fo submit Status Report and inter-alla as foliows:-

"Para 7 The report of ihe Tarnil Nadu Pollution Control Board also shows that some of the compliance reports were noted By therm on fhe basis of the statement made by the officials of tie Sth Respondent unit in OA. Ne 137"2@20. t appears thafiney Rave not inspected the int cfficaiy and aubautied ihe report without any analysis at their end. So, we direct the Tani Nadu Pollution Contral Board to inspect the unit in question in G.A No. ts 72020 again and Sie the status report and certify ihe adequacy af the systerrs provided and also ascertain the genuineness of ihe allegations made by ine apolicant in their reply dated

3. this respectfully sumnutted that with regard to the ohjectian filed by the applicant the following are submitted:- . ae} 73 girs i Obiections filed by.

the anpicant in OA.

No. 1381/2020

Remarks Submitted The applicant states whenever the untreated 'channel

-of the untreated effluents were jet out in the wat and On ~4 24.10.2021, | and villagers "had immediately contacted the Respondents, but none .fasponded. The opening up effluenis ohanneis Villagers nas anG road rocko on 24.70.2024 and affer which the paice officials came to the spot:

-and none of ihe Revenue Autherities oF the Tamilnadu Pollution Cantre! Board officials reached the » i that N AE ay $ there IS a rain, _ analysis | revealed ate satisfying the it ig submited that, ora al complaint was received from the public only 21 stating that on 25.1029 waste er water along with rain water is let cut through the drains from the unit Thirumalai Chemicals SIPCOT Complex, Ranipet, d by the on the same day of Mis.

Limited, industria! inspected and observed due to heavy downpour rain inside the unit behind the SBLATM point, which is located stagnation at south east corner of the uni was:

observed and reported by the unit that the rain water was discharged fhrough the existing opening orovided for rain water passing. A! sample was immediately collected iq the above spot by DEE, TNPCB, Vellore on 25.10.2027 and sent to Environmental TNPCB, Vellore for Capy of ROA is enclosed Advanced Laboratory, for reference (Annexure 1) and itis that all Board's standards.
Also the unit was instructed to empty the stagnated The unit was | TNPCB officials | water ine parameters 74 rain water in the above spot and. gent back to the ETP for further. trealment and disposal through the ; 7LO system. It was also instructed fo plug the above said opening. provided for rain water passing. The above instructions were a3 carried out by the unit and the verted inspection on 28.10.2021. There Same Was was no complaint received by the TNPCB officials on 24.70.2027. Hence the applicant stating that the TNPCB officials not inspected the site is not} frus, during | statement by the hh discharged 3 the Revenue : hoes.

| submit that, on the said:

'date , the police official, namely the -- deouty Superintendent of Police , Rainpet had collected the. untreated effluents and the same was sealed and handed over to Divisiona! sample of -- discharged untreated effluents were handed over to the Pollution Control Board officials .
Ranipet and « is.
is submitted that a sample of contaminated water was received on 25.70.2021 in the Advanced Environmental Laboratory, TNPCB, | Vellore stating that it was collected | on 24.10. 2021by DSP, Ranipet, The point of collection was not mentioned in ihe sample formal as collected by the DSP, Ranipet. The | TNPCBE officials communicated and present during | ihe callection of the above sample. Thus the collected sample by DSP, 24 102027 was handed over to TNPCB Lab on:
Ranipet on were not:
7S above sample revealed that the | parameters eB (5.2), TDS (2574 maf}, BOD (130 mali, COD (898 mg/l) were exceeded the Board's , standards. From the above ROA of waste water collected on: 24 U0 7024. it was observed thai there was possibility of contamination from the industry Wis TCL, Ranipet mixed with the | ' _ rain water on that day. The Capy of ROA is submitted herewifh as Annexure-{.

This applicant submits that, even affer tne matter taken

-up by the Hon'ble National rean Tribunal and after a eres of inspection by the " officials and Jorn Committee and even after levying penalty, the rescondent May Yul ov lirited, releasing the unt reated affluenis during tine of 'aining and at the subrt that, even during the road iy late midnights. | and none of the Revenue the sStagnatsd water ath i Thirumalat chemicals | easons or at the:

rocko, only the Police:
officials came to the spot it is submitted that, on receiving the public complaint on 25.10.2027, TNPCB officials immediately inspected the unit on the same day | and actions were taken to remove | inside the.
premises. It was also above said opening for rain water passing. The above instructions were Carried same owas verfied during inspection on 26.70.2021. Nence the statement of apolicant that TNPCB officials spat is not correct, The above unit not came fo the is being inspe as and when the problem is existed | > Instructed by :
the TNPCB officials to plug the out by the unit and the | cted by the TNPCB.
officials and collected the samples | 76 authorities or the officials of 'the foes Control Board came to the Tamiinadu Pollution spot or even not enquired | about the release of unvea said date.
ted effluent on the: and suitable action is taken by the Board.
Alter commissioning of upgraded ETP, adequacy. iest needs to be carried out by an independent govt. iresearch institution tke HT Madras and io certify that the unit as achieved 100 % ZLD: capacity, 'The 8° Respondent Unit has obtained report from the NT Madras | "which carried out the audit of the treaiment systems to access the capacity for 100% ZLD capacity. The liT report has recommended the icllowing:
i} Tre existing ZLD facility heed in M/S TCL is adequate to treat 800 KLD of wastewater, provided the plant is operated anc mainiained properly. i} The performance of the ETP significantly by optimizing the can be improved:
reactor sizes and properly Tae COD value of the treated water from | ETP Also, the activity of biomass in operating them.
';
is above 2000 mg/L. the system may be assessed. ii} The water mass balance of the system was salistactory, | within a permissibie error lirnit ivi There was an 8% discrepancy in the solid mass: balance. It may be due to the variation in fhe quality of: wastewater and intermittent storage, vy) The plant may avoid unnecessary storage facilities cyt TCL shail, in continuation iwith reputed institute such as IIT , Madras, prepare a DPR within three months-

me , for the remediation of it is submitted that IIT, Madras also. the 'Assessment of contamination level furnished roport oon at the yard area of TCL, Ranipet' and furnished its recommendations the land where the to the unit for remediation. It has to 'untreated = effluent was be carried out by the unit of M/s idischarged within the TCL, Ranipet.

industry site and execuis the task of remediation of contaminated site, under the supervision of TNPCE. . The entire cost for the.

study and remediation shall. be borne by the industry as | per polluter pays principe.

4. |t is respectfully subrnitted that, further the Hon'ble NGT in its order dated 08.11.2021 has directed inter alia as follows:

"Para 9: The Tamil Nadu Pollution Centro! Board is also directed ta verify the same and if such samples have been received by them, they are directed fo submit the report as fo whether the same has been tested 78 fruti in the allegations, what is the nature of sleps or action taken by fhe on this aspect.
Para 10; Further, the Tamil Nadu Pailution Control Board is aise directed fo file the report regarding the previous status of obtaining auinorization under ihe Hazardous and Qiher Waste Management (Transboundary and Movement) Rules, 2076 prior fo 17.02.2020 by the bth Respondent unit in O.A. No.131/2020 and if ne authorization was obtained by them, whal is the nature of action faken in this regard. Para 17: Further, the Tami! Nadu Pollution Contro! Board Is also direcied fo ascertain as to whether the continuous Online Effluent Monitoring System has been installed by the 8° respondent and other simular units fo ascertain efficacy of treatment of liquid wastes in that area in addition fo the requirement of installing Online Continuous Emission Monitoring System to ascertain the Ambient Air Quality and the efficacy of air pollution control mechanism."

5. lt is respectfully submitted that the sample collected on 24.16.2021 by the DSP, Ranipet was analysed by the Board's lab and the ROA reveals that the parameters TDS, BOD and COD are exceeding the standards prescrinad by the Board. The Cony of ROA is suomitied herewith as Annexure 1.

The report of analysis of staqnatec water sample collected by DEE, TNPCB, Vellore on 25.10.2021 reveals that the parameters TDS, BOD and COD are within the stancards prescribed by the Board. The Copy cf ROA is submitted herewith as Annexure UL. St kk was also instructed by the TNPCE officiais to plug the above said opening for rain water passing. The above instructions were carried out oy the unit and the same was verfied during inspection on 28.10.2027.

Again five number of samples taken in and around the unit of Mis Thirumalat Chemicals Limited, Ranipet on 14.11.2021 during rain, the ROA reveais that the parameter pH - 2 times, TSS - 1 time, BOD - 1 time, COD - 2 times were exceeded the standards prescribed by the Board. The Copy of ROA is submitted herewith as Annexure IIL.

6. It is respectfully submitted that in view of public complaint received through District Administration, the site was immediately inspected and fhree numbers of storm water drain samples were collected on 18.11.2021 by the DEE, TNPCB, Vellore in the presence of RDO, Ranipet and the ROA reveals that all the parameters are within ihe standards prescribed by the Board. The Copy of ROA is submitted herewith as Annexure lV.

7. tis respectfully submitted that based on the inspections carried out by the JCEE(M), TNPCB, Vellore on 09.11.2021, further directions under section 33(4)} of Water (P&CP) Act, 1974 was recommended and issued to the unit by the Board vide proc. db 20.11.2021 for compliance of the following conditions within 3 months time.

i. The unit shall restrict the number of discharge points connected with outlet drains to drain the excess rainwater in and around the unit.

i The unit shall install online continuous monitoring systems in the discharge points for the parameters TDS, TSS, PH, BOD, COD and other relevant parameters along with surveillance carnera and the same shall be connected te water quality watch of TNPCB and CPCB partal fer continuous monitoring.

ii. The unit shall reuse the entire treated effluent (RO permeate and MEE condensate} in their process continuously and to ensure TOO% ZLD.

wv. The unit shall not discharge any treated/untreated effluent < outside the prelvises and shall not be stagnated/ponding of "water under any circumstances.

7. it is respectfully submitted that the unit of M/s Thirumala:

Chernicals Limited had obtained Authorization under Hazardous Waste (MH & TS) Rules, 2608 vide proc. dated: 16.10.2014, valid for five years up te 15.70.2019.

8 H is respectfully submitted that the unit has instalied Electro Magnetic Flow Meters at 17 points of ZLD system and all the EMFM hawe been connected to the Water Quality watch Centre, TNPCB, Chennai. The urit has also provided Online Continuous Emission Monitoring System at four stacks and the same is connected to the Care Air Centre, TNPCER, Chennai.

Since the unit combleted its upuradation works of Z@LD system and UT, Madras has certified the adequacy of the 100% 2LD system provided by the unit, TNPCB has issued renewal of consent orders | under Water and Afr Acts vide pros. dt. 29.44.2021 with valicity for the period up to 34.03.2022 The Unit has obtained authorisation uncer HOWM Rules 2076, vide proceeding dated -11.02.2020 with validity upto 10.02.2025.

Linder the above circumstances, i is humbly prayed that this Hopmite National Green Tribunal (Southern Zone} may be pleased to om &t-and proper in this ease and thus pass. such order as it may dee VRE render justice. ENRON CMEMASA Be BEFORE ME 81

27. The Joint Committee also filed a report in this case dated 13.12.2021, e-filed om the same date which was extracted in Para 4 of the order which reads as follows:

OBSERVATIONS OF THE JOINT COMMITTEE (APPOINTED IN OA NO. 131 OF 2020) ON THE ALLEGATIONS MENTIONED BY THE APPLICANT IN THEIR REPLY DATED 05-11-2021.
1. Background The Hon'ble NGT, in Original Application Ne. 131 of 2020 (SZ) in the matter of M. Jayachandran, Ranipet District and Anr. Vs The Ministry of Rnvironment, Forest & Climate Change and Ors, vide tts order dated 08-1 {-

9001 directed to Joint Conmmtittee to ascertain as to whether the allegations mentioned by the applicant in O.A. No.131/2020 in their reply are genuine or not.

The allegation mentioned by the applicant in O.A, No. §91/2020 in ther reply 05.11.2021] pertains to releasing of untreated effluents by the ge Respondent, M/s Thiramatai Chemicals Ltd, SIPCOT, Ranipet on 34-10-2621 and 29-10-2021 at the time of raining/rainy season through rain water channel in indiscriminate way, The applicant further complained that the 8% Respondent had failed to comply with the Joint Commuittee's recommendations related to (i) Conducting adequacy test from IT Madras and obtaining certification that the unit has achieved 100% ZLD capacity alter commissioning of upgraded ETP and (8) Preparation of DPR through LT, M adras for the remediation of the land where the untreated effluent was discharged within the industry site and execution of the task of remediation of contaminated site, under the supervision of TNECB, 4 Joint Committee's visit in order to ascertain the allegations of the applicant and review the compliance status of the recor endations that are 'Partially Complied' or the 'Compliance is under progress', the Joint Conunittee had briefing meeting at the office of RDO, Ranipet and carried out a site visit at Stk Respondent Unit on 01-12-2021. The following comunittee members attended the site visit and ceviewed the comphance stafus:

82
1. R. Rajkumar suena 'TY CPCB, Regional Directorate, Chennai 9, | Smt. R. Poonkodi RDO, Ranipet y Gy MokF&CC, Chennai
3. (Rr M fuithaty fa SE.WRD, Pennaivar Basin Circle, Tiruvannamalai
4. Shric, Ravichandran -
DEE, TNPCB, Vellore
5. | Dr, R. Sridhar Scientist 'D', Integrated Regional Office (IRO}, 3, Joint Committee's observation Committee's observation on the allegations mentioned by the applicant related to releasing of untreated effluents by the 8 tb Respondent Unit and compliance status of recommendations giver in the following tabie:
No.131/2020 in ther reply

05.11.2021 pertains to releasing of untreated effluents by the 88 Respondent, M/s SIPCOT, Ranipel un 24-10- 9021 and 29-10-2021 at the time of raiiing/rainy season thr uh rain water channel in indiscriminate way Thiramalai Chemicals Ltd, | 2021 No, | Issues 'Joint Committee's observation _ l | The allegation ment ioned by The Committee noted that the water | the applicant in O.A,: samples collected on 24-10-2021 by Ranipet DSP office! and further on 95-10-2021 and 11-11-2021 (by TNPCS} were analysed and the test reports produced for Comnnittes's The reparis are enclosed af Ammesure-J, The fest ivformation.

were discussed he Conmittee.

reporls by From the analysis of water sample collected on 24-10-2021, 25-10 and Li-L1-2021 it observed that that th re effluent of the | industry was mixed with the rain water.

SUS Was | he Comunittce has gone furthest in this analysis. During inspection field on 1-12-2021, the. Commitee water san} ales from the Stagnated water the sife alsa catlected 'e Maleic Acid prese is observed at one » tocation | in the inside the premises of the industry and got analyzed through the external and third-party laboratory (M/s Glens Laboratory, EPA approved). The analysis results are given in the following Table Not. As per this analysis, the stagnated water samples collected inside the premises were showing the characteristic of the -- effluent _ generating from industry.

e TDS is ranging from 2500 to 19984 mg/l, total hardness tA Total Alcalinity ranging from O21 from SL? to 7634 mg/l indicates the untreated effluent characteristics of -- Inorgamic stream.

stagnated water collected near from 8.93 to 296.32 which This might be due to the fact that untreated effluent was discharged on | the land inside the industry | preniises.

at the location (Lreated effluent drain, was " alyzed and it was okwerved that sample is showing the characteristics of untreated effluent. This farther confirms that untreated effluent is stored in the industry | premises without following proper ranging from 210 to 1050 mg/l:

to 2654 mg/l, Chloride ranging :
e 16.81 me/l) ATED and Phthalic Acid ranges | indicates the effhient | characteristics of ss process elfluent.
Also, the samples which are collected storage tank}, near he stor water | saa B4 effluent management in the industry premises, The above observation clearly indicates the gross violation of industry in spite of having ZLD system for effluent management. 2 The unit was directed by | The unit has provided ZLD system TNPCB to restrict the | and adequacy of the same is also production of 50 % of its | carried out by IFT, Chennai.

consented quantity se as to achieve 2ero liquid| The 8® Respondent unit has discharge consistently il | obtained CTO from TNPCB vide letter ithe commencement &j| dated 29-11-2021 which is valid up. effective. functioning of | to 31st March 2022. newly constructed Zero Liquid Discharge (2LD) components.

3 Conducting adequacy test. Complied.

from HT Madras and abtaining certification that the unit has achieved 100% ZLD capacity after

-cornmissioning of upgraded ETP.

The 8 Respondent Unit has obtained report from the IIT Madras which carried out the audit of the treatment systems to access the capacity for 100% ZLD capacity.

The IIT report has recommended the following:

1} 'The existing ZLD facility in M/s TCL is adequate to treat 600 KLD of wastewater, provided the plant is operated and maintamed properly.
2) The performance of the ETP can be improved significantly by optimizing the reactor sizes and properly operating them. The CQD | value of the treated water from ETP 'is above 2000 mg/L. Also, the 85 activity of biomass in the system may | be assessed.
3) 'The water mass balance of the | system was satisfactory, within 3 permissible error lumnt
4) There was an 8% discrepancy in the solid mass balance. It inay be due to the variation in the quality of wastewater and intermittent storage.
5) The plant may avoid.

unnecessary storage facilities Copy af the report of the IT Madras:

filed "Status Environmental Audit of Thtrurmalat report GH Chemicals Ltd, Ranipet" is enclosed af Annexure-II.
Preparation of DPR through HT, Madras for the remediation of the land where the untreated efizent 'was discharged within the industry site and execution of the task of remediation of contaminated site, under the supervision of TNPCE Compiled, The DPR has been prepared by HT Madras for remediation of the land where the untreated efflueni was discharged within the industry site (Annexure-II]).
The Report was submitted to TNPC Board on 20.09.2021, As suggested by the TNPCB vide letter dated 25-9- | 2001, the 8 Respondent Unit has submitted the action plan with time schedule for execution of the work by the unit te the TNPCR. The contaminated site is heing developed a green park with trees, shrubs and BG Table No.1: Analysis results of the samples collected by the Joint Committee Parameters Stagnated Sample near | ATFD Stagnated Sample near i ETP {at storm water discharge point) Stagnated | : Sample finside premises near ATM) Treated Effluent Storage tank "T9984 982 "F800 Spey a i Q st a 73445 . Colour Yellow Yellow Yellow Cena [Nsagreeable | Ag Disagreeahie | Turbidity 3 164 78 S12 Total 1050 210 672 189 | Hardness :
Total 2267 2604 a2] 4516 Algalinily CHorideas = 7604 1226 Si 23903 cl BOD 183 79 87 3586 cop Ogg 353 369 1350 1372.9 214 528 359.5 Nivareas 100.5 4g BOL 230 -_ NOS DL: LDS Suki as 8085 S365 » 895 4900 Ne : Potagsnim 210 33 66 ae Total 20] 80 21,5 {36 Cae Oe O18 G55 148 BDL BLD 0.93 a BLOO BESO.

ne O,O18 BLO B.082 en HOQ:0,009) jO,8) BLO BLO : BLO (LOD: 1.03 COOL Good. | . a ke _ & - --

'Pumeric Ackl BLO BLO | BLO BLO (LO0:1.0} (LOC 1.0) LOL) ILO. 1.0) 'Phthalic Acid 396.22 50.39 | 8.93 326.34 a7 4, Directions issued by TNPCB:

"be Conmmittee noted that the TNPCB, vide letter dated 20-11-2021 (Annexure-IV}, has issued certain directions to the 8% Respondent Unit for the above violations which are extracted below:
(i) The unit shall restrict the number of water discharge points connected with outlet drains to drain the excess rain water in and around the above wit.

(ij} The unit shall install online continuous monitoring systems in consultation with JCEE (Mj, VLR in the discharge points for the sarameters such as TDS, TSS, P! BOD, COD and other relevant parameters along with surveillance camera and it shall be connected with WOW of TNPCB and CPCB web portal for continuous monitoring.

(iii) The unit shall rease the entire treated trade effluents (RO permeate and MEE Condensate) in their process continuously and to ensure {00% 2LD, fv) The unit shall not discharge any treated / untreated effluent outside the premises and shall not be stagnated /ponding of water under any circumstances.

5. Conclusion/Suggestions:

» The unit has complied with the earlier directions issued by TNPCB. ¢ As directed by the Hon'ble Tribunal to verily the allegation made by the applicant, the Joint Committee observed that water samples collected by the TNPCB & Joint Coninittee from the industry site, shows the efftuent characteristics, which might be due to the fact that effluent was discharged on the land inside the industry premises by vielating the consent condition in spite of having ZLD system. The unit has to comply with the above directions issued by the TNPCB vide letter dt 20-11- 2021, in view of the above, itis praved by the Joint Committee that the TNPCB shall take necessary action on the repeated viclations by the 8th Respondent Unit and periodically review the Urnt to camply with the directions issued. The eperation of the unil shall not attract repeated complaints. By considering the above facts and observation of the Joint Committee, the Hon'ble Tribunal may pass appropriate Order |s}/Direction {s) as deemed fit.
88
28. This Tribunal also placed on record the affidavit filed by the 8th respondent dated 08.12.2021 regarding the steps taken by them for the study to be conducted by the IIT Madras. They also produced the report submitted by Vellore Institute of Technology in respect of hydrological study. Since, this Tribunal felt that there is no necessity to try this case along O.A. No. 186 of 2020 as it relates a jarger issue of chromium contamination site remediatio is Tribunal decided to de-link y and accordingly this case this case and try the same sepa was de-linked from O.A. ,No 186 of 2020 by order dated I BR. Naresh ageassa it g the Sth Respondent, having > at ThirumalaiGkemicals Limited, 25-A, SIPCOT Industrial Complex, Ranipet, Tamil Nadu ~ 632 403, do hereby solemnly affirm and sincerely state as follows:
1. f am the Pactory Manager of the 8th Respondent (the "Answering Respondent') and as such well acquainted with the facts of the-case and competent to swear to the present Affidavit.

The instant Affidavit is being filed in compliance with the direction issued by this Hon'ble Tribunal in tts arder dated 27.01.2022, directing the Answering Respondent to comply with the following:

"10. The 8 Respondent is also directed to file a detailed report regarding the installation of Online Monitoring of Industrial Emission and Effluent System (OCEMS) as observed by the Pollution Control Board in their report."

In compliance with the above, the Answering Respondent submits as follows.

89

The Answering Respondent submits that i was one of frontrunners in operationalisiig the system of continuous online monitoring and had its system in place as far back as 2016 and has the capacity to monitor both emissions as well as effluents. Thereafter, the Answering Respondent was directed! enhance the functioning of its "Ondine Monitoring of Industrial Emission and Effluent Systems" ((OCEMS) by the Tamil Nadu Pollution Control Board, in its order dated 20.11.2021 vide Proc No. T5AINPCB/ F.O892/ VLRARLS W/ 202 1.

In prompt compliance of the same, the Answering Respondent has upgraded its OCEMS and the same has been cortmunicated to the Tamil Nadu Pollution Control Board as well. In fact, the 7 aml Nadu Pollution Control Board has rightly observed that the OCEMS has been duly operationalised by the 8th Respondent m7. its Report dated 03.01.2022, Houing planer:

"8. It is respectfully submitle heswnit has installed Electro Magnetic Flour Melers ats. EMPM Rave been carnectea, TNPCB, Chennai The unit ht Emission Monitoring Systernt connected to the Care Air Cen The AnsweringsResponde? 4 sarevided for pH and TDSyneters at the two raviwater 'outlets iL USs ises and '€ he. same to.the Care Air Cen. i Soard to enable provided Online Continuous al four stacks and the same is TNPCR, Chennai."

ng Respondent has also set up camera' 's in the premises and the video feed fron i to the Care Air Center for live mo ° feed as at ii) with this Affidatt.

lav filed along os cote ae ar . nae anes muntared ie Plu tet

8. The dow meter readings of 1? flow meters of the Zero Ligual Duscharge Systent aud pH, TiS of fe Rain Water Outlets (2 Nes} is aise _ ~ © a a cosected oniine to die Walter Quality \Vvatels Ceiire aid is beige sionite recdbon aid X 7 desis.

90

davit on record & itdft the facis andse

30. This Tribunal.

Ve sos << ; bs : j * Ces : 7 Tamil Nacu Pollution Sentrol Board Ss 08.03.2022, e-filed on 09.03.2022 extracted in Para 4 of the order which reads as follows:

"PEPORT FILED ON BEHALF OF THE STH & 6TH RESPONDENTS TAMIL NADU POLLUTION CONTROL BOARD. L J. Josephine Sahayarani, Daughter of Jesu Rajan , Christian, aged about 56 years, having office at No.76, Mount Saiai, Guindy, Chennai-600 032, do hereby solemnly affirm and siicerely state as follows:
3. TP aan the Joint Chief Environmental Engineer, Tamil Nadu Pollution Control Board, Chennai and I am filing this Report on behalf of the Sth & 6th Respondents Board and as such Lam well acquainted with the facts of ihe case as per records.

Oh

2. It is further submitted that the Hon'ble NGT (SZj, Chennai has passed common order dated 27.01.2022 and directed as follows:

"The Tamil Nadu Pollution Control Board is directed to consider the counter affidavit filed by the 8th Respondent to the Jomt Committee report filed on 13.12.2021 and submit their views on the same. As regards the installation of Online Monitoring of Inclustrial Emission and Effluent System (OCEMS) ts concerned, they are directed to file the further report regarding the same. They are also directed to furnish the reasons for non- establishment of OCEMS earlier and report the compensation levied for the violation".

3. It is respectfully submitted that in pursuance to the said NGT order, the respondent unit of M/s. Tirumalat Chenicals Limited, Ranipet was inspected on 15.02.2022. During inspection it was found that the unit has already'installed Electro Magnetic Flow Meters at 17 points of ZLD: system and. all the EMEM have been connected to the Water Ot Tentre, TNPCB, Chennai. The unit has also pre ne Continuous Emission Monitoring System at four stt the same is connected to the Care Air Centre, TNPCB, Cheniat Now the unit has installed.énline continuous monitoring systems in the dischaggespoints for the parameters pH ants along with surveilagce Seamera and 'thes sames were conn ied go water Svatch of $NPCB portalon.10,02.2022, per fhe d by TNPCB The unit has sealed one of the discharge points located adjacent to the SBI ATM near the Service Road.

The unit has restricted the two number of discharge points connected with outlet drains to drain the excess rainwater in and around the unit (North East-Ponnal Directions Issue _.

The unit shail restrict the number of discharge points connected wih outlet drains to drain ihe excess rainwater in and around the unit.

The unit shall install online continuous monitoring systems in the discharge points for ihe parameters TDS, TSS, PH, BOD, cop and other relevant parameters along with surveillance camera and the same shall be connected to water quality watch of TNPCB and CPCB portal far} continuous monitoring.

Road and South West-NH) 'The unit has installed online continuous monitoring systems in the discharge points for the parameters pH and TDS along with surveillance camera and the same were cannected to water quality watch of TNPCB sorta! on 10.02.2022 The unit shall reuse the entire treated effluent (RO permeate and | MEE condensate) in their process continuously and to ensure 100% ZLD.

y i . During All the components of ETP, RO, MEE and ATFD are under operations. No bye- pass of effluent from the treatment system noticed.

inspection the industry has recovered and stored saits within the unit premises.

92

'The unit shall nob discharge any | All ihe components of ETP" RO, MEE™ eated/untreated effluent outside | and ATFD are under operations, the premises and shall not be | stagnated/ponding of water under! RC permeate and Multiple Effect any circumstances. 'Evaporator (MEE) condensate uthize for the process.

com : RO reject is sert to MEE folaved by LATE Dt to recover sai, 'No discharge of any treated/untreated efuent outside the premises and no agnated/ponding of water within the rersises rmaticed..

Under the above circumstances, it is humbly prayed that this Hon'ble National Green. Tribunal (Southern Zone} may be pleased to pass such order as it may.de it.and proper in this case ancl thus render justice."

31. This Tribunal directed the du Pollution Control Board to file a report as to wheth cer < 8 whether it has been ay has bee

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peers oh ag PAG, ro remit differential fee | Congplred Page 82 Can e af imereage in consent fSes Yolunie cifically page 215 48 to be jrstalled te check 1 Comptied Page 3N1-3 and eo flere . Comrenienne Vobsnes - COUNSEL FOR REAPONDENT NOS a F 4 : : & ot REPORT FILED ON BEHALF OF THE 5" & 6°" RESPONDENTS TAMIL NADU POLLUTION CONTROL BOARD. i, R. Rajamanickarn, Son of P.M. Ramasamy , Hindu, aged about S? years, having office at No.76, Mount Salai, Guindy, Chennap-s6o0 O32, doa hereby solernriy affirm and sincerely state as. folows:-
4. i am the Joint Chief Environmental Engineer. Tarnl Nadu Poltutian Cantrol Soard, Chennai and { am Sling this Report on behalf of the gh a Bh Sesnondents Board and as such iam wel acquainted wilh the facts of the case per records.
2. {tis further submitted that the Hon'ble NGT (SZ), Chennai has passed cummon order dated 69.03.2022 and directed as follows:
"Para 5. The state pollution. contral board has nat answered fhe issue as to wheiner any compensation has been imposed and coliected or nat as observed by the Thbunal in the earlier order Sased on the reunarks of the Sub collector Para 6 : Fhey are directect fo fie a further report in this regard to ihis Tribunal on or before 29.93.2022"

4. ft ig respectfully submitted that, the unit has camplied the directions issued by the Board vide rec. dated.20,11.2021 aleng with providing of Online Ceantinuous Effluent Monitoring Systern (OCEMS) for pH and TOS along with oF surveillance camera and the online connectivity made by the unit with Care Air Centre, TNPCB, for direction No.2 and the compliance stalus on OCEMS was alsa submited to the Hon'ble NGT (SZ) on behalf of TNPCB under the "Report filed on behalf of Tamil Nadu Pollution Control Board" signed by the officer an 03.04.2022. and there was no direction issued in earlier stage to provide OCEMS in the discharge points as said above. The direction in this regard was issued to the unit vide Board's Proceeding dated 20.11.2021 only and there was ho Environmental Compensation imposed and levied in this regard by the Board. But in earlier stage, the Board has imposed an Environmental Compensation to the unil for nen compliance of consent order conditions issued fo the unit and issued certain directions along with imposing environmental cornpensation of Rs.18.8 Lakhs vide Board's Proceeding No. TS/TNPCBYF.O892/VLR/RLIZO19 dated 13.44.2019 and Rs. 17.40 Lakhs vide Board letter dated 08.01.2021 for repeated violation caused by the unil at that time and the unit also remitied the above environments! compensations to the TNFC8 at thai time, Under the above circumstances, it is humbly prayed that this Horrble National Green Tribunal (Southern Zone) may be pleased to pass such further or other orders as this Hon'ble Tribunal may deem fit and proper in the facts and circurnstances of this case and thus render justice.

BEFORE ME 34, The 8th respondent filed another compliance affidavit dated 18.02.2022, e-filed on 16.07.2022 which reads as follows:

4 Thindnals Yi Seveugee ode SETH. GG RR ttraee seeginly af Five gunk SHGECTY sfabo ae Eee pai st ily peste OE nensiciers Fat Cy AES wg.

og Palladian Cogival Boaed Tine aha a8 ret ape OAM eel she Pianit nach TRA nievanes Dinca Den CRS OES 3 Hae seas

35. The applicant filed their objections to the compliance report submitted by the 8th respondent where they have reiterated the earlier allegations made in the application. They have further mentioned that the compensation imposed is very less considering the fact that they are violators since long time and they are also not fully complied with the conditions.

100

36. The matter was heard on 12.07.2022. On that date due to inconvenience of the Learned Counsel appearing for the applicants as requested by the 2nd applicant who was present in court was permitted to submit the case represen ting his Learned Counsel and also considered the objections raised by them by way of reply. We also heard him and also the Learned Senior Counsel appearing for the 8th respondent and other respondents.

37, Considered the pleadings, var eports submitted including

--

See 2 = . ao. Sp ~ ; {pensation™ awarded by "t:

sufficiers imposed?
4. Relief and cost?
39. The applicant who appeared in person submitted that the 8th respondent is a continuous violator which is evident from the earlier proceedings initiated against them by the Sub-Collector and also by the Pollution Control Board. The Committee report will also go to show that they were discharging the untreated TOL effluent bypassing the effluent treatment plant into the storm water drain which affected the water quality in that area. So according to them, the environmental compensation imposed is not sufficient. Further even there are lot of violations of conditions imposed which results in pollution and the same will have to be monitored by the regulators continuously.

40, On the other hand, the Learned Senior Counsel appearing for the 8th respondent argued hat: in respect of the earlier ther litigations filed before uent to the action plan eK as a prepared arid a fomp liance of 1e those proceedings were Pollution Control Board was SS the same h d fe sr carried onttiby the 8th res A Kd pe recommenda ions ge by the Pollution Control Board later to act as an eco-friendly industry in order to discharge their commitments of protecting environment.

49. The Learned Counsel appearing for the Pollution Control Board submitted that earlier for violations and also continuous violations environmental compensation has been assessed and they have deposited the amount. The Conditions imposed were 102 complied with and they have camplied with the recommendations as well and as such the grievance of the applicant has been redressed. They will continuously monitor the activities of the 8th respondent and if there is any violation found, in future they will take appropriate action. The Learned Counsel appearing for the State Government also submitted in tune with the submissions made by the Learned Counsel for Tribunal had appointed a Joint Committee to go into the question and a Joint Committee had filed a report which was extracted in the earlier paragraphs and they have suggested certain recommendations to remedy the situation. If is also seer from the subsequent various reports filed by the Joint Committee as well as the Pollution Control Board that recommendations made by them were complied with and at present there is no discharge of untreated effluent into the water bodies. It may be further mentioned here that on earlier occasions the Tamil Nadu Pollution Control Board had imposed compensation of ks. 18,60,000/- by proceedings dated 13.09.2019 and subsequently, they imposed further compensation of Rs. 17,40,000/- by proceedings dated 08.11.2021 and both these amounts were deposited by the 8th respondent, So, we do notit is mecessary to impose any further compensation in this regarc Same were Pollution Control! Board had renewed the consent and it was also mentioned in the report that they were having all permissions and authorisation required under the various waste management rules and they are complying with the same. They have also provided the garland drains to collect their runoff water and that is also being treated through the treatment system provided and they are recycling the same for 104 their purposes and they are fulfilling the ZLD system that was also revarnped as directed by them and it was certified by the IIT Madras and it is on that basis they have issued the further renewal. So under such circumstances, as such there is no necessity to issue any further direction or compliance or further action to be taken against the 8 respondent unit at present. But at the same time in order to remove the apprehension of the applicants that there. isa possibility of pollution being caused and 8 respondent™is to repeat the violation, we direction x S feel that certain ans be given and with those pensation of Rs. l Control Board as directed by the Principal Bench and as such there is no necessity to impose further compensation in this regard.

ii. 8 respondent is directed not to discharge any untreated or treated effluent from their industry into the public drain and they must strictly adhere to the ZLD system and no 105 ii.

iv.

aan effluent or sewage from their property should reach the public drain which ultimately reaches the water bodies.

&h respondent is also directed to strictly adhere to the conditions imposed in the consent and clearance eranted and they are directed to strictly adhere to the environmental laws and norms provided for maintaining the pollution control mechanism, The Tamil Nadu Pollution Control Board is directed to 8m respondent unit especially during monsoon season and if there any ons imposed, then they are d . st m .

e SS st eiagure etc as coordance with law.

District Collector and Water Resource Department is also directed to monitor as to whether any of the industry in SIPCOT Industrial Estate, Ranipet imeluding the 8% respondent are discharging their wuntreated/treated effluent or sewage into the public drain and polluting the water bodies and if so they are also directed to take 106 appropriate action against those industries in accordance with law including initiating of proceedings, prosecution and proceedings under Section 133 of Code of Criminal Procedure in accordance with law.

The points are answered accordingly.

46.In the result the application is disposed of with following If.

Hi.

directions:

We do not think that there is any. necessity to impose any Solution Control Board had further compensation as. the already imposed compensatio. of Rs. 18,60,000/- and Rs. cipal' Bench and as such there is Ws, a ercompensation or sewage from their property should reach the public drain which ultimately reaches the water bodies. 8 respondent is also directed to strictly adhere to the conditions imposed in the consent and clearance granted and they are directed to strictly adhere to the environmental laws and norms provided for maintaining the pollution control mechanism.
107

TV.

VI.

VIL.

The Tamil Nadu Pollution Control Board is directed to monitor the functioning of the 8 respondent unit periodically especially during monseon season and if there is any violation found of any of the recommendations made by them earlier or by the Joint Committee and if found any illegal discharge of treated/ untreated effluent or sewage into the public drain or committed any violation of the conditions imposed, then they are. dire ed to take appropriate action against 8 respondent including imposition of Environmental itiating other proceedings of See S&S istrial Estate, Ranipet discharging"

appropriate with law inchiding initiating of prosecution and proceedings under Section 133 of Code of Criminal Procedure in accordance with law.
Considering the circumstances, parties are directed to bear their respective costs.
The Registry is directed to communicate this order to the. Tamil Nadu Pollution Control Board, District Collector, 108 Ranipet and Water Resource Department for their information and compliance of the directions.

47. With the above directions and observations, the application is disposed of.

(Justice K. Ramakrishnan) aM re a ee ee eo oe, + agopal Korlapati) (Dr. Saty O.A. No.l 29th July, es SE S = = St